(Population Served)
               Send certified mail to contact customers (per HH)
                      Contact customers by phone (per HH)
                Contact customers using door hangers
(per HH)
                                Annual burden
                                   (per HH)

                                hrs_fail_hh_op

                                       A
                                       B
                                       C
                                  D=(A+B+C)/3
10,001-50,000
                                                                            0.1
                                                                           0.25
                                                                           0.39
                                                                           0.23
50,001-100,000
                                                                            0.1
                                                                           0.25
                                                                           0.39
                                                                           0.23
100,001-1,000,000
                                                                            0.1
                                                                           0.25
                                                                           0.50
                                                                           0.27
>1,000,000
                                                                            0.1
                                                                           0.25
                                                                           0.67
                                                                           0.32
Acronyms: HH = household; LSLR = lead service line replacement.
Source: "Derivation of Failure to Meet LSLR Goal_Final Rule.xlsx."
Notes:
A: Assumed burden of 1 hour per 20 letters for all system size categories. Burden to prepare the letter is 20 letters per hour based on Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibits 35. Costs are associated with a certified letter (See worksheet, "Support Tables," Table S-2.) (USEPA, 2015b).
B: Assumed systems will spend 15 minutes (0.25 hours) discussing program with customers. This burden is consistent with that used for other contacts with customers, e.g., contact with customers who have a sample > 15 ug/L to arrange follow-up sample and discuss possible causes for elevated lead levels.
C: EPA assumed systems will use same doorhangers as used following disturbances (see "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet Water_Related Work for specific quotes).The burden includes the time to travel to the customer's home to deliver the door hangers. The Geographic extent of water systems from the 2006 Community Water Systems Survey, and Census Data. See "Derivation of Estimated Driving Distances_Final Rule.xlsx" for derivation of mileage. To develop the costs, the one-way driving distances of 4.9 miles for systems serving 10,001 to 100,000 people, 6.3 miles for systems serving 100,001  -  1,000,000 people, and 8.4 miles for those serving > 1,000,000 are divided by the assumed travel speed of 25 mph and multiplied by 2 to get the round-trip burden.

Exhibit 5-104 shows how EPA derived the cost for the required outreach for the first annual goal failure. The annual cost per household, cost_fail_hh, is provided in Column D. The cost is also multiplied by hh_remain_lsl.
Exhibit 5-104: Costs to Conduct Outreach in Response to First Failure to Meet LSLR Annual Goal ($/system)
                                  System Size
                              (Population Served)
               Send certified mail to contact customers (per HH)
                      Contact customers by phone (per HH)
                Contact customers using door hangers
(per HH)
                                  Annual cost
                                   (per HH)

                                 cost_fail_hh

                                       A
                                       B
                                       C
                                       D
10,001-50,000
                                                                          $5.38
                                                                             $0
                                                                          $5.50
                                                                          $3.63
50,001-100,000
                                                                          $5.38
                                                                             $0
                                                                          $5.50
                                                                          $3.63
100,001-1,000,000
                                                                          $5.38
                                                                             $0
                                                                          $7.01
                                                                          $4.13
>1,000,000
                                                                          $5.38
                                                                             $0
                                                                          $9.28
                                                                          $4.89
Acronyms: HH = household.
Source: "Derivation of Failure to Meet LSLR Goals_Final Rule.xlsx."
Notes:
A: Certified mail with electronic return receipt, single piece. Includes certified mail cost ($3.35), emailed signature receipt ($1.45), and first class postage ($0.49). (https://pe.usps.com/text/dmm300/Notice123.htm#_c109).
B: Systems will not incur any material costs for a phone call.
C: Includes $0.21 for the material costs of door hangers based on quotes from three vendors plus the round trip vehicle costs of $5.29 for systems serving 10,001 to 50,000 people, $6.80 for systems serving 100,001 to 1,000,000 people, and $9.07 for systems serving more than 1,000,000 people. For more information on door hanger costs see "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet, "Service Line Disturbances." For assumptions related to roundtrip travel see note C under Exhibit 5-103.

 Conduct activities in response to each additional failure to meet LSLR goal (hrs_fail_sys_op, cost_sys_hh). Systems that continue to fail to meet their goal in any subsequent concurrent year must select one of the three initial outreach activities and two additional activities. The additional outreach activities include: 1) social media campaign, 2) distribute information via mail to organizations representing plumbers and contractors, and 3) outreach to newspaper, television (TV), or radio. To estimate the burden and cost for the additional failures, EPA assumed systems:
 Would select the town hall meeting from the initial outreach activity list.
 Would have an equal probability of selecting a social media campaign, coordination with plumbing and contactor organization, and outreach to a newspaper.
 Would not select visiting targeted customers to discuss the LSLR program and opportunities for replacement as one of the methods for subsequent goal-based failures. This is a simplifying assumption because this activity is expressed on a per household basis, whereas all other activities for subsequent failures to meet the goal or expressed on a per system basis.
      Exhibit 5-105 shows how EPA derived the annual burden for each subsequent failure to meet the annual goal. The annual burden per system, hrs_fail_sys_op, is provided in Column E.
Exhibit 5-105: Burden to Conduct Additional Outreach in Response to Subsequent Failure(s) to Meet LSLR Goal (hrs/system)
                                  System Size
                              (Population Served)
                         Townhall Meeting (per system)
                      Social Media Campaign (per system)
Coordinate with organizations representing plumbers and contractors
(per system)
           Outreach to newspaper, television, or radio (per system)
                          Annual Burden (per system)

                                hrs_fail_sys_op

                                       A
                                       B
                                       C
                                       D
                              E=A+[(B+C+D)/3)*2]
10,001-50,000
                                                                           68.0
                                                                           76.0
                                                                            4.0
                                                                            0.5
                                                                            122
50,001-100,000
                                                                           88.0
                                                                          136.0
                                                                           33.0
                                                                            0.5
                                                                            201
100,001-1,000,000
                                                                          128.0
                                                                          136.0
                                                                           33.0
                                                                            0.5
                                                                            241
>1,000,000
                                                                          128.0
                                                                          136.0
                                                                           33.0
                                                                            0.5
                                                                            241
Source: "Derivation of Failure to Meet LSLR Goals_Final Rule.xlsx."
Notes:
A: See file, "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet, "Pb ALE_Other Activity Detail," Table 1: System Burden for Public Meetings and Table 4: System Burden for Additional PE Activities after a Lead ALE.
B: See file, "Derivation of Failure to Meet LSLR Goals_Final Rule.xlsx," worksheet, "Social Media Campaign" for detailed assumptions.
C: EPA assumed systems reach out to four groups. Assumes systems serving 10,001 to 50,000 people reach out via email (0.5 hrs) and phone (0.5 hrs), and large system reach out via email (0.5 hrs) and webinar (0.25 to post material and 1 hours to schedule webinar).
D: Assumed systems will pay for an ad in the newspaper. The burden is the same as that used for other outreach activities that are required for CWSs that exceed the lead AL. See "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet "Pb ALE_Other Activity Detail," Table 4.

Exhibit 5-106 shows how EPA derived the annual cost for the required outreach for each subsequent failure to meet the goal-based replacement rate. The annual cost per system, cost_fail_sys, is provided in Column E.
Exhibit 5-106: Cost to Conduct Additional Outreach in Response to Subsequent Failure(s) to Meet LSLR Goal (hrs/system)
                                  System Size
                              (Population Served)
                         Townhall Meeting (per system)
                      Social Media Campaign (per system)
Coordinate with organizations representing plumbers and contractors
(per system)
           Outreach to newspaper, television, or radio (per system)
                           Annual Cost (per system)

                                 cost_fail_sys

                                       A
                                       B
                                       C
                                       D
                              E=A+[(B+C+D)/3)*2]
10,001-50,000
                                                                           $211
                                                                             $0
                                                                             $0
                                                                         $3,660
                                                                         $2,651
50,001-100,000
                                                                           $669
                                                                           $300
                                                                             $0
                                                                         $8,090
                                                                         $6,263
100,001-1,000,000
                                                                         $2,337
                                                                           $300
                                                                             $0
                                                                         $8,090
                                                                         $7,930
>1,000,000
                                                                        $19,325
                                                                           $300
                                                                             $0
                                                                         $8,090
                                                                        $24,918
Source: "Derivation of Failure to Meet LSLR Goals_Final Rule.xlsx."
Notes:
A: See file, "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet, "Pb ALE_Other Activity Detail," Table 5: System Cost for Additional PE Activities after a Lead ALE.
B: See "Derivation of Failure to Meet LSLR Goals_Final Rule.xlsx," worksheet, "Social Media Campaign" for detailed assumptions.
C: EPA assumed systems reach out to four groups via phone and email and would not incur any non-labor costs.
D: Assumed systems will pay for an ad in the newspaper. The cost is the same as that used for other outreach activities that are required for CWSs that exceed the lead AL. See "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet "Pb ALE_Other Activity Detail," Table 5.

Exhibit 5-107 provides the SafeWater LCR model costing approach for LSL activities associated with failure to meet the goal-based replacement rate including additional cost inputs that are required to calculate these costs.
Exhibit 5-107: Failure to Meet Goal-based Replacement Rate Activities Cost Estimation in SafeWater LCR by Activity[1][,2]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th] - Range
Other Conditions

    Consult with Primacy Agency on activities to satisfy additional goal-based LSLR program outreach requirements
The total consulting hours per system multiplied by the system labor rate.

(hrs_consult_fail_op*rate_op)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS that does not meet its goal-based LSLR rate

(num_lslr_replace / num_lsl_base) < pp_lsl_replaced_vol_goal
Once a year
    Conduct activities in response to the first failure to meet LSLR goal
The number of households with remaining LSLs multiplied by the total of the hours per household times the system labor rate, plus the material cost per household.

hh_remain_lsl*((hrs_fail_hh_op*rate_op)+cost_fail_hh)

Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS that does not meet its goal-based LSLR rate for the first time

(num_lslr_replace / num_lsl_base) < pp_lsl_replaced_vol_goal
Once a year
    Conduct activities in response to each additional failure to meet LSLR goal
The hours per system multiplied by the system labor rate, plus the material cost per system.

((hrs_fail_sys_op*rate_op)+cost_fail_sys)

Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS that does not meet its goal-based LSLR rate for two or more times

(num_lslr_replace / num_lsl_base) < pp_lsl_replaced_vol_goal
Once a year
Acronyms: AL = action level; CWS = community water system; LSL = lead service line; LSLR = lead service line replacement; NTNCWS = non-transient non-community water system; PWS = public water system; TL = trigger level.
Notes:
[1] The data variables in this exhibit are defined previously in this section with the exception of:
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
[2] The system can discontinue the activities in this exhibit if: 1) the goal is met, 2) the system no longer exceeds the TL for two consecutive one-year tap sampling monitoring periods, or 3) the system has made at least two good faith efforts to contact all customers served by an LSL or galvanized requiring replacement about the LSLR program.
Estimate of national lead service line testing and replacement costs
Exhibit 5-108 and Exhibit 5-109 show the estimated annualized national cost, under the low and high cost scenarios, of developing the LSL inventory, and conducting the customer-initiated, and goal-based and mandatory LSLR programs under the previous LCR, the LCRR, and the incremental cost discounted at 3 and 7 percent, respectively. Note that mandatory program costs may be overestimated because the EPA analysis does not account for LSL replacements (from voluntary programs or emergency repair) that occur between a system's initial inventory and the date the system has its first ALE. If replacements occur during this time period that are not captured in the EPA analysis the model estimated annual number of LSL replacement required under the system's mandatory program will be too high. The discounted mandatory program costs also do not capture the year to year variation that can occur under the two-year rolling average replacement criterion and therefore may over or under estimate discounted costs.

                               Low Cost Estimate
                               High Cost Estimate

                                                                   Previous LCR
                                                                     Final LCRR
                                                                    Incremental
                                                                   Previous LCR
                                                                     Final LCRR
                                                                    Incremental
 LSL Inventory
                                                                             $0
                                                                     $6,318,000
                                                                     $6,318,000
                                                                             $0
                                                                    $10,109,000
                                                                    $10,109,000
 System LSLR Plan
                                                                             $0
                                                                       $304,000
                                                                       $304,000
                                                                             $0
                                                                       $395,000
                                                                       $395,000
 System LSLR (Mandatory)
                                                                       $600,000
                                                                    $15,550,000
                                                                    $14,950,000
                                                                    $26,777,000
                                                                    $62,417,000
                                                                    $35,641,000
 LSLR Ancillary Activities (Mandatory)
                                                                        $27,000
                                                                     $1,087,000
                                                                     $1,060,000
                                                                       $500,000
                                                                     $3,383,000
                                                                     $2,882,000
 System LSLR (Goal Based)
                                                                             $0
                                                                     $6,298,000
                                                                     $6,298,000
                                                                             $0
                                                                    $22,580,000
                                                                    $22,580,000
 LSLR Ancillary Activities (Goal Based)
                                                                             $0
                                                                       $755,000
                                                                       $755,000
                                                                             $0
                                                                     $1,524,000
                                                                     $1,524,000
 Activities Triggered by Not Meeting Goal
                                                                             $0
                                                                     $6,087,000
                                                                     $6,087,000
                                                                             $0
                                                                    $19,663,000
                                                                    $19,663,000
 System LSLR (Customer-initiated)
                                                                             $0
                                                                     $6,943,000
                                                                     $6,943,000
                                                                             $0
                                                                    $18,946,000
                                                                    $18,946,000
 LSLR Ancillary Activities (Customer-initiated)
                                                                             $0
                                                                     $1,030,000
                                                                     $1,030,000
                                                                             $0
                                                                     $1,224,000
                                                                     $1,224,000
 Total Annual PWS Lead Service Replacement Costs
                                                                       $628,000
                                                                    $44,372,000
                                                                    $43,744,000
                                                                    $27,277,000
                                                                   $140,242,000
                                                                   $112,965,000
 Household LSLR (Mandatory)
                                                                       $182,000
                                                                             $0
                                                                      $-182,000
                                                                     $5,466,000
                                                                             $0
                                                                    $-5,466,000
 Household LSLR (Goal based)
                                                                             $0
                                                                     $8,100,000
                                                                     $8,100,000
                                                                             $0
                                                                    $19,542,000
                                                                    $19,542,000
 Total Annual Lead Service Replacement Costs
                                                                       $810,000
                                                                    $52,472,000
                                                                    $51,662,000
                                                                    $32,743,000
                                                                   $159,784,000
                                                                   $127,041,000
Acronyms: LSL = lead service line; LSLR = lead service line replacement; PWS = public water system.
Note: Detail may not add exactly to total due to independent rounding.
Exhibit 5-108: National Annualized Lead Service Line Replacement Costs  -  All PWSs at 3 Percent Discount Rate

Exhibit 5-109: National Annualized Lead Service Line Replacement Costs  -  All PWSs
at 7 Percent Discount Rate

                               Low Cost Estimate
                               High Cost Estimate

                                                                   Previous LCR
                                                                     Final LCRR
                                                                    Incremental
                                                                   Previous LCR
                                                                     Final LCRR
                                                                    Incremental
 LSL Inventory
                                                                             $0
                                                                     $6,863,000
                                                                     $6,863,000
                                                                             $0
                                                                    $10,593,000
                                                                    $10,593,000
 System LSLR Plan
                                                                             $0
                                                                       $467,000
                                                                       $467,000
                                                                             $0
                                                                       $607,000
                                                                       $607,000
 System LSLR (Mandatory)
                                                                       $638,000
                                                                    $16,681,000
                                                                    $16,044,000
                                                                    $37,623,000
                                                                    $79,869,000
                                                                    $42,246,000
 LSLR Ancillary Activities (Mandatory)
                                                                        $29,000
                                                                     $1,249,000
                                                                     $1,220,000
                                                                       $704,000
                                                                     $4,438,000
                                                                     $3,734,000
 System LSLR (Goal Based)
                                                                             $0
                                                                     $6,676,000
                                                                     $6,676,000
                                                                             $0
                                                                    $28,204,000
                                                                    $28,204,000
 LSLR Ancillary Activities (Goal Based)
                                                                             $0
                                                                       $824,000
                                                                       $824,000
                                                                             $0
                                                                     $1,956,000
                                                                     $1,956,000
 Activities Triggered by Not Meeting Goal
                                                                             $0
                                                                     $6,636,000
                                                                     $6,636,000
                                                                             $0
                                                                    $25,589,000
                                                                    $25,589,000
 System LSLR (Customer-initiated)
                                                                             $0
                                                                     $6,442,000
                                                                     $6,442,000
                                                                             $0
                                                                    $17,189,000
                                                                    $17,189,000
 LSLR Ancillary Activities (Customer-initiated)
                                                                             $0
                                                                       $965,000
                                                                       $965,000
                                                                             $0
                                                                     $1,118,000
                                                                     $1,118,000
 Total Annual PWS Lead Service Replacement Costs
                                                                       $667,000
                                                                    $46,803,000
                                                                    $46,136,000
                                                                    $38,327,000
                                                                   $169,562,000
                                                                   $131,235,000
 Household LSLR (Mandatory)
                                                                       $193,000
                                                                             $0
                                                                      $-193,000
                                                                     $7,681,000
                                                                             $0
                                                                    $-7,681,000
 Household LSLR (Goal based)
                                                                             $0
                                                                     $8,587,000
                                                                     $8,587,000
                                                                             $0
                                                                    $24,409,000
                                                                    $24,409,000
 Total Annual Lead Service Replacement Costs
                                                                       $860,000
                                                                    $55,389,000
                                                                    $54,529,000
                                                                    $46,008,000
                                                                   $193,971,000
                                                                   $147,963,000
Acronyms: LSL = lead service line; LSLR = lead service line replacement; PWS = public water system.
Note: Detail may not add exactly to total due to independent rounding.

PWS POU-Related Costs
As discussed in Section <IP_ADDRESS>, CWSs serving 10,000 or fewer people and NTNCWSs with a lead 90[th] percentile above the TL must evaluate and recommend to their Primacy Agency which compliance alternative they would implement if they have a future lead ALE from among: 1) LSLR, 2) CCT installation/re-optimization, 3) POU device installation and maintenance, or 4) replacement of lead-bearing materials. For modeling purposes, EPA assumed that systems would choose the least costly option from among the first three alternatives. EPA did not evaluate the cost of replacing lead-bearing materials. The SafeWater LCR model calculates the annualized cost the system will face under each of these three options and selects the least costly alternative.
Those approved for the POU provision must develop a plan and implement the program if they have a future lead ALE. Note that once the POU option is started, the system must continue to implement this program regardless of their subsequent lead 90[th] percentile levels.
In addition to the cost to provide and maintain POU devices and educate customers on them, systems have associated ancillary public education and sampling costs. POU-related costs are grouped into two subsections:
 <IP_ADDRESS>: POU Device Installation and Maintenance
 <IP_ADDRESS>: POU Ancillary Activities
In addition, Section <IP_ADDRESS> provides the national annualized POU costs under the low cost and high cost scenarios at a 3 and 7 percent discount rate.
POU Device Installation and Maintenance
All costs in this category are grouped into one activity: a) provide, monitor, and maintain POU devices.
    Provide, monitor, and maintain POU devices (annual_pou_cost_hh). CWSs approved for the POU program must provide one POU device at each household they serve and continue to maintain the device. EPA determined the average number of households per system, which is equivalent to the number of POU devices by dividing the retail population served by all systems in each of the five size categories serving 10,000 people or fewer people (pws_pop) by the average number of people per household of (2.59 (numb_hh)) and then dividing by the number of systems per size category, as shown in Exhibit 5-110.
Exhibit 5-110: Average Number of Households and POU Devices per CWS
                                  System Size
                              (Population Served)
                                 # of Systems
                               Retail Population
                   Households (HH) per System Size Category
             Average HH per System (Equals Number of POU Devices)

                                    pws_pop

                                       A
                                       B
                                  C = B/2.59
                                    D = C/A
<=100
                                                                         12,046
                                                                        723,487
                                                                        279,339
                                                                             23
101-500
                                                                         15,307
                                                                      3,884,780
                                                                      1,499,915
                                                                             98
501-1,000
                                                                          5,396
                                                                      3,989,089
                                                                      1,540,189
                                                                            285
1,001-3,300
                                                                          8,035
                                                                     15,312,930
                                                                      5,912,328
                                                                            736
3,301-10,000
                                                                          4,974
                                                                     29,070,747
                                                                     11,224,227
                                                                          2,257
Acronyms: HH = household; POU = point-of-use.
Notes:
A,B: SDWIS/Fed third quarter 2016 "frozen" data set that includes information reported through June 30, 2016.
C: 2.59 is the average number of people per household for the year 2011 (United States Census Bureau, 2010). Table AVG1. Average Number Of People Per Household, By Race And Hispanic Origin, Marital Status, Age, And Education Of Householder: 2010. This corresponds to SafeWater data variable: numb_hh.

NTNCWSs must provide a POU device on each tap used for drinking water consumption. Exhibit 5-111 provides the estimated number of POU devices per NTNCWSs based on 11 types of NTNCWS service categories classified under five Internal Plumbing Code (IPC) categories (business, industrial, residential, daycare, and school). Two estimates are provided, a minimum that excludes the installation of POU on bathroom taps and a maximum that includes bathroom taps. Additional detail on EPA's approach is provided in "Derivation of POU Inputs_Final Rule.xlsx."
Exhibit 5-111: Minimum and Maximum Estimated Number of Taps Requiring POU Devices per NTNCWS
                                  System Size
                              (Population Served)
                         Minimum Number of POU Devices
                         Maximum Number of POU Devices

                                   numb_pou

                                       A
                                       B
<=100
                                                                              3
                                                                              9
101-500
                                                                              5
                                                                             23
501-1,000
                                                                             10
                                                                             56
1,001-3,300
                                                                             16
                                                                            117
3,301-10,000
                                                                             41
                                                                            482
10,001-50,000
                                                                            207
                                                                          2,910
50,001-100,000
                                                                             73
                                                                            366
100,001-1,000,000
                                                                            276
                                                                          1,636
> 1,000,000

Source: "Derivation of POU Inputs_Final Rule.xlsx."
Notes:
A: The minimum number of POU devices is based on the weighted average of number of taps excluding bathrooms. See Table A-1 in "Derivation of POU Inputs_Final Rule.xlsx," worksheet "NTNCWS_Cost Model_Inputs_Final Rule.xlsx."
B: The maximum number of POU devices is based on the weighted average of number of taps including bathrooms. See Table A-2 in "Derivation of POU Inputs_Final Rule.xlsx," worksheet "NTNCWS_Cost Model_Inputs_Final Rule.xlsx."

The number of POU devices (numb_pou) is multiplied by the unit cost of the POU device installation and maintenance (annual_pou_cost_hh) to produce the total cost. EPA used a modified version of the WBS model to calculate unit costs for POU devices that specifically remove lead. The WBS model includes the following cost components of a complete POU program:
 POU device purchase, and scheduling and installation labor;
 Labor for POU device maintenance; and
 Materials (replacement filters) for POU device maintenance.

EPA assumed 25 percent of households receive countertop units and 75 percent receive faucet mount units. The resulting estimated annual average cost ranges between $113 - $116 per household per year depending on the discount rate (3 percent or 7 percent) used. The derivation of this unit cost (annual_pou_cost_hh) is shown in detail in Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2020).
Exhibit 5-112 provides the SafeWater LCR model costing approach for installation and maintenance of POU devices including additional cost inputs that are required to calculate these costs.
Exhibit 5-112: Point-of-Use Device Installation and Maintenance Cost Estimation in SafeWater LCR by Activity[1]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th]  -  Range[1]
Other Conditions

    Provide, monitor, and maintain POU devices
Households per system multiplied by the unit cost of the POU device installation and maintenance.

(pws_pop/numb_hh)*annual_pou_cost_hh
The number of POU devices per system multiplied by the unit cost of the POU device installation and maintenance.

numb_pou*annual_pou_cost_hh
All
Model PWS installing a POU device
Once per year
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system; POU = point-of-use; PWS = public water system.
Notes:
[1] Once the POU option is started in response to exceeding the lead AL, systems must continue to implement this program regardless of their subsequent lead 90[th] percentile levels. POU installation occurs once with O&M costs continuing annually.
POU Ancillary Activities
EPA has developed costs for one-time ancillary PWS activities related to POU program development and on-going ancillary activities as shown in Exhibit 5-113. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of each activity follows the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font. In a few instances, some of these activities are conducted by the state instead of the water system. These activities are identified in the exhibit and further explained in the exhibit notes.
Exhibit 5-113: PWS Ancillary POU-Related Burden and Cost Estimates[1]
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
 Develop POU plan and submit to Primacy Agency (one-time)[2]
178 to 328 hrs for CWSs;
148 to 388 hrs for NTNCWSs
hrs_pou_plan_dev_op
Develop PE materials and submit to Primacy Agency (one-time)
3.5 hrs per CWS
3.5 to 20 hrs for NTNCWSs

hrs_pe_pou_op
Print POU education materials
Burden
0.0025 hrs/sample per CWS
1 hr/NTNCWS

Cost
$0.025 sample per CWS
$0.025 per NTNCWS
Burden
hrs_print_pe_pou_op
hrs_ntncws_distr_pe_pou_op

Cost
cost_print_pe_pou
cost_ntncws_distr_pe_pou

Obtain households for POU monitoring
0.5 hrs per sample for CWSs only

hrs_samp_volunt_pou_op
Deliver POU monitoring materials and instructions to participating households
Burden
0.25 hrs/sample per CWS

Cost
$6.85 sample per CWS
$0.025 per NTNCWS
Burden
hrs_discuss_samp_op

Cost
cost_pou_samp[3]
Collect tap samples after POU installation
CWS
Burden: 0.39 hrs/sample
Cost: $5.29

NTNCWS
0.5 hrs/sample
CWS
hrs_pickup_samp_op
cost_pickup_samp

NTNCWS
hrs_source_op
Determine if sample should be rejected and not analyzed
0.25 hrs/rejected sample for CWSs only
hrs_samp_reject_op
Analyze POU tap samples
In-House Burden
N/A

In-House Cost
N/A

Commercial Analysis
$21.58/ sample per CWS and NTNCWSs
In-House Burden
hrs_analyze_samp_op[3]

In-House Cost
cost_lab_lt_samp[3]

Commercial Analysis
cost_commerical_lab[3]
Prepare and submit sample invalidation request to Primacy Agency
2 hrs per sample per CWS and NTNCWS
hrs_samp_invalid_op
Inform customers of POU tap sample results
CWS
Burden: 0.05 hrs/sample
Cost: $0.58/sample

NTNCWS
Burden: 1 hr/sample
Cost: $0.025/sample
CWS
hrs_inform_samp_op
cost_cust_lt

NTNCWS
hrs_ntncws_inform_samp_op
cost_ntncws_cust_lt
Certify to Primacy Agency that POU tap results were reported to customers
0.66 to 1 hr/year per CWS and NTNCWS
hrs_cert_cust_lt_op
Prepare and submit annual report on POU program to Primacy Agency
1 to 2 hrs per CWS;
1 to 8 hrs per NTNCWS
hrs_pou_report_ann_prep_op
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system; PE = public education; POU = point-of-use.
Source: Data sources for each activity are provided following this exhibit.
Notes:
1 Requirements apply only to CWSs serving 10,000 or fewer people and NTNCWS that exceed the AL and have POU provision and maintenance as their approved compliance option.
[2] The rule does not explicitly include a POU plan. However, EPA assumed most systems would prepare this plan prior to implementing a POU program. This assumption may overestimate costs during the first year the program is implemented.
3 In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina, the state pays for the cost of bottles, shipping, analysis, and providing sample results to the system. Thus, the state will incur the burden and cost for these activities in lieu of the system.

    Develop POU plan and submit to Primacy Agency (hrs_pou_plan_dev_op). Although not required under the LCRR, EPA assumed that systems (i.e., CWSs serving 10,000 or fewer people and NTNCWSs without CCT) above the TL that select the POU option would develop a plan to provide and maintain POU devices for lead removal. EPA assumed the POU plan would include gathering background information and identifying plan elements, customer participation (CWSs only), installation, monitoring and maintenance, and logistics and administration. Each of these plan elements are included in the overall burden estimate and provided in Exhibit 5-114 and Exhibit 5-115 for CWSs and NTNCWSs, respectively.
Additional detail on each of these plan elements is provided in the file, "Derivation of POU Inputs_Final Rule.xlsx."
Exhibit 5-114: CWS Burden to Develop a POU Plan (hrs/system)
hrs_pou_plan_dev_op
                        System Size (Population Served)
                         Gather Background Information
                        Plan for Customer Participation
                             Plan for Installation
                     Plan for Monitoring & Maintenance
                    Plan for Logistics & Administration
                                     Total

                                       A
                                       B
                                       C
                                       D
                                       E
                                     F=A:E
<=100
                                                                             58
                                                                             30
                                                                             30
                                                                             50
                                                                             10
                                                                            178
101-500
                                                                             58
                                                                             30
                                                                             30
                                                                             50
                                                                             10
                                                                            178
501-1,000
                                                                            108
                                                                             60
                                                                             60
                                                                            100
                                                                              0
                                                                            328
1,001-10,000
                                                                            108
                                                                             60
                                                                             60
                                                                            100
                                                                              0
                                                                            328
>10,000
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
Source: "Derivation of POU Inputs_Final Rule.xlsx." This file provides the associated burden for the activities listed in Notes A through E.
Notes:
General: With the exception of reading the guidance (see note A) and planning for logistics and administration (see note E), CWSs serving more than 500 people are assumed to incur twice the burden than those serving 500 or fewer people.
A: Includes read and understand POU or point of entry (POE) Treatment Options for Small Drinking Water Systems (USEPA, 2006b) and identify considerations and options for their appropriate system type; prepare a draft outline of plan elements and submit for management and state approval, as applicable; present a draft outline of plan elements to system board/management bodies and incorporate feedback; and consult with a legal expert on property liability and additional insurance.
B: Includes identifying in the plan the types of customer access and maintenance agreements needed and their schedule for development; includes 2 hours of legal consultation.
C: Includes identifying the number of taps to treat and the schedule and customer priority for installation; identifying whether vendors or licensed plumbers, and certified operators will install the units and how they will be managed and tracked; and how and when arrangements for access to installation sites will occur and how they will be managed and tracked.
D: Includes description of vendor responsibilities and utility responsibilities for monitoring and maintenance of the POU units; unit maintenance frequencies and checklist for maintenance inspections; POU unit routine replacement frequencies and protocol for emergency reporting of problems and response; and incorporation of rule-specific monitoring requirements into the plan.
E: Includes description of contractual agreements and oversight responsibilities for lease agreements. Assumed this primarily affects CWSs serving 500 and fewer people because they would not have available staff for maintenance and monitoring of these units.
Exhibit 5-115: NTNCWS Burden to Develop a POU Plan (hrs/system)
hrs_pou_plan_dev_op
                        System Size (Population Served)
                         Gather Background Information
                        Plan for Customer Participation
                             Plan for Installation
                     Plan for Monitoring & Maintenance
                    Plan for Logistics & Administration
                                     Total

                                       A
                                       B
                                       C
                                       D
                                       E
                                     F=A:E
<=500
                                                                             58
                                                                              0
                                                                             30
                                                                             50
                                                                             10
                                                                            148
501-10,000
                                                                            108
                                                                              0
                                                                             60
                                                                             50
                                                                             10
                                                                            228
10,001-50,000
                                                                            208
                                                                              0
                                                                            120
                                                                             50
                                                                             10
                                                                            388
50,001- 1,000,000
                                                                            108
                                                                              0
                                                                             60
                                                                             50
                                                                             10
                                                                            228
Source: "Derivation of POU Inputs_Final Rule.xlsx."
Notes:
General: No NTNCWS serves more than 1 million people. Three NTNCWSs serve 50,001  -  1,000,000 people. These systems have fewer taps than the average estimated number for those serving 10,001 - 50,000 people. Thus, EPA assumed a similar burden for these three largest NTNCWSs as those serving 3,301 - 10,000 people. No NTNCWS serves > 1,000,000 people.
A: Includes read and understand POU or POE Treatment Options for Small Drinking Water Systems (USEPA, 2006b) and identify considerations and options for their appropriate system type; prepare a draft outline of plan elements and submit for management and Primacy Agency approval, as applicable; present a draft outline of plan elements to governing bodies and incorporate feedback; and consult with a legal expert on property liability and additional insurance.
B: Does not apply to NTNCWSs.
C: Includes identifying the number of taps to treat and the schedule for installation; identifying whether vendors or licensed plumbers, and electricians will install the units and how these services will be provided; and how and when arrangements for access to installation sites will occur and how they will be managed and tracked.
D: Includes description of vendor responsibilities for monitoring and maintenance of the POU units; unit maintenance frequencies and checklist for maintenance inspections; POU unit routine replacement frequencies and protocol for emergency reporting of problems and response; and incorporation of rule-specific monitoring requirements into the plan.
E: Includes description of contractual agreements and oversight responsibilities for lease agreements.

    Develop PE materials and submit to Primacy Agency (hrs_pe_pou_op). CWSs serving 10,000 or fewer people and NTNCWSs with a lead ALE that choose the POU option must implement the POU program including providing public education on the maintenance and use of POU device to all households they serve. EPA assumed systems serving 50,000 or fewer people and those serving more than 50,000 people will incur a one-time burden of 3.5 hours and 20 hours, respectively, to develop these PE materials and submit them to the Primacy Agency for review (hrs_pe_pou_op). Burden estimates are similar to those related to the development of other PE materials (e.g., general LSL information, educational materials for service line disturbances, etc.) and are based on tier 2 PN preparation burden (USEPA, 2015a).
    Print POU education materials (hrs_print_pe_pou_op, cost_print_pe_pou, hrs_ntncws_distr_pe_pou, cost_ntncws_distr_pe_pou). EPA estimated CWSs serving 10,000 or fewer people will require 0.0025 hours per household to print POU public education materials based on assumptions for production labor used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule, Exhibit 17 (USEPA, 2007). EPA assumed that this material would be provided in addition to the manufacturer's information that comes with the POU device. The estimated cost for systems to print POU PE material per household is $0.025 that is the cost of paper. EPA assumed that there will be no envelope or mailing costs because PE materials will be provided when the system provides the POU device. See "General Cost Model Inputs" for specific vendor paper quotes. EPA assumed NTNCWSs would provide materials via email and post materials publicly with an estimated burden of 0.5 hours to develop/send e-mail and an additional 0.5 hours to post the materials, for a total of 1 hour (hrs_ntncws_distr_pe_pou_op). NTNCWSs will also incur a cost for PE posted materials (cost_ntncws_distr_pe_pou) that will include paper costs of $0.025 based on costs from 3 vendors (see file "General Cost Model Inputs_Final Rule.xlsx" for more detail).
    Obtain households for POU monitoring (hrs_samp_volunt_pou_op). Under the POU program, systems must sample one-third of locations with POU devices annually. For CWSs, EPA assumed customers can collect these samples. EPA estimated that a CWSs will incur a burden of 0.5 hours to obtain customers for POU sampling. EPA also applied the same inflation percentages, from the assumption associated with lead tap sampling, to the number of required POU samples to account for the likelihood a customer does not collect the sample (10 percent, 1 - pp_hh_return_samp), the sample is rejected (5 percent, pp_samp_reject), or invalidated (0.6 percent, pp_samp_invalid). Refer to Section <IP_ADDRESS>.2, activity e) for additional detail.
    Deliver POU monitoring materials and instructions to participating households (hrs_discuss_samp_op, cost_pou_samp). EPA used the same data variables and inputs for CWSs to discuss proper sampling procedures with customers of 0.25 hours per sample (hrs_discuss_samp_op) as under the lead tap program. EPA also assumed systems will incur the same non-labor costs to provide a test kit (including bottles and instruction) and the kits to customers (cost_pou_samp) of $6.85 for CWSs serving 10,000 or fewer people as used for systems without LSLs under the tap sampling program (cost_5_lt_samp). EPA also applied the same inflation percentages to the number of samples to account for the likelihood a customer does not collect the sample (1 - pp_hh_return_samp), the sample is rejected (pp_samp_reject), or invalidated (pp_samp_invalid). Refer to Section <IP_ADDRESS>.2, activities e) and g) for additional detailed assumptions.
    Collect tap samples after POU installation (hrs_pickup_samp_op, cost_pickup_samp, hrs_source_op). EPA uses the same data variable and input for the burden and O&M cost for CWSs serving 10,000 or fewer to travel to a customer's home to pick-up the collected sample of 0.39 hours (hrs_pickup_samp) and $5.29 (cost_pickup_samp). Refer to Section <IP_ADDRESS>.2, activity h) for additional detailed assumptions. EPA also applied the same inflation percentages to the number of samples to account for the likelihoods a customer would not collect the sample (1 - pp_hh_return_samp), the sample is rejected (pp_samp_reject), or invalidated (pp_samp_invalid).
    For NTNCWSs, EPA uses the same data variable and input for the burden to collect POU sample as a source water sample of 0.5 hours/sample (hrs_source_op). Refer to Section <IP_ADDRESS>.2, activity z) for additional detailed assumptions. EPA also inflated the number of samples to account for invalidated samples (pp_samp_invalid).
    CWSs and NTNCWSs must collect tap samples at one-third of the households or taps with POU devices, respectively. See Exhibit 5-111 and Exhibit 5-112 for the estimated number of POU devices for CWSs and NTNCWSs, respectively.
    Determine if samples should be rejected and not analyzed (hrs_samp_reject_op). EPA used the same data variable and input, of 0.25 hours per sample (hrs_samp_reject_op), for the CWS's burden to review samples collected by customers to determine if they were collected properly or should be rejected and not submitted for analysis. EPA also applied the same inflation percentage of 5 percent to the number of samples to account for the likelihood a sample is rejected (pp_samp_reject).
    Analyze POU tap samples (hrs_analyze_samp_op, cost_lab_lt_samp, cost_commercial_lab). Based on input from laboratories, EPA assumed CWSs serving 10,000 or fewer people and all NTNCWSs will use commercial labs for sample analysis; therefore, these systems will not incur any in-house analytical burden (hrs_analyze_samp_op) or cost (cost_lab_lt_samp). Instead these systems will incur a cost of $21.58 per sample (cost_commercial_lab) to have their POU tap samples analyzed for lead by a commercial lab. That cost corresponds to the same cost input used for systems without LSLs under the lead tap sampling program (cost_5_commercial_lab). Refer to Section <IP_ADDRESS>.2, activity j) for additional detail. EPA also applied the same inflation percentage of 0.6 percent to the number of samples to account for the likelihood a sample is invalidated (pp_samp_invalid).
    Prepare and submit sample invalidation request to Primacy Agency (hrs_samp_invalid_op). EPA used the lead tap sampling data variable and input of 2 hours per request (hrs_samp_invalid_op) for the burden for CWSs and NTNCWSs to prepare and submit a sample invalidation request to their Primacy Agency. EPA assumed that Primacy Agencies will approve sample invalidation requests for the 0.6 percent of samples for which systems will submit these requests (pp_samp_invalid).
    Inform customers of POU tap sample results (hrs_inform_samp_op, cost_cust_lt, hrs_ntncws_inform_samp_op, cost_ntncws_cust_lt). EPA uses the same data variables and inputs for systems to provide the sampling results collected from POU taps as the lead tap sampling program. CWSs must report individual lead sample results to customers who participated in the sampling pool. EPA estimates that systems will require an average of 0.05 hours per customer (hrs_inform_samp_op). Systems are also assumed to mail these results at a cost of $0.58 (cost_cust_lt). For NTNCWSs, EPA assumed the systems will deliver materials via email to all customers and post in a public location at a burden of 1 hour for all system sizes (hrs_ntncws_inform_samp_op). EPA assumed NTNCWSs will incur paper costs of $0.025 (cost_ntncws_cust_lt) to post the flyer. Refer to Section <IP_ADDRESS>.2, activity l) for additional detailed assumptions regarding these four data variables.
    Certify to Primacy Agency that POU tap monitoring results were reported to customers (hrs_cert_cust_lt_op). For both the lead tap and POU monitoring programs, systems must prepare and submit an annual certification to their Primacy Agencies that they informed customers of their monitoring results. For the POU certification, EPA used the same data variable and input as used for the lead tap sampling program. EPA assumed a burden of 0.66 hours per year for CWSs and NTNCWSs serving 50,000 or fewer people and 1 hour for those serving more than 50,000 people. Refer to Section <IP_ADDRESS>.2, activity m) for additional detailed assumptions.
    Prepare and submit annual POU program Report to Primacy Agency (hrs_pou_report_ann_prep_op). Systems must prepare and submit a report of their POU program that includes monitoring results, any corrective actions if the TL was exceeded, and if requested by the Primacy Agency, any maintenance activities. The estimated burden and assumptions for CWSs and NTNCWSs are provided in Exhibit 5-116. EPA assumed systems would submit this report electronically to the Primacy Agency and thus would incur no paper or mailings costs.
Exhibit 5-116: PWS Annual POU Program Report Preparation and Submission Burden
                                  System size
                              (Population Served)
                                     CWSs
                                    NTNCWSs

                          hrs_pou_report_ann_prep_op

                                       A
                                       B
<=3,300
                                                                              1
                                                                              1
3,301-10,000
                                                                              2
                                                                              2
10,001-50,000
                                                                            N/A
                                                                              4
50,001-100,000
                                                                            N/A
                                                                              4
100,001-1,000,000
                                                                            N/A
                                                                              8
>1,000,000
                                                                            N/A

Source: "Derivation of POU Inputs_Final Rule.xlsx."
Notes:
A, B: Assume reporting and recording keeping is similar to April 2006 EPA guidance on POU/POE devices (USEPA, 2006b).
B: No NTNCWSs serves more than 1 million people. Thus, the burden for this size category is 0.

Exhibit 5-117 provides the SafeWater LCR model cost estimation approach for system ancillary POU system cost inputs including additional cost inputs that are required to calculate these costs.
Exhibit 5-117: PWS Point-of-Use Ancillary Costing Estimation in SafeWater LCR by Activity[1][,] 2, 3
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th] - Range[2]
Other Conditions

    Develop POU plan and submit to Primacy Agency
The total hours per system multiplied by the system labor rate.

(hrs_pou_plan_dev_op*rate_op)
Cost applies as written to NTNCWSs.
Above TL
Model PWS selecting POU installation and maintenance as their compliance option
One time
 Develop PE materials and submit to Primacy Agency for review
The total hours per system multiplied by the system labor rate.

(hrs_pe_pou_op*rate_op)
Cost applies as written to NTNCWSs.
Above AL
Model PWS installing POU device

One time
 Print POU education material
The hours per household multiplied by the system labor rate and the material cost.

(pws_pop/numb_hh)* ((hrs_print_pe_pou_op*rate_op)+ cost_print_pe_pou)

The hours per system multiplied by the system labor rate and the material cost.
((hrs_ntncws_distr_pe_pou_op*rate_op)+cost_ntncws_distr_pe_pou)
Above TL
Model PWS installing POU device
Once a year
 Obtain households for POU Monitoring
One third of households per system multiplied by the hours per sample and the system labor rate. The number of required samples (assumed to be one per household) is inflated to include those unreturned, invalidated, and rejected to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(((1/3)*(pws_pop/numb_hh))+(((1/3)*(pws_pop/numb_hh))*(1-pp_hh_return_samp))+(((1/3)*(pws_pop/numb_hh))*pp_samp_invalid)+(((1/3)*(pws_pop/numb_hh))*pp_samp_reject))*(hrs_samp_volunt_pou_op*rate_op)
Cost does not apply to NTNCWSs.
All
Model PWS installing POU device
Once a year
 Deliver POU monitoring materials and instructions to participating households[4]
One third of households per system multiplied by the total of the hours per sample to provide instructions times the system labor rate, plus the cost of materials per sample. The number of required samples (assumed to be one per household) is inflated to include those unreturned, invalidated, and rejected, to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

((((1/3)*(pws_pop/numb_hh)))+(((1/3)*(pws_pop/numb_hh))*pp_samp_invalid)+(((1/3)*(pws_pop/numb_hh))*(1-pp_hh_return_samp))+(((1/3)*(pws_pop/numb_hh))*pp_samp_reject))*((hrs_discuss_samp_op*rate_op)+cost_pou_samp)
Cost does not apply to NTNCWSs.
All
Model PWS installing POU device
Once a year
 Collect tap samples after POU installation
One third of households per system multiplied by the hours per sample and the system labor rate. The number of required samples (assumed to be one per household) is inflated to include those unreturned, invalidated and rejected to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

((((1/3)*(pws_pop/numb_hh)))+(((1/3)*(pws_pop/numb_hh))*pp_samp_invalid)+(((1/3)*(pws_pop/numb_hh))*(1-pp_hh_return_samp))+(((1/3)*(pws_pop/numb_hh))*pp_samp_reject))*((hrs_pickup_samp_op*rate_op)+cost_pickup_samp)
One third of the number of POU devices per system multiplied by the total of the hours per system times the system labor rate, plus the material cost. The number of required samples is inflated to include those invalidated to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(((1/3)*numb_pou)+(((1/3)*numb_pou)*pp_samp_invalid))*((hrs_source_op*rate_op)+cost_pou_samp)
All
Model PWS installing POU device
Once a year
 Determine if samples should be rejected and not analyzed
One third of households per system with a sample expected to be rejected (calculated by multiplying the total number of required samples by the likelihood of rejection) multiplied by the hours per sample and the system labor rate.

(((1/3)*(pws_pop/numb_hh))*pp_samp_reject)*(hrs_samp_reject_op*rate_op)
Cost does not apply to NTNCWSs.
All
Model PWS installing POU device
Once a year
 Analyze POU tap samples[3]
1/3 of households per system multiplied by the material cost of the commercial lab analysis per sample. All systems installing POUs are assumed to use commercial labs for sample analysis.

The number of samples (assumed to be one per HH) is inflated to include those invalidated, to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

 ((((1/3)*(pws_pop/numb_hh))+(((1/3)*(pws_pop/numb_hh))*pp_samp_invalid))*cost_commercial_lab)

1/3 of the number of POU devices per system multiplied by the material cost of the commercial lab analysis per sample. All systems installing POUs are assumed to use commercial labs for sample analysis. The number of required samples is inflated to include those invalidated to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

Systems will collect one sample per POU device.

(((1/3)*numb_pou)+(((1/3)*numb_pou)*pp_samp_invalid))*cost_commercial_lab
All
Model PWS installing POU device
Once a year
 Prepare and submit sample invalidation request to Primacy Agency
1/3 of HHs per system where a sample is expected to be invalid (calculated by multiplying the total number of required samples by the likelihood of invalidation) multiplied by the hours per sample and the system labor rate.

(((1/3)*(pws_pop/numb_hh))*pp_samp_invalid)*(hrs_samp_invalid_op*rate_op)
1/3 of the number of POU devices per system where a sample is expected to be invalid (calculated by multiplying the total number of required samples by the likelihood of invalidation) multiplied by the hours per sample and the system labor rate.

((1/3)*numb_pou)*pp_samp_invalid)*(hrs_samp_invalid_op*rate_op)
All
Model PWS installing POU device
Once a year
 Inform customers of POU tap sample results
1/3 of HHs per system multiplied by the total of the hours per sample times the system labor rate plus the material cost per sample.

((1/3)*(pws_pop/numb_hh))*((hrs_inform_samp_op*rate_op)+cost_cust_lt)
The hours per system multiplied by the system labor rate, plus the material cost.

(hrs_ntncws_inform_samp_op*rate_op)+ cost_ntncws_cust_lt
All
Model PWS installing POU device

Once a year
 Certify to Primacy Agency that POU tap sample results were reported to customers
The total hours per system to submit certification multiplied by the system labor rate.

(hrs_cert_cust_lt_op*rate_op)
Cost applies as written to NTNCWSs.
All
Model PWS installing POU device

Once a year
 Prepare and submit annual POU program report to Primacy Agency
The total hours reporting cost per system multiplied by the system labor rate.

(hrs_pou_report_ann_prep_op*rate_op)
Cost applies as written to NTNCWSs.
All
Model PWS installing POU device

Once a year
Acronyms: AL = action level; CWS = community water system; HH = household; NTNCWS = non-transient non-community water system; PE = public education; POU = point-of-use; PWS = public water system; TL = trigger level.
Notes:
[1] The data variables in this exhibit are defined previously in this section with the exception of:
 numb_pou: Number of POU devices per PWSs that elects POU option (Section <IP_ADDRESS>).
 pp_commercial_samp: Likelihood a sample will be analyzed by a commercial laboratory (Section <IP_ADDRESS>.2, activity J)).
 pp_lab_samp: Likelihood a sample will be analyzed in-house (Section <IP_ADDRESS>.2, activity j)).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
[2] Once the POU program is started in response to a lead ALE, systems must continue to implement this program regardless of their subsequent lead 90[th] percentile levels.
[3] For CWSs, the number of POU devices equals the number of households.
[4] The burden and costs to provide sample bottles (cost_pou_samp) under activity f) and conduct analyses under activity i) are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.
Estimate of PWS National Point-of-Use Device Installation and Maintenance Costs
The estimated national annualized POU device installation and maintenance costs for the final rule, under the low cost scenario, are $3,418,000 at a 3 percent discount rate and $3,308,000 at a 7 percent discount rate. The POU impacts of the final rule for the high cost scenario are $20,238,000 discounted at 3 percent and $19,928,000 discounted at 7 percent. Since POU costs are zero under the previous LCR, the incremental costs range from $3,418,000 to $20,238,000 at a 3 percent discount rate and from $3,308,000 to $19,928,000 at a 7 percent discount rate, under the low and high cost scenarios respectively (see Exhibit 5-1 and Exhibit 5-2).
PWS Lead Public Education and Outreach Costs
Systems will incur labor and non-labor costs to provide consumer notice in response to a single lead sample above 15 ug/L, to conduct public education requirements in response to a lead 90[th] percentile level, and to conduct additional education and outreach regardless of their lead 90[th] percentile level. These activities and associated costs are detailed in Sections <IP_ADDRESS> through <IP_ADDRESS>, respectively. Exhibit 5-133 provides the SafeWater LCR model cost estimation approach for system lead public education and outreach costs for these three subsections and is located at the end of Section <IP_ADDRESS>. Section <IP_ADDRESS> provides the national annualized lead public education and outreach costs at a 3 and 7 percent discount rate.
Note that public education requirements for systems with LSLs that pertain to general LSL outreach that is provided to customers with LSLs, galvanized requiring replacement, or that are served by lines of unknown material and targeted outreach that is required when they exceed the TL were previously discussed in Section <IP_ADDRESS> in activity k). Public education requirements for systems implementing a POU program were previously discussed in Section <IP_ADDRESS> in activities d), e), and f).
Consumer Notice in Response to a Lead Sample > 15 ug/L
EPA has developed costs for consumer notice in response to a lead sample above 15 ug/L, as shown in Exhibit 5-118. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of the unit burden follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-118: PWS Burden for Consumer Notification When Sample is > 15 ug/L
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
 Provide notice to customers with lead tap samples > 15 ug/L
0.25 hrs/customer contact
hrs_pe_above_al_prep_op
 Provide a copy of the 3 calendar day notice to the Primacy Agency
0.08 hrs/customer contact
hrs_above_15_notice_op
Source: "Derivation of Public Education Inputs_CWS_Final Rule.xlsx."

    Provide notice to customers with lead tap samples > 15 ug/L (hrs_pe_above_al_prep_op). Under the LCRR, systems must notify any customer with a sample result above 15 ug/L as soon as practicable but no later than 3 days after learning of the results. Exhibit 5-63 in Section <IP_ADDRESS> provides the likelihood a system will have a single sample above 15 ug/L for each of the three lead 90[th] percentile classifications (pp_above_al_bin_one, pp_above_al_bin_two, and pp_above_al_bin_three). Also refer to Chapter 4, Section <IP_ADDRESS> for a detailed discussion of EPA's approach for developing these percentages.
   Systems that choose to mail the notification must have the letters postmarked within three days. EPA assumed CWSs would elect to call customers and would incur a burden of 15 minutes or 0.25 hours per call (hrs_pe_above_al_prep_op). EPA assumed that NTNCWSs would use the same mechanism they currently use to inform their customers of sample results via posting and electronic notification but would provide this information sooner. To avoid double counting, EPA did not assign any additional burden or costs to NTNCWSs for this quicker notification but included the burden and costs as part of the Lead Tap Sampling Costs using hrs_NTNCWS_inform_samp_op and cost_NTNCWS_inform_lt.
    Provide a copy of the 3 calendar day notice to the Primacy Agency (hrs_above_15_notice_op). Systems must submit a copy of the 3 calendar day notification to their Primacy Agencies. EPA assumed systems would require 5 minutes or 0.083 hours to submit an electronic copy ($0) of this notice to the Primacy Agency (hrs_above_15_notice_op). EPA assumed a lower burden to provide this notice than required to notify the customer of their results of 0.25 hours via a phone call (hrs_pe_above_al_prep_op) discussed in activity a).
Activities Regardless of Lead 90[th] Percentile Level
EPA has developed CWS costs for activities associated with new public education requirements under the LCRR that are independent of a system's lead 90[th] percentile range, as provided in Exhibit 5-119. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of the unit burden and/or cost follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-119: PWS Burden and Cost for Public Education Activities that Are Independent of Lead 90[th] Percentile Levels
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
Update CCR language (one-time)
0.5 hrs/CWS serving <=3,300 people;
1 hr/CWS serving > 3,300 people
hrs_update_ccr_op
Develop new customer outreach plan (one-time)
4 hrs/CWS with LSLs serving <=50,000 people;
8 hr/CWS with LSLs serving > 50,000 people
hrs_cust_plan_op
Develop approach for improved public access to lead health-related information and tap sample results (one-time)
10 to 40 hours/CWS
hrs_pub_access_op
Establish a process for public access to information on LSL locations (one-time)
5 to 10 hours/CWS with LSLs
hrs_access_lsl_op
Maintain a process for public access to lead health information, LSL locations, and tap sample results
No LSLs
2 hrs/CWS serving <= 3,300 people
4 hrs/CWS serving > 3,300 people

With LSLs
6 hrs/CWS serving <= 3,300 people
12 hrs/CWS serving > 3,300 people
hrs_maint_lsl_op
Respond to customer request for LSL information
0.05 hrs/request;
$0/request
hrs_hh_request_op;
cost_hh_request
Respond to requests from realtors, home inspectors, and potential home buyers for LSL information
0.05 hrs/request;
$0/request
hrs_other_request_op;
cost_other_request
Develop list of state and local health agencies
CWSs
0.08 hrs/state and local health agency
hrs_hc_list_op
Develop lead outreach materials for state and local health agencies
3.5 hrs/CWS serving <=50,000 people;
20 hrs/CWS serving > 50,000 people
hrs_pub_devel_hc_op
Deliver lead outreach materials for state and local health agencies
CWSs
2 to 42 hrs/state and local health agency;
$5.29/ state and local health agency
hrs_hc_op;
cost_hc
Develop PE for disturbances and submit to Primacy Agency (one-time)
3.5 hrs/CWS with LSLs serving <=50,000 people;
20 hrs/CWS with LSLs serving > 50,000 people
hrs_pub_devel_wtr_op
Deliver PE during disturbances
0.083 hours/delivery;
$0.21/delivery
hrs_pub_deliv_wtr_op;
cost_pub_deliv_wtr_ed
Deliver filters and cartridges during disturbances and maintain them for 6 months
$44.00/household
cost_filter_hh
Acronyms: CCR = consumer confidence report; CWS = community water system; LSL = lead service lines; PE = public education.
Sources:
c)  - n):"Derivation of Public Education Inputs_CWS_Final Rule.xlsx." and USEPA. 2020.
o): Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water. July 2020. Office of Water.

    Update CCR language (hrs_update_ccr_op). EPA is requiring CWSs to update information about lead in the CCR. CWSs will incur a one-time burden (hrs_update_ccr_op) to update their CCR with the revised lead health effects language and for systems with LSLs to further update their materials to include information about a system's LSLR program and opportunities to replace LSLs. Systems with LSLs must also include information on how to access the LSL inventory and how to access the results of all tap sampling in the CCR. EPA assumed for:
 CWSs serving 3,300 or fewer, 50 percent will use CCRiWriter or a similar program to update their CCR and will incur no additional burden because the standard text will already be in the program. This percentage is based on current CCRiWriter users who are generally small systems. All other CWSs serving 3,300 or fewer are assumed to incur 1 hour, giving an average burden of 0.5 hours across all systems in this size category.
 CWSs serving more than 3,300 people will not use CCRiWriter and will incur a burden of 1 hour.
    Develop new customer outreach plan (hrs_cust_plan_op). In response to LCRR requirements, CWSs with LSLs will develop a new customer outreach plan. EPA estimated that systems serving 50,000 or fewer people will incur 4 hours of burden and those systems serving more than 50,000 people will take 8 hours to develop the plan.
    Develop approach for improved public access to lead health-related information and tap sample results (hrs_pub_access_op). CWSs will incur a one-time burden to develop improved public access to lead data that includes lead health-related data and tap monitoring results. EPA assumed that systems serving 3,300 or fewer people with no existing system website will make data available for the public in hard copy form at the system office. Systems serving more than 3,300 will update their existing websites. The one-time burden estimates are included in Exhibit 5-120.
Exhibit 5-120: One-Time Burden (per CWS) to Develop Approach for Improved Access to Lead Information
                                 System Size
                              (Population Served)
 Hours to Develop Approach for Improved Public Access to Lead Data (all CWSs)

                               hrs_pub_access_op
<=3,300
                                                                             10
3,301-10,000
                                                                             20
10,001-50,000
                                                                             25
50,001-100,000
                                                                             30
100,001-1,000,000
                                                                             35
>1,000,000
                                                                             40
            Acronyms: CWS = community water system.
            Source: "Derivation of Public Education Inputs_CWSs_Final Rule.xlsx."

    Establish a process for public access to information on LSL locations (hrs_access_lsl_op). Under the LCRR, CWSs must establish a way for customers and the public to access information on LSLs. EPA assumed that this will be a one-time burden that applies to all CWSs with LSLs regardless of lead 90[th] percentile level. EPA assumed systems serving 3,300 or fewer with no existing system website will make the information available in hard copy form at the system office and incur 5 hours to print materials and set up a viewing location. EPA assumed systems serving more than 3,300 people will provide access to information about lead line locations and the replacement program by adding content to an already existing website with links to materials and incur a burden of 10 hours per system. Note that the hours associated with determining locations of LSLs and establishing a replacement outreach program are described in Section <IP_ADDRESS>.
    Maintain a process for public access to health information, LSL locations, and tap sample results (hrs_maint_lsl_op). CWSs with LSLs would also incur an annual burden to maintain a way for the public to access lead health and LSL information. EPA assumed that:
 CWSs serving 3,300 or fewer people have no existing system website. Those without LSLs will require 2 hours to maintain lead-related data in hard copy files. Those systems with LSLs take an additional 4 hours to provide updated LSL locational information for a total annual burden of 6 hours.
 Systems serving more than 3,300 people will require 2 hours and 10 hours to update their website annually with health information and new LSL locational information, respectively, for a total annual burden of 12 hours.
    Respond to customer requests for LSL information (hrs_hh_request_op, cost_hh_request). CWSs will incur a per household burden to respond to LSL information requests from homeowners and residents (hrs_hh_request_op). EPA assumed CWSs with LSLs will respond by phone and spend an average of 3 minutes (0.05 hours) per request. EPA assumed systems without LSLs may still get inquiries, but the burden to be negligible. EPA assumed systems will not provide printed materials in response to these inquiries. Therefore, the cost to respond to request from households (cost_hh_request) is $0.
   EPA estimated the likelihood that that a particular household in a system with LSLs will request information about LSLs to be 0.0036 each year (pp_hh_request_lslr). This was computed as a weighted average over the 32-year period from year 4 through year 35 of the analysis, as shown in Exhibit 5-121. Underlying this estimate are the assumptions that these requests would come from 10 percent of households having young children (under six years of age) present in each year in those systems having LSLs. As shown in Exhibit 5-121, EPA estimated that in year 4, the likelihood that a household already has children under the age of six is 0.1156 (Column C, based on Columns A and B). EPA also estimated that the likelihood a new child will be born at a household each year for years 5 through 35 is 0.0337 (Column E, based on Columns D and A). Column F (using the results in Columns C and E) shows the calculation of the weighted average likelihood of a child under six being present in a given household in each of the 32 years of the analysis period. Lastly, Column G applies the assumption that only 10 percent of those households will request LSL information.
Exhibit 5-121: Likelihood that a Resident Will Request Information about LSLs
                     Total Households in the United States
                 Households with Children under Six Years Old
       Likelihood a Household Has Children under Six Years Old in Year 4
                                Births per year
            Likelihood of a Birth per Household per Year in Years
                                    5 to 35
32-Year Weighted Average Likelihood a Household has Children under Six Years Old Each Year
Likelihood that a Household Having Children under Six Will Request LSL Information Each Year
                                       A
                                       B
                                   C = (B/A)
                                       D
                                   E = (D/A)
                               F = (C+(31*E))/32
                                   G = F*0.1

                              pp_hh_request_lslr
                                                                    118,208,250
                                                                     13,661,829
                                                                         0.1156
                                                                      3,988,076
                                                                         0.0337
                                                                         0.0363
                                                                         0.0036
Acronyms: LSL = lead service line.
Sources:
A-C: Derived from United States Census Bureau, 2015 American Community Survey 1-Year Estimates. Available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
D: A total of 3,988,076 births were registered in the United States in 2014, up 1 percent from 2013. The number of births rose among each of the largest race and Hispanic origin groups (non-Hispanic white, non-Hispanic black, and Hispanic women) from 2013 to 2014. Available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.

    Respond to other requests for LSL information (hrs_other_request_op, cost_other_request). CWSs with LSLs must also respond to requests for LSL information from other parties (e.g., realtors, home inspectors, and potential homebuyers). EPA assumed the same burden of 0.5 hours to respond to these requests by phone as assumed for responding to a request from a homeowner (hrs_hh_request_op). EPA assumed systems without LSLs may still get inquiries, but that the burden will be negligible. EPA assumed systems will not provide printed materials in response to these inquiries. Therefore, the material cost to respond to other LSL information requests (cost_other_request) is $0.
   EPA conducted the following steps to determine the estimated number of requests that systems will receive each year from other parties (numb_other_request).
 Determined the percentage of households with children under the age of 6 that moved using United States Census Bureau data from 2014, as shown in Exhibit 5-122.
Exhibit 5-122: Households (HHs) with Children under 6 and That Moved
                              Total number of HHs
                        Total number of HHs that moved
                      Total HHs with any children under 6
                Total HHs with any children under 6 that moved
                         Percent of all HHs that moved
              Percent of HHs with any children under 6 that moved
                                       A
                                       B
                                       C
                                       D
                                E = (B/A)*100%
                                F = (D/A)*100%
                                                                         50,730
                                                                          6,549
                                                                         14,759
                                                                          2,788
                                                                         12.91%
                                                                          5.50%
  Source: United States Census Bureau, Current Population Survey, 2014 Annual Social and Economic Supplement, Table 8. Available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.

 Multiplied the percentage of households with children under the age of 6 that moved by the number of households per system (numb_hh). EPA assumed that other parties would request LSL information on 10 percent of the resulting number of households. The resulting number of requests (numb_other_request) is provided in Exhibit 5-123.
Exhibit 5-123: Number of LSLR Information Requests from Realtors, Home Inspectors, and Potential Home Buyers
                        System Size (Population Served)
                                Number of CWSs
                           Total Population Served
                          Average Population per CWS
                          Average Households per CWS
                          Number of requests per CWS

                                       A
                                       B
                                    C = B/A
                                   D=C/2.59
                                E=D*5.50%*0.1%

                                    pws_pop
                                    numb_hh
                              numb_other_request
<=100
                                                                         12,046
                                                                        723,487
                                                                             60
                                                                             23
                                                                              0
101-500
                                                                         15,307
                                                                      3,884,780
                                                                            254
                                                                             98
                                                                              1
501-1,000
                                                                          5,396
                                                                      3,989,089
                                                                            739
                                                                            285
                                                                              2
1,001-3,300
                                                                          8,035
                                                                     15,312,930
                                                                          1,906
                                                                            736
                                                                              4
3,301-10,000
                                                                          4,974
                                                                     29,070,747
                                                                          5,845
                                                                          2,257
                                                                             12
10,001-50,000
                                                                          3,331
                                                                     72,870,205
                                                                         21,876
                                                                          8,446
                                                                             46
50,001-100,000
                                                                            550
                                                                     38,134,020
                                                                         69,335
                                                                         26,770
                                                                            147
100,001-1,000,000
                                                                            407
                                                                     98,526,569
                                                                        242,080
                                                                         93,467
                                                                            514
>1,000,000
                                                                             21
                                                                     42,043,440
                                                                      2,002,069
                                                                        772,999
                                                                          4,248
Notes:
A, B: SDWIS/Fed third quarter 2016 frozen data set, current through June 30, 2016.
D: Estimated as 2.59 people per household (numb_hh) for the year 2010 (United States Census Bureau, 2010). Table AVG1. Average Number of People Per Household, By Race and Hispanic Origin, Marital Status, Age, And Education Of Householder: 2010. Available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
E: Assumed 10 percent of households with children ages 6 and under that moved from Col F, Exhibit 5-123 (or 5.5 percent) would request information.

    Develop list of state and local health agencies (hrs_hc_list_op). All CWSs must conduct annual outreach to state and local health agencies to discuss the sources of lead in drinking water, health effects of lead, steps to reduce exposure to lead in drinking water, and information on find-and-fix activities. EPA expects CWSs will work with their Primacy Agencies to conduct increased lead outreach to health care agencies. Systems will incur a one-time upfront burden to develop an initial list of state and local health departments in their service area. EPA assumed systems would require 5 minutes for each health agency or 0.08 hours per agency, which is the same burden the Agency used to estimate the burden to develop an initial contact list of schools and child cares for the lead in drinking water testing program (hrs_school_identify_op) in activity cc) of Section <IP_ADDRESS>.1. The burden per health agency is multiplied by the number of health agencies (numb_ha +1), shown in Exhibit 5-124, to develop the unit cost.
Exhibit 5-124: Estimated Number of Health Agencies
                                 System Size
                              (Population served)
                         # of Organizations per system

                                  numb_ha +1
<=100,000
                                                                              2
100,001  -  1,000,000
                                                                              4
>1,000,000
                                                                             20
       Source: "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet, Pb ALE_Recipients, Table 1a, Column E. EPA assumed each system would contact one additional state health agency.

    Develop lead outreach materials for state and local health agencies (hrs_pub_devel_hc_op). All CWSs are assumed to incur burden to develop lead outreach materials that will be distributed to state and local health agencies. EPA assumed systems will incur the same burden to develop these materials as other outreach materials. The burden estimate is 3.5 hours for systems serving 50,000 or fewer people and 20 hours for those serving more than 50,000 people, e.g., LSL general outreach materials (hrs_pe_lsl_gen_develop_op; Section <IP_ADDRESS>, activity c)).
    Deliver lead outreach to state and local health agencies (hrs_hc_op, cost_hc). EPA assumed CWSs would incur an annual burden to produce and distribute a report that includes a cover letter, the outreach materials developed under activity k), and the results of any school testing and find-and-fix activities in response to a sample above 15 ug/L (as previously discussed in Section <IP_ADDRESS> and Section <IP_ADDRESS>.3, respectively). Systems will also incur annual burden to make any necessary updates to the list of organizations. The resulting annual burden estimates for conducting outreach to health care agencies are provided in Exhibit 5-125.
Exhibit 5-125: Annual CWS Burden (per system) to Conduct Outreach to State and Local Health Agencies
                        System Size (Population served)
                         # of Organizations per system
                       Production Time per organization
                              Distribute Letters
                         Update List of Organizations
                                     Total

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

                                  numb_ha + 1

                                   hrs_hc_op
<=3,300
                                       2
                                       1
                                       2
                                       0
                                       2
3,301-100,000
                                       2
                                       1
                                       2
                                       1
                                       3
100,001-1,000,000
                                       4
                                       1
                                       4
                                       2
                                       6
>1,000,000
                                      20
                                       2
                                      40
                                       2
                                      42
Notes
A: See Exhibit 5-125.
B: EPA assumed systems would require 1 hour and 2 hours to prepare a cover letter and assemble outreach materials to health agencies, and the results of any school testing and find-and-fix activities in response to a sample above 15 ug/L for systems serving 1 million people or fewer and more than 1 million people, respectively.
D: EPA assumed zero burden for systems serving 3,300 or fewer people. For CWSs serving 3,301 to 100,000 people, EPA assumed an annual burden of 1 hour per system to update the list of organizations. For systems serving more than 100,000 people, EPA assumed an annual burden of 2 hours per system.

EPA assumed systems will deliver the information to state and local health departments via certified mail at an estimated cost of $5.38 per organization (cost_hc) that includes paper ($0.025), envelope ($0.067), and certified mail ($5.29).
    Develop PE materials for disturbances of service lines and submit to Primacy Agency (hrs_pub_devel_wtr_op). CWSs with LSLs must send public education to customers when there is scheduled water-related work that could result in disturbances of service lines and will incur a one-time burden to develop materials. EPA assumed:
 All CWSs with LSLs will develop these materials.
The development of PE materials is similar across all types of public education because systems will use EPA-developed templates (see activity i) above for a more detailed discussion).
Systems serving 50,000 people or fewer will incur a one-time burden of 3.5 hours.
Systems serving more than 50,000 people will adapt the templates and incur a one-time burden of 20 hours.
    Deliver PE materials during disturbances of service lines (hrs_pub_deliv_wtr_op, cost_pub_deliv_wtr_ed). CWSs that cause disturbances to a lead, galvanized requiring replacement, or lead status unknown service line will also incur an annual burden to deliver public education to impacted households about the potential for elevated lead levels in drinking water as a result of the disturbance. The annual burden to deliver public education (hrs_pub_deliv_wtr_op) is assumed to be 5 minutes per delivery (0.083 hours). Systems are assumed to provide the messaging on door hangers that they will distribute when they are in the area conducting work. The average cost of doorhangers is $0.21 based on quotes from three vendors (cost_pub_deliv_wtr_ed). See "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet "Water_Related Work" for specific quotes.
   EPA assumed that 5.9 percent of households will be impacted annually by disturbances and would receive this public education (perc_hh_water_wrk) based on the estimated life of a water main, meter, and other service line replacements provided by Massachusetts Water Resources Authority. Utilizing these data, EPA assumed an average 17-year life of a meter. CWSs would replace a meter at an annual rate of 5.9 percent.
    Deliver filters and cartridges during disturbances of service lines and maintain them for 6 months (cost_filter_hh). Systems are required to provide these filters whenever there is a physical disturbance of an LSL, galvanized requiring replacement, or lead status unknown systems that involves replacement of a meter, gooseneck, pigtail, or other connector that entails disconnecting on and reconnecting the LSL. EPA assumes the likelihood of these disturbances to be 5.9 percent (perc_hh_water_wrk).
    EPA assumes that the pitchers and POU filters delivered to each resident to use for six months following LSLR will cost $44 on average (including shipping and filter replacement). Although many pitchers come with filters that will provide lead removal for more than six months, the average cost includes a filter replacement cost for those that do not last six months.
Public Education Activities in Response to Lead ALE
The LCRR retains the public education requirements of the previous rule for systems that exceed the lead AL and adds a requirement for systems to update their mandatory PE language. EPA has developed system costs for these activities, as provided in Exhibit 5-126. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of the unit burden follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-126: PWS PE Burden in Response to Lead ALE
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
Update mandatory language for lead ALE PE and submit to Primacy Agency for review (one-time)
3.5 hrs/PWS serving <=50,000 people;
20 hrs/PWS serving > 50,000 people
hrs_pe_al_devel_op
Deliver lead ALE PE materials to all customers
CWSs
0.0025 hours/household;
$0.21 to $0.30/CWS

NTNCWSs
1 hr/NTNCWS
$0.025/NTNCWS
CWSs
hrs_distr_edu_op; cost_pe_lcr_delivery

NTNCWSs
hrs_ntncws_distr_edu_op; cost_ntncws_pe_lcr_delivery
Contact public health agencies to obtain additional organizations and update recipient list
0.5 hrs/CWSs serving <=3,300 people;
1.5 hrs/CWS serving 3,301 to 100,000 people;
2.5 hrs/CWS serving > 100,000 people
hrs_ha_op
Notify public health agencies and other organizations
0.0025 hours/organization;
$5.38/organization

hrs_distr_agencies_pe_op; cost_pe_lead_ale
Post notice to website
0.5 hrs/CWSs serving > 100,000 people
hrs_web_op
Consult with Primacy Agency on other PE activities
2 hrs/CWS
hrs_ale_consult_op
Implement other PE activities
1.9 to 1,037 hrs/CWS;
$24.64 to $159,000/CWS
hrs_ale_other_op;
cost_ale_other
Prepare press release
10 hrs/press release per CWS serving > 3,300 people;
$0/press release
hrs_pr_op;
cost_pr
Certify to Primacy Agency that lead outreach was completed
CWSs
2 hrs/CWS serving <=50,000 people;
3 hrs/CWS serving > 50,000 people

NTNCWSs
0.66 hrs/NTNCWS serving <=50,000 people;
1 hr/NTNCWS serving > 50,000 people

CWSs
hrs_pe_certify_quarterly_op

NTNCWSs
hrs_cert_outreach_annual_op
Acronyms: ALE = action level exceedance; CWS = community water system; NTNCWS = non-transient non-community water system; PE = public education; PWS = public water system.
Sources:
p), q) & x): "Derivation of Public Education Inputs_CWS_Final Rule.xlsx"; "Derivation of Public Education Inputs_NTNCWS_Final Rule.xlsx."
r)-w) : "Derivation of Public Education Inputs_CWS_Final Rule.xlsx."

    Update mandatory language for lead ALE PE (hrs_pe_al_devel_op). Under the LCRR, CWSs and NTNCWSs with lead ALEs must update their mandatory health effects language, and those that also have LSLs must include information about their LSLR program and opportunities to replace LSLs. EPA assumed a one-time burden of 3.5 hours for systems serving 50,000 or fewer and 20 hours per systems serving more than 50,000 people to update these materials. These values are the same as used for other types of PE material updates, e.g., CCR language updates. See Section <IP_ADDRESS>, activity j) above for an outline of the rationale for the burden estimates.
    Deliver lead ALE PE materials to all customers (hrs_distr_edu_op, cost_pe_lcr_delivery, hrs_ntncws_distr_edu_op, cost_ntncws_pe_lcr_delivery). The LCRR retains the prior PE requirements for CWSs to distribute PE to all households they serve (see Exhibit 5-124 for the estimated number of households (numb_hh). EPA estimates CWSs would require 15 minutes per 100 copies (0.0025 hours/household) to distribute PE materials (hrs_distr_edu_op). The estimate is based on assumptions for production labor used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule, Exhibit 17 (USEPA, 2007). CWSs will also incur the following material cost associated with delivery of annual lead PE in the water bill. EPA assumed 50 percent of systems will include lead public education in the water bill and only incur an additional cost for paper ($0.025). The other 50 percent will mail a pamphlet and incur costs for paper ($0.025), envelope ($0.067), and postage ($0.49). Systems serving more than 500 people will deliver more than 200 pamphlets and qualify for bulk-rate postage ($0.30). Thus, the average annual delivery cost per household (cost_pe_lcr_delivery) is $0.30 for CWSs serving 500 or fewer people and $0.21 for CWSs serving more than 500 people. The cost formula is shown below for:
 CWSs serving <= 500 people = ($0.025*50%) + (($0.025 + $0.067 + $0.49) * 50%) = $0.30.
 CWSs serving > 500 people = ($0.025*50%) + (($0.025 + $0.067 + $0.30) * 50%) = $0.21.
   The LCRR also retains the prior public education requirements for NTNCWSs following a lead ALE. NTNCWSs are subject to different requirements for public education delivery than a CWS. NTNCWSs are subject to annual requirements and can deliver material via email and public posting, and, therefore, incur a different burden than CWSs. EPA assumed that NTNCWSs will deliver materials via email and post materials publicly with an estimated burden of 0.5 hours to develop/send e-mail and an additional 0.5 hours to post the materials, for a total of 1 hour (hrs_ntncws_distr_edu_op). NTNCWSs will also incur a cost for public education posted materials (cost_ntncws_pe_lcr_delivery) that will include paper costs of $0.025 based on costs from 3 vendors (see file "General Cost Model Inputs_Final Rule.xlsx" for more detail).
    Contact public health agencies to obtain additional organizations and update recipient list (hrs_ha_op). CWSs must contact local health care agencies to obtain a list of additional organizations that serve at-risk populations. The estimated number of health agencies (numb_ha) is provided in Exhibit 5-125. EPA assumed that systems on average spend 30 minutes (0.5 hours) per health agency by phone or person to obtain a list of additional community-based organization that should be contacted in response to a lead ALE (hrs_ha_op). EPA assumed this contact would result in additional burden to update the list of organizations for systems serving more than 3,300 people. Specifically:
 Systems serving 3,301 to 100,000 people would incur an additional annual burden requirement of 1 hour per system to update the list of organizations for a total annual burden of 1.5 hours.
 Systems serving more than 100,000 people would incur an additional burden of 2 hours per system to update the list of organizations for a total of 2.5 hours.
    These estimates are based on Appendix H-3 in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (USEPA, 2007).
    Notify public health agencies and other organizations (hrs_distr_agencies_pe_op, cost_pe_lead_ale). CWSs must provide public education materials to facilities that include but are not limited to local health departments, schools, child cares, and medical providers that offer services to pregnant women, children, and infants to better reach these at-risk populations and their caregivers (numb_lcr_other_org). This input is provided in Exhibit 5-127.
 Estimated hours to conduct outreach per organization. EPA assumed systems would require 15 minutes per 100 copies (0.0025 hours/organization) to produce the outreach for public health agencies and other organizations in response to a lead ALE (hrs_distr_agencies_pe_op). This estimate is based on assumptions for production labor used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (Exhibit 17) (USEPA, 2007).
 Notify public health agencies and other organizations. EPA assumed CWSs will send one pamphlet per health agency and other organizations and ask these organization to make copies. EPA assumed the information is delivered via certified mail at an estimated cost of $5.38 per organization. This total unit cost includes paper ($0.025), envelope ($0.067), and certified mail ($5.29) (cost_pe_lead_ale).
Exhibit 5-127: Number of Local Health Agencies, Schools, Child Cares, and Targeted Medical Providers Proportionally Distributed by CWS Population Served
                        System Size (Population Served)
                                 # of Systems
                               Population Served
                 Number of Agencies Proportionally Distributed
                         Number of Agencies per System
      Number of Agencies per System (Rounded Up to Nearest Whole Number)

                                       A
                                       B
                                       C
                                    D = C/A
                                       E

                              numb_lcr_other_org
<=100
                                                                         12,046
                                                                        723,487
                                                                          2,207
                                                                            0.2
                                                                              1
101-500
                                                                         15,307
                                                                      3,884,780
                                                                         11,853
                                                                            0.8
                                                                              1
501-1,000
                                                                          5,396
                                                                      3,989,089
                                                                         12,171
                                                                            2.3
                                                                              2
1,001-3,300
                                                                          8,035
                                                                     15,312,930
                                                                         46,721
                                                                            5.8
                                                                              6
3,301-10,000
                                                                          4,974
                                                                     29,070,747
                                                                         88,697
                                                                           17.8
                                                                             18
10,001-50,000
                                                                          3,331
                                                                     72,870,205
                                                                        222,332
                                                                           66.7
                                                                             67
50,001-100,000
                                                                            550
                                                                     38,134,020
                                                                        116,350
                                                                          211.5
                                                                            212
100,001-1,000,000
                                                                            407
                                                                     98,526,569
                                                                        300,612
                                                                          738.6
                                                                            739
>1,000,000
                                                                             21
                                                                     42,043,440
                                                                        128,278
                                                                         6108.5
                                                                          6,109
Total
                                                                         50,067
                                                                    304,555,267
                                                                        929,220

Source: "Derivation of Public Education Inputs_CWS_Final Rule.xlsx," worksheet, "Pb ALE_Recipient," Table 2a.
Notes:
General: Under the previous rule and final LCRR, CWSs must provide lead public education materials to facilities that include but are not limited to local health departments, schools, child cares, and medical providers that offer services to pregnant women, children, and infants to better reach these at-risk populations and their caregivers. The estimates do not explicitly include all groups that are required to receive PE, i.e., the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) and Head Start, and public and private hospitals and clinics, family planning centers, local welfare agencies. Note the omission of some of the organizations that receive PE will not impact the incremental costs of the final LCRR because this requirement is the same under the previous rule and final LCRR.
A&B: From SDWIS/Fed, current through June 30, 2016.
C: Assumes the 2,800 local health agencies; 127,233 elementary and secondary schools; and 673,648 child cares are proportionally distributed across the size categories.

    Post notice to website (hrs_web_op). Each CWSs serving more than 100,000 with a lead ALE must post PE materials on their website at an estimated annual burden of 0.5 hours per system. This estimate is based on the burden to post a notice on a website used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (page 57) (USEPA, 2007). Systems serving 100,000 or fewer people are not subject to this requirement.
    Consult with Primacy Agency on other PE activities (hrs_ale_consult_op). CWSs will consult with their Primacy Agency on other required PE activities conducted in response to a lead ALE and will incur a burden of 2 hours per CWS. This assumption is based on the estimate to consult with the Primacy Agency on public education activities used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule, page 60 (USEPA, 2007).
    Implement other PE activities (hrs_ale_other_op, cost_ale_other). CWSs with a lead ALE will also incur burden to implement other PE activities that use other delivery methods to inform consumers about the health effects of lead and ways to mitigate their exposure. Specifically, CWSs that exceed the lead ALE and serve more than 3,300 people must conduct additional annual PE activities from a list specified in the rule in consultation with the Primacy Agency until the system no longer has a lead ALE. CWSs serving 3,300 or fewer people must select one activity. These activities and EPA's burden assumptions are as follows:
 Public Service Announcements (PSAs): Systems will require 5 hours to prepare and e-mail a notification to newspapers and radio and TV stations.
 Paid Ads: Systems will require 30 minutes to coordinate paid advertisements.
 Public Display: Systems will post notices at local grocery stores, laundromats, or similar establishments. Systems serving 500 or fewer people would need 5 such postings, and systems serving between 501 and 10,000 people need 20 postings. Those serving 10,001 to 50,000 people need 100 postings, 50,001 to 100,000 need 200 postings, and 100,001 to 1,000,000 need 500 postings. It is assumed that it will take a system 1 hour to complete 5 postings.
 Email Notification: Systems will have a preexisting list of customer e-mail addresses and incur a burden of 1 hour.