Utilizing the utility data EPA collected on the average unit cost of full, utility-side, and customer-side LSLR to represent the potential universe of LSLR costs facing water systems is also uncertain given the small number of observations (See Exhibit A-2). Because of this uncertainty in the LSLR cost estimate and the potentially large impact this unit cost may have on the overall national cost estimates, EPA chose to develop low and high LSLR unit cost estimates as inputs for the SafeWater LCR model in the development of cost ranges that potentially bracket the overall uncertainty in EPA's estimated average LSLR unit costs.
Based on a review of the data from all sources and experience with LSLR in high-profile systems including Flint, Michigan EPA developed a low and high LSLR unit cost estimate as follows:
 Low estimate: 25[th] percentile of utility estimates for each type of replacement: utility-side, customer-side, and full, as well as planned full and planned utility-side.
 High estimate: 75[th] percentile of utility estimates for each type of replacement: utility-side, customer-side, and full, as well as planned full and planned utility-side.
EPA did not use the minimum and maximum values for this bounding exercise given that applying these figures to 100 percent of LSLRs seemed unreasonably extreme. Moreover, a key cost driver is length of LSL to be replaced, and the minimum and maximum would represent an extremely short or long line and not a typical length. Using minimum and maximum values would have produced a national estimate range greater than what is warranted given the uncertainty in the distribution of LSLR unit costs.
The low and high estimates used in this EA are presented in Exhibit A-3. They are expected to provide a range of national costs of the final LCRR that reflects the degree of uncertainty in the average LSLR unit costs.

Exhibit A-3: Low and High Estimates for LSLR Unit Costs (2016$)
                                 Type of LSLR
                               Unit Cost ($2016)

                                    Average
                                      Low
                                    High[3]
Utility-Side
                                                                        $4,578
                                                                        $2,449
                                                                        $5,689
Customer-Side
                                                                        $3,559
                                                                        $2,514
                                                                        $3,929
Full Replacement
                                                                        $5,066
                                                                        $3,953
                                                                        $6,024
Utility-Side, Planned
                                                                        $3,663
                                                                        $1,959
                                                                        $4,551
Full Replacement, Planned
                                                                        $4,053
                                                                        $3,163
                                                                        $4,819
       Source: "Derivation of LSLR Costs_Final Rule.xlsx", worksheet "Summary of LSLR Costs."
       Notes:
       1. The values are based on utility reported estimates (total of 38 utilities, converted to 2016$).
       2. The planned costs in the last two rows are further adjusted downward 20 percent to represent replacements that are part of planned capital improvements.
       3. The low value is the 25[th] percentile of the values for each replacement type, and the high value is the 75[th] percentile. The low and high values are used as inputs for the SafeWater LCR model.
Applicability of LSLR Unit Costs under the Previous Rule and Final LCRR
This section provides the assumptions for the percent of systems incurring each of the five types of LSLR unit cost shown in Exhibit A-3 under the previous rule and final LCRR.
Previous Rule
CWSs
As noted previously, under the previous rule CWSs with LSLs that continued to exceed the lead AL after the installation of CCT were required to  annually replace at least seven percent of the initial number of LSLs in their distribution system until they no longer exceed the lead AL for two consecutive 6-month monitoring periods. Systems are not required to incur the costs of replacing the customer-owned portion of the LSL. Three types of actions, or replacements, can count toward the requirement:
 Tested-out
 Utility-side LSLR
 Full LSLR
Under the previous rule, an LSL could have "tested out" (i.e., be considered replaced) if all samples from the LSL are at or below the lead AL. "Tested-out" LSLs do not have to be physically replaced. EPA assumed that 25 percent of CWSs serving more than 10,000 people would test their LSLs before replacing them to determine if any meet the tested-out criteria, and that 80 percent of these would meet the criteria based on success rates from two large utilities (see the file "Derivation of LSLR  Costs_Final Rule.xlsx", worksheet "Percent Replace Type Previous" for details). Thus, the overall estimated rate of LSLs that are replaced through the tested-out provision for CWSs serving more than 10,000 people is 20 percent (25 percent x 80 percent). EPA has documentation indicating that only larger systems conduct a mix of test-outs and replacements when required to replace LSLs. Thus, EPA conservatively assumes that zero percent of CWSs serving 10,000 or fewer will elect to use the test-out provision.
To determine the proportion of physical replacements that are full replacements versus utility-side only replacements, EPA relied on a survey done by Black & Veatch in 2004 (Black & Veatch, 2004). The derivation and assumptions for the split between tested out, utility-side, and full replacement under the previous rule are shown in Exhibit A-4.
For utility-side and full LSLR, EPA assumed that 1 percent are planned replacements based on the assumed rate of infrastructure replacement from the original LCR Regulatory Impact Analysis (USEPA, 1991) and would thus incur planned replacement unit costs.

Exhibit A-4: Derivation of Percent of LSLR that are Tested Out, Utility-Side, and Full LSLR for CWSs under the Previous Rule
Source: "Derivation of LSLR Costs_Final Rule.xlsx."
Notes:
A: & B: Based on a survey by Black & Veatch which targeted 300 water systems and had a response rate of 41 systems. Results were presented at the USEPA LSLR workshop in 2004 (See file "BV LSL Survey Summary," docket no EPA-HQ-OW-2017-0300). For more information on the survey, see Strategies to Obtain Customer Acceptance of Complete Lead Service Line Replacement (AWWA, 2005).
C: EPA assumed that 25 percent of CWSs serving more than 10,000 people would test their LSLs before replacing them to determine if any meet the tested-out criteria. EPA only has documentation indicating that larger systems conduct a mix of test-outs and replacements when required to replace LSLs. Thus, EPA conservatively assumed that zero percent of CWSs serving <= 10,000 will elect to use the test out criteria.
D: EPA assumed that the percent of LSLs that meet the test-out criteria under the previous rule was 80 percent for systems serving > 10,000 people based on success rate from DC Water (76 percent) and Fort Wayne (89.2 percent). The Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule reported test out success rate for DC Water of 76 percent but does not indicate the number of LSL test-out samples collected (USEPA, 2007). Fort Wayne took 1,975 sample and 213 or 10.8 percent were above 15 ug/L, with the remaining 89.2 percent with sample results at or below 15 ug/L.

NTNCWSs
For NTNCWSs, all LSLRs under the previous rule were expected to be full replacement since the NTNCWS typically owns the entire service line. Planned unit costs are not applicable to NTNCWSs since they do not typically engage in large water main replacement work outside of their facilities. In addition, EPA conservatively assumed no NTNCWS will elect to use the test-out provision.
Final LCRR
CWSs
For CWSs serving more than 10,000 people, the LCRR requires two types of replacement programs depending on a system's lead 90[th] percentile level:
 A goal-based program for CWSs serving more than 10,000 people that have a TLE, where they must replace LSLs at a rate approved by the Primacy Agency, and
 A mandatory program for CWSs serving more than 10,000 that have a lead action level exceedance (ALE), where they must fully replace at least 3 percent of their LSLs annually. This also applies to CWSs serving 10,000 or fewer people and NTNCWSs for which LSLR is their approved compliance option.
In addition to these programs CWSs not performing goal-based or mandatory LSLR must also replace their portion of an LSL within 45 days of the customer replacement or within 180 days with Primacy Agency approval.
See Chapter 5, Section 5.3.4 for additional details about these programs and assumptions for modeling the programs in the SafeWater LCR model.

For the goal-based program, EPA assumed that the CWS will only incur costs for utility-side LSLR and that the customers will pay for their portion to achieve full replacements. For the mandatory program, EPA assumed that systems will pay for the full LSLR (replace both the utility-side and customer-side) or complete prior utility-side LSLR by paying for the replacement of the customer-side LSLR. To estimate the percent of replacements that can be done by completing a prior utility-side replacement, EPA assumed a 1 percent replacement rate from 1991 when the original LCR was promulgated to 2020 (29 years) when the LCRR became final with approximately 72 percent of those being partial replacements based on Black & Veatch (2004), resulting in approximately 20 percent (0.29*0.72) of LSLs being partially replaced on the utility side. The remaining replacements are assumed to be full LSLR. EPA estimated that 1 percent of full or utility-side replacement will continue to be done as part of infrastructure projects and will be assigned the lower unit costs for planned LSLR. For all customer-initiated LSL replacements, EPA assumed all replacements will be utility-side and not planned since they are initiated by the customer. The assumptions for the types of replacement for the goal-based and, mandatory replacement programs, and customer-initiated replacements are summarized in Exhibit A-5.
CWSs serving 10,000 or fewer people that have an ALE and have LSLR as their approved compliance option must replace LSLs at a schedule set by the Primacy Agency not to exceed 15 years and must replace all LSLs regardless of their subsequent lead 90[th] percentile value. The assumption used in the SafeWater LCR model is that these systems will replace 7 percent of their LSLs each year until all are replaced. EPA assumed that CWSs serving 10,000 or fewer people will use the mix of LSLR types shown for mandatory replacement in Exhibit A-5.
Exhibit A-5: Likelihood of LSLR Type by Replacement Requirement
                              Type of Replacement
                      Likelihood under Goal-Based Program
                      Likelihood under Mandatory Program
                      Likelihood under Customer-Initiated
                          SafeWater LCR Data Variable
Utility-Side (Planned)
                                                                             1%

pp_lslr_cap_emerg
Utility-Side
                                                                            99%

                                                                           100%
Customer-Initiated
pp_cust_init_lslr

Goal-based
1 - pp_lslr_cap_emerg
Full Replacement (Planned)

                                                                             1%

pp_lslr_cap_emerg
Full Replacement

                                                                            79%

1 - (pp_lslr_cap_emerg - pp_lslr_partial)
Customer-Side (i.e., completing a prior partial)

                                                                            20%

pp_lslr_partial
         Source: Derivation of LSLR Costs_Final Rule.xlsx.

NTNCWSs
Similar to the previous rule for NTNCWSs, all LSLRs under the final LCRR are expected to be full replacements since the NTNCWS typically owns the entire service line. Planned unit costs are not applicable to NTNCWSs since they do not typically engage in large water main replacement work outside of their facilities. NTNCWSs that have an ALE and have LSLR as their approved compliance option must replace LSLs at a schedule set by the Primacy Agency not to exceed 15 years and must replace all LSLs regardless of their subsequent lead 90[th] percentile value. The assumption used in the SafeWater LCR model is that these systems will replace 7 percent of their LSLs each year until all are replaced.

References
American Water Works Association (AWWA). 2005. Strategies to Obtain Customer Acceptance of Complete Lead Service Line Replacement. Denver, CO. Available online at https://www.awwa.org/Portals/0/AWWA/Government/StrategiesforLSLs.pdf?ver=2013-03-29-132027-193.
Black & Veatch. 2004. Notes from the EPA Lead Service Line Replacement Workshop. Conducted for American Water Works Association. December 10, 2004.
Cornwell, D.A, R.A. Brown, and S.H Via. 2016. National Survey of Lead Service Line Occurrence. Journal AWWA. 108(4):E182-E191.
Dixon, K. and S. Via. 2011. Lead Service Lines: A Survey of Utility Replacement Practices. Presented at the AWWA Water Quality Technology Conference & Expo, Phoenix, AZ, November 13-17, 2011.
ROWE Professional Services Company. 2016. Summary Report  -  Water Services Inventory and Pilot Replacement. City of Flint.
Sandvig, A., P. Kwan, G. Kirmeyer, B. Maynard, D. Mast, R.R. Trussell, S. Trussell, A. Cantor, and A. Prescott. 2008. Contribution of service line and plumbing fixtures to lead and copper rule compliance issues. Denver, CO: AWWA Research Foundation.
United States Environmental Protection Agency (USEPA). 1991. Final Regulatory Impact Analysis of National Primary Drinking Water Regulations for Lead and Copper. April 1991. Office of Water.
USEPA. 2007. Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule. September 2007. Office of Water. EPA-815-R0-7022.
USEPA. 2020a. Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water. July 2020. Office of Water.
USEPA. 2020b. Public Comment and Response Document for the Final Lead and Copper Rule Revisions.

: Modeling Costs in the SafeWater LCR Model and Economic Impact and Analysis of the Previous Rule
Introduction
In order to estimate the compliance costs (and benefits) of the final Lead and Copper Rule revisions (LCRR), the United States Environmental Protection Agency (EPA) developed a new variant of its existing SafeWater CBX model. This new model, called the SafeWater Lead and Copper Rule (LCR) model, is designed to estimate the costs and benefits of a treatment technique rule, and focuses on water contamination in the distribution system. Appendix B, Sections B.2 through B.4 describe in detail how the SafeWater LCR model develops a model system structure to account for baseline and compliance characteristic variability and how these system characteristics are used in conjunction with both previous and final rule compliance requirements to simulate model system compliance actions and develop costs estimates over the 35-year period of analysis under both scenarios. Because of limited data, in order to assess the costs (and benefits) and characterize uncertainty, EPA estimated previous and final rule compliance costs (and benefits) under high and low bracketing scenarios. Appendix B describes how the SafeWater LCR model works incorporating appropriate data.
Specifically, in this appendix, EPA provides detail on how the SafeWater LCR model estimates the incremental compliance costs of the final LCRR. In order to calculate the incremental impact of the final LCRR, each model-public water systems' (PWSs') costs must first be estimated separately under both the final LCRR and the previous LCR. Then, for each model-PWS, the SafeWater LCR model subtracts the estimated costs under the previous LCR from the model-PWS's estimated costs under the final LCRR cost to determine the incremental costs of the final LCRR. The same is done for costs borne by Primacy Agencies and households for lead service line replacement (LSLRs). In Section B.2, EPA describes the PWS characteristics and modeling assumptions that are held constant in order to ensure consistency between the previous LCR and the final LCRR compliance cost estimate. In Section B.3, EPA provides an overview of its approach to estimate the cost of the final LCRR. The same information for the previous rule is provided in Section B.4. In Section B.5, EPA provides the data and algorithms used to calculate the cost of each compliance activity PWSs will undertake to comply with the previous LCR. In Section B.6, EPA provides the data and algorithms used to calculate the cost of each activity Primacy Agencies will undertake to implement and administer the previous LCR. The data and algorithms used to calculate PWSs and Primacy Agencies costs under the final LCRR are provided in Chapter 5 in Sections 5.3 and 5.4, respectively.
Baseline Conditions and Modeling Assumption for both the Previous LCR and Final LCRR
Model-PWSs
In constructing the sample of model-PWSs for the cost analysis in the SafeWater LCR model, EPA began with the 50,067 community water systems (CWSs) and 17,589 non-transient non-community water systems (NTNCWS) in Safe Drinking Water Act Information System/federal version (SDWIS/Fed). As described in Chapter 4, from SDWIS/Fed, EPA knows each PWS's:
 System type (CWS or NTNCWS);
 Primary water source (surface water or groundwater);
 Population served;
 Corrosion control treatment (CCT) status (yes/no);
 Ownership (public or private); and
 Number of service connections.
Many additional baseline and compliance characteristics of each model-PWS are needed to estimate the costs of the previous and final rules. Therefore, EPA draws from additional data sources to assign the characteristics to each model-PWS. Because many model-PWS baseline characteristics are assigned from distributional information, EPA needed to ensure that the sample size was large enough to generate results that were stable for each of the 36 PWS categories. In other words, every time EPA assigned a model-PWS in a PWS category a set of baseline characteristics and estimated the costs of the final LCRR, the model should have generated similar results for the PWS category. If a PWS category had too few model-PWSs, the model would not produce stable results due to the large number of distributional variables in the analysis.
Therefore, EPA oversampled the SDWIS/Fed inventory to increase the number of model-PWSs in each PWS category. For every PWS category, EPA set the target minimum number of model-PWSs to 5,000. Consider the example of CWSs serving 3,301-10,000 people with groundwater as their primary water source. As shown in Exhibit 4-3, this PWS category has 2,771 systems. In order to ensure the model includes at least 5,000 model-PWSs, EPA replicated each PWS in the SDWIS/Fed inventory. So, for this example PWS category, the sample will have 5,542 model-PWSs. Continuing with this example, when EPA estimated the costs for this PWS category, each model-PWS would have a weight of 0.5 (2,771 divided by 5,542). To calculate the costs for this PWS category, EPA multiplied the cost for each model-PWS by 0.5 to get the model-PWS's weighted cost, and then sums the weighted costs for all 5,542 model-PWSs in the sample to get the total cost for the PWS category.
Once the model-PWSs were created, EPA assigned each model-PWS in the sample all baseline characteristics, so that the estimate of costs for the previous LCR and the final LCRR are based on the same baseline characteristics. In Exhibit B-1, EPA provides the list of baseline characteristics assigned to each model-PWS that are critical to understanding how the model estimates costs.

Exhibit B-1: Select Baseline Characteristics Assigned from Distributional Information to Model-PWSs
Baseline Characteristic
Data Description
Number of entry points to the distribution system
Section 4.3.6; "Derivation of Baseline CCT Characteristics_Final Rule.xlsx"
Model-PWS has LSLs in baseline (yes/no)
Exhibit 5-4
Percent of connections that are lead (if any)
Exhibit 5-4
Type of CCT in place (if any)
Section 4.3.6, "Derivation of Baseline CCT Characteristics_Final Rule.xlsx"
Current pH level
"Derivation of Baseline CCT Characteristics_Final Rule.xlsx"
Current PO4 dose
"Derivation of Baseline CCT Characteristics_Final Rule.xlsx"
Lead 90[th] percentile placement (less than or equal to the TL, greater than the TL and less than or equal to the AL, above the AL) under previous rule
Exhibit 5-5
Lead 90[th] percentile placement (less than or equal to the TL, greater than the TL and less than or equal to the AL, above the AL) under final LCRR
Exhibit 5-6
Tap sampling frequency in baseline
Exhibits 4-29 through 4-32
Source water change (y/n) each year of analysis
Exhibits 4-46 and 4-47
Treatment technology change (y/n) each year of the analysis
Exhibits 4-48 and 4-49
Acronyms: AL = action level; CCT = corrosion control treatment; LCRR = Lead and Copper Rule revisions; LSL = lead service line; PO4 = orthophosphate; TL = trigger level.
Many other data elements are assigned to the model-PWSs in order to maintain consistency between the estimation of costs for the previous and final rules (e.g., the expected likelihood that a tap water sample will be invalidated). Chapter 5, Section 5.3, discusses how each data element is used in the estimation of costs and provides an explanation of, or a reference to, how these data were developed.
Very Large Systems
There are 21 very large systems serving more than one million people. Because of the small number of systems in this size category, as well as the large costs these systems could face due to their size, EPA decided to collect additional PWS-specific information on baseline characteristics from these systems and use a modified model-PWS approach for estimating the compliance costs for this category of PWSs. Very large systems are potentially cost drivers because they serve greater than one million people. Utilizing SafeWater to select their baseline conditions can potentially generate erroneous compliance cost estimates. The set of such systems is relatively small (21) compared to systems in other system size categories. Therefore, collecting system specific information about relevant baseline characteristics is feasible and preferable to estimating compliance costs through a modeling process. For these very large systems, EPA attempted to collect information on their number of lead service lines (LSLs), EP-specific orthophosphate practices and chemical doses, pH measurements and pH adjustment practices, service populations, and average annual daily and design flow (DF) rates. EPA gathered this information from SDWIS/Fed, and from publicly available information such as Consumer Confidence Reports and system websites. In addition, the American Water Works Association (AWWA) provided additional data from member systems to fill data gaps.
When PWS-specific CCT data were available for very large systems, the SafeWater LCR model calculated the CCT costs at each EP individually using the information about the EPs' baseline CCT practices and doses. If data were not available, EPA assigned baseline CCT characteristics using the model-PWS approach described above. Likewise, if system specific LSL inventory data were available, the SafeWater LCR model used the data to calculate the costs but if PWS specific LSL inventory data were not available, the SafeWater LCR model assigned the number of LSL's using the same model-PWS approach for smaller system size categories. Exhibit B-2 provides a summary of data collected on each of the very large systems. All other baseline and cost characteristic data were assigned in the same manner as the systems serving 100,001 to 1 million size category.

Exhibit B-2: Summary of SDWIS/Fed and AWWA Data for PWS Systems Serving more than 1M People
                                   PWS Name
                   Phosphate Inhibitor Use for Sequestration
                              pH Adjustment Data
                                 LSL Inventory
                              Flow Data Provided
City of Phoenix
                                      No
                          Yes, EP level data provided
                       Public replaced, Private unknown
                            EP level data provided
East Bay Mud
                                      No
                          Yes, EP level data provided
                                 All replaced
                            EP level data provided
Los Angeles-City, Dept. Of Water & Power
                               No data provided
City of San Diego
                               No data provided
Miami-Dade Water and Sewer Authority - Main System
                                      No
                                      No
                     Some Public replaced, Private unknown
                            EP level data provided
Chicago
                               No data provided
 Massachusetts Water Resources Authority
                                      No
                          Yes, EP level data provided
                        Both Public and Private present
                            EP level data provided
Washington Suburban Sanitary Commission
                              Yes, dose provided
                          Yes, EP level data provided
                       Public replaced, Private unknown
                            EP level data provided
City of Baltimore
                               No data provided
MO American St Louis Co. & St Charles Co.
                                      No
                          Yes, EP level data provided
                       Public replaced, Private present
                            EP level data provided
Las Vegas Valley Water District
                                      No
                                      No
                                 None present
                            EP level data provided
Suffolk County Water Authority
                                      No
                                      No
                       Specific EPs with LSL Identified
                            EP level data provided
New York City System
                              Yes, dose provided
                          Yes, EP level data provided
                       Public replaced, Private present
                            EP level data provided
Cleveland Public Water System
                               No data provided
Columbus Public Water System
                               No data provided
Philadelphia Water Department
                              Yes, dose provided
                          Yes, EP level data provided
                        Both Public and Private present
                            EP level data provided
Metropolitan
                               No data provided
San Antonio Water System
                               No data provided
Dallas Water Utility
                               No data provided
City of Houston
                                      No
                          Yes, EP level data provided
                        Both Public and Private unknown
                            EP level data provided
Fairfax County Water Authority
                              Yes, dose provided
                          Yes, EP level data provided
                                 None present
                            EP level data provided
Analysis Period and Discount Rates
EPA estimated the incremental cost of the final LCRR over a 35-year period in order to fully capture the costs of the rule since it may take over 30 years for many CWSs to complete their LSLR program. In accordance with EPA policy, and based on guidance from the Office of Management and Budget (OMB), when calculating social costs and benefits, EPA discounted future costs (and benefits) under two alternative social discount rates, 3 percent and 7 percent.
When evaluating the economic impacts on PWSs and households (not social costs and benefits), EPA uses the estimated PWS cost of capital to discount future costs, as this best represents the actual costs of compliance that systems will incur over time. EPA used data from the 2006 Community Water System Survey (CWSS) to estimate the PWS cost of capital (USEPA, 2009a; 2009b). The survey defined the following categories of funding sources:
      Current revenue;
      Equity or other funds from private investors;
      Department of Homeland Security (DHS) grant;
      Other government grants;
      Drinking Water State Revolving Fund (DWSRF), including loans and Principal Repayment Forgiveness;
      Other borrowing from public sector sources; and
      Borrowing from private sectors sources.
EPA calculated the overall weighted average cost of capital (across all funding sources and loan periods) for each size/ownership category, weighted by the percentage of funding from each source. The cost of capital for each CWS size category and ownership type is shown in Exhibit B-3. Since similar cost of capital information is not available for NTNCWSs, EPA used the CWS cost of capital when calculating the annualized cost per NTNCWS.
Exhibit B-3: Weighted Average Cost of Capital by PWS Ownership and Size Category
Size Category
                              Publicly Owned CWS
                              Privately Owned CWS
<=100
                                                                           3.8%
                                                                           7.8%
101-500
                                                                           5.5%
                                                                           8.2%
501-1,000
                                                                           4.0%
                                                                           8.6%
1,001-3,300
                                                                           4.7%
                                                                           7.1%
3,301-10,000
                                                                           5.8%
                                                                           7.0%
10,001-50,000
                                                                           6.1%
                                                                           7.0%
50,001-100,000
                                                                           4.9%
                                                                           6.9%
100,001-500,000
                                                                           4.7%
                                                                           3.9%
Over 500,000
                                                                           3.7%
                                                                           7.8%

As mentioned above, these cost of capital estimates are derived from the 2006 CWSS. Since 2006, Congress has established several new programs, and expanded other existing programs, PWSs can access to lower their cost of capital. These include the DWSRF, the Water Infrastructure Finance and Innovation (WIFIA) Program, and the Water Infrastructure Improvements for the Nation Act of 2016 (WIIN Act).
Through the DWSRF Program, EPA allocates annual capitalization grants to states. The funds, along with a 20 percent state match, are placed into a dedicated loan fund to finance eligible water system infrastructure improvement projects. States are permitted to use funding from their DWSRF to facilitate LSLR projects and are taking steps to modify their DWSRF programs to prioritize LSLR. The WIFIA program provides creditworthy PWSs access to low-interest direct federal loans that can be used to finance capital improvements including LSLRs. Under the WIIN Act, three new grant programs were established related to reducing lead in drinking water (assistance for small and disadvantaged communities, reducing lead in drinking water, and lead testing in school and child care program drinking water). Therefore, the actual cost of capital faced by some water utilities may be lower than those used in this analysis.
Rule Implementation Schedule
EPA projects that rule implementation activities will begin immediately after rule promulgation. These activities will include one-time Primacy Agency and PWS costs for staff to read the rule, become familiar with its provisions, and train employees on the new rule. PWSs will comply with the inventory and LSLR initial planning requirements of the final rule in years 1 through 3 of the analysis. EPA expects that systems will begin complying with all other final rule requirements three years after promulgation, or in year 4 of the analysis.
Estimating Compliance Activity under the Final LCRR
As described in Chapter 3, some compliance activities are required only if the PWS has a lead 90[th] percentile level (P90) above the trigger level (TL) or action level (AL). Therefore, the SafeWater LCR model must keep track of each model-PWS's lead 90[th] percentile (P90) throughout the period of analysis. PWSs undertake many compliance activities that EPA assumes, for simplicity of the modeling, will not affect a PWS's P90. These include, for example, developing an inventory of LSLs, CWS sampling at schools and child cares, and public education (PE). In fact, for modeling purposes, EPA assumes that the only compliance activities that will change a model-PWS's P90 are:
      Installation of CCT;
      Re-optimization of existing CCT;
      Removal of LSLs; and
      A system-wide find-and-fix activity (assumed in the cost modeling to be a system-wide increase in pH and to occur infrequently).
In addition to these final rule compliance activities changing a PWS's P90, changing a water source or treatment technology can also result in a change in P90.
This section describes the modeling framework for the final LCRR that the SafeWater LCR model employs to determine whether a model-PWS will take an action that will change its P90, which in turn will change other actions the PWS will be required to take.
The SafeWater LCR model first assigns a P90-range to each model-PWS for the previous LCR using the expected percentiles in Chapter 5, Exhibit 5-7 and Exhibit 5-8. As discussed in Section <IP_ADDRESS>, because the tap sampling requirements under the final LCRR requires taking 100 percent of lead tap samples from LSL sites, for PWSs with LSLs, the likelihood that a PWS would have a P90 greater than the TL or AL is higher under the final LCRR (Chapter 5, Exhibit 5-6) compared to under the previous rule (Chapter 5, Exhibit 5-5). However, rather than simply assigning each model-PWS a P90-range under the final LCRR using the percentages in Chapter 5 directly, in order to maintain consistency between the previous LCR and the final LCRR for each PWS, the SafeWater LCR model uses the model-PWS's initial P90-range under the previous LCR to determine whether the model-PWS's initial P90-range under the final LCRR is as follows (see Step 1 in Exhibit B-4):
If the model-PWS has no LSLs, the P90-range under the final LCRR is the same as under the previous LCR.
If the model-PWS has LSLs and the P90 is greater than the AL under the previous LCR, then the P90-range under the final LCRR is the same as under the previous LCR.
If the model-PWS has LSLs and the P90 is greater than the TL but not greater than the AL under the previous LCR, then randomly select the P90-range for the final LCRR using the following probabilities:
       Prob(P90 greater than the AL under final LCRR) = (Prob(P90 greater than the AL under final LCRR)  -  Prob(P90 greater than the AL under previous LCR)) / Prob(P90 greater than the TL but not greater than the AL under previous LCR)
       Prob(P90 greater than the TL but not greater than the AL under final LCRR) = 1- (((Prob(P90 greater than the AL under final LCRR)  -  Prob(P90 greater than the AL under previous LCR)) / Prob(P90 greater than the TL but not greater than AL under previous LCR))
If model-PWS has LSLs and P90 is at or below the TL under the previous LCR, then randomly select the P90-range for the LCRR using the following probabilities:
       Prob(P90 greater than the TL but not greater than the AL under LCRR) = (Prob(P90 greater than the TL but not greater than the AL under final LCRR)  -  Prob(P90 greater than the TL but not greater than the AL under previous LCR)) / Prob(P90 Less than or equal to the TL under previous LCR)
       Prob(P90 Less than or equal to the TL under final LCRR) = 1-((Prob(P90 greater than the TL but not greater than the AL under final LCRR)  -  Prob(P90 greater than the TL but not greater than the AL under previous LCR)) / Prob(P90 Less than or equal to the TL under previous LCR))
The SafeWater LCR model works on an annual time step which EPA calls the "year-loop." At the beginning of the first year that the final rule's tap sampling requirements take effect (year 4 of the period of analysis), the model-PWS's initial P90y-range is set as explained above. As the SafeWater LCR model progresses through the year-loop, it continually updates its projection of the starting P90-range for the following year (P90y+1-range) based on:
The current year's starting P90-range (P90y-range)
Changes in source water and treatment technology (not required under the LCR) in the current year
Installation or re-optimization of CCT in the current year
Replacement of LSLs in the current year
System-wide find-and-fix activity (assumed in the cost modeling to be a system-wide increase in pH) in the current year
Change in source water or treatment technology
As mentioned above, a change in source water or treatment technology can affect a model-PWS's projected P90y+1-range. The first step within the year-loop is to determine whether the model-PWS has a significant change in source water or a change in treatment technology during the year (Step 3 in Exhibit B-4). If the model-PWS does not, then their projected P90y+1-range is not affected by a significant source water change or treatment change (Step 7), and the model-PWS moves on to the next component of the year-loop (Step 9).
If, however, the model-PWS does have a significant change in source water or a treatment technology change (Step 3), it is possible that this change could affect its P90y+1-range. Therefore, the SafeWater LCR model draws a new P90-range for the model-PWS, which represents the possible P90y+1-range associated with the new source water or treatment technology, as shown in Exhibit B-4 (Step 4).
If the model-PWS has installed or re-optimized CCT prior to the current year (Step 5), EPA assumed that the CCT is adequate to mitigate any increase in lead concentration associated with the significant source water change or treatment technology changes. Therefore, if the newly drawn P90-range is higher than the current P90y-range (Step 6), the SafeWater LCR model will keep the P90y+1-range the same as the P90y-range, as there will be no change in lead concentrations associated with the change in source water or treatment technology (Step 7). On the other hand, if the newly drawn P90-range is lower than the current P90y-range (Step 6), SafeWater will set the P90y+1-range equal to the newly drawn P90-range, in effect lowering the model-PWS's P90y+1-range (Step 8). If the model-PWS has not installed or re-optimized CCT prior to the current year (Step 5), then the SafeWater LCR model will set the P90y+1-range equal to the newly drawn P90-range (which may result in either an increase or decrease of the P90y+1-range). In all three cases, the model-PWS will move on to the next component of the year-loop (Step 9).
Exhibit B-4: Simulating Change in Source Water or Treatment Technology in SafeWater LCR

Small CWS and NTNCWS flexibility
As discussed in Chapter 3, the final LCRR includes significant flexibility for CWSs that serve 10,000 or fewer people, and all NTNCWSs. If these PWSs have a P90 greater than the AL, they can choose from four options to reduce the concentration of lead in their water. EPA includes three of these options in its cost analysis of the final LCRR:
 Replace 7 percent of their baseline number of LSLs per year until all LSLs are replaced.
Optimize existing CCT or install new CCT.
Provide point-of use (POU) devices to all customers.
The fourth option is available to CWSs and NTNCWSs that have control over their entire plumbing system. These systems may choose to remove all lead-bearing plumbing material.
For modeling purposes, EPA assigns a compliance cost to all systems that exceed the ALE in the SafeWater LCR model. EPA uses a cost minimization assumption in the model, and assigns the least cost alternative between the LSLR, CCT, and POU compliance alternatives. EPA lacks the system characteristic data that would allow the Agency to determine a small system's cost for replacement of lead-bearing plumbing materials because of the significant variability among systems and the plumbing materials in the buildings they serve. EPA assumed a system would only select the replacement of lead-bearing plumbing materials compliance option if it cost less than the three other alternative compliance options. By selecting the least cost of the three other options EPA has accounted for the costs that small water systems would incur but may be overestimating the costs for those systems that find the cost of lead bearing plumbing replacement to be less than the other three options.
Corrosion control and point-of-use technology
After the SafeWater LCR model determines whether a model-PWS's P90y+1-range will be affected by a change in source water or treatment technology, the model continues within the year-loop and begins the process of determining whether the model-PWS will install CCT, re-optimize CCT, or install POU devices (in the case of small CWSs or all NTNCWSs). The SafeWater LCR model uses the model-PWS's P90y+1-range rather than the current year-loop's initial P90-range (P90y-range) to determine if the PWS will install CCT, re-optimize CCT, or install POU. This is because EPA assumes that if a PWS proposes a significant change in water source or a change in treatment technology, the Primacy Agency will require the PWS to determine the impact of the change on lead levels, and take any corrective measures (installing CCT, re-optimizing CCT, or installing POU) before making the change in source water or treatment technology. Therefore, the SafeWater LCR model assumes that a change of water source or treatment technology would never lead to an AL exceedance, as the PWS would implement, if needed, appropriate CCT or POU (if eligible) prior to the change.
The SafeWater LCR model keeps track of the model-PWS's CCT status throughout the period of analysis. Once a model-PWS with existing CCT re-optimizes its CCT, or a model-PWS without CCT installs CCT, EPA assumes that the CCT is optimized and no further changes to CCT will be needed. Therefore, as the SafeWater LCR model continues within its year-loop (see Exhibit B-5), it determines whether the model-PWS has already re-optimized its existing CCT, or installed new CCT, and therefore has optimized CCT in place (Step 10). If it does, then SafeWater makes no change to CCT in place and to the model-PWS's P90y+1-range due to CCT (Step 22) and the model-PWS moves on to the next stage of the year-loop (Step 27).
Model CWSs serving more than 10,000 people with a P90y+1-range greater than the AL (Step 11) and existing CCT in place (Step 16) will re-optimize their existing CCT (Step 17). If they do not have existing CCT in place (Step 16), they will install CCT (Step 19). EPA assumes that both re-optimization of and installation of CCT, due to an ALE, will occur four years after the ALE (y+4) due to the time required to conduct a pipe loop study. The same is true for small model CWSs and all NTNCWS (Step 13) if CCT is their least costly compliance strategy (Step 15). However, if POU is their least costly compliance strategy (Step 20), the model-PWS will install POU (Step 21). If POU and CCT are both not the model-PWS's least costly compliance strategy, then the SafeWater LCR model makes no change to the model-PWS's P90y+1-range due to CCT or POU (Step 22), and the model-PWS moves on to the next stage of the year-loop (Step 27).
All model-PWSs that do not have optimized CCT (Step 10), have a P90y+1-range greater than the TL but not greater than the AL (Steps 11 and 12), and have existing CCT in place (Step 14), will re-optimize their CCT (Step 18). EPA assumes re-optimization due to a trigger level exceedance (TLE) will occur three years after the action level exceedance (ALE) (y+3) due to the time required to conduct a coupon study. If the model-PWS does not have existing CCT (Step 14), it will take no action that results in the SafeWater LCR model changing the PWS's P90y+1-range due to CCT (Step 22), and the model-PWS will move on to the next stage of the year-loop (Step 27).
Once a model-PWS re-optimizes existing CCT, or installs CCT, SafeWater will adjust its P90-range to reflect the effectiveness of the CCT in reducing lead levels (Steps 24, 25, and 26) before moving on to the next stage of the year-loop (Step 27). EPA assumes it will take two years after CCT installation or re-optimization for the PWS's P90 levels to fall (y+6 for CCT installation or re-optimization due to an ALE; y+5 for CCT re-optimization due to a TLE).
EPA assumes that CCT is more likely to reduce lead levels to not greater than the TL if a model-PWS does not have LSLs. Chapter 5, Exhibit 5.9 and Exhibit 5.10 provides EPA's assumptions on how P90 levels will change due to CCT adjustment under the low and high cost scenarios. Likewise, EPA assumes that the P90y+1-range will always be not greater than the TL for all small CWSs and all NTNCWSs that install POU (Step 23) before they move to the next step of the year-loop (Step 27).
Exhibit B-5: Simulating Corrosion Control and Point-of-Use Technology under Final LCRR in SafeWater LCR

Lead service line replacements
The SafeWater LCR model keeps track of the number of LSLs a model-PWS still has in place at the beginning of each year-loop. If a model-PWS does not have any LSLs in place (Step 28 in Exhibit B-6), then SafeWater will make no change to the model-PWS's P90y+1-range due to LSLRs (Step 44), and the model-PWS moves on to the next stage of the year-loop (Step 47).
If a model-PWS has LSLs in place at the beginning of the year-loop (Step 28), the requirements it faces depend on system size and type (Step 29). If the model-PWS is a CWS serving 10,000 or fewer people, or a NTNCWS (Step 29), its P90y is greater than the AL (Step 30), and LSLR is its least costly compliance option (Step 33), then it is required to replace 7 percent of its baseline number of LSLs each year (Step 34). If its P90y is not greater than the AL (Step 30), or LSLR is not the least costly compliance option (Step 33), it will be required to replace LSLs when the system becomes aware that a household has replaced their side of the service line (Customer Initiated LSLR, see Step 40).
 If the model-PWS is not a CWS serving 10,000 or fewer people, or an NTNCWS (Step 29), its LSLR requirements depend on the model-PWS's P90y-range. If the model-PWS's P90y is greater than the AL (Step 31), it is required to implement a mandatory LSLR program replacing a rolling two-year average of 3% known and unknown LSLs per year. This rolling average allows systems that experience LSLR rate fluctuation to still meet a 3% replacement rate on average for each two-year period while the water system is required to implement the LSLR program. The regulation also requires that a cumulative number of replacements be reached equal to 3% of the sum of known lead, galvanized requiring replacement, and lead status unknown service lines in the initial inventory, times the number of years that elapsed between the system's first ALE and the date on which the system's 90th percentile lead levels are at or below the action level for 2 years (four consecutive 6-month monitoring periods). Because EPA does not have information on the annual variation in replacement rates which systems may experience when required to conduct mandatory replacement the Agency has assumed an annual replacement rate of 3% (which equals a 3% rolling average value across all two year time periods)(Step 35). If its P90y is greater than the TL but not greater than the AL (Steps 31 and 32), it is required to establish an annual LSLR goal-based rate in consultation with the Primacy Agency (Step 36) and will replace some number of LSLs each year (Step 37). If the model-PWS fails to meet its annual LSLR goal-based rate (Step 38), it is required to undertake additional goal-based LSLR program outreach (Step 41). The quantity and types of additional outreach required depend on the number of consecutive periods the model-PWS fails to meet its goal. If it meets its annual LSLR goal-based rate (Step 38), it may stop the additional LSLR program outreach (Step 41). If the model-PWS's P90y is not greater than the TL (Step 32), it will be required to replace LSLs when the system becomes aware that a household has replaced their side of the service line (Step 40).
When a model-PWS replaces any LSLs during the year (Steps 34, 35, 37, and 40), the SafeWater LCR model determines whether, at the end of the year, the model-PWS has no more LSLs remaining (Step 42). If this is the case, the SafeWater LCR model sets the P90y+1-range to not greater than the TL to reflect the impact of LSLRs on lead concentrations (Step 46) and the model-PWS moves on to the next stage of the year-loop (Step 47). If, at the end of the year, the model-PWS still has LSLs in place, the SafeWater LCR model will make no change to the model-PWS's P90y+1-range due to LSLR (Step 44), and the model-PWS moves on to the next stage of the year-loop (Step 47).

Exhibit B-6: Simulating Lead Service Line Replacements under Final LCRR in SafeWater LCR

Find-and-fix
In addition to requiring PWSs to take compliance actions to reduce lead concentrations when their system-wide P90 exceeds the TL or AL, the final LCRR will also require PWSs to "find-and-fix" issues that cause a single lead tap water sample to exceed 15 ug/L. Although the final rule requires any PWS with tap water samples exceeding 15 ug/L to identify and address localized elevated lead concentrations, EPA assumes, for modeling purposes, that CCT-related find-and-fix requirements will be addressed only after a PWS has optimized CCT in place. Therefore, if a model-PWS does not have optimized CCT in place (Step 48 in Exhibit B-8) or does not have at least one lead tap sample above 15 ug/L in the year (Step 49), then it is assumed to not  make any CCT adjustments, and the SafeWater LCR model will make no change to the model-PWS's P90y+1-range due to find-and-fix (Step 57). The model-PWS will simply move to the next year-loop (Step 2, Exhibit B-4.
If a model-PWS does have optimized CCT in place, the SafeWater LCR model calculates the number of tap samples that will be above 15 ug/L in the current year of the analysis as a binomial distribution defined by the number of samples the model-PWS takes during the year and the likelihood that any given sample will be greater than 15 ug/L (Step 49). The number of tap samples a model-PWS will take in a year depends on the model-PWS's tap sampling frequency (semi-annual, or once every one, three, or nine years) and the system size. Exhibit B-7 provides the likelihood that a single lead tap sample will be above 15 ug/L, which varies by the model-PWS's P90y-range and LSL status.
Exhibit B-7: Likelihood That a Single Tap Water Sample Will Be Above 15 ug/L
P90y-Range
                              Model-PWS Has LSLs
                         Model-PWS Does Not Have LSLs
Greater than the AL
                                     0.254
                                     0.227
Greater than the TL but Not Greater than the AL
                                     0.061
                                     0.154
Not Greater than the TL
                                     0.012
                                     0.003
   Source: "Derivation of Probability_Sample_Above_15_Final Rule.xlsx." Also see Chapter 4, Section <IP_ADDRESS> for addition detail.
The causes of, and associated solutions to, localized elevated lead concentrations within a distribution system are varied and location-specific. In order to estimate model-PWS costs, EPA developed the following assumptions about how model-PWSs would respond to the final LCRR find-and-fix requirements:
 The first year, after CCT installation or CCT re-optimization, that a model-PWS has a tap sample above 15 ug/L, the PWS will investigate but take no corrective action.
The second year, after CCT installation or CCT re-optimization, that a model-PWS has a tap sample above 15 ug/L, it will flush the distribution system in the affected area to reduce water age, improving CCT, and lower lead concentration levels.
The third year, after CCT installation or CCT re-optimization, that a model-PWS has a tap sample above 15 ug/L, it will adjust pH at one EP to the distribution system (EP). This is the final action a model-PWS with only one EP will take in response to the find-and-fix requirement.
The fourth year, after CCT installation or CCT re-optimization, if a model-PWS, with more than one EP, has a tap sample above 15 ug/L, it will adjust pH at its remaining EPs. This is the final action any model-PWS will take in response to the find-and-fix requirement.
Therefore, within the SafeWater LCR model, if a model-PWS with re-optimized CCT in place (Step 48 in Exhibit B-8) has at least one lead tap sample above 15 ug/L in a given year (Step 49), its response will depend on the find-and-fix activity it took in prior years:
 If this is the first year the model-PWS has at least one lead tap sample above 15 ug/L (Step 50), it will investigate the issue but take no corrective actions. The SafeWater LCR model will make no change to the model-PWS's P90y+1-range due to find-and-fix (Step 57). The model-PWS will move to the next year-loop (Step 60).
If this is the second year the model-PWS has at least one lead tap sample above 15 ug/L (Step 51), it will flush its distribution system once to reduce lead levels (Step 53). The SafeWater LCR model will make no change to the model-PWS's P90y+1-range due to find-and-fix (Step 57). The model-PWS will move to the next year-loop (Step 60).
If this is the third year the model-PWS has at least one lead tap sample above 15 ug/L (Step 52), it will adjust the pH at one EP (Step 54). If the model-PWS has multiple EPs, the SafeWater LCR model will make no change to the model-PWS's P90y+1-range due to find-and-fix (Step 57). If, on the other hand, the model-PWS has only one EP, then the SafeWater LCR model will set the model-PWS's P90y+1-range to reflect the improved system-wide corrosion control (Step 59). In both cases, the model-PWS will move to the next year-loop (Step 60).
If this is the fourth year the model-PWS has at least one lead tap sample above 15 ug/L (Step 55), and the model-PWS has not yet modified pH at all EPs (Step 56), then the model-PWS will adjust pH at its remaining EPs (Step 58). The SafeWater LCR model will set its P90y+1-range to reflect the improved corrosion control system-wide (Step 59). The model-PWS will then move to the next year-loop (Step 60).

Exhibit B-8: Simulating Find-and-fix Requirements under the Final Rule in SafeWater LCR

Estimating Compliance Activity Under the Previous LCR
In order to maintain consistency between how the SafeWater LCR model estimates the costs for the final LCRR and the previous LCR, certain parts of the cost model remain constant across rule scenarios, including the baseline characteristics of the model-PWSs, the analysis period and discount rates, how very large systems are modeled, the assignment of the model-PWS's initial P90, the likelihood a single sample is greater than the AL, and how changes in source water or treatment changes impact the PWS's P90y+1 . Therefore, these elements are not repeated in this section. In addition, all cost estimates for the previous LCR are provided Chapter 5.
In addition, EPA estimated the costs of the previous LCR under the same low cost and high cost scenarios used to estimate the final LCRR costs. 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 previous and final monitoring requirements; 3) the cost of installing and optimizing CCT; 4) the effectiveness of CCT in mitigating lead concentrations; and 5) the cost of LSLR.
As described in Chapters 3, compliance activities under the previous rule were required when the lead 90th percentile (P90) was greater than the 15 ug/L. Therefore, the SafeWater LCR model must keep track of each model-PWS's P90 throughout the period of analysis. PWSs undertake many compliance activities that EPA assumes, for simplicity of the modeling, will not affect a PWS's P90. These include, for example, PE. In fact, for modeling purposes, EPA assumes that the only compliance activities that will change a model-PWS's P90 are
 Installation of CCT
 Re-optimization of CCT; and
 Removal of LSLs.
In addition to these previous rule compliance activities changing a model-PWS's P90, changing a water source or treatment technology can also result in a change in P90.
This section describes the modeling framework for the previous LCR that the SafeWater LCR model employs to determine if a model-PWS will take an action that will change its P90, which in turn will change other actions the model-PWS will be required to take.

Corrosion control technology
After the SafeWater LCR model determines if a model-PWS's P90y+1-range will be impacted by a change in source water or treatment technology (see Section B.3.1), it continues within the year-loop and begins the process of determining if the model-PWS will install or optimize CCT. EPA assumes that system will be installing CCT or optimizing existing CCT that achieve the same standard as under the final rule.
The SafeWater LCR model keeps track of the model-PWS's CCT status throughout the period of analysis. Once a model-PWS with existing CCT re-optimizes its CCT, or a model-PWS without CCT installs CCT, EPA assumes that the CCT is optimized and no further changes to CCT will be needed. Therefore, as the SafeWater LCR model continues within its year-loop (see Exhibit B-9, which continues the steps presented in Exhibit B-4), it determines whether the model-PWS has already re-optimized its existing CCT, or installed new CCT, and therefore has optimized CCT in place (Step 10). If it does, then SafeWater makes no change to CCT in place and to the model-PWS's P90y+1-range due to CCT (Step 16) and the model-PWS moves on to the next stage of the year-loop (Step 18).
Model-PWSs with a P90y+1-range greater than the AL (Step 11) and existing CCT in place (Step 13) will re-optimize their existing CCT (Step 12). If they do not have existing CCT in place (Step 16), they will install CCT (Step 14). Once a model-PWS optimizes existing CCT, or installs CCT, SafeWater will adjust its P90y+n-range to reflect the effectiveness of the CCT in reducing lead levels (Step 15) before moving on to the next stage of the year-loop (Step 18). In the case of re-optimizing existing CCT, the model-PWS will first make a recommendation to their Primacy Agency regarding CCT optimization and the Primacy Agency will review the recommendation and either require the model-PWS to perform a CCT study or inform the model-PWS of what changes to their CCT treatment are required. Depending on if a CCT study is required or not, this process can take two or three years. EPA assumes that it will require another year for the model-PWS to optimize their CCT and an additional two years for the model-PWS's P90 levels to fall at or below the AL.  In the case of new CCT installation, if the model-PWS has not already conducted a CCT study, EPA assumes it will take the model-PWS two years to complete the CCT study and an additional two years to install the CCT technology. EPA assumes that the model-PWS's P90 will fall below the AL two years after CCT is installed.

Exhibit B-9: Simulating Corrosion Control under the Previous LCR in SafeWater LCR

Lead service line replacements
As described above, under the previous LCR, if a PWS's P90y is above the AL, PWSs are required to install CCT. If they already have CCT installed, and their P90y is above the AL, they are required to replace 7 percent of their baseline number of LSLs each year until their P90 falls at or below the AL.[,] EPA assumes that it will take 3 years for PWSs to identify and correct any issues in order to get below the AL for 2 consecutive 6-month monitoring periods, which would allow them to discontinue the LSLR program under the previous LCR. Therefore, for modeling purposes, the SafeWater LCR model will require 3 years of LSLRs. Furthermore, EPA assumes a PWS will only conduct one 3-year period of LSLRs during the period of analysis.
Therefore, the SafeWater LCR model first checks to see if the model-PWS has already conducted three years of LSLRs (Step 19 in Exhibit B-10) and if it has, then the SafeWater LCR model makes no change to the model-PWS's P90y+1-range due to LSLRs (Step 26) and the model-PWS returns to the beginning of the year-loop (Step 2 in Exhibit B-4) to determine its compliance actions and costs for the next year of the analysis.
If the model-PWS has not already completed three years of LSLRs (Step 19), but it did conduct LSLR in the prior year (Step 20), it must already be in a three-year LSLR period. In this case, the model-PWS will remove 7 percent of its baseline LSLs this year (Step 24). If this is the third year of the model-PWS's LSLR program, then at the end of the year (Step 27) the SafeWater LCR model will adjust the model-PWS's P90y+1-range to reflect the impact of LSLR and any other corrective actions the model-PWS took on the model-PWS's lead concentrations (Step 28). EPA assumes that the model-PWS's P90y+1-range will be below the AL. The model-PWS will then return to the beginning of the year-loop (Step 2 in Exhibit B-4) to determine its compliance actions and costs for the next year of the analysis.
If the model-PWS has not removed any LSLs in prior years (Steps 19 and 20), does not have CCT installed (Step 21), has LSLs in the system inventory (Step 22), and has a P90y above the AL (Step 23) it will begin its three year LSLR program by removing 7 percent of its baseline LSLs (Step 24). Since the model-PWS has not completed its three year LSLR program (Step 26), the SafeWater LCR model will not make any adjustment to the model-PWS's P90y+1-range (Step 27) and the model-PWS will return to the beginning of the year-loop (Step 2 in Exhibit B-4) to determine its compliance actions and costs for the next year of the analysis.
Exhibit B-10: Simulating Lead Service Line Replacements under the Previous LCR in SafeWater LCR

Estimating Public Water System Costs under Previous LCR
This section details how EPA estimated the cost of compliance with each major component of the previous LCR, including:
 B.5.1: PWS Sampling Costs
 B.5.2: PWS CCT-Related Costs
 B.5.3: PWS Lead Service Line Replacement-Related Costs
 B.5.4: PWS Public Education-Related Costs
For most activities, water systems will incur costs in the form of burden (i.e., hours). The burden is multiplied by the labor rate ($/hr), as presented in Section <IP_ADDRESS>, to estimate labor unit costs. Systems will also incur capital and maintenance O&M costs for some activities. Exhibit B-11 provides an overview of the rule components, subcomponents, and activities for which EPA estimated water system costs for the previous rule. Those activities in italics and shaded in gray are new requirements under the LCRR and are provided to more fully characterize the differences between the previous rule and LCRR. The new LCRR requirements associated with one-time activities to implement and administer the rule changes, lead in drinking water testing at schools and child cares, find-and-fix requirements, goal-based and mandatory LSLR programs, expanded public outreach requirements, and the POU program are not applicable to the previous LCR and thus are not included in this section. Refer to Chapter 5, Exhibit 5-10 for a complete list of PWS activities under the LCRR.
At the end of each subsection, EPA provides a summary exhibit showing the SafeWater LCR modeling approach for each water system activity (e.g., Exhibit B-14, Exhibit B-18). The exhibits are organized as follows:
 The first and second columns show how unit burden and labor rate information is combined to estimate a CWS and NTNCWS cost per activity, respectively.
 The third and fourth columns indicate the conditions under which the water system activity occurs. The columns indicate if the system activity is dependent on
 The system's 90[th] percentile range. See Appendix B, Section B.3 for a detailed discussion of how the SafeWater LCR model tracks a water system's 90[th] percentile level and accounts for changes in the 90[th] percentile level over the 35-year analysis period
 Other characteristics of the system such as presence or absence of LSLs and/or CCT, and frequency of monitoring.
 The fifth column indicates the frequency of the activity (e.g., one-time, annually, every 3 years).
The SafeWater LCR model uses the information from these exhibits to calculate total annualized water system cost for each activity. See Section 5.2.4 of Chapter 5 for detail on the cost modeling methodology.
For the purpose of the SafeWater LCR modeling, all cost model inputs are assigned a unique data variable name, usually in the form of abbreviations or shorthand separated by underlined spaces (e.g., rate_op, hrs_read_rule_op). The SafeWater LCR model uses these data variables to model previous rule scenarios for different system sizes and types.
Exhibit B-11: PWS Cost Components, Subcomponents, and Activities Organized by Section1
                                   Component
                                 Subcomponents
                                  Activities2
B.5.1: PWS Sampling Costs
B.5.1.1: Lead Tap
   Update sampling instruction for lead tap sampling and submit to Primacy Agency (LCRR only)
   Contact homes to establish new 100 percent LSL tap sampling pool (LCRR only)
   Report any changes in sampling location to the Primacy Agency
   Confer with Primacy Agency on initial lead sampling data and status under LCRR (LCRR only)
   Obtain households for each round of lead tap sampling
   Offer incentives to households to encourage participation in lead tap sampling program
   Ship lead tap sampling material and instructions to participating households
   Collect lead tap samples
   Determine if sample should be rejected and not analyzed
   Analyze lead tap samples in-house or commercially
   Prepare and submit sample invalidation request to Primacy Agency
   Inform customers of lead tap sample results
   Certify to Primacy Agency that results were reported to customers
   Submit request to renew 9-year monitoring waiver to Primacy Agency
   Submit sampling results and lead 90[th] percentile calculation to Primacy Agency

B.5.1.2: Lead Water Quality Parameter Monitoring
   Collect lead WQP samples in the distribution system
   Analyze distribution system lead WQP samples
   Collect lead WQP samples from entry points
   Analyze entry point lead WQP samples
   Report lead WQP sampling data and compliance with OWQPs to Primacy Agency

B.5.1.3: Copper Water Quality Parameter Monitoring
   Collect copper WQP samples in the distribution system
   Analyze distribution system copper WQP samples
   Collect copper WQP samples from entry points
   Analyze entry point copper WQP samples
   Report copper WQP sampling data and compliance with OWQPs to Primacy Agency

B.5.1.4: Source Water Monitoring
   Collect source water samples
   Analyze source water samples
   Report source water monitoring results to Primacy Agency
B.5.2: PWS Corrosion Control Costs

B.5.2.1: CCT Installation
    Submit water quality data to determine if CCT study is needed
   Conduct a CCT study
   Install CCT Treatment (PO4, PO4 with post treatment, pH adjustment, or modify pH)

B.5.2.2: Re-optimization of Existing Corrosion Control
   Submit water quality data to Primacy Agency to determine if CCT study revision is needed
   Revise CCT study
   Reoptimize existing CCT

B.5.2.3: System Lead CCT Routine Costs
   Review CCT guidance (LCRR only)
   Provide water quality data to Primacy Agency and discuss during sanitary survey (LCRR only)
   Notify and consult with Primacy Agency on required actions in response to source water change
   Notify and consult with Primacy Agency on required actions in response to treatment change
B.5.3: PWS Lead Service Line Replacement-Related Costs
B.5.3.1: Lead Service Line Replacement
 Systems replace their portion of the LSL
   Households replace privately-owned portion of the LSL

B.5.3.2: Lead Service Line Replacement Ancillary Activities
   Develop information that asks if customers want their LSL replaced
   Deliver information that asks if customers want their LSL replaced
   Develop information that goes to customers prior to partial LSLR
   Deliver prior notification for partial LSLRs
   Contact customers about the replacement
   Collect samples for test out provision
   Analyze lead tap samples for test out provision
   Collect lead tap samples after partial LSLR
   Analyze lead tap samples after partial LSLR
   Inform customers of results of testing after partial LSLR
   Submit report on lead tap samples after partial LSLR to Primacy Agency
   Submit annual report on LSLR program to Primacy Agency
B.5.4: PWS Lead Public Education and Outreach Costs
    Update mandatory language for lead ALE PE and submit to Primacy Agency
Deliver PE materials to all customers
Contact public health agencies to obtain additional organizations and update recipient list
Notify public health agencies and other organizations
Post notice to website
Consult with Primacy Agency on other PE activities
Implement other PE activities
Prepare press release
Certify to Primacy Agency that lead outreach was completed
Acronyms: ALE = action level exceedance; CCT = corrosion control treatment; CWS = community water system; LSL = lead service line; LSLR = lead service line replacement; OWQPs = optimal water quality parameters; PE = public education; PO4 = orthophosphate; PWS = public water system; WQP = water quality parameter.
Notes:
1 Systems also incur burden for recordkeeping activities under the previous LCR, such as retaining records of decisions, supporting documentation, technical basis for decisions, and documentation submitted by the system. EPA has included burden for recordkeeping with each activity when applicable and opposed to providing separate burden estimates.
[2] EPA assigned a unique letter identification (ID) for each activity under a given rule component. Activities are generally organized with upfront, one-time activities first followed by ongoing activities. Activities shaded in gray and italics indicate new requirements that apply only to the LCRR. They are included to more fully characterize the differences between the previous rule and LCRR.
PWS Sampling Costs
This section provides system unit burden and cost for lead tap sampling, lead water quality parameter (WQP) monitoring, copper WQP monitoring, and source water monitoring in Sections B.5.1.1 through B.5.1.4, respectively.
Lead Tap Sampling
The discussion of lead tap sampling costs for water systems is presented in two subsections as follows:
      B.<IP_ADDRESS>: Lead Tap Sampling Schedules and Required Number of Samples
      B.<IP_ADDRESS>: Lead Tap Sampling Activities
 Exhibit B-14 at the end of Section B.<IP_ADDRESS> is a summary exhibit that indicates how the cost inputs are modeled by the SafeWater LCR model. Note that the SafeWater LCR model does not include the costs of copper tap sampling, because the LCRR does not change the program that is relevant for estimating the costs using the SafeWater LCR model.
Lead Tap Sampling Schedules and Required Number of Samples
All CWSs and NTNCWSs are subject to lead tap sampling requirements. The frequency and required number of samples depend on the systems' lead 90[th] percentile level and/or compliance with optimal water quality parameters (OWQPs) as detailed in Chapter 4, Section <IP_ADDRESS>. Systems that qualify for reduced monitoring can collect tap samples from a reduced number of sites on an annual, triennial, or 9-year monitoring schedule. Those on routine monitoring must conduct lead tap monitoring every six months at the standard number of sample sites.
Because the number of required sampling sites and sampling schedules can vary, costs are estimated separately for systems on the different lead tap monitoring schedules. EPA estimated the percentages of systems that would be on semi-annual monitoring, and on a reduced annual (p_tap_annual), triennial (p_tap_triennial), or 9-year monitoring (p_tap_nine) schedule at the start of the LCRR implementation period (assumed to be year 4) based on historical SDWIS/Fed data. Chapter 4, Section <IP_ADDRESS> provides a detailed discussion of how these percentages were derived. Exhibit 4-29 and Exhibit 4-30 provide the percentage of CWSs with CCT and without CCT, respectively, on semi-annual monitoring, and on a reduced annual, triennial, or 9-year monitoring schedule. Exhibit 4-31 and Exhibit 4-32 provide similar information for NTNCWSs with and without CCT, respectively.
 The minimum required number of tap samples for CWSs and NTNCWSs on routine (numb_samp_customer) and reduced monitoring (numb_reduced_tap) under the previous rule and LCRR are the same. Refer to Chapter 5, Section <IP_ADDRESS>.1.
Lead Tap Sampling Activities
EPA has developed costs for system activities associated with lead tap monitoring as shown in Exhibit B-12. The exhibit provides the unit burden and/or cost for each activity. The third column provides the corresponding SafeWater LCR model data variable in red/italic font. Activities that are conducted by some states in lieu of the water system are identified in the exhibit and further noted below the exhibit. The last column indicates whether or not the activity, unit burden or cost, and the SafeWater LCR model data variable are identical to those used for the LCRR, as described in Chapter 5, Section <IP_ADDRESS>. The assumptions that differ from the LCRR follow the exhibit. Gray shaded rows indicate new requirements that apply only to the LCRR. They are included to more fully characterize the differences between the previous rule and LCRR.
Exhibit B-12: PWS Lead Tap Sampling Unit Burden and Cost Estimates[1]
                                   Activity
                          Unit Burden and/or Cost[1]
                          SafeWater LCR Data Variable
                                 Same As LCRR?
    Update sampling instruction for lead tap sampling and submit to Primacy Agency (one-time)
N/A
hrs_devel_samp_op
N/A. New LCRR requirement.
   Contact homes to establish new 100 percent LSL tap sampling pool (one-time)
N/A
hrs_add_lsl_samp_op
N/A. New LCRR requirement.
   Report any changes in sampling location to the Primacy Agency
3 hrs/CWS
hrs_chng_tap_op
Yes. See Section <IP_ADDRESS>.2, activity c).
   Confer with Primacy Agency on initial lead sampling data and status under LCRR
N/A
hrs_initial_tap_confer_op
N/A. New LCRR requirement.
   Obtain households for each round of lead tap sampling
0.5 hrs/sample per CWS
hrs_samp_volunt_op
No. See discussion following the exhibit.
   Offer incentives to households to encourage participation in lead tap sampling program
$10 to $100/sample per CWS
cost_incentive
Yes. See Section <IP_ADDRESS>.2, activity f).
   Ship lead tap sampling material and instructions to participating households
Burden per sample (CWSs only)
0.25 hrs

Cost per sample (CWSs only)
$6.85 to $11.37
Burden
hrs_discuss_samp_op

Cost
cost_lt_samp[2]
No. See discussion following the exhibit.
   Collect lead tap samples
Burden per sample
0.39 to 0.67 hrs per CWS;
0.5 hrs per NTNCWS

Cost per sample
$5.29 to $9.07 per CWS
Burden
hrs_pickup_samp_op

Cost
cost_pickup_samp
Yes. See Section <IP_ADDRESS>.2, activity h).
   Determine if sample should be rejected and not analyzed
0.25 hrs/rejected sample for CWSs
hrs_samp_reject_op
Yes. See Section <IP_ADDRESS>.2, activity i).
   Analyze lead tap samples in-house or commercially
In-house Analysis (CWSs > 100K only)
Burden: 0.44 hrs/sample
Cost: $2.38/sample

In-house Analysis
hrs_analyze_samp_op[2]
cost_lab_lt_samp[2]

Yes. See Section <IP_ADDRESS>.2, activity j).

Commercial Analysis
$21.58/ sample
Commercial Analysis
cost_commercial_lab[2]
No. See discussion following the exhibit.
   Prepare and submit sample invalidation request to Primacy Agency
2 hrs per sample per CWS and NTNCWS
hrs_samp_invalid_op
Yes. See Section <IP_ADDRESS>.2, activity k).
   Inform customers of lead tap sample results
CWS/sample per sample
Burden: 0.05 hrs
Cost: $0.58

NTNCWS/system per system
Burden: 1 hr
Cost: $0.025

CWS
hrs_inform_samp_op
cost_cust_lt

NTNCWS
hrs_ntncws_inform_samp_op
cost_ntncws_cust_lt

Yes. See Section <IP_ADDRESS>.2, activity l).
   Certify to Primacy Agency that results were reported to customers
0.66 to 1 hr/monitoring period per CWS or NTNCWS
hrs_cert_cust_lt_op
Yes. See Section <IP_ADDRESS>.2, activity m).
   Submit request to renew 9-year monitoring waiver to Primacy Agency
1 hr/9 years per qualifying CWS or NTNCWS
hrs_renew_nine_op
Yes. See Section <IP_ADDRESS>.2, activity n).
   Submit sampling results and lead 90[th] calculation to Primacy Agency
1 to 1.5 hrs/monitoring period per CWS and NTNCWS

hrs_annual_lt_op[2]
No. See discussion following the exhibit.
Acronyms: CWS = community water system; LCRR = Lead and Copper Rule revisions; LSL = lead service line; NTNCWS = non-transient non-community water system; PWS = public water system.
Source: "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx."
Notes:
[1] Many of the activities listed above do not apply to NTNCWSs because, unlike CWSs, they collect their own samples from sampling locations under their control and thus, are unlikely to change sampling sites or reject samples for analysis. They also do not need to solicit sampling participation for customers or travel to their residences to pick up samples.
[2] In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina, the state pays for the cost of bottles, shipping, analysis, and providing sample results to the system. Thus, the state will incur the burden and cost for these activities in lieu of the system.
    Obtain households for each round of lead tap sampling (hrs_samp_volunt_op). For each monitoring period, CWSs will contact customers to obtain volunteers to participate in the lead tap sampling program. EPA assumed CWSs will spend 0.5 hours per customer based on the following assumptions:
      CWSs will contact customers by phone.
      CWSs will spend 20 minutes with those that agree to participate to explain the program, or 50 percent of customers, and 5 minutes with those that do not, for an average of 15 minutes per sample.
      Because systems will need to contact 2 customers for every one sample, the 15-minute burden is doubled, resulting in an average burden of 0.5 hours per sample.
The assumptions used to estimate this burden are the same as those for the LCRR with the exception that under the LCRR, systems must collect all samples from available sites served by LSLs. EPA assumed CWSs with LSLs will require additional efforts to obtain customers to participate in the sampling pool due to a more aggressive LSLR program and require 1 hour per sample. EPA applies the same inflation factors to account for customers that do not collect their sample (1-pp_hh_return_samp), sample rejection (pp_samp_reject), and sample invalidation (pp_samp_invalid) as the LCRR. See Chapter 5, Section <IP_ADDRESS>.2, activity e) for additional detail.
g)	Ship lead tap sampling materials and instructions to participating households (hrs_discuss_samp_op, cost_lt_samp). The rule allows customers to collect tap samples after receiving proper instructions from the water system. EPA assumed each CWS will spend an average of 0.25 hours to discuss sampling instructions with customers (hrs_discuss_samp_op). This estimate is based on information provided by the City of Chicago Department of Water Management (DWM) regarding its water testing program. DWM responded that on average staff required 0.25 hours to send out test kits. EPA assumed this burden included time to discuss sampling instructions with volunteers and is the same burden used for the LCRR.
   EPA assumed CWSs will ship sampling materials to customers. Thus, CWSs will also incur non-labor costs for a CWS to provide a test kit (including bottles and instruction) and ship the kits to customers (cost_lt_samp). The inputs and assumptions for this cost are provided in Exhibit B-13 and use the same inputs values as those used for systems without LSLs under the LCRR (cost_5_lt_samp). The costs under the previous rule and LCRR differ from systems with LSLs because under the LCRR, these systems must collect a fifth liter sample and will provide five sample bottles in lieu of one bottle in the sample kit. See Section <IP_ADDRESS>.2, activity g) for additional detail.
Exhibit B-13: Non-Labor Costs for CWS to Provide Test Kits (per Sample)
                        System Size (Population Served)
                                   Test Kit
                         Shipping bottles to customers
                  Total Non-Labor Costs to Provide Test Kits

                                 cost_lt_samp

                                       A
                                       B
                                    C = A+B
<=100,000
                                     $0.00
                                     $6.85
                                     $6.85
100,000-1,000,000
                                     $4.52
                                     $6.85
                                    $11.37
>1,000,000
                                     $4.52
                                     $6.85
                                    $11.37
Notes:
A: Bottles are provided as part of the commercial laboratory fee and all CWSs serving 100,000 or fewer people are assumed to use commercial labs. Bottle costs for CWSs serving > 100,000 people are based on three vendor quotes. See file, "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx," worksheet "In-House_Bottle_$."
B: Shipping cost based on information provided by the Chicago DWM in response to a 2016 questionnaire regarding their free testing program on the cost to ship a 3-bottle test kit of $6.85. (A copy of the questionnaire and DWM's responses are available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.) Note that this may overestimate shipping cost because systems will only be shipping a 1-bottle sample kit.
j)	Analyze lead tap samples in-house or commercially (hrs_analyze_samp_op, cost_lab_lt_samp, cost_commercial_lab). EPA used the same data variables and input values for the previous rule as the LCRR to model the burden and costs associated with in-house analyses that are assumed to be conducted by CWSs serving more than 100,000 people. Under the previous rule and LCRR, EPA assumed that CWSs serving 100,000 or fewer people and all NTNCWSs use a commercial laboratory. Under the previous rule, the cost for the commercial analysis (cost_commericial_lab) was the same as that for non-LSL systems under the LCRR (cost_5_commercial_lab) of $21.58 but differed from the commercial costs under the LCRR for LSL systems of $35.03. The higher commercial cost for LSL systems includes bottle costs for four additional 1-liter bottle that are used to collect a fifth liter sample (see Section Chapter 5, Section <IP_ADDRESS>.2, activity j) for additional detail).
o)	Submit sampling results and lead 90th percentile calculation to Primacy Agency (hrs_annual_lt_op). EPA estimated the burden for CWSs and NTNCWSs to submit tap monitoring results and their 90[th] percentile calculations is 1 hour for systems serving 10,000 or fewer, 1.25 hours for systems serving 10,001 to 50,000, and 1.5 hours for systems serving more than 100,000 people. These estimates are based on the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 48 (Tap Sample Calcs) (USEPA, 2015). Under the LCRR, EPA assumes systems with LSLs will incur a 25 percent higher burden because they must provide documentation if they are unable to meet their minimum sampling requirements with sites served by LSLs. See Section <IP_ADDRESS>.2, activity o) for additional detail.
Exhibit B-14 provides the SafeWater LCR model cost estimation approach for system lead tap sampling activities including additional cost inputs required to calculate these costs. As shown in the exhibit, the SafeWater LCR model relies upon additional inputs, such as number of samples for lead tap monitoring and the likelihood a system is below an AL or TL, to compute the cost per activity. For example, unit costs for k) Prepare and submit sample invalidation request to Primacy Agency is the product of the required number of samples, the probability of sample invalidation, the burden to prepare and submit the sample invalidation request, and the hourly rate. A description of the data variables and section where they are described in more detail are provided in footnote 1 to the exhibit.
Exhibit B-14: PWS Lead Tap Sampling Cost Estimation in SafeWater LCR by Activity[1]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
                             Frequency of Activity

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

   Update sampling instructions for lead tap sampling and submit to Primacy Agency
N/A. New activity required under the LCRR.
   Contact homes to establish new 100 percent LSL tap sampling pool
N/A. New activity required under the LCRR.
   Report any changes in sampling location to the Primacy Agency[3]
Total system hours per monitoring period multiplied by the system labor rate

(hrs_chng_tap_op*rate_op)

All
Model PWS is not on reduced tap sampling

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year

Cost does not apply to NTNCWSs.

Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS is on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Confer with Primacy Agency on initial lead sampling data and status under the LCRR
N/A. New activity required under the LCRR.
   Obtain households for each round of lead tap sampling
Number of required samples per system multiplied by the hours per sample and the system labor rate. The number of required samples is inflated to include those unreturned, invalidated, and rejected to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_samp_customer+(numb_samp_customer*(1-pp_hh_return_samp))+(numb_samp_customer*pp_samp_invalid)+(numb_samp_customer*pp_samp_reject))*(hrs_samp_volunt_op*rate_op)

All
Model PWS not on reduced tap monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year
Number of required samples per system multiplied by the hours per sample and the system labor rate. The number of required samples is inflated to include those unreturned, invalidated, and rejected to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_reduced_tap+(numb_reduced_tap*(1-pp_hh_return_samp))+(numb_reduced_tap*pp_samp_invalid)+(numb_reduced_tap*pp_samp_reject))*(hrs_samp_volunt_op*rate_op)
Cost does not apply to NTNCWSs.
All
Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS is on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Offer incentives to households to encourage participation in lead tap sampling program
Number of required samples per system multiplied by the cost of the incentive. This number is not inflated by the number of samples deemed invalid or rejected because it is assumed that if a sample is invalid or rejected the system will return to the same customer to resample. EPA also assumes that unreturned samples would not be eligible for an incentive.

(numb_samp_customer*cost_incentive)
Cost does not apply to NTNCWSs.
All

Model PWS not on reduced tap monitoring that offers an incentive

[1 - (p_tap_annual + p_tap_triennial + p_tap_nine)] * p_incentive
Twice per year
Number of required samples per system multiplied by the cost of the incentive. This number is not inflated by the number of samples deemed invalid or rejected, because it is assumed that if a sample is invalid or rejected the system will return to the same customer to resample. EPA also assumes that unreturned samples would not be eligible for an incentive.

(numb_reduced_tap*cost_incentive)
Cost does not apply to NTNCWSs.
All
Model PWS on annual reduced tap monitoring that offers an incentive

p_tap_annual * p_incentive
Once a year

Model PWS on triennial reduced tap monitoring that offers an incentive
p_tap_triennial * p_incentive
Every 3 years

Model PWS on nine-year reduced tap monitoring that offers an incentive

p_tap_nine * p_incentive
Every 9 years
   Ship lead tap sampling materials and instructions to participating households4
Number of required samples multiplied by the total of the hours per sample to provide instructions times the system labor rate, plus the cost of materials per sample. The number of required samples is inflated to include those unreturned, invalidated, and rejected, to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_samp_customer+(numb_samp_customer*(1-pp_hh_return_samp))+(numb_samp_customer*pp_samp_invalid)+(numb _samp_customer*pp_samp_reject))*((hrs_discuss_samp_op*rate_op)+cost_lt_samp)
Number of required samples multiplied by the cost of materials per sample. The number of required samples is inflated to include those invalidated to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_samp_customer+(numb_samp_customer*pp_samp_invalid))* cost_lt_samp)
All

Model PWS not on reduced tap sampling monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year
Number of required samples multiplied by the total of the hours per sample to provide instructions times the system labor rate, plus the cost of materials per sample. The number of required samples is inflated to include those unreturned, invalidated, and rejected, to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_reduced_tap+(numb_reduced_tap*(1-pp_hh_return_samp))+(numb_reduced_tap*pp_samp_invalid)+(numb_reduced_tap*pp_samp_reject))*((hrs_discuss_samp_op*rate_op)+cost_lt_samp)
Number of required samples multiplied by the cost of materials per sample. The number of required samples is inflated to include those invalidated to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_reduced_tap+(numb_reduced tap*pp_samp_invalid))* cost_lt_samp)
All
Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS is on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Collect lead tap samples
Number of required samples per system multiplied by the hours per sample and the system labor rate, plus the cost of materials per sample. The number of required samples is inflated to include those invalidated, unreturned, and rejected to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_samp_customer+(numb_samp_customer*pp_samp_invalid)+ +(numb_customer_samp*(1-pp_hh_return_samp))+(numb_samp_customer*pp_samp_reject))*((hrs_pickup_samp_op*rate_op)+cost_pickup_samp)
Number of required samples per system multiplied by the cost of materials per sample. The number of required samples is inflated to include those invalidated to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_samp_customer+(numb_samp_customer*pp_samp_invalid))*cost_pickup_samp
All

Model PWS not on reduced tap monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year
Number of required samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample. The number of required samples is inflated to include those unreturned, invalidated, and rejected, to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_reduced_tap+(numb_reduced_tap *(1-pp_hh_return_samp))+(numb_reduced_tap) *pp_samp_invalid)+(numb_reduced_tap*pp_samp_reject))* *((hrs_pickup_samp_op*rate_op)+cost_pickup_samp)
Number of required samples per systems multiplied by the cost of materials per sample. The number of required samples is inflated to include those invalidated to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(numb_reduced_tap+(numb_reduced_tap) *pp_samp_invalid))* *cost_pickup_samp
All
Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Determine if sample should be rejected and not analyzed
The number of samples expected to be rejected (calculated by multiplying the total number of required samples by the likelihood of rejection) multiplied by the hours per sample and the system labor rate.

(numb_samp_customer*pp_samp_reject)*(hrs_samp_reject_op*rate_op)

Cost does not apply to NTNCWSs.
All
Model PWS not on reduced tap sampling monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year
The number of samples expected to be rejected (calculated by multiplying the total number of required samples by the likelihood of rejection) multiplied by the hours per sample and the system labor rate.

(numb_reduced_tap*pp_samp_reject)*(hrs_samp_reject_op*rate_op)

Cost does not apply to NTNCWSs.
All
Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Analyze lead tap samples in-house or commercially[4]
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

The number of samples is inflated to include those invalidated, to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(((numb_samp_customer+(numb_samp_customer*pp_samp_invalid))*pp_lab_samp)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+(((numb_samp_customer+(numb_samp_customer*pp_samp_invalid))*pp_commercial_samp)*((hrs_analyze_samp_op*rate_op)+cost_commercial_lab))
Cost applies as written to NTNCWSs.
All

Model PWS not on reduced tap sampling monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

The number of samples is inflated to include those invalidated, to ensure that the cost reflects the additional burden that must occur to meet the sampling requirement.

(((numb_reduced_tap+(numb_reduced_tap*pp_samp_invalid))*pp_lab_samp)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+(((numb_reduced_tap+(numb_reduced_tap*pp_samp_invalid))*pp_commercial_samp)*((hrs_analyze_samp_op*rate_op)+cost_commercial_lab))
Cost applies as written to NTNCWSs.
All
Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS is on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Prepare and submit sample invalidation request to Primacy Agency
The number of samples expected to be invalid (calculated by multiplying the total number of required samples by the likelihood of invalidation) multiplied by the hours per sample and the system labor rate.

(numb_samp_customer*pp_samp_invalid)*(hrs_samp_invalid_op*rate_op
Cost applies as written to NTNCWSs.
All

Model PWS not on reduced tap monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year
The number of samples expected to be invalid (calculated by multiplying the total number of required samples by the likelihood of invalidation) multiplied by the hours per sample and the system labor rate.

(numb_reduced_tap*pp_samp_invalid)*(hrs_samp_invalid_op*rate_op)
Cost applies as written to NTNCWSs.
All

Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring p_tap_triennial
Every 3 years

Model PWS on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Inform customers of lead tap sample results
The number of required of samples per system multiplied by the total of the hours per sample times the system labor rate plus the material cost per sample.

(numb_samp_customer)*((hrs_inform_samp_op*rate_op)+cost_cust_lt)
Hours per sampling event multiplied by the system labor rate, plus the material cost per sampling event.

((hrs_ntncws_inform_samp_op*rate_op)+cost_ntncws_cust_lt)
All
Model PWS not on reduced tap sampling monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year
The number of required samples per system multiplied by the total of the hours per sample times the system labor rate plus the material cost per sample.

(numb_reduced_tap)*((hrs_inform_samp_op*rate_op)+cost_cust_lt)
Hours per sampling event multiplied by the system labor rate, plus the material cost per sampling event.

((hrs_ntncws_inform_samp_op*rate_op)+cost_ntncws_cust_lt)
All
Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Certify to Primacy Agency that results were reported to customers
Total hours per sampling event multiplied by the system labor rate.

(hrs_cert_cust_lt_op*rate_op)

Cost applies as written to NTNCWSs.
All

Model PWS not on reduced tap monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year

Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
    Submit request to renew 9-year monitoring waiver to Primacy Agency[3]
Total hours per sampling event multiplied by the system labor rate.

(hrs_renew_nine_op*rate_op)
Cost applies as written to NTNCWSs.
All

Model PWS on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
   Submit sampling results and lead 90[th] percentile calculation to Primacy Agency[3]
Total hours per sampling event multiplied by the system labor rate.

(hrs_annual_lt_op*rate_op)

All

Model PWS not on reduced tap monitoring

1 - (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice per year

Cost applies as written to NTNCWSs.

Model PWS on annual reduced tap monitoring

p_tap_annual
Once a year

Model PWS on triennial reduced tap monitoring

p_tap_triennial
Every 3 years

Model PWS is on nine-year reduced tap monitoring

p_tap_nine
Every 9 years
Acronyms: AL = action level; LSL = lead service line; PWS = public water system.
Notes:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 numb_reduced-tap: the number of lead tap samples for system on reduced annual, triennial, or 9-year monitoring (Chapter 5, Section <IP_ADDRESS>.1).
 numb_samp_customer: the number of lead tap samples for system on routine 6-month tap monitoring (Chapter 5, Section <IP_ADDRESS>.1).
 p_tap_annual, p_tap_triennial, and p_tap_nine: likelihood a system is collecting the reduced number of lead tap samples on an annual, triennial, or 9-year frequency, respectively (Chapter 5, Section <IP_ADDRESS>.1).
 rate_op: PWS hourly labor rate (Chapter 4, Section <IP_ADDRESS>).
[2] For modeling purposes, EPA assumed that systems would report changes in sampling location during each monitoring period.
[3] Only a subset of systems with lead 90[th] percentile values <= 5 ug/L can quality for a 9-year monitoring waiver. See Chapter 4, Section <IP_ADDRESS> for additional detail.
4 The burden and costs to provide sample bottles (cost_lt_samp) under activity g), conduct analyses under activity j), and report sample results to the system under activity o) are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.
Lead Water Quality Parameter Monitoring
Lead WQP monitoring is required for all systems serving more than 50,000 people with CCT (except systems with naturally non-corrosive water that meet the criteria in 40 CFR 141.81(b)(3) or "b3" systems) and those serving 50,000 or fewer people that exceed the lead AL of 15 ug/L. WQP samples are collected at representative sites throughout the distribution system (also referred to as tap samples) and at each EP to the distribution system. Systems must conduct WQP monitoring prior to the installation of CCT and after CCT installation. The Primacy Agency may designate OWQPs after the installation of CCT. Systems with CCT must continue to maintain WQPs at or above minimum values or within OWQP ranges designated by the Primacy Agency.
The remainder of this section is divided into four subsections:
      B.<IP_ADDRESS>: Baseline Corrosion Control Treatment
      B.<IP_ADDRESS>: Initial Monitoring Schedules
      B.<IP_ADDRESS>: Number of Samples
      B.<IP_ADDRESS>: Lead WQP Monitoring Activities
Baseline Corrosion Control Treatment
WQP monitoring requirements vary for systems with and without CCT and by type of CCT. To estimate costs associated with WQP monitoring, EPA identified systems with and without CCT, as described in Chapter 4, Section 4.3.3. For those with CCT, EPA estimated the percentage of systems that currently have one of the three types of CCT used in the cost model:
      Modify pH (pbaseph),
      Add PO4 without pH post-treatment (pbasepo4), and
      Add PO4 and modify pH (pbasephpo4)
 See Exhibit 5-14 in Chapter 5, Section <IP_ADDRESS>.1 for the baseline percent of systems with each of these exhibit CCTs.
Initial Monitoring Schedules
As described in Section <IP_ADDRESS>.1 in Chapter 4, systems with CCT could qualify for reduced WQP monitoring in the distribution system under the previous rule if they were in compliance with Primacy Agency-set OWQP ranges. The number of consecutive monitoring periods in which a system met these criteria determined if a system would collect two samples at a reduced number of sites on a semi-annual, annual, or triennial frequency. Note that the criteria for systems to qualify for reduced distribution system monitoring under the LCRR is more stringent than the previous rule and systems are no longer allowed to conduct this monitoring on a triennial frequency (see Chapter 4, Section <IP_ADDRESS>.2 for additional detail).
EPA assumed only systems serving more than 50,000 people would qualify for reduced distribution system monitoring because systems with and without CCT that serve 50,000 or fewer are only required to monitor for WQPs in those monitoring periods in which they have a lead or copper ALE. Section <IP_ADDRESS>.1 provides EPA's approach for determining the estimated percentage of systems with CCT in each size category that would be on one of four WQP distribution monitoring schedules at the start of rule implementation based on historical SDWIS/Fed data. These percentages are provided in Exhibit 4-36 and Exhibit 4-37 for ground water and surface water CWSs with CCT, respectively, and in Exhibit 4-38 and 4-39 for ground water and surface water NTNCWSs with CCT, respectively.
Number of Samples
The minimum number of WQP distribution system samples for CWSs and NTNCWSs on routine (numb_enhance_wqp) and reduced (numb_reduced_wqp) monitoring and minimum number of entry points (numb_ep_wqp) are the same under the previous rule and LCRR. See Exhibit 5-13 in Chapter 5. However, there is one new requirement under the LCRR that potentially impacts the number of distribution samples. Systems with a lead tap sample result above 15 ug/L must conduct WQP monitoring in the distribution system at or near the site with the high lead result. If an existing WQP site does not meet these criteria, the system must identify a new WQP monitoring site and use it for future sampling in addition to the existing number of WQP sites (see Chapter 5, Section <IP_ADDRESS>.3 for additional detail).
Lead WQP Monitoring Activities
EPA has developed water system costs for five lead WQP monitoring activities as shown in Exhibit B-15. The exhibit provides the unit burden and costs for each activity. The third column provides the corresponding SafeWater LCR model data variable in red/italic font. The last column indicates whether or not the activity, unit burden or cost, and the SafeWater LCR model data variable are identical to those used for the LCRR, as described in Chapter 5, Section <IP_ADDRESS>.4. The assumptions that differ from the LCRR follow the exhibit.
Exhibit B-15: PWS Lead WQP Monitoring Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
                                 Same As LCRR?
    Collect lead WQP samples in the distribution system
Burden per sample per PWS
0 hrs

Cost per sample
No CCT: $2.15 (CWS & NTNCWS)
pH adjustment:
  $2.15 to $2.32 (CWS);
  $1.83 to $2.15 (NTNCWS)
Orthophosphate:
  $2.15 to $4.14 (CWS)
  $1.83 to $2.15 (NTNCWS)
Burden
hrs_wqp_op

Cost
No CCT: cost_wqp_material
pH: cost_wqp_material_ph

Orthophosphate: cost_wqp_material_ortho
Yes. See Section <IP_ADDRESS>.4, activity p)
   Analyze distribution system lead WQP samples
In-House Burden per sample
No CCT: 0.15 hrs (CWS & NTNCWS)
pH adjustment:
  0.15 to 0.46 hrs (CWS)
  0.15 hrs (NTNCWS)
Orthophosphate:
  0.15 to 1.34 hrs (CWS)
  0.15 hrs (NTNCWS)

In-House Cost per sample
No CCT: $0.52 (CWS & NTNCWS)
pH adjustment:
  $0.52 to $0.72 (CWS)
  $0.52 (NTNCWS)
Orthophosphate:
  $0.52 to $0.78 (CWS)
  $0.52 (NTNCWS)

In-House Burden
No CCT: hrs_wqp_analyze_dist_op
pH: hrs_wqp_analyze_ph_op

Orthophosphate: hrs_wqp_analyze_ortho_op

In-House Cost
No CCT: cost_wqp_analyze
pH: cost_wqp_ph_analyze

Orthophosphate: cost_wqp_ortho_analyze

Yes. See Section <IP_ADDRESS>.4, activity q).

Commercial Cost per sample
No CCT: $45.85 (CWS & NTNCWS)
pH adjustment: $23.92 (CWS & NTNCWS)
Orthophosphate: $49.35 (CWS & NTNCWS)
Cost for Commercial Analysis
No CCT: cost_lab_wqp[1]
pH: cost_lab_ph_wqp
Orthophosphate: cost_lab_ortho_wqp
No. See discussion following the exhibit.
   Collect lead WQP samples from entry points
Burden per sample
0.5 hrs for 80 percent of ground water PWSs

Cost per sample
No CCT: $2.15 (CWS & NTNCWS)
pH adjustment:
  $2.15 to $2.32 (CWS);
  $1.83 to $2.15 (NTNCWS)
Orthophosphate:
  $2.15 to $4.14 (CWS)
  $1.83 to $2.15 (NTNCWS)
Burden
hrs_ep_wqp_op

Cost
cost_ep_wqp_material cost_ep_wqp_ph_material

cost_ep_wqp_ortho_material
Yes. See Section <IP_ADDRESS>.4, activity r)
   Analyze entry point lead WQP samples
In-house Burden per sample
No CCT: 0.15 hrs (CWS & NTNCWS)
pH adjustment:
  0.15 to 0.46 hrs (CWS)
  0.15 hrs (NTNCWS)
Orthophosphate:
  0.15 to 1.34 hrs (CWS)
  0.15 hrs (NTNCWS)

In-House Cost per sample
No CCT: $0.52 (CWS & NTNCWS)
pH adjustment:
  $0.52 to $0.72 (CWS)
  $0.52 (NTNCWS)
Orthophosphate:
  $0.52 to $0.78 (CWS)
  $0.52 (NTNCWS)

In-House Burden
hrs_wqp_analyze_ep_op
hrs_wqp_analyze_ph_ep_op

hrs_wqp_analyze_ortho_ep_op

In-House Cost
cost_wqp_analyze_ep
cost_wqp_analyze_ph_ep

cost_wqp_analyze_ortho_ep

Yes. See Section <IP_ADDRESS>.4, activity s)

Commercial Cost per sample
No CCT: $45.85 (CWS & NTNCWS)
pH adjustment: $23.92 (CWS & NTNCWS)
Orthophosphate: $49.35 (CWS & NTNCWS)
Commercial Cost
cost_lab_wqp_ep[1]

cost_lab_wqp_ph_ep

cost_lab_wqp_ortho_ep
No. See discussion following the exhibit.
   Report lead WQP sampling data and compliance with OWQPs
No CCT: 4 hrs/PWS
With CCT: 5 hrs/PWS
hrs_report_wqp_op
Yes. See Section <IP_ADDRESS>.4, activity t)
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRR = Lead and Copper Rule revisions; NTNCWS = non-transient non-community water system; OWQP = optimal water quality parameters; PWS = public water system; WQP = water quality parameter.
Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx."
Note:
1 As explained in more detail in the text following this exhibit, the commercial WQP laboratory costs differ between the previous rule and LCRR for systems without CCT.
    Analyze distribution system lead WQP samples (cost_lab_wqp). The only difference in unit burden and cost for lead WQP monitoring for the previous rule compared to the LCRR is the commercial costs per sample for systems with no CCT (cost_lab_wqp). Under the previous rule and LCRR, systems without CCT that have an ALE must analyze pH and alkalinity. The previous rule also required these systems to analyze calcium. The LCRR no longer requires calcium as an analyte because it is used to evaluate the effectiveness of calcium stabilization that has been eliminated as a CCT option under the LCRR. For modeling purposes, EPA assumed the following for both rules:
      All systems serving more than 50,000 people would already have CCT in place or are b3 systems and would not be required to install CCT.
      All systems would conduct pH in-house but only CWSs serving more than 100,000 people would conduct all their WQP analyses in-house. All other systems would use a commercial laboratory.
Under the previous rule, EPA assumed that CWSs and NTNCWSs serving 50,000 or fewer people without CCT would incur a commercial cost of $45.85 to analyze alkalinity ($23.92) and calcium ($21.93) based on the quotes provided by seven laboratories. Under the LCRR, the commercial laboratory cost includes only the alkalinity cost of $23.92. Also refer to Chapter 5, Section <IP_ADDRESS>.4, activity q) for a discussion of WQP analytical distribution system requirements under the LCRR.
    Analyze entry point lead WQP samples (cost_lab_wqp_ep). Similar to activity q), the only difference in unit burden and cost for lead WQP EP monitoring for the previous rule compared to the LCRR is the commercial costs per entry point sample for systems with no CCT (cost_lab_wqp_ep) See activity q) for detailed assumptions.
The SafeWater LCR model cost estimation approach for estimating the cost of lead WQP monitoring including additional cost inputs required to calculate these costs are identical to those for the LCRR. For additional detail, refer to Chapter 5, Exhibit 5-41.
Copper Water Quality Parameter Monitoring
The SafeWater LCR models Copper WQP Monitoring separately from the Lead WQP Monitoring. The frequency of Lead WQP Monitoring depends on the lead 90[th] percentile, with all systems above the AL and all systems serving more than 50,000 people except b3 systems conducting Lead WQP Monitoring. Copper WQP Monitoring is required when a system exceeds the copper AL. To not double count the cost of WQP monitoring for systems experiencing both a copper ALE and a lead ALE simultaneously, the SafeWater LCR models the costs of Copper and Lead WQP Monitoring separately and restricts Copper WQP Monitoring to systems with a copper ALE only and lead 90[th] percentile not greater than the lead AL.
Note that the cost inputs used to estimate WQP costs in response to a copper ALE are identical to those incurred in response to a lead ALE that are presented in Exhibit B-15 and discussed in Section B.<IP_ADDRESS> with the following exceptions:
 The likelihood of a system exceeding the copper ALE, which corresponds to p_copper_ale, is used in lieu of system's lead 90[th] percentile level. See Exhibit 5-42 and Exhibit 5-43 in Chapter 5 for the likelihood that a CWS and NTNCWS, respectively, will exceed the copper AL of 1.3 mg/L, but not the lead AL of 15 ug/L (p_copper_ale).
      Systems are not assumed to be on reduced WQP distribution system monitoring in response to a copper ALE, and all systems are assumed to be on a 6-month standard monitoring schedule. Thus, the data inputs associated with reduced monitoring are not applicable. These include the reduced number of WQP monitoring samples per distribution sample site (numb_reduced_wqp), and the likelihood that a system will be on a 6-month (p_wqp_six_red), annual (p_wqp_annual), or triennial schedule (p_wqp_triennial) WQP sampling schedule.
 The activities, unit burden and costs, and data variables used to estimate copper WQP monitoring costs are identical to those for lead, as shown in Exhibit B-16, with the exception that they are triggered in response to a copper ALE.
Exhibit B-16: PWS Copper WQP Monitoring Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
                                 Same As LCRR?
Collect copper WQP samples in the distribution system
                      Same as Exhibit B-15, activity p).
Analyze distribution system copper WQP samples
                      Same as Exhibit B-15, activity q).
Collect copper WQP samples from entry points
                      Same as Exhibit B-15, activity r).
Analyze entry point copper WQP samples
                      Same as Exhibit B-15, activity s).
Report copper WQP sampling data and compliance with OWQPs
                      Same as Exhibit B-15, activity t).
Acronyms: ALE = action level exceedance; LCRR = Lead and Copper Rule revisions; OWQP = optimal water quality parameter; WQP = water qualify parameter.
Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx."
The SafeWater LCR model cost estimation approach for estimating the cost of copper WQP monitoring including additional cost inputs required to calculate these costs are identical to those for the LCRR. For additional detail, refer to Exhibit 5-45 in Chapter 5.
Source Water Monitoring
Under the previous rule, source water monitoring was required if a water system had a significant source water change. PWSs also were required to conduct source water monitoring when they exceeded the lead or copper AL. The likelihood of a significant source change or ALE, as well as the required number of source water samples, are described in Chapter 5, Section <IP_ADDRESS>.1.
EPA has developed system costs for three source water monitoring activities as shown in Exhibit B-17. The exhibit provides the unit burden and/or cost for each activity. The third column provides the corresponding SafeWater LCR model data variable in red/italic font. Activities that are conducted by some states in lieu of the water system are identified in a footnote below the exhibit. The last column indicates the unit burden or cost, and the SafeWater LCR model data variable that are identical to those used for the LCRR, as described in Chapter 5, Section <IP_ADDRESS>.2. The one difference is that under the previous rule, systems must continue to conduct source water monitoring whenever they had a lead or copper ALE. Under the LCRR, systems can forego source water monitoring if they previously sampled source water in response to an ALE, the Primacy Agency has not required source water treatment, and they have not added any new water sources that changes their primacy source type. For modeling purposes, no system is assumed to have source water treatment.
Exhibit B-17: PWS Source Monitoring Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
                                 Same As LCRR?
   Collect source water samples
Burden
0.5 hrs/sample

Cost
$1.83/sample for CWSs serving > 100K
Burden
hrs_source_op

Cost
cost_source_material[1]
Yes. See Section <IP_ADDRESS>.2 -activity z)
   Analyze source water samples
In-House Burden
0.44 hrs/sample for CWSs serving > 100K

In-House Cost
$2.38/sample for CWSs serving > 100K

Commercial Cost
$21.58/sample for CWSs serving <= 100K and NTNCWSs
In-House Burden
hrs_analyze_samp_op[1]

In-House Cost
cost_source_analyze[1]

Commercial Cost
cost_source
Yes. See Section <IP_ADDRESS>.2 -activity aa)
   Report source water monitoring results to Primacy Agency
1 hour/report
hrs_report_source_op[1]
Yes. See Section <IP_ADDRESS>.2 -activity bb)
Acronyms: CWS = community water system; LCRR = Lead and Copper Rule revisions; NTNCWS = non-transient non-community water system; PWS = public water system.
Sources:
z): See Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 15 in Appendix H for burden (USEPA, 2015); "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx," worksheet: "In-House Bottle_$" for costs.
aa): See "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx," worksheet: "In-House Burden_hrs"; "In-House_Consumables_Summary_$"; and "Commercial Analytical_$."
bb): Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 48 in Appendix H (USEPA, 2015).
Note:
1 The burden and costs for these activities are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.
Exhibit B-18 shows the SafeWater LCR model cost estimation approach for system source water monitoring activities including additional cost inputs required to calculate these costs.
Exhibit B-18: PWS Source Water Monitoring Cost Estimation in SafeWater LCR by Activity[1]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th] - Range
Other Conditions

    Collect source water samples
The number of EPs per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_st_sample)*((hrs_source_op*rate_op)+cost_source_material))
Cost applies as written to NTNCWSs.
At or below AL
Model PWSs with surface water sources and a copper ALE

p_copper_ale
Once per event

Model PWSs with ground water sources and a copper ALE

p_copper_ale
Every three years per event

Above AL
Model PWSs with surface water sources
Once a year

Model PWSs with ground water sources
Every three years

All
Model PWSs on reduced tap monitoring that have had a significant source change

1- [p_tap_annual + p_tap_triennial +, p_tap_nine] and p_source_chng* p_source_sig
Once per event
Analyze source water samples[2]
There are different labor (burden) and material costs for a sample analyzed in house and a sample analyzed using a commercial lab. The in-house analysis costs are calculated using the number of required samples per EP multiplied by the number of EPs per system times the percentage of samples analyzed in house and the system labor rate, plus the material cost of the in-house analysis per sample. The commercial lab analysis costs are calculated using the number of required samples per EP multiplied by the number of EPs per system times the percentage of samples analyzed commercially times the material cost of the commercial lab analysis per sample.

((pp_lab_samp*(numb_ep*numb_st_sample))*((hrs_analyze_samp_op*rate_op)+cost_source_analyze))+((pp_commercial_samp*(numb_ep*numb_st_sample))*cost_source)
Cost applies as written to NTNCWSs.
At or below AL
Model PWS with surface water sources and a copper ALE

p_copper_ale
Once per event

Model-PWS with ground water sources and a copper ALE

p_copper_ale
Every three years per event

Above AL
Model PWS with surface water sources
Once a year

Model PWS with ground water sources
Every three years

All
All model PWSs on reduced tap monitoring that have had a significant source change

1- [p_tap_annual + p_tap_triennial +, p_tap_nine] and p_source_chng* p_source_sig
Once per event
Report source water monitoring results
The total reporting hours per system multiplied by the labor rate.

(hrs_report_source_op*rate_op)
Cost applies as written to NTNCWSs.
At or below AL
Model PWS with surface water sources and a copper ALE

p_copper_ale
Once per event

Model PWS with ground water sources and a copper ALE

p_copper_ale
Every three years per event

Above AL
Model PWS with surface water sources
Once a year

Model PWS with ground water sources
Every three years

All
All model PWSs on reduced tap monitoring that have had a significant source change

1- [p_tap_annual + p_tap_triennial + p_tap_nine] and p_source_chng* p_source_sig
Once per event
Acronyms: AL = action level; ALE = action level exceedance; CWS = community water system; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 numb_ep: number of entry points per systems (Chapter 5, Section <IP_ADDRESS>.3).
 numb_st_sample: number of samples per entry point for source water monitoring (Chapter 5, Section <IP_ADDRESS>.1).
 p_copper_ale: likelihood a system with exceed the copper AL (Chapter 5, Section <IP_ADDRESS>.1).
 p_source_chng: Likelihood a system will have a source change (Chapter 4, Section <IP_ADDRESS>).
 p_source_sig: Likelihood that the system will have a significant change in which it changes its primary source, e.g., for ground water to surface water (Chapter 4, Section <IP_ADDRESS>).
 rate_op: PWS hourly labor rate (Chapter 4, Section <IP_ADDRESS>).
[2] The burden and costs to provide sample bottles (cost_source_material) under activity z), conduct analyses under activity aa), and report results to the system under activity bb) are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.
PWS Corrosion Control Costs
This section discusses water system activities related to CCT installation (Section B.5.2.1) and re-optimization (Section B.5.2.2) and associated burden and costs.
The derivation and values for baseline pH (baselineph_wocct, baselineph_woph, baselineph_wpo4ph, baselineph_wph) and baseline PO4 dose (baselinepo4dose) are the same as those used to calculate the CCT costs for the final LCRR and can be found in Chapter 5, Exhibits 5-54, 5-55, and 5-57.
CCT Installation
PWSs without CCT may be required to install CCT under the LCRR if they exceed the lead AL. Costs related to CCT installation are categorized as follows:
 B.<IP_ADDRESS>: Capital and operations and maintenance costs.
 B.<IP_ADDRESS>: Ancillary CCT Installation costs.
Capital and Operation and Maintenance CCT Installation Costs
Under the previous LCR, a PWS that installs CCT will choose among three technology options that is listed as activity c) in Exhibit B-11.
 Add PO4 and pH post-treatment
 Add PO4 and modify pH
 Modify pH
EPA assumes that model-PWSs with a baseline pH (baselineph_wocct) equal to or greater than 7.2, but less than 8.4, will choose to add PO4 and conduct pH post-treatment, while those with pH below 7.2 will choose to add PO4 and modify pH. For model PWSs that add PO4 with pH post-treatment, the PO4 dose is equal to 3.2 mg/L and post-treatment will maintain the current pH level (baselineph_wocct). For model-PWSs that add PO4 and adjust pH, EPA assumes the same PO4 dose of 3.2 mg/L. In addition, model PWS will adjust pH from their starting pH (baselineph_wocct) to 7.2. EPA assumes that model-PWS with a baseline pH greater that 8.4 will choose to modify pH.