Contact school or child care to coordinate sample collection logistics (hrs_school_coor_sample_op). EPA assumed systems would incur the same average burden as under the mandatory program to call each facility to coordinate sample collection logistics including scheduling a walkthrough. The average time spent per call to coordinate sample collection logistics is 15 minutes (0.25 hours). See Section <IP_ADDRESS>.1, activity gg) for additional detail.
 Conduct walkthrough at school or child care before the start of sampling (hrs_walkthrough_school_op, cost_walkthrough_school). EPA assumed systems will incur the same burden and costs as under the mandatory program to conduct a walkthrough with each school or child care to become familiar with the facility and to identify sampling sites. The burden and cost for the water system to complete this task is 1.39 hours and $5.29 for CWSs serving 100,000 or fewer people, 1.5 hours and $6.80 for those serving 100,001 to 1 million people, and 1.67 hours and $9.07 for those serving more than 1 million people. See Section <IP_ADDRESS>.1, activity hh) for additional detail.
 Travel to collect samples (hrs_travel_samp_school_op, cost_travel_samp_school). EPA assumed systems will incur the same burden and costs as under the mandatory program to travel to a school or child care to collect samples of 0.39 hours and $5.29 for CWSs serving 100,000 or fewer people, 0.5 hours and $6.80 for those serving 100,001 to 1 million people, and 0.67 hours and $9.07 for those serving more than 1 million people. See Section <IP_ADDRESS>.1, activity ii) for additional detail.
 Collect samples (hrs_collect_samp_school_op, cost_collect_samp_school). EPA assumed CWSs will require the same per sample burden and cost to collect samples of 10 minutes (0.17 hours) for all system sizes and bottle cost of $1.83 that applies only to CWSs serving more than 100,000 people. See activity jj) for additional detail.
 Analyze samples (hrs_analyze_samp_op, cost_lab_lt_samp, cost_commercial_lab). Under the on request program phase, CWSs will incur the same burden and cost to analyze lead samples in-house or to use a commercial laboratory as lead tap sampling and the mandatory school and child care sampling program phase. Specifically, CWSs serving more than 100,000 people will incur a burden of 0.44 hrs per sample (hrs_analyze_samp_op) and cost of $2.38 per sample (cost_lab_lt_samp) to analyze lead samples in-house. CWSs serving 100,000 or fewer people will use a commercial lab at a cost of $21.58 per sample (cost_commercial_lab). See Section <IP_ADDRESS>.1, activity kk) for additional detail.
 Provide sampling results to tested facilities (hrs_inform_samp_pe_school_op, cost_inform_samp_pe_school). CWSs will incur the same burden and costs as under mandatory program phase to provide sampling results to tested facilities, Primacy Agencies, and state and local health departments. The CWS burden is 0.05 hrs and $0.58 per tested facility. See Section <IP_ADDRESS>.1, activity ll) for additional detail.
 Discuss sampling results with school and child cares (hrs_result_discuss_op). CWSs will continue to incur burden to discuss the sampling results with each school and child care under the on request program phase. EPA assumed the same average burden of 1 hour per tested facility as under the mandatory program.
    Conduct detailed discussion of high sampling results with school and child cares (hrs_school_help_op). EPA assumed systems would incur the same burden to work with each school or child care. EPA assumed systems will spend an additional 5 hours with each school or child care in which one or more samples are found to be high. Systems may need to explain the relevant portions of the 3Ts Toolkit and to address any follow-up questions that school or child care might have after the initial discussion. See Section <IP_ADDRESS>.1, activity nn) for additional detail).
 Prepare and provide an annual report on testing program to Primacy Agencies (hrs_annual_report_school_prepare_op, cost_annual_report_school_dist). Systems must continue to prepare and distribute an annual report regarding their testing program at schools and child cares at an estimated burden of 1 hour for CWSs serving 100,000 or fewer people, 2 hours for those serving 100,001 to 1 million people, and 8 hours for CWSs serving more than 1 million people, and a cost of $0.58 for all system sizes. See Section <IP_ADDRESS>.1, activity oo) for additional detail.
Exhibit 5-51 shows the SafeWater LCR model cost estimation approach for activities under the on request program phase including additional cost inputs required to calculate these costs.
Exhibit 5-51: PWS On Request School and Child Care Sampling Phase Cost Estimation in SafeWater LCR by Activity[1][,2]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th] - Range
Other Conditions

    Contact schools and child cares to offer sampling
The number of public elementary schools per system population times the system population multiplied by the hours per school times the system labor rate, plus the cost of materials.

numb_elem_schools_pub*pws_pop* ((hrs_school_annual_contact_op *rate_op)+ cost_school_annual_contact)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
Once a year

The number of public secondary schools per system population times system population multiplied by the hours per school times the system labor rate, plus the cost of materials.

numb_second_schools_pub*pws_pop*
((hrs_school_annual_contact_op *rate_op)+ cost_school_annual_contact)

Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

The number of child cares per system population times the system population multiplied by the hours per facility times the system labor rate, plus the cost of materials.

numb_daycares*pws_pop*
((hrs_school_annual_contact_op *rate_op)+ cost_school_annual_contact)

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

1 - p_grandfather_opt_child

The number of private elementary schools per system population times the system population multiplied by the hours per school times the system labor rate, plus the cost of materials.

numb_elem_schools_priv*pws_pop* ((hrs_school_annual_contact_op *rate_op)+ cost_school_annual_contact)

Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

The number of private secondary schools per system population times the system population multiplied by the hours per school times the system labor rate, plus the cost of materials.

numb_second_schools_priv*pws_pop*
((hrs_school_annual_contact_op *rate_op)+ cost_school_annual_contact)

Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

    Contact schools or child care to coordinate sample collection logistics
5% of public elementary schools multiplied by the hours per school and the system labor rate.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)*(hrs_school_coor_sample_op*rate_op)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
Once a year

5% of public secondary schools multiplied by the hours per school and the system labor rate.

(numb_second_schools_pub*pws_pop*pp_voluntary_partic)*(hrs_school_coor_sample_op*rate_op)

Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the hours per facility and the system labor rate.

(numb_daycares*pws_pop*pp_voluntary_partic)*(hrs_school_coor_sample_op*rate_op)

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the hours per school and the system labor rate.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)*(hrs_school_coor_sample_op*rate_op)

Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the hours per school and the system labor rate.

(numb_second_schools_priv*pws_pop*pp_voluntary_partic)*(hrs_school_coor_sample_op*rate_op)

Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

    Conduct walkthrough at school or facility before start of sampling
5% of public elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)*((hrs_walkthrough_school_op*rate_op)+cost_walkthrough_school)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
Once a year

5% of public secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_second_schools_pub*pws_pop*pp_voluntary_partic)*((hrs_walkthrough_school_op*rate_op)+cost_walkthrough_school)

Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the hours per facility times the system labor rate, plus the cost of materials.

(numb_daycares*pws_pop*pp_voluntary_partic)*((hrs_walkthrough_school_op*rate_op)+cost_walkthrough_school)

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)*((hrs_walkthrough_school_op*rate_op)+cost_walkthrough_school)

Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_second_schools_priv*pws_pop*pp_voluntary_partic)*((hrs_walkthrough_school_op*rate_op)+cost_walkthrough_school)

Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

    Travel to collect samples
5% of public elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)*((hrs_travel_samp_school_op*rate_op)+cost_travel_samp_school)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
Once a year

5% of public secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_second_schools_pub*pws_pop *pp_voluntary_partic)*((hrs_travel_samp_school_op*rate_op)+cost_travel_samp_school)

Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the hours per facility times the system labor rate, plus the cost of materials.

(numb_daycares*pp_voluntary_partic)*((hrs_travel_samp_school_op*rate_op)+cost_travel_samp_school)

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)*((hrs_travel_samp_school_op*rate_op)+cost_travel_samp_school)

Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_second_schools_priv*pws_pop *pp_voluntary_partic)*((hrs_travel_samp_school_op*rate_op)+cost_travel_samp_school)

Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

    Collect samples[3]
5% of public elementary schools multiplied by the number of samples per school, is multiplied by the number of hours per school times the system labor rate, plus the material cost.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)*numb_samp_five)*((hrs_collect_samp_school_op*rate_op)+cost_collect_samp_school)

All
Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
Once a year

5% of public secondary schools multiplied by the number of samples per school, is multiplied by the number of hours per school times the system labor rate, plus the material cost.

(numb_second_schools_pub*pws_popl*pp_voluntary_partic)*numb_samp_five)*((hrs_collect_samp_school_op*rate_op)+cost_collect_samp_school)
Cost does not apply to NTNCWSs.

Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the number of samples per facility, is multiplied by the number of hours per facility times the system labor rate, plus the material cost.

(numb_daycares*pp_voluntary_partic)*numb_samp_two)*((hrs_collect_samp_school_op*rate_op)+cost_collect_samp_school)

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the number of samples per school, is multiplied by the number of hours per school times the system labor rate, plus the material cost.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)*numb_samp_five)*((hrs_collect_samp_school_op*rate_op)+cost_collect_samp_school)

Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the number of samples per school, is multiplied by the number of hours per school times the system labor rate, plus the material cost.

(numb_second_schools_priv*pws_popl*pp_voluntary_partic)*numb_samp_five)*((hrs_collect_samp_school_op*rate_op)+cost_collect_samp_school)

Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

    Analyze samples[3]
The number of required samples per public elementary school multiplied by 5 percent of elementary schools per year times the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_elem_schools_pub*pws_pop*pp_voluntary_partic)*numb_samp_five)*pp_lab_samp_school)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+((((numb_elem_schools_pub*pws_pop*pp_voluntary_partic)*numb_samp_five)*pp_commercial_samp_school)*cost_commercial_lab)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
Once a year

The number of required samples per public secondary school multiplied by 5 percent of elementary schools per year times the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_second_schools_pub*pws_pop*pp_voluntary_partic)*numb_samp_five)*pp_lab_samp_school)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+((((numb_second_schools_pub*pws_pop*pp_voluntary_partic)*numb_samp_five)*pp_commercial_samp_school)*cost_commercial_lab)

Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

The number of required samples per day care multiplied by 5 percent of elementary schools per year times the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_daycares*pws_pop*pp_voluntary_partic)*numb_samp_five)*pp_lab_samp_school)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+((((numb_daycares*pws_pop*pp_voluntary_partic)*numb_samp_five)*pp_commercial_samp_school)*cost_commercial_lab)

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

1 - p_grandfather_opt_child

The number of required samples per private elementary school multiplied by 5 percent of elementary schools per year times the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_elem_schools_priv*pws_pop*pp_voluntary_partic)*numb_samp_five)*pp_lab_samp_school)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+((((numb_elem_schools_priv*pws_pop *pp_voluntary_partic)*numb_samp_five)*pp_commercial_samp_school)*cost_commercial_lab)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

The number of required samples per private secondary school multiplied by 5 percent of elementary schools per year times the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_second_schools_priv*pws_pop *pp_voluntary_partic)*numb_samp_five)*pp_lab_samp_school)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+((((numb_second_schools_priv*pws_pop *pp_voluntary_partic)*numb_samp_five)*pp_commercial_samp_school)*cost_commercial_lab)

Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

 Provide sampling results to tested facilities
5% of public elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)*((hrs_inform_samp_pe_school_op*rate_op)+cost_inform_samp_pe_school)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
Once a year

5% of public secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_second_schools_pub*pws_pop*pp_voluntary_partic)*((hrs_inform_samp_pe_school_op*rate_op)+cost_inform_samp_pe_school)

Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the hours per facility times the system labor rate, plus the cost of materials.

(numb_daycares*pws_pop*pp_voluntary_partic)*((hrs_inform_samp_pe_school_op*rate_op)+cost_inform_samp_pe_school)

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)*((hrs_inform_samp_pe_school_op*rate_op)+cost_inform_samp_pe_school)

Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

(numb_second_schools_priv*pws_pop*pp_voluntary_partic)*((hrs_inform_samp_pe_school_op*rate_op)+cost_inform_samp_pe_school)

Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

    Discuss sampling results with school and child cares
5% of public elementary schools multiplied by the hours per school times the system labor rate.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)*(hrs_result_discuss_op*rate_op)
Cost does not apply to NTNCWSs.
All
 Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
Once a year

5% of public secondary schools multiplied by the hours per school times the system labor rate.

(numb_second_schools_pub*pws_pop*pp_voluntary_partic)*(hrs_result_discuss_op*rate_op)

 Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the hours per facility times the system labor rate.

(numb_daycares*pws_pop*pp_voluntary_partic)*(hrs_result_discuss_op*rate_op)

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

 1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the hours per school times the system labor rate.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)*(hrs_result_discuss_op*rate_op)

Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the hours per school times the system labor rate.

(numb_second_schools_priv*pws_pop*pp_voluntary_partic)*(hrs_result_discuss_op*rate_op)

Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

    Conduct detailed discussion of high sampling results with school and child cares
5% of public elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_three*numb_samp_five)*(hrs_school_help_op*rate_op))
 Cost does not apply to NTNCWSs.

 At or below the TL
 Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
 Once a year

5% of public secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_second_schools_pub*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_three*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_daycares*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_three*numb_samp_five)*(hrs_school_help_op*rate_op))

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

 1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_three*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_second_schools_priv*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_three*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

5% of public elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_two*numb_samp_five)*(hrs_school_help_op*rate_op))
 Cost does not apply to NTNCWS.
 At or below AL and above TL
 Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub
 Once a year
5% of public secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_second_schools_pub*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_two*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_daycares*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_two*numb_samp_five)*(hrs_school_help_op*rate_op))

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

 1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_two*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_second_schools_priv*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_two*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

5% of public elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_elem_schools_pub*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_one*numb_samp_five)*(hrs_school_help_op*rate_op))
 Cost does not apply to NTNCWS.
 Above the AL
 Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_opt_pub

 Once a year

5% of public secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_second_schools_pub*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_one*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for public secondary school sampling

1 - p_grandfather_opt_pub

5% of child cares multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_daycares*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_one*numb_samp_five)*(hrs_school_help_op*rate_op))

Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

 1 - p_grandfather_opt_child

5% of private elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_elem_schools_priv*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_one*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for private elementary school sampling

1 - p_grandfather_opt_priv

5% of private secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_second_schools_priv*pws_pop*pp_voluntary_partic)* ((pp_above_al_bin_one*numb_samp_five)*(hrs_school_help_op*rate_op))

 Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_opt_priv

    Prepare and provide annual report on school and child care sampling to Primacy Agencies
The total hours per system multiplied by the system labor rate, plus the materials cost.

(hrs_annual_report_school_prepare_op*rate_op)+cost_annual_report_school_dist
Cost does not apply to NTNCWSs.
All
All model PWSs
Once a year
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
 numb_daycares, numb_elem_schools_priv, numb_elem_school_pub, numb_second_schools_priv, numb_second_school_pub: Number of child cares, number of private elementary schools, number of public elementary schools, number of public secondary schools, and number of private secondary schools, respectively that are served by CWSs (Section <IP_ADDRESS>).
 p_grandfather_opt_child p_grandfather_opt_priv, p_grandfather_opt_pub: States that qualify to waiver child cares, private K-12 schools, and public K-12 schools for the on request program (Section <IP_ADDRESS>).
 pp_above_al_bin_one: Likelihood a sample will be > 15 ug/L when the system's lead 90[th] percentile level is > 15 ug/L (Section <IP_ADDRESS>).
 pp_above_al_bin_two: Likelihood a sample will be > 15 ug/L when the system's lead 90[th] percentile level is above 10 ug/L but at or below 15 ug/L (Section <IP_ADDRESS>).
 pp_above_al_bin_three: Likelihood a sample will be > 15 ug/L when the system's lead 90[th] percentile level is <= 10 ug/L. (Section <IP_ADDRESS>).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
[2] The on request testing requirements are assumed to start for secondary schools in year 4 and for elementary schools and child cares after the Mandatory testing phase has been completed and will begin in year 9.
[3] The burden and costs to provide sample bottles (cost_collect_samp_school) under activity uu) and conduct analyses under activity vv) are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.
Estimate of PWS National Sampling Costs
Exhibit 5-52 and Exhibit 5-53 show the total estimated national sampling costs, under the low and high cost scenarios, discounted at 3 and 7 percent respectively, for the previous LCR, the LCRR, and the incremental cost. Note that previous LCR costs are projected over the 35-year period of analysis, like the estimated impact of the LCRR, and are affected by EPA's assumptions on five uncertainty variables which vary between the low and high cost scenarios. The low/high variable assignments for number of LSLs, CCT cost and effectiveness, LSLR costs, and the 90[th] percentile tap sample assignments for non-LSL systems are consistent across the previous rule and final LCRR projections. The 90[th] percentile tap sample assignments for LSL systems varies between the previous rule and LCRR. See Section <IP_ADDRESS>.2 for detail. In the case of sampling costs, the 90[th] percentile values have the largest impact on estimated costs under the low and high scenarios for the previous rule.
Exhibit 5-52: National Annualized Sampling Costs  -  All PWSs at 3 Percent Discount Rate (2016$)

                               Low Cost Estimate
                               High Cost Estimate

                                  Previous LCR
                                   Final LCRR
                                  Incremental
                                  Previous LCR
                                   Final LCRR
                                  Incremental
 Lead Tap Sampling
                                                                    $34,536,000
                                                                    $46,775,000
                                                                    $12,239,000
                                                                    $36,604,000
                                                                    $55,386,000
                                                                    $18,782,000
 Lead Water Quality Parameters Monitoring
                                                                     $7,265,000
                                                                     $8,225,000
                                                                       $959,000
                                                                     $8,311,000
                                                                    $10,211,000
                                                                     $1,900,000
 Copper Water Quality Parameters Monitoring
                                                                       $140,000
                                                                       $152,000
                                                                        $13,000
                                                                       $134,000
                                                                       $150,000
                                                                        $16,000
 Source Water Monitoring
                                                                        $20,000
                                                                         $9,419
                                                                       $-11,000
                                                                        $50,000
                                                                        $31,000
                                                                       $-18,000
 School Sampling
                                                                             $0
                                                                    $12,582,000
                                                                    $12,582,000
                                                                             $0
                                                                    $12,960,000
                                                                    $12,960,000
 Total Annual Sampling Costs
                                                                    $41,962,000
                                                                    $67,744,000
                                                                    $25,782,000
                                                                    $45,099,000
                                                                    $78,739,000
                                                                    $33,641,000
 Note: Detail may not add exactly to total due to independent rounding.

Exhibit 5-53: National Annualized Sampling Costs  -  All PWSs at 7 Percent Discount Rate (2016$)

                               Low Cost Estimate
                               High Cost Estimate

                                  Previous LCR
                                   Final LCRR
                                  Incremental
                                  Previous LCR
                                   Final LCRR
                                  Incremental
 Lead Tap Sampling Monitoring
                                                                    $33,746,000
                                                                    $47,597,000
                                                                    $13,851,000
                                                                    $36,573,000
                                                                    $58,566,000
                                                                    $21,993,000
 Lead Water Quality Parameters Monitoring
                                                                     $6,986,000
                                                                     $7,980,000
                                                                       $995,000
                                                                     $8,397,000
                                                                    $10,683,000
                                                                     $2,286,000
 Copper Water Quality Parameters Monitoring
                                                                       $133,000
                                                                       $145,000
                                                                        $12,000
                                                                       $128,000
                                                                       $143,000
                                                                        $15,000
 Source Water Monitoring
                                                                        $25,000
                                                                        $13,000
                                                                       $-12,000
                                                                        $66,000
                                                                        $45,000
                                                                       $-20,000
 School Sampling
                                                                             $0
                                                                    $14,461,000
                                                                    $14,461,000
                                                                             $0
                                                                    $14,969,000
                                                                    $14,969,000
 Total Annual Sampling Costs
                                                                    $40,890,000
                                                                    $70,197,000
                                                                    $29,307,000
                                                                    $45,164,000
                                                                    $84,407,000
                                                                    $39,243,000
 Note: Detail may not add exactly to total due to independent rounding.

PWS Corrosion Control Costs
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. EPA recognizes uncertainty in the effectiveness of CCT installation and re-optimization, especially for LSL systems, as explained in Section <IP_ADDRESS>.3. The likelihood of a model-PWS exceeding the TL or AL following CCT installation or re-optimization for the low and high cost scenarios are in Exhibit 5-7 and Exhibit 5-8, respectively. The "find-and-fix" adjustment to CCT is triggered by a new requirement under the LCRR where systems are required to take certain actions when individual lead tap samples are greater than 15 ug/L.
Any changes to the status of a system's CCT may result in technology related costs (capital and/or O&M), as well as ancillary costs for data submission, consultation, and CCT studies. This section presents the following CCT-related costs:
 <IP_ADDRESS>: CCT Installation
 <IP_ADDRESS>: Re-optimization
 <IP_ADDRESS>: Find-and-Fix Costs
 <IP_ADDRESS>: System Lead CCT Routine Costs
Each subsection presents capital and O&M costs followed by ancillary costs. Note that PWS costs for monitoring of CCT effectiveness (i.e., lead tap and WQP monitoring) has already been presented in Sections <IP_ADDRESS> and <IP_ADDRESS>, respectively. Also note that WWTP costs to address increased phosphorus loading are presented in Section 5.5.
All CCT-related capital and O&M costs are calculated using EPA's WBS cost models, which are described in Section 5.2.4 and detailed in Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2020). WBS capital cost equations are a function of DF, and WBS O&M cost equations are a function of average daily flow (ADF). These flows are estimated based on the system's population served. As explained in Section 4.3.6, DF and ADF for the system are divided by the average number of entry points per system to calculate flow per entry point. These entry point flow values are used in the WBS cost equations. CCT-related capital and O&M costs per entry point are summed for all entry points to produce the CCT-related capital and O&M costs for the system. As noted in Section <IP_ADDRESS>.5, EPA recognizes uncertainty in CCT capital and O&M cost equations by varying the WBS model inputs (e.g., fiberglass storage tank vs. more expensive stainless steel construction) to create "low" and "high" cost equations. Low CCT cost equations Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2020) are used for the low cost scenario, and high CCT cost equations are used for the high cost scenario.
In order to estimate CCT installation, re-optimization, or find-and-fix costs, the SafeWater LCR model  requires an estimate of the pH of the model-PWS's pre-regulatory compliance (or baseline) finished water. Using data from the Six-Year 3 Review Information Collection Request (ICR) Dataset, EPA developed triangular distributions based on the minimum, mode, and maximum of baseline pH levels (converted to log10 values) for model-PWSs with and without existing pH adjustment. For each distribution, EPA estimated distribution quartile threshold pH values and quartile midpoint values. Then EPA estimated system-weighted averages of the midpoint values to derive the final set of distributions for ground water and surface water systems with and without baseline pH adjustment shown in Exhibit 5-54.
Exhibit 5-54: Distribution of Baseline Finished Water pH by Source Water Type and pH Adjustment Status
                                  Likelihood
                               Finished Water pH

                      PWSs without pH Adjustment in Place
PWSs with pH Adjustment in Place

Groundwater
Surface Water
Groundwater
Surface Water
                                      10%
                                                                            5.1
                                                                            5.6
                                                                            6.3
                                                                            6.3
                                      15%
                                                                            5.9
                                                                            6.3
                                                                            6.8
                                                                            6.8
                                      25%
                                                                            6.6
                                                                            6.8
                                                                            7.3
                                                                            7.2
                                      25%
                                                                            7.3
                                                                            7.4
                                                                            7.8
                                                                            7.7
                                      15%
                                                                            8.0
                                                                            7.9
                                                                            8.3
                                                                            8.3
                                      10%
                                                                            8.6
                                                                            8.4
                                                                            8.8
                                                                            8.9

EPA then used the estimates in Exhibit 5-55 to develop the pH distribution for model-PWSs with 1) no CCT installed and 2) orthophosphate (PO4) treatment installed. EPA assumes that model-PWSs with no CCT would have pH of at least 7.0. Therefore, EPA truncated the values for "PWSs without pH Adjustment in Place" which resulted in the distribution for the variable baselineph_wocct. Likewise, EPA used the estimates in Exhibit 5-55 to develop the pH distribution for model-PWSs with PO4 in place without pH adjustment. EPA assumes that model-PWSs with only PO4 installed would have pH of at least 6.3. Therefore, EPA truncated the values for "PWSs without pH Adjustment in Place" which resulted in the distribution for the variable baseline_woph. The distributions for both baselineph_wocct and baselineph_woph are provided in Exhibit 5-55.
Exhibit 5-55: Distribution of Finished Water pH by Source Water Type for Model-PWSs without pH Adjustment in Place by CCT Status
                                  Probability
                               Finished Water pH
                                  Probability
                               Finished Water pH

                           PWSs without CCT in Place
                               baselineph_wocct

                          PWSs with just PO4 in Place
                                baselineph_woph

Groundwater
Surface Water

Groundwater
Surface Water

                                                                            25%
                                                                            6.3
                                                                            6.3
                                      50%
                                                                            7.0
                                                                            7.0
                                                                            25%
                                                                            6.6
                                                                            6.8
                                      25%
                                                                            7.3
                                                                            7.4
                                                                            25%
                                                                            7.3
                                                                            7.4
                                      15%
                                                                            8.0
                                                                            7.9
                                                                            15%
                                                                            8.0
                                                                            7.9
                                      10%
                                                                            8.6
                                                                            8.4
                                                                            10%
                                                                            8.6
                                                                            8.4

EPA then used the estimates in Exhibit 5-55 to develop the pH distribution for model-PWSs with pH adjustment in place by CCT status. EPA assumed that model-PWSs with PO4 and pH adjustment could have any of the baseline pH levels associated with "PWSs with pH adjustment in place." Therefore, no adjustment to the pH distribution for "PWSs with pH Adjustment in Place" was required to develop the distribution for the variable baselineph_wpo4ph. However, EPA determined that PWSs with only pH adjustment installed would have a pH of at least 8.2. Therefore, EPA truncated the values for "PWSs with pH Adjustment in Place" which resulted in the distribution for the variable baseline_wph. The distributions for both baselineph_wpo4ph and baselineph_wph are provided in Exhibit 5-56.
Exhibit 5-56: Distribution of Finished Water pH by Source Water Type for Model-PWSs with pH Adjustment in Place by CCT Status
                                  Probability
                               Finished Water pH
                                  Probability
                               Finished Water pH

                   PWSs with PO4 and pH Adjustment in Place
                               baselineph_wpo4ph

                     PWSs with only pH Adjustment in Place
                                baselineph_wph

Groundwater
Surface Water

Groundwater
Surface Water
                                      10%
                                                                            6.3
                                                                            6.3

                                      15%
                                                                            6.8
                                                                            6.8

                                      25%
                                                                            7.3
                                                                            7.2

                                      25%
                                                                            7.8
                                                                            7.7
                                                                            75%
                                                                            8.2
                                                                            8.2
                                      15%
                                                                            8.3
                                                                            8.3
                                                                            15%
                                                                            8.3
                                                                            8.3
                                      10%
                                                                            8.8
                                                                            8.9
                                                                            10%
                                                                            8.8
                                                                            8.9

In order to determine the cost of re-optimizing CCT or undertaking pH adjustment triggered by find-and-fix requirements, for model-PWSs with existing PO4 treatment installed, the SafeWater LCR model needs an estimate of the model-PWS's baseline dose of PO4. Using data from the Six-Year Review ICR Dataset, EPA developed a triangular distribution based on the minimum (0.05 mg/L), mode (1.4 mg/L), and maximum (4 mg/L) of reported baseline PO4 doses. For ease of modeling CCT unit costs, EPA limited the number of potential baseline PO4 doses to four ranges and represented each range by its median as shown in Exhibit 5-57, columns (a), (b), and (c). Using the triangular distribution, EPA determined the likelihood of a model-PWS having a baseline PO4 dose in each range as shown in column (d). EPA assumed this likelihood applied to model-PWSs serving 50,000 or fewer people with no LSLs. EPA then assumed that these smaller systems, that have LSLs, will be less likely than same size systems without LSLs to have PO4 doses in the lowest of the four ranges, since LSLs, when present, represent the greatest contributor of lead in a home's drinking water.  A study published by the American Water Works Association (AWWA) Research Foundation ``Contributions of Service Line and Plumbing Fixtures to Lead and Copper Rule Compliance Issues'' (Sandvig et al., 2008) estimates that 50 percent to 75 percent of lead in drinking water comes from LSLs. Since LSLs represent a more significant lead challenge, it is expected that systems would need higher orthophosphate doses to reduce lead levels. EPA modeled this assumption by decreasing the likelihood of having a dose of 0.525 mg/L by 50 percent and increasing the likelihood of having the next highest dose, 1.5 mg/L, by an equivalent amount (see column (e)).
EPA also made adjustments to implement its assumption that larger systems have a higher probability of higher doses than small systems with similar LSL status (see columns (f) and (g)), since the distribution systems are larger and more complex. Finally, EPA assumed, for modeling purposes, that a dose of 3.2 mg/L will result in optimized CCT and that no model-PWS in the baseline has fully optimized CCT as a conservative estimate. Therefore, the likelihood of a model-PWS having a baseline dose of 3.2 mg/L is set to zero and the likelihoods of the other doses is normalized so that the sum of the percentage values equal 100 percent. The final baseline PO4 doses, and their likelihoods, are provided in Exhibit 5-58.

Exhibit 5-57: Derivation of Baseline PO4 Dose by System Size and LSL Status
                            PO4 Dose Range Minimum
                                     (mg/L)
                                      (a)
                         PO4 Dose Range Maximum (mg/L)
                                      (b)
                         PO4 Dose Range Median (mg/L)
                                      (c)
                                  Likelihood
                               <=50,000 people
                                    No LSL
                                      (d)
                                  Likelihood
                               <=50,000 people
                                      LSL
                                      (e)
                                  Likelihood
                              > 50,000 people
                                    No LSL
                                      (f)
                         Likelihood >50,000 people
                                      LSL
                                      (g)
                                                                           0.05
                                                                          <1
                                                                          0.525
                                                                           7.9%
                                                                           4.0%
                                                                           4.0%
                                                                             0%
                                                                          >= 1
                                                                          <2
                                                                            1.5
                                                                          48.1%
                                                                          52.1%
                                                                          28.0%
                                                                          32.0%
                                                                           >=2
                                                                         <=3.2
                                                                           2.65
                                                                          38.6%
                                                                          38.6%
                                                                          43.4%
                                                                          43.4%
                                                                         >=3.2
                                                                              4
                                                                            3.6
                                                                           5.4%
                                                                           5.4%
                                                                          24.7%
                                                                          24.7%

Exhibit 5-58: Baseline PO4 Doses by System Size and LSL Status Used in Cost Modeling
                         PO4 Dose Range Median (mg/L)
                             Normalized Likelihood
                               <=50,000 people
                                    No LSL
                             Normalized Likelihood
                               <=50,000 people
                                      LSL
                             Normalized Likelihood
                              > 50,000 people
                                    No LSL
                                  Normalized
                                  Likelihood
                               >50,000 people
                                      LSL
                                                                          0.525
                                                                             8%
                                                                             4%
                                                                             5%
                                                                             0%
                                                                            1.5
                                                                            51%
                                                                            55%
                                                                            37%
                                                                            42%
                                                                           2.65
                                                                            41%
                                                                            41%
                                                                            58%
                                                                            58%

CCT Installation
PWSs without CCT may be required to install CCT under the LCRR if they exceed the lead AL. Costs related to CCT installation are categorized as follows:
 Capital and operations and maintenance costs (see Section <IP_ADDRESS>.1).
 Ancillary costs (see Section <IP_ADDRESS>.2).
Capital and Operation and Maintenance CCT Installation Costs
Under the final LCRR, a PWS that installs CCT (listed as activity b) in Exhibit 5-10) will choose among three technology options.
 Add PO4 and pH post-treatment
 Add PO4 and modify pH
 Modify pH
EPA assumed that model-PWSs with a baseline pH (baselineph_wocct) equal to or greater than 7.2, but less than 8.4, will choose to add PO4 and conduct pH post-treatment, while those with pH below 7.2 will choose to add PO4 and modify pH. For model PWSs that add PO4 with pH post-treatment, EPA assumed that the PO4 dose is equal to 3.2 mg/L and post-treatment will maintain the current pH level (baselineph_wocct). For model-PWSs that add PO4 and adjust pH, EPA assumes the same PO4 dose of 3.2 mg/L. In addition, EPA assumes the model PWS will adjust their pH from their starting pH (baselineph_wocct) to 7.2. EPA assumes that model-PWSs with a baseline pH greater that 8.4 will choose to modify pH and not add PO4.
The SafeWater LCR model uses the WBS unit cost functions (see Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2020), along with the EP flow values, to calculate the capital and O&M costs for CCT installation at each entry point to the distribution system (EP). All of the WBS capital cost equations are a function of DF, and all WBS O&M costs are a function of ADF. Since CCT is conducted at the model-PWS's EPs, the SafeWater LCR model calculates the DF and ADF of each EP. For all model-PWSs except some very large systems (see Section <IP_ADDRESS>), EPA does not know the number of people, and hence, flow, associated with individual EPs. Therefore, in the absence of this information, the SafeWater LCR model calculates the EPs flows assuming they are equal to:
         Entry Point Design Flow = PWS Design Flow / PWS Number of EPs
  Entry Point Average Daily Flow = PWS Average Daily Flow / PWS Number of EPs
The model-PWS capital and O&M cost of CCT installation at each EP is then multiplied by the number of EPs. The cost models, and their inputs, for calculating the capital and O&M cost of CCT installation are:
 PO4 and pH post-treatment
         PO4 dose = 3.2
         Current pH: = baselineph_wocct
         Ending pH = baselineph_wocct
 Add PO4 and modify pH
         PO4 dose = 3.2
         Current pH = baselineph_wocct
         Ending pH = 7.2
 Modify pH
         PO4 dose = 3.2
         Current pH = baselineph_wocct
         Ending pH = 9.2
In addition to the capital and O&M cost of CCT installation, model-PWSs also face an ancillary CCT study cost associated with CCT installation. This cost is discussed in the next section.
Ancillary CCT Installation Costs
EPA has developed system costs for an ancillary activity associated with CCT installation as shown in Exhibit 5-59. The exhibit provides the unit burden and/or cost for the activity. The assumptions used in the estimation of the unit burden and cost follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-59: PWS CCT Installation-Related Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
    Conduct a study
Study
 No LSLs (coupon testing): $7,205
 With LSLs (harvested pipe loop testing): $276,249 for <= 50,000 people; $342,475 for > 50,000 people

cost_cct_study_dem
Acronyms: CCT = corrosion control treatment; LSL = lead service line.
Note: Activity b), "Install CCT Treatment (PO4, PO4 with post treatment, pH adjustment, or modify pH)" was previously discussed in Section <IP_ADDRESS>.1.

    Conduct a Study (cost_cct_study_dem). EPA assumed Primacy Agencies will require all systems to conduct either harvested pipe loop testing or a coupon study prior to CCT installation. The SafeWater LCR model uses the following set of assumptions:
 Systems required to conduct a CCT study will use a contractor.
 Systems without LSLs will use a coupon study at an estimated cost of $7,205 for systems of all sizes.
 Systems with LSLs will incur a cost of $276,249 for those serving 50,000 or fewer and $342,476 for those serving more than 50,000 people for harvested pipe loop testing.
The development of harvested pipe loop and coupon test study costs are detailed in Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2020).
Exhibit 5-60 details how the data variables are used to estimate system ancillary activities related to CCT Installation.
Exhibit 5-60: PWS Ancillary CCT Installation Cost Estimation in SafeWater LCR by Activity[1]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th] - Range
Other Conditions

    Conduct a CCT study
Material cost per system for the marginal contractor cost, with the difference between coupon testing and harvested pipe loop testing reflected in the stratification of the data by system LSL status.

cost_cct_study_dem
Cost applies as written to NTNCWSs.
Above AL
Model PWSs without CCT that conducts a study on CCT installation
One time
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; LSL = lead service line; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
Re-optimization of Existing Corrosion Control Treatment
PWSs that have previously implemented CCT may be required to re-optimize their treatment if they exceed the lead TL. Costs related to CCT re-optimization are categorized as follows:
 Capital and operations and maintenance costs (see Section <IP_ADDRESS>.1).
 Ancillary costs (see Section <IP_ADDRESS>.2).
Capital and Operation and Maintenance CCT Re-optimization Costs
Estimating the cost of existing CCT
While EPA knows which model-PWSs currently have CCT installed, EPA does not know which CCT technology they have installed. Therefore, when the SafeWater LCR model develops the model-PWSs, it assigns a CCT technology to each model PWS known to have CCT in place. These CCT technologies, and their input parameters used in the WBS models, to calculate existing CCT O&M costs, are:
 Add PO4 with PH Post Treatment.
             PO4 Dose = baselinepo4dose
             Starting pH: baselineph_woph
             Ending pH: baselineph_woph

 Modify pH.
             Starting pH: baselineph_wph  -  0.5
             Ending pH: pH: baselineph_wph

 Technology: Add PO4 and Modify PH.
             PO4 Dose = baselinepo4dose
             Starting pH: baselineph_wpo4ph- 0.5
             Ending pH: baselineph_wpo4ph
Estimating the cost of re-optimizing existing CCT
EPA assumed that if a model-PWS must re-optimize its CCT under the final LCRR (listed as activity d) in Exhibit 5-10), it will achieve the following standards based on its existing CCT technology (which was described above):
 Add PO4 and pH post-treatment.
 Increase PO4 dose to 3.2 mg/L.
 Maintain existing pH.
 Add PO4 and modify pH.
 Increase PO4 dose of 3.2 mg/L.
 Maintain pH at a minimum of 7.2.
 Modify pH.
 Maintain pH at 9.2.
To calculate the cost to re-optimize CCT, the SafeWater LCR model first calculates the annual O&M cost of treating to the above assumed standards (PO4 dose and/or pH level) as if no CCT was installed. To do so, the SafeWater LCR model uses the following parameters and WBS cost functions:
 Add PO4 and pH post-treatment.
             PO4 Dose = 3.2 mg/L
             Beginning pH = baselineph_woph
             Ending pH = baselineph_woph
 Add PO4 and modify pH.
             PO4 Dose = 3.2 mg/L
             Beginning pH = baselineph_wpo4ph- 0.5
             Ending pH = the greater of baselineph_wpo4ph or 7.2
 Modify pH.
             Beginning pH = baselineph_wph -0.5
             Ending pH = 9.2
The SafeWater LCR model then subtracts the model PWS's existing CCT annual O&M cost from the new annual O&M cost to calculate the share of the model PWS's annual CCT O&M costs attributable to the final LCRR CCT requirements. These O&M costs, combined with the annualized capital cost to retrofit the CCT system based on the new parameters, described above, equal the model PWS's total annual capital and O&M cost for CCT adjustment. The following section discusses additional ancillary costs associated with CCT adjustment.
Ancillary CCT Re-optimization Costs
EPA has developed system ancillary costs for an ancillary activity associated with CCT re-optimization as shown in Exhibit 5-61. The exhibit provides the unit burden and/or cost for the activity. The assumptions used in the estimation of the unit burden follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-61: PWS CCT Ancillary Re-optimization Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
    Revise CCT study
Systems with TLE but no ALE
$5,651 to $10,872/system

Systems with ALE
No LSLs: $7,205
with LSLs: $276,249 to $342,476
cost_revise_cct

cost_cct_study_dem
Acronyms: ALE = action level exceedance, CCT = corrosion control treatment; LSL = lead service line; TLE = trigger level exceedance.
Source: Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2020).
Note: Activity d), "Reoptimize existing CCT" was previously discussed in Section <IP_ADDRESS>.1.

    Revise CCT study (cost_revise_cct; cost_cct_study_dem). EPA assumed Primacy Agencies will require all systems to conduct a study prior to CCT re-optimization.
 Systems will use a contractor to conduct a study.
 Systems with a TLE but no ALE will revise their existing CCT (cost_revise_cct) that is estimated at $5,651 for systems serving 3,300 or fewer people, $8,046 for systems serving 3,301 to 50,000 people, and $10,872 for systems serving more than 50,000 people. Note that this may overestimate costs because the final LCRR gives Primacy Agencies discretion to allow these systems to re-optimize without first conducting a study.
 Systems with an ALE will conduct a demonstration study (cost_cct_study_dem). Specifically, systems:
 Without LSLs will do a coupon study at an estimated cost of $7,205 for all sizes.
 With LSLs will do a harvested pipe loop at an estimated cost of $276,249 for systems serving 50,000 or fewer people and $342,476 for those serving more than 50,000 people.
The development of harvested pipe loop and coupon test study costs are detailed in Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2020).
Exhibit 5-62 shows the SafeWater LCR model cost estimation approach for system ancillary CCT re-optimization study activities including additional cost inputs required to calculate these costs.
Exhibit 5-62: PWS CCT Ancillary Re-optimization Cost Estimation in SafeWater LCR by Activity[1]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th] - Range
Other Conditions

    Revise CCT study
Material cost per system for the marginal contractor cost for revision of CCT study.

cost_revise_cct
Cost applies as written to NTNCWSs.
At or below AL and above TL
Model PWS re-optimizing CCT
One time
Material cost per system for the marginal contractor cost, with the difference between coupon testing and harvested pipe loop testing reflected in the stratification of the data by system LSL status.

cost_cct_study_dem
Cost applies as written to NTNCWSs.
Above AL
Model PWS re-optimizing CCT
One time
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; LSL = lead service line; NTNCWS = non-transient non-community water system; PWS = public water system; TL = trigger level.
Notes:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
Find-and-Fix Costs
Under the final LCRR, PWSs must take find-and-fix corrective actions whenever an individual tap water sample exceeds 15 ug/L. The likelihood that a sample would exceed 15 ug/L is provided in Exhibit 5-63.
Exhibit 5-63: Likelihood of an Individual Lead Sample Result Above 15 ug/L
                                  LSL Status
                                     ALE
                              (P90 >15 μg/L)
                                     TLE
                       (10 μg/L < P90  <=15 μg/L)
                                  No TLE/ALE
                               (P90 <=10 μg/L)

pp_above_al_bin_one
pp_above_al_bin_two
pp_above_al_bin_three
Has LSLs
                                                                          25.4%
                                                                           6.1%
                                                                           1.2%
No LSLs
                                                                          22.7%
                                                                          15.4%
                                                                           0.3%
   Acronyms: ALE = action level exceedance; LSL = lead service line; TLE = trigger level exceedance.
   Source: Total rows in Columns G through I in Exhibit 4-24 in Chapter 4.

EPA assumed in the SafeWater LCR model that in response to individual tap water samples above 15 ug/L, model-PWSs will take progressively more stringent corrective actions. These assumed actions are:
 First sampling period with one or more individual tap water samples above 15 ug/L  -  model-PWS will investigate the cause but not take any corrective action.
 Second sampling period with one or more individual tap water samples above 15 ug/L  -  model-PWS will perform spot flushing once in the distribution system.
 Third sampling period with one or more individual tap water samples above 15 ug/L  -  model-PWS will increase the pH level at one EP.
 Fourth sampling period with one or more individual tap water samples above 15 ug/L  -  model-PWS will increase the pH at all other EPs (if more than one).
These corrective actions are not meant to encompass the entire suite of find-and-fix compliance options but rather provide a representation of typical actions a PWS might take to correct reoccurring individual tap samples over 15 ug/L.
Cost of Spot Flushing an Entry Point
In response to a second sampling period with at least one lead tap sample greater than 15 ug/L, EPA assumed, in the Safe Water LCR model, that systems will perform spot flushing. Spot flushing involves crews opening hydrants in the area of the tap monitoring result to bring in fresh water and eliminate potential issues with elevated water age, which could cause the water to be more corrosive. The assumptions for spot flushing are consistent with the Technology and Cost Document for the Revised Total Coliform Rule (USEPA, 2012a). See Exhibit 5-64 for the PWS unit burden and cost for spot flushing with detailed assumptions in the notes.
Exhibit 5-64: PWS Burden and Cost to Flush as Find-and-Fix Response
                                 System Size
                              (Population Served)
                   Burden (hrs per system) (hrs_flush_wqp_op)
                      Cost ($ per system) (cost_flush_wqp)

                                       A
                                       B
 <=1,000
                                                                              4
                                                                        $121.80
 1,001-3,300
                                                                              4
                                                                        $182.08
 3,301-100,000
                                                                              8
                                                                        $182.08
 >100,000
                                                                              8
                                                                        $242.37
   Source: Technology and Cost Document for the Revised Total Coliform Rule (USEPA, 2012a; "Derivation of Initial P90 Categorization_Final Rule.xlsx.").
   Notes:
   A: Assumes that each spot flushing response is a one-half day event. Assumes 1-person crew for systems serving 3,300 or fewer people and 2-person crew for those serving > 3,300 people.
   B: Estimate is based on value of flushed water and cost of flushed water disposal, i.e., dichlorination. Where LCRR system size categories do not match those used in the technology and cost document for the Revised Total Coliform Rule (RTCR), EPA used the closest category.
Cost of pH Adjustment
In response to a third sampling period with at least one lead tap sample greater than 15 ug/L, EPA assumed, in the Safe Water LCR model, that a model-PWS will increase its pH at one EP if it has optimized CCT in place. EPA assumed the model-PWS will achieve the following standards:
 If model-PWS has used PO4 for its corrosion inhibitor, then the system will maintain its pH at a minimum of 7.5 instead of 7.2.
 If a model-PWS modified pH for corrosion control, it will maintain its pH at 9.4 instead of 9.2.
To calculate the cost to increase pH in response to individual tap samples above 15 ug/L, the SafeWater LCR model first calculates the total annual O&M cost for treating to the find-and-fix standards listed above as if no CCT was installed. The SafeWater LCR model also calculates the capital cost to retrofit the CCT system for additional pH adjustment. To do so, the SafeWater LCR model uses the following parameters and WBS cost functions:
 If the model-PWS has PO4 treatment installed and its baselineph_woph < 7.5:
          Add PO4 and Modify pH
          PO4 Dose = 3.2
          Starting pH: baselineph_woph
          Ending pH: 7.5

 If the model-PWS has PO4 treatment installed and its baselineph_woph >= 7.5:
           Add PO4 with pH Post Treatment
           PO4 Dose = 3.2
           Starting pH: baselineph_woph
           Ending pH: baselineph_woph

 If the model-PWS has pH adjustment installed:
           Modify pH
           Starting pH: = baselineph_woph  -  0.5
           Ending pH: 9.4

The SafeWater LCR model then subtracts the model-PWS's current CCT annual O&M cost from the new find-and-fix annual O&M cost to calculate the share of model-PWS's annual CCT O&M costs attributable to find-and-fix actions. These O&M costs combined with the annualized capital cost to retrofit the CCT system based on the new parameters, described above, equal the model-PWS's total annual capital and O&M cost of find-and-fix. Additional ancillary costs associated with find-and-fix are discussed in the following section.
In the fourth sampling period with one or more individual tap water samples above 15 ug/L, the model-PWS will increase the pH at all other EPs (if the model-PWS has more than one EP). This calculation is the same as described for the year 3 find-and-fix pH adjustment except that the calculation is made for all entry points.
Ancillary Find-and-Fix Costs
EPA developed ancillary costs associated with of a system's find-and-fix responses to a lead tap result above 15 ug/L as shown in Exhibit 5-65. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of each activity follows the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font. In a few instances, some of these activities are conducted by the state instead of the water system. These activities are identified in the exhibit and further explained in the exhibit notes.
Exhibit 5-65: PWS Ancillary Find-and-Fix Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
    Contact customers and collect follow-up tap sample
Burden per sample
CWSs: 3.4 to 3.7 hrs
NTNCWSs: 0.5 hrs
Costs per sample
CWSs: $5.29 to $12.43
NTNCWSs: $0
Burden
hrs_samp_above_al_op

Cost
cost_samp_above_al

Analyze follow-up lead tap sample
In-house Analysis (CWSs > 100K only)
Burden: 0.44 hrs/sample
Cost: $2.38

Commercial Analysis
$21.58
In-house Analysis
hrs_analyze_samp_op[1]
cost_lab_lt_samp[1]

Commercial Analysis
cost_commercial_lab[1]
Collect distribution system WQP sample
Burden per sample per PWS
0.5 hrs

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

Cost
No CCT: cost_wqp_material
pH: cost_wqp_material_ph

Orthophosphate: cost_wqp_material_ortho
Analyze distribution system WQP sample
In-House Burden per sample
No CCT: 0.15 hrs (CWS & NTNCWS)
pH adjustment:
  0.15 to 0.46 hrs (CWS)
  0.15 hrs (NTNCWS)
Orthophosphate:
  0.15 to 1.34 hrs (CWS)
  0.15 hrs (NTNCWS)

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

Commercial cost per sample
No CCT: $23.92 (CWS & NTNCWS)
pH adjustment: $23.92 (CWS & NTNCWS)
Orthophosphate: $49.35 (CWS & NTNCWS)
In-House Burden
No CCT: hrs_wqp_analyze_dist_op
pH adjustment: hrs_wqp_analyze_ph_op

Orthophosphate: hrs_wqp_analyze_ortho_op

In-House Cost
No CCT: cost_wqp_analyze
pH adjustment: cost_wqp_ph_analyze

Orthophosphate: cost_wqp_ortho_analyze

Commercial Cost
No CCT: cost_lab_wqp
pH: cost_lab_ph_wqp
Orthophosphate: cost_lab_ortho_wqp
Review incidents of system-wide event and other system conditions
CWSs: 4 to 30 hrs/system
NTNCWSs: 1 to 14 hrs/system
hrs_events_deter_find_fix_op
Consult with Primacy Agency prior to making CCT changes
2 hrs per system with CCT

hrs_consult_find_fix_op
Report follow-up sample results and overall "find-and-fix" responses to Primacy Agency
2 hrs/PWS serving <= 50,000 people;
4 hrs/PWS serving > 50,000 people
hrs_comp_report_find_fix_op
Acronyms: CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-community water system; PWS = public water system; WQP = water quality parameter.
Sources: Data sources for each activity are provided following this exhibit.
Note:
[1] In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina, the state pays for the cost of bottles, shipping, analysis, and providing sample results to the system. Thus, the state will incur the burden and cost for these activities in lieu of the system.

Contact customers and collect follow-up tap samples (hrs_samp_above_al_op, cost_samp_above_al). CWSs and NTNCWSs will incur burden and costs to contact customers and collect a follow-up tap sample at each compliance sampling location that had a result above 15 ug/L. Exhibit 5-63 in Section <IP_ADDRESS> provides the likelihood a system will have a single sample above 15 ug/L for each of the three lead 90[th] percentile classifications (pp_above_al_bin_one, pp_above_al_bin_two, and pp_above_al_bin_three). Also refer to Chapter 4, Section <IP_ADDRESS> for a detailed discussion of EPA's approach for developing these percentages. For modeling purposes, EPA assumed all customers would respond to the water system and agree to have a follow-up sample collected.
    Exhibit 5-66 provides the burden or labor associated with these activities for CWSs and Exhibit 5-67 provides the associated costs. Burden and cost estimates for NTNCWSs follow the exhibits.
    Note that the required notification to the customer of the original sample result above 15 ug/L that triggered the additional sampling is captured under the public education requirements in Section <IP_ADDRESS> using input hrs_pe_above_al_prep_op. EPA assumed CWSs will call customers and incur a burden of 0.25 hours per call as opposed to mailing. EPA also assumed NTNCWSs will use the same mechanism they currently use to inform their customers of sample results via posting and electronic notification but would provide this information within 3 calendar days. To avoid double counting, EPA did not assign any additional burden or costs to NTNCWSs for this 3 calendar day notification but included the burden and costs as part of the Lead Tap Sampling Costs using hrs_NTNCWS_inform_samp_op and cost_NTNCWS_inform_lt. See Section <IP_ADDRESS>.2, activity l).
Exhibit 5-66: Burden (hours) for CWSs to Contact Customers and Collect Tap Samples for Locations with a Lead Tap Sample > 15 ug/L (hrs_samp_above_al_op)
                                  System Size
                              (Population Served)
                                   Phone Call
                                   Site Visit
                                     Total

                              Travel (Round-Trip)
                             Look for Lead Sources
                               Sample Collection

                                       A
                                       B
                                       C
                                       D
                                     E=A:D
 <=100,000
                                                                            0.5
                                                                           0.39
                                                                              2
                                                                            0.5
                                                                            3.4
 100,001-1,000,000
                                                                            0.5
                                                                           0.50
                                                                              2
                                                                            0.5
                                                                            3.5
 >1,000,000
                                                                            0.5
                                                                           0.67
                                                                              2
                                                                            0.5
                                                                            3.7
 Source: "Derivation of Probability of Sample_Above_15_Final Rule.xlsx."
 Notes:
 General: This requirement applies to all CWSs that have any sample > 15 ug/L.
 A: Assumed systems would spend 0.5 hours to contact customer to coordinate site visit and to discuss possible causes of the high tap sample value.
 B: Based on census data and zip codes from the 2006 Community Water System Survey, assumed the following one-way driving distances for CWSs: 4.9 miles for those serving <= 100,000 people, 6.3 miles for those serving 100,001  -  1,000,000, and 8.4 miles for those serving > 1,000,000. See file, "Derivation of Estimated Driving Distances_Final Rule.xlsx," available in the docket under EPA-HQ-OW-2017-0300 at www.regulations.gov," for additional detail. EPA assumed an average speed of 25 miles per hour and two times distance for round-trip travel.
 C: Assumed systems will spend 2 hours on average to look for lead sources in premise plumbing and service line.
 D: Assumed same burden as used for systems to collect a lead and copper source water sample, see Section <IP_ADDRESS>.2, activity z) for detail.

Exhibit 5-67: Costs for CWSs to Contact Customers and Collect Tap Samples for Locations with a Lead Tap Sample > 15 ug/L (cost_samp_above_al)
                                  System Size
                              (Population Served)
                                   Phone Call
                                   Site Visit
                                     Total

                              Travel (Round-Trip)
                             Look for Lead Sources
                               Sample Collection

                                       A
                                       B
                                       C
                                       D
                                     E=A:D
 <=100,000
                                                                          $0.00
                                                                          $5.29
                                                                          $0.00
                                                                          $0.00
                                                                          $5.29
 100,001-1,000,000
                                                                          $0.00
                                                                          $6.80
                                                                          $0.00
                                                                          $3.36
                                                                         $10.16
 >1,000,000
                                                                          $0.00
                                                                          $9.07
                                                                          $0.00
                                                                          $3.36
                                                                         $12.43
Source: "Derivation of Probability of Sample_Above_15_Final Rule.xlsx."
Notes:
General: This requirement applies to all CWSs that have any sample > 15 ug/L.
A&C: Assumed to have no non-labor costs.
B: Based on census data and zip codes from the 2006 Community Water System Survey, assumed the following one-way driving distances for CWSs: 4.9 miles for those serving <= 100,000 people, 6.3 miles for those serving 100,001  -  1,000,000, and 8.4 miles for those serving > 1,000,000. See file, "Derivation of Estimated Driving Distances_Final Rule.xlsx," available in the docket under EPA-HQ-OW-2017-0300 at www.regulations.gov," for additional detail. Assumed cost of $0.54 per mile using the 2016 reimbursement rate from at https://www.gsa.gov/travel/plan-book/per-diem-rates.
D: Based on information from laboratories, only CWSs serving > 100,000 people are assumed to conduct in-house analyses for lead whereas those serving <= 100,000 people will use a commercial lab and bottles are supplied by the commercial lab. The average cost of a 1-liter wide mouth bottle assuming a bulk discount rate of 15 percent based on three sources is $3.36. See "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx", worksheet": In-House_Bottle_$" for additional information.

NTNCWSs will also be required to collect a follow-up sample but will incur a different burden and cost from CWSs because they do not serve homeowners and thus, are not required to conduct a separate site visit. EPA assumed NTNCWSs will incur a burden 0.5 hours per follow-up sample (hrs_samp_above_al_op), which is the same burden as that used to collect a lead and copper source water sample and is based on the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 15 (USEPA, 2015b). In addition, NTNCWSs will incur no bottle costs to collect the sample because EPA assumed all NTNCWSs will use a commercial lab in which bottles are included as part of the laboratory fee. Thus, cost_samp_above_15 is $0.
Analyze follow-up tap samples (hrs_analyze_samp_op, cost_lab_lt_samp, cost_commercial_lab). As previously presented in Section <IP_ADDRESS>.2, activity j), EPA assumed CWSs serving more than 100,000 people will conduct lead analyses in-house and require 0.44 hours per sample based on estimates provided by three laboratories (hrs_analyze_samp_op). These systems will also incur consumable costs of $2.38 per sample based on information from three vendors (cost_lab_lt_samp). The remaining CWSs and all NTNCWSs are assumed to use a commercial laboratory and incur a cost of $21.58 per lead sample based on quotes from six laboratories (cost_commercial_lab). See "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx," "worksheet Commercial Analytical_$"  for additional information.
Collect distribution system WQP sample (hrs_wqp_find_fix_op, cost_wqp_material, cost_wqp_material_ph, cost_wqp_material_ortho). Systems must collect one distribution sample at or near the site where the high lead sample was collected within five days of learning of the lead results. Thus, EPA assumed the timing of this monitoring may not coincide with their Total Coliform Rule (TCR) samples and systems would incur a burden of 0.5 hours to collect the WQP sample (hrs_wqp_find_fix_op). EPA uses the same SafeWater LCR model data variables and input values for the burden and cost associated with WQP distribution system sample collection as described in Section <IP_ADDRESS>.4 and Exhibit 5-25 (CWSs) and Exhibit 5-26 (NTNCWSs) for this activity.
   If an existing WQP site does not meet these criteria, the system must identify a new monitoring site. Systems with CCT only must use it for future WQP distribution system sampling. In the final rule, EPA has capped the additional number of WQP sample sites that must be added in response to find-and-fix to twice the standard number of required WQP sample sites. For example, as discussed in Section <IP_ADDRESS>.3, systems serving 10,001 to 50,000 people must conduct monitoring from 10 sites if they are on routine monitoring (numb_enhance_wqp). For find-and-fix distribution monitoring, no more than 10 additional sites would be added for systems on routine or reduced monitoring.
   NTNCWSs have limited distribution systems and EPA assumed these systems with CCT will not add new WQP sites. For CWSs, EPA estimated the likelihood a WQP site will need to be added (pp_overlap_find_fix) in Exhibit 5-68. This likelihood is used to determine the number of sites added to a CWS's WQP sample collection and analysis each year (numb_wqp_sites_added).
Exhibit 5-68: Likelihood a CWS Will Add a WQP Sampling Site in Response to Find-and-Fix
                                  System Size
                              (Population Served)
                      Tap Samples sites (routine number)
                                  WQP sites
                               (routine number)
                     Percent of WQPs compared to Tap Sites
                     Likelihood a CWS will add a WQP site

                              pp_overlap_find_fix

                                       A
                                       B
                                  C = B/A*100
                                       D
<=100
                                                                              5
                                                                              1
                                                                          20.0%
                                                                           0.0%
101-500
                                                                             10
                                                                              1
                                                                          10.0%
                                                                           0.0%
501-1,000
                                                                             20
                                                                              2
                                                                          10.0%
                                                                           0.0%
1,001-3,300
                                                                             20
                                                                              2
                                                                          10.0%
                                                                          20.0%
3,301-10,000
                                                                             40
                                                                              3
                                                                           7.5%
                                                                          20.0%
10,001-100,000
                                                                             60
                                                                             10
                                                                          16.7%
                                                                          20.0%
>100,000
                                                                            100
                                                                             25
                                                                          25.0%
                                                                          10.0%
Source: "Derivation of Probability_Sample_Above_15_Final Rule.xlsx."
Notes:
A: See Exhibit 5-13.
B: See Exhibit 5-23.
D: EPA assumed for CWSs with CCT serving:
 <=1,000 people, the distribution system is not extensive and the WQP sampling location would be at or near the sampling site with the lead result above 15 ug/L. Thus, these systems would have a zero likelihood of adding a new WQP site.
 > 1,000 people, EPA divided the minimum required number of WQP sites (Column B) by the number of tap sites (Column A). EPA assumed the higher the ratio, the more likely a system would be to have a WQP sampling site at or near a required tap sampling site with lead values greater than 15 ug/L and the lower the likelihood a system would add a new WQP sampling site. Specifically, EPA assumed those with a ratio of <= 20 percent (those serving 1,001 - 100,000 people) would have a 0.2 likelihood of adding a new WQP site. EPA assumed those with a ratio of > 20 percent would have a lower likelihood of 0.1 of adding a new WQP site (those serving > 100,000 people).

Analyze distribution system WQP sample. Systems must collect the same WQPs as discussed in Section <IP_ADDRESS>.4 for lead WQP monitoring. Specifically, systems without CCT and those using pH adjustment must sample for pH and alkalinity, those using orthophosphate treatment must sample for pH, alkalinity, and orthophosphate. Thus, EPA used the same SafeWater LCR model data variables and input values for WQP sample analysis as described in Section <IP_ADDRESS>.4 for lead WQP monitoring. See Exhibit 5-27 and Exhibit 5-28 for the analytical burden for CWSs and NTNCWSs to conduct in-house analyses, respectively (hrs_wqp_analyze_dist_op, hrs_wqp_analyze_ph_op, hrs_wqp_analyze_ortho_op). See Exhibit 5-29 and Exhibit 5-30 for the in-house analytical costs for CWSs and NTNCWSs, respectively (cost_wqp_analyze, cost_wqp_ph_analyze, cost_wqp_ortho_analyze). See Exhibit 5-31 and Exhibit 5-32 for the commercial costs per sample for CWSs and NTNCWSs, respectively (cost_lab_wqp, cost_lab_ph_wqp, cost_lab_ortho_wqp).
Review incidents of system-wide events and other system conditions (hrs_events_deter_find_fix_op). Under the LCRR, systems must determine if a CCT "fix" is needed following lead tap sample result(s) above 15 ug/L. For the purposes of this cost analysis, EPA assumed that systems will assess distribution system operations and determine if there could have been factors that contributed to deteriorating water quality and elevated lead levels. Exhibit 5-69 provides the estimated burden for CWSs and NTNCWSs to conduct this assessment. The estimates are based on comparable activities and burden estimates for CWSs and NTNCWSs to conduct level 1 assessments following non-acute TCR violations. Additional detail on the derivation of these burdens is provided in "Derivation of Probability_Sample_Above_15_Final Rule.xlsx," in worksheet, "Distribution_System_Assessment."
   Exhibit 5-69: PWS Burden to Conduct Distribution System Assessment
                                   System Size
                               (Population Served)
                   CWS Burden to Conduct Assessment (hrs/system)
                 NTNCWS Burden to Conduct Assessment (hrs/system)

                           hrs_events_deter_find_fix_op
 <=1,000
                                                                              4
                                                                              1
 1,001-3,300
                                                                              6
                                                                              1
 3,301-10,000
                                                                              8
                                                                              4
 10,001-50,000
                                                                             10
                                                                              5
 50,001-100,000
                                                                             13
                                                                              6
 >100,000
                                                                             30
                                                                             14
   Source: Technology and Cost Document for the Final Revised Total Coliform Rule (USEPA, 2012a); Economic Analysis for the Final Revised Total Coliform Rule (USEPA, 2012b) (available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov). Derived in "Derivation of Probability_Sample_Above_15_Final Rule.xlsx," worksheet, "Distribution_System_Assessment."

Consult with Primacy Agency prior to making CCT changes (hrs_consult_find_fix_op). Systems with CCT that have at least one sample > 15 ug/L must consult with their Primacy Agency prior to making any CCT changes. EPA assumed a 2 hour consultation burden that is consistent with other types of consultations and is based on the estimated burden for systems to consult with their Primacy Agency on public education activities from pg. 60 of the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (USEPA, 2007).
Report to Primacy Agency on find-and-fix activities (hrs_comp_report_find_fix_op). PWSs will incur burden to provide the results of tap and WQP monitoring results, and any distribution system management actions or CCT adjustments made to fix the cause of sample results above 15 ug/L to their Primacy Agency. EPA assumed the systems will require 2 hours and 4 hours to prepare the annual report for systems serving 50,000 or fewer and those serving more than 50,000 people, respectively. EPA assumed systems would not incur a separate cost for generating a physical report because systems would provide this information electronically to their Primacy Agency. Systems must also provide this information to the health departments. EPA assumed that systems would incorporate the find-and-fix results into a larger report that includes outreach information and school sampling results (CWSs only). The material cost of the report is captured under the cost to distribute the outreach, which corresponds to data input cost_hc. See Section <IP_ADDRESS>, activity l).
Exhibit 5-70 provides the SafeWater LCR model cost estimation approach for system ancillary find-and-fix activities including additional cost inputs that are required to calculate the total costs.
Exhibit 5-70: PWS Ancillary Find-and-Fix Cost Estimation in SafeWater LCR by Activity[1][.2]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th]  -  Range
Other Conditions

    Contact customers and collect follow-up tap samples[3]
The number of required samples per system >15 ug/L multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(pp_above_al_bin_three*numb_samp_customer)*((hrs_samp_above_al_op*rate_op)+cost_samp_above_al)
Cost applies as written to NTNCWSs.
At or below TL
PWSs not on reduced tap sampling and not doing POU sampling

1  -  (p_tap_annual + p_tap_triennial + p_tap_nine)
Twice a year
The number of required samples per system >15 ug/L multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(pp_above_al_bin_three*numb_reduced_tap)*((hrs_samp_above_al_op*rate_op)+cost_samp_above_al)

PWSs on annual reduced tap sampling and not doing POU sampling

p_tap_annual
Once a year

PWSs on triennial reduced tap sampling and not doing POU sampling

p_tap_triennial
Every 3 years
The number of required samples per system >15 ug/L multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(pp_above_al_bin_two*numb_samp_customer)*((hrs_samp_above_al_op*rate_op)+cost_samp_above_al)
Cost applies as written to NTNCWSs.
At or below AL and above TL
All PWSs with at least one sample > 15 ug/L
Once a year
The number of required samples per system >15 ug/L multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(pp_above_al_bin_one*numb_samp_customer)*((hrs_samp_above_al_op*rate_op)+cost_samp_above_al)

Above AL
All PWSs with at least one sample > 15 ug/L
Twice a year
    Analyze follow-up lead tap sample[3]
The number of samples multiplied by the likelihoods for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

(((pp_above_al_bin_three*numb_samp_customer)*pp_lab_samp)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+(((pp_above_al_bin_three*numb_samp_customer)*pp_commercial_samp)*cost_commercial_lab)
Cost applies as written to NTNCWSs.
At or below TL
PWSs is not on reduced tap sampling and not doing POU sampling

1  -  (p_tap_annual + p_tap_triennial + p_tap_nine)

Twice a year
The number of samples multiplied by the likelihoods for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

(((pp_above_al_bin_three*numb_reduced_tap)*pp_lab_samp)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+(((pp_above_al_bin_three*numb_reduced_tap)*pp_commercial_samp)*cost_commercial_lab)

PWSs on annual reduced tap sampling and not doing POU sampling

p_tap_annual
Once a year

PWSs on triennial reduced tap sampling and not doing POU sampling

p_tap_triennial
Every 3 years
The number of samples multiplied by the likelihoods for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

(((pp_above_al_bin_two*numb_samp_customer)*pp_lab_samp)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+(((pp_above_al_bin_two*numb_samp_customer)*pp_commercial_samp)*cost_commercial_lab)
Cost applies as written to NTNCWSs.
At or below AL and above TL
All PWSs with at least one sample > 15 ug/L
Once a year
The number of samples multiplied by the likelihoods for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

(((pp_above_al_bin_one*numb_samp_customer)*pp_lab_samp)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+(((pp_above_al_bin_one*numb_samp_customer)*pp_commercial_samp)*cost_commercial_lab)
Cost applies as written to NTNCWSs.
Above AL
All PWSs with at least one sample > 15 ug/L
Twice a year
    Collect distribution system WQP sample
The number of required samples per system >15 ug/L multiplied by the total of hours per sample times the system labor rate, plus the material cost per sample. A system only needs to collect an additional WQP monitoring sample if there is not existing WQP monitoring done near the site of the >15 ug/L tap sample.

numb_wqp_sites_added *((hrs_wqp_find_fix_op*rate_op)+cost_wqp_material_ph)
Cost does not apply to NTNCWSs.
All
PWSs with existing CCT of pH and not doing POU sampling

pbaseph

Once per event

The number of required samples per system >15 ug/L multiplied by the total of hours per sample times the system labor rate, plus the material cost per sample. A system only needs to collect an additional WQP monitoring sample if there is not existing WQP monitoring done at or near the site of the >15 ug/L tap sample.

numb_wqp_sites_added*((hrs_wqp_find_fix_op*rate_op)+cost_wqp_material_ortho)
Cost does not apply to NTNCWSs.
All
PWSs with existing CCT of PO4 or both PO4 and pH adjustment and not doing POU sampling

pbasepo4, pbasephpo4,
Once per event
    Analyze distribution system WQP sample
The number of samples multiplied by the likelihoods for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

A system only needs to collect an additional WQP monitoring sample if there is not existing WQP monitoring done near the site of the >15 ug/L tap sample.

((numb_wqp_sites_added*pp_lab_samp)*((hrs_wqp_analyze_ph_op*rate_op)+cost_wqp_ph_analyze))+((numb_wqp_sites_added*pp_commercial_samp)*cost_lab_ph_wqp)
Cost does not apply to NTNCWS
All
PWS with existing CCT of pH and not doing POU sampling

pbaseph
Once per event
The number of samples multiplied by the likelihoods for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

A system only needs to collect an additional WQP monitoring sample if there is not existing WQP monitoring done near the site of the >15 ug/L tap sample.

((numb_wqp_sites_added*pp_lab_samp)*((hrs_wqp_analyze_ortho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_wqp_sites_added*pp_commercial_samp)*cost_lab_ortho_wqp)
Cost does not apply to NTNCWS
All
PWSs with existing CCT of PO4 or both PO4 and pH adjustment and not doing POU sampling

pbasepo4, pbasephpo4
Once per event
    Review incidents of system-wise event and other system conditions
The labor hours for review per system multiplied by the system labor rate.

(hrs_events_deter_find_fix_op*rate_op)
Cost applies as written to NTNCWSs.
All
All PWSs with at least one sample > 15 ug/L
Once per event
    Consult with Primacy Agency prior to making CCT changes
The labor hours per system multiplied by the system labor

(hrs_consult_find_fix_op*rate_op)
Cost applies as written to NTNCWSs.
All
All PWSs where a second sampling period has at least one sample > 15 ug/L
Once per event
    Report follow-up sample results and overall "find-and-fix" responses
Hours for reporting multiplied by the system labor rate.

(hrs_comp_report_find_fix_op*rate_op)
Cost applies as written to NTNCWSs.
All
All PWSs with at least one sample > 15 ug/L
Once per event
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-community water system; PO4 = orthophosphate; POU = point-of-use; PWS = public water system; TL = trigger level; WQP = water quality parameter.
Notes:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 pbaseph, pbasepo4, and pbasephpo4: Likelihood system has pH adjustment, orthophosphate, or pH adjustment and orthophosphate for their CCT (Section <IP_ADDRESS>.1).
 pp_lab_samp and pp_commercial_samp: Likelihood that system will use in-house laboratory or commercial laboratory, respectively (Section <IP_ADDRESS>.2).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
2 Systems on 9-year monitoring schedules cannot have any lead or copper in their entire distribution system including all buildings they serve and thus, none should have any samples above 15 ug/L and be subject to find-and-fix requirements.
[3] The burden and costs to provide sample bottles (cost_samp_above_al) under activity e) and conduct analyses under activity f) are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.

System Lead CCT Routine Costs
EPA developed routine costs associated with CCT as shown in Exhibit 5-71. The exhibit provides the unit burden each activity. The assumptions used in the estimation of each activity follows the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-71: PWS CCT Routine Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
   Review CCT guidance
 1 hr/system with CCT serving > 50K/update[1]
hrs_rev_cct_op
   Provide water quality data to Primacy Agency and discuss during sanitary survey
 1.5 to 3 hrs/system with CCT per sanitary survey[2]
hrs_sanit_surv_op
   Notify and consult with Primacy Agency if CCT actions are required in response to source water change
 10 to 22 hrs/system on reduced tap monitoring
 6 to 12 hrs/system on routine tap monitoring
 hrs_coop_source_chng_red_op

 hrs_coop_source_chng_rout_op
   Notify and consult with Primacy Agency if CCT actions are required in response to treatment change
 4 to 82 hrs/system on reduced tap monitoring
 3 to 42 hrs/system on routine tap monitoring
 hrs_coop_treat_chng_red_op

 hrs_coop_treat_chng_rout_op
Acronyms: CCT = corrosion control treatment.
Sources:
[1]Frequency of CCT guidance updates is assumed to be every 5 years.
[2]Sanitary surveys are conducted at least every 5 years for NTNCWSs and every 3 years for CWSs except where ground water CWSs meet special performance criteria and are permitted to conduct sanitary surveys every 5 years (p_spec_req).
l) & m): "Derivation of CCT Study and Review Costs_Final Rule.xlsx."
n): "Derivation of Probability_SourceChange_Final Rule.xlsx."
o): "Derivation of Probability_TreatmentChange_Final Rule.xlsx."

    Review CCT guidance (hrs_rev_cct_op). EPA assumed that Primacy Agencies will review new guidance and determine applicability for systems serving 50,000 or fewer people. However, EPA assumed that systems serving more than 50,000 people will review the new CCT guidance themselves to determine if CCT adjustment is needed and spend 1 hour on this review. EPA assumed a relatively small burden because the revised guidance is expected to include an executive summary that can be used by large systems to quickly assess if new information is applicable to their system. EPA also assumed that the burden for systems to discuss updated guidance with the Primacy Agency is already accounted for in the estimated burden to review CCT during the sanitary survey (hrs_sanit_surv_op). See section m) below.
    Provide water quality data to Primacy Agency and discuss during sanitary survey (hrs_sanit_surv_op). Systems 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. EPA assumed that documents are submitted electronically or provided on-site. EPA assume 0.5  -  2 hours depending on system size for gathering and submitting data to the Primacy Agency, and 1 hour to discuss this information as well as any relevant updated CCT guidance during the sanitary survey, as shown in Exhibit 5-72.
Exhibit 5-72: Estimated PWS Burden to Gather Data and Review CCT-Related Data during Sanitary Survey to Determine if CCT Is Still Optimized
                        System Size (Population Served)
                SafeWater LCR Data Variable: hrs_sanit_surv_op
<=1,000
                                                                            1.5
1,001-10,000
                                                                            2.0
10,001-100,000
                                                                            2.5
>100,000
                                                                            3.0
        Source: "Derivation of CCT Study and Review Costs_Final Rule.xlsx.

   In addition to the unit costs, the SafeWater LCR model requires the frequency of the sanitary survey as an input to calculate total costs for this activity. The required frequency of sanitary surveys is based on system size and water type as follows:
 The minimum frequency for all NTNCWSs is once every 5 years.
 The minimum frequency for surface water CWSs is once every 3 years.
 The minimum frequency for ground water CWSs is 3 years but can be extended to 5 years if systems provide 4-log treatment of viruses (using inactivation, removal, or a Primacy Agency-approved combination of these technologies) before or at the first customer or have an outstanding performance record (e.g., past sanitary surveys with no significant deficiencies).
   To determine the percent of ground water systems that meet the criteria for a minimum frequency of 5 years (p_spec_req), EPA used Exhibit 5-73 from the Economic Analysis for the Final Ground Water Rule (USEPA, 2006a) that provides the estimated percentage of ground water systems meeting the 4-log removal criteria. These may be an underestimation because this approach does not capture systems with outstanding performance that would also qualify for a 5-year sanitary survey frequency.
Exhibit 5-73: Estimated Percent of Ground Water CWSs Achieving 4-log Virus Inactivation
                        System Size (Population Served)
Data from the Economic Analysis for the Final Ground Water Rule (USEPA, 2006a)
            Estimated GW CWSs getting 4-Log In at all Entry Points
                 Percent of GW CWSs getting 4-log (p_spec_req)

                             Total No. of GW CWSs
               Total No. of Entry Points with 4-log Inactivation
                    Average No. of Entry points per system

                                       A
                                       B
                                       C
                                    D = B/C
                                    E = D/A
<=100
                                                                        12,843
                                                                         3,996
                                                                            1.3
                                                                         3,074
                                                                          23.9%
101-500
                                                                        14,358
                                                                         8,873
                                                                            1.6
                                                                         5,546
                                                                          38.6%
501-1,000
                                                                         4,649
                                                                         3,547
                                                                              2
                                                                         1,774
                                                                          38.2%
1,001-3,300
                                                                         5,910
                                                                         5,378
                                                                            2.4
                                                                         2,241
                                                                          37.9%
3,301-10,000
                                                                         2,884
                                                                         3,547
                                                                            3.2
                                                                         1,108
                                                                          38.4%
10,001-50,000
                                                                         1,445
                                                                         3,856
                                                                            5.6
                                                                           689
                                                                          47.7%
50,001-100,000
                                                                           168
                                                                           583
                                                                           11.3
                                                                            52
                                                                          31.0%
100,001-1,000,000
                                                                           103
                                                                           545
                                                                           12.4
                                                                            44
                                                                          42.7%
> 1,000,000
                                                                             3
                                                                             34
                                                                           11.4
                                                                             3
                                                                         100.0%
Total
                                                     42,363
                                                                        30,359

                                                                        14,531
                                                                          34.3%
Acronyms: CWS = community water system; GW = ground water.
Source: "Derivation of CCT Study and Review Costs_Final Rule.xlsx."
Notes:
A: Economic Analysis for the Final Ground Water Rule, Exhibit 4.2, Columns F plus K (USEPA, 2006a).
B: Economic Analysis for the Final Ground Water Rule, Exhibit 4.3, Column H (USEPA, 2006a).
C: Economic Analysis for the Final Ground Water Rule, Exhibit 4.3, Column A (USEPA, 2006a).
D: Assumed that systems that provide 4-log inactivation do so at all entry points in their system, and these systems have the same number of entry points as other systems.

    Notify and Consult with Primacy Agency on Required Actions in Response to Source Water Change (hrs_coop_source_chng_red_op, hrs_coop_source_chng_rout_op). Systems are required to seek prior approval before making any source water changes and to consult with the Primacy Agency on needed responses including the possibility of CCT installation. The likelihood of a system changing source (p_source_chng) is discussed in Section <IP_ADDRESS> with estimated percentages for CWSs and NTNCWSs presented in Exhibit 4-46 and Exhibit 4-47, respectively. Exhibit 5-74 below provides the estimated system burden to report the source change and consult with the Primacy Agency for systems on reduced and routine tap monitoring. Note that EPA estimated fewer hours for consultation for systems on routine monitoring because they are in more frequent contact with the Primacy Agency compared to those on reduced monitoring.
Exhibit 5-74: Estimated Hours per System to Report and Consult on Source Water Change
       Hrs for systems on reduced monitoring to report a source change
                         (hrs_coop_source_chng_red_op)
        Hrs for systems on routine monitoring to report a source change
                        (hrs_coop_source_chng_rout_op)
                                       A
                                       B
                                    Minimum
                                    Maximum
                                  Most Likely
                                    Minimum
                                    Maximum
                                  Most Likely
                                      10
                                      22
                                      10
                                       6
                                      12
                                       6
Source: "Derivation of Probability_SourceChange_Final Rule.xlsx."
Notes: