Provide targeted LSLR program outreach templates and consult with PWS (hrs_temp_lslr_out_js). CWSs serving more than 10,000 people with LSLs and a TLE must provide additional outreach to customers with LSLs regarding the system's LSLR program. EPA assumed that the Primacy Agency will incur a one-time burden to provide a template for these outreach materials and consult with the system of 2.25 to 2.5 hours. The estimates are based on responses from Indiana and North Carolina to an ASDWA survey regarding the burden to provide a template for revised sampling instructions. EPA assumed that the burden to provide the outreach template would be the same as the burden to provide the sampling template (hrs_rev_samp_js), which is based on the North Carolina estimate of 0.25 hours per sampling instructions template and the Indiana estimate of 0.5 hours per template. It includes an additional 2 hours for consultation with the CWS. The questionnaire and each state's responses are available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
    Review targeted outreach materials (hrs_review_targeted_pe_js). EPA assumed that Primacy Agencies will incur a one-time burden to review the LSL program outreach materials described in activity g) above. EPA assumed that CWSs serving 10,001 to 50,000 people will use a template and Primacy Agencies will require 0.5 hours to review the outreach materials. EPA assumed that systems serving more than 50,000 people will adapt the template and the Primacy Agencies will require more time to review these materials of 2 hours. This estimate is consistent with that assumed for the review of other types of consumer outreach and public education materials.
    Determine additional activities for PWSs not meeting their goal-based rate (hrs_consult_fail_js). Primacy Agencies will also incur burden to determine needed activities for CWSs serving more than 10,000 people with a TLE that fail to meet their goal-based replacement requirements. EPA assumed Primacy Agencies will incur a burden of 2 hours per system (hrs_consult_fail_js). EPA assumed this consultation burden is similar to that used for other activities and is based on the estimated burden for systems to consult with their Primacy Agency on public education activities from pg. 60 of the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (USEPA, 2007).
    To estimate total costs for this activity, EPA multiplied the burden by the estimated number of systems that fail to meet their LSLR goal. For modeling purposes, 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 of 1 to 5 percent with a most likely value of 2.5 percent (pp_lsl_replaced_vol_pct). For each system in the goal-based program, the SafeWater LCR model randomly selects a replacement rate from this distribution and when the rate is less than 2 percent, the Primacy Agency will incur burden to determine additional activities for PWSs.
    Review annual LSLR program report (hrs_report_lcr_js). Primacy Agencies will incur annual burden to review systems' reports on their LSL mandatory and goal-based program, their replacement schedule, location of LSLs replaced, customer outreach, and post-LSLR sampling. Exhibit 5-176 provides the estimated burden associated with this review. Note that EPA estimated a larger burden for CWSs than NTNCWSs because NTNCWSs have fewer LSLs. Refer to Sections <IP_ADDRESS> and <IP_ADDRESS> for an estimate of the number of LSLs for CWSs and NTNCWSs, respectively, by system size.
   Exhibit 5-176: Primacy Agency Burden to Review System's Annual LSLR Report (hrs per system)
                                 System Size
                              (Population Served)
                                     CWSs
                                    NTNCWSs

                  SafeWater cost input ID: hrs_report_lcr_js

                                       A
                                       B
<=3,300
                                                                            0.5
                                                                            0.5
3,301-10,000
                                                                              1
                                                                            0.5
10,001-100,000
                                                                              2
                                                                            0.5
>100,000
                                                                              4
                                                                            0.5
   Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system.
   Source: "Derivation of LSLR Ancillary Costs_Final Rule.xlsx."

Exhibit 5-177 provides the SafeWater LCR model costing approach including additional cost inputs that are required to calculate the total costs.
Exhibit 5-177: Primacy Agency Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity[1][,2]
Primacy Agency Cost Per Activity for CWSs
Primacy Agency Cost Per Activity for NTNCWSs
Conditions for Cost to Apply to a Primacy Agency
Frequency of Activity

Lead 90[th] - Range
Other Conditions

    Assist with LSL inventory development and review inventory for PWSs with LSLs
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_inventory_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
All
Primacy Agencies with any model PWSs without LSLs that has not previously submitted documentation
p_lsl; 1 - p_inventory
One Time
    Review information from PWSs that have no LSLs
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_rev_nolsl_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
All
Primacy Agencies with any model PWSs with LSLs without an existing inventory

p_lsl; 1 - p_inventory
One Time
    Provide templates for general LSL outreach materials
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_pe_lsl_gen_temp_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
All
Primacy Agencies with any model PWSs with LSLs

p_lsl
One Time
    Review general LSL outreach materials
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_pe_lsl_rev_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
All
Primacy Agencies with any model PWSs with LSLs

p_lsl
One Time
    Review updates to LSL inventory
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_inv_update_rev_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
All
Primacy Agencies with any model PWSs with LSLs

p_lsl
Once a year
    Review LSLR plan and negotiate goals
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_lslr_plan_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
All
Primacy Agencies with any model PWSs with LSLs

p_lsl
One Time
    Provide targeted LSLR program outreach templates and consult with PWS
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_temp_lslr_out_js*rate_js)
Cost does not apply to Primacy Agencies for NTNCWSs.
At or below AL and above TL
Primacy Agencies with any model PWSs participating in the goal-based LSLR programs

p_lsl
One Time
    Review targeted outreach materials
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_review_targeted_pe_js*rate_js)
Cost does not apply to Primacy Agencies for NTNCWSs.
At or below AL and above TL
Primacy Agencies with any model PWSs participating in the goal-based LSLR programs

p_lsl
One Time

    Determine additional activities for PWSs not meeting their goal-based rate
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_consult_fail_js*rate_js)
Cost does not apply to Primacy Agencies for NTNCWSs.
At or below AL and above TL
Primacy Agencies with any model PWSs that do not meet their goal-based replacement rate

p_lsl;
(num_lsl_replace / num_lsl_base) < pp_lsl_replaced_vol_goal
Once a year
    Review annual LSLR program report
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_report_lcr_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
Above TL
Primacy Agencies with any model PWSs participating in the goal-based or mandatory LSLR programs

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 the following:
 num_lsl_replace: total number of LSLs replaced each year (see <IP_ADDRESS>, activity g)).
 num_lsl_base: baseline number of LSLs (see Section 4.3.4).
 p_inventory: Likelihood a system has complete its service line inventory in advance of the rule (Section <IP_ADDRESS>, activity a)).
 p_lsl: Likelihood a system has LSLs (Section 4.3.4).
 rate_js: Primacy Agency hourly labor rate (Section <IP_ADDRESS>).
[2] As previously discussed in Section <IP_ADDRESS>, in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the state pays for the cost of bottles and shipping and conducting the analysis for samples following LSLR. Thus, the state will incur the burden and cost for these activities.
Primacy Agency POU Related Costs
Primacy Agencies will incur both one-time and ongoing burden to conduct oversight activities related to systems' POU programs. As previously discussed in Section 3.2.2, CWSs serving 10,000 or fewer people above the TL and NTNCWSs with a lead 90[th] percentile above the TL must evaluate and recommend to their Primacy Agency which compliance alternative they would implement if they have a future lead ALE that can include POU device installation and maintenance. Primacy Agency activities and associated SafeWater LCR model cost inputs for one-time and ongoing activities are described in Sections <IP_ADDRESS> and <IP_ADDRESS>, respectively.
One-Time POU Program Costs
EPA has developed costs for three one-time Primacy Agency activities related to POU program oversight as shown in Exhibit 5-178. The exhibit provides the unit burden for each activity. The assumptions used in the estimation of the unit burdens follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-178: Primacy Agency One-Time POU-Related Burden Estimates
                                   Activity
                                  Unit Burden
                          SafeWater LCR Data Variable
    Review POU plan
89 to 164 hrs/CWS serving <= 10,000;
74 to 194 hrs/NTNCWSs
hrs_pou_plan_rev_js
Provide templates for POU outreach materials
0.25 to 0.5 hrs/PWS serving <= 10,000
hrs_temp_pou_js
Review POU PE materials
0.5 hrs/CWS serving <= 10,000;
0.5 to 2 hrs/NTNCWSs
hrs_review_pe_pou_js
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system; PE = public education; POU = point-of-use; PWS = public water system.
Source:
a): "Derivation of POU Inputs_Final Rule.xlsx."
b) & c): "Derivation of Public Education Inputs_CWS_Final Rule.xlsx";  "Derivation of Public Education Inputs_NTNCWS_Final Rule.xlsx."
Notes:
a) - c): Primacy Agencies will only conduct these activities for the subset of CWS serving <=3,300 people and NTNCWSs that have a TLE or lead ALE without a prior TLE and for which POU provision and maintenance is their approved lead compliance option.

 Review POU plan (hrs_pou_plan_rev_js). As previously stated in Section <IP_ADDRESS>, the rule does not explicitly require systems to prepare a POU plan. However, EPA assumed systems would prepare a plan and Primacy Agencies would incur burden to review water systems' POU plans. These assumptions are made given the desire in the EA to capture all reasonable costs incurred by the impacted entities and the high likelihood that Primacy Agencies will want to have oversight on the human health protective actions being taken by a system in response to high lead samples at households. The SafeWater LCR model assumes that these plans are developed by CWSs serving 10,000 or fewer people and NTNCWSs that meet the following criteria: 1) have no CCT, 2) have a lead ALE, and 3) POU provision and maintenance is their approved compliance option. EPA assumed that Primacy Agency burden to review the plan is 50 percent of the PWS burden to prepare the plan (hrs_pou_plan_dev_op). The Primacy Agency burden is provided in Exhibit 5-179. See Section <IP_ADDRESS>, activity b) for assumptions used to estimate the PWS burden. EPA estimates NTNCWSs on average will have more taps that will require POU devices than CWSs and thus they will require additional burden to develop the plan and for the Primacy Agency to review the plan.
Exhibit 5-179: Estimated Hours for Primacy Agency Review of POU Plan (hrs/system)
                                  System size
                              (Population Served)
                                     CWSs
                                    NTNCWSs

               SafeWater LCR Data Variable: hrs_pou_plan_rev_js

                                       A
                                       B
<=500
                                                                             89
                                                                             74
501-3,300
                                                                            164
                                                                            114
3,301 to 10,000
                                                                            164
                                                                            114
10,001-50,000
                                                                            N/A
                                                                            194
50,001-1,000,000
                                                                           N/A
                                                                            114
>1,000,000
                                                                           N/A

Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system; POU = point-of-use.
Source: "Derivation of POU Inputs_Final Rule.xlsx."
Notes:
A: EPA assumed Primacy Agencies will incur 50 percent of the burden as to review the plan as for water systems to prepare the plan (see data variable hrs_pou_plan_dev_op in Section <IP_ADDRESS>, activity b)).
B: No NTNCWSs serves more than 1 million people; thus, the burden for this size category is 0. EPA estimates that NTNCWSs serving 10,001 - 50,000 people have the highest estimated number of taps, will have a higher burden to prepare the POU plan, and Primacy Agencies will require additional burden to review the plan. See "Derivation of POU Inputs_Final Rule.xlsx" for the approach for estimating the required number of POU devices.

 Provide templates for POU outreach materials (hrs_temp_pou_js). EPA assumed that Primacy Agencies will provide templates to CWSs serving 10,000 or fewer people and NTNCWSs to develop POU outreach materials that describe the POU program and proper use of the POU devices. EPA assumed Primacy Agencies will incur a one-time burden of 0.25 to 0.5 hours to provide these templates based on responses to an ASDWA survey regarding the burden to provide revised sampling instruction templates from North Carolina and Indiana of 0.25 and 0.5 hours, respectively.  The questionnaire and each state's responses are available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
 Review POU PE materials (hrs_review_pe_pou_js). CWSs serving 10,000 or fewer people with a lead ALE that selected the POU option must provide PE on the use of POU device to all households they serve. NTNCWSs must provide this outreach to the consumers they serve. EPA estimated that Primacy Agencies will incur a one-time burden to review these PE materials of 0.5 hours for CWSs serving 10,000 or fewer people and NTNCWSs serving 50,000 or fewer. EPA assumed Primacy Agencies would require 2 hours to review these materials for NTNCWSs serving more than 50,000 people.
 Exhibit 5-181 in Section <IP_ADDRESS> provides the SafeWater LCR model approach including additional cost inputs that are required to calculate the total costs.
Ongoing POU Program Costs
EPA has developed costs for three ongoing Primacy Agency activities related to POU program oversight as shown in Exhibit 5-180. The exhibit provides the unit burden for each activity. The assumptions used in the estimation of the unit burdens follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-180: Primacy Agency Ongoing POU-Related Burden Estimates
                                   Activity
                                  Unit Burden
                          SafeWater LCR Data Variable
Review sample invalidation request for POU monitoring
2 hrs/request
hrs_samp_invalid_js
Review customer notification certifications
0.33 to 0.5/certification
hrs_cert_cust_lt_js
Review annual POU program report
0.5 hrs/CWS serving <= 10,000 people;
0.5 to 4 hr/NTNCWS
hrs_pou_report_ann_rev_js
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system; POU = point-of-use.
Sources:
d) & e): "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx."
f): "Derivation of POU Inputs_Final Rule.xlsx."

 Review sample invalidation request for POU monitoring (hrs_samp_invalid_js). Systems must sample one-third of locations with POU devices annually. For CWSs, all households must have POU devices, so sampling must occur at one third of households. The number of households per system is estimated as the retail population (pws_pop) divided by the total number of households per system (numb_hh). For NTNCWSs, the number of POUs is equivalent to the number of taps used for drinking water consumption. See Section <IP_ADDRESS> for additional details and values for these inputs. EPA assumed that 0.6 percent of samples will be invalidated, consistent with the assumption for other compliance tap sampling (pp_samp_invalid). See Section <IP_ADDRESS>.2, activity e) for additional information. EPA assumed Primacy Agencies will require 2 hours per sample invalidation request based on a 2016 ASDWA questionnaire. The questionnaire and each state's responses are available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
    Review customer notification certifications (hrs_cert_cust_lt_js). As discussed in Section <IP_ADDRESS> the burden for Primacy Agencies to review each system's certification that monitoring results were reported to customers is 0.33 hours to 0.5 hours and is based on North Carolina and Indiana's estimates for this review, respectively, in response to a 2016 ASDWA questionnaire. EPA assumed this review has the same burden regardless of whether the lead tap sample is collected at a site with or without a POU device and thus used the same data variable and input. The questionnaire and each state's responses are available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
    Review annual POU program report (hrs_pou_report_ann_rev_js). Primacy Agencies will incur burden to review a system's annual report on its POU program that includes monitoring results and may include corrective actions and routine maintenance activities. EPA estimated that Primacy Agencies will incur 50 percent of the burden to review the plan as assumed for the system to prepare the plan (hrs_pou_report_ann_prep_op). See Exhibit 5-181 for the estimated burden to review POU reports for CWSs and NTNCWSs.
Exhibit 5-181: Primacy Burden to Review Annual POU Program Report (hours/system
                                  System size
                              (Population Served)
                                     CWSs
                                    NTNCWSs

             SafeWater Cost Model Input: hrs_pou_report_ann_rev_js

                                       A
                                       B
<=3,300
                                                                            0.5
                                                                            0.5
3,301-10,000
                                                                              1
                                                                              1
10,001-50,000
                                                                            N/A
                                                                              2
50,001-100,000
                                                                            N/A
                                                                              2
100,001-1,000,000
                                                                            N/A
                                                                              4
>1,000,000
                                                                            N/A

Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system.
Source: "Derivation of POU Inputs_Final Rule.xlsx."
Notes:
A & B: Estimated as 50 percent of system burden to prepare the report (hrs_pou_report_ann_prep_op). See Section <IP_ADDRESS>, activity m) for details. No NTNCWSs serves more than 1 million people. Thus, the burden for this size category is 0.

Exhibit 5-182 provides the SafeWater LCR model costing approach for POU-related activities a) through f) including additional cost inputs that are required to calculate the total costs.
Exhibit 5-182: Primacy Agency POU Cost Estimation in SafeWater LCR (by Activity)[1][,2]
Primacy Agency Cost Per Activity for CWSs
Primacy Agency Cost Per Activity for NTNCWSs
Conditions for Cost to Apply to a Primacy Agency
Frequency of Activity

Lead 90[th]  -  Range
Other Conditions

Review POU plan
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_pou_plan_rev_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
Above TL
Primacy Agencies with model PWSs installing POU devices or conducting a POU plan
One time
    Provide templates for POU outreach materials
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_temp_pou_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
Above TL
Primacy Agencies with model PWSs installing POU devices or conducting a POU devices
One time
    Review POU PE materials
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_review_pe_pou_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
Above AL
Primacy Agencies with any model PWSs installing POU devices

One time
    Review sample invalidation request for POU monitoring
One third of households per system where the sample is determined to be invalid (assume one sample per household) multiplied by the hours per sample per system and the Primacy Agency labor rate.

(((1/3)*(pws_pop/numb_hh)*pp_samp_invalid)*(hrs_samp_invalid_js*rate_js)
One third the number of POU devices per system where the sample is determined to be invalid (assume one sample per POU device) multiplied by the hours per sample per system and the Primacy Agency labor rate.

(((1/3)*numb_pou)*pp_samp_invalid)*(hrs_samp_invalid_js*rate_js)
All
Primacy Agencies with any model PWSs installing POU devices

Once a year
    Review customer notification certifications
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_cert_cust_lt_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs
All
Primacy Agencies with any model PWSs installing POU devices
Once a year
    Review annual POU program report
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_pou_report_ann_rev_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs
All
Primacy Agencies with any model PWSs installing POU devices
Once a year
Acronyms: AL = action level; CWS = community water system; NTNCWS = non-transient non-community water system; POU = point-of-use; 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:
 numb_pou: Number of POU devices per PWSs that elects POU option (Section <IP_ADDRESS>).
 pp_samp_invalid: Likelihood that a lead sample will be deemed invalid (Section <IP_ADDRESS>.2, activity e)).
 rate_js: Primacy Agency hourly labor rate (Section <IP_ADDRESS>).
[2] As previously discussed in Section <IP_ADDRESS>, in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the state pays for the cost of bottles and shipping and conducting the analysis for samples following LSLR. Thus, the state will incur the burden and cost for these activities.

Primacy Agency Public Education-Related Costs
Primacy Agencies will incur burden to conduct oversight and review activities related to the public education requirements of the LCRR. These activities are broadly grouped into those: related to a consumer notice in response to a single lead sample above 15 ug/L that are independent of a system's lead 90[th] percentile level and conducted in response to a lead ALE. These activities and associated costs are detailed in Sections <IP_ADDRESS> through <IP_ADDRESS>, respectively.
Note that Primacy Agency public education activities associated with general LSL outreach and targeted outreach were previously discussed in Section <IP_ADDRESS>. Primacy Agency public education activities associated with the POU program were previously discussion in Section 5.4.5.
Consumer Notice in Response to a Lead Sample > 15 ug/L
EPA has developed Primacy Agency costs related to a system's 3 day calendar consumer notice in response to a lead sample above 15 ug/L, as shown in Exhibit 5-183. The exhibit provides the unit burden. The assumptions used in the estimation of the unit burden follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-183: PWS Burden for Consumer Notification When Sample is > 15 ug/L
                                   Activity
                                  Unit Burden
                          SafeWater LCR Data Variable
 Review copy of the 3 calendar day notice when sample exceeds 15 ug/L
0.08 hrs/customer contact
hrs_above_15_notice_js
Source: "Derivation of Public Education Inputs_CWS_Final Rule.xlsx."

    Review a copy of the 3 calendar day notice when sample exceeds 15 ug/L (hrs_above_15_notice_js). EPA assumed Primacy Agencies will incur a burden of 5 minutes or 0.08 hours to review a copy of the 3 calendar day notice that systems must provide to consumers if their sample exceeds 15 ug/L.
Activities Regardless of the Lead 90[th] Percentile Level
EPA has developed system costs for activities associated with new public education requirements under the LCRR that are independent of a system's lead 90[th] percentile status, as provided in Exhibit 5-184. The exhibit provides the unit burden. The assumptions for the unit burden follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-184: Primacy Agency Burden for Public Education Activities that Are Independent of Lead 90[th] Percentile Levels
                                   Activity
                                  Unit Burden
                          SafeWater LCR Data Variable
Provide templates for updated CCR language (one-time)
0.25 to 0.5 hrs/CWS
hrs_temp_ccr_js
Provide templates for state and local health departments lead outreach
0.25 to 0.5 hrs/CWS
hrs_pub_temp_hc_js
Review lead outreach materials for state and local health departments
0.5 to 2 hrs/CWS
hrs_pub_rev_hc_js
Participate in joint communication efforts with state and local health departments
1 hr/CWS
hrs_hc_js
Review PE materials for service line disturbances
0.5 to 2 hrs/CWS with LSLs
hrs_review_wtr_pe_js
Acronyms: CCR = consumer confidence report; CWS = community water system; LSL = lead service lines; PE = public education.
Sources:
b) - f): "Derivation of Public Education Inputs_CWS_Final Rule.xlsx."

    Provide templates for updated CCR language (hrs_temp_ccr_js). EPA assumed that Primacy Agencies will provide templates to CWSs to update their CCR language to include the revised mandatory health effects language and for those with LSLs to further update their materials to include information about the system's LSLR program and opportunities to replace LSLs. EPA assumed Primacy Agencies will incur a one-time burden of 0.25 to 0.5 hours to provide these templates. These estimates are based on responses to an ASDWA survey regarding the burden to provide revised sampling instruction templates from North Carolina and Indiana of 0.25 and 0.5 hours, respectively. This estimate is the same as the estimated burden to provide the sampling template (hrs_rev_samp_js) as discussed in Section <IP_ADDRESS>, activity a). The questionnaire and each state's responses are available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.

    Provide templates for state and local health departments lead outreach (hrs_pub_temp_hc_js). EPA assumed Primacy Agencies will incur a one-time burden to provide templates to CWSs to develop outreach materials that will be sent to state and local health departments. EPA assumed Primacy Agencies will incur a one-time burden of 0.25 to 0.5 hours to provide these templates. These estimates are based on responses to an ASDWA survey regarding the burden to provide revised sampling instruction templates from North Carolina and Indiana of 0.25 and 0.5 hours, respectively. This estimate is the same as the estimated burden to provide the sampling template (hrs_rev_samp_js) as discussed in Section <IP_ADDRESS>, activity a). The questionnaire and each state's responses are available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.

    Review lead outreach materials for state and local health departments (hrs_pub_rev_hc_js). EPA estimated that Primacy Agencies will incur a one-time burden to review PE material developed by CWSs that is described in activity c). EPA assumed systems serving 50,000 or fewer people will use the template with minor changes. Thus, Primacy Agencies will require minimal time to review the PE materials of 0.5 hours per system. Systems serving more than 50,000 people will adapt the template and Primacy Agencies will require more time to review these materials of 2 hours per system.
    Participate in joint communication efforts with state and local health departments (hrs_hc_js). Primacy Agencies will incur annual burden to participate in joint communication efforts with CWSs to provide lead PE to health departments annually. EPA assumed that water systems would have the major role in this activity, but Primacy Agencies would provide support to develop joint letters to be sent to state and local health departments of 1 hour per system.
    Review PE materials for service line disturbances (hrs_review_wtr_pe_js). EPA estimated that Primacy Agencies will incur a one-time burden to review PE material developed by CWSs with LSLs for delivery during scheduled water-related work. EPA assumed systems serving 50,000 or fewer people will use the template with minor changes. Thus, Primacy Agencies will require minimal time to review the PE materials of 0.5 hours per system. Systems serving more than 50,000 people will adapt the template and Primacy Agencies will require more time to review these materials of 2 hours per system.
Exhibit 5-186 in Section <IP_ADDRESS> provides details on how costs are calculated for PWS public education activities a) through i) including additional cost inputs that are required to calculate these costs.
Public Education Activities in Response to Lead ALE
EPA has developed Primacy Agency costs for activities associated with public education requirements in response to a lead ALE as provided in Exhibit 5-185. The exhibit provides the unit burden. The assumptions for the unit burden follow the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font.
Exhibit 5-185: Primacy Agency PE Burden in Response to Lead ALE
                                   Activity
                                  Unit Burden
                          SafeWater LCR Data Variable
Provide template and review revised lead language (one-time)
0.5 to 2 hrs/CWS or NTNCWS
hrs_ale_lang_js
Consult with CWS on other PE activities in response to a lead ALE
2 hrs/CWS
hrs_ale_consult_js
Review PE certifications
CWSs
1 to 1.5 hrs/CWS

NTNCWSs
0.33 to 0.5 hr/NTNCWS
CWSs
hrs_pe_certify_quarterly_js

NTNCWSs
hrs_cert_outreach_annual_js
Acronyms: ALE = action level exceedance; CWS = community water system; NTNCWS = non-transient non-community water system; PE = public education.
Sources:
g): "Derivation of Public Education Inputs_CWS_Final Rule.xlsx"; "Derivation of Public Education Inputs_NTNCWS_Final Rule.xlsx."
h) & i): "Derivation of Public Education Inputs_CWS_Final Rule.xlsx."

g) 	Provide template and review revised lead language (hrs_ale_lang_js). The LCRR requires systems with a lead ALE to update the mandatory health effects language and those with LSLs to further update their materials to include information about their LSLR program and opportunities for customers to replace LSLs. Primacy Agencies will incur one-time burden to provide templates and review each system's revised public education mandatory language in materials that are delivered when a system has a lead ALE. EPA assumed the same burden to provide a template and review PE language that is used for other types of PE. Specifically, systems serving 50,000 or fewer people will use the template with only very minor changes and Primacy Agencies will require 0.5 hrs/system for their review. Systems serving more than 50,000 people will adapt template and Primacy Agencies will require more time to review these materials of 2 hours per system.
 h) 	Consult with CWS on other PE activities in response to a lead ALE (hrs_ale_consult_js). Primacy Agencies will consult with CWSs on other required PE activities conducted in response to a lead ALE and will incur a burden of 2 hours per CWS. This assumption is based on the estimate for systems to consult with their Primacy Agency on public education activities used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (USEPA, 2007).
 i) 	Review PE certifications (hrs_pe_certify_quarterly_js, hrs_cert_outreach_annual_js). Primacy Agencies will review each system's certification that they have met their public education and outreach requirements including any done in response to a lead ALE. CWSs have quarterly, semi-annual, and annual public education requirements in response to a lead ALE (see Section 3.8.1 for detailed requirements). Thus, CWSs must report the certification on a quarterly basis. EPA estimated an average 0.33 and 0.5 hours to review public education certifications under the previous rule based on data from North Carolina and Indiana, respectively, in response to an ASDWA survey about LCR implementation. These estimates were multiplied by 0.75 to account for quarters where there is less information to report on the self-certification. Then the numbers were multiplied by four to account for the quarterly frequency of the self-certification letter. EPA assumed that the review of each certification for systems serving 50,000 or fewer people would require 0.33 hours or 1 hour annually (based on the lower burden reported from North Carolina) and 0.5 hours/certification or 1.5 hours annually for CWSs serving more than 50,000 people (based on the higher burden reported from Indiana). As previously discussed in Section <IP_ADDRESS>, NTNCWSs do not have quarterly public education requirements in response to a lead ALE and submit an annual certification only hrs_cert_outreach_annual_js. The questionnaire and each state's responses are available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov.
   Note as previously discussed in Section <IP_ADDRESS>, EPA assumed that a system's certification would not only include any outreach conducted in response to a lead ALE but also include lead consumer notice that is conducted in response to a sample exceeding 15 ug/L and other outreach activities that are independent of a system's lead 90[th] percentile level.
Exhibit 5-186 provides details on how total costs for the LCRR are calculated these activities including additional cost inputs that are required to calculate the total costs.
Exhibit 5-186: Primacy Agency Lead Public Education Cost Estimation in SafeWater LCR (by Activity)[1][, 2]
Primacy Agency Cost Per Activity for CWSs
Primacy Agency Cost Per Activity for NTNCWSs
Conditions for Cost to Apply to a Primacy Agency
Frequency of Activity

Lead 90[th] - Range
Other Conditions

    Review copy of the 3 calendar day notice when sample exceeds 15 ug/L
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_above_15_notice_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
All
All Primacy Agencies
Once per event
    Provide templates for updated CCR language
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_temp_ccr_js*rate_js)
Cost does not apply to Primacy Agencies for NTNCWSs.
All
All Primacy Agencies
One time
    Provide templates for state and local health departments lead outreach
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_pub_temp_hc_js*rate_js)
Cost does not apply to Primacy Agencies for NTNCWSs.
All
All Primacy Agencies
One time
    Review lead outreach materials for state and local health departments
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_pub_rev_hc_js*rate_js)
Cost does not apply to Primacy Agencies for NTNCWSs.
All
All Primacy Agencies
One time
    Participate in joint communication efforts with local health departments

The hours per system multiplied by the Primacy Agency labor rate.

(hrs_hc_js*rate_js)
Cost does not apply to Primacy Agencies for NTNCWSs.
All
All Primacy Agencies
Once per year
    Review PE materials for service line disturbances
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_review_wtr_pe_js*rate_js)
Cost does not apply Primacy Agencies for NTNCWSs.
All
Primacy Agencies with any model PWSs with LSLs

p_lsl
One time
    Provide template and review revised lead language
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_ale_lang_js*rate_js)
Cost applies as written to Primacy Agencies for NTNCWSs.
Above AL
All Primacy Agencies
One time
    Consult with CWS on other PE activities in response to lead ALE[3]
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_ale_consult_js*rate_js)
Cost does not apply to Primacy Agencies for NTNCWSs.
Above AL
All Primacy Agencies
Once a year
    Review PE certifications
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_pe_certify_quarterly_js*rate_js)
The hours per system multiplied by the Primacy Agency labor rate.

(hrs_cert_outreach_annual_js*rate_js)
Above AL
All Primacy Agencies
Once per year[4]
Acronyms: AL = action level; ALE = action level exceedance; CCR = consumer confidence report; CWS = community water system; LSL = lead service line; NTNCWS = non-transient non-community water system; PE = public education; PWS = public water system.
Notes:
[1] Primacy Agency oversight burden and costs for systems with LSLs with the exception of those associated with service line disturbances and implementing the POU program are included  in Sections 5.4.4 and <IP_ADDRESS>, respectively.
[2] 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).
 rate_js: Primacy Agency hourly labor rate (Section <IP_ADDRESS>).
[3] Primacy Agencies can discontinue these activities when the system no longer has a lead ALE for one monitoring period.
[4] Primacy Agencies will review certifications quarterly for CWSs that are providing PE in response to a lead ALE. For modeling purposes, the Primacy Agency burden is estimated on an annual basis.
Summary of Primacy Agency Costs
The estimated national annualized Primacy Agency costs for the final rule, under the low cost scenario, are $25,852,000 at a 3 percent discount rate and $26,949,000 at a 7 percent discount rate. The Primacy Agency costs of the final rule for the high cost scenario are $27,893,000 discounted at 3 percent and $29,645,000 discounted at 7 percent. The incremental costs range from $19,707,000 to $20,756,000 at a 3 percent discount rate and from $20,876,000 to $22,216,000 at a 7 percent discount rate, under the low and high cost scenarios respectively (see Exhibit 5-1 and Exhibit 5-2).
Costs and Ecological Impacts Associated with Additional Phosphate Usage
Adding phosphate to LSLs creates a protective inner coating on pipes that can inhibit lead leaching. However, once phosphate is added to the PWS, some of this incremental loading remains in the water stream as it flows into WWTPs downstream. This generates treatment costs for certain WWTPs. In addition, at those locations where treatment does not occur, water with elevated phosphorus concentrations may discharge to water bodies and induce certain ecological impacts.
Estimating the Costs of Increased Phosphorus Loadings
Incremental phosphorus loading to wastewater treatment plants
When PWSs add orthophosphate to their finished water for corrosion control purposes, some portion of the orthophosphate added will reach downstream WWTPs. To estimate the potential fate of the orthophosphate added at PWSs, EPA developed a conceptual mass balance model, shown in Exhibit 5-187. EPA applied this conceptual model to estimate the increase in loading at WWTPs (G in Exhibit 5-187), given an initial loading from corrosion control at water treatment plants (A in Exhibit 5-187). In applying the model, EPA used the assumptions shown in Exhibit 5-188 regarding the other sources and losses of phosphorus (B through F in Exhibit 5-187).
Exhibit 5-187: Phosphorus Mass Balance Conceptual Model

Exhibit 5-188: Summary of Assumptions Used in Estimating Phosphorus Loading Increase
Phosphorus Source or Loss
Assumptions Used
Loss Due to Incorporation in Distribution System Scale (B)
Assumed 0 percent based on data that P accounted for very little of the total mass of the scale formed during pipe loop testing (Benjamin et al., 1990); this assumption results in a conservative estimate of the incremental loading (i.e., erring on the side of greater loading).
Loss to Distribution System Leaks and Breaks (C)
Average = 57.42 gpd/connection; Warm Climate = 53.64 gpd/connection; Cold Climate = 78.52 gpd/connection (Chastain-Howley et al., 2013).[1]
Loss to Outdoor or Other Uses (D)
Average = 30 percent (USEPA, 2008b); Warm Climate = 67%; Cold Climate = 22% (Mayer et al., 1999).[2]
Baseline Residential Loading (E)
Not used; relevant only to calculating total loading, not incremental loading.
Loss to Sewer System Leaks and Overflows (F)
Assumed 0 percent based on an estimate that that losses due to sewer overflows and misconnections are relatively small (Comber et al., 2013); this assumption results in a conservative estimate of the incremental loading (i.e., erring on the side of greater loading).
Acronyms: P = phosphorus; gpd = gallons per day.
Notes:
[1] With respect to temperature, systems were classified as one of two categories depending on whether their location had an average annual temperature above or below 50°F (10°C).
[2] Warm climate value reflects the upper bound of outdoor use reported for cities in hot climates; cold climate value reflects the lower bound of outdoor use reported for cities in a cooler, wetter climates.
Specifically, EPA adapted the conceptual mass balance model and the assumptions, shown in Exhibit 5-187 and Exhibit 5-188, respectively into Equation 1, and applied this equation in SafeWater LCR model to estimate the incremental WWTP loading resulting from adding upstream orthophosphate at each affected drinking water treatment plant.
Equation 1:
      Pincremental=0.775xAverage FlowxPO4 Dose-0.061xConnections x PO4 Dose
Where:
      Pincremental = incremental WWTP loading in pounds per year measured as phosphorus
      Average Flow = drinking water system average flow in thousand gallons per year
      PO4 Dose = incremental orthophosphate dosage in milligrams per liter (mg/L) as PO4
      Connections = drinking water system number of connections
The equation above incorporates the colder climate assumptions from Chastain-Howley et al. (2013) and Mayer et al. (1999). Colder climates have greater losses to leaks and break, but a lower percentage of losses of outdoor use. Warmer climates show the opposite pattern. The equation uses the colder climate assumptions because, in combination, these assumptions result in an overall larger estimated loading increases than the warm climate or average climate assumptions.
Incremental phosphorus removal costs at wastewater treatment plants
WWTPs could incur costs because of upstream orthophosphate addition if they have permit discharge limits for phosphorus parameters. Exhibit 5-189 shows data from EPA's national pollutant discharge elimination system (NPDES) on the status of WWTPs with respect to permit limits for phosphorus.
Exhibit 5-189: WWTP Status with Respect to Phosphorus Discharge Permit Limits
Year
Total Number of WWTPs
Number of WWTPs with Phosphorus Permit Limits
Percentage of WWTPs with Phosphorus Permit Limits
2007
14,593
1,436
9.8%
2016
15,387
2,027
13.2%
Source: Based on data from EPA's Discharge Monitoring Report (DMR) "EZ Search" using search criteria limiting results to the phosphorus parameter group and WWTPs only. Includes 50 states, the District of Columbia, and 5 territories.

As shown in Exhibit 5-189, the percentage of WWTPs with phosphorus limits has increased over time. From 2007 to 2016, in annual percentage rate terms, the growth rate in the percentage of WWTPs with phosphorus limits is 3.3 percent, calculated as follows:
13.2%9.8%1/9-1
EPA assumed this increase would continue as states transition from narrative to numerical nutrient criteria and set numeric permits limits, especially for impaired waters. EPA applied the growth rate observed from 2007 to 2016 to estimate the anticipated percentage of WWTPs with phosphorus limits in future years. EPA estimated the percentage anticipated for a given year using Equation 2. EPA calculated the estimated percentage for each year of the analysis and applied these percentages in the SafeWater LCR model as discussed below.
Equation 2:
%Y=%2016x(1+Rate)(Y-2016)
Where:
      Y = specific year being estimated
      %Y = percentage of WWTPs anticipated to have phosphorus discharge limits in year Y
      %2016 = percentage of WWTPs with phosphorus discharge limits in 2016, or 13.2%
      Rate = historical annual percent growth rate observed from 2007 to 2016, or 3.3%
Note that Equation 2 results in an estimated 41 percent of WWTPs with phosphorus discharge limits after 35 years. Applied as the percentage of WWTPs that need to take treatment actions, this estimate is likely conservative particularly given the potential availability of alternative compliance mechanisms, such as, individual facility variance and nutrient trading programs.
The specific actions a WWTP might need to take to maintain compliance with its NPDES phosphorus limit will depend on the type of treatment present at the WWTP and the corresponding phosphorus removal provided (if any). Assuming a phosphorus permit limit of 1 mg/L (as Total P)  -  the most common limit observed in the source data for Exhibit 5-189  -  it is likely that most of the WWTPs that already have phosphorus limits have some type of treatment to achieve the limit. Technologies for phosphorus removal from wastewater include the following (Jiang et al., 2004; USEPA, 2013; Rodgers, 2014):
 enhanced biological processes (e.g., those that rely on phosphate accumulating organisms);
 chemical precipitation;
 adsorptive media;
 membrane processes;
 various emerging or innovative technologies; and
 treatment trains that combine one or more of the above.
Some treatment processes can accommodate incremental increases in influent loading and still maintain their removal efficiency. Examples include enhanced biological processes (assuming they are not limited by influent biological oxygen demand) and membrane processes. Such processes might not require significant adjustment to maintain their existing phosphorus removal efficiency, given an incremental increase.
Other treatment processes can require modification to their design or operation to maintain their removal efficiency in the face of an influent loading increase. A specific example is chemical precipitation, in which the dosage of chemical(s) added (e.g., ferric chloride, alum) is directly proportional to the influent phosphorus concentration. If influent loading increases, treatment trains relying on chemical precipitation would need to add more chemicals to maintain their efficiency of phosphorus removal.
Data are not available to identify the specific WWTPs that might be affected by increased orthophosphate loading or the burden associated with the phosphorus removal technologies in place at these WWTPs. Therefore, EPA estimated costs by assuming that, on average, these costs would be similar to costs for a WWTP that uses ferric chloride for chemical precipitation to maintain 90 to 98 percent removal, and that has sufficient existing capacity to accommodate the increase in phosphorus loading.
Specifically, EPA used the assumptions shown in Exhibit 5-190 to derive a unit cost of $4.59 per pound of phosphorus for removing incremental phosphorus. This unit cost includes the cost of additional chemical consumption and the operating cost of additional sludge processing and disposal. This unit cost will overestimate costs for WWTPs that do not require significant operational adjustment to maintain their existing phosphorus removal efficiency. That would include, for example, WWTPs using enhanced biological processes that are not limited by biological oxygen demand. The unit cost, however, assumes that existing chemical feed, solids separation, and sludge management equipment has sufficient capacity. Therefore, it will underestimate costs for WWTPs that need to expand their treatment process capacity or install additional treatment to handle the increased loading.
Exhibit 5-190: Summary of Assumptions Used in Estimating Phosphorus Removal Unit Cost
Assumption
Value Used
Sources
Unit cost for ferric chloride
$0.11 per pound of bulk solution
Average of vendor bids in Fredrick County (2014) and Bi-state Commission (2014), escalated to 2016 dollars using Bureau of Labor Statistics Producer Price Index for industrial chemicals
Ferric chloride solution concentration
40%
Consistent with vendor bids in Frederick County (2014) and Bi-state Commission (2014)
Ferric chloride solution bulk density
11.85 pounds per gallon
Consistent with 40% ferric chloride solution concentration; used to convert vendor bids in Bi-state Commission (2014)
Molar ratio required for phosphorus removal
2 moles iron per mole of phosphorus
A molar ratio of 1.5 to 2:1 (iron-to-phosphorus) can achieve an 80 to 98% reduction in soluble phosphorus per USEPA (2010)
Unit cost for sludge processing and disposal
$336 per dry ton
Average of actual sludge management costs reported in Stamford Water Pollution Control Authority (WPCA) (2013), City of Seabrook (2016), Sloan et al. (2008), Center for Rural Pennsylvania (2007), escalated to 2016 dollars using the consumer price index
Sludge production factor
10 grams per gram of phosphorus removed
USEPA (2010)

Finally, the costs a WWTP could incur depend on the magnitude of the loading increase relative to the specific WWTP's effluent permit limit. WWTPs whose current discharge concentrations are closer to their limit are more likely to have to take action. However, WWTPs whose current concentrations are well below their limit could incur costs if, for example:
 They are currently achieving their limit using a P removal technology.
 The P removal provided by that technology is significant.
 The P removal achieved by technology is sensitive to incremental P loading increases (e.g., chemical phosphorus removal).
Furthermore, future phosphorus limits could be more stringent than existing limits.
Therefore, EPA assumed that any WWTP with a discharge limit for phosphorus parameters could incur costs. Accordingly, in calculating costs in the SafeWater LCR model, EPA used the anticipated percentage of WWTPs with phosphorus discharge limits, calculated as shown in Equation 2, as the likelihood that incremental orthophosphate loading from a drinking water system would reach a WWTP with a limit. EPA combined this likelihood and the unit cost estimated above with incremental phosphorus loading to calculate incremental costs to WWTPs for each year of the analysis period. This calculation is equivalent to that shown in Equation 3.
Equation 3:
Incremental CostY=%YxUnit CostxPincremental
Where:
      Incremental CostY = incremental cost to WWTPs in year Y
      %Y = percentage of WWTPs anticipated to have phosphorus discharge limits in year Y, calculated as shown in Equation 2
      Unit Cost = incremental cost of treatment per pound of phosphorus, or $4.59 per pound
      ∑Pincremental = incremental WWTP loading in pounds per year measured as total phosphorous from all affected drinking water treatment plants
As shown in Exhibit 5-1 and Exhibit 5-2, the incremental annualized cost that WWTPs will incur to remove additional phosphorous associated with the final LCRR ranges from $1.2M to $1.8M at a 3 percent discount rate, and $1.5M to $2.6M at a 7 percent discount rate.
Ecological Impacts of Phosphorus Loadings
The ecological impacts of increased phosphorous loadings are highly localized: total phosphorus loadings will depend on the amount and timing of the releases, characteristics of the receiving water body, effluent discharge rate, existing total phosphorus levels, and weather and climate conditions. Unfortunately, detailed spatially explicit information on effluents and on receiving water bodies does not exist in a form suitable for this analysis. Rather, to evaluate the potential ecological impacts of the rule, EPA developed approximate, national-level total phosphorous loading estimates, and evaluated the significance of the loadings compared to other phosphorous sources in the terrestrial ecosystem.
Incremental total phosphorus loadings in water bodies
The SafeWater LCR model, using Equation 1 described above, estimated the total incremental phosphorus loadings to reach WWTPs under the final LCRR. Exhibit 5-191 provides the estimated total and increase in phosphorus loadings nationally for selected years after the final LCRR goes into effect under the low cost scenario. Exhibit 5-192 provides the same information for the high cost scenario.
Exhibit 5-191: Nationwide Annual Phosphorus Reaching WWTPs after Implementation of the Final LCRR under Low Cost Scenario

                      Thousands of Pounds of Phosphorous

                                                                         Year 0
                                                                         Year 5
                                                                        Year 15
                                                                        Year 25
                                                                        Year 35
Previous LCR
                                                                        14,010
                                                                        14,010
                                                                        14,327
                                                                        14,399
                                                                        14,474
Final LCRR

                                                                        14,010
                                                                        14,716
                                                                        15,016
                                                                        15,330
Increase Under Previous LCR

                                                                           -
                                                                           317
                                                                           389
                                                                           464
Increase under Final LCRR

                                                                           -
                                                                           706
                                                                         1,006
                                                                         1,320
Incremental Increase over Previous LCR

                                                                           -
                                                                           389
                                                                           617
                                                                           855

Exhibit 5-192: Nationwide Annual Phosphorus Reaching WWTPs after Implementation of the Final LCRR under High Cost Scenario

                      Thousands of Pounds of Phosphorous

                                                                         Year 0
                                                                         Year 5
                                                                        Year 15
                                                                        Year 25
                                                                        Year 35
Previous LCR
                                                                        14,040
                                                                        14,040
                                                                        15,179
                                                                        15,240
                                                                        15,310
Final LCRR

                                                                        14,040
                                                                        16,499
                                                                        16,792
                                                                        17,049
Increase Under Previous LCR

                                                                           -
                                                                         1,139
                                                                         1,200
                                                                         1,270
Increase under Final LCRR

                                                                           -
                                                                         2,459
                                                                         2,752
                                                                         3,009
Incremental Increase over Previous LCR

                                                                           -
                                                                         1,321
                                                                         1,552
                                                                         1,739

EPA then adjusted these values for the expected treatment of influent at WWTPs. Based on the Clean Watersheds Needs Survey, about 50 percent of facilities (36 percent of flow) have secondary water treatment and 34 percent of facilities (57 percent of flow) have greater than secondary treatment (USEPA, 2012b) that will reduce the amount of phosphorus reaching waterbodies. Estimates suggest that secondary treatment may remove 20 to 75 percent of total phosphorus and greater than secondary treatment may remove 90 to 95 percent (Metcalf and Eddy, 2003; Grady, 2011; USEPA, 2015c) of the phosphorus reaching waterbodies. Thus, EPA conservatively estimates that 36 percent of flow will experience a 20 percent reduction in total phosphorus and 57 percent of the flow will experience a 90 percent reduction of total phosphorus, generating a flow-weighted average reduction in total phosphorus levels of about 58.5 percent. Using these assumptions, EPA estimated the amount of total phosphorus that is expected to enter receiving waterways nationally as a result of the previous and final rules under the low cost assumptions (Exhibit 5-193) and high cost assumptions (Exhibit 5-194).
Exhibit 5-193: Nationwide Annual Phosphorus Reaching Waterbodies after Implementation of the Final LCRR under Low Cost Scenario

                      Thousands of Pounds of Phosphorous

                                                                         Year 0
                                                                         Year 5
                                                                        Year 15
                                                                        Year 25
                                                                        Year 35
Previous LCR
                                                                         5,812
                                                                         5,812
                                                                         5,944
                                                                         5,973
                                                                         6,004
Final LCRR

                                                                         5,812
                                                                         6,105
                                                                         6,229
                                                                         6,359
Increase Under Previous LCR

                                                                           -
                                                                           132
                                                                           161
                                                                           193
Increase under Final LCRR

                                                                           -
                                                                           293
                                                                           417
                                                                           547
Incremental Increase over Previous LCR

                                                                           -
                                                                           161
                                                                           256
                                                                           355

Exhibit 5-194: Nationwide Annual Phosphorus Reaching Waterbodies after Implementation of the Final LCRR under High Cost Scenario

                      Thousands of Pounds of Phosphorous

                                                                         Year 0
                                                                         Year 5
                                                                        Year 15
                                                                        Year 25
                                                                        Year 35
Previous LCR
                                                                         5,824
                                                                         5,824
                                                                         6,297
                                                                         6,322
                                                                         6,351
Final LCRR

                                                                         5,824
                                                                         6,845
                                                                         6,966
                                                                         7,073
Increase Under Previous LCR

                                                                           -
                                                                           472
                                                                           498
                                                                           527
Increase under Final LCRR

                                                                           -
                                                                         1,020
                                                                         1,142
                                                                         1,248
Incremental Increase over Previous LCR

                                                                           -
                                                                           548
                                                                           644
                                                                           722

To put these phosphorus loadings in context, estimates from the United States Geological Survey (USGS) SPAtially Referenced Regression On Watershed attributes (SPARROW) model suggest that anthropogenic sources deposit roughly 750 million pounds of total phosphorus per year (USEPA, 2019b). Under the high cost scenario, this additional phosphorous loading is small, less than 0.1 percent (722,000/ 750,000,000) of the total phosphorous load deposited annually from all other anthropogenic sources.
Of course, national average load impacts may obscure significant localized ecological impacts. The existing data do not allow an assessment as to whether this incremental load will induce ecological impacts in particular areas; however, localized impacts may occur in water bodies without restrictions on phosphate deposits, or in locations with existing elevated phosphate levels. The next section describes potential ecological impacts that could occur in receiving water bodies.
Ecological impacts of potential increases in phosphate loadings
Aquatic organisms rely on some amount of essential nutrients, including nitrogen and phosphorous, for growth and survival. In many aquatic ecosystems, phosphorous is the limiting nutrient, therefore controlling the growth rate (USEPA, 2016b). Discharging excess phosphorous into waterbodies can therefore stimulate excess plant and algae growth and, under certain circumstances, impose create undesirable ecological impacts. Phosphorous in the environment can persist longer periods of time relative to nitrogen. Sediment-bound phosphorous can persist unchanged and, when re-suspended back to the water column, can pose renewed threats. Localized conditions will enhance or dissipate phosphorous problems.
In particular, nutrient pollution causes eutrophication -- that is, excessive plant and algae growth -- in lakes, reservoirs, streams, and estuaries throughout the United States. According to EPA's 2012 National Lakes Assessment, 40 percent of lakes in the United States have excess phosphorus (USEPA, 2016b). EPA's 2008-2009 National Rivers and Streams Assessment found that 40 percent of river and stream miles have nutrient pollution (USEPA, 2016c). Eutrophication, by inducing primary production, leads to seasonal decomposition of additional biomass, consuming oxygen and creating a state of hypoxia, or low oxygen, within the water body. In extreme cases, the low to no oxygen states can create dead zones, or areas in the water where aquatic life cannot survive. Studies indicate that eutrophication can decrease aquatic diversity for this reason (e.g., Dodds et al., 2009).
Eutrophication may also stimulate the growth of harmful algal blooms (HABs), or over-abundant algae populations. Algal blooms can seriously harm the aquatic ecosystem by blocking sunlight and creating diurnal swings in oxygen levels as a result of overnight respiration. Such conditions can starve and deplete aquatic species. In addition, rapid photosynthesis may consume dissolved inorganic carbon and elevate pH (Chislock et al., 2013). Certain types of phosphorous-fueled algal blooms, such as cyanobacteria, also produce toxins to both humans and aquatic life. These toxins include microcystins (liver toxins) and neurotoxins. This issue is particularly prevalent in lakes or other slow-flowing water bodies. HAB events have directly or indirectly contributed to fish kill events by causing the absorption or ingestion of toxins, or by creating conditions of limited sunlight and oxygen (Glibert et al., 2005).
Finally, an increase in phosphorus loadings can lead to significant economic impacts and undesirable aesthetic impacts. Research estimates significant economic costs of eutrophication, including recreation and angling costs and property value costs (Dodds et al., 2009). Aesthetic impacts such as reduced water clarity and an increase in foul-smelling odors may also arise, making water unsuitable for recreational activities such as swimming, boating, and fishing (Dodds et al., 2009). Phosphorus additions can also reduce the non-use (e.g., option, existence or bequest value) value of the water resource.
References
Association of State Drinking Water Administrators (ASDWA). 2020a. Costs of States Transactions Study (CoSTS) for EPA's Proposed LCRR. February 6, 2020.
ASDWA. 2020b. States LCRR Compliance Monitoring Costs 03172020. May 17, 2020.
Benjamin, M.M., S.H. Reiber, J.F. Ferguson, E.A. Vanderwerff, and M.W. Miller. 1990. Chemistry of Corrosion Inhibitors in Potable Water. American Water Works Association Research Foundation.
Bi-state Commission. 2014. 2015 Water Treatment Chemicals - October 29, 2014 - Bid opening.
Center for Rural Pennsylvania. 2007. Biosolids Disposal in Pennsylvania. November.
Chastain-Howley, A., G. Kunkel, W. Jernigan, and D. Sayers. 2013. Water loss: The North American dataset. Journal AWWA 105(6): 57-60.
Chislock, M.F., E. Doster,  R.A. Zitomer, and A.E. Wilson. 2013. Eutrophication: Causes, consequences, and controls in aquatic ecosystems. Nature Education Knowledge 4(4):10.
City of Seabrook. 2016. Agenda Briefing: Bid Award for Disposal of Municipal Sludge Project 2016-05. 11 April.
Comber, S., M. Gardner, K. Georges, D. Blackwood, and D. Gilmour. 2013. Domestic source of phosphorus to sewage treatment works. Environmental Technology 34(9-12):1349-1358.
Cornwell, D.A, R.A. Brown, and S.H Via. 2016. National Survey of Lead Service Line Occurrence. Journal AWWA. 108(4):E182-E191.
Dodds, W.K., W.W. Bouska,  J.L. Eitzmann,  T.J. Pilger,  K.L. Pitts,  A.J. Riley,  J.T. Schloesser, and D.J. Thornbrugh. 2009. Eutrophication of U.S. freshwaters: Analysis of potential economic damages. Environmental Science Technology 43(1):12-19.
Environmental Defense Fund and American University School of Public Affairs. 2020. Lead Pipes and Environmental Justice: A Study of Lead Pipe Replacement in Washington, DC. March 2020. https://www.edf.org/sites/default/files/u4296/LeadPipe_EnvironJustice_AU%20and%20EDF%20Report.pdf?utm_source=presentation&utm_campaign=edf-health_none_upd_hlth&utm_medium=referral&utm_id=1597699006.
Frederick County. 2014. Executive Summary, Mayor and Board of Aldermen, Re: Bid #14-135 (Chemicals for Water Supply and Wastewater Treatment). 29 May.
Glibert, P.M., D.M. Anderson, P. Gentien, E. Graneli, and K.G. Sellner. 2005. The global, complex phenomena of harmful algal blooms. Oceanography 18(2):136-147.
Grady, C.P.L. 2011. Biological Wastewater Treatment. 3rd Edition.
IntelliTech Systems, Inc. 2010. SafeWater CBX Model Peer Review.
Jiang, F., M.B. Beck, R.G. Cummings, K. Rowles, and D. Russell. 2004. Estimation of Costs of Phosphorus Removal in Wastewater Treatment Facilities: Construction De Novo. Water Policy Working Paper #2004-010. June.
LSLR Collaborative. Identifying Service Line Material. https://www.lslr-collaborative.org/identifying-service-line-material.html.
Mayer, P.W., W.B. DeOreo, E.M. Opitz, J.C. Kiefer, W.Y. Davis, B. Dziegielewski, and J.O. Nelson. 1999. Residential End Uses of Water. American Water Works Association Research Foundation.
Metcalf and Eddy. 2003. Wastewater Engineering: Treatment and Reuse. 4th Edition.
Rodgers, M. 2014. Impact of Corrosion Control on Publicly Owned Treatment Works. Presented at American Water Works Association Water Quality Technology Conference. New Orleans, Louisiana. November 16-20.
Sandvig, A., P. Kwan, P.E., G. Kirmeyer, P.E., Dr. B. Maynard, Dr. D. Mast, Dr. R. R. Trussell, P.E., Dr. S. Trussell, P.E., A. Cantor, P.E., MCSD, and A. Prescott. 2008. Contribution of Service Line and Plumbing Fixtures to Lead and Copper Rule Compliance Issues. Denver, Colo.: Awwa Research Foundation. Peer reviewed by AwwaRF Project Advisory Committee.
Sloan, D.S., R.A. Pelletier, and M. Modell. 2008. Sludge management in the City of Orlando - It's supercritical. Florida Water Resources Journal June:46-54.
Stamford Water Pollution Control Authority (WPCA). 2013. Memorandum to SWPCA Board, Re: Sludge Drying and Disposal. 7 January.
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: 2010. http://www.census.gov/hhes/families/data/cps2010.html.
United States Census Bureau. 2016. 2015 American Community Survey. https://www.census.gov/acs/www/data/data-tables-and-tools/data-profiles/2015/.
United States Environmental Protection Agency (USEPA). 1991. Final Regulatory Impact Analysis of National Primary Drinking Water Regulations for Lead and Copper. April 1991. Office of Water.
USEPA. 2006a. Economic Analysis for the Final Ground Water Rule. October 2006. Office of Water. EPA 815-R-06-014.
USEPA. 2006b. Point-of-Use or Point-of-Entry Treatment Options for Small Drinking Water Systems. April 2006. Office of Water. EPA 815-R-06-010.
USEPA. 2007. Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule. September 2007. Office of Water. EPA-815-R0-7022.
USEPA. 2008a. Lead and Copper Rule: Public Education & Other Public Information Requirements for Community Water Systems. June 2008. Office of Water. EPA-816-F-08-019. https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=60001O8Y.txt.
USEPA. 2008b. Indoor Water Use in the United States. June 2008. EPA-832-F-06-004.
USEPA. 2009. 2006 Community Water System Survey.  February 2009. Office of Water. EPA 815-R-09-001. https://www.epa.gov/dwreginfo/community-water-system-survey.
USEPA. 2010. Nutrient Control Design Manual. Office of Research and Development, National Risk Management Research Laboratory - Water Supply and Water Resources Division. EPA/600/R‐10/100. August.
USEPA. 2012a. Technology and Cost Document for the Final Revised Total Coliform Rule. Office of Water. EPA-815-R-12-005. December 2012. https://beta.regulations.gov/document/EPA-HQ-OW-2008-0878-0299.
USEPA. 2012b. Economic Analysis for the Final Revised Total Coliform Rule. Office of Water. EPA 815-R-12-004. September 2012. Available at https://nepis.epa.gov/Exe/ZyPDF.cgi/P100PIVO.PDF?Dockey=P100PIVO.PDF.
USEPA. 2013. Emerging Technologies for Wastewater Treatment and In-Plant Wet Weather Management. EPA 832-R-12-011. March 2013.
USEPA. 2015a. Public Water System Supervision Program Information Collection Request (ICR) (Renewal). October 2015. https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201510-2040-001.
USEPA. 2015b. Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules Information Collection Request (Renewal). December 2015. https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201511-2040-001.
USEPA. 2015c. Case Studies on Implementing Low-Cost Modifications to Improve Nutrient Reduction at WWTPs. Draft report. 147 p.
USEPA. 2016a. EPA Letter to Governors and State Environment and Public Health Commissioners. February 29, 2016. https://www.epa.gov/dwreginfo/epa-letter-governors-and-state-environment-and-public-health-commissioners.
USEPA. 2016b. National Lakes Assessment 2012: A Collaborative Survey of Lakes in the United States. https://www.epa.gov/sites/production/files/2016-12/documents/nla_report_dec_2016.pdf.
USEPA. 2016c. National Rivers and Streams Assessment 2008-2009 Fact Sheet. https://www.epa.gov/sites/production/files/2016-03/documents/fact_sheet_draft_variation_march_2016_revision.pdf.
USEPA. 2018. 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities: A Training, Testing, and Taking Action Approach (Revised Manual). October 2018. Office of Water. EPA 815-B-18-007. https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water-toolkit.
USEPA. 2019a. Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primacy Agencies and Public Water Systems. March 2016 (Updated 2019). Office of Water. EPA 816-B-16-003. https://www.epa.gov/dwreginfo/optimal-corrosion-control-treatment-evaluation-technical-recommendations.
USEPA. 2019b. Estimated Total Nitrogen and Total Phosphorus Loads and Yields Generated within States. Retrieved from: https://www.epa.gov/nutrient-policy-data/estimated-total-nitrogen-and-total-phosphorus-loads-and-yields-generated-within.
USEPA. 2020. Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water. July 2020. Office of Water.
Benefits Resulting from the Lead and Copper Rule Revisions
Introduction
Lead is a highly toxic pollutant that can damage neurological, cardiovascular, immunological, developmental, and other major body systems (USEPA, 2013). Children are at higher risk from the effects of lead than adults, due to differences in physiology and behavior (USEPA, 2013).
Similarly, although copper is essential to normal physiology, its excess intake is also associated with several adverse health outcomes (NRC, 2000). Most commonly, excess exposure to copper leads to gastrointestinal symptoms such as nausea, vomiting, and diarrhea (NRC, 2000). In children with genetic disorders or predispositions to accumulate copper, chronic exposure to non-physiological levels of this element can result in liver damage.
Due to these serious adverse effects, the Lead and Copper Rule revisions (LCRR) are expected to lead to reduced exposures and thus significant health benefits, which are described in this chapter and associated appendices. Some of these benefits are expressed in monetary terms. Section 6.2 presents data on the reduction of lead levels in water as a result of two interventions: 1) the removal of lead service lines (LSLs) and 2) the introduction of corrosion control treatment (CCT). Section 6.3 discusses the assignment of drinking water concentrations to public water system (PWS) populations. Sections 6.4 and 6.5 focus on the benefits of line removal and corrosion control interventions.
Appendices D - K contain additional information on the effects of lead and copper exposure, and the potential benefits of interventions in the LCRR. While only the estimated benefits of avoided intelligence quotient (IQ) loss in children are quantified in this chapter, numerous other adverse health effects are associated with exposures to lead, many at low doses. Appendix D provides more detailed information on the six categories of health effects that the United States Environmental Protection Agency (EPA or the Agency) and the National Toxicology Program (NTP) have deemed to be associated with lead exposures: cardiovascular effects, renal effects, reproductive and developmental effects, immunological effects, neurological effects, and cancer. Also, the adverse health effects associated with copper are summarized in Appendix E. At sufficient exposures, copper has been associated with gastrointestinal effects in the general population and with liver toxicity in susceptible individuals. EPA anticipates that these adverse health effects will also be reduced due to the rule, but they are not explicitly quantified in this analysis. Appendix F presents additional information on the water lead modeling; and Appendix G provides information on children's blood lead modeling, IQ estimates, and valuation for children up to age 7. Appendix H presents a sensitivity analysis on the blood lead estimates provided in this chapter for adults, looking at alternative models. Appendix I provides blood lead estimates and discusses additional endpoints that might potentially be quantified for children once peer reviewed. Appendix J provides more detail on studies used to develop concentration response functions between blood lead level (BLL) and IQ loss, and studies EPA may consider using to relate blood lead to other adverse endpoints after the methodologies are peer reviewed. Appendix K provides further detail on the literature and methodologies behind the value of an IQ point, which is described in Section 6.4.4.
Baseline and Post-Rule Drinking Water Lead Exposures
This section discusses methods for estimating baseline (i.e., current) and post-rule exposures to lead through drinking water. EPA used the lead concentration of water drawn from the kitchen tap to estimate exposure through drinking water under each of the potential CCT and LSL scenarios. No national level dataset exists that incorporates sufficient detail regarding these scenarios, so EPA obtained datasets from multiple sources. This combined dataset has limitations, such as varying sampling methods and locations. EPA managed these limitations, first through data cleaning, coding, model fitting, and selection. EPA subsequently used this model to produce a simulated dataset of lead concentrations under the different scenarios used to control for variation in the combined dataset to the extent possible.
To estimate drinking water lead concentrations at the tap, EPA obtained and assessed tap water lead concentration data from utilities, EPA's regional offices and Office of Research and Development, and authors of published journal articles. These data include information about sampling methods, locations, dates, and LSL status. EPA further divided the lead tap concentration records into CCT categories based on the locations and dates of samples, and known treatment and finished water quality histories. EPA combined these sources to produce a dataset (described in Section 6.2.1) for further analysis (Section 6.2.2). EPA then fit a model to these data and subsequently used the fitted model to simulate representative lead concentrations in PWSs. The resulting simulated dataset of the tap sample lead concentrations was used to estimate BLL (Section 6.2.3; Stanek et al., 2020).
Ideally, to determine the potential lead tap concentrations under the various CCT and LSL scenarios, a researcher would analyze the variation of lead concentrations in tap samples nationwide across the defined scenarios. However, due to the nature of the available data, EPA's lead concentration data were collected from different locations, with different methods, over multiple decades, and for different purposes. Therefore, the interpretation of what is driving the tap sample lead concentration variation within and across CCT and LSL scenarios becomes complicated. A good deal of the variation in the lead concentration data may be due to the use of different sample collection methodologies and unequal numbers of repeated samples in the same time and place. Therefore, rather than using summary statistics from the original data directly, EPA undertook a detailed analysis to understand the effects of the LSL and CCT scenarios while statistically controlling for data collection artifacts that may have contributed to variation in measurements of lead concentration at the tap (Sections 6.2.1 and 6.2.2).
EPA implemented the following analyses of the aggregate dataset and made adjustments to the data to enhance the quality. After compiling the water lead concentration dataset, EPA statistically modeled the relationship of LSLs and CCT with lead concentrations at the tap (Section 6.2.2). This model also related lead concentration to the amount of water that had flowed from the tap after stagnation. Additionally, EPA incorporated methods to estimate the effects of different water systems, residences, and sampling events at the same residence. EPA incorporated terms into the model for the amount of water, city water system, and residence to control for data collection artifacts from different studies, as most cities were linked to a single study per city water system (Exhibit 6-1). EPA similarly controlled for differences among sampling events in the same homes and within studies.
The fitted model demonstrates that LSL status and CCT both affect lead concentration at the tap. The presence of an LSL is associated with higher lead concentrations. In homes with any LSL (full or partial), improved CCT is associated with lower lead concentrations. CCT has less of an effect in homes with no LSL present. Assessment showed that seven combinations (i.e., scenarios) of LSL status and CCT had predicted concentrations that were sufficiently distinct to warrant separate predictive modeling. These seven scenarios were used to produce estimates of drinking water concentration. EPA also used information from the statistical model to simulate estimates of lead concentration for the fifth cumulative one-liter volume drawn from a household tap after stagnation (Section 6.2.3). This represents the average cumulative sample volume after stagnation for samples in the original dataset, and is therefore analogous to the central tendency of the original dataset, statistically controlling across interventions for profile liter, city, site, and sampling event to produce comparable estimates. The fifth liter, on average, is representative of a liter drawn near the lead concentration peak in water from an LSL and where lead concentrations differed the most among the different scenarios. This volume would be drawn from the tap roughly 30 - 45 seconds after starting the tap at a flow rate of 2 gal/min.
Throughout this document, EPA uses a standard terminology to describe LSL status and CCT implementation. "LSL" indicates lead service lines are present, "partial" indicates some presence of lead in service lines (i.e., partial replacement), and "no LSL" indicates no LSLs. For CCT, "none" indicates no CCT, "partial" represents systems that have some CCT in place but are not optimized, and "representative" indicates a water chemistry that exemplifies the best CCT currently in use (which can include some combination of higher phosphate values or optimized pH levels). Water lead concentration prediction intervals overlapped completely for all CCT scenarios in homes with no LSL (described in Section 6.2.3), so "combined" indicates pooled CCT estimates representing all three states of CCT in non-LSL households. Further details are provided in Section 6.3.
Drinking Water Lead Concentration Profile Data
EPA combined data from multiple sources for use in estimating lead concentration at the tap based on LSL status and CCT implementation. These data represented 18,039 samples collected from 1,638 homes in 15 cities representing 14 city water systems across the United States and Canada (Exhibit 6-1). Data included lead concentrations and information regarding LSL status, location, and date of sample collection from seven municipal water systems in the United States and eight in Canada between 1998 and 2016. EPA chose to include data from Canada because data from the United States were limited or nonexistent for certain types of sites, such as sites without corrosion control after LSL removal or homes with LSLs but no CCT. Overall, geometric mean concentrations were similar in the two countries (described in Section <IP_ADDRESS>), although there were not enough overlapping data to compare the geometric means for all combinations of LSL and CCT status.
Exhibit 6-1: Tap Water Lead Concentration Sample Data: Source Citations, City Water System, LSL and CCT Status Represented in the Data Source, and Number of Individual Sample Bottles per Source*
                          Citation of Data Source[a]
                City Water System Represented by Data Source[b]
                     LSL Status of Samples by Data Source
                           CCT Status by Data Source
                   Total Number of Samples by Data Source[c]
Camara et al., 2013
Halifax, NS
LSL, No LSL, Partial
Partial[d]
                                      16
The Cadmus Group, Inc., 2007
Washington, D.C.
LSL, Partial
Partial
                                      969
Campbell, 2016
Ottawa, ON
LSL, Partial
Representative
                                     5,149
Commons, 2011
Providence, RI d
LSL, Partial
Partial
                                      169
Commons, 2014
Providence, RI d
Partial
Partial
                                      40
Craik, 2016
Edmonton, AB
LSL, No LSL, Partial
None
                                      967
Del Toral et al., 2013
Chicago, IL
LSL
Representative
                                      695
Del Toral, 2016
Flint, IL
LSL, No LSL
Partial, Representative
                                     3,678
Deshommes et al., 2016
Montreal, QC
LSL, No LSL, Partial
None
                                      630
Desmarais et al., 2015
London, ON
LSL, Partial
None
                                     1,430
EPCOR Water Services, 2008
Edmonton, AB
LSL
None
                                      107
Hayes et al., 2014
Calgary, AB
LSL, No LSL
None
                                      144
Muylwyk, 2016
Guelph, ON
LSL, No LSL, Partial
None
                                     1,039
O'Brien & Gere, 2015
Providence, RI d
LSL, Partial
Partial
                                      158
DC Water, 2016
Washington, D.C.
LSL, No LSL, Partial
Representative
                                     1,391
Schock, 2016
Sebring, OH
LSL
Partial, None
                                      825
Estes-Smargiassi et al., 2006
Boston, MA
LSL, Partial
Representative
                                      50
Swertfeger et al., 2006
Desmarais et al., 2015
Triantafyllidou et al., 2015
Cincinnati, OH
LSL, No LSL, Partial
Partial, Representative
                                      582
* The full analytical dataset is provided in Docket # EPA HQ-OW-2017-0300 "Combined Lead Profile Data.xlsx."
[a] Some of these citations contain data from multiple studies, including previously published and unpublished data.
[b] Some of these cities represent places where corrosion control levels changed in the same location over time, or where LSLs were replaced.
c The number of samples is the number of individually measured water samples (i.e., bottles). The number of profile sampling events is shown in Section <IP_ADDRESS>.
[d] Cincinnati before 2006; Halifax and Providence/Cranston water systems were revised from "Representative" CCT to "Partial" CCT based on public comment as well as peer review of Stanek et al., 2020. These changes were applied to all of the following figures and tables.
Lead Concentration Profiles
Most data sources contained series, or "profiles," of water samples that were drawn from the same kitchen tap after a whole-house stagnation period. Exhibit 6-2 shows the general sampling process as it relates to portions of home plumbing, service line, and the connection to the city water main. In general, the water in water mains does not contain lead. Water can become contaminated during stagnation by lead leaching from LSL and home plumbing containing lead. When the tap is turned on and water is drawn after stagnation, lead concentrations may show peaks based on the amount and location of lead-bearing plumbing materials in contact with the water between the tap and the water main. In other words, there may be considerable variation in lead concentration measured in water samples drawn from a tap after a stagnation period; this variation decreases as non-stagnant water from the main reaches the tap. Taps have different flow rates, and the volume of water rather than the length of time was used to account for the position in tap sampling series.
A "complete" profile includes consecutive measurements taken from the tap, through any peaks in lead concentration, to a point where the lead concentration in water shows little to no further decrease. Exhibit 6-3 displays an example of a complete profile of lead in tap water. Most of the primary data sources, representing the 14 city water systems, contain profiles of varying levels of completeness (Exhibit 6-4 and Exhibit 6-5). However, the sources also incorporate data regarding sample volume and position in the profile series for each individual sample. EPA used this information to calculate the "profile liter" variable (Section 6.2.2) to control for variability in differences in profile position and volume among samples within the fitted model and the following simulation.
Although these data represent a large portion of available data, they may not be nationally representative with respect to the following factors: water chemistry and corrosion control practices; service line length, materials, and scales; size, type, and location of internal piping and lead sources; the type and number of residences with LSLs; and the relative contribution of particulate lead. These data also do not incorporate water usage patterns within a home that could affect exposure, such as dishwasher use, laundry, and showering. Some usage patterns may flush water lines and reduce exposure to stagnant water through drinking and cooking. The following sections describe how EPA cleaned the data; coded and fit models to control for some of the variation in the existing dataset due to water system, site, and sampling methods; and produced simulated values for use in BLL estimation.
Exhibit 6-2: Diagram Showing Plumbing Where Water Can Become Contaminated with Lead

Shows a profile of multiple, one-liter samples. Although mixing occurs, the earliest samples drawn after stagnation are representative of water in fixtures and home plumbing, while those that follow represent water from service lines, and finally, the water main.
Exhibit 6-3: Example of a Complete Consecutive Liter Profile of Lead Concentrations in Tap Water from a Location with a Lead Service Line

Note: Lead concentration is elevated in the first liter, lower in the second through third liters, highest from the fourth to sixth liters, and zero after the seventh liter. Red dots represent lead (Pb) concentration plotted at the midpoint of the cumulative volume of each sample ("profile liter"). The widths of the horizontal bars indicate the total volume of each sample. These samples were from a residence with an LSL and representative CCT in Providence, RI.
Data Cleaning
EPA cleaned and combined the datasets listed in Exhibit 6-1 by removing duplicate records, records without water lead concentration values, and records that did not meet the criteria for inclusion in the profile dataset. Only samples of known volume after stagnation periods of at least 30 minutes were included in the profile data. Samples that were collected immediately after flushing events were generally excluded, unless the flushing volume had also been recorded. Samples from known locations other than kitchen taps, such as exterior spigots, were also excluded from the data. Concentration records for homes that underwent partial or full lead service line replacements (LSLRs) occasionally included a number of post-replacement sampling profile series collected over several months to years after service line replacement. In these cases, lead concentrations typically declined over subsequent sampling periods, as residual lead in household plumbing was flushed. As there were too few cases of this post-replacement sampling in the dataset to incorporate this effect in models, only the last profile after LSLR was included in the analysis dataset. If elapsed time after an LSLR could not be determined for the post-replacement samples, all samples after LSLR were included, which may increase the observed variability in estimates of concentration after LSLR. An outlier for a site in Washington, D.C., was removed after confirming with the data provider (personal communication, DC Water, Maureen Schmelling, May 2017) that the sample was unlikely to be representative of concentrations in most homes. Other cases with concentrations higher or lower than expected for particular CCT and LSL categories did not have clear reasons to exclude them, such as suspect sample collection conditions or obvious particulate lead. These values were included for the integrity of the dataset.
Before producing summary statistics or fitting models using the profile dataset, EPA set all known lead non-detects to 0.1 ug/L, and then log-transformed the lead concentrations. The summary tables in Exhibit 6-4 and Exhibit 6-5 reflect the data cleaning steps, and a more detailed description can be found in Appendix F, Section F.1.
Exhibit 6-4 and Exhibit 6-5 show the geometric mean, standard deviation (SD), and maximum lead concentration for each combination of CCT and LSL status in the cleaned data after log-transformation of lead concentrations for all 18,039 samples included in the model. Notes regarding data cleaning and categorization for specific datasets are contained in Appendix F, Section F-1. Exhibit 6-5 provides summary statistics by LSL and CCT status from the existing data, ignoring differences in city water system, site, sampling event, and study sampling volume methodology.

Exhibit 6-4: Summary Statistics for Tap Water Lead Concentrations by LSL and CCT Status Combinations, Country, and Citation
                                      LSL
                                      CCT
                                    Country
                                  Citation[a]
                          Geometric Mean Lead (ug/L)
                               Geometric SD Lead
                       Arithmetic Mean
Profile Liter[b]
                          Arithmetic SD Profile Liter
                               Number of Samples
                              Number of Profiles
                                Number of Sites
                                      LSL
                                     None
                                      USA
Schock, 2016
                                                                          26.84
                                                                           1.13
                                                                           5.87
                                                                           4.29
                                                                             15
                                                                              1
                                                                              1

                                      CND
Craik, 2016
                                                                          15.35
                                                                           2.50
                                                                           4.95
                                                                           3.52
                                                                            194
                                                                             26
                                                                             20

Deshommes et al., 2016
                                                                          26.87
                                                                           2.14
                                                                           3.99
                                                                           2.80
                                                                            309
                                                                             69
                                                                             27

Desmarais et al., 2015
                                                                          16.43
                                                                           2.21
                                                                           4.00
                                                                           2.29
                                                                          1,062
                                                                            133
                                                                             11

EPCOR Water Services, 2008
                                                                          21.45
                                                                           1.93
                                                                           3.87
                                                                           3.26
                                                                            107
                                                                             26
                                                                             11

Hayes et al., 2014
                                                                          14.55
                                                                           1.71
                                                                           6.00
                                                                           3.47
                                                                            120
                                                                              5
                                                                              5

Muylwyk, 2016
                                                                          16.63
                                                                           2.56
                                                                           1.00
                                                                           0.50
                                                                            248
                                                                            124
                                                                            123
                                      LSL
                                    Partial
                                      USA

The Cadmus Group Inc., 2007
                                                                           9.81
                                                                           3.30
                                                                          11.95
                                                                           7.82
                                                                            895
                                                                             41
                                                                             36

Commons, 2011
                                                                          14.60
                                                                           2.70
                                                                           7.81
                                                                           4.78
                                                                            121
                                                                              8
                                                                              8

Del Toral, 2016
                                                                           2.71
                                                                           4.41
                                                                           5.60
                                                                           4.23
                                                                          2,068
                                                                            137
                                                                             91

O'Brien & Gere, 2015
                                                                          14.77
                                                                           2.99
                                                                           1.77
                                                                           2.14
                                                                            133
                                                                             46
                                                                              7

DC Water, 2016
                                                                           6.17
                                                                           3.16
                                                                           8.48
                                                                           5.55
                                                                            205
                                                                             13
                                                                              6

Schock, 2016
                                                                           6.89
                                                                           2.49
                                                                           5.93
                                                                           4.28
                                                                            810
                                                                             53
                                                                             14

Swertfeger et al., 2006; Desmarais et al., 2015; Triantafyllidou et al., 2015
                                                                          10.47
                                                                           1.96
                                                                           0.38
                                                                           0.00
                                                                             91
                                                                             91
                                                                             21

                                      CND
Camara et al., 2013
                                                                          16.30
                                                                           1.93
                                                                           2.00
                                                                           1.20
                                                                              8
                                                                              2
                                                                              2
                                      LSL
                                Representative
                                      USA
Del Toral et al., 2013
                                                                           8.00
                                                                           2.03
                                                                           6.19
                                                                           3.70
                                                                            695
                                                                             57
                                                                             32

Del Toral, 2016
                                                                           2.81
                                                                           3.07
                                                                           6.50
                                                                           4.73
                                                                          1,270
                                                                             80
                                                                             47

DC Water, 2016
                                                                           3.05
                                                                           3.34
                                                                           6.74
                                                                           4.12
                                                                            839
                                                                             64
                                                                             52

Estes-Smargiassi et al., 2006
                                                                           5.23
                                                                           2.28
                                                                           3.03
                                                                           2.78
                                                                             25
                                                                              2
                                                                              2

Swertfeger et al., 2006; Desmarais et al., 2015; Triantafyllidou et al., 2015
                                                                           1.38
                                                                           4.01
                                                                           3.55
                                                                           2.70
                                                                            303
                                                                             46
                                                                             12

                                      CND
Campbell, 2016
                                                                           1.89
                                                                           3.57
                                                                           2.15
                                                                           1.35
                                                                          4,997
                                                                          1,205
                                                                            639
                                    Partial
                                     None
                                      USA
None
                                                                            ---
                                                                            ---
                                                                            ---
                                                                            ---
                                                                            ---
                                                                            ---
                                                                            ---

                                      CND
Craik, 2016
                                                                           6.81
                                                                           5.71
                                                                           1.96
                                                                           1.13
                                                                            451
                                                                            122
                                                                            116

Deshommes et al., 2016
                                                                          12.71
                                                                           2.04
                                                                           4.76
                                                                           3.26
                                                                            248
                                                                             40
                                                                             40

Desmarais et al., 2015
                                                                          10.00
                                                                           2.06
                                                                           4.00
                                                                           2.29
                                                                            368
                                                                             46
                                                                              4

Muylwyk, 2016
                                                                           7.53
                                                                           4.86
                                                                           1.00
                                                                           0.50
                                                                            341
                                                                            171
                                                                            169
                                    Partial
                                    Partial
                                      USA
The Cadmus Group, Inc., 2007
                                                                           3.70
                                                                           3.02
                                                                          10.64
                                                                           7.21
                                                                             74
                                                                              4
                                                                              2

Commons, 2011
                                                                           9.12
                                                                           2.88
                                                                           3.56
                                                                           2.19
                                                                             48
                                                                              7
                                                                              7

Commons, 2014
                                                                          10.19
                                                                           2.19
                                                                           6.88
                                                                           4.20
                                                                             40
                                                                              3
                                                                              3

O'Brien & Gere, 2015
                                                                           8.84
                                                                           2.57
                                                                           1.70
                                                                           2.11
                                                                             25
                                                                              9
                                                                              1

DC Water, 2016
                                                                           8.80
                                                                           1.93
                                                                           7.50
                                                                           4.47
                                                                             15
                                                                              1
                                                                              1

Swertfeger et al., 2006; Desmarais et al., 2015; Triantafyllidou et al., 2015
                                                                           2.78
                                                                           2.53
                                                                           0.38
                                                                           0.00
                                                                             11
                                                                             11
                                                                             11

                                      CND
Camara et al., 2013
                                                                          18.44
                                                                           1.27
                                                                           2.00
                                                                           1.29
                                                                              4
                                                                              1
                                                                              1
                                    Partial
                                Representative
                                      USA
DC Water, 2016
                                                                           1.95
                                                                           2.45
                                                                           7.30
                                                                           4.60
                                                                            266
                                                                             19
                                                                             19

Estes-Smargiassi et al., 2006
                                                                           0.24
                                                                           4.53
                                                                           3.03
                                                                           2.78
                                                                             25
                                                                              2
                                                                              2

Swertfeger et al., 2006; Desmarais et al., 2015; Triantafyllidou et al., 2015
                                                                           1.54
                                                                           2.07
                                                                           3.35
                                                                           2.68
                                                                            116
                                                                             10
                                                                              2

                                      CND
Campbell, 2016
                                                                           1.71
                                                                           3.37
                                                                           4.00
                                                                           2.30
                                                                            152
                                                                             19
                                                                             11
                                    No LSL
                                     None
                                      USA
None
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