Total Annual Corrosion Control Technology Costs....     312,364,000     332,309,000      19,945,000      339,077,000     414,967,000      75,890,000
--------------------------------------------------------------------------------------------------------------------------------------------------------

3. Lead Service Line Inventory and Replacement Costs
    The proposed LCR revisions require all water systems to create an
LSL materials inventory during the first three years after rule
promulgation or demonstrate to the State that the water system does not
have LSLs. Because many water systems have already complied with State
inventory requirements (e.g., Ohio, see http://codes.ohio.gov/orc/6109.121) that are at least as stringent as those required under the
proposed LCRR, the EPA adjusted the probability of conducting an
inventory downward to reflect the State requirements. Water system
inventory costs also reflect the development, by all water systems with
LSLs, of an initial LSLR plan. The plan would include procedures to
conduct full lead service line replacement, a strategy for informing
customers before a full or partial lead service line replacement, a
lead service line replacement goal rate in the event of a lead trigger
level exceedance, a pitcher filter tracking and maintenance system, a
procedure for customers to flush service lines and premise plumbing of
particulate lead, and a funding strategy for conducting lead service
line replacements.
    Depending on a water system's 90th percentile lead tap sample
value, it may be required to initiate a LSLR program. Small CWSs,
serving 10,000 or fewer people, and NTNCWSs have flexibility in the
selection of a compliance option if the trigger or action levels are
exceeded. These water systems may select to implement CCT or POU
devices and not receive LSLR costs in the model. See section III.E of
this notice for additional information on the compliance alternatives
available to small CWSs and NTNCWSs. The cost model under both the low
and high scenarios applies the estimated LSLR costs to those CWS
serving 10,000 or fewer people and any NTNCWSs for which the LSLR
option is determined to be the least cost compliance alternative. Under
both the low and high cost scenarios, the model estimates the cost for
implementing LSLR, CCT, and POU for each water system that meets the
small water system flexibility criteria and maintains only the cost
associated with the least costly option for each system. See section
VI.C.4 of this notice for a discussion of the modeling and a summary of
the number of systems selecting each alternative compliance option.
    The EPA collected LSLR unit cost information primarily from four
surveys. Given the small number of observations collected and lack of
systematic sampling techniques utilized in the surveys the resultant
estimates of replacement costs based on these data were highly
uncertain. Therefore, the EPA develop low- and high-end LSLR cost
values that are used in the cost model to provide a low/high cost range
to inform the understanding of uncertainty (Note four other factors
used to produce the low and high cost estimates also influence the LSLR
total cost estimates). See Chapter 5, section <IP_ADDRESS>.4 and Appendix A,
Section 3 for more information on the development of the LSLR unit cost
range.
    LSLR cost includes not only the physical replacement of the service
line but also prior notification of LSLRs as part of water system
maintenance operations; contacting customers and site visits to confirm
service line material and site conditions before replacement; providing
customers with flushing procedures following a replacement; delivering
pitcher filters and cartridges concurrent with the LSLR, and
maintenance for three months; collecting and analyzing a tap sample
three to six months after the replacement of a LSL; and informing the
customer of the results.
    Under the proposed rule, water systems with a 90th percentile lead
tap sample value greater than 10 [mu]g/L and less than or equal to 15
[mu]g/L are considered to have a trigger level exceedance. These water
systems are required to develop and implement a ``goal-based'' LSLR
program where the annual replacement goal is set locally through a
water system and State determination process. Ancillary costs incurred
by these water systems include: The development and delivery of
outreach materials to known and potential LSL households and submitting
annual reports to the State on program activities. For water systems
that do not meet the annual ``goal-based'' replacement rate, the
proposed rule requires that additional outreach to lead service line
customers be conducted. The additional outreach conducted is determined
in conjunction with the State and is progressive, increasing with
additional missed annual goals.
    Under this proposal, water systems with 90th percentile tap sample
data that exceed 15 [mu]g/L (action level) are required to fully
replace 3 percent of their LSLs per year for as long as the water
system remains above the action level for any portion of a monitoring
year. These water systems must also submit to the State an annual
report on program activities.
    In order to estimate the share of the LSLR cost that is paid by
customers, the EPA made the conservative assumption that customers
under the ``goal-based'' plan always pay for the part of the LSL
belonging to them both when a full LSL is replaced and when the
customer side is being replaced after a water system had completed a
partial LSLR in the past. Customers do not pay for pig tail/gooseneck
replacements in the model. Under mandatory replacement the EPA assumes
that the system pays for all replacements both full and partial.
    Exhibits 6-6 and 6-7 show the estimated annualized national cost
for both the low and high cost scenarios, discounted at 3 and 7
percent, respectively, of water systems developing the LSL inventory,
water systems conducting the goal-based and mandatory LSLR programs,
and household removal costs for the customer-owned portion of the LSL
under the current LCR, the proposed LCRR, and the incremental cost. The
EPA did not estimate costs to CWSs for replacing the water system-owned

portion of an LSL in response to receiving notification that a
customer-owned portion of an LSL was replaced outside of a water system
replacement program. The EPA expects that a small number of these types
of replacements would happen annually. Detailed information on the
estimation of LSLR costs can be found in Chapter 5, section 5.3.3 of
the EA.

                                Exhibit 6-6--National Annualized Lead Service Line Replacement Costs at 3% Discount Rate
                                                                         [2016$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                        Low cost estimate                               High cost estimate
                                                        ------------------------------------------------------------------------------------------------
                                                           Current LCR    Proposed LCRR    Incremental      Current LCR    Proposed LCRR    Incremental
--------------------------------------------------------------------------------------------------------------------------------------------------------
Lead Service Line Inventory............................              $0      $5,068,000      $5,068,000               $0      $8,075,000      $8,075,000
System Lead Service Line Replacement...................         579,000       8,235,000       7,656,000       22,399,000      68,264,000      45,865,000
Lead Service Line Replacement Ancillary Activities.....          59,000       3,206,000       3,147,000          715,000       4,879,000       4,164,000
Activities Triggered by Not Meeting Voluntary Target...               0       4,149,000       4,149,000                0      16,138,000      16,138,000
                                                        ------------------------------------------------------------------------------------------------
    Total Annual PWS Lead Service Replacement Costs....         638,000      20,658,000      20,020,000       23,113,000      97,357,000      74,244,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
Household Lead Service Line Replacement................         234,000       5,478,000       5,244,000        9,063,000      20,003,000      10,940,000
                                                        ------------------------------------------------------------------------------------------------
    Total Annual Lead Service Replacement Costs........         872,000      26,137,000      25,265,000       32,176,000     117,359,000      85,183,000
--------------------------------------------------------------------------------------------------------------------------------------------------------

                                Exhibit 6-7--National Annualized Lead Service Line Replacement Costs at 7% Discount Rate
                                                                         [2016$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                        Low cost estimate                               High cost estimate
                                                        ------------------------------------------------------------------------------------------------
                                                           Current LCR    Proposed LCRR    Incremental      Current LCR    Proposed LCRR    Incremental
--------------------------------------------------------------------------------------------------------------------------------------------------------
Lead Service Line Inventory............................              $0      $5,633,000      $5,633,000               $0      $8,617,000      $8,617,000
System Lead Service Line Replacement...................         520,000       8,197,000       7,677,000       30,793,000      86,480,000      55,687,000
Lead Service Line Replacement Ancillary Activities.....          53,000       4,314,000       4,261,000          983,000       6,726,000       5,743,000
Activities Triggered by Not Meeting Voluntary Target...               0       4,191,000       4,191,000                0      20,447,000      20,447,000
                                                        ------------------------------------------------------------------------------------------------
    Total Annual PWS Lead Service Replacement Costs....         573,000      22,335,000      21,762,000       31,776,000     122,270,000      90,494,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
Household Lead Service Line Replacement................         210,000       5,290,000       5,080,000       12,459,000      22,501,000      10,042,000
                                                        ------------------------------------------------------------------------------------------------
    Total Annual Lead Service Replacement Costs........         783,000      27,625,000      26,842,000       44,234,000     144,771,000     100,537,000
--------------------------------------------------------------------------------------------------------------------------------------------------------

4. Point-of-Use Costs
    Under the proposed rule requirements, small CWSs, serving 10,000 or
fewer people, and NTNCWS with a 90th percentile lead value above the
action level of 15 [mu]g/L may choose between LSLR, CCT installation,
or POU device installation and maintenance. See section III.E of this
notice for additional information on the compliance alternatives
available to small CWSs and NTNCWSs. In addition to the cost to provide
and maintain POU devices, water systems selecting the POU compliance
option face additional ancillary costs in the form of: (1) POU
implementation planning for installation, maintenance, and monitoring
of the devices, (2) educating customers on the proper use of the POU
device, (3) sampling POU devises to insure the device is working
correctly, and (4) coordination and obtaining approvals from the State.
    The cost model applies these POU costs to those CWS serving 10,000
or fewer people and any NTNCWSs for which the POU option is estimated
to be the least cost compliance alternative. The determination of the
least cost compliance alternative is computed across each
representative model PWS in the cost model based on its assigned
characteristics including: the number of lead service lines, cost of
LSLR, the presence of corrosion control, the cost and effectiveness of
CCT, the starting WQPs, the number of entry points, the unit cost of
POU, and the number of households. For a larger discussion on the
assignment of system characteristics, see section VI.B of this notice
and Chapter 5 of the EA. These characteristics are the primary drivers
in determining the costs once a water system has been triggered into
CCT installation or re-optimization, lead service line replacement, or
POU provision and maintenance. The model estimates the net present
value for implementing each compliance alternative and selects the
least cost alternative to retain in the summarized proposed rule costs.
    The EPA is estimating low and high cost scenarios, to characterize
uncertainty in the cost model results. These scenarios are functions of
assigning different low and high input values to a number of the
variables that affect the relative cost of the small system compliance
choices (see Chapter 5 section 5.2 of the EA for additional information
on uncertain variable value assignment). Therefore, as the model output
shows, the choice of compliance technology is different across the low
and high cost scenarios.
    Exhibits 6-8 and 6-9 show the total number of CWS serving 10,000 or
fewer people and NTNCWSs, the total number of systems by type and
population size that would select one of the small system compliance
options, the number of NTNCWSs selecting each compliance alternative in
the model, and the number of CWSs by population size selecting each
compliance alternative in the model, under both the low and high cost
scenarios. In general, the exhibits show across both the low and high
scenarios that the majority of water systems would select re-optimizing
under the small system compliance options. If a system has CCT in
place, the incremental costs of re-optimization are low compared to all
other alternatives. The POU device implementation seems to be the least
cost alternative when the number of households in the system is low as
demonstrated by the decrease in the

selection of the POU option as CWS population size increases in the
model. The pattern seen in the selection of LSLR between the low and
high cost scenarios demonstrates that the choice of compliance by small
systems is driven by relative costs. Under the low cost scenario far
greater numbers of systems select LSLR given the assumed lower numbers
of LSLs per system and lower cost of replacement under this scenarios.
While CCT installation cost is also lower under the low cost scenario
the difference in cost between the high and low scenarios is relatively
small compared to the reduction in cost for LSLR between the scenarios.
POU cost remains unchanged between the low cost and high cost
scenarios. The installation of CCT becomes more cost effective as
system population size increases, but in the larger system size
categories you can also see the effect of the relative cost of LSLR in
the low cost scenario.

        Exhibit 6-8--NTNCWS and Small System Counts Impacted Under Flexibility Option--Low Cost Scenario
                                        [Over 35 year period of analysis]
----------------------------------------------------------------------------------------------------------------
                                               NTNCWS                               CWS
                                          ----------------------------------------------------------------------
                                                                                501-      1,001-     3,301-
                                             All Systems     <=100     101- 500    1,000      3,300      10,000
----------------------------------------------------------------------------------------------------------------
Total PWS Count in System Size Category..          17,589     12,046     15,307      5,396      8,035      4,974
Total PWS Count of Systems with LSLR,               1,453      1,521      2,498      1,148      1,544      2,037
 POU, or CCT activity....................
Number of PWSs with Lead Service Line                  34        474        975        541        608      1,535
 Removals................................
Number of PWSs that Install CCT..........              15         25        438        189        288         80
Number of PWSs that Re-optimize CCT......             287        398        851        410        649        423
Number of PWSs that Install POU..........           1,117        625        234          8          0          0
----------------------------------------------------------------------------------------------------------------

        Exhibit 6-9--NTNCWS and Small System Counts Impacted Under Flexibility Option--High Cost Scenario
                                        [Over 35 year period of analysis]
----------------------------------------------------------------------------------------------------------------
                                               NTNCWS                               CWS
                                          ----------------------------------------------------------------------
                                                                                501-      1,001-     3,301-
                                             All Systems     <=100     101- 500    1,000      3,300      10,000
----------------------------------------------------------------------------------------------------------------
Total PWS Count in System Size Category..          17,589     12,046     15,307      5,396      8,035      4,974
Total PWS Count of Systems with LSLR,               2,354      1,938      2,782      1,677      3,274      1,314
 POU, or CCT activity....................
Number of PWSs with Lead Service Line                  94        139        118        476      1,246         86
 Removals................................
Number of PWSs that Install CCT..........              14         10        491        327        477        195
Number of PWSs that Re-optimize CCT......             347        368      1,319        813      1,540      1,032
Number of PWSs that Install POU..........           1,900      1,422        855         61         10          1
----------------------------------------------------------------------------------------------------------------

    The estimated national annualized point-of-use device installation
and maintenance costs for the proposed rule, under the low cost
scenario, are $3,995,000 at a 3 percent discount rate and $3,492,000 at
a 7 percent discount rate. The POU impacts of the proposed rule for the
high cost scenario are $16,400,000 discounted at 3 percent and
$15,485,000 discounted at 7 percent. Since POU costs are zero under the
current LCR, the incremental costs range from $3,995,000 to $16,400,000
at a 3 percent discount rate and from $3,492,000 to $15,485,000 at a 7
percent discount rate, under the low and high cost scenarios
respectively. Additional information on the estimation of POU costs can
be found in Chapter 5, section 5.3.4 of the EA.
5. Public Education and Outreach Costs
    In addition to the current LCR public education requirements for
water systems with a lead action level exceedance, the cost model
includes proposed rule requirements for ongoing lead education that
applies to all water systems with LSLs, regardless of the 90th
percentile level, and requirements in response to a single tap sample
exceeding the 15 [mu]g/L lead action level.
    The proposed rule requires a number of updates to existing public
education and additional outreach activities associated with LSLs. The
public education requirements costed for all water systems, regardless
of their lead 90th percentile tap sample levels, include: (1) Updating
Consumer Confidence Report language, (2) developing a lead outreach
plan and materials for new customers, (3) developing an approach for
improved public access to lead information, (4) participating in joint
communication efforts with the State to provide increased information
on lead education to health care providers, and (5) providing annual
documentation and certification to the State that public outreach on
lead has been completed. The costed proposed LCR public education
requirements applying to all water systems with lead service lines are:
(1) The planning, initially implementing and maintaining customer and
public access to LSL location information, and (2) the development of
lead educational materials for water-related utility work and delivery
of those materials to affected households during water-related work
that could result in service line disturbance.
    The proposed rule public education costs that are applied to water
systems that exceed the 15 [mu]g/L action level include: (1) The
development of lead language for public education in response to a lead
action level exceedance, (2) delivery of education materials to
customers for CWSs and posting of lead information for NTNCWs, (3)
water systems contacting public health agencies to obtain a list of
additional community organizations that should receive PE materials,
(4) water systems notifying public health agencies and other community
organizations, (5) large water systems posting a lead notice on their
website, (6) water system issuing a press release, (7) water systems
consulting with the State on the materials development and appropriate
activities while the action level is exceeded, and (8) annually

certifying public education activities have been completed.
    The proposed rule also includes a requirement for water systems to
notify affected customers within 24 hours of becoming aware of an
individual tap sample exceeding the 15 [mu]g/L lead action level. The
model includes the development cost of the notification and education
materials to be delivered to affected households and the incremental
cost of expedited delivery of the notification. Note that materials
costs related to follow-up testing when a sample exceeds 15 [mu]g/L are
included in the tap sampling costs in section VI.C.1 of this notice.
The estimated annualized national water system public education and
outreach costs for the current LCR range from $48,000 to $1,093,000 at
a 3 percent discount rate under the low and high cost scenarios
respectively. At a 7 percent discount rate the annualized estimated
current rule PE cost range is from $65,000 to $1,513,000. Under the
proposed rule low cost scenario, the estimated impacts are $29,364,000
at a 3 percent discount rate and $28,765,000 at a 7 percent discount
rate. Under the high scenario the estimated annualized costs are
$35,491,000 at a 3 percent discount rate and $35,525,000 at a 7 percent
discount rate. Therefore, the incremental estimated public education
and outreach costs for water systems range from $29,316,000 to
$34,398,000 at a 3 percent discount rate and $28,700,000 to 34,012,000
at a 7 percent discount rate. See Chapter 5, section 5.3.5 of the EA
for additional detailed information on the estimation of public
education and outreach costs.
6. Drinking Water System Implementation and Administrative Costs
    All water systems will have one-time start-up activities associated
with the implementation of the proposed rule. These compliance costs
include: Water system burden to read and understand the revised rule;
water systems assigning personnel and resources for rule
implementation; water system personnel time for attending trainings
provided by the State; and clarifying regulatory requirements with the
State during rule implementation. This category of cost is not impacted
by the variable that define the low and high cost scenarios, therefore
only one set of estimated costs exist in the category. The estimated
annualized national PWS implementation and administrative costs for the
proposed LCR revisions are $1,863,000 at a 3 percent discount rate and
$3,092,000 at a 7 percent discount rate. Since there are no costs under
the current LCR, the PWS implementation and administrative incremental
costs are also $1,863,000 at a 3 percent discount rate and $3,092,000
at a 7 percent discount rate. Additional information on the estimation
of water system implementation and administrative costs can be found in
Chapter 5, section 5.3.6 of the EA.
7. Annualized per Household Costs
    The cost model calculates the annualized cost per household, by
first calculating the cost per gallon of water produced by the CWS.
This cost per gallon represents the cost incurred by the system to
comply with the requirements of the proposed LCRR. This includes CCT
cost, inventory creation, system payed customer-side LSLR, tap
sampling, public education, and administrative costs. Because of
uncertainty in five important LCRR cost driver input variables,
discussed in section VI.A. of this notice, the Agency developed low and
high cost scenarios. These scenarios produce a range in the estimated
cost per gallon and two estimates for annualized per household costs.
    The model multiplies this low and high scenario costs per gallon by
the average annual household consumption (in gallons) to determine the
cost per household per year associated with increased costs borne by
the CWS. The EPA then adds to both these values the total consumer-side
lead service line replacement cost borne by households in the system,
divided by the number of households served by the system, to derive the
CWS's average annual household low and high scenario cost estimates.
Exhibits 6-10 and 6-11 show the distributions of incremental annualized
costs for CWS households by primary water source and size category.
Note, the percentiles represent the distribution of average household
costs across CWSs in a category, not the distribution of costs across
all households in a CWS category. Some households that pay for a
customer-side LSLR will bear a much greater annual household burden.
The EPA estimates the cost of removing the customer-owned side of a
service line range from $1,480 to $4,440, with a central tendency of
$2,960. The percentage of customers in each water system paying the
higher customer-side LSL costs depends on the number of LSL in the
water system, the rate of replacement, and the details of the water
systems LSLR program.

            Exhibit 10--Annualized Incremental Cost per Household by CWS Category--Low Cost Scenario
                                                     [2016$]
----------------------------------------------------------------------------------------------------------------
                                                     10th         25th         50th         75th         90th
         Source water                Size         Percentile   Percentile   Percentile   Percentile   Percentile
----------------------------------------------------------------------------------------------------------------
Ground.......................  100 or Fewer....       $-5.36        $5.33        $8.61       $13.79       $23.01
Ground.......................  101 to 500......         0.85         1.43         2.62         4.20         6.85
Ground.......................  501 to 1,000....         0.28         0.35         0.47         0.67         1.57
Ground.......................  1,001 to 3,300..         0.11         0.16         0.24         0.34         0.76
Ground.......................  3,301 to 10,000.         0.19         0.26         0.39         0.52         1.00
Ground.......................  10,001 to 50,000         0.04         0.07         0.13         0.21         0.38
Ground.......................  50,001 to                0.08         0.10         0.20         0.25         0.30
                                100,000.
Ground.......................  100,001 to               0.07         0.14         0.23         0.34         0.48
                                1,000,000.
Ground.......................  Greater than             0.17         0.17         0.24         0.26         0.26
                                1,000,000.
Surface......................  100 or Fewer....         2.87         4.96         8.86        15.52        23.87
Surface......................  101 to 500......         0.73         1.31         2.17         3.66         7.56
Surface......................  501 to 1,000....         0.26         0.34         0.52         0.81         2.11
Surface......................  1,001 to 3,300..         0.11         0.15         0.25         0.39         0.82
Surface......................  3,301 to 10,000.         0.20         0.26         0.43         0.78         1.56
Surface......................  10,001 to 50,000         0.05         0.09         0.19         0.38         1.55
Surface......................  50,001 to                0.08         0.11         0.25         0.32         1.07
                                100,000.
Surface......................  100,001 to               0.06         0.14         0.26         0.42         0.84
                                1,000,000.
Surface......................  Greater than             0.09         0.18         0.21         0.29         0.32
                                1,000,000.
----------------------------------------------------------------------------------------------------------------

            Exhibit 11--Annualized Incremental Cost per Household by CWS Category--High Cost Scenario
                                                     [2016$]
----------------------------------------------------------------------------------------------------------------
                                                     10th         25th         50th         75th         90th
         Source water                Size         Percentile   Percentile   Percentile   Percentile   Percentile
----------------------------------------------------------------------------------------------------------------
Ground.......................  100 or Fewer....      $-10.22        $4.78        $8.60       $15.22       $28.73
Ground.......................  101 to 500......        -1.06         1.36         2.87         4.85        11.54
Ground.......................  501 to 1,000....        -0.19         0.36         0.55         1.30         4.72
Ground.......................  1,001 to 3,300..         0.10         0.16         0.28         0.56         2.61
Ground.......................  3,301 to 10,000.         0.19         0.28         0.45         0.91         3.53
Ground.......................  10,001 to 50,000         0.05         0.08         0.14         0.29         2.61
Ground.......................  50,001 to                0.07         0.09         0.13         0.27         2.44
                                100,000.
Ground.......................  100,001 to               0.12         0.17         0.29         0.59         3.17
                                1,000,000.
Ground.......................  Greater than             0.17         0.17         0.24         0.26         0.26
                                1,000,000.
Surface......................  100 or Fewer....        -9.24         4.09        10.29        18.82        40.74
Surface......................  101 to 500......        -2.99         1.13         2.73         5.82        15.96
Surface......................  501 to 1,000....        -3.18         0.33         0.89         1.62         4.98
Surface......................  1,001 to 3,300..        -1.80         0.16         0.31         0.65         2.30
Surface......................  3,301 to 10,000.        -0.24         0.29         0.72         1.28         4.49
Surface......................  10,001 to 50,000         0.05         0.11         0.24         1.25         4.61
Surface......................  50,001 to                0.08         0.10         0.23         0.53         2.61
                                100,000.
Surface......................  100,001 to               0.10         0.20         0.34         1.31         3.46
                                1,000,000.
Surface......................  Greater than             0.09         0.18         0.21         0.29         0.32
                                1,000,000.
----------------------------------------------------------------------------------------------------------------

8. Primacy Agency Costs
    For each of the drinking water cost sections previously described,
primacy agencies (i.e., States) have associated costs. These include
start-up and implementation costs; reviewing water quality parameter,
source water, and school monitoring reports; reviewing and approving
lead tap sampling plans, sampling frequencies, results, and reports;
consultation and reviews during CCT, LSLR, and POU device installation;
and reviewing and approving the lead public education materials and
consulting on specific outreach requirements. In the EPA cost model,
the majority of the costs associated with States are determined on a
per water system basis. State actions and costs are largely driven by
the proposed rule required actions that are triggered for the
individual water systems. These per water system primacy agency costs
are then summed to obtain aggregate costs for this category.
    The State implementation and administration costs of complying with
the proposed LCR revisions include: Reading and understanding the rule;
adopting the rule and developing an implementation program; modifying
data recording systems; training staff; providing water system staff
with initial and on-going technical assistance and training;
coordinating annual administration tasks with the EPA; and reporting
data to SDWIS/Fed.
    State activities regarding sampling include reviewing:
     PWS reports on lead and copper WQP monitoring from entry
points and distribution system taps;
     Lead tap sampling plans, changes in sampling locations,
sample invalidations, sampling results and 90th percentile
calculations, and certification of customer notification of sampling
results;
     9-year waiver requests;
     Source water sampling results; and
     School sampling results.
    The State activities associated with CCT installation, re-
optimization, and ``find-and-fix'' rule requirements include:
     Consulting with water systems on source water and
treatment changes;
     Reviewing CCT studies for installation and re-
optimization;
     Reviewing post CCT installation WQP monitoring and tap
sample results (including sample invalidation);
     Setting optimal water quality parameters;
     Reviewing ``find-and-fix'' follow-up tap and water quality
parameter sampling for each individual lead tap sample greater than 15
[mu]g/L;
     Reviewing water system's ``find-and-fix'' summary reports;
     Reviewing new the EPA's CCT guidance; and
     Conducting CCT water quality reviews in conjunction with
sanitary surveys.
    LSLR creates a number of water system/State interactions. States
would be required to:
     Review water system inventory data;
     Confer with water systems with LSLs on initial planning
for LSLR program activities, including standard operating procedures
for conducting replacements, and outreach programs;
     Work with LSL water systems to determine a goal-based LSLR
rate;
     Provide templates and targeted public education language
for LSLR programs;
     Determine the additional outreach activities required if a
water system fails to meet its goal-based LSLR rate; and
     Review annual LSLR program compliance reports from water
systems.
    State activities associated with CWSs serving 3,300 or fewer people
and NTNCWSs that select POU as a treatment alternative include:
     Conferring with water systems on initial planning for POU
programs;
     Reviewing public education material for POU devices; and
     Reviewing annual reports on POU programs, including POU
device sampling results.
    Proposed public education provisions will require a great deal of
primacy agency oversight. Activities which produce primacy agency
burden include:
     Providing water systems with templates to update CCR
language;
     Reviewing water system information developed for new
customer outreach;
     Participating in joint communication efforts for sharing
lead public education with health care providers;
     Reviewing educational material developed for delivery
during water-related work;
     Reviewing water system certifications of lead public
education and outreach;
     Reviewing public education language submitted by water
systems in response to an individual tap sample above the action level;
     Consulting with water systems on public education response
to a lead

action level exceedance, including reviewing language; and
     Reviewing the water systems public education self-
certification letter following a lead action level exceedance.
    The cost model estimates that the Primacy Agencies will incur
incremental estimated annualized costs, under the low cost scenario,
totaling $14,915,000 at a 3 percent discount rate and $15,054,000 at a
7 percent discount rate. For the high cost scenario total estimated
costs is $15,598,000 at a 3 percent discount rate and $15,965,000 at a
7 percent discount rate. Additional information on the estimation of
primacy agency costs can be found in Chapter 5, section 5.4 of the EA.
9. Costs and Ecological Impacts Associated With Additional Phosphate
Usage
    Adding phosphate creates a protective inner coating on pipes that
can inhibit lead leaching. However, once phosphate is added to the
public water system (PWS), some of this incremental loading remains in
the water stream as it flows into wastewater treatment plants (WWTPs)
downstream. This generates treatment costs for certain WWTPs. In
addition, at those locations where treatment does not occur, water with
elevated phosphorus concentrations may discharge to water bodies and
induce certain ecological impacts.
    When water systems add orthophosphate to their finished water for
corrosion control purposes, some portion of the orthophosphate added
will reach downstream WWTPs. To estimate the potential fate of the
orthophosphate added at PWSs, the EPA developed a conceptual mass
balance model. The EPA applied this conceptual model to estimate the
increase in loading at WWTPs, given an initial loading from corrosion
control at water treatment plants. WWTPs could incur costs because of
upstream orthophosphate addition if they have permit discharge limits
for phosphorus parameters. The percentage of WWTPs with phosphorus
limits has increased over time. From 2007 to 2016, in annual percentage
rate terms, the growth rate in the percentage of WWTPs with phosphorus
limits is 3.3 percent.
    The EPA assumed this increase would continue as States transition
from narrative to numerical nutrient criteria and set numeric permits
limits, especially for impaired waters. The EPA applied the growth rate
observed from 2007 to 2016 to estimate the anticipated percentage of
WWTPs with phosphorus limits in future years. This growth rate results
in an estimated 41 percent of WWTPs with phosphorus discharge limits
after 35 years. Applied as the percentage of WWTPs that need to take
treatment actions, this estimate is likely conservative, particularly
given the potential availability of alternative compliance mechanisms,
such as, individual facility variance and nutrient trading programs.
    The specific actions a WWTP might need to take to maintain
compliance with a National Pollution Discharge Elimination System
(NPDES) phosphorus limit will depend on the type of treatment present
at the WWTP and the corresponding phosphorus removal provided (if any).
Based on a review of NPDES data, it is likely that most of the WWTPs
that already have phosphorus limits have some type of treatment to
achieve the limit.
    Some treatment processes can accommodate incremental increases in
influent loading and still maintain their removal efficiency. Such
processes might not need significant adjustment to maintain their
existing phosphorus removal efficiency, given an incremental increase.
Other treatment processes may need modifications to their design or
operation to maintain their removal efficiency in the face of an
influent loading increase.
    The EPA derived a unit cost of $4.59 per pound of phosphorus for
removing incremental phosphorus (see Chapter 5, section 5.5.1 of the EA
for additional information). This unit cost includes the cost of
additional chemical consumption and the operating cost of additional
sludge processing and disposal. The costs a WWTP could incur depend on
the magnitude of the loading increase relative to the specific WWTP's
effluent permit limit. WWTPs, whose current discharge concentrations
are closer to their limit, are more likely to have to act. WWTPs whose
current concentrations are well below their limit may not incur costs
but might, under certain conditions, incur costs (for example, when
phosphorus removal achieved by technology is sensitive to incremental
phosphorus loading increases). Furthermore, future phosphorus limits
could be more stringent than existing limits in certain watersheds.
    Therefore, the EPA conservatively assumed that any WWTP with a
discharge limit for phosphorus parameters could incur costs.
Accordingly, in calculating costs, the EPA used the anticipated
percentage of WWTPs with phosphorus discharge limits as the likelihood
that incremental orthophosphate loading from a drinking water system
would reach a WWTP with a limit. The EPA combined this likelihood and
the unit cost (previously estimated) with incremental phosphorus
loading to calculate incremental costs to WWTPs for each year of the
analysis period. The incremental annualized cost that WWTPs would incur
to remove additional phosphorous associated with the proposed LCRR,
under the low cost scenario, ranges from $668,000 to $1,066,000 at a 3
and 7 percent discount rate, respectively. The high cost scenario
produced an incremental estimated impact of $1,203,000 using a 3
percent discount rate, and $1,920,000 at a 7 percent discount rate.
    The EPA estimates that WWTP treatment reduces phosphorus loads
reaching water bodies by 59 percent but they are not eliminated. The
proposed rule's national-level total incremental phosphorus loads
reaching water bodies are projected to grow over the period of analysis
from the low/high scenario range of 202,000 to 460,000 pounds fifteen
years after promulgation to the low/high scenario range of 461,000 to
685,000 pounds at year 35. See Chapter 5, section 5.5 of the EA for
information on how loading estimates are calculated. The ecological
impacts of these increased phosphorous loadings are highly localized:
Total incremental phosphorus loadings will depend on the amount and
timing of the releases, characteristics of the receiving water body,
effluent discharge rate, existing total phosphorus levels, and weather
and climate conditions. Unfortunately, detailed spatially explicit
information on effluents and on receiving water bodies does not exist
in a form suitable for this analysis. Rather, to evaluate the potential
ecological impacts of the rule, the EPA evaluated the significance of
the national-level phosphorus loadings compared to other phosphorous
sources in the terrestrial ecosystem.
    To put these phosphorus loadings in context, estimates from the
USGS SPARROW model suggest that anthropogenic sources deposit roughly
750 million pounds of total phosphorus per year (USEPA, 2019b). The
total phosphorus loadings from the proposed LCRR high cost scenario
would contribute about 1 percent (7 million/750 million) of total
phosphorus entering receiving waterbodies in a given year, and the
incremental amount of total phosphorus associated with the proposed
LCRR relative to the current LCR grows only 0.09 percent (685,000/750
million). At the national level, the EPA expects total phosphorus
entering waterbodies as a result of the proposed LCR revisions to be
small, relative to the total phosphorus load deposited annually from
all other sources. National average load impacts may

obscure localized ecological impacts in some circumstances, but the
existing data do not allow an assessment as to whether this incremental
load will induce ecological impacts in particular areas. It is
possible, however, that localized impacts may occur in certain water
bodies without restrictions on phosphate deposits, or in locations with
existing elevated phosphate levels.
    An increase in phosphorus loadings can lead to economic impacts and
undesirable aesthetic impacts. Excess nutrient pollution can cause
eutrophication--excessive plant and algae growth--in lakes, reservoirs,
streams, and estuaries throughout the United States. Eutrophication, by
inducing primary production, leads to seasonal decomposition of
additional biomass, consuming oxygen and creating a State of hypoxia,
or low oxygen, within the water body. In extreme cases, the low to no
oxygen States can create dead zones, or areas in the water where
aquatic life cannot survive. Studies indicate that eutrophication can
decrease aquatic diversity for this reason (e.g., Dodds et al. 2009).
Eutrophication may also stimulate the growth of harmful algal blooms
(HABs), or over-abundant algae populations. Algal blooms can harm the
aquatic ecosystem by blocking sunlight and creating diurnal swings in
oxygen levels because of overnight respiration. Such conditions can
starve and deplete aquatic species.
10. Summary of Rule Costs
    The estimated annualized low and high scenario costs, discounted at
3 percent and 7 percent, that PWSs, households, and Primacy Agencies
will incur in complying with the current LCR, the proposed LCRR, and
incrementally are summarized in Exhibits 6-12 and 6-13. The total
estimated incremental annualized cost of the proposed LCRR range from
$132 to $270 million at a 3 percent discount rate, and $130 to $286
million at a 7 percent discount rate in 2016 dollars. The exhibits also
detail the proportion of the annualized costs attributable to each rule
component.

                                            Exhibit 6-12--National Annualized Rule Costs at 3% Discount Rate
                                                                         [2016$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                        Low cost estimate                               High cost estimate
                                                        ------------------------------------------------------------------------------------------------
                                                           Current LCR    Proposed LCRR    Incremental      Current LCR    Proposed LCRR    Incremental
--------------------------------------------------------------------------------------------------------------------------------------------------------
PWS Annual Costs:
    Sampling...........................................     $41,376,000     $73,931,000     $32,555,000      $42,809,000     $80,955,000     $38,146,000
    PWS Lead Service Line Replacement..................         638,000      20,658,000      20,020,000       23,113,000      97,357,000      74,244,000
    Corrosion Control Technology.......................     328,569,000     351,877,000      23,308,000      354,750,000     431,866,000      77,116,000
    Point-of Use Installation and Maintenance..........               0       3,995,000       3,995,000                0      16,400,000      16,400,000
    Public Education and Outreach......................          48,000      29,364,000      29,316,000        1,093,000      35,491,000      34,398,000
    Rule Implementation and Administration.............               0       1,863,000       1,863,000                0       1,863,000       1,863,000
                                                        ------------------------------------------------------------------------------------------------
        Total Annual PWS Costs.........................     370,631,000     481,688,000     111,057,000      421,766,000     663,931,000     242,165,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
State Rule Implementation and Administration...........       5,661,000      20,576,000      14,915,000        6,718,000      22,316,000      15,598,000
Household Lead Service Line Replacement................         234,000       5,478,000       5,244,000        9,063,000      20,003,000      10,940,000
Wastewater Treatment Plant Costs.......................         331,000       1,019,000         688,000          862,000       2,065,000       1,203,000
                                                        ------------------------------------------------------------------------------------------------
    Total Annual Rule Costs............................     376,857,000     508,762,000     131,905,000      438,408,000     708,314,000     269,906,000
--------------------------------------------------------------------------------------------------------------------------------------------------------

                                            Exhibit 6-13--National Annualized Rule Costs at 7% Discount Rate
                                                                         [2016$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                        Low cost estimate                               High cost estimate
                                                        ------------------------------------------------------------------------------------------------
                                                           Current LCR    Proposed LCRR    Incremental      Current LCR    Proposed LCRR    Incremental
--------------------------------------------------------------------------------------------------------------------------------------------------------
PWS Annual Costs:
    Sampling...........................................     $40,064,000     $71,897,000     $31,833,000      $42,039,000     $81,276,000     $39,237,000
    PWS Lead Service Line Replacement..................         573,000      22,335,000      21,762,000       31,776,000     122,270,000      90,494,000
    Corrosion Control Technology.......................     312,364,000     332,309,000      19,945,000      339,077,000     414,967,000      75,890,000
    Point-of Use Installation and Maintenance..........               0       3,492,000       3,492,000                0      15,485,000      15,485,000
    Public Education and Outreach......................          65,000      28,765,000      28,700,000        1,513,000      35,525,000      34,012,000
    Rule Implementation and Administration.............               0       3,092,000       3,092,000                0       3,092,000       3,092,000
                                                        ------------------------------------------------------------------------------------------------
        Total Annual PWS Costs.........................     353,067,000     461,889,000     108,822,000      414,405,000     672,615,000     258,210,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
State Rule Implementation and Administration...........       5,547,000      20,601,000      15,054,000        6,993,000      22,958,000      15,965,000
Household Lead Service Line Replacement................         210,000       5,290,000       5,080,000       12,459,000      22,501,000      10,042,000
Wastewater Treatment Plant Costs.......................         407,000       1,473,000       1,066,000        1,288,000       3,208,000       1,920,000
                                                        ------------------------------------------------------------------------------------------------
    Total Annual Rule Costs............................     359,230,000     489,253,000     130,023,000      435,144,000     721,282,000     286,138,000
--------------------------------------------------------------------------------------------------------------------------------------------------------

D. Benefits Analysis

    The proposed revisions to the LCR are expected to result in
significant health benefits, since both lead and copper are associated
with adverse health effects. Lead is a highly toxic pollutant that can
damage neurological, cardiovascular, immunological, developmental, and
other major body systems. The EPA is particularly concerned about
exposure experienced by children because lead can affect brain
development. Additionally, children through their physiology and water
ingestion requirements may be at higher risk. Research shows that, on
average, formula-fed infants and young children consume more drinking
water per day on a body weight basis than adolescents. Using the USDA
Continuing Survey of Food Intakes by Individuals (CSFII) data, Kahn and
Stralka (2009) demonstrated this trend, is most

pronounced in children under 1 year of age who drink more than double
older children and adults per kg of body weight. Additionally, children
absorb 2-4 times more lead than adults through the gastrointestinal
tract ((Mushak, (1991); WHO, (2011) and Ziegler et al. (1978)). No safe
level of lead exposure has been identified (USEPA, 2013). The EPA's
health risk reduction and benefits assessment of the proposed LCR
revisions concentrates on quantification and monetization of the
estimated impact of reductions in lead exposure on childhood IQ. As
explained in Appendix D in the Economic Assessment of the Proposed Lead
and Copper Rule Revision (EA), there are additional non-quantified lead
health impacts to both children and adults that will be realized as a
result of this rulemaking.
    Although copper is an essential element for health, excess intake
of copper has been associated with several adverse health effects. Most
commonly, excess exposure to copper results in gastrointestinal
symptoms such as nausea, vomiting, and diarrhea (National Research
Council, 2000). In susceptible populations, such as children with
genetic disorders or predispositions to accumulate copper, chronic
exposure to excess copper can result in liver toxicity. Because
household level data on the change in copper concentrations that result
from changes in CCT are not available, this analysis does not quantify
any potential benefits from reduced copper exposure that may result
from the proposed rule. See Appendix E in the EA for additional copper
health impact information.
    To quantify the potential impact to exposed populations of changes
in lead tap water concentrations as a result of the proposed LCR
revisions, the EPA:
     Estimated potential household lead tap water
concentrations under various levels of corrosion control treatment,
lead service line replacement, and implementation of POU devices;
     Modeled exposure using the lead tap water concentration
data, information on peoples' water consumption activities, and
background lead levels from other potential pathways;
     Derived the potential change in blood lead levels (BLLs)
that result from the changes in drinking water lead exposure;
     Used concentration response functions, from the scientific
literature, to measure changes in IQ for children given shifts in BLLs;
     Estimated the unit value of a change in childhood IQ; and
     Applied the unit values to the appropriate demographic
groups experiencing changes in lead tap water concentrations as a
result of the proposed regulatory changes across the period of
analysis.
    Subsections VI.D.1 through 4 of this notice outline the estimation
of lead concentration values in drinking water used to estimate before
and after rule implementation concentration scenarios, the
corresponding estimated avoided IQ loss in children, and a summary of
the monetized benefits of the proposed LCR Revisions.
1. Modeled Drinking Water Lead Concentrations
    The EPA determined the lead concentrations in drinking water at
residential locations through the collection and analysis of
consecutive sampling data representing homes pre and post removal of
LSLs, including partial removal of LSLs, under differing levels of
water system corrosion control treatment. The data was collected from
multiple sources including: Water systems, the EPA Regional Offices and
the Office of Research and Development, and authors of published
journal articles (Deshommes et al. 2016). This data includes lead
concentrations and information regarding LSL status, location, and date
of sample collection, representing 18,039 samples collected from 1,638
homes in 15 cities across the United States and Canada. The EPA grouped
the samples into LSL status categories (``LSL,'' ``Partial,'' ``No
LSL''). Samples were also grouped by CCT treatment, assigning status as
having ``None,'' ``Partial,'' or ``Representative.'' ``Partial''
includes those water systems with some pH adjustment and lower doses of
a phosphate corrosion inhibitor, but this treatment is not optimized.
``Representative'' are those water systems in the dataset that have
higher doses of phosphate inhibitors, which in the model are considered
optimized (see EA Chapter 6, section 6.2.1 for additional detail and
docket number EPA-HQ-OW-2017-0300 for the data).
    The EPA fit several regression models (see EA Chapter 6, section
6.2.2 for additional detail) of tap water lead concentration as
predicted by LSL presence (``LSL'' or ``No LSL''), LSL extent
(``Partial''), CCT status, and ``profile liter.'' Profile liter is the
cumulative volume a sample represented within a consecutive sampling
series at a single location and time. Models to describe the profile
liter accounted for the variation among sampling events, sampling
sites, and city. The EPA selected one of the regression models based on
its fit and parsimony and used it to produce simulated lead
concentrations for use in the benefits analysis (Exhibit 6-8, in
Chapter 6 of the EA). The selected model suggests that besides water
system, residence, and sampling event, the largest effects on lead
concentration in tap water come from the presence of LSLs and the
number of liters drawn since the last stagnation period. CCT produces
smaller effects on lead concentration than LSLs, and these effects are
larger in homes with LSLs.
    To statistically control for some sources of variability in the
input data, the EPA did not use summary statistics from the original
data directly in estimating the effects of LSL and CCT status. Instead,
the EPA produced simulated mean lead concentrations for 500,000
samples, summarized in Exhibit 6-14, based on the selected regression
model. The simulated sample concentrations represent estimates for new
cities, sites, and sampling events not included in the original
dataset. These simulations rely on estimates of variability and
uncertainty from the regression model and given information on LSL and
CCT status. Individual estimates are best thought of as the central
tendency for a sample concentration given regression model parameters
and estimated variance. The simulated samples represent, on average,
the lead concentrations taken after a short flushing period of roughly
30 seconds for all combinations of LSL and CCT status. This represents
a point near the average peak lead concentration for homes with full or
partial LSLs, and a point slightly below the peak lead concentration
for homes with no LSLs, regardless of CCT status.
    The EPA estimates that improving CCT will produce significant
reductions in lead tap water concentration overall. However, for full
LSLRs, the final model produced predictions of drinking water
concentrations that overlapped almost completely for all CCT
conditions. Therefore, the EPA used the pooled estimate of predicted
drinking water concentrations for all CCT conditions in residences with
no LSL in place for the main analysis in Chapter 6 of the EA. Because,
the EPA in using this pooled data the mean and standard deviation
values of tap water lead concentrations in Exhibit 6-14 are the same
for all three ``no LSLs'' status rows, regardless of whether there is
representative, partial, or no CCT. Effectively, in the primary
analysis the EPA did not quantify the incremental benefits of CCT when
LSLs are absent. On the other hand, because CCT is done on a system-
wide basis, there are no incremental costs

associated with providing CCT to homes without LSL when it is being
provided for the entire system. The impact of CCT for these no LSL
homes likely varies by location depending on the degree to which legacy
leaded plumbing materials, including leaded brass fixtures, and lead
solder remain at the location.
    The EPA does track the number of ``no LSL'' homes potentially
affected by water systems increasing their corrosion control during the
35-year period of analysis. The number of no LSL homes that experience
increase in CCT over the 35 years ranges from 14 million in the low
cost scenario and 26 million in the high cost scenario. The EPA
considered one possible approach to estimating the potential benefits
to children of reducing lead water concentrations in these homes (see
Appendix F of the EA) but has determined that the data are too limited
and the uncertainties too significant to include in the quantified and
monetized benefit estimates of this regulation. The EPA, therefore, is
requesting comment and additional information about the change in lead
concentrations that occur in non-LSL households that experience changes
in CCT.
    Because small CWSs that serve fewer than 10,000 people have
flexibility in the compliance option they select in response to a lead
action level exceedance, some CWSs are modeled as installing POU
devices at all residences. See section III.E of this notice for
additional information on the compliance alternatives available to
small CWSs. For individuals in these systems the EPA assumes, in the
analysis, that consumers in households with POU devises are exposed to
the same lead concentration as residents with ``No LSL'' and
``Representative'' CCT in place.

   Exhibit 6-14--LSL and CCT Scenarios and Simulated Geometric Mean Tap Water Lead Concentrations and Standard
         Deviations at the Fifth Liter Drawn After Stagnation for Each Combination of LSL and CCT Status
----------------------------------------------------------------------------------------------------------------
                                                                   Simulated SD      Simulated       Simulated
                                                  Simulated mean    \a\ of log    geometric mean   geometric SD
          LSL status               CCT status       of log lead   lead ([micro]g/ lead ([micro]g/   \a\ of lead
                                                   ([micro]g/L)         L)              L)         ([micro]g/L)
----------------------------------------------------------------------------------------------------------------
LSL...........................  None............            2.92            1.37           18.62            3.95
Partial.......................  None............            2.17            1.38            8.78            3.98
No LSL........................  None............           -0.29            1.38            0.75            3.98
LSL...........................  Partial.........            2.42            1.37           11.27            3.94
Partial.......................  Partial.........            1.67            1.37            5.32            3.93
No LSL........................  Partial.........           -0.29            1.38            0.75            3.98
LSL...........................  Representative..            1.95            1.38            7.01            3.96
Partial.......................  Representative..            1.19            1.38             3.3            3.96
No LSL........................  Representative..           -0.29            1.38            0.75            3.98
----------------------------------------------------------------------------------------------------------------
\a\ Standard deviations reflect ``among-sampling event'' variability.

    In the estimation of the costs and benefits of the proposed LCR
revisions, each modeled person within a water system is assigned to one
of the estimated drinking water concentrations in Exhibit 6-14,
depending on the CCT, POU, and LSL status. The EPA estimated benefits
under both the low cost and high cost scenarios used in the proposed
LCRR which characterize uncertainty in the cost estimates. The low cost
scenario and high cost scenario differ in their assumptions made about:
(1) The existing number of LSLs in PWSs; (2) the number of PWS above
the AL or TL under the current and proposed monitoring requirements;
(3) the cost of installing and re-optimizing corrosion control
treatment (CCT); (4) the effectiveness of CCT in mitigating lead
concentrations; and (5) the cost of lead service line replacement
(Section VI.C.3. above and Chapter 5, section 5.6 of the EA). The EPA
predicted the status of each system under the low and high scenarios at
baseline (prior to rule implementation) and in each year of rule
implementation. Depending on the timing of required actions that can
change CCT, POU, and LSL status under both the baseline and proposed
LCRR low and high scenario model runs, changes in lead concentration
and resultant blood lead are predicted every year for the total
population served by the systems for the 35-year period of analysis. In
the primary benefits analysis for the rule, improvements to CCT and the
use of installed POU devices are only predicted for individuals in
households with LSLs prior to the LCRR (consistent with discussion
above about the limits of the data for predicting the impact of CCT
when LSL are not present). In the model, LSL removals are predicted by
water system, by year, and multiplied by the average number of people
per household (across demographic categories) to determine the number
of people shifting from one LSL status to another. To predict the
changes in exposure that result from an improvement in CCT, the EPA
predicts the entire LSL population of a water system will move to the
new CCT status at the same time. The EPA also assumes that the entire
water system moves to the drinking water lead concentration, assigned
to POU when this option is implemented, which implies that everyone in
households in a distribution system with LSLs is properly using the
POU. See Chapter 6, section 6.3 of the EA for more detailed information
on the number of people switching lead concentration categories under
the low and high cost scenarios.
2. Impacts on Childhood IQ
    The 2013 Integrated Science Assessment for Lead (USEPA 2013) States
that there is a causal relationship between lead exposure and cognitive
function decrements in children based on several lines of evidence,
including findings from prospective studies in diverse populations
supported by evidence in animals, and evidence identifying potential
modes of action. The evidence from multiple high-quality studies using
large cohorts of children shows an association between blood lead
levels and decreased intelligence quotient (IQ). The 2012 National
Toxicology Program Monograph concluded that there is sufficient
evidence of association between blood lead levels <5 [mu]g/dL and
decreases in various general and specific measures of cognitive
function in children from three months to 16 years of age. This
conclusion is based on prospective and cross-sectional studies using a
wide range of tests to assess

cognitive function (National Toxicology Program, 2012).
    The EPA quantitatively assessed and monetized the benefits of
avoided losses in IQ as a result of the proposed LCR revisions. Modeled
lead tap water concentrations (previously discussed in this notice) are
used to estimate the extent to which the proposed rule would reduce
avoidable loss of IQ among children. The first step in the
quantification and monetization of avoided IQ loss is to estimate the
likely decrease in blood lead levels in children based on the
reductions in lead in their drinking water as a result of the proposed
LCRR.
    The EPA estimated the distribution of current blood lead levels in
children, age 0 to 7, using the EPA's Stochastic Human Exposure and
Dose Simulation Multimedia (SHEDS-Multimedia) model coupled with its
Integrated Exposure and Uptake Biokinetic (IEUBK) model. The coupled
SHEDS-IEUBK model framework was peer reviewed by the EPA in June of
2017 as part of exploratory work into developing a health-based
benchmark for lead in drinking water (ERG, 2017). For further
information on SHEDS-IEUBK model development and evaluation, refer to
Zartarian et al. (2017). As a first step in estimating the blood lead
levels, the EPA utilized the SHEDS-Multimedia model, which can estimate
distributions of lead exposure, using a two-stage Monte Carlo sampling
process, given input lead concentrations in various media and human
behavior data from the EPA's Consolidated Human Activity Database
(CHAD) and CDC's National Health and Nutrition Examination Survey
(NHANES). SHEDS-Multimedia, in this case, uses individual time-activity
diaries from CDC's NHANES and the EPA's CHAD for children aged 0 to 7
to simulate longitudinal activity diaries. Information from these
diaries is then combined with relevant lead input distributions (e.g.,
outdoor air lead concentrations, inhalation rates) to estimate
exposure. Drinking water tap concentrations for each of the modeled LSL
and CCT scenarios, above, were used as the drinking water inputs to
SHEDS-Multimedia. For more detail on the other lead exposure pathways
that are held constant as background in the model, see Chapter 6,
section 6.4, of the EA.
    In the SHEDS-IEUBK coupled methodology, the SHEDS model takes the
place of the exposure and variability components of the IEUBK model by
generating a probability distribution of lead intakes across media.
These intakes are multiplied by route-specific (e.g., inhalation,
ingestion) absorption fractions to obtain a distribution of lead
uptakes (see Exhibit 6-14 in the EA Chapter 6, section 6.4). This step
is consistent with the uptake estimation that would normally occur
within the IEUBK model. The media specific uptakes can be summed across
exposure routes to give total lead uptake per day. Next, the EPA used
age-based relationships derived from IEUBK, through the use of a
polynomial regression analysis, to relate these total lead uptakes to
blood lead levels. Exhibit 6-14 presents modeled SHEDS-IEUBK blood lead
levels in children by year of life and LSL, CCT status, and POU. The
blood lead levels in this exhibit represent what children's blood lead
level would be if they lived under the corresponding LSL, POU, and CCT
status combination for their entire lives. Note that when ``No LSL'' is
the beginning or post-rule state, 0.75 [micro]g/L is the assumed
concentration across all levels of CCT status (none, partial,
representative). The extent to which changes in CCT status make
meaningful difference in lead concentrations for those without LSL
cannot be determined from this Exhibit.

 Exhibit 6-14--Modeled SHEDS-IEUBK Geometric Mean Blood Lead Levels in Children for Each Possible Drinking Water Lead Exposure Scenario for Each Year of
                                                                          Life
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                               Geometric mean blood lead level ([micro]g/dL) for specified year of life
          Lead service line status             Corrosion control treatment  ----------------------------------------------------------------------------
                                                         status               0-1 \a\      1-2        2-3        3-4        4-5        5-6        6-7
--------------------------------------------------------------------------------------------------------------------------------------------------------
LSL........................................  None..........................       3.75       2.60       2.73       2.59       2.56       2.72       2.45
Partial....................................  None..........................       2.43       1.88       1.96       1.89       1.87       1.95       1.69
No LSL.....................................  None..........................       0.95       1.15       1.16       1.14       1.14       1.19       0.97
LSL........................................  Partial.......................       2.71       2.05       2.20       2.06       2.08       2.17       1.90
Partial....................................  Partial.......................       1.86       1.58       1.65       1.60       1.60       1.66       1.43
No LSL.....................................  Partial.......................       0.95       1.15       1.16       1.14       1.14       1.19       0.97
LSL........................................  Representative................       2.14       1.75       1.82       1.73       1.75       1.82       1.57
Partial....................................  Representative................       1.51       1.41       1.45       1.42       1.40       1.46       1.24
No LSL.....................................  Representative................       0.95       1.15       1.16       1.14       1.14       1.19       0.97
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                    POU                                           0.95       1.15       1.16       1.14       1.14       1.19       0.97
--------------------------------------------------------------------------------------------------------------------------------------------------------
\a\ Due to lack of available data, blood lead levels for the first year of life are based on regression from IEUBK for 0.5- to 1-year-olds only.
These represent the blood lead for a child living with the LSL/CCT status in the columns to the left. Each year blood lead corresponding to actual
  modeled child is summed and divided by 7 in the model to estimate lifetime average blood lead.
This table presents modeled SHEDS-IEUBK blood lead levels in children by year of life.

    The blood lead levels presented in Exhibit 6-14, are used as inputs
for the benefits modeling. For each year of the analysis modeled,
children are assigned blood lead levels, which correspond to a water
lead concentration representing the LSL, POU and CCT status of their
water system (see section 6.3 of the EA). In the proposed LCRR cost-
benefit model, individual children in LSL households for each water
system are tracked as they move from one LSL, CCT status, or POU to
another as a result of LCRR implementation. The tracking occurs for
both the low and high cost scenarios. Because the child's drinking
water lead concentration can change annually in the model, the EPA
chose to estimate lifetime blood lead levels by taking the average
across each year of the child's life, up to age 7. With this averaging,
age at implementation of the LCRR (changing LSL, CCT, or POU status),
is taken into account when calculating lifetime average blood lead
level.
    In order to relate the child's estimated lifetime average blood
lead level to an estimate of avoided IQ loss, the EPA selected a
concentration-response function based on lifetime blood lead from the
independent analysis by Crump et al. (2013). This study used data from
a 2005 paper by Lanphear et al., which has formed the basis of
concentration-response functions used

in several EPA regulations (National Ambient Air Quality Standard,
2008; TSCA Lead Repair and Renovation Rule, 2008; and Steam Electric
Effluent Limitation Guidelines Rule, 2005). The Crump et al. (2013)
function was selected over the Lanphear et al. (2005) reanalysis to
minimize issues with overestimating predicted IQ loss at the lowest
levels of lead exposure (less than 1 [micro]g/dL BLL), which is a
result of the use of the log-linear function. The Crump et al. (2013)
function avoids this issue by adding one to the estimated blood lead
levels prior to log-transformation. Since the proposed revisions to the
LCR are expected to reduce chronic exposures to lead, the EPA selected
lifetime blood lead as the most appropriate measure with which to
evaluate benefits. No threshold has been identified for the
neurological effects of lead (Budtz-J[oslash]rgensen et al., 2013;
Crump et al., 2013; Schwartz et al., 1991; USEPA, 2013). Therefore, the
EPA assumes that there is no threshold for this endpoint and quantified
avoided IQ loss associated with all blood lead levels. The EPA, as part
of its sensitivity analysis, estimated the BLL to IQ relationship using
Lanphear et al. (2005) and Kirrane and Patel (2014).\1\ See Chapter 6,
section 6.4.3 and Appendix F of the EA for a more detailed discussion.
---------------------------------------------------------------------------

    \1\ Lanphear et al. (2005) published a correction in 2019 that
revised the results to be consistent with the Kirrane and Patel
(2014) corrections.
---------------------------------------------------------------------------

    The estimated value of an IQ point decrement is derived from the
EPA's reanalysis of Salkever (1995), which estimates that a one-point
increase in IQ results in a 1.871 percent increase in lifetime earnings
for males and a 3.409 percent change in lifetime earnings for females.
Lifetime earnings are estimated using the average of 10 American
Community Survey (ACS) single-year samples (2008 to 2017) and projected
cohort life tables from the Social Security Administration. Projected
increases in lifetime earnings are then adjusted for the direct costs
of additional years of education and forgone earnings while in school.
The reanalysis of Salkever (1995) estimates a change of 0.0812 years of
schooling per change in IQ point resulting from a reduction in lead
exposure for males and a change of 0.0917 years of schooling for
females.
    To estimate the uncertainty underlying the model parameters of the
Salkever (1995) reanalysis, the EPA used a bootstrap approach to
estimate a distribution of model parameters over 10,000 replicates
(using random sampling with replacement). For each replicate, the net
monetized value of a one-point decrease in IQ is subsequently estimated
as the gross value of an IQ point, less the value of additional
education costs and lost earnings while in school. The EPA uses an IQ
point value discounted to age 7. Based on EPA's reanalysis of Salkever
(1995), the mean value of an IQ point in 2016$ discounted to age 7 is
$5,708 using a 7 percent discount rate and $22,503 using a 3 percent
discount rate.\2\ See Appendix F, of the EA for a sensitivity analysis
of avoided IQ loss benefits based on Lin et al. (2018).
---------------------------------------------------------------------------

    \2\ It should be noted that these values are slightly different
than those used in other recent rulemaking (e.g., the Lead Dust
Standard and the Perchlorate rule). This is simply due to the
differences in the age of the child when the benefits are accrued in
the analysis. Benefits for the LCRR are accrued at age seven and
therefore the value of an IQ point is discounted back to age 7 in
the LCRR analysis. This results in a slightly higher estimate than
the values used for the Perchlorate Rule and the Lead Dust Standard,
which are discounted to age zero and age three, respectively. It
should also be noted, and is described in Section 6.4.5 of the EA,
that the benefits in the LCRR are further discounted back to year
one of the analysis and annualized within SafeWater LCR.
---------------------------------------------------------------------------

    The EPA used the estimated changes in lifetime (age 0 to 7) average
blood lead levels that result from changes in LSL, CCT, or POU status
as inputs to the concentration response function from the independent
analysis by Crump et al. (2013). The resultant annual avoided IQ
decrement is then summed and multiplied by the EPA reanalyzed Salkever
(1995) value per IQ point which represent a weighted average for males
and females (3 or 7 percent depending on the discount rate being used
to annualize the stream of benefits across the period of analysis).
This annual stream of benefits was annualized at 3 and 7 percent over
the 35-year period of analysis, and further discounted to year one of
the period of analysis. See Exhibit 6-18 (discounted at 3 percent) and
Exhibit 6-19 (discounted at 7 percent) for the estimated benefit from
avoided IQ losses from both lead service line removals and improvements
to CCT at public water system as a result of the current rule, the
proposed LCR revisions, and the incremental difference between the
current and proposed rule estimates under both the low and high cost
scenarios.
3. Impacts on Adult Blood Lead Levels
    The EPA identified the potential adverse adult health effects
associated with lead utilizing information from the 2013 Integrated
Science Assessment for Lead (USEPA, 2013) and the U.S. Department of
Health and Human Services' National Toxicology Program Monograph on
Health Effects of Low-Level Lead (National Toxicology Program, 2012).
In these documents, lead has been associated with adverse
cardiovascular effects (both morbidity and mortality effects), renal
effects, reproductive effects, immunological effects, neurological
effects, and cancer. (see Appendix D of the EA).
    Although the EPA did not quantify or monetize changes in adult
health benefits for the proposed LCRR, the Agency has estimated the
potential changes in adult drinking water exposures and thus blood lead
levels to illustrate the extent of the lead reduction to the adult
population estimated as a result of the proposed LCRR. The EPA
estimated blood lead levels in adults for each year of life, beginning
at age 20 and ending with age 80. Males and females are assessed
separately because data from the CDC's National Health and Nutrition
Examination Survey (NHANES) indicate that men have higher average blood
lead levels than women. To estimate the changes in blood lead levels in
adults associated with the proposed rule, the EPA selected from a
number of available models a modified version of its Adult Lead
Methodology (ALM). The ALM ``uses a simplified representation of lead
biokinetics to predict quasi-steady state blood lead concentrations
among adults who have relatively steady patterns of site exposures''
(USEPA, 2003). The model assumes a linear slope between lead uptake and
blood lead levels, which is termed the ``biokinetic slope factor'' and
is described in more detail in Chapter 6 section 6.5 of the EA.
Although the model was originally developed to estimate blood lead
level impacts from lead in soil, based on the record, the EPA finds the
ALM can be tailored for use in estimating blood lead concentrations in
any adult exposed population and is able to consider other sources of
lead exposure, such as contaminated drinking water. The biokinetic
slope factor of 0.4 [micro]g/dL per [micro]g/day is still valid for use
in the case of drinking water since it is in part derived from studies
that measure both adult blood lead levels and concentrations of lead in
drinking water (Pocock et al., 1983; Sherlock et al., 1982).
    The EPA estimated expected BLLs for adults with the ALM using the
lead tap water concentration data by LSL, CCT, and POU status derived
from the profile dataset, discussed in section VI.D.1 and shown in
Exhibit 6-14 of this notice. For the background blood lead levels in
the model, the EPA used geometric mean blood lead levels for males and
females for each year of life between

ages 20 and 80 from NHANES 2011-2016, which may result in some minor
double counting of exposure from drinking water. Exhibit 6-15 displays
the estimated blood lead levels for adults by each LSL, POU or CCT
combination summarized by age groups (blood lead values for each year
of age are used to determine average BLL). The EPA also estimated BLLs
using output for other exposure pathways from SHEDS in the ALM and the
All Ages Lead Model, these results are shown in Appendix F of the EA.
The All Ages Lead Model results are not used in the primary analysis
because an ongoing peer review of the model has not been completed.

      Exhibit 6-15--Estimates of Blood Lead Levels in Adults Associated With Drinking Water Lead Exposures From LSL/CCT or POU Status Combinations
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                Geometric mean blood lead level ([micro]g/dL) for specified age
                                         Corrosion control                                                       group in years
      Lead service line status            treatment status               Sex           -----------------------------------------------------------------
                                                                                20-29      30-39      40-49      50-59      60-69      70-80
--------------------------------------------------------------------------------------------------------------------------------------------------------
LSL.................................  None...................  Males..................       1.90       2.05       2.26       2.46       2.66       2.93
                                                               Females................       1.60       1.73       1.92       2.25       2.38       2.55
Partial.............................  None...................  Males..................       1.33       1.46       1.67       1.87       2.04       2.28
                                                               Females................       1.03       1.14       1.34       1.66       1.77       1.91
No LSL..............................  None...................  Males..................       0.86       0.98       1.19       1.39       1.54       1.75
                                                               Females................       0.56       0.66       0.86       1.18       1.27       1.38
LSL.................................  Partial................  Males..................       1.47       1.61       1.82       2.02       2.20       2.44
                                                               Females................       1.17       1.29       1.48       1.81       1.92       2.07
Partial.............................  Partial................  Males..................       1.13       1.25       1.46       1.66       1.83       2.05
                                                               Females................       0.83       0.93       1.13       1.45       1.55       1.68
No LSL..............................  Partial................  Males..................       0.86       0.98       1.19       1.39       1.54       1.75
                                                               Females................       0.56       0.66       0.86       1.18       1.27       1.38
LSL.................................  Representative.........  Males..................       1.23       1.36       1.56       1.76       1.93       2.16
                                                               Females................       0.93       1.03       1.23       1.56       1.66       1.79
Partial.............................  Representative.........  Males..................       1.01       1.13       1.34       1.54       1.70       1.92
                                                               Females................       0.71       0.81       1.01       1.33       1.43       1.55
No LSL..............................  Representative.........  Males..................       0.86       0.98       1.19       1.39       1.54       1.75
                                                               Females................       0.56       0.66       0.86       1.18       1.27       1.38
--------------------------------------------------------------------------------------------------------------------------------------------------------
                             POU                               Males..................       0.86       0.98       1.19       1.39       1.54       1.75
                                                               Females................       0.56       0.66       0.86       1.18       1.27       1.38
--------------------------------------------------------------------------------------------------------------------------------------------------------

    As discussed in the analysis of childhood IQ impacts section VI.D.2
of this notice), the estimated BLLs in Exhibit 6-15 are average adult
annual blood lead levels given the corresponding estimated lead tap
water concentrations resulting from LSL, CCT, and POU status. In the
proposed LCR revisions cost-benefit model, individual males and females
in LSL households for each water system are tracked as they move from
one LSL, CCT, or POU status to another as a result of rule
implementation. Exhibit 6-16 shows the estimated changes in average
lifetime blood lead levels for adults that move from the set of initial
LSL, CCT, and POU status combinations to a new status as a result of
LSL removal, and/or installation of CCT or POU. Note that when ``No
LSL'' is the beginning or post-rule state, 0.75 [mu]g/L is the assumed
concentration across all levels of CCT status (none, partial,
representative). The extent to which changes in CCT status make
meaningful difference in lead concentrations for those without LSL
cannot be determined from this Exhibit.

               Exhibit 6-16--Estimated Lifetime Average Blood Lead Change for Adults Moving Between LSL, CCT, and POU Status Combinations
--------------------------------------------------------------------------------------------------------------------------------------------------------
                           Pre-rule drinking water                                             Post-rule drinking water                     Estimated
----------------------------------------------------------------------------------------------------------------------------------------  average blood
                                                                                lead change
                                                                                (in geometric
                                                                                Lead conc.                                                   means)
     Lead conc.  ([micro]g/L)           LSL status            CCT status        ([micro]g/L)        LSL status           CCT status     ----------------
                                                                                Ages 20-80
                                                                                ([micro]g/dL)
--------------------------------------------------------------------------------------------------------------------------------------------------------
18.62............................  LSL.................  None................            0.75  No LSL.............  None...............             1.09
18.62............................  LSL.................  None................            7.01  LSL................  Representative.....             0.71
18.62............................  LSL.................  None................            0.75  No LSL.............  Representative.....             1.09
                                                                                ------------------------------------------
18.62............................  LSL.................  None................            0.75                     POU                               1.09
                                                                                ------------------------------------------
8.78.............................  Partial.............  None................            0.75  No LSL.............  None...............             0.49
8.78.............................  Partial.............  None................             3.3  Partial............  Representative.....             0.34
8.78.............................  Partial.............  None................            0.75  No LSL.............  Representative.....             0.49
                                                                                ------------------------------------------
8.78.............................  Partial.............  None................            0.75                     POU                               0.49
                                                                                ------------------------------------------

0.75.............................  No LSL..............  None................            0.75  No LSL.............  Representative.....             0.00
                                                                                ------------------------------------------
0.75.............................  No LSL..............  None................            0.75                     POU                               0.00
                                                                                ------------------------------------------
11.27............................  LSL.................  Partial.............            0.75  No LSL.............  Partial............             0.64
11.27............................  LSL.................  Partial.............            7.01  LSL................  Representative.....             0.26
11.27............................  LSL.................  Partial.............            0.75  No LSL.............  Representative.....             0.64
                                                                                ------------------------------------------
11.27............................  LSL.................  Partial.............            0.75                     POU                               0.64
                                                                                ------------------------------------------
5.32.............................  Partial.............  Partial.............            0.75  No LSL.............  Partial............             0.28
5.32.............................  Partial.............  Partial.............             3.3  Partial............  Representative.....             0.12
5.32.............................  Partial.............  Partial.............            0.75  No LSL.............  Representative.....             0.28
                                                                                ------------------------------------------
5.32.............................  Partial.............  Partial.............            0.75                     POU                               0.28
                                                                                ------------------------------------------
0.75.............................  No LSL..............  Partial.............            0.75  No LSL.............  Representative.....             0.00
                                                                                ------------------------------------------
0.75.............................  No LSL..............  Partial.............            0.75                     POU                               0.00
                                                                                ------------------------------------------
7.01.............................  LSL.................  Representative......            0.75  No LSL.............  Representative.....             0.38
                                                                                ------------------------------------------
7.01.............................  LSL.................  Representative......            0.75                     POU                               0.38
                                                                                ------------------------------------------
3.3..............................  Partial.............  Representative......            0.75  No LSL.............  Representative.....             0.16
                                                                                ------------------------------------------
3.3..............................  Partial.............  Representative......            0.75                     POU                               0.16
                                                                                ------------------------------------------
0.75.............................  No LSL..............  Representative......            0.75                     POU                               0.00
--------------------------------------------------------------------------------------------------------------------------------------------------------

4. Total Monetized Benefits
    Exhibits 6-17 and 6-18 show the estimated, monetized national
annualized total benefits, under the low and high cost scenarios, from
avoided child IQ decrements associated with the current LCR, the
proposed LCRR, and the increment of change between the two, for CCT
improvements, LSLR, and POU devise implementation discounted at 3 and 7
percent, respectively. The potential changes in adult blood lead levels
estimated from changing LSL and CCT status under the proposed LCRR can
be found in section VI.D.3 of this notice and Chapter 6 of the EA. The
impact of lead on the risk of attention-deficit/hyperactivity disorder
and reductions in birth weight are discussed in Appendix H of the EA.
It should also be noted that because of the lack of granularity in the
assembled lead concentration profile data, with regard to CCT status
when samples were collected (see section VI.D.1 of this notice), the
benefits of small improvements in CCT, like those modeled under the
``find-and-fix,'' cannot be quantified in the model. For additional
information on non-quantified benefits see section VI.E.2 of this
notice.

                                      Exhibit 6-17--Summary of Estimated National Annual Benefits, 3% Discount Rate
                                                                         [2016$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
               System type: All estimate                                Low cost estimate                               High cost estimate
--------------------------------------------------------------------------------------------------------------------------------------------------------
              Estimated child IQ benefits                 Current  LCR   Proposed  LCRR    Incremental     Current  LCR   Proposed  LCRR    Incremental
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of Children Impacted (over 35 years)............          71,449       1,148,110       1,076,661        1,034,170       3,431,200       2,397,030
Annual IQ Point Decrement Avoided (CCT)................             431           8,764           8,333            6,875          28,127          21,252
Annual Value of IQ Impacts Avoided (CCT)...............      $7,300,000    $152,661,000    $145,361,000     $129,985,000    $521,356,000    $391,371,000
Annual IQ Point Decrement Avoided (LSLR/POU)...........             297           4,010           3,713            5,065          12,011           6,946
Annual Value of IQ Impacts Avoided (LSLR/POU)..........      $5,091,000     $70,811,000     $65,720,000      $99,412,000    $229,200,000    $129,788,000
                                                        ------------------------------------------------------------------------------------------------
    Total Annual Value of IQ Impacts Avoided...........     $12,391,000    $223,472,000    $211,081,000     $229,397,000    $750,556,000    $521,159,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
This table summarizes the national annual children's benefit for a 3 percent discount rate under High & Low Cost assumptions. This table uses a 3%
  discount rate over the 35 year analysis period. Children are modeled throughout their lifetime, and their drinking water concentration and BLL can
  change in each year of the analysis as CCT, POU or LSL changes happen in their modeled PWS.

                                      Exhibit 6-18--Summary of Estimated National Annual Benefits, 7% Discount Rate
                                                                         [2016$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
               System type: All estimate                                Low cost estimate                               High cost estimate
--------------------------------------------------------------------------------------------------------------------------------------------------------
              Estimated child IQ benefits                 Current  LCR   Proposed  LCRR    Incremental     Current  LCR   Proposed  LCRR    Incremental
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of Children Impacted (over 35 years)............          71,449       1,148,110       1,076,661        1,034,170       3,431,200       2,397,030
Annual IQ Point Decrement Avoided (CCT)................             431           8,764           8,333            6,875          28,127          21,252
Annual Value of IQ Impacts Avoided (CCT)...............      $1,201,000     $26,219,000     $25,018,000      $25,008,000     $97,772,000     $72,764,000
Annual IQ Point Decrement Avoided (LSLR/POU)...........             297           4,010           3,713            5,065          12,011           6,946
Annual Value of IQ Impacts Avoided (LSLR/POU)..........        $858,000     $12,453,000     $11,595,000      $20,311,000     $45,005,000     $24,694,000
                                                        ------------------------------------------------------------------------------------------------
    Total Annual Value of IQ Impacts Avoided...........      $2,059,000     $38,671,000     $36,612,000      $45,319,000    $142,778,000     $97,459,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
This table summarizes the national annual children's benefit for a 7 percent discount rate under High & Low Cost assumptions. This table uses a 7%
  discount rate over the 35 year analysis period. Children are modeled throughout their lifetime, and their drinking water concentration and BLL can
  change in each year of the analysis as CCT, POU or LSL changes happen in their modeled PWS.

E. Cost-Benefit Comparison
    This section summarizes and describes the numeric relationship
between the monetized incremental costs and benefits of the proposed
LCR revisions. The section also discusses both the non-monetized costs
and benefits of the rulemaking. Exhibits 6-19 and 6-20 compare the
annualized monetized incremental costs and benefits of the proposed
LCRR for the low and high cost scenarios. Under a 3 percent discount
rate, the net annualized incremental benefits, under the low and high
cost scenarios, range from $79 to $251 million. Under the low and high
cost scenarios and a 7 percent discount rate, the net annualized
incremental benefits range from a negative $91 to negative $189
million.

    Exhibit 6-19--Comparison of Estimated Monetized National Annualized Incremental Costs to Benefits of the
                                        Proposed LCRR at 3% Discount Rate
----------------------------------------------------------------------------------------------------------------
                                                                                Low cost        High cost
                                                                                scenario         scenario
----------------------------------------------------------------------------------------------------------------
Annualized Incremental Costs..................................................     $131,987,000     $269,989,000
Annualized Incremental Benefits...............................................      211,081,000      521,159,000
                                                                               ---------------------------------
    Annual Net Benefits.......................................................       79,094,000      251,170,000
----------------------------------------------------------------------------------------------------------------

    Exhibit 6-20--Comparison of Estimated Monetized National Annualized Incremental Costs to Benefits of the
                                        Proposed LCRR at 7% Discount Rate
----------------------------------------------------------------------------------------------------------------
                                                                                Low cost        High cost
                                                                                scenario         scenario
----------------------------------------------------------------------------------------------------------------
Annualized Incremental Costs..................................................     $130,104,000     $286,219,000
Annualized Incremental Benefits...............................................       36,612,000       97,459,000
                                                                               ---------------------------------
    Annual Net Benefits.......................................................      -91,492,000     -188,760,000
----------------------------------------------------------------------------------------------------------------

1. Non-Monetized Costs
    The proposed LCRR are expected to result in additional phosphate
being added to drinking water to reduce the amount of lead leaching
into the water in the distribution system. The EPA's cost model
estimated that, nationwide, the proposed LCRR will result in total
incremental phosphorus loads increasing over the period of analysis,
under the low cost and high cost scenarios, by a range of 202,000 to
460,000 pounds fifteen years after promulgation, and increasing under
the low cost and high cost scenarios by a range of 461,000 to 685,000
pounds at year 35. At the national level, under the high cost scenario,
this additional phosphorous loading is small, less than 0.09 percent of
the total phosphorous load deposited annually from all other
anthropogenic sources. However, national average load impacts may
obscure significant localized ecological impacts. Impacts, such as
eutrophication, may occur in water bodies without restrictions on
phosphate deposits, or in locations with existing elevated phosphate
levels. See Chapter 5, section 5.5.4 of the EA for additional
information.
2. Non-Quantified Non-Monetized Benefits
    In addition to the benefits monetized in the proposed rule analysis
for reductions in lead exposure, there are several other benefits that
are not quantified. The risk of adverse health effects due to lead that
are expected to decrease as a result of the proposed LCRR are
summarized in Appendix D of the EA and are expected to affect both
children and adults. The EPA focused its non-quantified impacts
assessment on the endpoint identified using two comprehensive U.S.
Government documents summarizing the recent literature on lead exposure
health impacts. These documents are the EPA's Integrated Science
Assessment for Lead (ISA) (USEPA, 2013); and the U.S. Department of
Health and Human Services' National Toxicology Program Monograph on
Health Effects of Low-Level Lead (National Toxicology Program (NTP),
2012). Both of these sources present comprehensive reviews of the
literature on the risk of adverse health effects associated with lead
exposure. The EPA summarized those endpoints to which either the EPA
ISA or the NTP Lead Monograph assigned

one of the top two tiers of confidence in the relationship between lead
exposure and the risk of adverse health effects. These endpoints
include: Cardiovascular effects, renal effects, reproductive and
developmental effects, immunological effects, neurological effects, and
cancer.
    There are a number of proposed rule requirements that reduce lead
exposure to both children and adults that the EPA could not quantify.
The proposed rule would require additional lead public education
requirements that target consumers directly, schools and child care
facilities, health agencies, and specifically people living in homes
with lead service lines. Increased education will lead to additional
averting behavior on the part of the exposed public, resulting in
reductions in the negative impacts of lead. The proposed rule also
would require the development of lead service line inventories and
making the location of lead service lines publicly accessible. This
would give exposed consumers more information, and it would provide
potential home buyers this information as well, possibly resulting in
additional lead service line removals initiated by homeowners before,
during, or following home sale transactions. The benefits of these
additional removals are not quantified in the analysis of the proposed
LCRR. As indicated in section VI.D.4 of this notice, because of the
lack of granularity in the lead tap water concentration data available
to the EPA for the proposed rule analysis, the benefits of small
improvements in CCT to individuals residing in homes with LSLs, like
those modeled under the ``find-and-fix,'' are not quantified.
    The EPA also did not quantify the benefits of reduced lead exposure
to individuals who reside in homes that do not have lead service lines.
The EPA has determined that the revised LCR requirements may result in
reduced lead exposure to the occupants of these buildings as a result
of improved monitoring and additional actions to optimize CCT. In the
analysis of the proposed LCRR, the number of non-LSL homes potentially
affected by water systems increasing their corrosion control during the
35-year period of analysis is 14 million in the low cost scenario and
26 million in the high cost scenario. These households, while not
having an LSL in place, may still contain leaded plumbing materials,
including leaded brass fixtures, and lead solder. These households
could potentially see reductions in lead tap water concentrations. The
EPA has assessed the potential benefits to children of reducing lead
water concentrations in these homes (see Appendix F of the EA) but has
determined that the data are too limited and the uncertainties too
significant to include in the quantified and monetized benefit
estimates of this regulation.
    Additionally, the risk of adverse health effects associated with
copper that are expected to be reduced by the proposed LCRR are
summarized in Appendix E of the EA. These risks include acute
gastrointestinal symptoms, which are the most common adverse effect
observed among adults and children. In sensitive groups, there may be
reductions in chronic hepatic effects, particularly for those with rare
conditions such as Wilson's disease and children pre-disposed to
genetic cirrhosis syndromes. These diseases disrupt copper homeostasis,
leading to excessive accumulation that can be worsened by excessive
copper ingestion (National Research Council, 2000).

F. Other Regulatory Options Considered

    The Office of Management and Budget recommends careful
consideration ``of all appropriate alternatives for the key attributes
or provisions of a rule (Office of Management and Budget, 2003).''
Pursuant to this guidance, the EPA considered other regulatory options
when developing the proposed LCRR related to:
     The lead in drinking water sampling program at schools and
licensed child care facilities,
     The lead tap sampling protocol requirements for water
systems with LSLs, and
     LSL locational information to be made publicly available.
     Providing small system flexibility to CWSs that serve a
population of 3,300 or less.
    Exhibit 6-21 provides a summary of the proposed requirement and
other option considered for these four areas.

 Exhibit 6-21--Summary of Other Options Considered for the Proposed LCRR
------------------------------------------------------------------------
                                                        Other option
            Area                  Proposed LCRR          considered
------------------------------------------------------------------------
Lead in Drinking Water        Mandatory program:    Upon request
 Sampling Program at Schools   20% of        program:
 and Licensed Child Care       schools and           Schools and
 Facilities.                   licensed child care   licensed child care
                               facilities tested     facilities would be
                               annually.             tested upon
                               5 samples     request.
                               per school.           5 samples
                               2 samples     per school.
                               per licensed child    2 samples
                               care facility.        per licensed child
                                                     care facility.
Lead Tap Sampling              Systems       Systems
 Requirements for Systems      with LSLs collect     with LSLs collect
 with Lead Service Lines       100% of their         100% of their
 (LSLs).                       samples from LSLs     samples from LSLs
                               sites, if             sites, if
                               available.            available.
                               Samples are   Samples are
                               first liter,          fifth liter,
                               collected after 6-    collected after 6-
                               hour minimum          hour minimum
                               stagnation time..     stagnation time.
Publicly Available LSL        Systems report a      Systems report the
 Locational Information.       location identifier   exact street
                               (e.g., street,        address of customer-
                               intersection,         owned portion of
                               landmark) for         LSLs
                               customer-owned
                               portion of LSLs.
Small System Flexibility....  CWSs that serve       CWSs that serve
                               10,000 or less        3,300 or less
                               people, and all       people, and all
                               NTNCWSs, are          NTNCWSs, are
                               provided compliance   provided compliance
                               flexibility when      flexibility when
                               they exceed the AL.   they exceed the AL.
------------------------------------------------------------------------
Notes: The fifth liter sample is intended to be representative of water
  residing in the LSL.

1. Lead Public Education and Sampling at Schools and Child Care
Facilities Option
    The EPA is proposing that all CWSs conduct a mandatory sampling and
public education program for schools and licensed child care facilities
that they serve. The EPA is also considering an ``upon request'' option
that would contain the same components of the mandatory program under
the proposed LCR revisions but would limit the sampling program to K-12
schools or child care facilities served by the water system that
request testing. CWSs would be required to annually contact these
facilities about this lead sampling program.

    For the ``upon request'' option, the EPA assumed that five percent
of schools and licensed child care facilities per year would elect to
participate in the sampling program and that CWSs would contact each
facility annually to determine its interest in the program in lieu of
developing a sampling schedule for each facility. CWSs would only be
required to sample at those facilities that request this sampling. As
shown in Exhibit 6-22, the ``upon request'' option is estimated to be
less costly than the proposed option. However, the cost of the ``upon
request'' option is highly dependent on the percentage of facilities
that request to participate in the sampling program. In addition, there
is a great degree of uncertainty regarding the percentage of facilities
that will request this sampling and how this interest may fluctuate
over time.

                       Exhibit 6-22--National Annualized Costs for School Sampling Options
                                                     [2016$]
----------------------------------------------------------------------------------------------------------------
                                                                                Annualized cost  Annualized cost
                                    Option                                      at 3%  discount  at 7%  discount
                                                                                rate             rate
----------------------------------------------------------------------------------------------------------------
Proposed LCRR: Mandatory Program..............................................      $28,540,000      $27,520,000
Other Option Considered: Upon Request Program.................................       10,430,000       10,047,200
----------------------------------------------------------------------------------------------------------------

2. Lead Tap Sampling Requirements for Water Systems With Lead Service
Lines
    The EPA is proposing that water systems with LSLs collect all one-
liter, first-draw tap samples from sites served by LSLs as opposed to a
minimum of 50 percent as currently required. As noted in section
III.E.1 of this notice, tap sample sites served by an LSL are at the
highest risk for elevated lead levels in drinking water, therefore, the
EPA is revising the tap sample site selection criteria to ensure water
systems with LSLs use those sites for lead tap sampling. The EPA is
proposing to retain the first draw sampling procedure because this
approach has been effectively implemented by water systems and can
identify when systems must take additional actions to address elevated
lead exposure. However, studies have shown LSLs to be one of the
greatest contributors to lead, and first-draw samples of one-liter may
not capture water that has sat in the lead service line, which may
contain the highest lead in drinking water levels. When the 1991 LCR
was promulgated, the best available data was first draw one-liter
samples. Recent studies have been conducted to identify which liter
from the tap best captures the highest level of lead that could
potentially be consumed by residents. The EPA has evaluated these
studies and determined that a fifth liter tap sample may be a more
conservative option than a first-draw sample, because it would capture
water from the lead service line, and sample results would
theoretically result in more protective measures, even though it is
unlikely that any given person consistently drinks water at the level
of the fifth liter draw. Therefore, the EPA is considering a ``fifth-
liter option.'' To take a fifth liter tap sample, the person sampling,
in accordance with all proposed tap sampling revisions, would fill a
one-gallon container that would not be analyzed, then immediately
collect a one-liter sample for lead in a separate bottle without
turning off the tap. While technically this is not the fifth liter of
water, the EPA will refer to this sample as the fifth liter.
    Under this proposal, copper samples would continue to be first-
draw, which would necessitate collection of two tap samples using
different protocols at each sampling site for systems with LSLs.
Collection of tap samples for both lead and copper at a single tap
sample site could not be achieved on the same day under the alternative
option above. To accomplish tap sampling for both lead and copper on a
single visit would require collection of five consecutive one liter tap
samples without turning the tap off. The first liter would be analyzed
for copper and the fifth liter would be analyzed for lead. This
procedure significantly complicates tap sample collection and may
introduce error, such as misidentifying the correct liter for the two
different analyses. Due to this complexity, copper samples may need to
be collected on a different day to meet stagnation time and first draw
requirements in the current LCR. The EPA requests comment on the
feasibility of the fifth liter collection option.
    The EPA expects that the fifth liter sampling for LSL water systems
will increase the percent of water systems with a trigger level
exceedance or action level exceedance and the probability that
individual tap samples would exceed 15 [micro]g/L. The EPA estimated
that the number and percentage of LSL water systems with an action
level exceedance would be two to three times higher under the fifth
liter option for water systems without and with CCT, respectively, than
the proposed LCR revisions. The EPA also estimated a larger number and
percentage of water systems would have a trigger level exceedance under
the fifth liter option, while the number and percentages of LSL water
systems with no trigger level exceedance or action level exceedance
would be lower. Note that these numbers would not change for non-LSL
water systems under the fifth liter option compared to the proposed LCR
revisions since the requirement to collect a fifth liter would only
apply to LSL water systems.
    Exhibits 6-23 and 6-24 provide the national annualized rule costs
and benefits, under the low cost scenario, discounted at 3 and 7
percent, for the current rule, proposed LCRR, and the fifth liter
option. Exhibits 6-25 and 6-26 provide the high cost scenario national
annualized rule costs and benefits at the 3 and 7 percent discount
rates. The EPA predicts higher State oversight costs, LSLR costs
assigned to households, and wastewater treatment plant costs associated
with CCT under the fifth liter option than under the proposed LCRR and
current rule. At a 3 percent discount rate, the EPA estimates higher
total benefits under the fifth liter option ($429 to $946 million)
compared to the proposed LCRR ($223 to $751 million) and current rule
($12 to $229 million) based on estimated IQ point decrement avoided
benefits. The EPA estimates that the cost of the rule will be higher
under the fifth liter option ($543 to $762 million) compared to the
proposed LCRR ($509 to $708 million) and current rule ($377 to 438
million) because more water systems will be required to conduct
additional tap sampling and treatment requirements in response to
higher measured fifth liter tap sample lead levels.
    At a 7 percent discount rate, the EPA estimates higher total
benefits under the fifth liter option ($76 to $178 million) compared to
the proposed LCRR ($39 to $143 million) and current rule ($2 to

$45 million) based on estimated IQ point decrement avoided benefits.
The EPA estimates that the cost of the rule will be higher under the
fifth liter option ($524 to $777 million) compared to the proposed LCRR
($489 to $721 million) and current rule ($359 to $435 million) because
more water systems will be required to conduct additional tap sampling