SUPPORTING STATEMENT
Information Collection Request (ICR) for the Lead and Copper Rule Revisions (LCRR)

1 	IDENTIFICATION OF THE INFORMATION COLLECTION
1(a) 	Title and Number of the Information Collection
TITLE: Information Collection Request for Lead and Copper Rule Revisions (LCRR)

EPA ICR Number: 2606.03

OMB Control Number: 2040-0297

1(b) 	Short Characterization/Abstract
On January 15, 2021, the U.S. Environmental Protection Agency (EPA) published in the Federal Register (FR) the "National Primary Drinking Water Regulations: Lead and Copper Rule Revisions" (LCRR) (86 FR 4198). In a subsequent action on June 16, 2021, EPA published the "National Primary Drinking Water Regulations: Lead and Copper Rule Revisions; Delay of Effective and Compliance Dates" (86 FR 31939), which set the new effective date for the LCRR as December 16, 2021, and the compliance date as October 16, 2024. Office of Management and Budget (OMB) approved the initial "Information Collection Request for Lead and Copper Rule Revisions (LCRR)" on July 25, 2022, and set the renewal date as December 31, 2023. Therefore, this ICR renewal characterizes the incremental impacts of the LCRR in terms of the burden and costs for the three years after December 31, 2023 (January 1, 2024 through December 31, 2026). Also, this ICR modifies the extension to the ICR titled, "Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules" (80 FR 78224, December 16, 2015, OMB control number 2040-0204), which estimates the burden and costs associated with the previous Lead and Copper Rule (LCR) as well as other rules.
In addition to the renewal of the "Information Collection Request for Lead and Copper Rule Revisions (LCRR)," this ICR includes information on the potential burden that may result from respondents (public water systems, primacy agencies, and EPA) that choose to follow recommendations included in EPA's "Guidance for Developing and Maintaining a Service Line Inventory" (August 2022, EPA 816-B-22-001) when seeking to comply with the inventory requirements of the LCRR over the same three-year period of January 1, 2024 to December 31, 2026. While this ICR covers a period of time following the LCRR compliance date, EPA intends to revise the LCRR prior to the compliance date. EPA intends to promulgate the Lead and Copper Rule Improvements (LCRI) by October 16, 2024 and revise many rule areas of the LCRR. EPA will issue an ICR that will revise the information collection to reflect the LCRI when it proposes and promulgates the LCRI. The following description of the LCRR and the estimated burden and costs associated with this ICR renewal for the LCRR describe what would happen without promulgation of the LCRI and is provided for the reader to understand the information that would be collected if the LCRI is not promulgated. However, EPA intends to promulgate the LCRI. At that time, EPA also intends to issue a new ICR that would describe and assess the revised burden and costs to reflect the LCRI when it proposes and promulgates the LCRI.
The Safe Drinking Water Act (SDWA) is the core statute addressing drinking water at the federal level. Under SDWA, EPA sets public health goals and enforceable standards for drinking water quality. In 1991, EPA promulgated the LCR, which requires public water systems (PWSs) to minimize lead and copper in drinking water by reducing water corrosivity and preventing lead and copper from leaching from premise plumbing and drinking water distribution system components. The LCR established a National Primary Drinking Water Regulation (NPDWR) for lead and copper that consists of a treatment technique requirement, including but not limited to corrosion control treatment (CCT), lead service line replacement (LSLR), and public education action, as well as established levels (ALs) for the 90[th] percentile values of lead and copper, routine monitoring and sampling. Between 2000 and 2007, EPA revised the LCR on three different occasions to streamline rule requirements, promote and strengthen national implementation, and reduce burden for water systems.
The LCRR revised the previous version of this NPDWR and requires community and non-transient non-community water systems to optimize corrosion control and, under specified conditions, install source water treatment, conduct public education, and/or replace lead service lines (LSLs) in the distribution system. The LCRR also expands public education requirements for lead, requires greater public access to information on lead, and further targets sensitive subpopulations by requiring additional lead in drinking water testing at schools and child care facilities. The LCRR is designed to identify and reduce lead exposure at systems with elevated lead concentrations in their drinking water by establishing a lead trigger level (TL) of 0.010 milligrams per liter (mg/L) in addition to the lead AL of 0.015 mg/L that was established under the LCR (a system's lead concentration is measured as the 90[th] percentile water lead level derived from a set of samples collected at consumers taps during each monitoring period). The LCRR retains both the lead and copper ALs, revises requirements for systems with a lead action level exceedance (ALE) and sets additional requirements for systems with a lead trigger level exceedance (TLE). Note, the maximum contaminant level goals (MCLGs) for both lead and copper have not been modified by the LCRR. See the LCRR final rule Federal Register for detailed information on the specific regulatory requirements (86 FR 4198).
Water systems required to comply with the regulation include Federal, state, tribal, and local governmental entities as well as private entities. States (and tribes) that have been granted primary enforcement authority (i.e., primacy) for the LCR are responsible for overseeing rule implementation by systems within their jurisdiction. In instances where a state or tribe does not have primacy, the EPA Region is the primacy agency. Systems demonstrate compliance through reporting the analytical results of collected samples, LSL statistics (both the number of LSLs present in a system and the number of LSLs replaced following a TLE or ALE), and other information to the primacy agency. Systems use this data to demonstrate compliance, assess treatment options, operate and maintain installed treatment, and communicate water quality information to consumers served by the system. Primacy agencies use the data to determine compliance, designate treatment to be installed, and set enforceable operating parameters. Primacy agencies are also required to report a subset of the data to EPA, which uses this information to protect public health by ensuring compliance with the LCR, measuring progress toward meeting the LCR's goals, and evaluating the appropriateness of state and tribal implementation activities. The information reported by primacy agencies to EPA can be found in the Safe Drinking Water Information System (SDWIS).
In 2024, the first year of the LCRR ICR renewal period, which includes the October 16, 2024 LCRR compliance date, PWSs should still be engaged in the regulatory startup activities identified in the original "Information Collection Request for Lead and Copper Rule Revisions (LCRR)." These activities include reading and understanding the LCRR, assigning personnel and resources for rule implementation, attending training and receiving technical assistance from the state, developing initial LSL inventories and submitting demonstrations for systems that do not have lead, galvanized requiring replacement (GRR), and unknown service lines, and conferring with primacy agencies on initial planning for LSLR and preparation of an LSLR plan when lead, GRR, and unknown service lines are present. During this same period, primacy agencies will conduct startup activities that include adopting the rule and developing a program to implement it, modifying their data systems, providing system staff with training and technical assistance, providing internal staff with training for implementation, assisting with initial LSL inventories and reviewing initial inventories, reviewing demonstrations of no LSLs, GRRs, and unknown lines from systems, and conferring with systems on initial planning for LSLR and reviewing the LSLR plan.
Following the LCRR compliance date, both systems and primacy agencies must work to implement several ongoing and additional regulatory requirements. The resultant ICR related burden and costs associated with these implementation activities are estimated in years 2025 and 2026 of this ICR renewal. The LCRR ICR water system activities occuring in years 2025 and 2026 include: ongoing rule implementation and administration, lead and copper tap monitoring, CCT, find-and-fix, water quality parameter monitoring, source water monitoring, LSL inventory updates, LSLR, small system point-of-use (POU) treatment as a compliance alternative, lead public education and outreach, public notification, and lead in drinking water testing programs at schools and child care facilities. During this same period, the burden and cost to primacy agencies stems from their review and oversight of the activities associated with each of the PWS requirements outlined above as well as training staff and managing data systems. See the LCRR final rule Federal Register notice for detailed information on the specific regulatory requirements to occur in the years 2024, 2025, and 2026 (86 FR 4198). However, note that EPA intends to revise many of the parts of the LCRR through the LCRI prior to the October 16, 2024, compliance date, including a future ICR associated with the LCRI.
In this ICR, EPA is also assessing the potential burden and cost to public water systems, primacy agencies, and EPA that choose to follow the non-binding recommendations made by EPA in its "Guidance for Developing and Maintaining a Service Line Inventory" (August 2022, EPA 816-B-22-001), or SL Inventory Guidance, when seeking to comply with the inventory requirements of the LCRR over the same three-year period (January 1, 2024 through December 31, 2026).
The purpose of the SL Inventory Guidance is to assist water systems as they develop and maintain their service line inventories and to provide primacy agencies with needed information for oversight and reporting to EPA. The guidance covers the lifecycle of the inventory, including inventory creation, material investigations, system reporting, primacy agency review, public accessibility of service line information, and service line consumer notification. In addition, the guidance provides best practices, case studies, and templates related to topics, such as the classification of service line materials; best practices for service line material investigations; inventory form and format; inventory accessibility; tools to support inventory development and data tracking; and ways to prioritize service line investigations.
More specifically, in this ICR, EPA assessed the potential incremental burden and cost associated with the general recommendations for PWSs to: create an initial inventory that is as thorough as possible; provide, in the publicly accessible inventory, location identifiers for all service lines that are sufficiently detailed to allow the identification of a specific service line; expand inventories to include service line subclassifications, other plumbing components such as lead connectors, and other details such as source of information, pipe diameter, and installation date; conduct interviews with experienced staff and plumbers to help focus the inventory effort and locate system records; interview neighboring water systems about regional construction practices; consider inventory practices as something that can be worked into the day-to-day activities of the system rather than treated as an independent effort; consider developing or modifying standard operating procedures (SOPs) to document how they will collect service line information during normal operations and update their inventories; partner with plumbers and other third parties to obtain information on service line materials; document the records they reviewed (including information from past reviews) as a best practice and include the source of the material classification in their inventory; and continue to gather information on service line materials after the lines have been classified and assess the accuracy of historical records.
The ICR also assesses the potential burden and cost impacts of the SL Inventory Guidance recommendations associated with the LCRR requirement to update the inventory. The guidance recommends that PWSs begin engaging customers and conducting proactive, on-site service line material investigations as soon as possible to improve their inventory, verify existing records, and reduce the number of unknowns. The service line investigative techniques discussed in the SL Inventory Guidance include visual observation, water quality sampling, predictive modeling, and excavation.
A third category of potential burden and costs that could result from PWSs choosing to implement the guidance recommendations are those associated with public accessibility of the inventory. In the guidance, EPA recommends that systems select the best method for sharing the inventory data with the public given their data sharing infrastructure, technological capabilities, and staff limitations. Online systems could share data in the form of interactive maps or downloadable spreadsheets on the system's website or through other cloud-based sharing apps or FTP/SFTP servers. For PWSs that do not have an online system to disseminate inventory data, EPA recommends that these PWSs consider developing such a system. Alternatively, in the guidance, EPA suggests that information can be shared in a tabular data format in preexisting utility mailings or newsletters.
Appendix A of the SL Inventory Guidance also provides templates to assist primacy agencies and PWSs to standardize and potentially simplify the inventory development and update process. For detailed information on the SL Inventory Guidance recommendations and templates, see https://www.epa.gov/system/files/documents/2022-08/Inventory%20Guidance_August%202022_508%20compliant.pdf.
For the three years (2024 to 2026) covered by this ICR renewal, the total net respondent burden associated with this ICR is estimated to be 28,980,857 hours, or an average net burden of 9,660,286 hours per year. The corresponding total net costs are estimated to be $1,923,487,269, or an average of $641,162,423 per year. EPA estimates the average net per-respondent burden for PWSs to be 372 total hours, or 124 hours per year. Average net per -respondent costs for PWSs are estimated to be $24,935, or $8,312 per year. The Agency estimates that the average burden per primacy agency is 67,558 hours, or 22,519 hours per year. The corresponding respondent net costs per primacy agency are estimated to be an average of $4,222,388, or $1,407,463 per year.
The total number of respondents for this ICR is 67,712. Fifty-six of these respondents are primacy agencies and the remaining 67,656 respondents are water systems. The total number of responses for these respondents is 168,167,669 with 166,068,857 responses for water systems and 2,098,812 responses for primacy agencies. The average burden per response is 0.17 hours. The average cost per response is $11.44.

2 	NEED FOR AND USE OF THE COLLECTION
2(a) 	Need/Authority for the Collection
EPA needs comprehensive and current information on lead and copper occurrence and associated enforcement activities to implement its program oversight and enforcement responsibilities mandated by SDWA. EPA identified rule changes in the LCRR rulemaking that clarify the intent of the LCR as well as ensure and enhance protection of public health through reduction in lead exposure. EPA will use the information collected to support the responsibilities outlined in SDWA. EPA will be able to strengthen rule implementation through the LCRR in the areas of monitoring, customer awareness, CCT, and LSLR. The LCRR does not alter the current MCLGs or treatment technique approach to controlling lead and copper in drinking water.
The authority for this collection is derived from different parts of SDWA, including the definition for a "primary drinking water regulation" under Section 1401(1)(D) of SDWA, which requires that a "primary drinking water regulation means a regulation" that "contains criteria and procedures to assure a supply of drinking water which dependably complies with such maximum contaminant levels [or treatment techniques promulgated in lieu of a maximum contaminant level]; including accepted methods for quality control and testing procedures to [e]nsure compliance with such levels and to [e]nsure proper operation and maintenance of the system..." Furthermore, Section 1445(a)(1)(A) of SDWA requires that "[e]very person who is subject to any requirement of this subchapter or who is a grantee, shall establish and maintain such records, make such reports, conduct such monitoring, and provide such information as the Administrator may reasonably require by regulation to assist the Administrator in establishing regulations under this subchapter, in determining whether such person has acted or is acting in compliance with this subchapter..." In addition, Section 1413(a)(3) of SDWA requires primacy agencies to "keep such records and make such reports...as the Administrator may require by regulation."
The sections from the SDWA 1996 Amendments, discussed above, are included as Appendix A to this document.
2(b) 	Uses/Users of the Data
2(b)(i) 	 Uses of the Data
Primary users of the data collected under this ICR are EPA, water system managers, consumers, and primacy agencies (i.e., state, territorial, and tribal regulators and, in some instances, EPA Regional Administrators). This section contains more information about how the lead and copper data generated by the LCRR regulatory changes will be used. The section also indicates how the non-binding recommendations from the SL Inventory Guidance may be used to improve PWS and primacy agency LCRR regulatory compliance.
The LCRR makes several changes to the lead and copper tap sampling. It requires all systems to 1) re-evaluate their tap sampling location based on their LSL inventory to ensure they are collecting tap samples from sites with LSLs (i.e., highest risk sites) and 2) update LSL inventories according to the tap sampling schedule but no more frequent than annually. The LCRR codifies the tap sampling protocol guidance issued by the EPA in February 2016. In addition, the LCRR modifies how systems calculate the 90[th] percentile lead level. For example, when a water system with LSLs has an insufficient number of sites to meet the minimum number of tap samples, the system must use all of the samples from LSL sites and the samples from non-LSL sites with the highest lead results to meet the minimum number of tap samples, even when more than the necessary number of tap samples are collected from these non-LSL sites. A system's lead 90[th] percentile will be used as a criterion to determine additional requirements. EPA did not revise the minimum number of required samples or the requirements to analyze a tap sample for both lead and copper. The burden for these revisions begins to accrue after the compliance date of October 16, 2024. Tap monitoring will be used to:
Evaluate the quality of water delivered to customers;
Evaluate system-specific needs, including examining treatment effectiveness;
Inform educational material provided to the public, including tap sample results;
Assess compliance and determine when it is necessary to alert the public of possible health risks resulting from non-compliance with Federal or State regulations; and
Modify monitoring frequencies to address potential health risks.
The LCRR includes revisions to CCT and water quality parameter (WQP) monitoring including the removal of calcium carbonate stabilization as a treatment technique and calcium as a regulated WQP. For water systems with CCT, exceedance of the lead TL or AL requires re-optimization. A water system without CCT would conduct a CCT study if it exceeds the lead TL and would implement CCT if it subsequently exceeded the lead AL. Another CCT-related change includes the revision of sanitary survey requirements to include CCT review and WQP assessment and consideration of potential CCT changes based on updated guidance that has been issued by EPA. The LCRR adds a new find-and-fix provision, requiring water systems to collect a follow-up sample for each lead tap sample that exceeds 0.015 mg/L. Systems with CCT are also required to collect a WQP sample and evaluate if localized or systemwide CCT adjustment is needed. As with tap sampling, WQP monitoring will be used to:
 Evaluate the quality of water delivered to customers;
Evaluate system-specific needs, including examining treatment effectiveness;
Assess compliance and determine when it is necessary to alert the public of possible health risks resulting from non-compliance with Federal or State regulations; and
Modify monitoring frequencies to address potential health risks.

The LCRR requires that systems complete and update an LSL inventory according to the tap sampling schedule, which is a comprehensive service line materials inventory that identifies LSLs and galvanized pipes that are currently or have ever been downstream of an LSL, and unknown service lines. The inventory will be used to inform LSLR efforts, lead and copper tap sampling sites, and public education efforts. In addition to the specific requirements of the LCRR, the SL Inventory Guidance (August 2022, EPA 816-B-22-001) provides water systems with additional information and recommendations that will assist the systems in developing a comprehensive and accurate service line inventory that will facilitate LCRR compliance, improve LSLR program efficiency, provide greater public health protection, potentially assist in obtaining external funds for inventory development and LSLR, and provide potential cost savings in complying with regulatory sampling, public education, and LSLR requirements. The SL Inventory Guidance recommendations, when implemented by systems, will also provide primacy agencies with robust inventory information for oversight and reporting. The public will also benefit from improved information on exposure to lead that will improve averting behaviors.
The revisions to the LCR requirements for LSL testing and replacement include requiring full LSLR at a mandatory minimum rate of three percent per year in response to a lead ALE and full LSLR based on a goal rate negotiated by the system and the primacy agency in response to a lead TLE. The LCRR prohibits systems from counting partial LSLRs toward their mandatory replacement rate or goal rate and eliminates the "test out" provision. Systems are required to replace the system-owned portion of the LSL if they are made aware that the customer is replacing their portion.
The revisions also require systems to 1) provide a pitcher filter certified to remove lead and replacement cartridges to last a minimum of six months and 2) collect one follow-up lead tap sample between three to six months for each affected residence after any LSLR. Systems must also develop standard operating procedures that help define operations that disturb LSLs and practices to minimize disturbance and consumer exposure to lead. Also, systems must conduct targeted public education (PE) to customers with LSLs, GRRs, and unknown service lines to encourage them to participate in the LSLR program. The data collected as the result of this revision will primarily be used to demonstrate compliance and determine when it is necessary to alert the public of possible health risks.
      The LCRR provides four compliance alternatives for a lead ALE to allow increased flexibility for small community water systems (CWSs) that serve 10,000 or fewer people and all non-transient and non-community water systems (NTNCWSs). The rule allows these water systems to choose among the options, which would allow them to select the most financially and technologically viable strategy that is effective in reducing lead in drinking water. The LCRR outlines the following compliance alternatives for small CWSs and NTNCWSs: 1) full LSLR in 15 years, 2) installation and maintenance of optimized corrosion control treatment (OCCT), 3) installation and maintenance of POU devices, and 4) replacement of all lead-bearing plumbing fixtures at every tap where water could be used for human consumption. The CWSs and NTNCWSs must have control of all plumbing materials to select option four. The data collected as a result of this revision will primarily be used to determine compliance and determine when it is necessary to alert the public of possible health risks resulting from non-compliance with federal or State regulations.
The LCRR adds additional lead PE and outreach requirements for systems responding to a lead ALE. The LCRR also codifies the Water Infrastructure Improvements for the Nation Act (WIIN Act), which requires water systems to provide public notice of a lead ALE within 24 hours. Most of the new PE requirements apply to systems regardless of their lead 90[th] percentile levels. The revisions include additional outreach to those potentially impacted by water-related work, new customers, and individual households with high lead results. Revisions would also increase information available to health care providers and the public and require updated lead language in the Consumer Confidence Report. CWSs that are conducting voluntary or mandatory LSLR would also be required to perform targeted outreach to customers with LSLs, GRRs, and unknown service lines, and CWSs that are providing and maintaining POU devices would be required to provide educational materials to customers. The data collection required for these programs will be used to inform the public of possible health risks and assess compliance.
Under the revisions for a change in source or treatment, all CWSs and NTNCWSs, regardless of lead 90th percentile levels, are required to obtain primacy agency approval prior to making any long-term treatment changes or adding a new source as well as sampling source water in response to a significant change in source. The data collected under this revision will be used to:
Evaluate the quality of water delivered to customers;
Evaluate system-specific needs, including examining treatment effectiveness; and
Modify monitoring frequencies to address potential health risks.
Source water monitoring and treatment has one revision under the LCRR. The source water monitoring requirements would only apply to the first time in which a water system exceeds the lead or copper AL. The source water monitoring and treatment requirements are independent of lead 90[th] percentile levels. This is a reduction in burden.
The LCRR creates a new requirement for CWSs to conduct lead in drinking water testing and public education at schools and child care facilities. Systems would be required to provide PE to each sampled school or child care facility and provide testing results to the facility, primacy agency, and State and local health departments. The data collected as the result of this revision will primarily be used to evaluate the quality of water delivered to consumers at sampled school or child care facilities.
2(b)(ii) Users of the Data
Primary users of the data collected under this ICR are water systems and their customers, primacy agencies, and EPA. The information collected by EPA is available to the public, via EPA's website (https://www3.epa.gov/enviro/facts/sdwis/search.html) or by requesting the data under the Freedom of Information Act (FOIA; 40 CFR, Chapter 1, Part 2). Other organizations and individuals that may utilize the data include but are not limited to the following:
Individual consumers, realtors, potential homebuyers, homeowners, households, and other members of the public;
News organizations;
Staff from other EPA programs (such as Superfund, the Resource Conservation and Recovery Act, and the Office of Enforcement and Compliance Assurance);
The Federal Emergency Management Administration;
Centers for Disease Control and Prevention;
Military bases;
Farmers Home Administration;
Department of Interior;
Department of Housing and Urban Development;
U.S. Army Corps of Engineers;
White House Task Forces;
American Water Works Association;
Association of Metropolitan Water Agencies;
National Rural Water Association;
Rural Community Assistance Partnership;
National Association of Water Companies;
Association of State Drinking Water Administrators;
Natural Resources Defense Council; and
Consumers Federation of America.
3	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
3(a) 	Non-duplication
EPA has consulted with other federal agencies, state agencies, industry organizations, water systems, and tribal organizations to ensure non-duplication of this information collection. To the best of the Agency's knowledge, the data required by the LCRR and the data potentially collected based on the recommendations in the SL Inventory Guidance are not available from any other source.
3(b) 	Public Notice Required Prior to ICR Submission to OMB
To comply with the 1995 Amendments to the Paperwork Reduction Act, the Agency is soliciting public comment on this draft ICR during a 60-day public comment. In the Federal Register notice announcing the solicitation of public comment on this draft ICR, EPA is requesting comment on the estimated respondent burden and other aspects of this information collection associated with the LCRR regulatory requirements. The Agency is also requesting comment on the potential burden and cost associated with the non-binding voluntary recommendations in EPA's "Guidance for Developing and Maintaining a Service Line Inventory" and the inventory templates provided in Appendix A of the document. In addition, EPA is requesting comment on the LCRR requirement reiterated in the SL Inventory Guidance that public water systems internally track address locations of each service line. Comments received will be considered by the Agency and used to adjust the burden and costs estimates presented in the final ICR prior to submission to the OMB.
3(c) 	Consultations
EPA conducted three sets of consultations that inform the Agency's estimated burden and size of the potentially affected universe. The first set was conducted during the development of the LCRR regulatory requirements. EPA engaged with multiple stakeholders representing a wide range of expertise. The first sub-section below describes these rule development consultation activities that informed the initial characterization of the affected universe and the ICR burdens associated with the LCRR regulatory requirements. Summaries from this initial set of meetings and consultations are available in the docket for the rule under EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
Post promulgation of the LCRR, EPA as part of compliance with the requirements of Executive Order (EO) 13990 conducted an extensive engagement process with Lead and Copper Rule stakeholders. This virtual engagement process represents an extensive set of consultations which have been used to inform the burden estimates in this LCRR ICR renewal. This effort is summarized in the second sub-section below. Summaries from this initial set of meetings and consultations are available in the docket for the virtual engagements under EPA-HQ-OW-2021-0255 at https://www.regulations.gov.
The third set of consultations was conducted as part of the SL Inventory Guidance development process. These consultations inform the ICR burden costs associated with the SL Inventory Guidance. The draft guidance was provided to eighteen different external stakeholder groups including regulated systems, primacy agencies, and non-governmental organizations. As part of this process to obtain input, EPA received approximately 1,500 specific comments on the draft guidance document. Sub-section three below summarizes this consultation effort.
3(c)(i) Consultations Conducted During the Development of the LCRR
Consultations with State and Local Government and Stakeholder Organizations
      In October 2008, EPA held a two-day stakeholder meeting at the Carnegie Institution for Science. The purpose of this meeting was to gather stakeholder input on actions that could be taken in the revisions to the LCR. Discussion topics included changes to the tiering criteria for lead and copper, LSLR requirements, particulate lead in tap water samples, optimal water quality parameters, tap sampling issues, and CCT technologies. EPA presented summaries of the scientific data that the Agency had compiled on these issues. EPA also requested stakeholder input and feedback on other issues EPA could consider for potential future action on the LCR. EPA held a public meeting on November 4, 2010, to discuss potential Long-Term Revisions to the LCR. The meeting was held to obtain stakeholder feedback about key issues and options to address the issues.
	EPA held a Federalism consultation on November 15, 2011, with representatives from State and local government organizations to solicit feedback on potential regulatory revisions to the LCR. In its capacity as an advisory committee to EPA, the Local Government Advisory Committee (LGAC) periodically makes recommendations and comments to the Agency on issues impacting local governments. EPA received comments that addressed sample site collection criteria and lead sampling protocol at LSL sites.
      In May and June of 2016, the Administrator and other high-ranking EPA officials conducted meetings with state officials, water system officials, and non-government organizations (NGOs). Sixteen state officials and 16 PWS officials met with EPA on May 26 and June 1, 2016, respectively. EPA met with 15 NGOs on June 2, 2016. During each meeting, EPA and stakeholder officials discussed critical needs and key opportunities for addressing drinking water challenges and four priority issues including the LCR with the goal of strengthening implementation of the previous LCR and improving public health protection through updates to the rule.
      In 2017, EPA sent a questionnaire to nine states regarding the burden and cost associated with the National Drinking Water Advisory Council's (NDWAC) recommendation to require all systems to develop a comprehensive LSL inventory and to expand the definition of an LSL to include lead connectors even if the service line is not made of lead. The questionnaire asked states how they would manage the LSL inventory requirement and their estimates for costs associated with reviewing PWS inventory documentation. The nine states were selected based on geographic diversity, high incidence of LSLs, and knowledge of existing LSLR programs. Seven states (Illinois, Michigan, Washington, Wisconsin, New Jersey, Rhode Island, and Ohio) out of the nine states responded to the questionnaire.
      EPA held another Federalism meeting on January 8, 2018, in Washington DC, with 17 intergovernmental associations and several associations representing state and local governments. EPA also held five follow-up briefings between January 8 and March 8, 2018. A total of 82 state and local governments and related associations provided input during the meetings and within 60 days after the initial meeting. Common issues discussed included LSLR, CCT, transparency and PE, tap sampling, and copper. EPA considered Federalism comments received in 2011 and 2018 when developing the LCRR. The Association of State Drinking Water Administrators (ASDWA) provided Federalism input on March 8, 2018, that informed the framework of the LCRR. To address ASDWA's concerns, EPA proposed 1) a new TL of 0.010 mg/L in addition to retaining the current AL of 0.015 mg/L, 2) a new set of requirements for systems with a TLE, and 3) a revised set of requirements for systems with an ALE.
Summaries from meetings and consultations are available in the docket for the rule under EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
National Drinking Water Advisory Council (NDWAC) and the Lead and Copper Rule Working Group
EPA consulted with NDWAC on July 21-22, 2011, to provide updates on the proposed LCR revisions and solicit feedback on potential regulatory options under consideration. In November 2011, NDWAC held deliberations on LSLR requirements after they received the Science Advisory Board's (SAB) final report on the effectiveness of partial LSLR. In December 2011, a public meeting was held where NDWAC provided EPA with major recommendations on the potential LCR regulatory revisions, which are outlined in a letter dated December 23, 2011.
In 2014, the NDWAC formed the Lead and Copper Rule Working Group (LCRWG) to provide additional advice to EPA on potential options for long-term regulatory revisions. EPA held seven in-person meetings with the LCRWG from March 2014 through June 2015, participated in multiple conference calls, and spent time outside these meetings to provide input to the LCRWG on key issues. The LCRWG focused their time to provide advice to EPA in addressing the following issues: sample site collection criteria, lead sampling protocols, public education for copper, and measures to ensure optimal CCT and LSLR. The NDWAC provided the Agency with their final recommendations and findings in a report submitted to the EPA Administrator in December 2015. In the report, the NDWAC acknowledged that reducing lead exposure is a shared responsibility between consumers, the government, PWSs, building owners, and public health officials. In addition, they recognized that creative financing is necessary to reach the LSL removal goals, especially for disparate and vulnerable communities. The NDWAC advised EPA to maintain the LCR as a treatment technique rule but with enhanced improvements. The NDWAC qualitatively considered costs before finalizing its recommendations, emphasizing that PWSs and states should focus efforts where the greatest public health protection can be achieved, incorporating their anticipated costs in their capital improvement program or the requests for Drinking Water State Revolving Funds. The LCRWG outlined an extensive list of recommendations for the LCRR, including establishing a goal-based LSLR program, strengthening CCT requirements, and tailoring water quality parameters to the specific CCT plan for each water system. A detailed description of the provisions for NDWAC's recommendations for the long-term revisions to the LCR can be found in the "Report of the Lead and Copper Rule Working Group to the National Drinking Water Advisory Council".
On December 4 and 5, 2019, EPA held a NDWAC meeting in Washington, DC, where EPA presented the proposed LCRR. In the presentation, the major LCRR revisions were highlighted, such as the LSL inventory, the new TL of 0.010 mg/L, and new sampling protocols. The presentation focused on six key areas: identifying areas most impacted, strengthening treatment requirements, replacing LSLs, increasing sampling reliability, improving risk communication, and protecting children in schools. EPA reiterated that the LCRR was developed with extensive consultation from state, local, and tribal partners to identify avenues that would reduce elevated levels of lead in drinking water. EPA reaffirmed its commitment to transparency and improved communication to the public.
The NDWAC recommendations and meeting summaries are available in the docket for the rule under EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
Science Advisory Board (SAB)
Science Advisory Board Evaluation of the Effectiveness of Partial Lead Service Line Replacements
In 2011, EPA's Office of Water requested the Science Advisory Board (SAB) to evaluate the current scientific data to determine the effectiveness of partial LSLRs in reducing drinking water lead levels. The SAB convened the Drinking Water Committee Augmented for the Review of the Effectiveness of Partial Lead Service Line Replacements to study the issue. EPA asked the SAB to evaluate the current scientific data on the following five partial LSLR issues: 1) associations between partial LSLR and blood lead levels in children; 2) lead tap water sampling data before and after partial LSLR; 3) comparisons between partial and full LSLR; 4) partial LSLR techniques; and 5) the impact of galvanic corrosion. The SAB deliberated and sought input from public meetings held on March 30 and 31, 2011, and during a public conference call on May 16, 2011. The SAB's final report, titled "SAB Evaluation of the Effectiveness of Partial Lead Service Line Replacements" was approved by the SAB on July 19, 2011, and transmitted to the EPA Administrator on September 28, 2011.
The SAB's September 2011 report and recommendations are available in the docket for the rule under EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
Science Advisory Board Consideration of the Scientific and Technical Basis of EPA's Proposed Rule Titled NPDWR: Proposed LCRR

 On March 30, 2020, the SAB and SAB Drinking Water Committee met by teleconference and elected to review the scientific and technical basis of the proposed LCRR. The SAB drinking water committee deliberated on this topic at a public teleconference held on May 11, 2020. The SAB provided advice and comments in its June 12, 2020, report (USEPA, 2020). The SAB reviewed the following LCRR topic areas and provided comment: lead tap sampling, water treatment including CCT and POU treatment devices, the addition of a TL, and the effectiveness of PE requirements including PE and sampling in schools and child care facilities. They also reviewed EPA's benefit-cost analysis, including the quantitative analysis of children's blood lead levels and IQ. In addition, the SAB provided feedback to EPA's specific questions that focused on: the identification of LSL inventory methods that would provide accuracy, cost efficiency, and minimize exposure risk (including the use of statistical methods); the identification of galvanized pipes formerly downstream of a lead source; and how to improve the efficacy of a number of PE outreach activities. The SAB's June 2020 report and recommendations are available in the docket for the rule under EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
Input from Small Business Stakeholders
      On August 14, 2012, EPA convened a Small Business Advocacy Review (SBAR) Panel. The SBAR Panel submitted its report to EPA in October 2012, which provided recommendations regarding the sample site selection criteria, PE for copper, the process for re-evaluating and revising CCT, copper monitoring waivers for systems that can demonstrate their water is non-aggressive toward copper; POU treatment units in lieu of CCT for NTNCWSs serving 10,000 people or fewer; the sampling protocol at sites served by LSLs; and mandatory LSLR requirements. To minimize impacts from the rule, systems with LSLs that serve 10,000 people or fewer would not be required to have a LSLR plan unless LSLR was the selected compliance option. See Section 8 of the SBREFA Panel Report available in the docket for the rule under EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
Tribal Consultations
	EPA consulted with tribal officials in developing the LCRR through the EPA American Indian Environmental Office. EPA held consultations with federally recognized Indian tribes in 2011 and 2018. The 2018 consultations with federally recognized Indian tribes began on January 16, 2018 and ended March 16, 2018. The first national webinar was held January 31, 2018, while the second national webinar was held February 15, 2018. A total of 48 tribal representatives participated in the two webinars. Updates on the consultation process were provided to the National Tribal Water Council upon request at regularly scheduled monthly meetings during the consultation process. Also, upon request, informational webinars were provided to the National Tribal Toxics Council's Lead Subcommittee on January 30, 2018, and the EPA Region 9's Regional Tribal Operations Committee on February 8, 2018. Additionally, EPA received written comments from the following tribes and tribal organizations: Navajo Tribal Utility Authority, National Tribal Water Council, United South and Eastern Tribes Sovereignty Protection Fund, and Yukon River Inter-Tribal Watershed Council. A summary report of the views expressed during tribal consultations is available in the docket under EPA-HQ-OW-2017-0300 at https://www.regulations.gov.
Environmental Justice
Because the LCRR may have environmental justice impacts, in March 2011, EPA held a public meeting to discuss environmental justice considerations. EPA published a public notice of the meeting in the Federal Register on February 15, 2011 (76 FR 8674).
3(c)(ii) Lead and Copper Rule Revisions Virtual Engagements Consultations
Between April and August 2021, EPA conducted a series of virtual engagements to obtain public input on the EO 13990 review of the LCRR. The virtual engagements included two public listening sessions, ten community roundtables (Pittsburgh, PA; Newark, NJ; Malden, MA; Washington, DC; Newburgh, NY; Benton Harbor and Highland Park, MI; Flint and Detroit, MI; Memphis, TN; Chicago, IL; and Milwaukee, WI), a tribal roundtable, a national stakeholder association roundtable, a national co-regulator meeting, and a meeting with organizations representing elected officials. EPA specifically sought engagement with communities that have been disproportionately impacted by lead in drinking water, especially low-income people and communities of color that have been underrepresented in past rulemaking efforts. A diverse group of individuals and associations provided feedback through these meetings and the docket, including people from communities impacted by lead in drinking water, local governments, water utilities, tribal communities, public health organizations, environmental groups, environmental justice organizations, and co-regulators. Summaries from these virtual engagement consultations are available in the docket for the rule under EPA-HQ-OW-2021-0255 at https://www.regulations.gov.
3(c)(iii) Service Line Inventory Guidance Consultations
EPA distributed the draft inventory guidance in March 2022 to five external stakeholders who are active in the creation or development of service line inventories. These groups were ASDWA, the American Water Works Association, and three NGOs (the Natural Resources Defense Council, Environmental Defense Fund, and Clean Water Action). Some of the external groups shared the draft with eight additional state regulators, the Association of Metropolitan Water Agencies, Blue Conduit, the Campaign for Lead Free Water, and two ASDWA contractors to supplement their comments. EPA accepted comments from these organizations. EPA asked that commenters provide feedback on: the degree to which the guidance would support water system and state efforts to develop and update LSL inventories; additional topics related to inventories that the guidance should cover; the technical accuracy of provided information, particularly the data associated with the inventory technologies and best practices; and the clarity of the technical information. Regarding the inventory template spreadsheet, EPA also asked for feedback on whether the document is useful and intuitive to fill out as well as what changes or additions would improve the template. EPA considered the approximately 1,500 comments received from these external stakeholders to prepare the final August 2022 service line guidance.
3(d) 	Effects of Less Frequent Collection
EPA considered a wide range of alternatives for the frequency of data collection under the LCRR regulatory development process and in the original OMB-approved ICR. EPA chose to require the least frequent collection that remains consistent with the overall goal of protecting public health. If data are collected less frequently, primacy agencies may not identify significant contaminant concentrations in a timely fashion that might threaten the health and safety of drinking water consumers. Monitoring frequencies have been carefully devised based on the following factors:
data quality needed for a representative sample;
precision and accuracy needed from the representative sample;
number of people served by the system;
source of the supply (e.g., surface water or ground water);
likelihood of finding contaminants; and
temporal variability in occurrence.
The LCRR puts in place a framework with a new TL in addition to an AL. Systems are required to perform more frequent monitoring and reporting if they exceed the TL. Under the LCRR, a system may be on a different monitoring schedule for lead and copper. For lead, the frequency of tap sampling and number of required samples depend solely on a system's 90[th] percentile lead level as follows:
Systems with an ALE would monitor every six months at the standard number of sampling locations in the previous rule. These systems are not eligible for reduced monitoring.
Systems with a TLE would monitor annually at the standard number of sampling locations in the previous rule and would not be eligible to collect samples at the reduced number of sites or to qualify for triennial or nine-year monitoring.
Systems without a TLE or ALE would conduct monitoring annually, triennially, or every nine years at the reduced number of sites.
The LCRR copper monitoring requirements are similar to those under the LCR, which are based on the system's 90[th] percentile copper level and compliance with a system's optimal WQP specifications. One difference is that a system's 90[th] percentile lead level is not a factor in determining the system's copper monitoring requirements.
3(e) 	General Guidelines
Apart from the two instances noted below, this ICR will not violate the guidelines codified under 5 CFR 1320.5(d)(2).
Records are required to be retained for a period greater than three years. In particular, the 1991 LCR requires all PWSs to retain on their premise original records of all sampling data and analyses, reports, surveys, letters, evaluations, schedules and any other information required by the state for no fewer than 12 years. Primacy agencies are subject to the same record retention period, except that primacy agencies are required to retain information relating to the decisions in §142.14(d)(8) until a new decision, determination, or designation has been issued, if no change is made to the state decision during the 12-year retention period. The Agency justified these record retention periods and received approval for them under the original 1991 LCR ICR.
In addition, the LCRR codifies §2106 of the Water Infrastructure Improvements for the Nation Act (WIIN Act), which revised §1414 of SDWA to require PWSs to notify customers, the primacy agency, and EPA of a lead ALE within 24 hours of learning of the ALE.
3(f) 	Confidentiality
No confidential information will be collected as a result of this ICR.
3(g) 	Sensitive Questions
No questions of a sensitive nature are included in any of the information collection requirements outlined in this ICR.
4 	THE RESPONDENTS AND THE INFORMATION REQUESTED
The following sections contain information on the respondents and the information they are requested to provide.
4(a) 	Respondents/North American Industry Classification System Codes
Data associated with this ICR are collected and maintained at the PWS, state, tribal, and Federal levels. Respondents include:
Owners/operators of PWSs, who must report to their primacy agency.
Primacy agencies, and the EPA Regions that act as primacy agencies for states, territories, and tribal lands that do not have primacy.
The North American Industry Classification System (NAICS) code for privately owned PWSs is 22131. The NAICS codes for state agencies that include drinking water programs are 92411 (Administration of Air and Water Resources and Solid Waste Management Programs) or 92312 (Administration of Public Health Programs). Ancillary systems (systems where providing water is ancillary to a primary business, e.g., mobile home parks) cannot be categorized in a single NAICS code. For ancillary systems, the NAICS code is that of the primary establishment or industry.
4(b) 	Information Requested
4(b)(i) Data items
The data items requested under this ICR differ across the three years covered by this ICR renewal (January 1, 2024 through December 31, 2026). In 2024, the first year of the ICR renewal period, which includes the October 16, 2024 LCRR compliance date, public water systems and primacy agencies will still be engaged in the regulatory startup/implementation activities identified in the original "Information Collection Request for Lead and Copper Rule Revisions (LCRR)." For PWSs these startup activities include the following:
Reading and understanding the LCRR;
Assigning personnel and resources for rule implementation;
Attending training and receiving technical assistance from the state;
Developing LSL inventories;
Demonstrating that the system only has non-lead service lines and submitting materials for review to the primacy (if applicable);
Developing LSL general outreach material if LSLs are present; and
Conferring with states on initial planning for LSLR and preparing an LSLR plan when LSLs are present.
During the same period, primacy agencies will conduct startup activities that include the following:
Adopting the rule and developing a program for implementation;
Modifying their data system;
Providing internal staff with training for implementation;
Providing system staff with training and technical assistance;
Assisting with LSL inventories and reviewing inventories;
Reviewing general LSL outreach materials for LSL systems;
Reviewing demonstrations of no LSLs, GRRs, and unknown service lines from systems; and
Conferring with systems on initial planning for LSLR and reviewing plan.
      Following the LCRR compliance date in year 2024, both water systems and primacy agencies must work to implement a number of additional regulatory requirements. The resultant ICR related data items associated with these implementation activities are estimated in years 2025 and 2026 of this ICR renewal. Exhibit 1 lists the data items associated with PWS and primacy agency LCRR activities occuring in years 2025 and 2026.
      Note that this ICR includes SL Inventory Guidance recommended activities that, while not adding new categories of requested data items, could potentially alter the burden and cost associated with LCRR regulatory data items, such as the initial inventory and LSL public education requirements in year 2024 and the requirements to provide LSL inventory updates in years 2025 and 2026.

Exhibit 1. Years 2025 and 2026 PWS and Primacy Agency Reporting Data Items Required by LCRR Post Compliance Date
                                  Regulatory
                                    Change
                                   PWS Costs
                             Primacy Agency Costs

                               System Reporting
                           Lead in Water Monitoring
                      Water Quality Parameter Monitoring
                               Public Education
                             Primacy Agency Review
Ongoing Rule Implementation and Administration
                                       x

                                       x
Lead and Copper Tap Monitoring
                                       x
                                       x

                                       x
                                       x
Corrosion Control Treatment
                                       x
                                       x
                                       x

                                       x
Find-and-fix
                                       x
                                       x
                                       x

                                       x
Water Quality Parameter Monitoring
                                       x

                                       x
                                       x
                                       x
Source Water Monitoring
                                       x
                                       x

                                       x
Lead Service Line Inventory Updates
                                       x

                                       x
Lead Service Line Replacement
                                       x
                                       x

                                       x
                                       x
Small System POU Compliance Alternative
                                       x
                                       x

                                       x
                                       x
Lead Public Education and Outreach
                                       x

                                       x
                                       x
Lead in Drinking Water Testing Program at Schools and Child Care Facilities
                                       x
                                       x

                                       x
                                       x

4(b)(ii) Respondent Activities
Regulatory Startup, Implementation, and LSL Inventory and Replacement Plan Activities Conducted in Year 2024
      This sub-section discusses the startup activities associated with the promulgation of the LCRR. The burden and cost impacts of these activities are estimated for year 2024 of this ICR. The initial LSL inventory and LSLR plan are also required in year 2024.

Adopting and Startup Implementation of the LCRR
Activities for Systems
Systems must conduct planning and startup activities for the implementation of the LCRR, including 1) reading and understanding the rule, 2) assigning personnel and resources, and 3) dedicating staff to attend training and receive technical assistance from the primacy agency.
Activities for Primacy Agencies
Primacy agencies must 1) adopt the rule into state regulations and develop an implementation program, 2) train primacy agency staff and provide training and technical assistance to drinking water system staff, and 3) modify data management systems to collect and track the new data fields required by the LCRR.
Initial Lead Service Line Inventory
Activities for Systems
	All systems must prepare and submit to their primacy agency a comprehensive initial service line material inventory that identifies LSLs, GRRs, unknown service lines, and non-lead service lines by the compliance date of October 16, 2024. The inventory does not need to be re-developed if the system has an existing inventory that meets the requirements of the LCRR. The public-facing (publicly accessible) inventory may be replaced by a written statement if the system can demonstrate that they have no LSLs, GRRs, and unknown service lines. As an assumption, PWSs without LSLs, GRRs, and unknown lines will incur burden to develop and submit documentation to the primacy agency that all of their service lines are non-lead. Systems with LSLs, GRRs, and unknown lines that developed inventories will incur the additional burden of submitting the inventory for primacy agency review. Systems with LSLs, GRRs, or unknown lines are also required to develop general LSL outreach materials for customers with LSLs, GRRs, or unknown service lines with information on the health effects and sources of lead in drinking water, how to have water tested for lead, actions customers can take to reduce exposure to lead, and information about the opportunities for LSLR. These materials are submitted to the primacy agency for review. Following the review process, systems would then distribute the approved outreach materials to households served by an LSL, GRR, or unknown service line annually.
	The SL Inventory Guidance makes a number of non-binding recommendations designed to improve the LSL data generated during the information collection process and the effectiveness of the LCRR requirements to reduce lead exposure from LSLs. Some of these recommendations could potentially result in increased burden and cost if followed during system compliance with the regulatory requirement to develop the initial inventory. The guidance recommends the following:
 Records Review. The LCRR requires systems to review several categories of records and information. The guidance expands on how specific examples within these categories can be used to determine the service line material. PWSs should take a number of steps to improve their understanding and verify existing data available to conduct a review of system records when developing the initial inventory, such as investigating local building codes to determine lead ban dates, utilizing construction records to determine age of buildings relative to lead bans and diameter of service line pipe (most LSLs are less than 2 inches), incorporate information from previous distribution system and LSL material reviews, interviewing experienced staff and plumbers, interviewing neighboring water systems about regional construction practices, digitizing tap cards are all recommended activities. EPA also encourages systems to not submit initial inventories with all service lines classified as unknown. However, in cases of high uncertainty, where historical records are found to be unreliable, or where records conflict, it is recommended that a system categorize the service lines as unknown.
 Investigation Methods. When developing the initial inventory and subsequent inventory updates, PWSs should prioritize field investigations by employing one or more on-site service line material investigation techniques as soon as possible to improve their inventory, verify existing records, and reduce the number of unknowns. The service line investigation methods discussed in the SL Inventory Guidance include visual observation by customers, plumbers (or other third parties), and system staff or contractors; water quality sampling; excavation (mechanical and vacuum); predictive modeling; and emerging methods. To reduce costs, it is recommended that systems work inventory activities into day-to-day activities rather than treat them as an independent effort. Water systems should consider developing or modifying SOPs to document how they will collect service line information during normal operations and update their inventories. Additionally, the guidance recommends that systems consider including the sources of the materials classification in their inventory as well as document where there was an LSL.
 Additional Inventory Elements and Data Formats. The SL Inventory Guidance makes a number of additional recommendations that will improve LCRR compliance and the LSLR program's efficiency as well as provide greater public health protection through the collection and dissemination of additional inventory information. The SL Inventory Guidance encourages PWSs to expand their inventories to include service line subclassifications (e.g., assigning an LSL likelihood to unknown material categorizations), additional plumbing components such as lead connectors and solder, and other details, such as source of information, pipe diameter, and installation date. Systems are recommended to track and use the actual material when classifying non-lead service line materials, such as using "copper" or "plastic." Systems are encouraged consider the use of electronic formats for their internal and public-facing inventories. PWSs should also consider including street addresses, when available, as their location identifier for all service lines in the public-facing inventory.
 Templates. The SL Inventory Guidance also provides template for PWSs to use in the development of their inventories, which helps improve the consistency of the service line information collected and reduces the uncertainty and burden associated with the reporting the inventory data for the primacy agency to review.

Activities for Primacy Agencies
	Primacy agencies must provide assistance to systems with the creation of LSL inventories. Primacy agencies must also review the submissions from systems for completeness of an LSL inventory as well as whether the system made a publicly accessible inventory or provided a written statement that demonstrates the system only has non-lead service lines. EPA assumed that primacy agencies would incur burden and cost for providing LSL systems with templates for LSL outreach. They would also have burden associated with the review of general LSL outreach materials provided by the LSL systems.
	Note that the SL Inventory Guidance makes recommendations to improve the quality and format of LSL system data. The guidance also provides templates for primacy agencies to streamline their oversite reviews associated with the LCRR inventory requirements. Although these recommendations will likely result in burden savings to primacy agencies, EPA was conservative in this ICR analysis and did not estimate these savings.

Lead Service Line Replacement Plan
Activities for Systems
	Systems with LSLs must create a lead service line replacement plan. The plan would include: a strategy for determining the composition of lead status unknown service lines in its inventory, a strategy for informing customers before a full or partial LSLR, procedures for coordinating the full LSLR, a funding strategy for conducting LSLR that includes ways to accommodate customers that are unable to pay to replace the portion they own, and a procedure for customers to flush service lines and premise plumbing of particulate lead post-replacement. In addition, for CWSs serving more than 10,000 people, a proposed replacement goal must be included in the event that the system should experience a TLE and be required to implement the required goal-based replacement program. PWSs must submit these LSLR plans to the primacy agency for review.

Activities for Primacy Agencies
Primacy agencies will incur burden to review the lead service line replacement plans submitted by systems.
Regulatory Activities Required by LCRR in Years 2025 and 2026
A number of additional regulatory activities with associated ICR burden and costs occur in years 2025 and 2026. The activities can be grouped into the larger categories including: ongoing rule implementation and administration, lead and copper tap monitoring, corrosion control treatment, find-and-fix, water quality parameter monitoring, source water monitoring, lead service line inventory updates, lead service replacement, small system POU compliance alternative, lead public education and outreach, and lead in drinking water testing program at schools and child care facilities.
Ongoing Rule Implementation and Administration
Activities for Systems
	CWSs serving 10,000 or fewer people and NTNCWSs with a 90[th] percentile lead level above the TL must evaluate and recommend to their primacy agency which compliance alternative they would implement if they have a future lead ALE from among: 1) LSLR, 2) CCT installation/re-optimization, 3) POU device installation and maintenance, or 4) replacement of lead-bearing materials. -

Activities for Primacy Agencies
For primacy agencies, a number of implementation and rule administration task that were costed for year 2024 also continue in years 2025 and 2026 (based on input from ASDWA these startup administrative tasks would occur over the first five years after rule promulgation affecting all 3 years of this ICR). These follow-on tasks include 1) develop an implementation program, 2) train primacy agency staff, and provide training and technical assistance to drinking water system staff, and 3) modify data management systems to collect and track the new data fields required by the LCRR.
In addition to the tasks continuing from 2024, primacy agencies will have new burdens and costs associated with: ongoing coordination activities with EPA, training for both agency staff and systems, providing technical assistance to systems, and data reporting to SDWIS.
Primacy agencies will also incur burden to review and approve the small system compliance options recommended by CWSs serving 10,000 or fewer and all NTNCWSs that exceed the TL.

Lead and Copper Tap Water Monitoring
Activities for Systems
      All CWSs and NTNCWSs are subject to lead tap sampling requirements. The frequency and required number of samples depend on the system's 90[th] percentile lead level and system size, but all systems are assumed to conduct one year of semi-annual monitoring at the start of rule compliance (year 2025). In year 2026 and thereafter, only systems with a 90[th] percentile level at or below the TL of 0.010 mg/L can qualify to conduct lead tap sampling at the reduced number of sites annually, triennially, or every nine years. Those with a lead ALE must conduct lead tap sampling every six months at the standard number of sample sites; those with a TLE must sample annually at the standard number of sites. Systems without a lead ALE or TLE can qualify for reduced triennial or 9-year monitoring, at a reduced number of sites, based on past tap sampling results, water quality parameter monitoring results as applicable, system size, and the presence of lead or copper in the distribution system. In addition, systems must sample for a minimum of two, six-month tap sampling monitoring periods following a change in source water or significant long-term change in treatment. For additional information on the LCRR required lead and copper sampling schedule and required number of samples see the "National Primary Drinking Water Regulation: Lead and Copper Rule Revisions" (86 FR 4198) published in the Federal Register.
	The ICR burden and costs for system activities associated with lead tap sampling are as follows:
 All PWSs will incur a one-time burden to update their sampling instructions to be consistent with the revised LCRR tap sampling procedures related to aerators, pre-stagnation flushing, and use of wide-mouth bottles for sample collection.
 Under the LCRR, CWSs with LSLs are required to contact additional residents to increase the size of the system's tap sampling pool. This will insure CWSs will have enough volunteers to collect all lead samples from sites served by LSLs meeting their minimum required number of tap samples.
 Systems must report to the primacy agency any changes in their tap sampling locations from the prior monitoring period and the reason for the change.
 EPA assumed systems will incur a one-time burden in 2025 to discuss their LCRR sampling requirements moving forward with the primacy agency based on their sampling results from the most recent two six-month monitoring periods.
 For each monitoring period, CWSs will contact customers from the tap sampling pool to obtain volunteers to participate in the lead tap sampling program. Note that EPA has estimated costs of some CWSs offering monetary incentives to their customers to encourage their participation in their lead tap sampling program.
 The rule allows customers to collect tap samples after receiving proper instructions from the water system. EPA assumes that CWSs will ship test kits including instructions to the volunteers that are conducting the tap sampling.
 CWS volunteers will collect the tap samples, and EPA assumes that system staff will obtain the samples from the residence. NTNCWS staff collect their own samples.
 CWSs will determine if samples collected by volunteer customers meet the required sampling protocol and if any should be rejected prior to analysis. EPA assumes all NTNCWSs collect their own samples and should be familiar with the sampling protocol and thus would not incur burden to determine if a sample should be rejected.
 Systems will analyze the lead tap samples.
 Some CWSs and NTNCWSs will request that the primacy agency invalidate a lead tap sample based on rule provided criteria.
 CWSs must report individual lead sample results to customers who participated in the sampling pool. NTNCWSs are also required to provide sampling results to the people they serve. For NTNCWSs, EPA assumed the systems will deliver materials via email to all customers and post in a public location.
 Systems must certify to the primacy agency that the lead tap sample results were reported to the customers.
 CWSs and NTNCWSs on nine-year monitoring waivers must submit documentation to the primacy agency every nine years that demonstrates their system and their customers' residences continue to have no lead- or copper-containing plumbing materials.
 CWSs and NTNCWSs submit their tap sampling results and 90[th] percentile calculations, after the conclusion of each monitoring period, to the primacy agency for review.
Activities for Primacy Agencies
EPA has identified eight primacy agency implementation assistance, oversight and review activities associated with lead tap sampling conducted by water systems. These include:
 The primacy agency providing revised tap sampling instructions templates to PWS and reviewing those PWS draft materials that are developed with the help of the templates.
 Primacy agencies will incur a one-time burden to review the revised sampling plans submitted by CWSs with LSLs that demonstrates they will meet their minimum sampling requirements using 100 percent LSLs sites for the collection of tap samples, if available.
 Primacy agencies incur a one-time upfront burden per system to review each system's latest two rounds of LCRR compliance monitoring data to determine their status under the rule and prepare them for any new requirements.
 For CWSs primacy agencies will review reported changes in tap sample locations between each monitoring period. EPA assumes this burden is negligible for NTNCWSs because they collect their own samples from sampling locations under their control and thus, are unlikely to change sampling sites and submit documentation to the primacy agency for review.
 Primacy agencies will incur burden associated with the review of system sample invalidation requests.
 The primacy agencies will review each system's certification that monitoring results were reported to the customers at the end of each monitoring period.
 Primacy agencies will also review the tap monitoring results and lead 90[th] percentile calculations at the completion of each monitoring period.
 Primacy agencies will review waiver requests from the subset of systems that submit nine-year monitoring waiver renewal documentation.
Corrosion Control Treatment
Activities for Systems
      PWSs may be required to install CCT, re-optimize their existing CCT, or perform a "find-and-fix" adjustment to their CCT under the LCRR. CCT installation and re-optimization are triggered based on the system's lead 90[th] percentile range. The CCT activities associated with ICR burden and cost are discussed below. Note CCT activities that result from find-and-fix requirements are discussed in a separate section below.
 For systems required to install CCT, EPA assumes that primacy agencies will require these systems to conduct a CCT study prior to installation. EPA also assumed primacy agencies will require all systems to update their previous CCT study prior to CCT re-optimization.
 Systems with CCT will incur burden to gather and submit non-compliance data (e.g., process control data, other WQP data) and meet with their primacy agency during the sanitary survey to determine if CCT is still optimized. In addition, EPA assumes that systems with CCT serving more than 50,000 people will review each update to EPA's CCT guidance themselves to determine if CCT adjustment may be needed prior to consultations with the primacy agency during the sanitary survey.
 Systems are required to seek prior approval before making any source water changes or long-term treatment changes and to consult with the primacy agency on needed responses including the possibility of CCT installation or re-optimization.
Activities for Primacy Agencies
      The primacy agency oversite of CCT activities associated with ICR burden and cost are listed below. Note that a number of oversite activities like reviewing system's CCT studies and setting OWQPs occur outside the ICR analysis window ending in December of 2026.
 Primacy agencies will incur burden to review updated EPA CCT guidance, identify changes that could affect their systems, prepare a memo to communicate changes to state surveyors, and be available to answer PWS questions.
 Primacy agencies will also incur burden to review water quality data with water systems that have CCT during sanitary surveys.
 Primacy agencies must consult with systems seeking prior approval before making any source water changes.
 Primacy agencies must consult with systems seeking prior approval before making any long-term treatment changes.

Find-and-Fix
Activities for Systems
The LCRR requires all CWSs and NTNCWSs to conduct a site investigation where a lead tap sample exceeds the AL of 0.015 mg/L. Based on the results of the site evaluation and other site evaluations occuring within a system, corrective actions may be taken in consultation with the primacy agency. Actions taken can range from site specific suggestions to residents to reduce lead exposure to changes in system wide CCT. For additional information on find-and fix LCRR requirements see the "National Primary Drinking Water Regulation: Lead and Copper Rule Revisions" (86 FR 4198) published in the Federal Register. Below is a list of the ICR relevant activities associated with the LCRR find-and-fix requirements:
 CWSs will incur burden and costs to contact customers and collect a follow-up tap sample at each compliance tap sampling location that had a result above 0.015 mg/L. As part of the sample collection, water system staff will look for lead sources in premise plumbing and service lines. NTNCWSs must also collect follow-up samples, but their burden and costs are lower given previous knowledge of and access to the sampling locations.
 Systems must analyze the follow-up tap samples.
 Systems must collect one distribution system sample at or near the site where the high lead sample was collected within five days of learning of the lead results. This sample will be used to assess WQPs.
 Systems will analyze the distribution system WQP sample. Note the number of parameters analyzed is dependent on the presence and type of CCT in the individual system.
 The system must inform the customer of the follow-up sampling results.
 Systems must determine if a CCT "fix" is needed following lead tap sample result(s) above 0.015 mg/L. EPA assumes that systems will use the collected follow-up tap samples and WQP samples from all find-and-fix locations, and information on system-wide conditions to assess distribution system operations and determine if there could have been factors that contributed to deteriorating water quality and elevated lead levels.
 Systems with CCT that have at least one sample above 0.015 mg/L must consult with their primacy agency prior to making any CCT changes.
 Systems will incur burden to provide a copy of the notice delivered to customers when an initial sample exceeds 0.015 mg/L, the results of follow-up tap sample, the WQP monitoring results, and any distribution system management actions or CCT adjustments made to fix the cause of sample results above 0.015 mg/L to their primacy agency.
Activities for Primacy Agencies
Primacy agency burden and costs related to find-and-fix activities include:
 Consulting with CCT systems that have at least one sample above 0.015 mg/L prior to the system making any CCT changes.
 Primacy agencies will incur burden to review each system's find-and-fix report that provides the results of tap and WQP monitoring, a distribution system assessment, and recommended corrective actions if a system has one or more samples above 0.015 mg/L in a given year.
Water Quality Parameter Monitoring
Activities for Systems
Lead WQP monitoring is required for all systems serving more than 50,000 people with CCT (except at "b3" systems which do not have CCT) and those serving 50,000 or fewer people that exceed the lead AL of 0.015 mg/L. Systems serving 50,000 or fewer people must continue WQP monitoring until they no longer exceed the lead and/or copper AL for two consecutive 6-month monitoring periods. WQP samples are collected at representative sites throughout the distribution system and at each entry point to the distribution system. Systems must conduct WQP monitoring prior to the installation of CCT and after CCT installation. The primacy agency may designate optimal water quality parameters (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 number of and specific parameters which are sampled vary for systems with and without CCT and by the type of CCT. The sample schedule and number of samples also vary based on system size, the number of entry points, tap sampling 90[th] percentile levels, and past WQP sampling results relative to the primacy agency set OWQPs. To qualify for reduced WQP distribution system monitoring, a system's 90[th] percentile lead tap sample must be equal to, or less than, 0.010 mg/L and the system must meet its OWQPs. There are no reduced monitoring provisions for WQPs collected at entry points. For additional information on the exact number of WPQ samples required under the LCRR see the "National Primary Drinking Water Regulation: Lead and Copper Rule Revisions" (86 FR 4198) published in the Federal Register.
The follow list of lead WQP system activities are associated with ICR burden and costs:
 Systems subject to lead WQP monitoring requirements must collect and analyze WQP samples in the distribution system.
 Systems will also collect and analyze lead WQP samples at each entry point to the distribution system.
 Systems are required to report their lead WQP sampling results and for those systems where OWQPs have been set by the primacy agency to demonstrate compliance with those OWQPs every six months.
   Copper WQP Monitoring is required when a system exceeds the copper AL. The number of required samples and sample schedule is the same a lead WQP monitoring except that to qualify for reduced monitoring a system must return copper tap sample results below the copper AL of 1.3 mg/L. Also, the lead find-and-fix requirements do not apply to copper WQP sampling sites. The activity categories associated with copper WQP monitoring are identical to lead WQP monitoring:
 Systems will collect and analyze copper WQP samples in the distribution system.
 Systems collect and analyze copper WQP samples from entry points.
 Systems are required to report their copper WQP sampling results and for those systems where OWQPs have been set by the primacy agency to demonstrate compliance with those OWQPs.
Activities for Primacy Agencies
Primacy agencies must review a system's lead and/or copper WQP monitoring data collected from entry points and within the distribution system as well as assess the systems compliance with OWQPs (if those values have been determined for the system) at the end of each WQP monitoring period.
Source Water Monitoring
Activities for Systems
Under the LCRR, CWSs and NTNCWSs must sample at each entry point if the system experiences a significant source water change and/or has not already conducted source water monitoring for a previous lead or copper ALE. Burden and costs to systems to comply with this requirement can be divided into three categories:
 CWSs and NTNCWSs with a significant source change and/or in response to their first lead or copper ALE must collect and analyze a source water sample at each entry point.
 Water systems are required to report their source water monitoring results to the primacy agency.
Activities for Primacy Agencies
Primacy agencies will incur burden to review source water monitoring results submitted by water systems after a significant source change and/or in response to the systems first lead or copper ALE.
Lead Service Line Inventory Updates
Activities for Systems
The LCRR requires systems with lead, GRR, and unknown service lines to report updated inventory information within 30 days of the end of each tap sampling monitoring period, but no more frequent than annually for those on semi-annual monitoring. This means that system reporting will be driven by lead tap sampling results and a system's 90[th] percentile tap level. The inventory update should reflect any replaced or newly discovered lead and GRR service lines or service line material classification changes. For this ICR, EPA assumes that LSL system inventories are updated and submitted to the primacy agency for review annually. EPA also includes the potential burden and costs associated with following SL Inventory Guidance recommendations. The guidance recommendations to note for inventory updates include those on-site service line material investigation techniques which include visual observation by customers, plumbers (or other third parties), and/or system staff or contractors, water quality sampling, predictive modeling, and excavation (mechanical and vacuum). To reduce cost the guidance also recommends that inventory activities be worked into the day-to-day activities of the system rather than treated as an independent effort. EPA also provides inventory update templates that should allow better consistence of record keeping improving the efficiency of conducting future inventory updates and reporting to primacy agencies.
Activities for Primacy Agencies
Primacy agencies will incur burden to review updates to systems LSL inventory. Although recommendations from the SL Inventory Guidance will likely result in burden savings to primacy agencies, EPA was conservative in this ICR analysis and did not estimate these savings.
Lead Service Line Replacement
Activities for Systems
Physical replacement of LSLs is required by the LCRR for systems with lead 90[th] percentile tap samples that fall within two ranges. CWSs serving more than 10,000 people that have a TLE (a 90[th] percentile lead tap sample greater than 0.010 mg/L but not greater than 0.015 mg/L) must implement a goal-based LSLR program in which they replace LSLs at a rate approved by the primacy agency. Systems must continue replacing LSLs until they no longer exceed the TL for two consecutive annual periods of tap sampling. CWSs serving more than 10,000 that have a lead ALE (a 90[th] percentile lead tap sample greater than 0.015 mg/L) must fully replace LSLs on a rolling 2-year average of 3 percent per year using a baseline number of LSLs equal to the number of LSLs and GRR service lines at the time the system first exceeds the lead trigger or action level plus the number of unknowns at the beginning of each year of the system's LSLR program. The mandatory program also requires that a cumulative number of replacements be reached equal to 3 percent 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 two years (four consecutive 6-month monitoring periods). CWSs serving 10,000 or fewer people and NTNCWSs with 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. For more information on small system compliance options see the "Small System POU Compliance Alternative" section. All PWSs are required to replace the system-owned portion of an LSL if they become aware that a customer has replace their portion of the line. Also, under all LSLR programs, an LSL is only counted toward a system's replacement rate if the entire LSL is replaced. Listed below there are a number of LSLR activities that incur ICR burden and cost.

 Systems with LSLs are required to distribute the general LSL outreach materials annually to customers served by an LSL, GRR, or service line of unknown material.
 CWSs subject to the goal-based or mandatory LSLR program will incur one-time burden to conduct a study including developing an LSLR financing plan.
 CWSs serving more than 10,000 people with a TLE will incur burden to consult with their primacy agencies and develop outreach materials on their LSLR program that invite customers to participate in their goal-based LSLR program.
 CWSs with LSLs that serve more than 10,000 people and have a TLE will incur burden to distribute targeted LSLR program outreach materials to households with lead, GRR, and unknown service lines.
 EPA assumes that systems will inspect and test lines to confirm they are not lead prior to conducting an LSLR.
 Systems participating in the goal-based or mandatory LSLR program must collect one lead tap sample following replacement of each LSL.
 Systems will incur the burden and cost to analyze the post-LSLR lead tap samples.
 Systems must notify their customers of their lead analytical results from the post-LSLR lead tap sample.
 Systems that are subject to the goal-based or mandatory LSLR program must submit an annual report to their primacy agency which covers topic areas like their replacement schedule, location of LSLs replaced, customer outreach, and post-LSLR pitcher filter delivery and sampling.
Activities for Primacy Agencies
Primacy agencies will conduct the following ICR related LSLR tasks:
 CWSs serving more than 10,000 people with LSLs and a TLE must provide additional outreach to customers with LSLs regarding the system's LSLR program. EPA assumed that the primacy agency will incur a one-time burden to provide a template for these outreach materials and consult with the system.
 Primacy agencies will incur a one-time burden to review the draft LSL program outreach materials.
 Primacy agencies will also incur burden to consult with systems and determine needed activities for CWSs serving more than 10,000 people with a TLE that fail to meet their goal-based replacement requirements.
 Primacy agencies will incur annual burden to review systems' reports on their LSL mandatory and goal-based program, their replacement schedule, location of LSLs replaced, customer outreach, and post-LSLR pitcher filter delivery and sampling.
Small System POU Compliance Alternative
Activities for Systems
CWSs serving 10,000 or fewer people and NTNCWSs with a lead 90[th] percentile above the TL must evaluate and recommend to their primacy agency which compliance alternative they would implement if they have a future lead ALE from among: 1) LSLR, 2) CCT installation/re-optimization, 3) POU device installation and maintenance, or 4) replacement of lead-bearing materials. Those small systems approved, by the primacy agency, for the POU provision must develop a plan and implement the program if they have a future lead ALE. The POU program burden and costs relevant to the ICR are as follows:
 EPA assumed that small systems would 1) develop a POU plan that describes how the system will provide and maintain POU devices and 2) submit the plan to primacy agency for review.
 Systems taking part in a POU program will be required to develop public education materials that inform users on how to properly use POU devices to maximize the units' effectiveness in reducing lead levels in drinking water. These materials will be submitted to the primacy agency for review.
 Systems will deliver the public education materials along with the POU devices through an LCRR-approved method or another method approved by the primacy agency.
 Under the POU program, systems must sample one-third of locations with POU devices annually. For CWSs, customers can collect these samples, therefore, systems will experience burden to obtain the annual household POU sampling pool.
 CWSs are assumed to deliver POU sampling materials and instructions to participating POU households from the sampling pool.
 CWS volunteers will collect the POU monitoring samples and EPA assumes that system staff will collect the samples from the residence. NTNCWS staff collect their own samples.
 CWS staff will determine if POU customer samples were collected properly or should be rejected and not analyzed.
 Systems will analyze POU monitoring samples.
 Systems will prepare and submit a sample invalidation request to their primacy agency.
 CWSs must report individual POU lead sample results to customers who participated in the POU sampling pool. NTNCWSs are assumed to report the sampling results through an email to all customers and post of results in a public location.
 Systems must prepare and submit an annual certification to their primacy agencies that they informed customers of their POU monitoring results.
 Systems must prepare and submit a report of their POU program that includes monitoring results, any corrective actions if the TL was exceeded, and if requested by the primacy agency, any maintenance activities.
Activities for Primacy Agencies
Primacy agencies will conduct the follow POU implementation and oversight activities that produce ICR burden and costs:
 Primacy agencies would incur a one-time burden to review water systems' POU plans.
 EPA assumed that primacy agencies will provide templates to CWSs serving 10,000 or fewer people and NTNCWSs to develop POU outreach materials that describe the POU program and proper use of the POU devices.
 Primacy agencies will incur a one-time burden to review the POU outreach materials developed by the systems.
 Primacy agencies must review sample invalidation request for POU monitoring.
 Primacy agencies must review each system's annual certification that POU monitoring results were reported to customers.
 Primacy agencies will incur burden to review a system's annual report on its POU program that includes monitoring results and may include corrective actions and routine maintenance activities.
Lead Public Education and Outreach
Activities for Systems
      Systems will incur burden and non-labor costs to provide a consumer notice in response to a single lead tap sample above 0.015 mg/L, to conduct additional education and outreach regardless of a system's lead 90[th] percentile level, and to conduct PE requirements in response to a lead 90[th] percentile ALE. Note that public education requirements for systems with LSLs that pertain to general LSL outreach that is provided to customers with LSLs, GRRs, or that are served by lines of unknown material and targeted outreach that is required when the system exceeds the TL were previously discussed in the "Lead Service Line Replacement" section. The PE requirements for systems implementing a POU program were previously discussed in the "Small System POU Compliance Alternative" section.
      Under the LCRR, systems must notify any customer with a tap sample result above 0.015 mg/L as soon as practicable but no later than 3 days after learning of the results. CWSs can notify customers by telephone within the three days but must follow-up with results by mail. Systems that choose only to mail the notification must have the letters postmarked within three days. NTNCWSs would use the same mechanism they currently use under the LCR to inform their customers of sample results via posting and electronic notification but would provide this information no later than three days after learning of the results. All systems must submit a copy of the three-calendar-day notification to their primacy agencies.
      There are new PE requirements under the LCRR that are independent of a system's lead 90[th] percentile range. These requirements are as follows:
 CWSs must update information about lead in the annual consumer confidence report (CCR).
 CWSs with LSLs will develop a new customer outreach plan.
 CWSs will incur a one-time burden to develop improved public access to lead data that includes lead health-related data and tap monitoring results.
 Systems with LSLs must also establish a way for customers and the public to access information on LSLs. Note that the SL Inventory Guidance makes a number of recommendations associated with the dissemination of LSL data. PWSs that do not have an online system for dissemination of inventory data should consider developing such a system. The guidance also recommends that online systems could share data in the form of interactive maps or downloadable spreadsheets on the system website or through other cloud-based sharing apps or FTP/SFTP servers. In the non-online space, the Agency indicates that information can be shared in a tabular data format in preexisting utility mailings or newsletters. Burden and cost impacts for the initial development of public access to the inventory are captured in the costs reported under the initial inventory development. Addition impacts are captured in the estimated impacts of the LCRR requirements for this section.
 CWSs would also incur an annual burden to maintain a way for the public to access the lead health and LSL information.
 CWSs will incur a burden to respond to LSL information requests from homeowners and residents, and other parties (e.g., realtors, home inspectors, and potential homebuyers).
 CWSs will also incur a burden to respond to LSL information requests from home other parties (e.g., realtors, home inspectors, and potential homebuyers).
 Systems will incur a one-time upfront burden to develop an initial list of State and local health departments serving their service area.
 CWSs are required to develop lead outreach materials that will be distributed to State and local health agencies.
 CWSs would incur an annual burden to produce and distribute the annual outreach to State and local health agencies, which includes the results of any school testing and find-and-fix activities in response to a tap sample above 0.015 mg/L. Systems will also incur an annual burden to make any necessary updates to the list of State and local health agencies.
 CWSs must conduct annual outreach to State and local health agencies to discuss the sources of lead in drinking water, health effects of lead, steps to reduce exposure to lead in drinking water, and information on find-and-fix activities. EPA expects CWSs will work with their primacy agencies to conduct increased lead outreach to health care agencies.
 CWSs with LSLs must send PE to customers when there is scheduled water-related work that could result in disturbances of service lines. The PE materials discuss the potential for elevated lead levels in drinking water as a result of the disturbance to LSLs. These systems will incur a one-time burden to develop materials, and an annual burden to deliver the PE to impacted households.
 CWSs must annually certify, to the primacy agency, PE activities were completed.

For systems with a lead ALE, a number of actions must be taken:
 PWSs must update their mandatory health effects language, and those that also have LSLs must include information about their LSLR program and opportunities to replace LSLs.
 CWSs are required to distribute PE materials to all households they serve and NTNCWSs are required to deliver material to customers via email and public posting.
 CWSs must contact local health care agencies to obtain a list of additional organizations that serve at-risk populations. Organizations would include schools, child cares, and medical providers that offer services to pregnant women, children, and infants.
 CWSs must provide public education materials to facilities that include local health departments and additional organizations that serve at-risk populations.
 Each CWSs serving more than 100,000 people with a lead ALE must post PE materials on their website.
 CWSs will consult with their primacy agency on other required PE activities to be conducted in response to a lead ALE. These activities potentially include public service announcements, paid ads, public displays, email notifications, public meetings, and materials sent to multifamily homes and other institutions.
 CWSs will also incur burden to implement the primacy agency selected other required PE activities.
 CWSs with an ALE must certify, to the primacy agency, PE activities completed on a quarterly basis.
Activities for Primacy Agencies
Primacy agencies will incur burden to conduct oversight and review activities related to the PE requirements of the LCRR. These activities are broadly grouped into the following: activities related to a consumer notice in response to a single lead sample above 0.015 mg/L, activities that are independent of a system's lead 90[th] percentile level, and activities conducted in response to a lead ALE.
Primacy agencies will review a copy of the 3-calendar-day notice that systems must provide to consumers if their lead tap sample exceeds 0.015 mg/L.
Primacy agencies will also have burden and costs associated with the new PE requirements under the LCRR that are independent of a system's lead 90[th] percentile status. EPA assumed that primacy agencies will provide templates to CWSs to update their CCR language with the revised LCRR mandatory health effects language and for those systems with LSLs to further update their materials to include information about the system's LSLR program and opportunities to replace LSLs. Primacy agencies will also incur a one-time burden to provide templates to CWSs for the development of outreach materials that will be sent to State and local health departments. Primacy agencies will incur burden associated with the review of the CCR, LSL, and health department outreach PE material developed by the CWSs. Primacy agencies will incur annual burden to participate in joint communication efforts with CWSs to provide lead PE to health departments annually. The primacy agencies will also incur a burden to review PE material developed by CWSs, with LSLs, for delivery during scheduled water-related work that may result in the disturbance of LSLs, GRRs, or unknown service lines.
	The LCRR requires systems with a lead ALE to update the mandatory health effects language and those with LSLs to further update their materials to include information about their LSLR program and opportunities for customers to replace LSLs. EPA assumes primacy agencies will incur a one-time burden to provide templates and review each system's revised PE mandatory language in materials that are delivered when a system has a lead ALE. In addition, primacy agencies will consult with CWSs on other ALE required PE activities to be conducted. These can include public service announcements, paid ads, public displays, email notifications, public meetings, and materials sent to multifamily homes and other institutions.
	Primacy agencies will review each system's certification that they have met their PE and outreach requirements including any done in response to a lead ALE. For the majority of systems this certification occurs annually. Note, CWSs have quarterly, semi-annual, and annual PE requirements in response to a lead ALE. Thus, CWSs with an ALE must report the certification on a quarterly basis.
Lead in Drinking Water Testing Program at Schools and Child Care Facilities
Activities for Systems
The LCRR requires CWSs to implement a lead in drinking water testing program at K-12 schools and licensed child care facilities. CWSs must collect five samples per tested school and two samples at each tested child care. The final rule splits this testing program into two phases. The "mandatory testing" phase occurs at elementary schools and child care facilities during the first five years of rule implementation. Under the mandatory testing program, systems must annually conduct testing at 20 percent of eligible schools and child care facilities such that each would be tested once in the 5-year period. During this mandatory program testing will be upon request at secondary schools. Starting in year six of the school testing program, CWSs are only required to test elementary schools, secondary schools, and child care facilities that request testing. For the ICR, this means that the burden estimates for years 2025 and 2026 will be based on the requirements for implementing the mandatory testing program only with an estimated 20 percent of eligible elementary schools and child care facilities being tested in each year as well as a smaller percent of secondary schools (5 percent) requesting sampling in each of the years.
The LCRR activities associated with ICR burden in the first two years of the mandatory program include:
 CWSs at the start of the program are required to create a contact list of schools and child cares facilities.
 CWSs will prepare outreach materials that describe the importance of lead testing and the systems lead in drinking water testing program at schools and child care facilities.
 CWSs would incur a one-time burden at the start of the program to prepare and distribute an initial letter explaining the sampling program.
 EPA assumed systems would coordinate with each school or child care facility at the start of the program to plan and finalize when each facility would be sampled.
 EPA assumes that systems would contact each school or child care facility to coordinate sample collection logistics.
 EPA assumes that CWSs will conduct a walkthrough to become familiar with the facility and to identify sampling sites prior to the sampling event.
 CWSs will incur burden to travel to and from sample sight.
 CWSs will collect lead samples.
 CWSs will analyze lead samples.
 CWSs must provide sampling results to each tested facility. As part of this requirement EPA assumed systems will incur additional burden, which increases when results show high lead levels, to discuss the sampling results with each school and child care facility.
 CWSs are required to prepare and provide an annual report to their primacy agency regarding their testing program at schools and child care facilities, and provide the sampling results to State and local health offices if different from the primacy agency.
Activities for Primacy Agencies
	Primacy agency activities for implementation assistance and oversight of CWSs' lead in drinking water testing programs at schools and child care facilities include:
 Primacy agencies reviewing the initial list of schools and licensed child care facilities served by each CWS.
 EPA assumed primacy agencies would provide a template to assist CWSs in developing outreach materials that describe the importance of lead testing and the lead in drinking water testing program at schools and child care facilities.
 EPA estimated that primacy agencies will incur a one-time burden to review the school and child care facility testing program materials developed by the CWSs.
 The primacy agency will also review the annual reports generated by CWSs on school and child care facility lead in drinking water testing program implementation and results.
Exhibit 2 lists the PWS data collection and reporting activities. These include new activities required by the LCRR as well as activities already required by the LCR that experience incremental burden increases as a result of other LCRR changes. For example, lead tap sampling occurs under the LCR, but the TL requirements under the LCRR increase the number of tap samples required for some systems. Exhibit 3 provides the primacy agency data collection and reporting activities.

Exhibit 2. PWSs Data Collection and Reporting Activities
                                   Activity
   Burden Frequency 2024-2026 (Annual Activities Start Year in Parentheses)
                    Rule Startup Implementation Activities
Systems read and understand the LCRR rule
                                  Once (2024)
Systems assign personnel and resources for rule implementation
                                  Once (2024)
Systems attend training and technical assistance from the primacy agencies during rule implementation
                                  Once (2024)
Systems submit small system flexibility compliance option
                                  Once (2025)
         Lead Service Line Inventory Activities (Initial and Updates)
Systems create initial inventory of lead service lines - records review plus field investigations per SL Inventory Guidance
                                  Once (2024)
Systems submit initial demonstration documentation of only non-lead service lines
                                  Once (2024)
Systems submit initial inventory
                                  Once (2024)
Systems develop public education material for LSLs
                                  Once (2024)
Systems distribute public education material for LSLs
                                 Annual (2024)
Systems update inventory including field investigations per SL Inventory Guidance
                                 Annual (2025)
Systems submit updated inventory report
                                 Annual (2025)
                 Lead Service Line Replacement Plan Activities
Systems create a lead service line replacement plan and submit for primacy agency review
                                  Once (2024)
                Lead and Copper Tap Water Monitoring Activities
Systems update sampling instructions for tap sampling
                                  Once (2025)
Systems contact homes to establish new 100 percent LSL tap sampling pool
                                  Once (2025)
Systems report changes in tap locations
                                 Annual (2025)
Systems confer with primacy agencies on tap sampling program
                                  Once (2025)
Systems obtain volunteer customers to participate from sampling pool
                                 Annual (2025)
Systems offer customer incentives for lead and copper tap samples
                                 Annual (2025)
Systems deliver sample equipment/instructions for the 5[th]-liter option
                                 Annual (2025)
Systems obtain lead and copper tap samples from households
                                 Annual (2025)
Systems determine that a sample should be rejected and not analyzed
                                 Annual (2025)
Systems analyze lead and copper tap samples
                                 Annual (2025)
Systems submit lead and copper tap sample invalidation requests to primacy agency
                                 Annual (2025)
Systems inform customers of results of lead and copper tap monitoring
                                 Annual (2025)
Systems certify to primacy agencies that sampling results were reported to customer
                                 Annual (2025)
Systems submit nine-year waiver request
                                 Annual (2025)
Systems draft and submit report on lead and copper tap sampling
                                 Annual (2025)
                    Corrosion Control Treatment Activities
Systems conduct or revise CCT study
                                  Once (2025)
Systems with LSLs gather non-water quality compliance data and review EPA CCT guidance prior to consultation with primacy agencies during the sanitary survey
                                  Once (2025)
Systems notify and consult with primacy agencies on modification of CCT
                                  Once (2025)
                            Find-and-Fix Activities
Systems collect the follow-up tap sample and assess lead sources at location when a tap sample is > 0.015 mg/L
                                 Annual (2025)
Systems analyze the follow up tap sample when a tap sample is > 0.015 mg/L
                                 Annual (2025)
Systems collect WQP in distribution system near location of tap sample > 0.015 mg/L
                                 Annual (2025)
Systems analyze WQP from distribution system when a tap sample is > 0.015 mg/L
                                 Annual (2025)
Systems review incidents of system-wide events and other system conditions
                                 Annual (2025)
Systems consult with primacy agencies prior to making find-and fix CCT changes
                                 Annual (2025)
Systems provide a copy of the 3-day notice delivered to customers to primacy agencies when a sample exceeds 0.015 mg/L
                                 Annual (2025)
Systems report all find and fix activities
                                 Annual (2025)
                 Water Quality Parameter Monitoring Activities
                              Lead WQP Activities
Systems collect and analyze lead WQP at distribution system
                                 Annual (2025)
Systems collect and analyze lead WQP at entry points
                                 Annual (2025)
Systems report on lead WQP monitoring
                                 Annual (2025)
                             Copper WQP Activities
Systems collect and analyze copper WQP in distribution system
                                 Annual (2025)
Systems collect and analyze copper WQP at entry points
                                 Annual (2025)
Systems report on copper WQP monitoring
                                 Annual (2025)
                      Source Water Monitoring Activities
Systems collect and analyze source water samples
                                 Annual (2025)
Systems report results of source water monitoring to primacy agencies
                                 Annual (2025)
Systems report and consult on source water changes
                                 Annual (2025)
                   Lead Service Line Replacement Activities
Systems conduct planning and identify financial options for LSLR Program and submit to primacy agency
                                  Once (2025)
Systems consult with primacy agency on targeted LSLR outreach materials
                                  Once (2025)
Systems distribute targeted outreach material on LSLR Program
                                 Annual (2025)
Systems contact customers to coordinate replacement
                                 Annual (2025)
Systems collect and analyze a tap sample 3 months after LSLR
                                 Annual (2025)
Systems inform customers of lead results after LSLR tap sample
                                 Annual (2025)
Systems submit annual report on LSLR program
                                 Annual (2025)
              Small System POU Compliance Alternative Activities
Systems conduct initial planning of POU Program
                                  Once (2025)
Systems develop public education for POUs and submits to primacy agencies for review
                                  Once (2025)
Systems provide POU educational materials to customers
                                 Annual (2025)
Systems obtain volunteer customers to participate in annual sampling program
                                 Annual (2025)
Systems deliver sampling equipment/instructions
                                 Annual (2025)
Systems collect lead tap samples
                                 Annual (2025)
Systems determines that a sample should be rejected and not analyzed
                                 Annual (2025)
Systems analyze lead tap samples
                                 Annual (2025)
Systems submit lead tap sample invalidation requests to primacy agency
                                 Annual (2025)
Systems inform customers of results of lead tap monitoring
                                 Annual (2025)
Systems certify to primacy agencies that sampling results were reported to customers
                                 Annual (2025)
Systems prepare and submit annual report on POU
                                 Annual (2025)
                   Public Education and Outreach Activities
            PE Activities Independent of Lead 90th Percentile Range
Systems update CCR
                                  Once (2025)
Systems with LSLs develop a new customer outreach plan
                                  Once (2025)
Systems develop approach for improved public access to lead information
                                  Once (2025)
Systems with LSLs establish a way for customers to access information on LSL locations
                                  Once (2025)
Systems maintain a way for customers to access information on LSL locations
                                 Annual (2025)
Systems with LSLs provide information about LSLs in response to request from homeowners and residents
                                 Annual (2025)
Systems with LSLs provide information about LSLs in response request from realtors, home inspectors, and potential home buyers
                                 Annual (2025)
Systems develop a list of health care providers
                                  Once (2025)
Systems develop material for State and local health agencies
                                  Once (2025)
System deliver PE to State and local health agencies, and participate in joint communication with the primacy agencies to provide increased information to health care providers on lead education
                                 Annual (2025)
Systems develop PE material for delivery during water-related work and submit it to the state for review
                                  Once (2025)
Systems deliver public education material during water-related work
                                 Annual (2025)
Systems certify to primacy agencies that PE outreach occurred including ALE outreach if applicable
                                 Annual (2025)
                   PE Activities for Action Level Exceedance
Systems must update their mandatory health effects language, and LSLs systems must also include information about their LSLR program
                                  Once (2025)
CWSs deliver materials to all households and NTNCWSs email and post lead information
                                 Annual (2025)
Systems contact public health agencies to obtain additional organizations
                                 Annual (2025)
Systems notify public health agencies and other organizations in response to lead ALE
                                 Annual (2025)
Systems post lead notice on website
                                 Annual (2025)
Systems consult with primacy agencies on additional PE activities for a lead ALE
                                 Annual (2025)
Systems implement primacy agency directed additional PE in response to lead ALE
                                 Annual (2025)
    PE Activities for Customers when Individual Tap Samples > 0.015 mg/L
Systems provide public education material for customer affected by tap sample > 0.015 mg/L
                                 Annual (2025)
Lead in Drinking Water Testing Program at Schools and Child Care Facilities Activities
Systems identify childcare facilities and schools served
                                  Once (2025)
Systems develop outreach materials explaining the school sampling program
                                  Once (2025)
Systems prepare and distribute outreach materials explaining the school sampling program
                                  Once (2025)
Systems call school/facility to determine sampling schedule when mandatory
                                  Once (2025)
Systems contact school/facility to offer sampling to secondary schools under opt-in
                                 Annual (2025)
Systems contact school/facility before sampling and coordinate
                                 Annual (2025)
Systems conduct walkthrough at school
                                 Annual (2025)
Systems travel to and from sampling site
                                 Annual (2025)
Systems collect lead samples
                                 Annual (2025)
Systems analyze lead samples
                                 Annual (2025)
Systems provide sampling results to school/facility and health agencies
                                 Annual (2025)
Systems discuss sampling results with school/facility
                                 Annual (2025)
Systems conduct additional detailed follow-up with school/facility when a lead sample is above 0.015 mg/L
                                 Annual (2025)
Systems prepare and submit annual schools sampling report
                                 Annual (2025)

Exhibit 3. Primacy Agency Data Collection and Reporting Activities
                                   Activity
   Burden Frequency 2024-2026 (Annual Activities Start Year in Parentheses)
              Rule Startup and Ongoing Implementation Activities
Primacy agencies adopt rule and develop program
                                 Annual (2024)
Primacy agencies provide primacy agencies staff with training for rule implementation
                                 Annual (2024)
Primacy agencies provide system staff with training and technical assistance during rule implementation
                                 Annual (2024)
Primacy agencies modify data system while implementing rule
                                 Annual (2024)
Primacy agencies coordinate with the EPA during annual administration of the rule
                                 Annual (2025)
Primacy agencies train staff for annual administration
                                 Annual (2025)
Primacy agencies provide on-going technical assistance
                                 Annual (2025)
Primacy agencies report to SDWIS
                                 Annual (2025)
Primacy agencies review and approve small system compliance option
                                  Once (2025)
         Lead Service Line Inventory Activities (Initial and Updates)
Primacy agencies assist with inventory development and review initial LSL inventory
                                  Once (2024)
Primacy agencies review information from PWSs that only have non-lead service lines
                                  Once (2024)
Primacy agencies provide template for public education material to LSLs
                                  Once (2024)
Primacy agencies review public education material for LSLs
                                  Once (2024)
Primacy agencies review updated LSL inventory
                                 Annual (2025)
                 Lead Service Line Replacement Plan Activities
Primacy agencies review lead service line replacement plan
                                  Once (2024)
                Lead and Copper Tap Water Monitoring Activities
Primacy agencies provide templates for and review sampling instructions for tap sampling
                                  Once (2025)
Primacy agencies review revised sampling plan from systems
                                 Annual (2026)
Primacy agencies review latest two rounds of sampling to determine system sampling requirements under LCRR
                                  Once (2025)
Primacy agencies review changes in tap locations
                                 Annual (2025)
Primacy agencies review sample invalidations requests for lead and copper tap sampling
                                 Annual (2025)
Primacy agencies review certification that sampling results were reported to customer
                                 Annual (2025)
Primacy agencies review report of lead and copper tap sampling
                                 Annual (2025)
Primacy agencies review nine-year waiver request
                                 Annual (2025)
                   Corrosion Control Treatment Requirements
Primacy agencies review CCT guidance and to which systems it applies
                                  Once (2025)
Primacy agencies review water quality data with systems that have CCT during sanitary survey
                                  Once (2025)
Primacy agencies consult with PWS on response to source change
                                 Annual (2025)
Primacy agencies consult with PWS on response to treatment change
                                 Annual (2025)
                           Find-and-Fix Requirements
Primacy agencies consults with the system prior to making find and fix CCT changes
                                 Annual (2025)
Primacy agencies reviews report regarding all find and fix activities
                                 Annual (2025)
                 Water Quality Parameter Monitoring Activities
                              Lead WQP Activities
Primacy agencies review lead water quality parameter data
                                 Annual (2025)
                             Copper WQP Activities
Primacy agencies review copper water quality parameter data
                                 Annual (2025)
                      Source Water Monitoring Activities
Primacy agencies review source water quality data
                                 Annual (2025)
                   Lead Service Line Replacement Activities
Primacy agencies provide outreach templates and consult with systems for LSLR Program outreach
                                  Once (2025)
Primacy agencies review targeted public education language for LSLR
                                  Once (2025)
Primacy agencies review annual report on LSLR activities, which includes LSLs replaced under goal based, mandatory, or customer-initiated programs, and required outreach and other additional PE required by the primacy agency
                                 Annual (2025)
              Small System POU Compliance Alternative Activities
Primacy agencies review POU plan
                                  Once (2025)
Primacy agencies provide templates for POU outreach materials
                                  Once (2025)
Primacy agencies review public education material for POUs
                                  Once (2025)
Primacy agencies review certification that sampling results were reported to customer
                                 Annual (2025)
Primacy agencies review annual report on POU
                                 Annual (2025)
Primacy agencies review sample invalidations requests for lead tap sampling
                                 Annual (2025)
                   Public Education and Outreach Activities
           PE Activities Independent of Lead 90[th] Percentile Range
Primacy agencies provide templates to update CCR
                                  Once (2025)
Primacy agencies provide lead outreach templates for State and local health providers