A: Applies to systems that are conducting reduced lead tap monitoring less frequently than every 6 months. The estimates are based on input received from North Carolina and Indiana in response to a 2016 ASDWA questionnaire regarding potential LCRR requirements. A copy of the questionnaire and each state's responses are available in the docket under EPA-HQ-OW-2017-0300 at www.regulations.gov. North Carolina estimated 2 hours to review a change in source from ground water to another ground water source and 3 hours for surface water source changes or surface water/ground water mixing. Indiana estimated 6 hours to review a change to a similar source and 20 hours to review a change to a dissimilar source. EPA used the average of the two state estimates of 2 and 6 hours (4 hours), doubled to 8 hours for systems, for the minimum and most likely value. EPA set the most likely equal to the minimum because fewer than 1 percent of systems made more significant sources changes during 2013 - 2016. For the maximum, EPA assumed the 20 hours were more reflective of the system burden to prepare needed documentation. To each estimate, EPA assumed an additional 2 hours for consultation with the Primacy Agency on needed action in response to the source change.
B: Applies to systems conducting routine lead tap monitoring every six months under the LCRR. Because these systems are in more frequent contact with the Primacy Agency, EPA assumed 50 percent of the burden estimated to prepare and submit the documentation for hrs_coop_source_chng_red_op or 50 percent of 8 hours for the minimum and most likely and 50 percent of 20 hours for the maximum plus an additional 2 hours for consultation. This equals a total burden of 6 hours for the minimum and most likely and 12 hours for the maximum.

    Notify and Consult with Primacy Agency on Required Actions in Response to Treatment Change (hrs_coop_treat_chng_red_op, hrs_coop_treat_chng_rout_op). Systems are required to seek prior approval before making any long-term treatment changes and to consult with the Primacy Agency on needed responses including the possibility of CCT installation. The likelihood of a system changing treatment (p_treat_chng) is discussed in Section <IP_ADDRESS> with estimated percentages for CWSs and NTNCWSs presented in Exhibit 4-48 and Exhibit 4-49, respectively. Exhibit 5-75 below provides the estimated system burden for this review and consultation for systems on reduced and routine monitoring. Consistent with activity n) above, EPA estimates fewer hours for systems on routine monitoring as opposed to those on reduced monitoring because they are in contact with their Primacy Agency more frequently.
Exhibit 5-75: Estimated Hours per System to Report and Consult on Treatment Change
                                 System Size
                              (Population Served)
Hrs for systems on reduced monitoring to report a treatment change (hrs_coop_treat_chng_red_op)
Hrs for systems on routine monitoring to report a treatment change (hrs_coop_treat_chng_rout_op)

                                       A
                                       B
<=100
                                                                              4
                                                                              3
101-500
                                                                              8
                                                                              5
501-1,000
                                                                             12
                                                                              7
1,001-3,300
                                                                             22
                                                                             12
3,301-50,000
                                                                             42
                                                                             22
>50,000
                                                                             82
                                                                             42
Source: "Derivation of Probability_TreatmentChange_Final Rule.xlsx."
Notes:
A: Applies to systems that are conducting reduced lead tap monitoring less frequently than every six months. The estimates are based on input received from North Carolina in response to a 2016 ASDWA questionnaire regarding potential LCRR requirements. A copy of the questionnaire and each state's responses are available in the docket under EPA-HQ-OW-2017-0300 at www.regulations.gov. North Carolina estimated 1-2 hours for small systems and 80 hours for systems serving more than 50,000 people to review a change in treatment. EPA assumed the same hours for systems to report on the change in treatment and assumed an incremental increase from 2 hours at the smallest system size up to 80 hours for systems serving more than 50,000 people. EPA assumed an additional 2 hours for consultation with the Primacy Agency to discuss required actions in response to the treatment change. Indiana also responded to the questionnaire and provided an estimated burden of 6 to 10 hours but did not provide detail on system size.
B: Applies to systems conducting routine lead tap monitoring every six months under the LCRR. Because these systems are in more frequent contact with the Primacy Agency, EPA assumed 50 percent of the burden estimated to prepare and submit documentation for hrs_coop_treat_chng_red_op and an additional 2 hours for consultation.

Exhibit 5-76 details how the data variables are used to estimate routine system activities related to CCT.
Exhibit 5-76: PWS Lead CCT Routine 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

    Review CCT guidance
Hours per system multiplied by the system labor rate.

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

Model PWSs with CCT serving >50,000 people

Once per Sanitary Survey[2]
    Provide water quality data to Primacy Agency and discuss during sanitary survey[2]
Hours per system multiplied by the system labor rate.
(hrs_sanit_surv_op * rate_op)
Cost applies as written to NTNCWSs.
All
Model PWSs with CCT
Once per Sanitary Survey[2]
    Notify and consult with Primacy Agency on response to a change in source water
The total hours per system multiplied by the system labor rate.

(hrs_coop_source_chng_rout_op*rate_op)
Cost applies as written to NTNCWSs.
At or below TL
Model PWS that is not on reduced tap sampling with a change in source water

1 - (p_tap_annual + p_tap_triennial + p_tap_nine) * p_source_chng
Once per event

Above TL
Model PWSs with a change in source water
p_source_chng

The total hours per system multiplied by the system labor rate.

(hrs_coop_source_chng_red_op*rate_op)

At or below TL
Model PWS that is on reduced tap sampling with a change in source water
(p_tap_annual + p_tap_triennial + p_tap_nine) * p_source_chng

    Notify and consult with Primacy Agency on response to a change in water treatment
The total hours per system multiplied by the system labor rate.

(hrs_coop_treat_chng_rout_op*rate_op)
Cost applies as written to NTNCWSs.
At or below TL
Model PWS that is not on reduced tap sampling with a change in treatment

1 - (p_tap_annual + p_tap_triennial + p_tap_nine) * p_treat_change
Once per Event

Above TL
Model PWSs with a change in treatment

p_treat_change

The total hours per system multiplied by the system labor rate.

(hrs_coop_treat_chng_red_op*rate_op)

At or below TL
Model PWS that is on reduced tap sampling with a change in treatment

(p_tap_annual + p_tap_triennial + p_tap_nine) * p_treat_change

Acronyms: CCT = corrosion control treatment; CWS = community water system; 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:
 p_tap_annual, p_tap_triennial, and p_tap_nine: Likelihood a system will qualify to collect the reduced number of lead tap samples at an annual, triennial, and nine-year frequency, respectively (Section <IP_ADDRESS>).
 p_source_chng: Likelihood that a system will change sources in a given year (Section <IP_ADDRESS>).
 p_treat_chng: Likelihood that a system will change treatment in a given year (Section <IP_ADDRESS>).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
Estimate of PWS National Corrosion Control Treatment Costs
Exhibit 5-77 and Exhibit 5-78 show the estimated national costs of CCT under the low and high cost scenarios, for the previous LCR, the LCRR, and the incremental cost, discounted at 3 and 7 percent, respectively. The CCT Operation and Maintenance (Existing) category in these exhibits are EPA's estimate of the ongoing cost of operating corrosion control at PWSs where CCT was in place at the beginning of the period of analysis. Also, note that incremental CCT cost are negative due to the LCRR compliance flexibilities for CWSs serving 10,000 or fewer people and all NTNCWSs. EPA predicts, based on the modeling assumption that systems will select the least costly compliance alternative, that some systems are selecting to conduct LSLR and POU in place of the more costly adjustment to CCT.

Exhibit 5-77: National Annualized Corrosion Control Technology 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
 CCT Operations and Maintenance (Existing)
                                                                   $327,171,000
                                                                   $327,171,000
                                                                             $0
                                                                   $327,490,000
                                                                   $327,490,000
                                                                             $0
 CCT Related Sanitary Survey and Source or Treatment Change Notification Activities
                                                                     $1,356,000
                                                                     $1,735,000
                                                                       $379,000
                                                                     $1,355,000
                                                                     $1,719,000
                                                                       $363,000
 CCT Installation
                                                                    $13,424,000
                                                                     $7,138,000
                                                                    $-6,286,000
                                                                    $41,261,000
                                                                    $19,392,000
                                                                   $-21,869,000
 CCT Installation Ancillary Activities
                                                                        $43,000
                                                                       $122,000
                                                                        $80,000
                                                                       $119,000
                                                                       $754,000
                                                                       $635,000
 CCT Re-Optimization (Due to ALE)
                                                                     $2,479,000
                                                                     $6,575,000
                                                                     $4,096,000
                                                                    $15,374,000
                                                                    $33,425,000
                                                                    $18,051,000
 CCT Re-Optimization Ancillary Activities (Due to ALE)
                                                                        $11,000
                                                                     $1,449,000
                                                                     $1,438,000
                                                                        $81,000
                                                                    $27,261,000
                                                                    $27,180,000
 CCT Re-Optimization (Due to TLE)
                                                                             $0
                                                                     $5,452,000
                                                                     $5,452,000
                                                                             $0
                                                                    $20,724,000
                                                                    $20,724,000
 CCT Re-Optimization Ancillary Activities (Due to TLE)
                                                                             $0
                                                                        $98,000
                                                                        $98,000
                                                                             $0
                                                                       $444,000
                                                                       $444,000
 Find-and-Fix Installation
                                                                             $0
                                                                     $8,271,000
                                                                     $8,271,000
                                                                             $0
                                                                    $31,688,000
                                                                    $31,688,000
 Find-and-Fix Ancillary Activities
                                                                             $0
                                                                     $5,884,000
                                                                     $5,884,000
                                                                             $0
                                                                     $8,190,000
                                                                     $8,190,000
 Total Annual Corrosion Control Technology Costs
                                                                   $344,483,000
                                                                   $363,894,000
                                                                    $19,412,000
                                                                   $385,681,000
                                                                   $471,087,000
                                                                    $85,407,000
 Note: Detail may not add exactly to total due to independent rounding.

Exhibit 5-78: National Annualized Corrosion Control Technology 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
 CCT Operations and Maintenance (Existing)
                                                                   $306,521,000
                                                                   $306,521,000
                                                                             $0
                                                                   $306,822,000
                                                                   $306,822,000
                                                                             $0
 CCT Related Sanitary Survey and Source or Treatment Change Notification Activities
                                                                     $1,293,000
                                                                     $1,662,000
                                                                       $368,000
                                                                     $1,293,000
                                                                     $1,641,000
                                                                       $348,000
 CCT Installation
                                                                    $12,499,000
                                                                     $6,623,000
                                                                    $-5,876,000
                                                                    $40,703,000
                                                                    $18,919,000
                                                                   $-21,783,000
 CCT Installation Ancillary Activities
                                                                        $57,000
                                                                       $168,000
                                                                       $111,000
                                                                       $160,000
                                                                     $1,034,000
                                                                       $875,000
 CCT Re-Optimization (Due to ALE)
                                                                     $2,299,000
                                                                     $5,664,000
                                                                     $3,365,000
                                                                    $15,724,000
                                                                    $33,041,000
                                                                    $17,317,000
 CCT Re-Optimization Ancillary Activities (Due to ALE)
                                                                        $15,000
                                                                     $1,913,000
                                                                     $1,898,000
                                                                       $107,000
                                                                    $35,996,000
                                                                    $35,888,000
 CCT Re-Optimization (Due to TLE)
                                                                             $0
                                                                     $4,784,000
                                                                     $4,784,000
                                                                             $0
                                                                    $20,888,000
                                                                    $20,888,000
 CCT Re-Optimization Ancillary Activities (Due to TLE)
                                                                             $0
                                                                       $140,000
                                                                       $140,000
                                                                             $0
                                                                       $633,000
                                                                       $633,000
 Find-and-Fix Installation
                                                                             $0
                                                                     $6,986,000
                                                                     $6,986,000
                                                                             $0
                                                                    $29,911,000
                                                                    $29,911,000
 Find-and-Fix Ancillary Activities
                                                                             $0
                                                                     $5,848,000
                                                                     $5,848,000
                                                                             $0
                                                                     $8,668,000
                                                                     $8,668,000
 Total Annual Corrosion Control Technology Costs
                                                                   $322,684,000
                                                                   $340,307,000
                                                                    $17,623,000
                                                                   $364,809,000
                                                                   $457,554,000
                                                                    $92,745,000
 Note: Detail may not add exactly to total due to independent rounding.

PWS Lead Service Line Inventory and Replacement Costs
The LCRR requires all systems to develop a service line inventory and, for those systems with LSLs, to develop a replacement plan and undertake certain outreach activities to educate consumers about lead and LSLR opportunities. Physical replacement of LSLs is required based on the systems' lead 90[th] percentile range as follows:
 Goal-Based program: CWSs serving more than 10,000 people that have a TLE must implement a goal-based LSLR program in which they replace LSLs at a rate approved by the Primacy Agency. Systems must continue replacing LSLs until they no longer exceed the TL for two consecutive annual periods of tap sampling.
 Mandatory program: CWSs serving more than 10,000 that have a lead ALE must fully replace LSLs on a rolling 2 year average of 3% per year using a baseline number of LSLs equal to the number of LSLs and galvanized requiring replacement service lines at the time the system first exceeds the lead trigger or action level plus the number of unknowns at the beginning of each year of the system's LSLR program. The mandatory program also requires that a cumulative number of replacements be reached equal to 3% of the sum of known lead, galvanized requiring replacement, and lead status unknown service lines in the initial inventory, times the number of years that elapsed between the system's first ALE and the date on which the system's 90[th] percentile lead levels are at or below the action level for two years (four consecutive 6-month monitoring periods). CWSs serving 10,000 or fewer people and NTNCWSs with LSLR as their approved compliance option must replace LSLs at a schedule set by the Primacy Agency not to exceed 15 years and must replace all LSLs regardless of their subsequent lead 90[th] percentile value. As noted previously, the LCRR provides small system flexibility by allowing CWSs serving 10,000 or fewer people and NTNCWSs to choose among four compliance options if they exceed the AL: 1) Replace all LSLs, 2) install POU treatment, 3) install/re-optimize CCT, or 4) replace all lead-bearing plumbing material. For modeling purposes, EPA assigns a compliance cost to all systems that exceed the ALE in the SafeWater LCR model. EPA uses a cost minimization assumption in the model, and assigns the least cost alternative between the LSLR, CCT, and POU compliance alternatives. EPA lacks the system characteristic data that would allow the Agency to determine a small system's cost for replacement of lead-bearing plumbing materials because of the significant variability among systems and the plumbing materials in the buildings they serve. EPA assumed a system would only select the replacement of lead-bearing plumbing materials compliance option if it cost less than the three other alternative compliance options. By selecting the least cost of the three other options EPA has accounted for the costs that small water systems would incur but may be overestimating the costs for those systems that find the cost of lead-bearing plumbing replacement to be less than the other three options.
 Customer-initiated program: All PWSs are required to replace the system-owned portion of an LSL if they become aware that a customer has replace their portion of the line. In the cost model, PWSs not performing goal-based or mandatory LSLR must still replace their portion of an LSL if a customer notifies them or, through the normal course of business, the system becomes aware that he/she is replacing his/her side. EPA estimated the likelihood of these replacements to be 0.05 percent of LSLs per year (p_cust_init_lslr) based on a 2020 report titled Lead Pipes and Environmental Justice: A Study of Lead Pipe Replacement in Washington, DC (Environmental Defense Fund and American University School of Public Affairs, 2020). The report includes a graph (Figure 7) showing the number of customer-initiated LSLRs each year from 2009 to 2018. The rate was approximately 25 LSLs per year (out of approximately 48,000 LSLs in DC Water's system) from 2009 through 2013. The rate jumped in 2014 to nearly 200 replacements per year, likely because of a new incentive for home renovators to participate in the program before applying for a permit. The number jumped again in 2017 to more than 300 replacements after the highly publicized elevated lead issues in Flint, Michigan and DC Water launched a new online interactive online map which made it easier for customers to see which properties had LSLs. EPA used the customer-initiated replacement rate from 2009 to 2013 (25 / 48,000 = 0.05 percent) to represent a typical system, although EPA recognizes that this value may be high for some systems because of the highly publicized case of elevated lead in Washington, D.C.'s water in 2004.
Under all programs, an LSL is counted toward a system's replacement rate if the entire LSL is replaced. This includes replacement of both the system-and customer- side of the LSL or removing the remaining portion of the LSL (assumed to be the customer's portion).
Costs for system LSLR-related activities are grouped into four subsections:
 <IP_ADDRESS>: Lead Service Line Inventory-Related Activities
 <IP_ADDRESS>: Lead Service Line Replacements
 <IP_ADDRESS>: Ancillary Lead Service Line Replacement Activities
 <IP_ADDRESS>: Failure to Meet Goal-based Replacement Rate Activities.
National annualized LSLR-related costs are presented at 3 percent and 7 percent discount rates in Section <IP_ADDRESS>.
A key input for LSLR-related costs is the baseline LSL inventory. For CWSs, EPA used results from two surveys to develop low and high estimates of 1) the percent of systems with LSLs (p_lsl) as shown in Exhibit 4-11 and Exhibit 4-14, and 2) the percent of service connections in LSL systems that are made of lead (perc_lsl) as shown in Exhibit 4-10 and Exhibit 4-13. See Section <IP_ADDRESS> for detailed assumptions and methodology. Note that where available, EPA used system-specific information on number of LSLs for PWSs serving greater than 1 million people. For NTNCWSs, EPA assumed that 2.5 percent have LSLs based on results from a 2017 EPA questionnaire. Exhibit 4-17 shows EPA's estimate of the percent of service connections in NTNCWSs that are lead. See Section <IP_ADDRESS> for additional detail.
Lead Service Line Inventory-Related Activities
EPA has developed system costs for activities associated with the LSL inventory as shown in Exhibit 5-79. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of the unit burden and cost following the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-79: PWS LSL Inventory-Related Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
 Create initial LSL inventory and submit to Primacy Agency (one-time)
20 to 400 hrs/CWS; 7 to 28 hrs/NTNCWS
hrs_inventory_op
Submit documentation of no LSLs to Primacy Agency (one-time)
10 to 40 hrs/CWS; 5 to 20 hrs/NTNCWS
hrs_nolsl_op
Develop general LSL outreach materials and submit to Primacy Agency for review (one-time)
3.5 hrs/PWS serving <= 50,000 people
20 hrs/PWS serving > 50,000 people
hrs_pe_lsl_gen_develop_op

Distribute general LSL outreach materials
CWSs
0.0026 to 0.4553 hrs/household;
$0.23 to $0.33/household

NTNCWSs
1 hr/system
$0.025/system
CWSs
hrs_pe_lsl_gen_dist_op
cost_pe_lsl_gen

NTNCWSs
hrs_ntncws_pe_lsl_gen_dist_op
cost_ntncws_pe_lsl_gen
Submit annual or triennial LSL inventory update to Primacy Agency
1 hour
hrs_report_inv_op
Acronyms: CWS = community water system; LSL = lead service lines; NTNCWS = non-transient non-community water system.
Sources: Data sources for each activity are provided following this exhibit.

    Create initial LSL Inventory and submit to Primacy Agency (hrs_inventory_op). As discussed in Chapter 3, Section <IP_ADDRESS>, all systems must complete an inventory of their service lines within the first three years after final rule promulgation. Systems will incur one-time burden to develop their initial LSL inventory that meets the requirements of the LCRR). EPA used information from two states and one system to inform the estimate, as presented in Exhibit 5-80.
Exhibit 5-80: One-Time Burden to Create LSL Inventory (hrs/system)
                                  System size
                              (Population Served)
                                     CWSs
                                    NTNCWSs

                               hrs_inventory_op

                                       A
                                       B
<=1,000
                                                                            20
                                                                             7
1,001-3,300
                                                                            40
                                                                             7
3,301-10,000
                                                                            80
                                                                            12
10,001-50,000
                                                                           100
                                                                            12
50,001-100,000
                                                                           200
                                                                            28
100,001-1,000,000
                                                                           300
                                                                            28
>1,000,000
                                                                           400

Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."
Notes:
A: For CWSs, EPA used the LSL inventory burden estimates provided by Indiana, Ohio, and Green Bay Water Utility to calculate the relationship of inventory burden per population served. EPA used these hours to inform the estimated burden, assuming increasing hours with increasing system size.
B: For NTNCWSs, EPA assumed systems should have the necessary documentation onsite to determine if a service line is lead or not because NTNCWSs own their own service lines. EPA assumed systems would incur the same burden to demonstrate the presence or absence of LSLs (see activity b) below) but those with LSLs would incur additional burden to develop a tracking system. Note that no NTNCWS serves more than 1 million people.

EPA also estimated the likelihood that systems with LSLs have already prepared their initial inventory and submitted it to their Primacy Agency (p_inventory) and would incur no burden for this activity under the LCRR. To estimate the likelihood that systems with LSLs have already prepared and submitted their inventory (p_inventory), EPA conducted the following steps separately for CWSs and NTNCWSs:

         Step 1: Estimated the percent and number of systems with LSLs using information from Section <IP_ADDRESS> for CWSs and Section <IP_ADDRESS> for NTNCWS. For CWSs, used an average of the low and high estimates.
         Step 2: Reviewed state programs to determine how many states already require systems to submit LSL inventory information that meets the requirements of the final rule. As of 2019, Illinois, Michigan, and Wisconsin required systems to complete LSL inventories that include the identification of galvanized service lines. In addition, Washington, D.C. has been active for a number of years in identifying its LSL inventory. Thus, EPA also assumed Washington, D.C. would complete its inventory in advance of the rule.
         Step 3: Estimated the number of systems with LSLs in these states that completed their inventory by multiplying the number of systems in each state and Washington, D.C. based on SDWIS/Fed 2016 data by the estimated percent of systems with LSLs as presented in Section 4.3.4.
         Step 4: For the remaining systems with LSLs in other states, assume that 5 percent voluntarily submitted information to their Primacy Agency that meets the LCRR requirements.
         Step 5: Added the number of systems in Steps 3 and 4 to determine the total number of systems with LSLs that completed their inventory that would meet the LCRR inventory requirements.
         Step 6: Divided the number of systems in Step 5 by the total number of systems with LSLs to produce a likelihood that systems with LSLs would submit their inventory in advance of the rule (p_inventory) and not incur burden to develop an inventory under the LCRR.
    See Exhibit 5-81 for results of this analysis.
Exhibit 5-81: Estimated Likelihood that Systems with LSLs Completed Their Inventory In Advance of the Rule (p_inventory)
                                  System Size
                              (Population Served)
                                     CWSs
                                    NTNCWSs

                                       A
                                       B
<=100
                                                                          11.3%
                                                                           5.0%
101-500
                                                                          11.8%
                                                                           5.0%
501-1,000
                                                                          14.9%
                                                                           5.1%
1,001-3,300
                                                                          14.5%
                                                                           5.0%
3,301-10,000
                                                                          14.2%
                                                                           5.0%
10,001-50,000
                                                                          15.6%
                                                                           5.0%
50,001-100,000
                                                                          13.8%
                                                                           5.0%
100,001-1,000,000
                                                                           9.9%
                                                                           5.0%
>1,000,000
                                                                           9.5%

Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."
Notes:
A,B: Based on review of states with LSL inventory requirements and assumption that 5 percent of LSL systems in other states without requirements will have completed their inventories in advance of the LCRR.

    Submit Documentation of No LSLs to Primacy Agency (hrs_nolsl_op). PWSs without LSLs will incur burden to develop and submit documentation to the Primacy Agency that none of their service lines are lead. CWSs without LSLs will incur additional burden to submit a request to omit LSL-specific information in their consumer confidence report (CCR) (note that the burden to update the CCR language itself is included with public education costs in Section <IP_ADDRESS>, activity c)). The estimated burdens for CWSs and NTNCWSs are provided in Exhibit 5-82.
Exhibit 5-82: One-Time Burden to Submit Documentation of No LSLs and Request to Omit LSL-Specific Information in the CCR (hrs/system)
                                  System size
                              (Population Served)
                                     CWSs
                                    NTNCWSs

                                 hrs_nolsl_op

                                       A
                                       B
<=3,300
                                                                             10
                                                                              5
3,301-50,000
                                                                             20
                                                                             10
>50,000
                                                                             40
                                                                             20
Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."
Notes:
A,B: EPA assumed systems that have no LSLs already have documentation but will require time to gather the information and prepare a package for their Primacy Agency. Larger systems will require more documentation and thus have a higher corresponding burden. NTNCWSs will spend less time providing supporting documentation because they own the entirety of their service line and should have available records on-site, as well as have fewer service lines than CWSs.

EPA assumed that some systems without LSLs completed their inventory and submitted documentation to their Primacy Agency in advance of the rule and will not incur any burden for this activity under the LCRR. To estimate the likelihood that systems without LSLs have already prepared and submitted their inventory (p_inventory) for the subset of systems without LSLs, EPA followed a similar approach as described in activity (a) as follows:
         Step 1: Estimated the percent and number of systems without LSLs using information from Sections <IP_ADDRESS> for CWSs and Section <IP_ADDRESS> for NTNCWSs. For CWSs used an average of the low and high estimates.
         Step 2: Multiplied the number of systems in Illinois, Michigan, and Wisconsin and the District of Columbia by the percentages of systems without LSLs in Step 1.
         Step 3: Estimated the number of systems in states/territories with no LSLs (American Samoa, Guam, Hawaii, and Nevada) using SDWIS/Fed 2016 data.
         Step 4: Added the results of Steps 2 and 3 to estimate the total number of systems without LSLs that would have either met the inventory requirements or are located in states/territories without LSLs. For the remaining systems without LSLs, assume that 5 percent voluntarily submitted information to their Primacy Agency that meets the LCRR requirements.
         Step 5: Divided the number of systems without LSLs from Step 4 by the total number of systems without LSLs to produce a likelihood that systems without LSLs would submit their inventory in advance of the rule (p_inventory) and not incur burden to develop an inventory under the LCRR. See Exhibit 5-83 for results of this analysis.
Exhibit 5-83: Estimated Likelihood that Systems without LSLs Completed Their Inventory In Advance of the Rule (p_inventory)
                                  System size
                              (Population Served)
                                     CWSs
                                    NTNCWSs

                                       A
                                       B
<=100
                                                                          12.1%
                                                                           5.6%
101-500
                                                                          12.5%
                                                                           5.9%
501-1,000
                                                                          15.8%
                                                                           5.7%
1,001-3,300
                                                                          15.3%
                                                                           6.8%
3,301-10,000
                                                                          15.5%
                                                                          13.6%
10,001-50,000
                                                                          16.6%
                                                                           5.0%
50,001-100,000
                                                                          15.5%
                                                                           5.0%
100,001-1,000,000
                                                                          13.0%
                                                                           5.0%
>1,000,000
                                                                          20.9%

Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system.
Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."
Notes:
A,B: Based on analysis of CWSs and NTNCWSs in states that already require systems to submit an LSL inventory and states and territories that have no LSLs. Assumed 5 percent of remaining systems without LSLs voluntarily submitted inventory information that met the requirements of the LCRR.
B: No NTNCWS serves more than 1 million people.

    Develop general LSL outreach materials and submit to Primacy Agency for review (hrs_pe_lsl_gen_develop_op). Systems with LSLs must provide notification to customers with LSLs, galvanized requiring replacement, or that are served by lines of unknown material, with information on the health effects and sources of lead in drinking water (including LSLs), how to have water tested for lead, actions customers can take to reduce exposure to lead, and information about the opportunities for LSLR. Systems will incur a one-time burden to develop these materials and submit them to the Primacy Agency. EPA assumed systems serving 50,000 or fewer people will require 3.5 hours to prepare and submit these materials and those serving more than 50,000 people will require 20 hours. Burden estimates for systems serving 50,000 or fewer people are based on tier 2 PN preparation burden (3.5 hours), and burden estimates for systems serving more than 50,000 people are based on tier 1 PN preparation burden for systems serving more than 10,000 people (30 hours) from the Public Water System Supervision Program Information Collection Request (ICR) (Renewal) (USEPA, 2015a). EPA assumed that all PWSs use an EPA-developed template. Those serving 50,000 or fewer people would not modify the content. However, systems serving more than 50,000 people would adapt the template for their use but would require 20 hours as opposed to the 30-hour estimate for Tier 1 PN.
    Distribute general LSL outreach materials (hrs_pe_lsl_gen_dist_op, cost_pe_lsl_gen, hrs_ntncws_pe_lsl_gen_dist_op, cost_ntncws_pe_lsl_gen). Systems with LSLs are required to distribute the general LSL outreach materials annually to customers served by an LSL or service line of unknown material. Exhibit 5-84 and Exhibit 5-85 provide the estimated burden and costs, respectively, for this activity per household for CWSs. A discussion of the burden and costs for NTNCWSs follow these exhibits.
Exhibit 5-84: Annual Burden (per household) to Distribute General LSL Notification
                        System Size (Population Served)
                         Separate mailing (hrs per CWS)
                           Bill Stuffer (hrs per CWS)
                                Average per CWS
                            Number of HH per system
                                   (numb_hh)
                                   Separate/
                           Bill Stuffer (hrs per HH)
                            Production (hrs per HH)
                               Total (hrs per HH)
                            (hrs_pe_lsl_gen_dist_op)

                                       A
                                       B
                                      C =
                                    (A+B)/2
                                       D
                                    E = C/D
                                       F
                                     G =E+F
 <=100
                                                                             15
                                                                              6
                                                                           10.5
                                                                             23
                                                                         0.4528
                                                                         0.0025
                                                                         0.4553
 101-500
                                                                             15
                                                                              6
                                                                           10.5
                                                                             98
                                                                         0.1072
                                                                         0.0025
                                                                         0.1097
 501-1,000
                                                                             25
                                                                             10
                                                                           17.5
                                                                            285
                                                                         0.0613
                                                                         0.0025
                                                                         0.0638
 1,001-3,300
                                                                             25
                                                                             10
                                                                           17.5
                                                                            736
                                                                         0.0238
                                                                         0.0025
                                                                         0.0263
 3,301-10,000
                                                                            120
                                                                             30
                                                                             75
                                                                          2,257
                                                                         0.0332
                                                                         0.0025
                                                                         0.0357
 10,001-50,000
                                                                            120
                                                                             30
                                                                             75
                                                                          8,446
                                                                         0.0089
                                                                         0.0025
                                                                         0.0114
 50,001-100,000
                                                                            120
                                                                             30
                                                                             75
                                                                         26,770
                                                                         0.0028
                                                                         0.0025
                                                                         0.0053
 100,001-1,000,000
                                                                            120
                                                                             30
                                                                             75
                                                                         93,467
                                                                         0.0008
                                                                         0.0025
                                                                         0.0033
 >1,000,000
                                                                            120
                                                                             30
                                                                             75
                                                                        772,999
                                                                         0.0001
                                                                         0.0025
                                                                         0.0026
Acronyms: CWS = community water system; HH = household.
Source: "Derivation of Public Education Inputs_CWS_Final Rule.xlsx."
Notes:
A: EPA assumption regarding the burden per system to conduct separate mailings.
B: EPA assumption regarding the burden per system to mail materials with the water bill.
C: EPA assumed that half of systems will conduct separate mailings and the other half will include targeted outreach materials with the water bill.
D: See Exhibit 5-123. Estimated as 2.59 people per household (numb_hh) for the year 2010 (United States Census Bureau, 2010). Table AVG1. Average Number of People Per Household, By Race and Hispanic Origin, Marital Status, Age, And Education Of Householder. Available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
F: EPA assumed 0.25 hours per 100 brochures for production. Estimate is based on assumptions for production labor used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (Exhibit 17) (USEPA, 2007).
Exhibit 5-85: Annual Cost (per household) to Distribute General LSL Notification
                        System Size (Population Served)
                          Cost per HH If In Water Bill
                        Cost per HH If Mailed Separately
                                Average ($/HH)
                               (cost_pe_lsl_gen)

                                       A
                                       B
                                 C = (A + B)/2
 <= 500
                                                                          $0.05
                                                                          $0.61
                                                                          $0.33
 > 500
                                                                          $0.05
                                                                          $0.42
                                                                          $0.23
Source: "Derivation of Public Education Inputs_CWS_Final Rule.xlsx."
Notes:
A: Estimate includes cost for cover letter (paper cost of $0.025) and brochure (paper cost of $0.025). See "General Cost Model Inputs_Final Rule.xlsx" for additional information about costs for paper EPA assumed that the weight of the cover letter and brochure would not result in additional postage being needed to mail the water bill.
B: Estimate includes cost for cover letter (paper cost of $0.025), brochure (paper cost of $0.025), envelope ($0.067), and postage ($0.49). EPA assumed that systems serving > 500 people will use the bulk rate for postage ($0.301). See "General Cost Model Inputs_Final Rule.xlsx" for additional information about costs for paper, envelopes, and postage.
C: EPA assumed that 50 percent of systems will mail published materials separately and 50 percent will include materials with the water bill.

NTNCWSs are assumed to provide information on the LSLR program via e-mail and public posting. EPA assumed a burden of 0.5 hour to develop/send e-mail for all system size categories and an additional 0.5 hours to post the notification publicly for a total of 1 hour (hrs_ntncws_pe_lsl_gen_dist_op). EPA also assumed that NTNCWSs will provide electronic notification and post a notification publicly when LSLR is taking place. Material costs are for paper only of $0.025 (cost_ntncws_pe_lsl_gen). See file, "General Cost Model Inputs_Final Rule.xlsx" for more detail.
In addition to the unit burden and cost estimates, EPA estimated the number of households to which outreach materials are distributed (those served by LSLs or those with unknown material) to calculate the total costs for this activity. The baseline percent of service lines that are lead (perc_lsl) for the low and high cost estimates for CWSs are shown in Exhibit 4-10, Exhibit 4-13, and Section <IP_ADDRESS>. The SafeWater LCR model tracks changes in the number of LSLs per system (and the number of households served by LSLs) over the 35-year rule period of analysis period with the data variable hh_remain_lsl. To account for the service lines of unknown material, EPA increases the baseline LSL count for each system by 28 percent using the data variable (pp_lslr_paper). Note that inventory does not include service lines that are galvanized requiring replacement and the model does not capture outreach to households served by these service lines that will result in an underestimation of cost.
    Submit annual or triennial LSL inventory update to Primacy Agency (hrs_report_inv_op). Systems with LSLs must report updated inventory information within 30 days of the end of each tap sampling monitoring period or annually for those on semi-annual monitoring. EPA assumed systems will require 1 hour to report this update electronically to the Primacy Agency. EPA assumed a relatively small burden because the time to maintain and update the LSL inventory information is accounted for under the LCRR requirement that system make their LSL information publicly available (hrs_access_lsl_op and hrs_maint_lsl_op; see Section <IP_ADDRESS>, activities f) and g)). Also, those systems subject to the goal-based or mandatory LSLR programs must provide a separate detailed annual report to their Primacy Agency (hrs_report_lcr_op; see activity r) in Section <IP_ADDRESS> below).
Exhibit 5-86 provides the SafeWater LCR model costing approach for these activities including additional cost inputs that are required to calculate the total costs.
Exhibit 5-86: Lead Service Line Inventory 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

    Create initial LSL inventory and submit to Primacy Agency
The total system hours multiplied by the system labor rate.

(hrs_inventory_op*rate_op)
Cost applies as written to NTNCWSs.
All
Model PWS with LSLs

p_lsl
1-p_inventory
One time
    Submit documentation of no LSLs to Primacy Agency
Likelihood that system has not developed an inventory in advance of the rule times hours per system multiplied by the system labor rate.

(hrs_nolsl_op*rate_op)
Cost applies as written to NTNCWSs.
All
Model PWSs without LSLs

1-p_lsl
1-p_inventory
One time
    Develop general LSL outreach materials and submit to Primacy Agency for review
The total hours per system multiplied by the system labor rate.

(hrs_pe_lsl_gen_develop_op*rate_op)
Cost applies as written to NTNCWSs.
All
Model PWS with LSLs

p_lsl
One time
    Distribute general LSL outreach materials
The number of remaining households with LSLs or an unknown line (calculated using the ratio of a possible "paper" replacement to known LSL) multiplied by the hours per household and the system labor rate, plus the material cost per household.

(hh_remain_lsl+num_paper_remain)*((hrs_pe_lsl_gen_dist_op*rate_op)+cost_pe_lsl_gen)
The total hours per system multiplied by the system labor rate, plus the material cost per system.

(hrs_ntncws_pe_lsl_gen_dist_op*rate_op)+cost_ntncws_pe_lsl_gen
All
Model PWS with LSLs

p_lsl
Once a year
    Submit annual or triennial LSL inventory update to Primacy Agency
The total hours for reporting per system multiplied by the system labor rate.

(hrs_report_inv_op*rate_op)
Cost applies as written to NTNCWSs.
All
Model PWS with LSLs

p_lsl
Per monitoring period or not less frequently than once per year
Acronyms: 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:
 p_lsl: Probability of having LSLs (Section 4.3.4).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
LSLR Plan
This section summarizes EPA's cost estimate for the LSLR plan that must be completed by all systems with LSLs at the start of the rule. Exhibit 5-87 provides the unit burden and/or cost for the activity. The assumptions used in the estimation of the unit burden and cost following the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-87: PWS LSLR Plan Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
   Develop LSLR plan and submit to Primacy Agency for review (one-time)
12 to 52 hrs/CWS;
12 hrs/NTNCWS
hrs_lslr_plan_op
Acronyms: CWS = community water system; LSLR = lead service line replacement; NTNCWS = non-transient non-community water system.
Sources: Data sources for each activity are provided following this exhibit.

    Develop LSLR Plan and submit to Primacy Agency for review (hrs_lslr_plan_op). All systems with LSLs must develop a plan for their LSLR program that includes the following elements:
       A strategy for determining the composition of lead status unknown service lines in its inventory.
       A strategy for informing customers before a full or partial LSLR.
       Procedures for coordinating the full LSLR.
       A funding strategy for conducting LSLR that includes ways to accommodate customers that are unable to pay to replace the portion they own.
       A procedure for customers to flush service lines and premise plumbing of particulate lead post-replacement.
  For CWSs serving more than 10,000 people, the plan also includes a recommended goal should the system be triggered into the goal-based program if they have a TLE. The estimated burden is provided in Exhibit 5-88. EPA assumed systems would require twice the burden to prepare the plan as for the Primacy Agency to review it. The Primacy Agency burden (hrs_lslr_plan_js) is based on the ASDWA CoSTS model that assumes 6 hrs for states to review the plan for small CWSs and NTNCWSs, 10 for medium CWSs, and 18 for large CWSs (ASDWA, 2020a). The model also assumed 8 hours to negotiate the goal. EPA assumed that the 8 hours would also be doubled for the system burden because the system would provide justification on why they recommended a certain goal rate. See data variable hrs_lslr_plan_js in Section <IP_ADDRESS>, activity f) for assumptions used to derive that input.

Exhibit 5-88: Estimated Burden for Systems with LSL to Develop an LSLR Plan
                                  System Size
                              (Population Served)
                               hrs_lslr_plan_op

                                     CWSs
                                    NTNCWSs
<=3,300
                                                                             12
                                                                             12
3,301-10,000
                                                                             20
                                                                             12
10,001-50,000
                                                                             36
                                                                             12
>50,000
                                                                             52
                                                                             12
   Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."

Exhibit 5-89 provides the SafeWater LCR model costing approach for this activity including additional cost inputs that are required to calculate the total costs.
Exhibit 5-89: LSLR Plan 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

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

(hrs_lslr_plan_op*rate_op)
Cost applies as written to NTNCWSs.
All
Model PWS with LSLs

p_lsl
One time
Acronyms: CWS = community water system; LSL = lead service line; LSLR = lead service line replacement; 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:
 p_lsl: Probability of having LSLs (Section 4.3.4).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).

Lead Service Line Replacements
This section summarizes EPA's cost estimates for physical replacement of LSLs. The detailed methodology is provided in Appendix A, Section A.2. EPA recognizes uncertainty in LSLR unit costs by having a low and high cost estimate that are used in the low and high costing scenario, respectively, as described in Section A.2 and summarized in Section <IP_ADDRESS>.5.
The costs are divided into two activities as shown in Exhibit 5-90. This division is based on if the system or the customer is assigned the cost for replacement in Safe Water LCR and EPA's cost estimates in general. The exhibit provides the range of unit costs for five different replacement types (utility-side, utility-side planned, full replacement, full replacement planned, and customer side) and three replacement programs that were described in Section 5.3.4, with assumptions following the exhibit. Additional detail is also provided in Section A.2. The last column in Exhibit 5-90 provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-90: PWS LSL Replacement Unit Cost Estimates
                                   Activity
                                   Unit Cost
                          SafeWater LCR Data Variable
Systems replace LSLs
Utility Side for Goal Based and Customer-initiated Only
$2,449 to $5,689/replacement for goal-based or customer-initiated programs
$1,959 to $4,551/replacement (planned for goal-based program only)

Full Replacement for Mandatory Only
$3,953 to $6,024/replacement
$3,163 to $4,819/replacement (planned)

Customer-side for Mandatory Program Only
$2,514 to $3,929/replacement1
Utility Side
cost_lslr_system_volun

cost_lslr_planned_volun

Full Replacement
cost_lslr_system_mand
cost_lslr_planned_mand

Customer Side
cost_lslr_hh

Households replace privately-owned portion of LSLs if under goal-based or customer-initiated program
Customer-side for Goal Based and Customer-initiated Only
$2,514 to $3,929/replacement for goal-based or customer-initiated programs only

Customer Side
cost_lslr_hh
Acronyms: LSL = lead service lines.
Source: Data sources for each activity are provided following this exhibit.
Note:
[1] Paid for by utility to complete a prior partial to achieve full replacement for Mandatory Program only.

g) 	Systems replace LSLs (cost_lslr_system_volun, cost_lslr_planned_volun, cost_lslr_system_mand cost_lslr_planned_mand,  cost_lslr_hh). EPA reviewed news reports, press releases, and utility websites to estimate the unit costs of utility-side, full, and customer-side LSLR. EPA used a unit cost for "planned" utility-side and full replacements that are done as part of infrastructure or capital improvement projects to reflect savings that the utility will experience from already being in the area, coordinating with other utilities and doing hard surface removal to access the water main near the LSLs (estimated as 20 percent savings). See Exhibit 5-91 for low and high unit cost estimates for these types of replacements. See Appendix A, Section A.2 for detailed information on the derivation of LSLR unit costs.
Exhibit 5-91: Estimated System Unit Costs for LSLR ($2016)
                                 Type of LSLR
                           Cost Input (2016$)[1, 2]
                          SafeWater LCR Data Variable
                                 Applicability

                             Low (25th percentile)
                            High (75th percentile)

Utility-Side
                                    $2,449
                                    $5,689
cost_lslr_system_volun
Goal-based and Customer-initiated Programs, cost for CWS to replace its portion.
Utility-Side (Planned)
                                    $1,959
                                    $4,551
cost_lslr_planned_volun
Goal-based Programs, cost for CWS to replace its portion when part of an emergency or infrastructure replacement.
Full Replacement
                                    $3,953
                                    $6,024
cost_lslr_system_mand
Mandatory Program, cost for CWSs to replace system and customer side. For NTNCWSs, this is the only input used under the previous rule and LCRR.
Full Replacement (Planned)
                                    $3,163
                                    $4,819
cost_lslr_planned_mand
Mandatory Program, cost for CWSs to replace system and customer side associated with an emergency or infrastructure replacement.
Customer-Side
                                    $2,514
                                    $3,929
cost_lslr_hh
Mandatory Program, cost for CWS to replace the customer side to complete a prior partial.[3]
Source: Exhibit A-3 in Appendix A and "Derivation of LSLR Costs_Final Rule.xlsx."
Notes:
1 LSLR costs are based on information for 38 systems that conducted LSLR between 2000 and 2019, with most projects occurring between 2015 and 2019 (note that all costs were converted to $2016). The planned costs in the second and fourth rows are further adjusted downward by 20 percent to represent savings that systems experience when replacing LSLs as part of planned capital improvements. See Section A.2 for details on derivation of each unit cost.
[2]The Low value is the 25[th] percentile of the system estimates and the High value is the 75[th] percentile. The Low and High values are used as inputs for the SafeWater LCR model.
[3]The unit cost for customer-side replacement is also used when the customer pays for their portion of the LSLR under the Goal-Based and Customer-Initiated programs.

   Exhibit 5-92 provides the estimated likelihood of each type of LSLR under each program as follows:
 For the goal-based program: EPA assumed that CWSs will only incur costs for the utility side of the LSLR, and that customers will pay for their portion to achieve full replacements.
 For the mandatory program: EPA assumed that the systems will pay to replace the utility-side as well as the private-side (i.e., Full LSLR). Note that this is a modeling assumption only and the rule does not require the system to pay for replacement of the private side. EPA assumed that systems might bear the full cost of the replacement to meet the mandatory replacement rate, recognizing that this might result in an overestimate in LSLR costs borne by systems. EPA recognizes that many systems have been replacing LSLs as part of infrastructure improvement programs and that some LSLs remaining may be only the customer side. For modeling purposes, EPA assumed that systems have been replacing the utility-side of LSLs at an average rate of 1 percent per year from 1991 when the original LCR was promulgated to 2020 (29 years) when the LCRR is anticipated to become final with approximately 72 percent of those being partial replacements. This translates to approximately 20 percent (0.29*0.72) of LSLR can be accomplished by replacing only the customer's side (i.e., "completing a prior partial"). Note that the unit cost to replace the customer side is the same regardless of whether the system performs the replacement or the customer.
 For both the goal-based and mandatory programs: EPA recognizes the cost savings that can be realized when replacements occur during planned infrastructure/capital improvement programs. In these cases, crews will already be in the area coordinating with other utilities and doing hard surface removal to access the water main near the LSLs. EPA estimated a 20 percent savings based on detailed cost information from Flint, Michigan (available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov). EPA assumed that this lower LSLR unit cost applies to approximately 1 percent of replacements each year.
 For the customer-initiated program: Systems must replace their portion of the LSL when a customer has replaced his/her portion and notified the water system. CWSs will only incur costs for the utility side of the LSLR.
Exhibit 5-92: Likelihood of LSLR Type of Systems by Program
                              Type of Replacement
                      Likelihood under Goal-Based Program
                      Likelihood under Mandatory Program
                      Likelihood under Customer-Initiated
                          SafeWater LCR Data Variable
Utility-Side (Planned)
                                                                             1%

pp_lslr_cap_emerg
Utility-Side
                                                                            99%

                                                                           100%
Customer-Initiated
pp_cust_init_lslr

Goal-based
1 - pp_lslr_cap_emerg
Full Replacement (Planned)

                                                                             1%

pp_lslr_cap_emerg
Full Replacement

                                                                            79%

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

                                                                            20%

pp_lslr_partial
   Source: Exhibit A-5 in Appendix A and Derivation of LSLR Costs_Final Rule.xlsx."

   In addition to the unit cost and likelihood of the type of LSLR under each program, EPA needs the total number of LSLs replaced each year (num_lsl_replace) to estimate LSLR costs under the rule. The number of LSLs replaced is calculated as the number of LSLs for a system multiplied by the replacement rate per year. EPA assumed the following replacement rates for each program:

          For the goal-based program, EPA assumed for modeling purposes that Primacy Agencies would set an average replacement rate goal of 2 percent per year (pp_lsl_replaced_vol_goal). To recognize that this is a goal and not a requirement, EPA modeled a range of actual replacement rates of 1 to 5 percent with a most likely value of 2.5 percent (pp_lsl_replaced_vol_pct).
          For the mandatory program, EPA assumed the required rate of full LSLR of 3 percent per year. Note that the Final LCRR provides compliance flexibility to water systems that are implementing a mandatory LSLR program by requiring replacements to be based on a rolling 2 year average of 3% per year using a baseline number of LSLs equal to the number of LSLs and galvanized requiring replacement service lines at the time the system first exceeds the lead trigger or action level plus the number of unknowns at the beginning of each year of the system's LSLR program. This rolling average allows systems that experience LSLR rate fluctuation to still meet a 3% replacement rate on average for the prior two-year period every year the water system is required to implement the LSLR program. The regulation also requires that a cumulative number of replacements be reached equal to 3% of the sum of known lead, galvanized requiring replacement, and lead status unknown service lines in the initial inventory, times the number of years that elapsed between the system's first ALE and the date on which the system's 90th percentile lead levels are at or below the action level for 2 years (four consecutive 6-month monitoring periods). EPA does not have information on the annual variation in replacement rates which systems may experience when required to conduct mandatory replacement, therefore, the Agency has assumed an annual replacement rate of 3% (which equals a 3% rolling average value across all two-year time periods). EPA's costs capture all estimated replacements required under the rule, but because the assumed 3% annual rate may not capture the year to year variation in LSL replacement rate. Therefore, EPA's estimated discounted costs may be under or over estimated.
          For the customer-initiated program, EPA estimated the likelihood of these replacement to be 0.05 percent of LSLs per year (pp_cust_init_lslr) based on the average of these types of replacements conducted by DC Water from 2008 through 2013 (Environmental Defense Fund and American University School of Public Affairs, 2020). Note that EPA applied this percentage to systems that are not replacing LSLs as part of the goal-based or mandatory replacement programs because the Agency assumed any customer-initiated replacements would be included as part of those programs.
    The number of LSLRs required in a year (numb_lsl_replace) is the product of the PWS's replacement rate multiplied by the baseline number of LSLs (which is the number of connections per system from SDWIS/Fed multiplied by perc_lsl for the low and high cost scenario, see Exhibit 5-4) plus the number of service lines of unknown material (which is the number of connections per system from SDWIS/Fed multiplied by pp_lslr_partial as described in Section <IP_ADDRESS> activity d)). As LSLs are replaced and service lines of unknown material are removed from the inventory, the number of LSLRs required each year will decrease. Note that EPA's analysis does not include per system estimates of the number of LSLs replaced over the period from the completion of the initial inventory to a system's first ALE. Therefore, EPA's estimated replacement costs for the mandatory program may be overestimated.
h) 	Households replace privately-owned portion of LSLs if goal-based program (cost_lslr_hh). As discussed in the section above, EPA assumed for the goal-based program, customers will incur the cost of replacing the portion of the service line they own. This cost ranges from a low estimate of $2,514 and a high estimate of $3,929 (same estimated cost that is incurred by PWSs for customer-side replacements under the mandatory LSLR program).
Exhibit 5-93 provides the SafeWater LCR model cost estimation approach for systems and households to replace LSLs including additional cost inputs required to calculate these costs.
Exhibit 5-93: Lead Service Line Replacement 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

    Systems replace LSLs
The sum of the number of lines replaced for each category of possible types of replacement (capital project, emergency replacement, or in response to the rule) multiplied by the costs per type of replacement.

((num_lsl_replace*pp_lslr_cap_emerg)*cost_lslr_planned_volun)+((num_lsl_replace*(1-(pp_lslr_cap_emerg +pp_lslr_partial)))*cost_lslr_system_volun)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS participating in the goal-based LSLR program

p_lsl

Once a year
The sum of the number of lines replaced for each category of possible types of replacement (capital project, emergency replacement, or in response to the rule) multiplied by the costs per type of replacement.

((num_lsl_replace*pp_lslr_cap_emerg)*cost_lslr_planned_mand)+((num_lsl_replace*(1-(pp_lslr_cap_emerg)))*cost_lslr_system_mand)+((num_lsl_replace*pp_lslr_partial)*cost_lslr_hh)
Cost applies as written to NTNCWSs which conduct LSLRs under the small system flexibility program.
Above AL
Model PWS participating in the mandatory LSLR program

p_lsl

Once a year
The number of customer-initiated partial line replacements multiplied but the cost of a partial utility side replacement.

(num_lsl_requested)*cost_lslr_system_volun
Cost does not apply to NTNCWSs.
At or below the TL
Model PWS not participating in the goal-based or mandatory LSLR programs

p_lsl

Once a year
    Households replace privately-owned portion of LSLs if goal-based program
The number of customer-side LSLs replaced as part of goal-based program each year times the unit cost.

(num_lsl_replace * cost_lslr_hh)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Households served by systems participating in the goal-based LSLR program

p_lsl
Once a year
Acronyms: AL = action level; CWS = community water system; LSL = lead service line; LSLR = lead service line replacement; NTNCWS = non-transient non-community water system; PWS = public water system; TL = trigger level.
Notes:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 p_lsl: Likelihood a system had LSLs (see Section 4.3.4).
Ancillary Lead Service Line Replacement Activities
EPA has developed system costs for ancillary activities associated with LSLR, as shown in Exhibit 5-94. 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 5-94: PWS LSL Replacement Ancillary Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
Conduct planning and identify financial options for LSLRs and submit to Primacy Agency (one-time)
400 to 1,100 hrs/CWS
hrs_fin_op_op
Consult with Primacy Agency and develop targeted LSLR program outreach materials (one-time)
5.5 hrs/CWS with TLE serving 10,001 to 50,000
22 hrs/CWS with TLE serving > 50,000
hrs_lslr_out_op
Distribute targeted LSLR program outreach materials
CWSs serving >10,000 with TLE
0.0026 to 0.0357 hrs/HH;
$0.23/HH

hrs_dist_lslr_out_op;
cost_lslr_out
Contact customers and conduct site visits prior to LSLR
Burden per replaced LSL
1.69 to 1.97 hrs

Cost per replaced LSL
$10.67 to $14.45/replaced LSL
Burden
hrs_replaced_lsl_contact_op

Cost
cost_replaced_lsl_contact
Inspect and test lines to confirm if they are not lead
Burden
1 to 2 hr/paper replacement

Cost
$109 to $328/paper replacement
Burden
hrs_lslr_paper_op

Cost
cost_lslr_paper
Deliver filters and cartridges at time of LSLR and maintain them for 6 months
$44.00/replaced LSL
cost_filter_hh
Collect tap sample post-LSLR
Burden per sample
CWSs: 0.9 to 1.2 hrs
NTNCWSs: 0.5 hrs

Cost per sample per CWS
Travel: $5.29 to $9.07
Bottle: $0 to $3.36
Burden
hrs_collect_lsl_lslr_op

Cost
cost_pickup_samp
cost_other_lt_samp[1]
Analyze post-LSLR tap sample
In-house Analysis (CWSs > 100K only)
Burden: 0.44 hrs/sample
Cost: $2.38

Commercial Analyses
$21.58/sample
In-house Analysis hrs_analyze_lsl_lslr_op[1]
cost_lab_lsl_lslr[1]

Commercial Analysis
cost_commercial_lsl_lslr[1]
Inform customers of tap sample result
Burden
CWSs: 0.05 hrs/sample
NTNCWSs: 1 hr/system

Cost
CWSs: $0.58/sample
NTNCWSs: $0.025/system

Burden
hrs_inform_samp_op
hrs_ntncws_cust_lslr_op

Cost
cost_cust_lslr
cost_ntncws_cust_lslr
Submit annual report on LSLR program to Primacy Agency
1 to 8 hrs/CWS
1 hr/NTNCWS
hrs_report_lcr_op
Acronyms: CWS = community water system; HH = household; LSL = lead service lines; LSLR = lead service line replacement; NTNCWS = non-transient non-community water system; TLE = trigger level exceedance.
Sources: Data sources for each activity are provided following this exhibit.
Note:
1 The burden and costs for these activities are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.

 Conduct planning and identify financial options for LSLRs and submit to Primacy Agency (hrs_fin_op_op). CWSs subject to the goal-based or mandatory LSLR program will incur one-time burden to conduct a study including developing an LSLR financing plan. This plan does not apply to NTNCWSs because EPA assumed that they own their entire service line(s). Exhibit 5-95 provides the detailed assumptions used to develop these estimates for three CWS size categories.
Exhibit 5-95: PWS Burden to Conduct LSLR Study Including Financing Plan
                               Planning Activity
                               Estimated Burden

                                 CWSs serving:

                                   <=10,000
                                10,001-100,000
                                  >100,000
Legal considerations for funding options.
   Determine if statutes/regulations prohibit/restrict a public system from paying for LSLRs on private property (i.e., using public funds for private purposes).
   Determine statutes/regulations prohibit/ restrict type of funding used for LSLRs and if so, do they apply to system type (public vs. private) and LSLR type (on public or private property).
                                                                              8
                                                                             16
                                                                             20
Identify potential funding sources.
   Consider grants, loans, or bonds or a combination; also consider other govt. support for low income homeowner-owned segments (e.g., HUD). Assume small systems have assistance identifying options.
   Include state-specific options (such as MA's interest-free LSLR program through their state revolving fund (SRF)).
                                                                             40
                                                                             60
                                                                            100
Evaluate funding sources.
Determine if project meets criteria, funding and project timeline are compatible, impact on user charges, additional engineering or special studies required, affordability for users.
                                                                             80
                                                                            100
                                                                            200
Meet with potential funding sources on requirements and project-specific details.
Include preparation and meeting by phone or in-person as applicable.
                                                                             40
                                                                             60
                                                                             80
Compile preliminary financing plan.
Include options considered and selected, funding amounts for each source, utility-owned and homeowner-owned LSL funding sources.
                                                                             60
                                                                            100
                                                                            300
Conduct public meetings and outreach.
Review project details and financing plan; assumed at least 2 meetings.
                                                                             80
                                                                            120
                                                                            200
Conduct consumer income survey (if applicable for funding source).
Assume needed for funding options for CWSs serving <=100,000 people.
                                                                             40
                                                                             60
                                                                              0
Submit pre-applications to funding sources.
Assume single funding source for CWSs serving <10,000; two for those serving 10,000 to 100,000; and three for those serving > 100,000.
                                                                             60
                                                                            120
                                                                            200
Totals
                                                                            408
                                                                            636
                                                                           1100
Round to hundreds.
                                                                            400
                                                                            600
                                                                           1100
Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."

 Consult with Primacy Agency and develop targeted LSLR program outreach materials (hrs_lslr_out_op). CWSs serving more than 10,000 people with a TLE will incur burden to consult with their Primacy Agencies and develop outreach materials on their LSLR program that invite customers to participate in their goal-based LSLR program. EPA assumed that all CWSs will use an EPA-developed template. EPA assumed that those systems serving 10,001 to 50,000 people will require 3.5 hours to develop these materials and an additional 2 hours to consult with the Primacy Agency for a total of 5.5 hours. Those serving more than 50,000 people will adapt the template and require 20 hours to develop the materials and an additional 2 hours to consult with the Primacy Agency for a total of 22 hours. The estimates for systems serving 50,000 or fewer people are based on tier 2 PN preparation burden (3.5 hours), and burden estimates for systems serving more than 50,000 people are based on tier 1 PN preparation burden for systems serving more than 10,000 people (30 hours) in the Public Water System Supervision Program Information Collection Request (ICR) (Renewal) (USEPA, 2015a). EPA assumed that systems serving more than 50,000 people would require 20 hours to develop the materials as opposed to the 30-hour estimate for Tier 1 PN.
 Distribute targeted LSLR program outreach materials (hrs_dist_lslr_out_op, cost_lslr_out). CWSs with LSLs that serve more than 10,000 people and have a TLE will incur burden to distribute targeted LSLR program outreach materials to households with LSL, galvanized service lines, and those of unknown material. The estimated burden and costing assumptions are provided in Exhibit 5-96. The rule allows CWSs to discontinue distribution of this outreach material after two consecutive monitoring periods at or below the TL.
Exhibit 5-96: Estimated Annual Burden (per household) to Distribute Targeted Outreach Materials about LSLR Program for CWSs with LSLs and a TLE that Serve > 10,000 People (hrs_dist_lslr_out_op)
                        System Size (Population Served)
                        Separate mailing (hrs per CWS)
                          Bill Stuffer (hrs per CWS)
                             Average (hrs per CWS)
                                  HH per CWS
                                   (numb_hh)
                      Separate/ Bill Stuffer (hrs per HH)
                            Production (hrs per HH)
                                     Total
                                   (hrs/HH)

                                       A
                                       B
                                  C = (A+B)/2
                                       D
                                   E = C / D
                                       F
                                   G = D + F
10,001-50,000
                                                                            120
                                                                             30
                                                                             75
                                                                          8,446
                                                                         0.0089
                                                                         0.0025
                                                                         0.0114
50,001-100,000
                                                                            120
                                                                             30
                                                                             75
                                                                         26,770
                                                                         0.0028
                                                                         0.0025
                                                                         0.0053
100,001-1,000,000
                                                                            120
                                                                             30
                                                                             75
                                                                         93,467
                                                                         0.0008
                                                                         0.0025
                                                                         0.0033
>1,000,000
                                                                            120
                                                                             30
                                                                             75
                                                                        772,999
                                                                         0.0001
                                                                         0.0025
                                                                         0.0026
Acronyms: CWS = community water system; HH = household.
Source: "Derivation of Public Education Inputs_CWS_Final Rule.xlsx."
Notes:
A: EPA assumption regarding the burden per system to prepare separate mailings.
B: EPA assumption regarding the burden per system to mail materials with the water bill.
C: EPA assumed that half of systems will conduct separate mailings and the other half will include targeted outreach materials with the water bill.
D: See Exhibit 5-123. Estimated as 2.59 people per household (numb_hh) for the year 2010 (United States Census Bureau, 2010). Table AVG1. Average Number of People Per Household, By Race and Hispanic Origin, Marital Status, Age, And Education Of Householder. Available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
F: EPA assumed 0.25 hours per 100 brochures for production. Estimate is based on assumptions for production labor used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (Exhibit 17) (USEPA, 2007).

These systems will also incur costs to distribute these materials. EPA assumed:
       Systems providing the materials in the water bill will incur a cost for a cover letter (paper cost of $0.025) and brochure (paper cost of $0.025) for a total cost of $0.05 per household. See "General Cost Model Inputs_Final Rule.xlsx" for additional information about costs for paper. EPA assumed that the weight of the cover letter and brochure would not result in additional postage being needed to mail the water bill.
       Systems distributing the materials in a separate mailing will also incur the cost of an envelope ($0.067), and bulk rate postage ($0.301) since systems will be sending out more than 200 mailings. This equals a total per household cost of $0.43 ($0.025 + $0.05 + $0.067 + $0.301). See "General Cost Model Inputs_Final Rule.xlsx" for additional information about costs for paper, envelopes, and postage.
       Half of these systems will include the materials in the water bill and another will mail them separately. Thus, the estimated cost is the average of $0.05 and $0.43 or $0.23 per household for data variable cost_lslr_out.
 Contact customers and conduct site visits prior to LSLR (hrs_replaced_lsl_contact_op, cost_replaced_lsl_contact). CWSs will incur burden and costs to coordinate with customers prior to replacing the LSLs. The estimated burden and costs are provided in Exhibit 5-97 and Exhibit 5-98, respectively.
Exhibit 5-97: Estimated Burden Associated with Contacting Customers and Site Visit Prior to LSLR (hrs/replaced LSL) (hrs_replaced_lsl_contact_op)
                                  System Size
                              (Population Served)
                                Upfront Contact
                               Site Visit Travel
                                On-Site Review
                                 Total Burden

                                  Phone Call
                                Prepare Letter
                                 Miles one way
                              Time one way (hrs)
                             Time Roundtrip (hrs)

                                       A
                                       B
                                       C
                                       D
                                    E = D*2
                                       F
                                  G = A+B+E+F
<=100,000
                                                                           0.25
                                                                           0.05
                                                                            4.9
                                                                          0.196
                                                                          0.392
                                                                              1
                                                                           1.69
100,001-1,000,000
                                                                           0.25
                                                                           0.05
                                                                            6.3
                                                                          0.252
                                                                          0.504
                                                                              1
                                                                           1.80
> 1,000,000
                                                                           0.25
                                                                           0.05
                                                                            8.4
                                                                          0.336
                                                                          0.672
                                                                              1
                                                                           1.97
Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."
Notes:
A & B: For each LSLR, EPA assumed a system will first contact customers twice. These contacts are to coordinate a site visit to confirm the presence of an LSL prior to the actual replacement of the line that are found to be lead. EPA assumed the system first calls the customer (15 minutes per customer) and then sends a certified letter. Burden to prepare the letter is 20 letters per hour based on the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 35 in Appendix H (USEPA, 2015b).
C - E: Based on census data and zip codes from the 2006 Community Water System Survey. See file, "Derivation of Estimated Driving Distances_Final Rule.xlsx." EPA assumed an average speed of 25 miles per hour, round trip.
F: Includes 1 hour for on-site visual inspection. Assumed no testing.
Exhibit 5-98: Estimated Costs Associated with Contacting Customers and Site Visit Prior to LSLR ($/replaced LSL) (cost_replaced_lsl_contact)
                                  System Size
                              (Population Served)
                                 Mailing Costs
                                Vehicle O&M
                                 Total Burden

                                Certified Mail
                                     Paper
                                   Envelopes
                                Miles Roundtrip
                               2016 Mileage Rate
                                 Cost per Trip

                                       A
                                       B
                                       C
                                       D
                                       E
                                   F = D * E
                                  G = A+B+C+F
<=100,000
                                                                          $5.29
                                                                          $0.03
                                                                          $0.07
                                                                            9.8
                                                                          $0.54
                                                                          $5.29
                                                                         $10.67
100,001-1,000,000
                                                                          $5.29
                                                                          $0.03
                                                                          $0.07
                                                                           12.6
                                                                          $0.54
                                                                          $6.80
                                                                         $12.19
> 1,000,000
                                                                          $5.29
                                                                          $0.03
                                                                          $0.07
                                                                           16.8
                                                                          $0.54
                                                                          $9.07
                                                                         $14.45
Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."
Notes:
A: Certified mail with electronic return receipt, single piece. Includes certified mail cost ($3.35), emailed signature receipt ($1.45), and first class postage ($0.49).
B&C: Based on quotes from 3 vendors. See file, "General Cost Model Inputs_Final Rule.xlsx" for additional detail.
D: 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 serving <= 100,000 people, 6.3 miles serving 100,001  -  1,000,000 people, and 8.4 miles for serving > 1,000,000 people. These distances were doubled to estimate roundtrip mileage. See file, "Derivation of Estimated Driving Distance_Final Rule.xlsx" for additional detail on how these estimates were derived.
E: Federal reimbursement rate of $0.54 (2016 mileage rate) based on GSA information (available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov).

 Inspect and test lines to confirm they are not lead (hrs_lslr_paper_op, cost_lslr_paper). EPA estimated that CWSs will incur burden and costs each year when they find that service lines are not lead in the field. These are also referred to as "paper replacements." EPA assumed that paper replacements occur in two ways: Site visits (no digging) and field testing (digging) as follows:
 Site visit (hrs_lslr_paper_op): System coordinates the site visit to visually confirm the service line type by looking at a meter pit or where the plumbing enters the home. For the customer-side, the site visit may require coordination with the resident in cases where the system representative needs to look at plumbing inside the home. EPA assumed that
             Pipe material can be verified through scratch testing and use of a magnet as described by the LSLR Collaborative in "Identifying Service Line Material" (LSLR Collaborative, n.d.). No digging is necessary.
             System operators can conduct up to 8 inspections per day. To account for the range of time that might be spent onsite, EPA estimated that between 0.5 and 1.5 hours would be needed per site. The Agency also added 0.5 hours for travel time to obtain a total estimated range of between 1 to 2 hours per site visit with a most likely value of 1.5 hours.
 Field Testing (cost_lslr_paper): EPA recognizes that there is a range of field testing methods including test pitting, potholing, and curb inspection. For the purposes of costing, however, EPA selected the typical method of hydrovacing to estimate field testing costs. EPA assumed that water systems would use a contractor and developed costs based on information provided by Green Bay, Pittsburgh, and DC Water (see the Derivation file, "Derivation of LSLR Ancillary Costs_Final Rule.xlsx," sheet "Paper Replacement Approach" for details).Based on this information, EPA estimated an average cost of $219 and calculated a low cost of $109 (50 percent of $219), and a high cost of $328 (150 percent of $219) for cost modeling purposes.
   For modeling purposes and to recognize uncertainty in this input, EPA assumed that the percent of inspections that could be visual (p_lslr_visual_inspection) is 0 percent (minimum) to 100 percent (maximum), with a most likely value of 50 percent. The remaining inspections are assumed to be completed using field testing.
   EPA estimated total costs of paper replacements by applying a likelihood that for each line physically replaced, another will be proven not to be lead (pp_lslr_paper). This likelihood is based on the assumption that systems will confirm that unknown service lines are not lead for an additional 28 percent over their estimated LSL inventory. Refer to Section <IP_ADDRESS>, activity d) for detailed assumptions.
 Deliver filters and cartridges at time of LSLR and maintain them for 6 months (cost_filter_hh). Systems must provide a pitcher filter (i.e., pour through filter) that is certified to remove lead to each resident following any LSLR. EPA assumed that the pitchers and filters delivered to each resident to use for six months following LSLR will cost $44 on average (including shipping and filter replacement). Although many pitchers come with filters that will provide lead removal for more than six months, the average cost includes a filter replacement cost for those that do not last six months.
Collect tap sample post-LSLR (hrs_collect_lsl_lslr_op, cost_pickup_samp, cost_other_lt_samp). All systems participating in the goal-based or mandatory LSLR program must collect one sample following replacement of each LSL (numb_samp_lslr). Burden and costs for this activity are different than mandatory tap sampling because the system collects the sample after replacement as opposed to the customers collecting the sample under tap sampling. Exhibit 5-99 and Exhibit 5-100 provide the estimated CWS burden and cost to collect these samples. A discussion of the burden and costs to NTNCWSs follow these exhibits.
Exhibit 5-99: CWS Unit Burden to Collect Post-LSLR Tap Sample
                                 System Size
                              (Population Served)
                              Burden (hrs/Sample)

                     Round-trip travel to customer's home
                           Sample Collection Burden
                        Total Sample Collection Burden

                            hrs_collect_lsl_lslr_op

                                       A
                                       B
                                    C = A+B
<=100,000
                                                                          0.39
                                                                            0.5
                                                                            0.9
100,001-1,000,000
                                                                          0.50
                                                                            0.5
                                                                            1.0
>1,000,000
                                                                          0.67
                                                                            0.5
                                                                            1.2
Source: "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx"
Notes:
A: 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 serving <= 100,000 people, 6.3 miles serving 100,001  -  1,000,000, and 8.4 miles for > 1,000,000. These distances were doubled to estimate roundtrip mileage. See file, "Derivation of Estimated Driving Distance_Final Rule.xlsx" for additional detail on how these estimates were derived. Assumed an average speed of 25 miles per hour.
B: Assumed the system would require the same burden to collect the sample following LSLR as required to collect a source water sample. Source water burden is from the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 15 in Appendix H (USEPA, 2015b).

Exhibit 5-100: CWS Unit Cost to Collect Post-LSLR Tap Sample
                                 System Size
                              (Population Served)
                               Cost (hrs/Sample)

                     Round-trip travel to customer's home
                                  Bottle Cost

                               cost_pickup_samp
                              cost_other_lt_samp

                                       A
                                       B
<=100,000
                                                                         $5.29
                                                                          $0.00
100,001-1,000,000
                                                                         $6.80
                                                                          $3.36
>1,000,000
                                                                         $9.07
                                                                          $3.36
Source: "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx."
Notes:
A: 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 serving <= 100,000 people, 6.3 miles serving 100,001  -  1,000,000, and 8.4 miles for > 1,000,000. These distances were doubled to estimate roundtrip mileage. See file, "Derivation of Estimated Driving Distance_Final Rule.xlsx" for additional detail on how these estimates were derived. Assumed an average speed of 25 miles per hour. Used the Federal reimbursement rate of $0.54 (2016 mileage rate).
B: Bottles are included as part of the commercial laboratory fee. Only CWSs serving more than 100,000 people are assumed to conduct analyses in-house for lead. For a detailed discussion of the assumptions used to estimate bottle costs, see "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx," worksheet, "In-House_Bottle_$."

   NTNCWSs will not incur the burden or costs to travel to a customer's house to collect a sample. In addition, NTNCWSs do not incur bottle costs because laboratories provide the 1-liter bottle as part of their commercial laboratory fee. Thus, they will only incur a burden of 0.5 hours per sample and $0 costs associated with sample collection.
Analyze post-LSLR tap sample (hrs_analyze_lsl_lslr_op, cost_lab_lsl_lslr, cost_commercial_lsl_lslr). As previously discussed 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_lsl_lslr_op). These systems will also incur consumable costs of $2.38 per sample based on information from three vendors (cost_lab_lsl_lslr). The remaining CWSs and all NTNCWSs are assumed to use commercial laboratories and incur a cost of $21.58 per lead sample based on quotes from six laboratories (cost_commercial_lsl_lslr). Note that although the data variable names are different, the unit costs for lead sample analysis are the same as for lead tap sampling as presented in Section <IP_ADDRESS>.2.
Inform customers of tap sample result (hrs_inform_samp_op, cost_cust_lslr, hrs_ntncws_cust_lslr_op, cost_ntncws_cust_lslr). Systems must notify their customers of their lead analytical results from the sample collected following LSLR. EPA made the following assumptions regarding the burden and/or costs for this notification:
 CWSs of all sizes will send the results to their customers at a burden of 0.05 hours (hrs_inform_samp_op) and a cost of $0.58 (cost_cust_lslr). These inputs are the same as those used for the tap sampling program. The burden estimate of 1 hour per 20 letters for all systems sizes is based on the public education burden for systems to notify occupants of results estimated in the (2015 Disinfectants and Disinfection Byproducts, Chemical, and Radionuclides Rules ICR, Exhibit 35 in Appendix H). Systems are also assumed to mail the post-LSLR sample results. The cost consists of postage ($0.49), paper ($0.025), and envelope ($0.067) for a total cost of $0.58/sample. See file, "General Cost Model Inputs_Final Rule.xlsx" for additional information on the sources of these estimates.
 NTNCWSs are assumed to notify the people they serve electronically and through posting. EPA assumed all NTNCWSs of all size categories will spend 0.5 hours to develop/send e-mail and an additional 0.5 hours to post the notification publicly for a total of burden 1 hour per system (hrs_ntncws_cust_lslr_op). In addition, NTNCWSs will incur material costs for paper posting of $0.025 based on quotes from three vendors (cost_ntncws_cust_lslr). See derivation file, "General Cost Model Inputs_Final Rule.xlsx" for quotes.
Submit annual report on LSLR program to Primacy Agency (hrs_report_lcr_op). Systems that are subject to the goal-based or mandatory LSLR program must submit an annual report to their Primacy Agency. EPA estimated that burden would be higher as system size increases to account for larger number of LSLs replaced. EPA estimated the following burden for CWSs to prepare and submit their annual report:
 CWSs serving 3,300 or fewer and NTNCWSs: 1 hour.
 CWSs serving 3,301 to 10,000 people: 2 hours.
 CWSs serving 10,001 to 100,000 people: 4 hours.
 CWSs serving more than 100,000 people: 8 hours.
Exhibit 5-101 provides the SafeWater LCR model cost estimation approach for PWS ancillary LSLR activities including additional cost inputs that are required to calculate these costs.
Exhibit 5-101: Lead Service Line Inventory Ancillary 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 planning and identify financial options for LSLRs and submit to Primacy Agency
The total hours per system multiplied by the system labor rate.

(hrs_fin_op_op*rate_op)
Cost does not apply to NTNCWSs.
All
Model PWSs with LSLs conducting goal-based or mandatory LSLR

p_lsl
One time
    Consult with Primacy Agency and develop targeted LSLR program outreach material
The total consulting hours per system multiplied by the system labor rate.

(hrs_lslr_out_op*rate_op)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS participating in goal-based LSLR program

p_lsl
One time
    Distribute targeted LSLR program outreach materials
The number of households with remaining LSLs multiplied by the total of the hours per household times the system labor rate, plus the materials cost.

hh_remain_lsl * (hrs_dist_lslr_out_op * rate_op + cost_lslr_out)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS participating in the goal-based LSLR program

p_lsl
Once a year
    Contact customers and conduct site visits prior to LSLR
The number of lines replaced multiplied by the total of the hours per lead line replacement times the system labor rates, plus the material cost.

num_lsl_replace * (hrs_replaced_lsl_contact_op * rate_op + cost_replaced_lsl_contact)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS participating in the goal-based LSLR program

p_lsl
Once a year

Above AL
Model PWS participating in the mandatory LSLR program

p_lsl

    Inspect and test lines to confirm they are not lead

Because of uncertainty during the development of the initial LSL inventory systems may test some lines to determine if they are in fact lead and in need of replacement. If the line is visually inspected there is a labor burden per line times the system labor rate. If the line is field tested there is a material cost burden that represents the work conducted by a contractor.

(((num_lsl_replace*pp_lslr_paper)*p_lslr_visual_inspection)*(hrs_lslr_paper_op*rate_op))+(((num_lsl_replace*pp_lslr_paper)*(1-p_lslr_visual_inspection))*cost_lslr_paper)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS participating in the goal-based LSLR program

p_lsl
Once a year

Above AL
Model PWS participating in the mandatory LSLR program

p_lsl

    Deliver filters and cartridges at time of LSLR and maintain them for 6 months
The number of lines replaced multiplied by the material cost.

num_lsl_replace*cost_filter_hh
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS participating in the goal-based LSLR program

p_lsl
Once a year

Cost applies as written to NTNCWSs.
Above AL
Model PWS participating in the mandatory LSLR program

p_lsl

    Collect tap sample post-LSLR[2]
The number of samples per replaced lead line multiplied by the number of lines replaced, multiplied by the total of the hours per lead line replacement times the system labor rates, plus the material cost.

(numb_samp_lslr*num_lsl_replace)*((hrs_collect_lsl_lslr_op*rate_op)+cost_other_lt_samp+cost_pickup_samp)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS participating in the goal-based LSLR program

p_lsl
Once a year

Cost applies as written to NTNCWSs.
Above AL
Model PWS participating in the mandatory LSLR program

p_lsl

    Analyze post-LSLR tap sample[2]
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

(((numb_samp_lslr*num_lsl_replace)*pp_lab_samp)*((hrs_analyze_lsl_lslr_op*rate_op)+cost_lab_lsl_lslr))+(((numb_samp_lslr*num_lsl_replace)*pp_commercial_samp)*cost_commercial_lsl_lslr)
Cost does not apply to NTNCWSs.
At or below AL and above TL
Model PWS participating in the goal-based LSLR program

p_lsl
Once a year

Cost applies as written to NTNCWSs.
Above AL
Model PWS participating in the mandatory LSLR program

p_lsl

    Inform customers of the tap sample result
The number of lines replaced multiplied by the total of the hours per lead line replacement times the system labor rates, plus the material cost.

num_lsl_replace*((hrs_inform_samp_op*rate_op)+cost_cust_lslr)
Cost does not apply to NTNCWSs.

At or below AL and above TL
Model PWS participating in the goal-based LSLR program

p_lsl
Once a year

The total hours per system times the system labor rates, plus the material cost.

(hrs_ntncws_cust_lslr_op*rate_op)+cost_ntncws_cust_lslr)
Above AL
Model PWS participating in the mandatory LSLR program

p_lsl

    Submit annual report on LSLR program to Primacy Agency
The total hours for reporting per system multiplied by the system labor rate.

(hrs_report_lcr_op*rate_op)
Cost applies as written to NTNCWSs.
Above TL
Model PWS participating in either the goal-based or mandatory LSLR program

p_lsl
Once a year
Acronyms: AL = action level; CWS = community water system; LSL = lead service line; LSLR = lead service line replacement; NTNCWS = non-transient non-community water system; PWS = public water system; TL = trigger level.
Notes:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 p_lsl: Likelihood a system has LSLs (Section 4.3.4).
 pp_lab_samp: Likelihood of in-house analysis (Section <IP_ADDRESS>.2, activity j)).
 pp_commercial_samp: Likelihood of commercial lab analysis (Section <IP_ADDRESS>.2, activity j)).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
[2] The burden and costs to provide sample bottles (cost_other_lt_samp) under activity o) and conduct analyses under activity p) are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.
Failure to Meet Goal-based Replacement Rate Activities
Exhibit 5-102 shows EPA's estimated burden and/or costs for three ongoing outreach activities that CWSs serving more than 10,000 people must undertake if they fail to meet their goal-based replacement rate. The assumptions used in the estimation of the unit burden and costs follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font. Systems must continue the activities in this exhibit until: 1) the goal is met, 2) the system is at or below the TL for two consecutive one-year monitoring periods, or 3) the system has made at least two good faith efforts to contact all customers served by an LSL or galvanized requiring replacement about the LSLR program.
Exhibit 5-102: Failure to Meet Goal-based Replacement Rate Activities Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
Consult with Primacy Agency on activities to satisfy additional goal-based LSLR program outreach requirements
2 hrs/CWS serving > 10,000 people
hrs_consult_fail_op
Conduct activities in response to the first failure to meet LSLR goal
Burden per HH per CWS serving > 10,000 people
0.23 to 0.32 hrs

Cost per HH per CWS serving > 10,000 people
$3.63 to $4.89
Burden
hrs_fail_hh_op

Cost
cost_fail_hh
Conduct activities in response to each additional failure to meet LSLR goal
Burden per CWS serving > 10,000 people
122 to 241 hrs

Cost per CWS serving > 10,000 people
$2,651 to $24,918
Burden
hrs_fail_sys_op

Cost
cost_fail_sys
Acronyms: CWS = community water system; HH = household; LSLR = lead service line replacement.
Sources: Data sources for each activity are provided following this exhibit.
Note: The system cannot discontinue the activities in this exhibit until: 1) the goal is met, 2) the system is at or below the TL for two consecutive one-year monitoring periods, or 3) the system has made at least two good faith efforts to contact all customers served by an LSL or galvanized requiring replacement about the LSLR program.

In addition to unit and burden costs, another important input is the likelihood that a system fails to meet its replacement goal. The SafeWater LCR model calculates this as the difference between the goal set by the Primacy Agency and the system's actual replacement rate. As described previously in Section <IP_ADDRESS>, activity i), EPA assumed that Primacy Agencies would set an average replacement rate goal of 2 percent per year (pp_lsl_replaced_vol_goal). To recognize that this is a goal and not a requirement, EPA modeled a range of actual replacement rates from 1 to 5 percent with a most likely value of 2.5 percent (pp_lsl_replaced_vol_pct). For each CWSs serving 10,000 or more people in the goal-based program, the SafeWater LCR model randomly selects a replacement rate from this distribution. When the rate is less than 2 percent, the system incurs burden and costs for additional outreach activities described in s) through u) below.
Consult with Primacy Agency on activities to satisfy additional goal-based LSLR program outreach requirements (hrs_consult_fail_op). EPA estimates CWSs serving 10,000 people or more that fail to meet their replacement goal will incur an annual burden of 2 hours to consult with their Primacy Agency on needed outreach activities to consumers to promote LSLR and encourage consumers to participate in the replacement program. This estimate is based on the 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).
Conduct activities in response to the first failure to meet LSLR goal (hrs_fail_hh_op, cost_fail_hh). CWSs serving more than 10,000 people that fail to meet their goal must select one of three outreach activities in the first year in which they miss their goal. These activities include: 1) certified mail to customers with lead or galvanized requiring replacement, 2) town hall meeting, 3) community event and provide lead outreach materials and information on LSLR program, 4) contact customers via phone, text message, email, or door hanger, or 5) other Primacy Agency approved methods. To estimate the burden and cost for the initial failure, EPA:
 Developed separate costs for contacting customers by phone and using doorhangers.
 Assumed systems will have an equal probability of picking one of the three outreach activities in Columns A - C are presented in Exhibit 5-103.
 Assumed systems would not select a community event or town hall meeting during the first year as a simplifying assumption because this activity is expressed on a per system basis, whereas the other activities are expressed on a per household basis and apply to those with LSLs or galvanized service lines. Instead as described in activity u), systems would elect to hold a town hall meeting as one of their activities during those years in which they continue to fail to meet their LSL goal.
    As shown in Column D of Exhibit 5-103, EPA estimated the average burden per household for hrs_fail_hh_op. The burden is applied to hh_remain_lsl, which is the number of households served by LSLs in the current year.
Exhibit 5-103: Burden to Conduct Additional Outreach in Response to First Failure to Meet LSLR Goal (hrs/household)
                                  System Size