Economic Analysis for the Final Lead and Copper Rule Revisions
Office of Water (4607M)
EPA 816-R-20-008
December 2020
Table of Contents
1	Introduction	1-1
1.1	Summary of the Final LCRR	1-3
1.2	Document Organization	1-12
1.3	Calculations and Citations	1-12
1.4	References	1-17
2	Need for the Rule	2-1
2.1	Statutory Requirements, Regulatory Actions and National EPA Initiatives Affecting Lead and Copper in Drinking Water	2-2
2.1.1	Safe Drinking Water Act (SDWA) Requirements and Drinking Water Regulations Addressing Lead Prior to 1991	2-2
2.1.2	Lead and Copper Rule (1991)	2-3
2.1.3	SDWA Amendments (1996)	2-4
2.1.4	Lead and Copper Rule Minor Revisions (2000)	2-4
2.1.5	2004 National Review of the LCR Leading up to the LCR Short-Term Revisions of 2007	2-4
<IP_ADDRESS>	Elements of the Comprehensive Review	2-5
<IP_ADDRESS>	Development of the Drinking Water Lead Reduction Plan and LCR Short-Term Revisions	2-7
2.1.6	Lead and Copper Rule Short-Term Revisions and Clarifications (2007)	2-7
2.1.7	Additional Actions to Reduce Lead in Plumbing Materials (2008-present)	2-8
2.2	Outreach, Consultation, Workgroup Activities, and Other Events Contributing to the Lead and Copper Rule Revisions	2-9
2.2.1	Stakeholder Meetings	2-9
2.2.2	Input from Small Business Stakeholders	2-10
2.2.3	Input from SAB and NDWAC	2-10
<IP_ADDRESS>	SAB Review	2-10
<IP_ADDRESS>	NDWAC Meetings	2-11
2.2.4	Consultation with Tribal Governments	2-12
2.2.5	Public Meeting on Environmental Justice	2-13
2.2.6	Consultation with State and Local Government Organizations	2-13
<IP_ADDRESS>	November 2011 Federalism Consultation	2-13
<IP_ADDRESS>	ASDWA Questionnaire to States on Possible LCRR Requirements	2-13
<IP_ADDRESS>	Questionnaire to States on LSL Inventory and Other LSL-Related Information	2-14
<IP_ADDRESS>	January 2018 Federalism Consultation	2-14
<IP_ADDRESS>	Meetings with ASDWA	2-14
2.2.7	Public Water Systems	2-15
<IP_ADDRESS>	Input from PWSs	2-15
2.2.8	EPA Letter to Governors and State Environment and Public Health Commissions and Tribal Leaders	2-16
2.2.9	Administrator's Meeting with States, PWS, and Non-Government Organizations	2-17
2.2.10	Public Comments on the Proposed LCRR	2-17
2.3	Statutory Authority for Promulgating the Rule	2-17
2.4	Economic Rationale	2-18
2.5	References	2-20
3	Regulatory Revisions	3-1
3.1	Introduction	3-1
3.2	Action Level, Trigger Level, and Small System Flexibilities	3-2
3.2.1	Additional Requirements Related to the Action Level and New Trigger Level	3-2
<IP_ADDRESS>	Previous Rule	3-2
<IP_ADDRESS>	Description of Final Regulatory Change	3-2
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-4
3.2.2	Small System Flexibilities	3-4
<IP_ADDRESS>	Previous Rule	3-4
<IP_ADDRESS>	Description of Final Regulatory Change	3-5
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-6
3.3	Lead and Copper Tap Sampling	3-7
3.3.1	Re-evaluation of Tap Sample Sites Based on LSL Inventory and Revised Tiering Criteria	3-9
<IP_ADDRESS>	Previous Rule	3-9
<IP_ADDRESS>	Description of Final Regulatory Change	3-10
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-12
3.3.2	Tap Sampling Collection Procedures	3-13
<IP_ADDRESS>	Previous Rule	3-13
<IP_ADDRESS>	Description of Final Regulatory Change	3-14
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-14
3.3.3	Sampling Frequency and Number of Samples Based on Lead 90[th] Percentile Level	3-16
<IP_ADDRESS>	Previous Rule	3-16
<IP_ADDRESS>	Description of Final Regulatory Change	3-16
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-21
3.4	Corrosion Control Treatment and Water Quality Parameter Monitoring	3-22
3.4.1	Regulated WQPs and Applicability	3-25
<IP_ADDRESS>	Previous Rule	3-25
<IP_ADDRESS>	Description of Final Regulatory Change	3-26
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-27
3.4.2	CCT Installation and Re-optimization Based on Lead 90[th] Percentile	3-27
<IP_ADDRESS>	Previous Rule	3-27
<IP_ADDRESS>	Description of Final Regulatory Change	3-28
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-31
3.4.3	Performance of Corrosion Control Treatment Study	3-32
<IP_ADDRESS>	Previous Rule	3-32
<IP_ADDRESS>	Description of Final Regulatory Change	3-33
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-34
3.4.4	Criteria for Reduced WQP Monitoring	3-35
<IP_ADDRESS>	Previous Rule	3-35
<IP_ADDRESS>	Description of Final Regulatory Change	3-36
<IP_ADDRESS>	Rationale for the Final Regulatory Change	3-37
3.4.5	Actions in Response to a Lead Tap Sample Result Exceeding 15 μg/L  -  "Find-and-Fix"	3-37
<IP_ADDRESS>	Previous Rule	3-37
<IP_ADDRESS>	Description of Final Regulatory Change	3-37
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-39
3.4.6	Review of CCT and WQPs During Sanitary Survey	3-39
<IP_ADDRESS>	Previous Rule	3-39
<IP_ADDRESS>	Description of Final Regulatory Change	3-40
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-40
3.5	Lead Service Line Inventory and Replacement	3-41
3.5.1	Develop Comprehensive Service Line Materials Inventory and LSLR Plan	3-43
<IP_ADDRESS>	Previous Rule	3-43
<IP_ADDRESS>	Description of Final Regulatory Change	3-44
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-45
3.5.2	Promote Full LSLR	3-47
<IP_ADDRESS>	Previous Rule	3-47
<IP_ADDRESS>	Description of Final Regulatory Change	3-48
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-52
3.5.3	LSL Notification and Targeted Outreach to LSL Consumers	3-56
<IP_ADDRESS>	Previous Rule	3-56
<IP_ADDRESS>	Description of Final Regulatory Change	3-56
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-56
3.6	Point-of-Use Treatment	3-57
3.6.1	POU Provision and Maintenance	3-58
<IP_ADDRESS>	Previous Rule	3-58
<IP_ADDRESS>	Description of Final Regulatory Change	3-58
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-59
3.7	Replacement of Lead-Bearing Plumbing Materials	3-60
3.7.1	Replacement of Lead-Bearing Plumbing Materials	3-61
<IP_ADDRESS>	Previous Rule	3-61
<IP_ADDRESS>	Description of Final Regulatory Change	3-61
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-62
3.8	Lead Public Education and Outreach	3-62
3.8.1	Lead PE and PN after an ALE	3-64
<IP_ADDRESS>	Previous Rule	3-64
<IP_ADDRESS>	Description of Final Regulatory Change	3-65
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-65
3.8.2	Additional Lead PE and Outreach	3-65
<IP_ADDRESS>	Previous Rule	3-65
<IP_ADDRESS>	Description of Final Regulatory Change	3-66
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-68
3.9	Change in Source or Treatment	3-71
3.9.1	Reporting a Change in Source or Treatment and Follow-up Actions	3-72
<IP_ADDRESS>	Previous Rule	3-72
<IP_ADDRESS>	Description of Final Regulatory Change	3-72
<IP_ADDRESS>	Rationale for Proposed Final Change	3-72
3.10	Source Water Monitoring and Treatment	3-73
3.10.1	Source Water Monitoring	3-74
<IP_ADDRESS>	Previous Rule	3-74
<IP_ADDRESS>	Description of Final Regulatory Change	3-74
<IP_ADDRESS>	Rationale for the Final Regulatory Change	3-75
3.11	Public Education and Sampling for Lead at Schools and Child Cares	3-75
3.11.1	Sampling for Lead in Schools and Child Cares	3-76
<IP_ADDRESS>	Previous Rule	3-76
<IP_ADDRESS>	Description of Final Regulatory Change	3-77
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-79
3.12	Other Rule Changes	3-81
3.12.1	Removal of Obsolete Dates	3-82
<IP_ADDRESS>	Previous Rule	3-82
<IP_ADDRESS>	Description of Final Regulatory Change	3-82
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-83
3.13	Primacy Agency Reporting and Recordkeeping Requirements and Special Primacy Conditions	3-83
3.13.1	Reporting Requirements	3-83
<IP_ADDRESS>	Previous Rule	3-83
<IP_ADDRESS>	Description of Final Regulatory Change	3-84
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-84
3.13.2	Record Keeping Requirements	3-84
<IP_ADDRESS>	Previous Rule	3-84
<IP_ADDRESS>	Description of Final Regulatory Change	3-85
<IP_ADDRESS>	Rationale for Final Regulatory Change	3-85
3.13.3	Special Primacy Requirements	3-86
3.14	References	3-87
4	Baseline Drinking Water System Characteristics	4-1
4.1	Introduction	4-1
4.2	Data Sources	4-1
4.2.1	SDWIS/Fed 2016	4-3
<IP_ADDRESS>	Classification of Systems Using SDWIS/Fed Data	4-3
<IP_ADDRESS>	Lead and Copper Rule-Specific Data	4-5
<IP_ADDRESS>	Treatment Facility Information	4-7
<IP_ADDRESS>	Verification of SDWIS/Fed Data	4-7
4.2.2	2006 Community Water System Survey	4-8
4.2.3	Geometries and Characteristics of Public Water Systems (2000)	4-9
4.2.4	AWWA 1988 Lead Information Survey	4-9
4.2.5	AWWA 2011 and 2013 Surveys of Lead Service Line Occurrence	4-10
4.2.6	Six-Year Review Data	4-11
4.2.7	State of Michigan Lead Compliance Monitoring Data	4-12
4.2.8	Data Sources for Schools, Child Cares, Local Health Agencies, and Targeted Medical Providers	4-13
<IP_ADDRESS>	Schools	4-13
<IP_ADDRESS>	Child Cares	4-14
<IP_ADDRESS>	Local Health Agencies and Targeted Medical Providers	4-14
4.3	Drinking Water System Baseline	4-14
4.3.1	Water System Inventory	4-15
<IP_ADDRESS>	Discussion of Data Limitations and Uncertainty	4-17
4.3.2	Population and Households Served	4-18
<IP_ADDRESS>	Discussion of Data Limitations and Uncertainty	4-20
4.3.3	Corrosion Control Treatment (CCT) Status	4-21
<IP_ADDRESS>	Discussion of Data Limitations and Uncertainty	4-25
4.3.4	LSL Inventory and Duration of Mandatory Replacement	4-25
<IP_ADDRESS>	LSL Inventory for CWSs	4-26
<IP_ADDRESS>	LSL Inventory for NTNCWSs	4-40
<IP_ADDRESS>	Duration of Mandatory Replacement	4-44
4.3.5	Lead and Copper Tap Levels	4-45
<IP_ADDRESS>	Percent of Systems with No TLE or ALE, a TLE, or ALE	4-46
<IP_ADDRESS>	Likelihood of an Individual Lead Sample Exceeding 15 ug/L	4-57
<IP_ADDRESS>	Systems with Copper Only ALEs	4-60
4.3.6	Treatment Plant Characterization	4-63
<IP_ADDRESS>	Discussion of Data Limitations and Uncertainties	4-63
4.3.7	Lead and Copper Tap and WQP Monitoring Schedules	4-64
<IP_ADDRESS>	Lead and Copper Tap Monitoring	4-64
<IP_ADDRESS>	Water Quality Parameter Monitoring	4-71
4.3.8	Source and Treatment Changes	4-78
<IP_ADDRESS>	Source Change	4-79
<IP_ADDRESS>	Primary Source Change	4-81
<IP_ADDRESS>	Treatment Change	4-82
4.3.9	Schools, Child Cares, Local Health Departments, and Targeted Medical Providers	4-84
<IP_ADDRESS>	Estimated Number of Facilities	4-85
<IP_ADDRESS>	Estimated Percentage of States with Existing School and Child Care Testing Programs	4-90
4.3.10	Labor Rates	4-96
<IP_ADDRESS>	Public Water System Labor Rates	4-97
<IP_ADDRESS>	Primacy Agency Labor Rates	4-99
<IP_ADDRESS>	Discussion of Data Limitations and Uncertainty	4-100
4.4	Uncertainties in the Baseline and Compliance Characteristics of Systems	4-100
4.5	References	4-104
5	Economic Impact and Cost Analysis of the Final Lead and Copper Rule Revisions	5-1
5.1	Introduction	5-1
5.1.1	Summary of Rule Costs	5-1
5.1.2	Overview of the Chapter	5-4
5.2	Cost Modeling Method	5-4
5.2.1	Overview of the SafeWater LCR Model	5-4
5.2.2	History of SafeWater Model Development	5-5
5.2.3	Development of SafeWater CBX	5-6
<IP_ADDRESS>	Modeling PWS Variability in SafeWater CBX	5-6
<IP_ADDRESS>	Modeling Uncertainty in SafeWater CBX	5-7
<IP_ADDRESS>	External Peer Review of SafeWater CBX	5-8
5.2.4	Overview of SafeWater LCR	5-8
<IP_ADDRESS>	Modeling PWS Variability in the SafeWater LCR Model	5-9
<IP_ADDRESS>	Modeling Uncertainty in the SafeWater LCR Model	5-9
<IP_ADDRESS>	Model PWSs, Large Systems, Discounting, Compliance Schedule, and Simulating Compliance Activities	5-15
5.3	Estimating Public Water System Costs	5-19
5.3.1	PWS Implementation and Administrative Costs	5-24
<IP_ADDRESS>	PWS One-Time Implementation and Administrative Costs	5-24
<IP_ADDRESS>	Estimate of PWS National Implementation and Administrative Costs	5-26
5.3.2	PWS Sampling Costs	5-27
<IP_ADDRESS>	PWS Lead Tap Sampling	5-27
<IP_ADDRESS>	PWS Lead Water Quality Parameter Monitoring	5-58
<IP_ADDRESS>	PWS Copper Water Quality Parameter Monitoring	5-81
<IP_ADDRESS>	PWS Source Water Monitoring	5-90
<IP_ADDRESS>	PWS School and Child Care Lead Sampling Costs	5-94
<IP_ADDRESS>	Estimate of PWS National Sampling Costs	5-135
5.3.3	PWS Corrosion Control Costs	5-137
<IP_ADDRESS>	CCT Installation	5-142
<IP_ADDRESS>	Re-optimization of Existing Corrosion Control Treatment	5-144
<IP_ADDRESS>	Find-and-Fix Costs	5-148
<IP_ADDRESS>	System Lead CCT Routine Costs	5-162
<IP_ADDRESS>	Estimate of PWS National Corrosion Control Treatment Costs	5-168
5.3.4	PWS Lead Service Line Inventory and Replacement Costs	5-171
<IP_ADDRESS>	Lead Service Line Inventory-Related Activities	5-173
<IP_ADDRESS>	LSLR Plan	5-181
<IP_ADDRESS>	Lead Service Line Replacements	5-182
<IP_ADDRESS>	Ancillary Lead Service Line Replacement Activities	5-188
<IP_ADDRESS>	Failure to Meet Goal-based Replacement Rate Activities	5-199
<IP_ADDRESS>	Estimate of national lead service line testing and replacement costs	5-205
5.3.5	PWS POU-Related Costs	5-208
<IP_ADDRESS>	POU Device Installation and Maintenance	5-208
<IP_ADDRESS>	POU Ancillary Activities	5-210
<IP_ADDRESS>	Estimate of PWS National Point-of-Use Device Installation and Maintenance Costs	5-221
5.3.6	PWS Lead Public Education and Outreach Costs	5-222
<IP_ADDRESS>	Consumer Notice in Response to a Lead Sample > 15 ug/L	5-222
<IP_ADDRESS>	Activities Regardless of Lead 90[th] Percentile Level	5-223
<IP_ADDRESS>	Public Education Activities in Response to Lead ALE	5-230
<IP_ADDRESS>	Estimate of National Lead Public Education and Outreach Costs	246
5.3.7	Summary of PWS Costs	246
<IP_ADDRESS>	PWS counts and population affected by rule components	246
<IP_ADDRESS>	National PWS Costs by System Category	249
<IP_ADDRESS>	Household Costs by CWS Size and Source Water Type	262
5.4	Estimating Primacy Agency Costs	267
5.4.1	Primacy Agency Implementation and Administrative Costs	270
<IP_ADDRESS>	Primacy Agency Start-up Implementation and Administrative Activities	270
<IP_ADDRESS>	Primacy Agency Annual Implementation and Administrative Activities	272
5.4.2	Primacy Agency Sampling Related Costs	275
<IP_ADDRESS>	Primacy Agency Lead Tap Sampling Costs	275
<IP_ADDRESS>	Primacy Agency Lead WQP Sampling Costs	5-285
<IP_ADDRESS>	Primacy Agency Copper WQP Monitoring Costs	5-286
<IP_ADDRESS>	Primacy Agency Source Water Monitoring Costs	5-288
<IP_ADDRESS>	Primacy Agency School Sampling Costs	5-290
5.4.3	Primacy Agency CCT Related Costs	5-292
<IP_ADDRESS>	Primacy Agency CCT Installation Costs	5-292
<IP_ADDRESS>	Primacy Agency CCT Re-optimization Costs	5-294
<IP_ADDRESS>	Primacy Agency Find-and-Fix Costs	5-296
<IP_ADDRESS>	Primacy Agency Lead CCT Routine Costs	5-297
5.4.4	Primacy Agency Lead Service Line Inventory and Replacement Related Costs	5-303
<IP_ADDRESS>	LSL Inventory Costs	5-304
<IP_ADDRESS>	LSLR Plan Costs	5-305
<IP_ADDRESS>	LSL Replacement Costs	5-306
5.4.5	Primacy Agency POU Related Costs	5-310
<IP_ADDRESS>	One-Time POU Program Costs	5-310
<IP_ADDRESS>	Ongoing POU Program Costs	5-312
5.4.6	Primacy Agency Public Education-Related Costs	5-315
<IP_ADDRESS>	Consumer Notice in Response to a Lead Sample > 15 ug/L	5-315
<IP_ADDRESS>	Activities Regardless of the Lead 90[th] Percentile Level	5-316
<IP_ADDRESS>	Public Education Activities in Response to Lead ALE	5-317
5.4.7	Summary of Primacy Agency Costs	5-320
5.5	Costs and Ecological Impacts Associated with Additional Phosphate Usage	5-321
5.5.1	Estimating the Costs of Increased Phosphorus Loadings	5-321
<IP_ADDRESS>	Incremental phosphorus loading to wastewater treatment plants	5-321
<IP_ADDRESS>	Incremental phosphorus removal costs at wastewater treatment plants	5-323
5.5.2	Ecological Impacts of Phosphorus Loadings	5-326
<IP_ADDRESS>	Incremental total phosphorus loadings in water bodies	5-326
<IP_ADDRESS>	Ecological impacts of potential increases in phosphate loadings	5-328
5.6	References	5-329
6	Benefits Resulting from the Lead and Copper Rule Revisions	6-1
6.1	Introduction	6-1
6.2	Baseline and Post-Rule Drinking Water Lead Exposures	6-2
6.2.1	Drinking Water Lead Concentration Profile Data	6-3
<IP_ADDRESS>	Lead Concentration Profiles	6-4
<IP_ADDRESS>	Data Cleaning	6-6
<IP_ADDRESS>	Coding	6-10
6.2.2	Drinking Water Lead Concentration Model Fitting and Selection	6-11
6.2.3	Simulated Drinking Water Lead Concentrations Based on Selected Model Fit	6-15
6.2.4	Determination of Point-of-Use Water Concentrations	6-18
6.2.5	Limitations of Baseline and Post-Rule Water Concentration Estimates	6-18
6.3	Assignment of Drinking Water Lead Tap Concentrations to PWS Populations	6-19
6.4	Quantification and Monetization of Children's Benefits from Reductions in Lead Drinking Water Concentrations	6-26
6.4.1	Methods for Estimating Blood Lead Levels in Children	6-26
<IP_ADDRESS>	SHEDS-Multimedia Modeling	6-26
<IP_ADDRESS>	IEUBK Model	6-28
<IP_ADDRESS>	Background Lead Exposure Inputs into SHEDS	6-30
<IP_ADDRESS>	Coupling of SHEDS-IEUBK	6-31
6.4.2	Estimates of Pre- and Post-Rule Blood Lead Levels in Children	6-34
6.4.3	Concentration-Response Functions for Lead and Changes in IQ	6-34
6.4.4	Valuation of Avoided IQ Loss	6-38
6.4.5	Implementation of Children's Benefit Calculations in the SafeWater LCR model	6-39
6.4.6	Monetized National Annual Children's Benefits	6-42
6.5	Quantification of Adult Blood Lead Levels	6-45
6.5.1	Methods for Estimating Blood Lead Levels in Adults	6-45
<IP_ADDRESS>	Adult Lead Methodology	6-46
<IP_ADDRESS>	Modified Adult Lead Methodology	6-46
6.5.2	Estimates of Pre- and Post-Rule Blood Lead Levels in Adults	6-48
6.6	Summary of Non-Quantified and Non-Monetized Benefits	6-50
6.7	References	6-52
7	Comparison of Costs to Benefits	7-1
7.1	Summary of the Incremental Costs of the Final LCRR	7-1
7.1.1	Monetized Incremental Costs	7-1
7.1.2	Non-monetized Costs	7-2
7.2	Summary of the Incremental Benefits of the final LCRR	7-2
7.2.1	Monetized Incremental Benefits	7-2
7.2.2	Non-monetized Benefits	7-4
7.3	Comparison of Incremental Costs to Incremental Benefits	7-6
7.4	References	7-7
8	Statutory and Administrative Requirements	8-1
8.1	Introduction	8-1
8.2	Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: Improving Regulation and Regulatory Review	8-2
8.3	Paperwork Reduction Act	8-3
8.3.1	Primacy Agency Activities	8-3
8.3.2	System Activities	8-4
8.4	The Final Regulatory Flexibility Analysis (FRFA)	8-6
8.4.1	Need for and Objectives of the Rule	8-6
8.4.2	Summary of SBAR Comments and Recommendations	8-6
8.4.3	Summary of the Proposed Rule and Public Comments on the Impacts to Small Entities	8-7
8.4.4	Number and Description of Small Entities Affected	8-8
8.4.5	Description of the Compliance Requirements of the Rule	8-8
8.4.6	Analysis of Alternative Small System Rule Requirements	8-8
<IP_ADDRESS>	Alternative Small System Flexibility Option	8-18
8.4.7	Determination of Final Small System Requirements under the LCRR	8-23
8.5	Unfunded Mandates Reform Act	8-24
8.6	Executive Order 13132: Federalism	8-27
8.7	Executive Order 13175: Consultation and Coordination with Indian Tribal Governments	8-28
8.8	Executive Order 13045: Protection of Children from Environmental Health and Safety Risks	8-29
8.9	Executive Order 13211: Actions That Significantly Affect Energy Supply, Distribution, or Use	8-30
8.9.1	Energy Supply	8-30
8.9.2	Energy Distribution	8-30
8.9.3	Energy Use	8-30
8.10	National Technology Transfer and Advancement Act	8-31
8.11	Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations	8-31
8.12	Consultations with the Science Advisory Board, National Drinking Water Advisory Council, and the Secretary of Health and Human Services	8-32
8.12.1	Consultation with Science Advisory Board	8-32
8.12.2	Consultation with National Drinking Water Advisory Council	8-33
<IP_ADDRESS>	2011 NDWAC Consultation	8-33
<IP_ADDRESS>	2013 NDWAC Consultation	8-34
<IP_ADDRESS>	2014  -  2015 NDWAC LCRWG Meetings	8-34
<IP_ADDRESS>	2019 NDWAC Consultation	8-35
8.12.3	Consultation with Health and Human Services	8-35
8.13	References	8-35
9	Other Options Considered	9-1
9.1	Introduction	9-1
9.2	Public Education and Sampling in Schools and Child Cares Option	9-2
9.3	Lead Tap Sampling Requirements for Systems with Lead Service Lines	9-5
9.3.1	Percent of Systems with No TLE or ALE, a TLE, and ALE Based on First Liter Option	9-6
9.3.2	Likelihood of individual lead tap samples being > 15 ug/L	9-8
9.3.3	Costs and Benefits Comparison	9-13
9.4	Reporting of LSL-Related Information	9-13
9.5	Small System Flexibility	9-17
9.6	References	9-18

List of Exhibits
Exhibit 1-1: Summary of Revisions to System Requirements under the Final LCRR	1-6
Exhibit 1-2: Supporting Report and Spreadsheet Files	1-13
Exhibit 3-1: Lead 90[th] Percentile Level Categories	3-2
Exhibit 3-2: Final LCRR Requirements Dependent on 90[th] Percentile Level[1]	3-2
Exhibit 3-3: Summary of Requirements for Small CWSs and All NTNCWSs that have a TLE/ALE by Compliance Option	3-5
Exhibit 3-4: Summary of Lead and Copper Tap Sampling Requirements under the Final LCRR	3-8
Exhibit 3-5: Previous Lead and Copper Site Selection Criteria	3-10
Exhibit 3-6: Revised Lead and Copper Site Selection Criteria under the Final Rule	3-11
Exhibit 3-7: Criteria for Increased and Reduced Tap Sample Monitoring	3-17
Exhibit 3-8: Criteria for Moving Lead 90[th] Percentile Categories under the Final Rule	3-19
Exhibit 3-9: Final LCRR Requirements that Must Be Completed or Continued if a System No Longer Exceeds the TL	3-20
Exhibit 3-10: Final LCRR Requirements that Must be Completed or Continued if a System No Longer Exceeds the Lead AL	3-21
Exhibit 3-11: Summary of CCT Requirements under the Final LCRR	3-23
Exhibit 3-12: WQP Monitoring Requirements under the Previous Rule	3-26
Exhibit 3-13: Additional CCT Step Requirements for Systems under the Final LCRR	3-28
Exhibit 3-14: Previous Rule Reduced WQP Tap Monitoring Criteria	3-35
Exhibit 3-15: Final Rule Revised Reduced WQP Tap Monitoring Criteria	3-36
Exhibit 3-16: Final Rule Minimum Number of WQP Tap Sites and Maximum Number of Additional Sites Added under Find-and-Fix	3-38
Exhibit 3-17: Summary of LSLR Requirements under the Final LCRR	3-42
Exhibit 3-18: Summary of the POU Alternative to CCT and LSLR under the Final LCRR	3-57
Exhibit 3-19: Summary of Replacement of Lead-Bearing Plumbing Materials Requirements under the Final LCRR	3-60
Exhibit 3-20: Summary of PE and Outreach Requirements under the Final LCRR	3-63
Exhibit 3-21: Summary of Requirements for Change in Source or Treatment under the Final LCRR	3-71
Exhibit 3-22: Summary of Source Water Monitoring under the Final LCRR	3-73
Exhibit 3-23: Summary of Lead in Drinking Water Sampling Program at Schools and Child Cares under the Final LCRR	3-76
Exhibit 3-24: Monitoring Program Details for Schools and Child Cares under the Final LCRR	3-77
Exhibit 3-25: Contents of Annual Report for CWSs PE and Sampling Programs in Schools and Child Cares under the Final LCRR	3-79
Exhibit 3-26: List of Obsolete Dates Removed from the Final LCRR	3-82
Exhibit 4-1: Data Sources Used to Develop the Baseline for the Final LCRR	4-2
Exhibit 4-2: Geographic Distribution of Responses to the 1988 AWWA LIS	4-10
Exhibit 4-3: Inventory of CWSs	4-15
Exhibit 4-4: Inventory of NTNCWSs	4-17
Exhibit 4-5: Population and Number of Households Served by CWSs	4-19
Exhibit 4-6: Population Served by NTNCWSs	4-20
Exhibit 4-7: Number of CWSs with and without CCT	4-23
Exhibit 4-8: Number of NTNCWS with and without CCT	4-24
Exhibit 4-9: LSL Estimates from the 1991 RIA	4-27
Exhibit 4-10: LSL Inventory Based on 1988 AWWA LIS (1991 RIA, Adjusted)	4-30
Exhibit 4-11: Estimated Systems with LSLs by CCT Status (1991 RIA: Adjusted)	4-33
Exhibit 4-12: Percent of water systems with lead service lines and number of LSLs per 1,000 persons for systems with LSLs from Cornwell et al. (2016)	4-35
Exhibit 4-13: LSL Inventory Based on 2011 and 2013 AWWA Surveys (Cornwell et al. 2016)	4-37
Exhibit 4-14: Estimated Systems with LSLs by CCT Status (Cornwell et al. 2016)	4-39
Exhibit 4-15: Summary of State Responses Regarding the Percentage of NTNCWSs with LSLs	4-41
Exhibit 4-16: Estimated Number and Percentage of NTNCWSs with LSLs by CCT Status	4-42
Exhibit 4-17: Number of LSLs in NTNCWSs with CCT by Size Category	4-43
Exhibit 4-18: Number of CWSs with LSL Determination Based on State, Tribal, and Web Data1	4-47
Exhibit 4-19: Percent of CWSs with No TLE or ALE, a TLE, and an ALE (Baseline Conditions)	4-49
Exhibit 4-20: Number and Percent of CWSs with No TLE or ALE, a TLE, and an ALE (Final LCRR)	4-52
Exhibit 4-21: Percent of CWSs with Known LSL Status to All CWSs by System Size	4-54
Exhibit 4-22: Comparison of P90 Data for CWSs with At Least One Reported Value to the Set of CWSs with Known LSL Status and P90 Data by Three P90 Ranges, System Size, and CCT Status (Percent) Using the Baseline/High Estimate	4-55
Exhibit 4-23: Number and Percent of CWSs with No TLE or ALE, a TLE, and ALE  -  Comparison of Results from Three Geographic Regions with Known LSL Status Using the Baseline/High Estimate	4-56
Exhibit 4-24: Percent of Individual Lead Sample Result Above 15 ug/L Based on Michigan CWSs with Known LSL Status for Final LCRR	4-59
Exhibit 4-25: Average Percent of CWSs that Had Any Copper Only ALE from 2012 - 2015	4-61
Exhibit 4-26: Average Percent of NTNCWSs that Had Any Copper Only ALE from 2012 - 2015	4-62
Exhibit 4-27: Criteria for Reduced and Increased Lead and Copper Tap Sampling under the Previous Rule	4-64
Exhibit 4-28: SDWIS/Fed Criteria Used to Estimate Lead Tap Sampling Monitoring Schedules	4-66
Exhibit 4-29: Estimated Percentage of CWSs with CCT on Various Lead Tap Monitoring Schedules by Size and Source Type	4-67
Exhibit 4-30: Estimated Percentage of CWSs without CCT on Various Lead Tap Monitoring Schedules by Size and Source Type	4-68
Exhibit 4-31: Estimated Percentage of NTNCWSs with CCT on Various Lead Monitoring Schedules by Size and Source Type	4-69
Exhibit 4-32: Estimated Percentage of NTNCWSs without CCT on Various Lead Tap Monitoring Schedules by Size and Source Type	4-69
Exhibit 4-33: Estimated Number and Percentage of CWSs with Reported Lead ALEs Only	4-70
Exhibit 4-34: Criteria for Reduced and Increased WQP Distribution System Monitoring	4-71
Exhibit 4-35: SDWIS/Fed Data and Criteria Used to Estimate WQP Distribution System Monitoring Schedules under the Previous Rule	4-72
Exhibit 4-36: Number of Ground Water CWSs with CCT on Various WQP Distribution System Monitoring Schedules (Previous Rule)	4-73
Exhibit 4-37: Number of Surface Water CWSs with CCT on Various WQP Distribution System Monitoring Schedules (Previous Rule)	4-74
Exhibit 4-38: Number of Ground Water NTNCWSs with CCT on Various WQP Distribution System Monitoring Schedules (Previous Rule)	4-74
Exhibit 4-39: Number of Surface Water NTNCWSs with CCT on Various WQP Distribution System Monitoring Schedules (Previous Rule)	4-75
Exhibit 4-40: Revised Reduced WQP Tap Monitoring Criteria under the Final LCRR	4-75
Exhibit 4-41: Number of Ground Water CWSs with CCT on Various WQP Distribution System Monitoring Schedules (Final Rule)	4-76
Exhibit 4-42: Number of Surface Water CWSs with CCT on Various WQP Distribution System Monitoring Schedules (Final Rule)	4-77
Exhibit 4-43: Number of Ground Water NTNCWSs with CCT on Various WQP Distribution System Monitoring Schedules (Final Rule)	4-77
Exhibit 4-44: Number of Surface Water NTNCWSs with CCT on Various WQP Distribution System Monitoring Schedules (Final Rule)	4-78
Exhibit 4-45: Change in Source Example Scenario	4-79
Exhibit 4-46: Estimated Percent of CWSs that Will Change Source Each Year	4-80
Exhibit 4-47: Estimated Percent of NTNCWS that Will Change Source Each Year	4-81
Exhibit 4-48: Estimated Percent of CWSs that Will Change Treatment Each Year	4-83
Exhibit 4-49. Estimated Percent of NTNCWSs that Will Change Treatment Each Year	4-84
Exhibit 4-50: Number of Schools and Child Cares by State and United States Territory, Adjusted to Remove NTNCWS Schools and Child Cares	4-86
Exhibit 4-51: Estimated Average Number of Local Health Agencies and Targeted Medical Providers per CWS	4-89
Exhibit 4-52: States Where CWSs Meet the Requirements for Mandatory Program Waivers at Schools	4-92
Exhibit 4-53: States Where CWSs Meet the Requirements for On Request Waivers at Schools	4-93
Exhibit 4-54: States Where CWSs Do Not Meet the Requirements for Waivers at Schools	4-93
Exhibit 4-55: States Where CWSs Meet the Requirements for Mandatory Program Waivers at Child Cares	4-94
Exhibit 4-56: States Where CWSs Meet the Requirements for On Request Waivers at Child Cares	4-95
Exhibit 4-57: States Where CWSs Do Not Meet the Requirements for Waivers at Child Cares	4-95
Exhibit 4-58: Comparison of Wage Rate Surveys	4-97
Exhibit 4-59: Hourly Labor Costs Including Wages Plus Benefits (2007$)	4-98
Exhibit 4-60: Weighted Labor Rates for CWSs and NTNCWSs (2016$)	4-99
Exhibit 4-61: Loaded Labor Rate for Primacy Agency Staff (2016$)	4-100
Exhibit 4-62: Summary of Uncertainties in the Baseline and Compliance Characteristics of Drinking Water Systems	4-101
Exhibit 5-1: National Annualized Rule Costs - All PWSs at 3 Percent Discount Rate (2016$)	5-2
Exhibit 5-2: National Annualized Rule Costs - All PWSs at 7 Percent Discount Rate (2016$)	5-3
Exhibit 5-3: Model PWS Approach Utilized by SafeWater CBX to Model PWS Variability	5-7
Exhibit 5-4: Percent of CWSs with CCT that have LSLs, Percent of CWSs without CCT that Have LSLs, and Percent of Connections that Are Lead in CWSs with LSLs under Low and High Cost Scenarios [1]	5-10
Exhibit 5-5: Likelihood of Initial Model PWS 90[th] Percentile Placement under Previous LCR	5-11
Exhibit 5-6: Likelihood of Initial Model PWS 90[th] Percentile Placement under Final LCRR	5-12
Exhibit 5-7: Low Cost Scenario Assumptions for CCT Effectiveness Likelihood of Change in Post CCT Installation or Re-optimization P90y+1 Range	5-13
Exhibit 5-8: High Cost Scenario Assumptions for CCT Effectiveness Likelihood of Change in Post CCT Installation or Re-optimization P90y+1 Range	5-13
Exhibit 5-9: LSLR Unit Costs for Low and High Cost Scenarios ($2016)	5-15
Exhibit 5-10: PWS Cost Components, Subcomponents, and Activities Organized by Section1	5-20
Exhibit 5-11: PWS One-Time Administration Activities and Unit Burden Estimates	5-25
Exhibit 5-12: PWS Administration and Rule Implementation Cost Estimation in SafeWater LCR by Activity	5-26
Exhibit 5-13: Minimum Number of Lead Tap Sampling Sites for Routine and Reduced Monitoring	5-28
Exhibit 5-14: PWS Lead Tap Sampling Unit Burden and Cost Estimates	5-28
Exhibit 5-15: CWS Burden to Achieve a Sampling Pool with 100 Percent Lead Service Line Sites	5-31
Exhibit 5-16: Non-Labor Costs for CWS without LSLs to Provide Test Kits (per Sample)	5-34
Exhibit 5-17: Non-Labor Costs for CWS with LSLs to Provide Test Kits (per Sample)	5-35
Exhibit 5-18: Travel Burden and Cost for Lead Tap Sample Pickup	5-36
Exhibit 5-19: Burden to Submit Lead Tap Sampling Results and 90[th] Percentile Level	5-39
Exhibit 5-20: PWS Lead Tap Sampling Cost Estimation in SafeWater LCR by Activity[1]	5-40
Exhibit 5-21: Baseline Percentage of Systems Modifying pH and/or Adding PO4	5-60
Exhibit 5-22: Normalized Baseline Percentage of Systems Modifying pH and/or Adding PO4	5-60
Exhibit 5-23: Minimum Number of WQP Distribution Samples for Systems on Routine or Reduced Monitoring	5-61
Exhibit 5-24: PWS Lead WQP Monitoring Unit Burden and Cost Estimates	5-62
Exhibit 5-25: CWS Material Costs Associated with Distribution System Sample Collection	5-64
Exhibit 5-26: NTNCWS Material Costs Associated with Distribution System Sample Collection	5-65
Exhibit 5-27: CWS In-House WQP Analytical Burden for Distribution System Samples (hrs/sample)	5-66
Exhibit 5-28: NTNCWS In-House WQP Analytical Burden for Distribution System Samples (hrs/sample)	5-66
Exhibit 5-29: CWS In-House WQP Analytical Cost for Distribution System Samples ($/sample)	5-67
Exhibit 5-30: NTNCWS In-House WQP Analytical Cost for Distribution System Samples ($/sample)	5-67
Exhibit 5-31: CWS Commercial WQP Analytical Cost for Distribution System Samples ($/sample)	5-68
Exhibit 5-32: NTNCWS Commercial WQP Analytical Cost for Distribution System Samples ($/sample)	5-68
Exhibit 5-33: CWS Material Costs Associated with Entry Point Sample Collection	5-69
Exhibit 5-34: NTNCWS Material Costs Associated with Entry Point Sample Collection	5-70
Exhibit 5-35: CWS In-House WQP Analytical Burden for Entry Point Samples (hrs/sample)	5-70
Exhibit 5-36: NTNCWS In-House WQP Analytical Burden for Entry Point Samples (hrs/sample)	5-70
Exhibit 5-37: CWS In-House WQP Analytical Cost for Entry Point Samples ($/sample)	5-71
Exhibit 5-38: NTNCWS In-House WQP Analytical Cost for Entry Point Samples ($/sample)	5-71
Exhibit 5-39: CWS Commercial WQP Analytical Cost for Entry Point Samples ($/sample)	5-71
Exhibit 5-40: NTNCWS Commercial WQP Analytical Cost for Entry Point Samples ($/sample)	5-72
Exhibit 5-41: PWS Lead WQP Monitoring Cost Estimation in SafeWater LCR by Activity[1]	5-73
Exhibit 5-42: Estimated Likelihood a CWS Will Have a Copper Only ALE	5-82
Exhibit 5-43: Estimated Likelihood a NTNCWS Will Have a Copper Only ALE	5-83
Exhibit 5-44: PWS Copper WQP Monitoring Unit Burden and Cost Estimates	5-83
Exhibit 5-45: PWS Copper WQP Monitoring Cost Estimation in SafeWater LCR by Activity[1]	5-85
Exhibit 5-46: PWS Source Monitoring Burden and Cost Estimates	5-91
Exhibit 5-47: PWS Source Water Monitoring Cost Estimation in SafeWater LCR by Activity[1]	5-93
Exhibit 5-48: CWS Elementary School and Child Care Sampling Unit Burden and Cost Estimates for the Mandatory Program Phase (Years 4 - 8)	5-95
Exhibit 5-49: PWS Mandatory School and Child Care Sampling Phase Cost Estimation in SafeWater LCR by Activity[1, 2]	5-101
Exhibit 5-50: PWS School and Child Care Sampling Unit Burden and Cost Estimates under the On Request Program 	5-117
Exhibit 5-51: PWS On Request School and Child Care Sampling Phase Cost Estimation in SafeWater LCR by Activity[1,2]	5-121
Exhibit 5-52: National Annualized Sampling Costs  -  All PWSs at 3 Percent Discount Rate (2016$)	5-134
Exhibit 5-53: National Annualized Sampling Costs  -  All PWSs at 7 Percent Discount Rate (2016$)	5-135
Exhibit 5-54: Distribution of Baseline Finished Water pH by Source Water Type and pH Adjustment Status	5-137
Exhibit 5-55: Distribution of Finished Water pH by Source Water Type for Model-PWSs without pH Adjustment in Place by CCT Status	5-138
Exhibit 5-56: Distribution of Finished Water pH by Source Water Type for Model-PWSs with pH Adjustment in Place by CCT Status	5-138
Exhibit 5-57: Derivation of Baseline PO4 Dose by System Size and LSL Status	5-140
Exhibit 5-58: Baseline PO4 Doses by System Size and LSL Status Used in Cost Modeling	5-140
Exhibit 5-59: PWS CCT Installation-Related Unit Burden and Cost Estimates	5-142
Exhibit 5-60: PWS Ancillary CCT Installation Cost Estimation in SafeWater LCR by Activity[1]	5-143
Exhibit 5-61: PWS CCT Ancillary Re-optimization Unit Burden and Cost Estimates	5-145
Exhibit 5-62: PWS CCT Ancillary Re-optimization Cost Estimation in SafeWater LCR by Activity[1]	5-146
Exhibit 5-63: Likelihood of an Individual Lead Sample Result Above 15 ug/L	5-147
Exhibit 5-64: PWS Burden and Cost to Flush as Find-and-Fix Response	5-148
Exhibit 5-65: PWS Ancillary Find-and-Fix Unit Burden and Cost Estimates	5-149
Exhibit 5-66: Burden (hours) for CWSs to Contact Customers and Collect Tap Samples for Locations with a Lead Tap Sample > 15 ug/L (hrs_samp_above_al_op)	5-151
Exhibit 5-67: Costs for CWSs to Contact Customers and Collect Tap Samples for Locations with a Lead Tap Sample > 15 ug/L (cost_samp_above_al)	5-152
Exhibit 5-68: Likelihood a CWS Will Add a WQP Sampling Site in Response to Find-and-Fix	5-153
Exhibit 5-69: PWS Burden to Conduct Distribution System Assessment	5-154
Exhibit 5-70: PWS Ancillary Find-and-Fix Cost Estimation in SafeWater LCR by Activity[1.2]	5-156
Exhibit 5-71: PWS CCT Routine Unit Burden and Cost Estimates	5-161
Exhibit 5-72: Estimated PWS Burden to Gather Data and Review CCT-Related Data during Sanitary Survey to Determine if CCT Is Still Optimized	5-162
Exhibit 5-73: Estimated Percent of Ground Water CWSs Achieving 4-log Virus Inactivation	5-162
Exhibit 5-74: Estimated Hours per System to Report and Consult on Source Water Change	5-164
Exhibit 5-75: Estimated Hours per System to Report and Consult on Treatment Change	5-165
Exhibit 5-76: PWS Lead CCT Routine Cost Estimation in SafeWater LCR by Activity[1]	5-165
Exhibit 5-77: National Annualized Corrosion Control Technology Costs  -  All PWSs at 3 Percent Discount Rate (2016$)	5-168
Exhibit 5-78: National Annualized Corrosion Control Technology Costs  -  All PWSs at 7 Percent Discount Rate (2016$)	5-169
Exhibit 5-79: PWS LSL Inventory-Related Unit Burden and Cost Estimates	5-172
Exhibit 5-80: One-Time Burden to Create LSL Inventory (hrs/system)	5-173
Exhibit 5-81: Estimated Likelihood that Systems with LSLs Completed Their Inventory In Advance of the Rule (p_inventory)	5-174
Exhibit 5-82: One-Time Burden to Submit Documentation of No LSLs and Request to Omit LSL-Specific Information in the CCR (hrs/system)	5-175
Exhibit 5-83: Estimated Likelihood that Systems without LSLs Completed Their Inventory In Advance of the Rule (p_inventory)	5-176
Exhibit 5-84: Annual Burden (per household) to Distribute General LSL Notification	5-177
Exhibit 5-85: Annual Cost (per household) to Distribute General LSL Notification	5-177
Exhibit 5-86: Lead Service Line Inventory Cost Estimation in SafeWater LCR by Activity[1]	5-179
Exhibit 5-87: PWS LSLR Plan Unit Burden and Cost Estimates	5-180
Exhibit 5-88: Estimated Burden for Systems with LSL to Develop an LSLR Plan	5-181
Exhibit 5-89: LSLR Plan Cost Estimation in SafeWater LCR by Activity[1]	5-181
Exhibit 5-90: PWS LSL Replacement Unit Cost Estimates	5-182
Exhibit 5-91: Estimated System Unit Costs for LSLR ($2016)	5-182
Exhibit 5-92: Likelihood of LSLR Type of Systems by Program	5-184
Exhibit 5-93: Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity[1]	5-186
Exhibit 5-94: PWS LSL Replacement Ancillary Unit Burden and Cost Estimates	5-187
Exhibit 5-95: PWS Burden to Conduct LSLR Study Including Financing Plan	5-188
Exhibit 5-96: Estimated Annual Burden (per household) to Distribute Targeted Outreach Materials about LSLR Program for CWSs with LSLs and a TLE that Serve > 10,000 People (hrs_dist_lslr_out_op)	5-190
Exhibit 5-97: Estimated Burden Associated with Contacting Customers and Site Visit Prior to LSLR (hrs/replaced LSL) (hrs_replaced_lsl_contact_op)	5-191
Exhibit 5-98: Estimated Costs Associated with Contacting Customers and Site Visit Prior to LSLR ($/replaced LSL) (cost_replaced_lsl_contact)	5-191
Exhibit 5-99: CWS Unit Burden to Collect Post-LSLR Tap Sample	5-193
Exhibit 5-100: CWS Unit Cost to Collect Post-LSLR Tap Sample	5-193
Exhibit 5-101: Lead Service Line Inventory Ancillary Cost Estimation in SafeWater LCR by Activity[1]	5-195
Exhibit 5-102: Failure to Meet Goal-based Replacement Rate Activities Unit Burden and Cost Estimates	5-198
Exhibit 5-103: Burden to Conduct Additional Outreach in Response to First Failure to Meet LSLR Goal (hrs/household)	5-200
Exhibit 5-104: Costs to Conduct Outreach in Response to First Failure to Meet LSLR Annual Goal ($/system)	5-201
Exhibit 5-105: Burden to Conduct Additional Outreach in Response to Subsequent Failure(s) to Meet LSLR Goal (hrs/system)	5-202
Exhibit 5-106: Cost to Conduct Additional Outreach in Response to Subsequent Failure(s) to Meet LSLR Goal (hrs/system)	5-202
Exhibit 5-107: Failure to Meet Goal-based Replacement Rate Activities Cost Estimation in SafeWater LCR by Activity[1,2]	5-203
Exhibit 5-108: National Annualized Lead Service Line Replacement Costs  -  All PWSs at 3 Percent Discount Rate	5-205
Exhibit 5-109: National Annualized Lead Service Line Replacement Costs  -  All PWSs at 7 Percent Discount Rate	5-206
Exhibit 5-110: Average Number of Households and POU Devices per CWS	5-207
Exhibit 5-111: Minimum and Maximum Estimated Number of Taps Requiring POU Devices per NTNCWS	5-208
Exhibit 5-112: Point-of-Use Device Installation and Maintenance Cost Estimation in SafeWater LCR by Activity[1]	5-209
Exhibit 5-113: PWS Ancillary POU-Related Burden and Cost Estimates[1]	5-210
Exhibit 5-114: CWS Burden to Develop a POU Plan (hrs/system)	5-212
Exhibit 5-115: NTNCWS Burden to Develop a POU Plan (hrs/system)	5-212
Exhibit 5-116: PWS Annual POU Program Report Preparation and Submission Burden	5-215
Exhibit 5-117: PWS Point-of-Use Ancillary Costing Estimation in SafeWater LCR by Activity[1, 2, 3]	5-216
Exhibit 5-118: PWS Burden for Consumer Notification When Sample is > 15 ug/L	5-221
Exhibit 5-119: PWS Burden and Cost for Public Education Activities that Are Independent of Lead 90[th] Percentile Levels	5-222
Exhibit 5-120: One-Time Burden (per CWS) to Develop Approach for Improved Access to Lead Information	5-224
Exhibit 5-121: Likelihood that a Resident Will Request Information about LSLs	5-225
Exhibit 5-122: Households (HHs) with Children under 6 and That Moved	5-226
Exhibit 5-123: Number of LSLR Information Requests from Realtors, Home Inspectors, and Potential Home Buyers	5-226
Exhibit 5-124: Estimated Number of Health Agencies	5-227
Exhibit 5-125: Annual CWS Burden (per system) to Conduct Outreach to State and Local Health Agencies	5-228
Exhibit 5-126: PWS PE Burden in Response to Lead ALE	5-229
Exhibit 5-127: Number of Local Health Agencies, Schools, Child Cares, and Targeted Medical Providers Proportionally Distributed by CWS Population Served	5-232
Exhibit 5-128: System Burden for Public Meetings	5-234
Exhibit 5-129: System Burden for Additional PE Activities after a Lead ALE	5-235
Exhibit 5-130: Cost for Paid Ads	5-236
Exhibit 5-131: Average cost for 10 column inches (about 1/8 of a page) for three system sizes	5-236
Exhibit 5-132: System Cost for Additional Public Education Activities after a Lead ALE	5-238
Exhibit 5-133: PWS Lead Public Education Unit Costing Approach in SafeWater LCR by Activity[1]	240
Exhibit 5-134: System Counts and Population Impacted (Over 35 Year Period of Analysis)	246
Exhibit 5-135: National Annualized PWS Costs by System Category  -  Low Cost Scenario  -  at 3 Percent Discount Rate (2016$)	249
Exhibit 5-136: National Annualized PWS Costs by System Category  -  High Cost Scenario  -  at 3 Percent Discount Rate (2016$)	252
Exhibit 5-137: National Annualized PWS Costs by System Category  -  Low Cost Scenario  -  at 7 Percent Discount Rate (2016$)	255
Exhibit 5-138: National Annualized PWS Costs by System Category  -  High Cost Scenario  -  at 7 Percent Discount Rate (2016$)	258
Exhibit 5-139: Annualized Incremental Cost per Household by CWS Category - Low Cost Scenario (2016$)	262
Exhibit 5-140: Annualized Incremental Cost per Household by CWS Category - High Cost Scenario (2016$)	264
Exhibit 5-141: Primacy Agency Cost Components, Subcomponents, and Activities Organized by Section1	267
Exhibit 5-142: Primacy Agency Administration Activities and Unit Burden Estimates (Occur during Years 1 through 5)	270
Exhibit 5-143: Estimated Burden for Primacy Agencies to Provide Staff Training during Years 1 through 5	271
Exhibit 5-144: Primacy Agency Annual Administration Activities and Unit Burden Estimates	271
Exhibit 5-145: Primacy Agency Administration and Rule Implementation Cost Estimation in SafeWater LCR (by Activity)[1]	273
Exhibit 5-146: Primacy Agency Lead Tap Sampling Burden Estimates	274
Exhibit 5-147: Burden to Review Lead Tap Sampling Results and 90[th] Percentile Level	277
Exhibit 5-148: Primacy Agency Lead Tap Sampling Unit Cost Estimation in SafeWater LCR by Activity[1]	278
Exhibit 5-149: Primacy Agency Lead WQP Monitoring Burden Estimates	5-284
Exhibit 5-150: Primacy Agency Lead WQP Monitoring Cost Estimation in SafeWater LCR by Activity[1]	5-285
Exhibit 5-151: Primacy Agency Copper WQP Monitoring Burden Estimates	5-286
Exhibit 5-152: Primacy Agency Copper WQP Monitoring Cost Estimation in SafeWater LCR by Activity[1]	5-286
Exhibit 5-153: Primacy Agency Source Monitoring Burden Estimates	5-287
Exhibit 5-154: Primacy Agency Source Water Monitoring Cost Estimation in SafeWater LCR by Activity[1]	5-288
Exhibit 5-155: Primacy Agency School Sampling Burden Estimates	5-289
Exhibit 5-156: Primacy Agency School Sampling Cost Estimation in SafeWater LCR by Activity[1,2]	5-290
Exhibit 5-157: Primacy Agency CCT Installation Related Burden Estimates	5-291
Exhibit 5-158: Estimated Burden for Primacy Agencies to Review Initial CCT Study	5-292
Exhibit 5-159: Estimated Burden for Primacy Agency Review to Set OWQPs	5-292
Exhibit 5-160: Primacy Agency CCT Installation Cost Estimation in SafeWater LCR by Activity[1]	5-293
Exhibit 5-161: Primacy Agency CCT Re-Optimization-Related Burden Estimates	5-293
Exhibit 5-162: Estimated Burden for Primacy Agencies to Review a Revised CCT Study and Determine Needed CCT Adjustment	5-294
Exhibit 5-163: Primacy Agency CCT Re-optimization Cost Estimation in SafeWater LCR by Activity[1]	5-294
Exhibit 5-164: Primacy Agency Find-and-Fix Burden Estimates	5-295
Exhibit 5-165: Primacy Agency CCT Find-and-Fix Cost Estimation in SafeWater LCR by Activity[1,2]	5-296
Exhibit 5-166: Primacy Agency CCT Installation Related Burden Estimates	5-297
Exhibit 5-167: Estimated Primacy Agency Burden to Review CCT-Related Data during Sanitary Survey	5-298
Exhibit 5-168: Estimated Hours per System for Primacy Agency to Consult on Source Water Change	5-299
Exhibit 5-169: Estimated Hours per System for Primacy Agency to Consult on Treatment Change	5-300
Exhibit 5-170: Primacy Agency CCT Re-optimization Cost Estimation in SafeWater LCR by Activity[1]	5-300
Exhibit 5-171: Primacy Agency LSL Inventory Burden Estimates	5-303
Exhibit 5-172: One-Time Burden to Review System LSL Inventory (hrs/system)	5-303
Exhibit 5-173: Primacy Agency LSL Inventory Burden Estimates	5-305
Exhibit 5-174: One-Time Burden to Review LSLR Plan and Negotiate Replacement Goal (hrs/system)	5-305
Exhibit 5-175: Primacy Agency Ongoing LSL Testing and Replacement-Related Costs Burden Estimates	5-305
Exhibit 5-176: Primacy Agency Burden to Review System's Annual LSLR Report (hrs per system)	5-307
Exhibit 5-177: Primacy Agency Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity[1,2]	5-307
Exhibit 5-178: Primacy Agency One-Time POU-Related Burden Estimates	5-310
Exhibit 5-179: Estimated Hours for Primacy Agency Review of POU Plan (hrs/system)	5-310
Exhibit 5-180: Primacy Agency Ongoing POU-Related Burden Estimates	5-311
Exhibit 5-181: Primacy Burden to Review Annual POU Program Report (hours/system	5-312
Exhibit 5-182: Primacy Agency POU Cost Estimation in SafeWater LCR (by Activity)[1,2]	5-313
Exhibit 5-183: PWS Burden for Consumer Notification When Sample is > 15 ug/L	5-315
Exhibit 5-184: Primacy Agency Burden for Public Education Activities that Are Independent of Lead 90[th] Percentile Levels	5-315
Exhibit 5-185: Primacy Agency PE Burden in Response to Lead ALE	5-317
Exhibit 5-186: Primacy Agency Lead Public Education Cost Estimation in SafeWater LCR (by Activity)[1, 2]	5-318
Exhibit 5-187: Phosphorus Mass Balance Conceptual Model	5-320
Exhibit 5-188: Summary of Assumptions Used in Estimating Phosphorus Loading Increase	5-321
Exhibit 5-189: WWTP Status with Respect to Phosphorus Discharge Permit Limits	5-322
Exhibit 5-190: Summary of Assumptions Used in Estimating Phosphorus Removal Unit Cost	5-324
Exhibit 5-191: Nationwide Annual Phosphorus Reaching WWTPs after Implementation of the Final LCRR under Low Cost Scenario	5-326
Exhibit 5-192: Nationwide Annual Phosphorus Reaching WWTPs after Implementation of the Final LCRR under High Cost Scenario	5-326
Exhibit 5-193: Nationwide Annual Phosphorus Reaching Waterbodies after Implementation of the Final LCRR under Low Cost Scenario	5-326
Exhibit 5-194: Nationwide Annual Phosphorus Reaching Waterbodies after Implementation of the Final LCRR under High Cost Scenario	5-327
Exhibit 6-1: Tap Water Lead Concentration Sample Data: Source Citations, City Water System, LSL and CCT Status Represented in the Data Source, and Number of Individual Sample Bottles per Source*	6-4
Exhibit 6-2: Diagram Showing Plumbing Where Water Can Become Contaminated with Lead	6-5
Exhibit 6-3: Example of a Complete Consecutive Liter Profile of Lead Concentrations in Tap Water from a Location with a Lead Service Line	6-6
Exhibit 6-4: Summary Statistics for Tap Water Lead Concentrations by LSL and CCT Status Combinations, Country, and Citation	6-8
Exhibit 6-5: Summary Statistics, Including Geometric Mean, Standard Deviation (SD), Maximum Value, and Sample Size for Tap Water Lead Concentration Sample Data by LSL and CCT Status Used in Statistical Modeling	6-10
Exhibit 6-6: Numeric Values Assigned to Two Discrete Contrast Variables Representing LSL Status in the Estimated Drinking Water Lead Concentration Regression Model	6-11
Exhibit 6-7: Numeric Values Assigned to a Discrete Contrast Variable Representing CCT Status Use in the Estimated Drinking Water Lead Concentration Regression Model	6-11
Exhibit 6-8: Comparison of Tap Sample Lead Concentration Model Results Based on Maximum Likelihood Estimators for Goodness of Fit	6-14
Exhibit 6-9: Results from the Reduced Cubic Spline Interaction Model with CCT Interactions: Fixed Effects and Random Effects for Sampling Event, Site, and City Water System	6-14
Exhibit 6-10: Estimates for the Simulated Data Showing the Relationship between Tap Lead Concentration and Profile Liter for Each Combination of CCT and LSL Status	6-16
Exhibit 6-11: LSL and CCT Scenarios and Simulated Geometric Mean Tap Water Lead Concentrations and Standard Deviations at the Fifth Liter Drawn after Stagnation for Each Combination of LSL and CCT Status	6-17
Exhibit 6-12: Mapping Simulated Drinking Water Lead Tap Concentrations to Benefit Scenarios	6-19
Exhibit 6-13: Summary of Geometric Mean Water Lead Concentration Changes Resulting from Rule Implementation, and Associated Number of People for Each Treatment Combination Change over 35-Year Analysis Period (Low-Cost Scenario)	6-22
Exhibit 6-14: Summary of Geometric Mean Water Lead Concentration Changes Resulting from Rule Implementation, and Associated Number of People for Each Treatment Combination Change over 35-Year Analysis Period (High-Cost Scenario)	6-24
Exhibit 6-15: Overview of SHEDS-Multimedia Methodology	6-28
Exhibit 6-16: Structure of the IEUBK Model for Lead in Children	6-29
Exhibit 6-17: Summary of Daily Water Consumption Inputs for Drinking Water Consumption in SHEDS-IEUBK Coupling (Zartarian et al., 2017)	6-30
Exhibit 6-18: Summary of Daily Inputs for Dietary Lead Intake (μg/day) in SHEDS-IEUBK (Xue et al., 2010)	6-30
Exhibit 6-19: Summary of Daily Inputs for Soil and Dust Lead Concentration (ppm) in SHEDS-IEUBK Coupling (Zartarian et al., 2017)	6-31
Exhibit 6-20: Summary of Daily Inputs for Soil/Dust Ingestion (mg/day) in SHEDS-IEUBK Coupling (Ozkaynak et al., 2011)	6-31
Exhibit 6-21: Default Lead Absorption Fractions across Media Used in SHEDS-IEUBK Model Runs	6-32
Exhibit 6-22: Age-Specific Polynomial Regressions Equations for Approximating IEUBK (Zartarian et al., 2017)	6-32
Exhibit 6-23: Summary of SHEDS-IEUBK Coupling	6-33
Exhibit 6-24: Modeled SHEDS-IEUBK Geometric Mean Blood Lead Levels in Children for Each Possible Drinking Water Lead Exposure Scenario for Each Year of Life	6-34
Exhibit 6-25: Comparison of Adjusted Coefficients from Lanphear et al. Erratum (2019) with Those Obtained in the Kirrane and Patel (2014) Reanalysis and Independent Analysis of Lanphear et al. (2005) by Crump et al. (2013)	6-36
Exhibit 6-26: Avoided IQ Loss per Child Associated with the Concentration-Response Function from Crump et al. (2013) and Additional Blood Lead Estimates	6-37
Exhibit 6-27: National Annual Children's Benefits, All PWS, 3 Percent Discount Rate (2016$)	6-42
Exhibit 6-28: National Annual Children's Benefits, All PWS, 7 Percent Discount Rate (2016$)	6-43
Exhibit 6-29: Geometric Mean Blood Lead Levels from NHANES 2011 - 2016 (CDC, 2016)	6-47
Exhibit 6-30: Constant Variables Entered into the ALM	6-48
Exhibit 6-31: Estimates of Blood Lead Levels in Adults Associated with Drinking Water Lead Exposures from LSL/CCT or POU Combinations	6-49
Exhibit 6-32: Estimated Lifetime Average Blood Lead Level Change for Adults Experiencing Alternate LSL, CCT, and POU Status Combinations	6-50
Exhibit 7-1: National Annualized Incremental Costs of the Final LCRR at 3 Percent Discount Rate ($2016)	7-1
Exhibit 7-2: National Annualized Incremental Costs of the Final LCRR at 7 Percent Discount Rate (2016$)	7-2
Exhibit 7-3: National Annualized Incremental Benefits of the Final LCRR at 3 Percent Discount Rate (2016$)	7-3
Exhibit 7-4: National Annualized Incremental Benefits of the Final LCRR at 7 Percent Discount Rate (2016$)	7-4
Exhibit 7-5: Comparison of Estimated Monetized National Annualized Incremental Costs to Benefits of the Final LCRR at 3 Percent Discount Rate	7-6
Exhibit 7-6: Comparison of Estimated Monetized National Annualized Incremental Costs to Benefits of the Final LCRR at 7 Percent Discount Rate	7-7
Exhibit 8-1: Change in Average Annual Net Burden and Costs for the Final LCRR ICR	8-4
Exhibit 8-2: Total Net Responses, Burden, and Costs for the Final LCRR ICR for Each Required Activity	8-5
Exhibit 8-3: NTNCWS and Small CWS Counts Impacted Under Flexibility Option - Low Cost Scenario (Over 35 Year Period of Analysis)	8-10
Exhibit 8-4: NTNCWS and Small CWS Counts Impacted Under Flexibility Option - High Cost Scenario (Over 35 Year Period of Analysis)	8-11
Exhibit 8-5: National Annualized Rule Costs - CWSs Serving 3,301 to 10,000 People with Small System Compliance Flexibility (Final Rule) at 3% Discount Rate (2016$)	8-12
Exhibit 8-6: National Annualized Rule Costs - CWSs Serving 3,301 to 10,000 People with Small System Compliance Flexibility (Final Rule) at 7% Discount Rate (2016$)	8-12
Exhibit 8-7: Comparison of Final LCRR Incremental Cost with Small System Flexibility to LCRR Incremental Cost without the Small System Flexibility (2016$)	8-13
Exhibit 8-8: Incremental Costs vs. Revenue for Small CWSs  -  Low Cost Scenario	8-15
Exhibit 8-9: Incremental Costs vs. Revenue for Small CWSs  -  High Cost Scenario	8-16
Exhibit 8-10: Distribution of Incremental Costs vs. Revenue for Small CWSs  -  Low Cost Scenario	8-17
Exhibit 8-11: Distribution of Incremental Costs vs. Revenue for Small CWSs  -  High Cost Scenario	8-18
Exhibit 8-12: National Annualized Incremental Rule Costs with Compliance Flexibility for CWSs Serving 3,300 or Fewer People and All NTNCWSs (2016$)	8-19
Exhibit 8-13: National Annualized Rule Costs - CWSs Serving 3,301 to 10,000 People without Small System Compliance Flexibility at 3% Discount Rate (2016$)	8-20
Exhibit 8-14: National Annualized Rule Costs - CWSs Serving 3,301 to 10,000 People without Small System Compliance Flexibility at 7% Discount Rate (2016$)	8-20
Exhibit 8-15: Comparison of Final LCRR Incremental Cost with Small System Flexibility for CWSs Serving 3,300 or Fewer People and NTNCWSs to LCRR Incremental Cost without the Small System Flexibility (2016$)	8-21
Exhibit 8-16: Incremental Costs vs. Revenue for Small CWSs Serving 3,301-10,000 People  -  Low Cost Scenario	8-22
Exhibit 8-17: Incremental Costs vs. Revenue for Small CWSs Serving 3,301-10,000 People  -  High Cost Scenario	8-22
Exhibit 8-18: Distribution of Incremental Costs vs. Revenue for CWSs Serving 3,301-10,000 People - Low Cost Scenario	8-23
Exhibit 8-19: Distribution of Incremental Costs vs. Revenue for CWSs Serving 3,301-10,000 People - High Cost Scenario	8-23
Exhibit 8-20: Total Annualized Incremental Costs and Benefits at 3 Percent Discount Rate	8-26
Exhibit 8-21: Total Annualized Incremental Costs and Benefits at 7 Percent Discount Rate	8-26
Exhibit 8-22: Total Annualized Incremental Costs and Benefits  for Small PWSs (<= 10,000 people) at 3 Percent Discount Rate	8-26
Exhibit 8-23: Total Annualized Incremental Costs and Benefits  for Small PWSs (<=10,000 people) at 7 Percent Discount Rate	8-27
Exhibit 8-24: Summary of Environmental Justice Evaluation Topics, Methods, and Findings	8-32
Exhibit 9-1: Summary of Other Options Considered for the Final LCRR	9-1
Exhibit 9-2: Comparison of Three Options Considered for the Lead in Drinking Water Sampling Program at Schools and Child Cares	9-3
Exhibit 9-3: National Annualized Costs for School Sampling Options (2016$)	9-5
Exhibit 9-4: Percent of Non-LSL Systems and LSL Systems under the First and Fifth Liter Tap Sampling Protocols with No TLE or ALE, a TLE, and an ALE[1-3]	9-8
Exhibit 9-5: Likelihood of an Individual First Liter Lead Tap Sample Result Above 15 ug/L Based on Michigan CWSs Data Stratified by System 90[th] Percentile, LSL Status, and Population Served for the First Liter Option	9-11
Exhibit 9-6: Likelihoods of a First Liter Individual Lead Tap Sample Result Above 15 ug/L for LSL Systems under the First Liter Option Compared to the Likelihoods of a Fifth Liter Individual Lead Tap Sample Result Above 15 ug/L for LSL Systems under the Final LCRR	9-12
Exhibit 9-7: National Annualized Incremental Rule Costs at 3 Percent Discount Rate for the First Liter Option and Final LCRR (2016$)	9-13
Exhibit 9-8: National Annualized Incremental Rule Costs at 7 Percent Discount Rate for the First Liter Option and Final LCRR (2016$)	9-13
Exhibit 9-9: National Annualized Incremental Rule Costs at 3 Percent Discount Rate for the Final LCRR and the Alternative Small System Flexibility Threshold Considered (2016$)	9-17
Exhibit 9-10: National Annualized Incremental Rule Costs at 7 Percent Discount Rate for the Final LCRR and the Alternative Small System Flexibility Threshold Considered (2016$)	9-18

List of Acronyms
ug/L
micrograms per liter
AALM
All Ages Lead model
ACS
American Community Survey
ADF
Average daily flow
ADHD
Attention-deficit/hyperactivity disorder
AFQT
Armed Forces Qualifying Test
AHHS
American Healthy Homes Survey
AIC
Akaike's Information Criterion
AL
Action level
ALE
Action level exceedance
ALM
Adult lead methodology
ALS
Amyotrophic lateral sclerosis
AMA
American Medical Association
ANSI
American National Standards Institute
ASCE
American Society of Civil Engineers
ASDWA
Association of State Drinking Water Administrators
ASVAB
Armed Services Vocational Aptitude Battery
ATSDR
Agency for Toxic Substances and Disease Registry
AWIA
America's Water Infrastructure Act
AWWA
American Water Works Association
BAEP
Brainstem auditory evoked potential
BIC
Bayesian information criterion
BLL
Blood lead level
BLS
Bureau of Labor Statistics
BMD
Benchmark dose
BMI
Body mass index
BMR
Benchmark response
BP
Blood pressure
CCR
Consumer Confidence Report
CCT
Corrosion control treatment
CDBG
Community development block grant
CDC
Centers for Disease Control and Prevention
CED
Committee for Economic Development
CFR
Code of Federal Regulations
CFSAN
Center for Food Safety and Applied Nutrition
CHAD
Consolidated Human Activity Database
CHD
Coronary heart disease
CI
Confidence interval
CND
Canada
CPI
Consumer price index
CRF
Concentration-response functions
CRP
c-reactive protein
CVD
Cardiovascular disease
CWS
Community water system
CWSS
Community Water System Survey
DBP
Diastolic blood pressure
DF
Design flow
DHS
Department of Homeland Security
DISC
Diagnostic Interview Schedule for Children
DMR
Discharge monitoring report
DSM
Diagnostic and Statistical Manual of Mental Disorders
DTH
Delayed-type hypersensitivity
DWINSA
Drinking Water Infrastructure Needs Survey and Assessment
DWM
Department of Water Management
DWSRF
Drinking water state revolving fund
EA
Economic analysis
ECI
Employment cost index
ECTT
Error code tracking tool
EDF
Environmental Defense Fund
EGLE
Environment, Great Lakes, and Energy
EKG
Electrocardiogram
EO
Executive order
EOG
End-of-grade
EP
Entry point
EPA
United States Environmental Protection Agency
FDA
Food and Drug Administration
FIML
Full-information maximum likelihood
FOIA
Freedom of Information Act
FR
Federal Register
FRFA
Final Regulatory Flexibility Analysis
FRN
Federal Register Notice
FSIQ
Full scale intelligence quotient
FTE
Full-time equivalent
GAO
Government Accountability Office
GCI
General cognitive index
GCWW
Greater Cincinnati Water Works
GFR
Glomerular filtration rate
GI
Gastro-intestinal
GIS
Geographic information system
GM
Geometric mean
GUA
Ground water under the influence of surface water active
GW
Ground water
GWA
Ground water active
GWR
Ground Water Rule
GWUDI
Ground water under the direct influence of surface water
HAB
Harmful algal blooms
HH
Households
HHFKA
Healthy Hunger-Free Kids Act
HHS
Department of Health and Human Services
HMR
Heavy metals registry
HR
Hazard ratio
HUD
U.S. Department of Housing and Urban Development
IARC
International Agency for Research on Cancer
ICC
Indian childhood cirrhosis
ICD
International Classification of Diseases
ICR
Information collection request
ICT
Idiopathic copper toxicosis
IESWTR
Interim Enhanced Surface Water Treatment Rule
IEUBK
Integrated exposure uptake biokinetic
IPC
Internal plumbing code
IQ
Intelligence quotient
ISA
Integrated Science Assessment for Lead
LCCA
Lead Contamination Control Act
LCR
Lead and Copper Rule
LCRMR
Lead and Copper Rule Minor Revisions
LCRR
Lead and Copper Rule Revisions
LCRWG
Lead and Copper Rule Working Group
LGAC
Local government advisory committee
LIS
Lead information survey
LOAEL
Low-observed-adverse-effect-level
LOD
Limit of detection
LSL
Lead service line
LSLR
Lead service line replacement
MCL
Maximum contaminant level
MCLG
Maximum contaminant level goal
MDI
Mental development index
MDL
Method detection limit
MFR
Multi-family residence
MGD
Million gallons per day
MHP
Mobile home park
MMSE
Mini-mental state examination
MRDL
Maximum disinfectant residual level
MRL
Minimal risk level
NAAQS
National Ambient Air Quality Standards
NACCHO
National Association of County and City Health Officials
NAICS
North American Industry Classification System
NARA
National Association for Regulatory Administration
NCCIC
National Child Care Information and Technical Assistance Center
NCES
National Center for Education Statistics
NDDIC
National Digestive Diseases Clearinghouse
NDWAC
National Drinking Water Advisory Council
NHANES
National Health and Nutrition Examination Survey
NHEXAS
National Human Exposure Assessment Survey
NIDDK
National Institute of Diabetes and Digestive and Kidney Diseases
NLSY
National Longitudinal Survey of Youth
NOAEL
No adverse effect level
NPDES
National Pollutant Discharge Elimination System
NPDWR
National primary drinking water regulation
NRDC
Natural Resources Defense Council
NSF
NSF International
NTNCWS
Non-transient non-community water system
NTP
National Toxicology Program
NTTAA
National Technology Transfer and Advancement Act
OCCT
Optimal corrosion control treatment
OES
Occupational employment survey
OGWDW
Office of Ground Water and Drinking Water
OMB
Office of Management and Budget
OWQP
Optimal water quality parameter
P90
Lead 90th percentile level
PE
Public education
PN
Public notice
POE
Point-of-entry
POU
Point-of-Use
PQL
Practical quantitation limit
PRA
Paperwork Reduction Act
PSA
Public service announcement
PUMS
Public use microdata sample
PVC
Polyvinyl chloride
PWD
Philadelphia water department
PWS
Public water system
PWSID
Public water system identification number
PWSS
Public water system supervision
QA
Quality assurance
QC
Quality control
RDA
Recommended daily allowance
REML
Restricted maximum likelihood
RFA
Regulatory Flexibility Act
RIA
Regulatory impact assessment
RLDWA
Reduction of Lead in Drinking Water Act
RTCR
Revised Total Coliform Rule
RTOC
Regional Tribal Operations Committee
SAB
Science Advisory Board
SAT
Standard assessment test
SBA
Small Business Administration
SBAR
Small Business Advocacy Review
SBP
Systolic blood pressure
SBREFA
Small Business Regulatory Enforcement Fairness Act
SD
Standard deviation
SDWA
Safe Drinking Water Act
SDWIS
Safe Drinking Water Information System
SDWIS/FED
Safe Drinking Water Information System/Federal version
SE
Standard error
SFS
Single family structure
SHEDS
Stochastic Human Exposure and Dose Simulation
SISNOSE
Significant economic impact on a substantial number of small entities
SRF
State revolving fund
SS
Sums of squares
SSA
Social Security Administration
SW
Surface water
SWDIS
Safe Drinking Water Information System
TCR
Total Coliform Rule
TDS
Total Diet Study 2007-2013
TL
Trigger level
TLE
Trigger level exceedance
TP
Total phosphorous
TV
Television
UK
United Kingdom
UL
Upper intake levels
UMRA
Unfunded mandates reform act
USA
United States of America
USDA
United States Department of Agriculture
USEPA
Unites States Environmental Protection Agency
USGS
United States Geological Survey
VLS
Very large system
WBS
Work breakdown structure
WIC
Women, infants and children
WIFIA
Water Infrastructure Finance and Innovation Act
WIIN
Water Infrastructure Improvements for the Nation
WISC
Wechsler intelligence scale for children
WLL
Water lead level
WPCA
Water Pollution Control Authority
WQP
Water quality parameter
WQTC
Water Quality Technology Conference
WWTP
Wastewater treatment plant

Introduction
The United States has made tremendous progress in lowering children's blood lead levels. As a result of multiple federal laws and regulations, including the 1973 phase out of lead in automobile gasoline, the 1978 ban on lead paint for residential and consumer use, the 1986 beginning of banning the use of leaded pipe and solder in water supplies, the 1991 Lead and Copper Rule (LCR), and the 1995 ban on lead in solder in food cans, the median concentration of lead in the blood of children aged 1 to 5 years dropped from 15 micrograms per deciliter in 1976 - 1980 to 0.7 micrograms per deciliter in 2015-2016, a decrease of 95 percent (USEPA, 2019a).
Data evaluated by the National Toxicology Program (NTP, 2012) demonstrates that there is sufficient evidence to conclude that there are adverse health effects associated with low-level lead exposure. Sources of lead include lead-based paint, drinking water, and soil contaminated by historical sources. The Federal Action Plan (Action Plan) to Reduce Childhood Lead Exposures and Associated Health Impacts, issued in December 2018, provides a blueprint for reducing further lead exposure and associated harm through collaboration among federal agencies and with a range of stakeholders, including states, tribes, and local communities, along with businesses, property owners, and parents. The Action Plan is the product of the President's Task Force on Environmental Health Risks and Safety Risks to Children (Task Force, 2018). The Task Force is comprised of 17 federal departments and offices including the Department of Health and Human Services and the Department of Housing and Urban Development, which co-chaired the development of the Action Plan with the United States Environmental Protection Agency (EPA).
Through this plan, EPA committed to reducing lead exposures from multiple sources including paint, ambient air, and soil and dust contamination, especially to children who are among the most vulnerable to the effects of lead. On June 21, 2019, EPA announced new, tighter standards for lead in dust on floors and windowsills to protect children from the harmful effects of lead exposure (84 FR 32632; USEPA, 2019b). The standards were lowered from 40 ug of lead in dust per square foot (ft2) on floors and 250 ug of lead in dust per ft2 on interior windowsills, to 10 ug/ft2 and 100 ug/ ft2, respectively. The lead hazard standards help property owners, lead paint professionals, and government agencies identify lead hazards in residential paint, dust and soil. On June 19, 2020 EPA released a proposal to lower the clearance levels for lead in dust on floors and windowsills after lead removal activities from 40 ug/ft2 to 10 ug/ft2 for floor dust and from 250 ug/ft2 to 100 ug/ft2 for windowsill dust (85 FR 37810; USEPA, 2020a). The dust lead clearance levels are used to demonstrate that abatement activities effectively and permanently eliminate those hazards. They apply in most pre-1978 housing and child-occupied facilities. The proposed, tighter standards would increase the effectiveness of abatement in pre-1978 homes and child care facilities.
To address lead in soil, EPA will continue to remove, remediate, and take corrective actions at contaminated sites, including Superfund, Resource Conservation and Recovery Act Corrective Action, and other cleanup sites. EPA will also continue to work with state and tribal air agencies to help nonattainment areas meet the National Ambient Air Quality Standards. EPA is also focused on conducting critical research and improving public awareness by consolidating and streamlining federal messaging.
Lead and copper enter drinking water mainly from corrosion of plumbing materials containing lead and copper. Lead was widely used in plumbing materials until Congress prohibited the use or introduction into commerce of pipes and pipe fittings and fixtures that contained more than eight percent lead and solder or flux that contained more than 0.2 percent lead in 1986. On September 1, 2020, EPA published the final rule: Use of Lead Free Pipes, Fittings, Fixtures, Solder, and Flux for Drinking Water (USEPA, 2020b). The Lead-Free final rule significantly limits the lead content allowed in plumbing materials (e.g., pipes, fittings, and fixtures) used in new construction and replacement of existing plumbing. Specifically, the Lead-Free rule reduces the percentage of lead content allowed in these materials from eight percent to 0.25 percent in accordance with the 2011 Reduction of Lead in Drinking Water Act.
Many buildings were constructed prior to the restrictions on using plumbing materials that contained lead. There are currently an estimated 6.3 to 9.3 million homes served by lead service lines (LSLs) in thousands of communities nationwide, in addition to millions of older buildings with lead solder and faucets that contain lead. See Chapter 4, Section <IP_ADDRESS> for additional information on the estimated number and location of LSLs. To reduce exposure to lead through drinking water, the Action Plan highlights several key actions, including EPA's commitment to making regulatory changes to implement the statutory definition of lead-free plumbing products and assisting schools and child cares with testing for lead in drinking water using the 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities: A Training, Testing, and Taking Action Approach (Revised Manual) (USEPA, 2018). The Action Plan also highlights EPA's support to states and communities by identifying funding opportunities through the Drinking Water State Revolving Fund and the Water Infrastructure Finance and Innovation Act loan program for updating and replacing drinking water infrastructure. In addition, the Action Plan highlights three newly authorized grant programs under the Water Infrastructure Improvements for the Nation Act, to fund grants to small and disadvantaged communities for developing and maintaining infrastructure, for lead reduction projects, and to support the voluntary testing of drinking water in schools and child cares. The Action Plan also highlights the importance of preventing lead exposure from drinking water by working with states, tribes, and local stakeholders to share best practices and tools to better implement the National Primary Drinking Water Regulations for Lead and Copper. For more information about the Federal Lead Action Plan see https://www.epa.gov/sites/production/files/2018-12/documents/fedactionplan_lead_final.pdf.
To reduce exposure to lead through drinking water, EPA issued the LCR in 1991 (USEPA, 1991). Since its implementation, drinking water exposures have declined, resulting in major improvements in public health. For example, the number of the nation's large drinking water systems (i.e., serving more than 50,000 persons) that have exceeded the LCR action level (AL) of 15 micrograms per liter (ug/L) has decreased by over 90 percent, and over 95 percent of all water systems have not reported an action level exceedance (ALE) from 2017-2019 (USEPA, 2019c).
This economic analysis (EA) presents the evaluation of the benefits and costs of the final LCRR. The analysis is performed in compliance with Executive Order 12866, Regulatory Planning and Review (58 Federal Register [FR] 51735, October 4, 1993), and Executive Order 13563, Improving Regulations and Review (76 FR 3821, January 21, 2011). These executive orders require EPA to estimate the economic impact of rules that have an annual effect on the economy of over $100 million, make that analysis available to the public for comment prior to publication of the final rule, and consider ways to reduce regulatory burden and maintain flexibility for the public. In addition, the Safe Drinking Water Act (SDWA) requires the EPA Administrator to "publish and seek public comment on an analysis of the health risk reduction benefits and costs likely to be experienced as the result of compliance with the treatment technique and alternative treatment techniques that are being considered . . ." (SDWA Section 1412(b)(3)(C)(ii)). EPA solicited public comment on all aspects of the data and analysis presented in this EA and associated Appendices.
This chapter provides a summary of the final LCRR in Section 1.1. Section 1.2, outlines the organization of this EA, and provides information regarding supporting calculations and citations in Section 1.3.
Summary of the Final LCRR
The final LCRR includes a suite of actions to address lead contamination in drinking water that, taken together, will improve the LCR and further reduce lead exposure in comparison with the previous LCR, resulting in an enduring positive public health impact. This approach focuses on six key areas:
 Identifying Areas Most Impacted. To help identify areas with the greatest potential for lead contamination of drinking water and most in need of remediation, EPA's final rule requires that all water systems complete and maintain an LSL inventory and collect tap samples from a prescribed selection of homes with LSLs if present in the distribution system. To reduce elevated levels of lead in certain locations, EPA's final rule also requires water systems to engage in a "find-and-fix" process to identify the causes of these elevated levels as well as take potential actions to reduce lead levels.
 Strengthening Treatment Requirements. EPA is finalizing expanded requirements for corrosion control treatment (CCT) based on tap sampling results. The final rule also establishes a new trigger level (TL) of 10 ug/L. At this TL, systems that currently treat for corrosion are required to re-optimize their existing treatment. Systems that do not currently treat for corrosion will be required to conduct a corrosion control study so that the system is prepared to respond quickly if the system exceeds the AL in a subsequent monitoring period. Flexibility is important for small systems so that they can protect public health by taking the treatment action that makes sense for their community. The LCRR provides new alternatives (i.e., small system flexibilities) to CCT for community water systems (CWSs) serving 10,000 or fewer people and all non-transient non-community water systems (NTNCWSs) including point-of-use (POU) treatment and replacement of lead bearing plumbing materials.
 Systematically Replacing LSLs. The final LCRR requires water systems with high lead levels to initiate LSL removal, permanently reducing a significant source of lead in many communities. All water systems with LSLs or lead status unknown service lines must create a lead service line replacement (LSLR) plan by the rule compliance date. The more stringent sampling requirements in the final rule will better identify elevated lead levels, which will result in more systems replacing LSLs. Systems that are above the TL (greater than 10 ug/L) but at or below the lead AL (15 ug/L) must conduct replacements at a goal rate approved by the Primacy Agency, and, systems that are above the AL, must replace an average annual rate of three percent, calculated on a two-year rolling basis. The base number of service lines to which the mandatory rate of three percent, or rate otherwise specified in § 141.84(g)(9), is applied is equal to the number of known LSLs and galvanized requiring replacement service lines at the time the system first exceeds the lead AL plus the number of unknowns at the beginning of each year of the system's LSLR program. Systems cannot end their goal-based program until they demonstrate their lead 90[th] percentile levels are at or below the lead TL for two consecutive years. Systems can stop their mandatory replacement program once they demonstrate their lead 90[th] percentile levels are at or below the AL for two consecutive years and the cumulative percentage of LSLs replaced by the system is greater than or equal to three percent, or as otherwise specified in § 141.84(g)(9), times the number of years that elapsed between when the system most recently began mandatory LSLR and the date on which the system's 90[th] percentile lead levels are at or below the action level for two consecutive years. Only full LSL replacements will be counted towards the required goal-based and mandatory rate, not partial replacements and not replacement through testing. The final rule requires water systems to replace the water system-owned portion of an LSL when a customer chooses to replace their customer-owned portion of the line within 45 days, with the ability to have up to 180 days with notification of the Primacy Agency.
 Increasing Sampling Reliability. EPA is changing the criteria for selecting homes at which to collect tap samples and the way in which those samples are collected. EPA is requiring tap sample site selection to focus on sites with LSLs (where present) and is requiring a new way to collect tap samples at these sites. Systems with LSLs must collect fifth liter samples that are representative of water that has been in the LSL for several hours, which will provide better information on the highest concentration of lead in drinking water. The final LCRR prohibits tap sampling instructions that call for pre-stagnation flushing or, the cleaning or removing of faucet aerators, and includes a requirement that tap samples be collected in bottles with a wide-mouth configuration. Collectively, these new more stringent sampling requirements will better identify elevated lead levels and result in more water systems taking required lead mitigation actions.
 Improving Risk Communication. EPA is requiring systems to notify consumers of a system-wide lead ALE within 24 hours. For individual tap samples that exceed 15 ug/L, EPA is requiring systems to notify the individual consumer within three days. EPA is also requiring the consistent use of clear and concise language in public notifications and all public education materials including the consumer confidence report (CCR) on the health effects of exposure to lead in drinking water. The final rule increases the number, forms, and comprehensiveness of public education materials on lead in drinking water that are provided to the public. It also requires systems to conduct regular outreach to customers with LSLs. Systems must make their LSL inventory publicly available and must notify occupants of homes with known or potential LSLs every year about their LSL, drinking water exposure risks, and mitigation options, including removal. The final rule's requirements to provide understandable and consistent information about the levels of lead in drinking water, the sources of lead in a system, and the risks of lead in drinking water, will increase public actions to limit exposure to lead in drinking water.
 Protecting Children in Schools. Since children are at the highest risk of significant harm from lead exposure (USEPA, 2013), EPA is requiring that CWSs test for lead in drinking water in school and child cares. Systems must conduct one round of drinking water sampling at each elementary school and each child care they serve over no more than five years, testing 20 percent of the facilities they serve each year. The system will be required to provide the results to the school or child care and information on actions that can be taken by the school or child care to reduce lead in drinking water. The system will also be required to provide information to the school or child care facility on methods to communicate results to users of the facility and parents. CWSs are also required to provide testing on request to secondary schools and to elementary schools and child care facilities after the first round of mandatory testing. These requirements will provide schools and child cares with an understanding of how to create and manage a drinking water testing program that is customizable to their needs and an appreciation of the benefits of such a program.
Through strengthened treatment procedures, expanded sampling, and improved protocols for identifying lead, EPA's LCRR will require more water systems to progressively take more actions to reduce lead levels in drinking water. Additionally, by improving transparency and communication, the rule is expected to increase community awareness and accelerate the replacement of LSLs. By taking these collective actions EPA, Primacy Agencies, and water systems will be implementing a proactive holistic approach to more aggressively manage lead in drinking water.
Exhibit 1-1 provides a summary of the revisions to system requirements under the final rule by major rule component (e.g., lead and copper tap monitoring, LSLR). In this Exhibit and throughout this notice and supporting documents the requirements for the LCR that are in place prior to the compliance date of this rulemaking are referred to as the "previous LCR" and the requirements that will be in place on the compliance date of this rulemaking are referred to as the "final LCRR" or "final rule."
Exhibit 1-1: Summary of Revisions to System Requirements under the Final LCRR
                                 Previous LCR
                                  Final LCRR
                                   AL and TL
 90th percentile (P90) level above lead AL of 15 ug/L or copper AL of 1.3 mg/L requires additional actions.

 90th percentile (P90) level above lead AL of 15 ug/L or copper AL of 1.3 mg/L requires more actions than the previous rule.
 Defines lead TL of 10 ug/L < P90 <= 15 ug/L that triggers additional planning, monitoring, and treatment requirements.
                        Lead and Copper Tap Monitoring
Sample Site Selection
 Prioritizes collection of samples from sites with sources of lead in contact with drinking water.
 Highest priority given to sites served by copper pipes with lead solder installed after 1982 but before the state ban on lead pipes and/or LSLs.
 Systems must collect 50 percent of samples from LSLs, if available.
Sample Site Selection
 Changes priorities for collection of samples with a greater focus on LSLs.
 Prioritizes collecting samples from sites served by LSLs  -  all samples must be collected from sites served by LSLs, if available.
 No distinction in prioritization of copper pipes with lead solder by installation date.
 Improved tap sample site selection tiering criteria.
Collection Procedure
 Requires collection of the first-liter sample after water has sat stagnant for a minimum of 6 hours.

Collection Procedure
 Requires collection of the fifth liter sample in homes with LSLs after water has sat stagnant for a minimum of 6 hours and maintains first-liter sampling protocol in homes without LSLs.
 Adds requirement that samples must be collected in wide-mouth bottles.
 Prohibits sampling instructions that include recommendations for aerator cleaning/removal and pre-stagnation flushing prior to sample collection.
Monitoring Frequency
 Samples are analyzed for both lead and copper.
 Systems must collect standard number of samples, based on population; semi-annually unless they qualify for reduced monitoring.
 Systems can qualify for annual or triennial monitoring at reduced number of sites. Schedule based on number of consecutive years meeting the following criteria:
   Serves <= 50,000 people and <= lead & copper ALs.
   Serves any population size, meets Primacy Agency-specified OWQPs, and <= lead AL.
 Triennial monitoring also applies to any system with lead and copper 90th percentile levels <= 0.005 mg/L and <= 0.65 mg/L, respectively, for 2 consecutive 6-month monitoring periods.
 9-year monitoring waiver available to systems serving <= 3,300.
Monitoring Frequency
 Some samples may be analyzed for only lead when lead monitoring is conducted more frequently than copper.
 Copper follows the same criteria as the previous rule.
 Lead monitoring schedule is based on P90 level for all systems as follows:
   P90 > 15 μg/L: Semi-annually at the standard number of sites.
   10 ug/L < P90 <= 15 ug/L: Annually at the standard number of sites.
   P90 <= 10 μg/L:
     Annually at the standard number of sites and triennially at reduced number of sites using same criteria as previous rule except copper 90th percentile level is not considered.
     Every 9 years based on previous rule requirements for a 9-year monitoring waiver.
                                 CCT and WQPs
CCT
 Systems serving > 50,000 people were required to install treatment by January 1, 1997 with limited exception.
 Systems serving <= 50,000 that exceed lead and/or copper AL are subject to CCT requirements (e.g., CCT recommendation, study if required by Primacy Agency, CCT installation). They can discontinue CCT steps if no longer exceed both ALs for two consecutive 6-month monitoring periods.
 Systems must operate CCT to meet any Primacy Agency-designated OWQPs that define optimal CCT.
 There is no requirement for systems to re-optimize.
CCT
 Specifies CCT requirements for systems with P90 level 10 ug/L < P90 <= 15 μg/L:
   No CCT: must conduct a CCT study if required by Primacy Agency.
   With CCT: must follow the steps for re-optimizing CCT, as specified in the rule.
 Systems with P90 level > 15 μg/L:
   No CCT: must complete CCT installation regardless of their subsequent P90 levels.
   With CCT: must re-optimize CCT.
 CWSs serving <= 10,000 people and NTNCWSs can select an option other than CCT to address lead. See Small System Flexibility.
CCT Options: Includes alkalinity and pH adjustment, calcium hardness adjustment, and phosphate or silicate-based corrosion inhibitor.
CCT Options: Removes calcium hardness as an option and specifies any phosphate inhibitor must be orthophosphate.
Regulated WQPs:
 No CCT: pH, alkalinity, calcium, conductivity, temperature, orthophosphate (if phosphate-based inhibitor is used), silica (if silica-based inhibitor is used).
 With CCT: pH, alkalinity, and based on type of CCT either orthophosphate, silica, or calcium.
Regulated WQPs:
 Eliminates WQPs related to calcium hardness (i.e., calcium, conductivity, and temperature).
WQP Monitoring
 Systems serving >= 50,000 people must conduct regular WQP monitoring at entry points and within the distribution system.
 Systems serving <= 50,000 people conduct monitoring only in those periods > lead or copper AL.
 Contains provisions to sample at reduced number of sites in distribution system less frequency for all systems meeting their OWQPs.
WQP Monitoring
 Systems serving >= 50,000 people must conduct regular WQP monitoring at entry points and within the distribution system.
 Systems serving <= 50,000 people must continue WQP monitoring until they no longer > lead and/or copper AL for two consecutive 6-month monitoring periods.
 To qualify for reduced WQP distribution monitoring, P90 must be <= 10 ug/L and the system must meet its OWQPs.
Sanitary Survey Review:
 Treatment must be reviewed during sanitary surveys; no specific requirement to assess CCT or WQPs.
Sanitary Survey Review:
 CCT and WQP data must be reviewed during sanitary surveys against most recent CCT guidance issued by EPA.
Find-and-Fix:
 No required follow-up samples or additional actions if an individual sample exceeds 15 μg/L.
Find-and-Fix:
 If individual tap samples > 15 ug/L systems must:
       Collect tap sample of any liter or volume at the same tap sample site within 30 days.
       Conduct WQP monitoring at or near the site > 15 μg/L.
       Perform needed corrective action.
       Document customer refusal or nonresponse after 2 attempts.
       Provide information to state and local public health officials.
                          LSL Inventory and LSLR Plan
Initial LSL Program Activities:
 Systems were required to complete a materials evaluation by the time of initial sampling. No requirement to update materials evaluation.
 No LSLR plan is required.
Initial LSL Program Activities:
 All systems must develop an LSL inventory or demonstrate absence of LSLs within 3 years of final rule publication.
 LSL inventory must be updated annually or triennially, based on their tap sampling frequency.
 All systems with known or possible LSLs must develop an LSLR plan.
LSLR:
 Systems with LSLs with P90 > 15 ug/L after CCT installation must annually replace >=7 percent of number of LSLs in their distribution system when the lead AL is first exceeded.
 Systems must replace the LSL portion they own and offer to replace the private portion at the owner's expense.
 Full LSLR, partial LSLR, and LSLs with lead sample results <=15 ug/L ("test-outs") count toward the 7 percent replacement rate.
 Systems can discontinue LSLR after 2 consecutive 6-month monitoring periods <= lead AL.
LSLR:
 Rule specifies replacement programs based on P90 level for CWSs serving > 10,000 people:
   If P90 > 15 ug/L: Must fully replace 3 percent of LSLs per year based upon a 2 year rolling average (mandatory replacement) for at least 4 consecutive 6-month monitoring periods.
   If 10 ug/L < P90 <= 15 ug/L: Implement an LSLR program with replacement goals in consultation with the Primacy Agency for 2 consecutive 1-year monitoring periods.
 Small CWSs and NTNCWSs that LSLR as their approved compliance option must complete LSLR within 15 years if P90 > 15 ug/L. See Small System Flexibility.
 Annual LSLR rate is based on number of LSLs and galvanized requiring replacement service lines when the system first exceeds the AL plus the current number of lead status unknown.
 Only full LSLR (both customer-owned and system-owned portion) count toward mandatory rate or goal-based rate.
 All systems must replace their portion of an LSL if notified by consumer of private side replacement within 45 days of notification or within 180 days after notification to the Primacy Agency.
 Following each LSLR, systems must:
   Provide pitcher filters or POU devices, and cartridges to each customer for 6 months after replacement. Provide pitcher filters/cartridges within 24 hours for full and partial LSLRs.
   Collect a lead tap sample at locations served by replaced line within 3 to 6 months after replacement.
 Systems must replace galvanized service lines that are or ever were downstream of an LSL.
LSL-Related Outreach:
 When water system plans to replace the portion it owns, it must offer to replace customer-owned portion at owner's expense.
 System replacing its portion only must:
   Provide notification to affected residences within 45 days prior to replacement on possible elevated short-term lead levels and measures to minimize exposure.
   Include offer to collect lead tap sample within 72 hours of replacement.
   Provide test results within 3 business days after receiving results.
LSL-Related Outreach:
 Inform consumers annually that they are served by LSL or lead status unknown service line.
 Systems subject to goal-based program must:
   Conduct targeted outreach that encourages consumers with LSLs to participate in the LSLR program.
   Conduct an additional outreach activity if they fail to meet their goal.
 Systems subject to mandatory LSLR include information on LSLR program in PE materials that are provided in response to P90 > AL.

                           Small System Flexibility
No provisions for systems to elect an alternative treatment approach but sets specific requirements for CCT and LSLR.
  Allows CWSs serving <= 10,000 people and all NTNCWSs with P90 > 10 ug/L to select their approach to address lead with Primacy Agency approval.
  Systems can choose CCT, LSLR, provision and maintenance of POU devices, or replace all lead-bearing plumbing materials.
                         Public Education and Outreach
    All CWSs must provide education material in the annual CCR.
    Systems with P90 > AL must provide PE to customers about lead sources, health effects, measures to reduce lead exposure, and additional information sources.
    Systems must provide lead consumer notice to individuals served at tested taps within 30 days of learning results.
    Customers can contact the CWS to get PE materials translated in other languages.

 CWSs must provide updated health effects language in all PE materials and the CCR.
 Customers can contact the CWS to get PE materials translated in other languages.
 All CWSs must include information on how to access service line inventory information and how to access the results of all tap sampling in the CCR.
 If P90 > AL:
   Previous rule PE requirements apply.
   Systems must notify consumers of P90 > AL within 24 hours.
 In addition, CWSs must:
   Deliver notice and educational materials to consumers during water-related work that could disturb LSLs.
   Provide increased information to local and state health agencies.
   Provide lead consumer notice to consumers whose individual tap sample is > 15 ug/L as soon as practicable but no later than 3 days.
  Also see LSL-Related Outreach section of table.
                         Change in Source or Treatment
Systems on a reduced tap monitoring schedule must obtain prior Primacy Agency approval before changing their source or treatment.
Systems on any tap monitoring schedule must obtain prior Primacy Agency approval before changing their source or treatment. These systems must also conduct tap monitoring semi-annually.
                     Source Water Monitoring and Treatment
 Periodic source water monitoring is required for systems with:
   Source water treatment; or
   P90 > AL and no source water treatment.
 Primacy Agencies can waive continued source water monitoring if:
   The system has already conducted source water monitoring for a previous P90 > AL;
   Primacy Agencies have determined that source water treatment is not required; and
   The system has not added any new water sources.
               Lead in Drinking Water at Schools and Child cares
::	Does not include separate testing and education program for CWSs at schools and child cares.
::	Schools and child cares that are classified as NTNCWSs must sample for lead and copper.
 CWS must conduct sampling at 20% of elementary schools and 20% of child cares per year and conduct sampling at secondary schools on request over 5 years and conduct sampling on request of all schools and child care facilities thereafter.
 Sample results and PE must be provided to each sampled school/child care, Primacy Agency and local or state health department.
 Excludes facilities built or replaced all plumbing after January 1, 2014.
                           Primacy Agency Reporting
Primacy Agencies must report information to EPA that includes but is not limited to:
 All P90 levels for systems serving > 3,300 people, and only levels > 15 ug/L for smaller systems.
 Systems that are required to initiate LSLR and the date replacement must begin.
 Systems for which OCCT has been designated.
Expands previous rule requirements to include:
 All P90 values for all system sizes.
 The current number of LSLs and lead status unknown service lines for every water system.
 OCCT status of all systems including Primacy Agency-specified OWQPs.
Acronyms: AL = action level; ALE = action level exceedance; CCR = consumer confidence report; CCT = corrosion control treatment; CWS = community water system; LCR = Lead and Copper Rule; LCRR = Lead and Copper Rule revisions; LSL = lead service line; LSLR = lead service line replacement; NTNCWS = non-transient non-community water system; OCCT = optimal corrosion control treatment; OWQP = optimal water quality parameter; P90 = lead 90[th] percentile; PE = public education; POU = point-of use; TL = trigger level; TLE = trigger level exceedance; WQP = water quality parameter.
Document Organization
The remainder of this EA is organized into the following chapters:
Chapter 2: Need for the Rule summarizes the goal of the LCRR, why EPA revised the rule, and the regulatory history. It also explains the statutory authority for the final LCRR and the economic rationale for the regulatory approach.
Chapter 3: Regulatory Revisions provides a description of the regulatory revisions included in the final LCRR and the rationale for the change.
Chapter 4: Baseline Drinking Water System Characteristics describes systems subject to the final LCRR including the population they serve and CCT status, lead and copper tap water concentration levels, the extent of LSLs in the United States, the proportion of systems on reduced monitoring under the previous LCR, and the rate of historical source and treatment changes to characterize the baseline before EPA models estimated changes that result from complying with the final LCRR requirements.
Chapter 5: Economic Impact and Cost Analysis of the Final Lead and Copper Rule Revisions provides an estimate of the potential health benefits of the final LCRR options relative to the baseline, including quantification and monetization where possible.
Chapter 6: Benefits Resulting from the Lead and Copper Rule Revisions provides a description of the estimated costs for the final regulatory changes affecting systems and Primacy Agencies and focuses on the incremental costs between the previous LCR and the final LCRR requirements.
Chapter 7: Comparison of Costs to Benefits provides a summary of costs and benefits associated with the provisions of the previous LCR and the final LCRR requirements.
Chapter 8: Statutory and Administrative Requirements discusses distributional analyses performed to evaluate the effects of the final LCRR options on different segments of the population in accordance with 13 federal mandates and statutory reviews, including but not limited to the Regulatory Flexibility Act, Unfunded Mandates Reform Act, and Executive Order 12898 on, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations.
Chapter 9: Other Options Considered presents other alternatives EPA evaluated when developing the final LCRR for which EPA took public comment during the proposed rule comment period. These include public education and sampling at schools and child cares, modifications to the tap sample collection protocol for systems with LSLs, and information to be made publicly available regarding the location of LSLs and galvanized requiring replacement.
Calculations and Citations
This EA involves numerous detailed and complex analyses, and the following are provided to help the reader understand how those analyses were conducted and their underlying data and assumptions:
Appendices containing supporting spreadsheets and analyses:
          Appendix A: LSLR Unit Costs
          Appendix B: Modeling Costs in the SafeWater LCR Model and Economic Impact and Analysis of the Previous Rule
          Appendix C: Detailed Costs Results
          Appendix D: Adverse Health Effects Associated with Lead Exposures
          Appendix E: Adverse Health Effects Associated with Copper Exposures
          Appendix F: Water Lead Level Analysis and Simulation
          Appendix G: Sensitivity Analysis for Blood Lead and IQ Benefits in Children
          Appendix H: Alternative Approaches to Estimating Changes in Blood Lead Levels in Adults
          Appendix I: Discussion of Additional Potentially Reduced Adverse Health Endpoints in Children
          Appendix J: Detailed Summaries of Studies That May Potentially Inform Concentration-Response Functions
          Appendix K: Estimating Value of an IQ Point
Tabular exhibits, most of which include a row with the formulas used to calculate the contents of each column and information sources for values that are not calculated in the exhibits.
Exhibits that illustrate methodologies of analyses as well as final LCRR requirements.
Supporting report and electronic spreadsheet files, as explained in Exhibit 1-2 below.
Exhibit 1-2: Supporting Report and Spreadsheet Files
                                   File Name
                                  Description
CWS Inventory Characteristics_Final Rule.xlsx
Provides inventory, milestone, violation, and treatment information from the SDWIS/Fed third quarter 2016 "frozen" dataset for 50,067 CWSs and how these data are used to provide baseline system characteristics described in Chapter 4 and Appendix B.
Derivation of Administrative Burden and Costs_Final Rule.xlsx
Provides one-time and ongoing administrative burden and costs associated with the previous and final rules for water systems and Primacy Agencies.
Derivation of Baseline CCT Characteristics_Final Rule.xlsx
Provides the number of entry points per system, baseline orthophosphate and baseline pH levels under the previous rule.
Derivation of CCT Study and Review Costs_Final Rule.xlsx
Provides EPA's assumptions regarding which systems will be required to conduct a CCT study and if applicable, if the study will be a desktop or demonstration study, and the estimated costs of these studies under the previous rule. Also, provides Primacy Agency CCT review-related activities for the previous and final rules.
Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water.pdf
Provides CCT costs for the final rule.
Derivation of Estimated Driving Distances_Final Rule.xlsx
Outlines EPA's approach for estimating the distance a water system would drive to a customer's home for lead sampling, site investigation, or other reasons.
Derivation of Failure to Meet LSLR Goals_Final Rule.xlsx
Calculates the burden and costs for CWSs serving > 10,000 people with a TLE to conduct outreach activities if they fail to meet their annual LSLR goal.
Derivation of Initial P90 Categorization_Baseline_Final Rule.xlsx
Assigns CWSs to one of three P90 categories using two approaches: A low estimate based on their lowest P90 level and high estimate based on their highest P90 level. These estimates represent the baseline condition before systems implement the requirements of the final LCRR.
Derivation of Initial P90 Categorization_CWS_NTNCWS Compare_Final Rule.xlsx
Assigns CWSs and NTNCWSs to one of three categories using two approaches: A low estimate based on their lowest P90 level and high estimate based on their highest P90 level. Compares the estimates of baseline conditions of CWSs to NTNCWs.
Derivation of Initial P90 Categorization_Final Rule.xlsx
Assigns CWSs to one of three categories using two approaches: A low estimate based on their lowest P90 level and high estimate based on their highest P90 level. For the systems with known LSLs, adjusts the P90 levels to simulate the requirement under the final LCRR for these systems to collect all samples from sites served by LSLs versus 50 percent as previously required and to collect a fifth liter sample in lieu of a first-draw sample.
Derivation of Initial P90 Categorization_ First Liter Option.xlsx
Assigns CWSs to one of three P90 categories using two approaches: A low estimate based on their lowest P90 level and high estimate based on their highest P90 level. For the systems with known LSLs, adjusts the P90 levels to simulate the requirements under the first-liter option in which systems with LSLs collect all first-liter samples from sites served by LSLs versus 50 percent as previously required.
Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx
Provides estimated burden and costs for lead sample collection, analysis, and reporting as well as assumptions and data sources for each estimate.
Derivation of LSL Number_CWS_Final Rule.xlsx
Calculates the number and percent of CWSs with LSLs, the average number of LSLs per system, the percent of service connections that are lead, and the total number of LSLs.
Derivation of LSLR Ancillary Costs_Final Rule.xlsx
Provides the derivation of costs associated with LSLR other than physical replacement including inventory, planning, and "paper replacements."
Derivation of LSLR Costs_Final Rule.xlsx
Provides the derivation of the LSL physical replacement costs, including detailed results from four surveys of LSLR costs as well as individual utility estimates. Also includes percentages for different replacement types.
Derivation of LSLR_Time_Span_Analysis_CWS_Final Rule.xlsx
Estimates the average length of time a CWS that is triggered into LSLR replaces LSLs under the previous LCR. The results of this analysis are also used for NTNCWSs.
Derivation of Pb Schedules_CWS_Final Rule.xlsx
Estimates baseline lead tap sampling schedules for CWSs using the SDWIS/Fed 3rd quarter 2016 "frozen" dataset starting in Year 4 of the 35-year analysis period and for the final LCRR starting in Year 5 for systems with P90 <= 15 ug/L.
Derivation of Pb Schedules_NTNCWSs_Final Rule.xlsx
Estimates baseline lead tap sampling schedules for NTNCWSs using the SDWIS/Fed 3rd quarter 2016 "frozen" dataset starting in Year 4 of the 35-year analysis period and for the final LCRR starting in Year 5 for systems with P90 <= 15 ug/L.
Derivation of POU Inputs_Final Rule.xlsx
Provides costing inputs for small CWSs and those NTNCWSs that select POU devices as their compliance option. Includes estimated number of required POU devices, development of a POU process, annual reporting, and Primacy Agency review.
Derivation of Probability_Sample_Above_15_First Liter Option.xlsx
Provides estimates of the likelihood of an individual tap sample being > 15 ug/L based on system size, LSL status, and P90 classification under the first-liter option, as described in Chapter 9. Also includes estimated burden and costs for response to samples > 15 ug/L.
Derivation of Probability_Sample_Above_15_Final Rule.xlsx
Provides estimates of the likelihood of an individual tap sample being > 15 ug/L based on system size, LSL status, and P90 classification under the final LCRR.
Derivation of Probability_SourceChange_Final Rule.xlsx
Provides the estimated likelihood that a CWS or NTNCWS will add a new source or change its primary source. Also includes reporting, review, and Primacy Agency consultation associated with this change.
Derivation of Probability_TreatmentChange_Final Rule.xlsx
Provides the estimated likelihood that a CWS or NTNCWS will add a new treatment. Also includes reporting, review, and Primacy Agency consultation associated with this change.
Derivation of Public Education Inputs_CWS_Final Rule.xlsx
Provides the derivation of the inputs used to estimate public education burden and costs under the previous rule and final LCRR for CWSs.
Derivation of Public Education Inputs_NTNCWS_Final Rule.xlsx
Provides the derivation of the inputs used to estimate public education burden and costs under the previous rule and final LCRR for NTNCWSs.
Derivation of School_Child Care Inputs_Final Rule.xlsx
Provides the derivation of the inputs used to estimate the burden and costs for CWSs to conduct a lead in drinking water testing program at schools and licensed child cares.
Derivation of State LSL Status_Final Rule.xlsx
Provides system-specific information for the subset of CWSs with known LSL status (either presence or absence of LSLs) based on data submitted by several Primacy Agencies and web searches. Also includes the geographic representativeness of states with known LSL status.
Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx
Provides the derivation of the inputs used to estimate burden and costs for system WQP sample collection, analysis, and reporting and Primacy Agency review.
Derivation of WQP Schedules_CWS_Baseline_Final Rule.xlsx
Estimates the initial WQP distribution system monitoring schedules under the previous rule for CWSs using the SDWIS/Fed 3rd quarter 2016 "frozen" dataset.
Derivation of WQP Schedules_CWS_Final Rule.xlsx
Estimates the initial WQP distribution system monitoring schedules under the final LCRR for CWSs using the SDWIS/Fed 3rd quarter 2016 "frozen" dataset.
Derivation of WQP Schedules_NTNCWS_Baseline_Final Rule.xlsx
Estimates the initial WQP distribution system monitoring schedules under the previous rule for CWSs using the SDWIS/Fed 3rd quarter 2016 "frozen" dataset.
Derivation of WQP Schedules_NTNCWS_Final Rule.xlsx
Estimates WQP distribution system monitoring schedules for NTNCWSs under the final LCRR using the SDWIS/Fed 3rd quarter 2016 "frozen" dataset.
Extent of P90 Data_Final Rule.xlsx
Provides the estimated percentage of CWSs with at least one reported P90 value during 2007  -  2015 and the percentage with known LSL status for three system size categories to determine if systems serving <= 3,300 people were underrepresented.
Final CoSTS 2-6-20.xlsx
Provides ASDWA's estimated increase burden estimates for Primacy Agencies to oversee the requirements of the LCRR as proposed.
General Cost Model Inputs_Final Rule.xlsx
Provides general costing inputs that include system and Primacy Agency labor costs, postage, paper, and envelopes.
NTNCWS Inventory Characteristics_Final Rule.xlsx
Provides inventory, milestone, violation, and treatment information from the SDWIS/Fed third quarter 2016 "frozen" dataset for 17,589 NTNCWS and how these data are used to provide baseline system characteristics described in Chapter 4 and Appendix B.
P90_Unknown LSL vs. LSL Known Status CWSs_Final Rule.xlsx
Compares the P90 data for the subset of systems with known LSLs status and reported P90 values to the larger set of CWSs with at least one reported P90 value (but unknown LSL status) in SDWIS/Fed for 2007  -  2015 to determine the representativeness of the subset.
VLS system-provided data tables for appendix.xlsx
Provides a summary of system-level data compiled by EPA for LSL estimates for systems serving more than 1 million people.
Acronyms: ASDWA = Association of State Drinking Water Administrators; CCT = corrosion control treatment; CoSTS = Costs of State Transactions Study; CWS = community water system; LCR = Lead and Copper Rule; LCRR = Lead and Copper Rule revisions; LSL = lead service line; LSLR = lead service line replacement; NTNCWS = non-transient non-community water system; P90 = lead 90[th] percentile level; POU = point-of use; SDWIS/Fed: Safe Drinking Water Information System/Federal Version; TLE = trigger level exceedance; VLS = very large system; WQP = water quality parameter.
Notes: These documents are available in the docket for the final rule under docket number EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
References
Executive Order 12866. 1993. Regulatory Planning and Review. Federal Register 58(190):51735, October 4, 1993. Available at https://www.reginfo.gov/public/jsp/Utilities/EO_12866.pdf.
Executive Order 13563. 2011. Improving Regulation and Regulatory Review. Federal Register 76(14):3821, January 21, 2011. Available at https://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdf.
National Toxicology Program (NTP). 2012. NTP Monograph: Health Effects of Low-Level Lead. U.S. Department of Health and Human Services. Office of Health Assessment and Translation. Division of the National Toxicology Program. https://ntp.niehs.nih.gov/ntp/ohat/lead/final/monographhealtheffectslowlevellead_newissn_508.pdf.
President's Task Force on Environmental Health Risks and Safety Risks to Children (Task Force). 2018. Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts. December 2018. https://www.epa.gov/sites/production/files/2018-12/documents/fedactionplan_lead_final.pdf.
United States Environmental Protection Agency (USEPA). 1991. Drinking Water Regulations; Maximum Contaminant Level Goals and National Primary Drinking Water Regulations for Lead and Copper; Final Rule. Federal Register 56(110): 26460. June 7, 1991. Washington, D.C.: Government Printing Office.
USEPA. 2013. Integrated Science Assessment for Lead. United States Environmental Protection Agency, Office of Research and Development. Research Triangle Park, NC. EPA/600/R-10/075F.
USEPA. 2018. 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities: A Training, Testing, and Taking Action Approach (Revised Manual). October 2018. Office of Water. EPA 815-B-18-007. https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water-toolkit.
USEPA. 2019a. America's children and the environment. EPA-100K19004. https://www.epa.gov/sites/production/files/2019-10/documents/ace2019-v17s.pdf.
USEPA. 2019b. Review of Dust-Lead Standards and the Definition of Lead-Based Paint. Federal Register 84(131):32632. July 9, 2019. Washington, D.C.: Government Printing Office. https://www.govinfo.gov/content/pkg/FR-2019-07-09/pdf/2019-14024.pdf.
USEPA. 2019c. Learn About Lead and Copper Rule Compliance. October 2019. Office of Water. EPA 815-F-19-007. https://www.epa.gov/sites/production/files/2019-10/documents/lcr_data_factsheet_10-9-2019.pdf.
USEPA. 2020a. Review of Dust-Lead Post-Abatement Clearance Levels  -  Proposed Rule. Federal Register 85(122):37810. June 24, 2020. Washington, D.C.: Government Printing Office. https://www.govinfo.gov/content/pkg/FR-2020-06-24/pdf/2020-13582.pdf.
USEPA. 2020b. Use of Lead Free Pipes, Fittings, Fixtures, Solder, and Flux for Drinking Water; Final Rule. Federal Register 85(170):54235. September 1, 2020. https://www.govinfo.gov/content/pkg/FR-2020-09-01/pdf/2020-16869.pdf.
Need for the Rule
Lead and copper enter drinking water primarily through the corrosion of distribution system and household plumbing materials that contain these metals. The goal of the Lead and Copper Rule (LCR) is to protect public health by reducing exposure to lead and copper in drinking water and the associated health risks from this exposure. The LCR accomplishes this primarily by controlling water corrosivity, thereby minimizing the leaching of these metals from household plumbing and drinking water distribution system components. The United States Environmental Protection Agency (EPA) has revised the LCR to strengthen the rule's implementation in the following areas: corrosion control treatment (CCT), lead service line replacement (LSLR), monitoring, public education (PE), and improved access to information.
The LCR was first promulgated in 1991 (USEPA, 1991). Since then, the LCR has undergone several revisions. In 2000, EPA published revisions pertaining to implementation issues to streamline monitoring and reporting requirements and reduce implementation burden (USEPA, 2000). In early 2004, EPA began a wide-ranging national review of LCR implementation, hereafter referred to as the "2004 National Review," to determine if there were continuing challenges related to elevated levels of lead in drinking water (see Section 2.1.5). The review identified several areas where there was confusion about implementation of the existing regulations. In October 2007, EPA promulgated the Short-Term Regulatory Revisions to the Lead and Copper Rule, hereafter referred to as the "LCR Short-Term Revisions" (USEPA, 2007). These revisions addressed several of the issues identified during the 2004 National Review. However, several issues remained that required additional data collection, research, analysis, and additional stakeholder involvement to support regulatory decisions. These issues have been addressed in the Lead and Copper Rule revisions (LCRR) regulatory process. The purpose of this document is to provide additional technical information on the final LCRR.
In addition to the 2004 National Review, several additional activities and sources of information and input have contributed to the development of the final LCRR, including but not limited to LCR stakeholder meetings held by EPA; input from the Science Advisory Board (SAB); recommendations made by the National Drinking Water Advisory Council (NDWAC) and its Lead and Copper Rule Working Group (LCRWG); comments received in response to consultations with state, local, and tribal governments and intergovernmental organizations in 2018 and in prior years; and comments received from the public in response to the November 13, 2019 proposed LCRR. These activities and sources of input are described further in Section 2.2 and collectively contributed to the development of the final LCRR as summarized in Chapter 1 and detailed in Chapter 3.
The remainder of this chapter is organized as follows:
 Section 2.1 provides the statutory requirements, a chronology of the regulatory actions, and initiatives affecting lead and copper in drinking water prior to the publication of the final LCRR.
 Section 2.2 provides a description of the activities following the LCR Short-Term Revisions that have informed development of the final LCRR.
 Section 2.3 discusses regulatory authority for the regulation.
 Section 2.4 discusses the economic rationale for the regulation.
Statutory Requirements, Regulatory Actions and National EPA Initiatives Affecting Lead and Copper in Drinking Water
This section provides a chronology of regulatory actions and initiatives affecting lead and copper in drinking water prior to the publication of the final LCRR.
Safe Drinking Water Act (SDWA) Requirements and Drinking Water Regulations Addressing Lead Prior to 1991
The SDWA (Public Law 93-523) was passed in 1974. The Act authorized EPA to establish National Primary Drinking Water Regulations (NPDWRs) for public water systems (PWSs). EPA published national interim primary drinking water regulations on December 24, 1975. Included among those regulations was a maximum contaminant level (MCL) of 0.05 mg/L for lead. The monitoring requirements for lead under these interim regulations focused on limiting the lead levels of drinking water entering the distribution system. The supporting materials for these interim regulations (USEPA, 1976) recognized to some degree that elevated lead levels were due to corrosion problems in the distribution system and household plumbing, however the regulation did not address this source of contamination.
Amendments to the SDWA in 1986 (Public Law 99-339) required the use of "lead free" materials in the installation or repair of pipes, fixtures, solders, and fluxes in any facility that provides water for human consumption. As defined in Section 1417(d), "lead free" solders and fluxes may not contain more than 0.2 percent lead, and "lead free" pipes, pipe fittings, and well pumps could not at the time contain more than 8.0 percent lead. All Primacy Agencies were required to implement the "lead ban" by August 6, 1988 (USEPA, 1987).
To limit children's exposure to lead, one of the most sensitive populations, Congress passed the Lead Contamination Control Act (LCCA) (Public Law 100-572) in 1988 that further amended the SDWA. The LCCA is aimed at the identification and reduction of lead in drinking water at schools and child care centers, including the recall of drinking water coolers with lead lined tanks and the publication of a list of drinking water coolers that were not "lead free." It required EPA to provide guidance to states and localities to test for and remedy lead contamination in drinking water at schools and child care centers. In addition, the LCCA required testing, recall, repair, and/or replacement of water coolers with lead-lined storage tanks or with other parts containing lead. One section of the LCCA that required states to establish program to conduct testing and remedial actions has since been repealed as part of the Water Infrastructure Improvements for the Nation Act (WIIN Act) (Public Law 114-322, Dec. 16, 2016; United States, 2016). Prior to the WIIN Act repeal of that section of the LCCA, in 1996, the U.S. Court of Appeals for the 5[th] Circuit  held that this now-repealed provision requiring States to establish programs for testing and remediating lead was unconstitutional under the Tenth Amendment because it directly compelled states to enact and enforce a federal regulatory program and provided no options for the states to decline. Since that time, EPA developed and revised its voluntary program for states, schools, and child cares to address lead in drinking water (USEPA, 2018). In 2016, the WIIN Act replaced the repealed version of Section 1464(d) of the SDWA with a new provision establishing a voluntary school and childcare lead testing grant program. 42 US.C. § 300j-24(d). Many states have also enacted their own testing programs.
Lead and Copper Rule (1991)
The 1986 SDWA Amendments directed EPA to revise the regulations for lead and copper in drinking water. In response to this directive, the Agency proposed revisions in 1988. On June 7, 1991, EPA promulgated the LCR (USEPA, 1991), and established a maximum contaminant level goal (MCLG) of zero for lead and 1.3 mg/L for copper. The LCR established treatment technique requirements instead of an MCL. Section 1412(b)(7)(A) of the SDWA authorizes EPA to "promulgate a national primary drinking water regulation that requires the use of a treatment technique in lieu of establishing an MCL, if the Administrator makes a finding that it is not economically or technologically feasible to ascertain the level of the contaminant." EPA's decision to promulgate a treatment technique rule for lead instead of an MCL in 1991 has been upheld by the United States Court of Appeals for the District of Columbia Circuit. American Water Works Association (AWWA) v. EPA, 40 F.3d 1266, 1270-71 (D.C Cir. 1994).
In establishing treatment technique requirements, the Administrator is required to identify those treatment techniques "which in the Administrator's judgment, would prevent known or anticipated adverse effects on the health of persons to the extent feasible." 42 U.S.C. § 300g-1(b)(7)(A). "Feasible" is defined in Section 1412(b)(4)(D) of the SDWA as "feasible with the use of the best technology, treatment techniques and other means which the Administrator finds after examination for efficacy under field conditions and not solely under laboratory conditions, are available (taking cost into consideration)." The 1991 LCR established requirements for PWSs to conduct tap sampling at households with plumbing materials containing lead and copper. The1991 LCR set an action level (AL) of 0.015 mg/L (or 15 ug/L) for lead and 1.3 mg/L (or 1,300 ug/L) for copper. The AL is exceeded if the concentration in more than ten percent of water samples (i.e., the 90[th] percentile level) collected at interior taps during any monitoring period is greater than 0.015 mg/L for lead or 1.3 mg/L for copper. Water systems that exceed the AL are not in violation of the LCR but these systems are required to take actions to reduce drinking water lead and copper exposure including CCT, PE, and LSLR.
SDWA Amendments (1996)
The 1996 Amendments to the SDWA added that "lead free" plumbing fittings and fixtures must meet standards established under Section 1417(e) (42 U.S.C. 300g - 6(e)). Section 1417(e) of the SDWA required EPA to accept a voluntary standard within a year or issue a regulation within two years. Furthermore, for the voluntary standard to be accepted, the Administrator must provide technical assistance to a qualified third-party in the development of the voluntary standard and associated testing protocols for examining lead leaching from new plumbing fittings and fixtures.
In 1996, the National Sanitation Foundation (NSF) developed National Sanitation Foundation/American National Standards Institute (NSF/ANSI) Standard 61, Section 9, which limits the amount of lead that can be leached from endpoint devices for water intended for human consumption (NSF, 2019). EPA published, in the Federal Register (FR) (USEPA, 1997), its view that NSF 61, Section 9 satisfied the requirement of Section 1417(e) . Specifically, EPA found that NSF 61, Section 9 is an established voluntary standard. Therefore, the obligation to issue a new regulation was not triggered. As a result, from August 1997 to January 2014, only those plumbing fixtures and fittings that had a maximum lead content of eight percent and were NSF/ANSI Standard 61, Section 9 certified could be defined as "lead free" per the SDWA.
Lead and Copper Rule Minor Revisions (2000)
On January 12, 2000, EPA published the final Lead and Copper Rule Minor Revisions (USEPA, 2000). The goals of the revisions were to streamline requirements, promote consistent national implementation, and in many cases, reduce the burden for community water systems (CWSs) and non-transient non-community water systems (NTNCWSs). The changes affected the following rule requirements: demonstration of optimal corrosion control, LSLR, PE, monitoring, analytical methods, reporting and recordkeeping, and special primacy considerations.
2004 National Review of the LCR Leading up to the LCR Short-Term Revisions of 2007
In early 2004, EPA began a wide-ranging review of the implementation of the LCR in response to high profile action level exceedances (ALEs) experienced by the District of Columbia Water and Sewer Authority (DC Water, formerly known as DC Water and Sewer Authority). The purpose of the 2004 National Review was to answer the following questions regarding lead in drinking water:
 Is this a national problem? Does a large percentage of the population receive water that exceeds the lead AL? Do many systems fail to meet the lead AL?
 How well has the rule worked to reduce lead levels in systems over the past 12 years, particularly in systems that had demonstrated high lead levels in the initial rounds of sampling?
 Is the rule effectively implemented, particularly with respect to monitoring and PE requirements?
The comprehensive review consisted of the following elements:
 A series of workshops to identify issues and gather comments and suggestions from stakeholders on particular topics,
 A review of data (i.e., reported 90[th] percentile levels) and LCR implementation by Primacy Agencies and utilities to evaluate the effectiveness of the rule, and
 A series of NDWAC meetings to address concerns related to PE requirements.
Elements of the Comprehensive Review
The following sections provide more detail regarding elements included in the comprehensive review of the LCR that contributed to the development of the LCR Short-Term Revisions. Workshop and meeting summaries mentioned in these sections are available in the docket for the proposed rule under EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
Review of Data to Evaluate the Effectiveness of the Rule (2004)
In 2004, EPA reviewed implementation of LCR requirements by Primacy Agencies. EPA asked Primacy Agency managers and staff, who have primary oversight responsibility, questions regarding implementation of various aspects of the LCR. The questions were centered on the following broad categories: sampling issues, calculation of the 90[th] percentile value, treatment issues, LSLR, PE, and enforcement (USEPA, 2005a).