General: The exhibit presents commercial laboratory costs for alkalinity and orthophosphate. Alkalinity costs are based on the average of quotes from six laboratories; those for orthophosphate are based on seven laboratory quotes. CWSs serving <= 100,000 people will use commercial laboratories for these analyses. CWSs serving > 100,000 people are assumed to conduct all WQP analyses in-house and thus, will incur no commercial costs. All systems are assumed to conduct pH analyses in-house, which results in no commercial costs.
A: Systems without CCT sample pH and alkalinity. EPA assumed no costs for systems serving > 50,000 people without CCT because they are b3 systems (11 in total) and not subject to WQP requirements. The commercial cost for systems serving <= 50,000 people is for alkalinity analyses.
B: Systems using pH adjustment for CCT sample pH and alkalinity. The commercial cost for systems serving <= 100,000 people is for alkalinity analyses.
C: Systems using orthophosphate treatment sample pH, alkalinity, and orthophosphate. The commercial cost for systems serving <= 100,000 is for alkalinity and orthophosphate analysis.
Exhibit 5-32: NTNCWS Commercial WQP Analytical Cost for Distribution System Samples ($/sample)
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                                 cost_lab_wqp
                                cost_lab_ph_wqp
                              cost_lab_ortho_wqp

                                       A
                                       B
                                       C
<=50,000
                                                                         $23.92
                                                                         $23.92
                                                                         $49.35
50,001-100,000
                                                                           $0
                                                                         $23.92
                                                                         $49.35
100,001-1,000,000
                                                                           $0
                                                                         $23.92
                                                                         $49.35
>1,000,000

Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," worksheet "Commercial WQP."
Notes:
General: The exhibit presents commercial costs for alkalinity and orthophosphate. Alkalinity costs are based on the average of quotes from six laboratories; those for orthophosphate are based on seven laboratory quotes. All NTNCWSs serving 50,000 to 1 million people are assumed to have CCT; no NTNCWS serves > 1 million people. All NTNCWSs are assumed to conduct pH analyses in-house and to use commercial laboratories for other analyses.
A: Systems without CCT will sample pH and alkalinity. EPA assumed no costs for NTNCWSs serving > 50,000 people without CCT because all NTNCWSs are assumed to have CCT. All NTNCWSs are assumed to analyze pH in-house but to use commercial laboratories for all other analyses.
B: Systems using pH adjustment for CCT sample pH and alkalinity. The commercial cost for NTNCWSs is for alkalinity analyses.
C: Systems using orthophosphate treatment sample pH, alkalinity, and orthophosphate. The commercial cost for NTNCWSs is for alkalinity and orthophosphate analyses.

    Collect lead WQP samples from entry points (hrs_ep_wqp_op, cost_ep_wqp_material, cost_ep_wqp_ph_material, cost_ep_wqp_ortho_material). Systems will also collect WQP samples at each entry point to the distribution system. EPA assumed the burden to collect WQP samples (hrs_ep_wqp_op) to be:
 0 hours for all surface water systems and 20 percent of ground water systems because they are already collecting entry point samples to comply with other drinking water regulations
 0.5 hours for the remaining 80 percent of ground water systems.
   These estimates are based on the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal) (USEPA, 2015b).
    EPA assumed that systems will analyze for the same WQPs in entry points samples as distribution samples and incur the same material costs (i.e., bottle costs) as detailed in activity p). Even though burden and costs inputs are identical, EPA used different data variable names for entry point samples for modeling flexibility in the SafeWater LCR model. The input values and corresponding data variable IDs for entry point samples are provided in Exhibit 5-33 and Exhibit 5-34 for CWSs and NTNCWSs, respectively.
Exhibit 5-33: CWS Material Costs Associated with Entry Point Sample Collection
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                             cost_ep_wqp_material
                            cost_ep_wqp_ph_material
                          cost_ep_wqp_ortho_material

                                       A
                                       B
                                       C
<=50,000
                                                                          $2.15
                                                                          $2.15
                                                                          $2.15
50,001-100,000
                                                                            $0
                                                                          $2.15
                                                                          $2.15
>100,000
                                                                            $0
                                                                          $2.32
                                                                          $4.14
Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," worksheet "In-House_Bottle_$."
Notes: The input values in this exhibit are identical to Exhibit 5-25. Refer to the exhibit notes for Exhibit 5-25 for detailed assumptions.

Exhibit 5-34: NTNCWS Material Costs Associated with Entry Point Sample Collection
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                             cost_ep_wqp_material
                            cost_ep_wqp_ph_material
                          cost_ep_wqp_ortho_material

                                       A
                                       B
                                       C
<=50,000
                                                                          $2.15
                                                                          $2.15
                                                                          $2.15
50,001-100,000
                                                                            $0
                                                                          $2.15
                                                                          $2.15
100,001-1,000,000
                                                                            $0
                                                                          $1.83
                                                                          $1.83
>1,000,000

Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," worksheet "In-House_Bottle_$."
Notes: The input values in this exhibit are identical to Exhibit 5-26. Refer to the exhibit notes for Exhibit 5-26 for detailed assumptions.

    Analyze entry point lead WQP samples. EPA assumed systems analyze the same WQPs in entry points samples as distribution system samples and incur the same in-house burden and material (i.e., bottle) cost or commercial costs as detailed in activity q). The input values with corresponding SafeWater LCR model entry point data variables are provided in the following exhibits:
 Exhibit 5-35 and Exhibit 5-36 for CWS and NTNCWS in-house analytical burden, respectively,
 Exhibit 5-37 and Exhibit 5-38 for CWS and NTNCWS in-house analytical cost, respectively, and
 Exhibit 5-39 and Exhibit 5-40 for CWS and NTNCWS commercial analyses, respectively.
Exhibit 5-35: CWS In-House WQP Analytical Burden for Entry Point Samples (hrs/sample)
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                             hrs_wqp_analyze_ep_op
                           hrs_wqp_analyze_ph_ep_op
                           hrs_wqp_analyze_ortho_op

                                       A
                                       B
                                       C
<=50,000
                                                                           0.15
                                                                           0.15
                                                                           0.15
50,001-100,000
                                                                            0
                                                                           0.15
                                                                           0.15
>100,000
                                                                            0
                                                                           0.46
                                                                           1.34
Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," worksheet "In-House_Burden Quotes."
Notes: The input values in this exhibit are identical to Exhibit 5-27. Refer to the exhibit notes for Exhibit 5-27 for detailed assumptions.

Exhibit 5-36: NTNCWS In-House WQP Analytical Burden for Entry Point Samples (hrs/sample)
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                             hrs_wqp_analyze_ep_op
                           hrs_wqp_analyze_ph_ep_op
                           hrs_wqp_analyze_ortho_op

                                       A
                                       B
                                       C
<=50,000
                                                                           0.15
                                                                           0.15
                                                                           0.15
50,001-100,000
                                                                            0
                                                                           0.15
                                                                           0.15
100,001-1,000,000
                                                                            0
                                                                           0.15
                                                                           0.15
>1,000,000

Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," worksheet, "In-House_Burden Quotes."
Notes: The input values in this exhibit are identical to Exhibit 5-28. Refer to the exhibit notes for Exhibit 5-28 for detailed assumptions.

Exhibit 5-37: CWS In-House WQP Analytical Cost for Entry Point Samples ($/sample)
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                              cost_wqp_analyze_ep
                              cost_lab_wqp_ph_ep
                           cost_wqp_analyze_ortho_ep

                                       A
                                       B
                                       C
<=50,000
                                                                          $0.52
                                                                          $0.52
                                                                          $0.52
50,001-100,000
                                                                           $0
                                                                          $0.52
                                                                          $0.52
>100,000
                                                                           $0
                                                                          $0.72
                                                                          $0.78
Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," "In-House_Consumables_Summary_$."
Notes: The input values in this exhibit are identical to Exhibit 5-29. Refer to the exhibit notes for Exhibit 5-29 for detailed assumptions.

Exhibit 5-38: NTNCWS In-House WQP Analytical Cost for Entry Point Samples ($/sample)
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                              cost_wqp_analyze_ep
                              cost_lab_wqp_ph_ep
                           cost_wqp_analyze_ortho_ep

                                       A
                                       B
                                       C
<=50,000
                                                                          $0.52
                                                                          $0.52
                                                                          $0.52
50,001-100,000
                                                                           $0
                                                                          $0.52
                                                                          $0.52
100,001-1,000,000
                                                                           $0
                                                                          $0.52
                                                                          $0.52
>1,000,000

Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," worksheet: "In-House_Consumables_Summary_$."
Notes: The input values in this exhibit are identical to Exhibit 5-30. Refer to the exhibit notes for Exhibit 5-30 for detailed assumptions.

Exhibit 5-39: CWS Commercial WQP Analytical Cost for Entry Point Samples ($/sample)
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                                cost_lab_wqp_ep
                              cost_lab_wqp_ph_ep
                             cost_lab_wqp_ortho_ep

                                       A
                                       B
                                       C
<=50,000
                                                                         $23.92
                                                                         $23.92
                                                                         $49.35
50,001-100,000
                                                                           $0
                                                                         $23.92
                                                                         $49.35
>100,000
                                                                           $0
                                                                          $0.00
                                                                          $0.00
Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," worksheet "Commercial WQP."
Notes: The input values in this exhibit are identical to Exhibit 5-31. Refer to the exhibit notes for Exhibit 5-31 for detailed assumptions.
Exhibit 5-40: NTNCWS Commercial WQP Analytical Cost for Entry Point Samples ($/sample)
                                  System Size
                              (Population Served)
                                  Without CCT
                              With pH Adjustment
                              With Orthophosphate

                                cost_lab_wqp_ep
                              cost_lab_wqp_ph_ep
                             cost_lab_wqp_ortho_ep

                                       A
                                       B
                                       C
<=50,000
                                                                         $23.92
                                                                         $23.92
                                                                         $49.35
50,001-100,000
                                                                           $0
                                                                         $23.92
                                                                         $49.35
100,001-1,000,000
                                                                           $0
                                                                         $23.92
                                                                         $49.35
>1,000,000

Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx," worksheet: "Commercial WQP."
Notes: The input values in this exhibit are identical to Exhibit 5-32. Refer to the exhibit notes for Exhibit 5-32 for detailed assumptions.

    Report lead WQP sampling data and compliance with OWQPs to Primacy Agency (hrs_report_wqp_op). Systems are required to report their WQP results and for those systems where OWQPs have been set to demonstrate compliance with those OWQPs every six months. EPA estimated systems with CCT and without CCT would require 5 hours and 4 hours, respectively. The estimated reporting burden for systems with CCT is based on the WQP Reporting (Annual) burden in Appendix H, Exhibit 35 of the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal) (USEPA, 2015b). EPA assumed systems without CCT would incur a lower burden because they would be reporting less entry point monitoring data than those with CCT that must conduct entry point monitoring biweekly. These systems without CCT are also not determining compliance with OWQPs.
Exhibit 5-41 shows the SafeWater LCR model cost estimation approach for water system lead WQP monitoring activities including additional cost inputs that are required to calculate these costs.
Exhibit 5-41: PWS Lead WQP Monitoring Cost Estimation in SafeWater LCR by Activity[1]

NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity
CWS Cost Per Activity

Lead 90[th] - Range
Other Conditions

Collect lead WQP samples in the distribution system
Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material))
Cost applies as written to NTNCWSs.
Above AL
Model PWSs serving <=50,000 without CCT
Twice per year
Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material_ph))

Model PWSs serving <=50,000 with pH adjustment
pbaseph

Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material_ortho))

Model PWSs serving <=50,000 with PO4 or both PO4 and pH adjustment

pbasepo4, pbasephpo4

Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material_ph))
Cost applies as written to NTNCWSs.
All

Model PWSs serving >50,000 with pH adjustment that do not qualify for reduced WQP monitoring
Twice per year
Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material_ortho))

Model PWSs serving >50,000 with PO4 or both PO4 and pH adjustment that do not qualify for reduced WQP monitoring

pbasepo4, pbasephpo4,
1  -  (p_wqp_annual + p_wqp_triennial + p_wqp_six_red)
Twice per year
Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_reduced_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material_ph))
Cost applies as written to NTNCWSs.

Model PWSs with pH adjustment on six-month reduced WQP monitoring

pbaseph, p_wqp_six_red
Twice a year

All
Model PWSs with pH adjustment on annual WQP monitoring

pbaseph, p_wqp_annual
Once a year

Model PWSs with pH adjustment on triennial WQP monitoring

pbaseph, p_wqp_triennial
Every three years
Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_reduced_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material_ortho))
Cost applies as written to NTNCWSs.

Model PWSs with PO4 or both PO4 and pH adjustment on six-month reduced sample WQP monitoring

pbasepo4, pbasephpo4, p_wqp_six_red
Twice a year

All
Model PWSs with PO4 or both PO4 and pH adjustment on annual WQP monitoring

pbasepo4, pbasephpo4, p_wqp_annual
Once a year

Model PWSs with PO4 or both PO4 and pH adjustment on triennial WQP monitoring

pbasepo4, pbasephpo4, p_wqp_triennial
Every three years
    Analyze distribution system lead WQP samples
There are different labor (burden) and material costs for a sample analyzed in house and a sample analyzed using a commercial lab. The in-house analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in house times the system labor rate, plus the material cost of the in-house analysis per sample. The commercial lab analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in a commercial lab times the system labor rate, plus the material cost of the commercial lab analysis per sample.

(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_dist_op*rate_op)+cost_wqp_analyze))+((numb_enhance_wqp*pp_commercial_samp)*cost_lab_wqp))
Cost applies as written to NTNCWSs.
Above AL

Model PWSs serving <=50,000 without CCT

Twice a year

There are different labor (burden) and material costs for a sample analyzed in house and a sample analyzed using a commercial lab. The in-house analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in house times the system labor rate, plus the material cost of the in-house analysis per sample. The commercial lab analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in a commercial lab times the system labor rate, plus the material cost of the commercial lab analysis per sample.

(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ph_op*rate_op)+cost_wqp_ph_analyze))+((numb_enhance_wqp*pp_commercial_samp)*cost_lab_ph_wqp))

Model PWSs serving <=50,000 with pH adjustment

pbaseph

There are different labor (burden) and material costs for a sample analyzed in house and a sample analyzed using a commercial lab. The in-house analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in house times the system labor rate, plus the material cost of the in-house analysis per sample. The commercial lab analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in a commercial lab times the system labor rate, plus the material cost of the commercial lab analysis per sample.

(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ortho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_enhance_wqp*pp_commercial_samp)*cost_lab_ortho_wqp))

Model PWSs serving <=50,000 with PO4 or both PO4 and pH adjustment

pbasepo4, pbasephpo4

There are different labor (burden) and material costs for a sample analyzed in house and a sample analyzed using a commercial lab. The in-house analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in house times the system labor rate, plus the material cost of the in-house analysis per sample. The commercial lab analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in a commercial lab times the system labor rate, plus the material cost of the commercial lab analysis per sample.

(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ph_op*rate_op)+cost_wqp_ph_analyze))+((numb_enhance_wqp*pp_commercial_samp)*cost_lab_ph_wqp))
Cost applies as written to NTNCWSs.
All

Model PWSs serving >50,000 with pH adjustment that do not qualify for reduced WQP monitoring

pbaseph;
1- (p_wqp_annual, p_wqp_triennial, p_wqp_six_red)
Twice a year
There are different labor (burden) and material costs for a sample analyzed in house and a sample analyzed using a commercial lab. The in-house analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in house times the system labor rate, plus the material cost of the in-house analysis per sample. The commercial lab analysis costs are calculated using the number of required samples per system multiplied by the percentage of samples analyzed in a commercial lab times the system labor rate, plus the material cost of the commercial lab analysis per sample.

(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ortho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_enhance_wqp*pp_commercial_samp)*cost_lab_ortho_wqp))

Model PWSs serving >50,000 with PO4 or both PO4 and pH adjustment that do not qualify for reduced WQP monitoring

pbasepo4; pbasephpo4;
1  -  (p_wqp_annual, p_wqp_triennial, p_wqp_six_red)
Twice a year
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

(((numb_reduced_wqp*pp_lab_samp)*((hrs_wqp_analyze_ph_op*rate_op)+cost_wqp_ph_analyze))+((numb_reduced_wqp*pp_commercial_samp)*cost_lab_ph_wqp))
Cost applies as written to NTNCWSs.
All

Model PWSs with pH adjustment on six-month reduced sample WQP monitoring

pbaseph, p_wqp_six_red
Twice a year

Model PWSs with pH adjustment on annual WQP monitoring

pbaseph, p_wqp_annual
Once a year

Model PWSs with pH adjustment on triennial WQP monitoring

pbaseph, p_wqp_triennial
Every three years
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

(((numb_reduced_wqp*pp_lab_samp)*((hrs_wqp_analyze_ortho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_reduced_wqp*pp_commercial_samp)*cost_lab_ortho_wqp))
Cost applies as written to NTNCWSs.
All

Model PWSs serving > 50,000 with PO4 or both PO4 and pH adjustment on six-month reduced WQP monitoring

pbasepo4, pbasephpo4, p_wqp_six_red
Twice a year

Model PWSs serving > 50,000 with PO4 or both PO4 and pH adjustment on annual WQP monitoring
pbasepo4, pbasephpo4, p_wqp_annual
Once a year

Model PWSs serving > 50,000 with PO4 or both PO4 and pH adjustment on triennial WQP monitoring

pbasepo4, pbasephpo4, p_wqp_triennial
Every three years
    Collect lead WQP samples from entry points
The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_ep_wqp_material))
Cost applies as written to NTNCWSs.
Above AL
Model PWSs serving <=50,000 without CCT
Twice a year
The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_ep_wqp_ph_material))

Model PWSs serving <=50,000 with pH adjustment

pbaseph
Every 2 weeks
The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_ep_wqp_ortho_material))

Model PWSs serving <=50,000 with PO4 or both PO4 and pH adjustment
pbasepo4, pbasephpo4

The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_ep_wqp_ph_material))
Cost applies as written to NTNCWSs.
All

Model PWSs serving > 50,000 with pH adjustment

pbaseph
Every 2 weeks
The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_ep_wqp_ortho_material))

Model PWSs serving > 50,000 with PO4 or both PO4 and pH adjustment

pbasepo4, pbasephpo4

    Analyze entry point lead WQP samples
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analyze_ep_op*rate_op)+cost_wqp_analyze_ep))+(((numb_ep*numb_ep_wqp)*pp_commercial_samp)* cost_lab_wqp_ep))
Cost applies as written to NTNCWSs.
Above AL
Model PWSs serving <=50,000 without CCT
Twice a year
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analyze_ph_ep_op*rate_op)+cost_wqp_analyze_ph_ep))+(((numb_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ph_ep))
Cost applies as written to NTNCWSs.
Above AL
Model PWSs serving <=50,000 with pH adjustment

pbaseph
Every two weeks

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

((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analyze_ortho_ep_op*rate_op)+cost_wqp_analyze_ortho_ep))+(((numb_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ortho_ep))

Above AL
Model PWSs serving <=50,000 with PO4 or both PO4 and pH adjustment

pbasepo4, pbasephpo4

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

((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analyze_ph_ep_op*rate_op)+cost_wqp_analyze_ph_ep))+(((numb_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ph_ep))
Cost applies as written to NTNCWSs.
All
Model PWSs serving >50,000 with pH adjustment

pbaseph
Every two weeks

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

((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analyze_ortho_op*rate_op)+cost_wqp_analyze_ortho_ep))+(((numb_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ortho_ep))

Model PWSs serving >50,000 with PO4 or both PO4 and pH adjustment

pbasepo4, pbasephpo4

    Report lead WQP sampling data and compliance with OWQPs to Primacy Agency
The labor hours for reporting per system multiplied by the labor rate.

(hrs_report_wqp_op*rate_op)
Cost applies as written to NTNCWSs.
Above AL

Model PWSs serving <=50,000 without CCT
Twice a year

Model PWSs serving <=50,000 with pH adjustment

pbaseph

Model PWSs serving <=50,000 with PO4 or both PO4 and pH adjustment

pbasepo4, pbasephpo4

All
Model PWSs serving >50,000 with pH adjustment

pbaseph

Model PWSs serving >50,000 with PO4 or both PO4 and pH adjustment

pbasepo4, pbasephpo4

Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-community water system; OWQP = optimal water quality parameter; PO4 = orthophosphate; PWS = public water system; WQP = water quality parameter.
Note:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 numb_enhance_wqp: number of distribution system samples for systems on routine WQP monitoring (Section <IP_ADDRESS>.3).
 numb_ep: number of entry points per systems (Section <IP_ADDRESS>.3).
 numb_reduced_wqp: number of distribution system samples for systems on reduced WQP monitoring (Section <IP_ADDRESS>.3).
 pbaseph: likelihood a system has an existing CCT of modify pH (Section <IP_ADDRESS>.1).
 pbasepo4: likelihood a system has existing CCT of adding PO4 without pH post treatment (Section <IP_ADDRESS>.1).
 pbasephpo4: likelihood a system has existing CCT of adding PO4 with modify pH (Section <IP_ADDRESS>.1).
 p_wqp_annual, p_wqp_triennial, p_wqp_six_red: likelihood a system is on reduced distribution system monitoring schedule at an semi-annual, annual, or triennial schedule, respectively (Section <IP_ADDRESS>.2).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).

PWS Copper Water Quality Parameter Monitoring
This discussion of copper WQP monitoring costs for water systems is presented in the following subsections:
         <IP_ADDRESS>.1: Applicability and Likelihood of a Copper ALE
         <IP_ADDRESS>.2: Copper WQP Monitoring Activities
Applicability and Likelihood of a Copper ALE
The SafeWater LCR models Copper WQP Monitoring separately from the Lead WQP Monitoring. The frequency of Lead WQP Monitoring depends on the lead 90[th] percentile, with all systems above the AL and all systems serving more than 50,000 people conducting Lead WQP Monitoring. Copper WQP Monitoring is required when a system exceeds the copper AL. To not double count the cost of WQP monitoring for systems experiencing both a copper ALE and a lead ALE simultaneously, the SafeWater LCR models the costs of Copper and Lead WQP Monitoring separately and restricts Copper WQP Monitoring to systems with a copper ALE only and lead 90[th] percentile not greater than the lead AL.
Note that the cost inputs used to estimate WQP costs in response to a copper ALE are identical to those incurred in response to a lead ALE with the following exceptions:
 The likelihood of a system's exceeding the copper ALE, which corresponds to p_copper_ale, is used in lieu of system's lead 90[th] percentile level.
 Systems are not assumed to be on reduced WQP distribution system monitoring in response to a copper ALE, and all systems are assumed to be on a 6-month standard monitoring schedule. Thus, the data inputs associated with reduced monitoring are not applicable. These include the reduced number of WQP monitoring samples per distribution sample site (numb_reduced_wqp), and the likelihood that a system will be on a 6-month (p_wqp_six_red) or annual (p_wqp_annual) WQP sampling schedule.
Exhibit 5-42 and Exhibit 5-43 provide the likelihood that a CWS and NTNCWS, respectively, will exceed the copper AL of 1.3 mg/L, but not the lead AL of 15 ug/L (p_copper_ale). In each exhibit, the estimated percentages are provided for each of the 9 size categories and two source water types used in the cost model. For systems without CCT, EPA derived the percentages from SDWIS/Fed 90[th] percentile results from 2012  -  2015 as follows:
 Step 1: For each year during 2012  -  2015, EPA identified the number of CWSs with a reported copper 90[th] percentile value above the copper AL and no reported lead 90[th] percentile above the AL for the nine size categories and two source types.
 Step 2: EPA divided the number of systems in step 1 by the number of CWSs in each size and source strata to develop a percentage. Each percentage was divided by 100 to derive the likelihood.
EPA used the same approach to develop the estimated percent of NTNCWSs with ALEs. Chapter 4, Exhibit 4-25 and Exhibit 4-26 provide the results of this analysis for CWSs and NTNCWSs, respectively. Note that for modeling purposes, EPA assumed that no system with CCT would have a copper ALE and thus, would have a likelihood of 0 percent. EPA made this simplifying assumption because < 1 percent of CWSs and < 3.5 percent of NTNCWSs were estimated to have a copper ALE. Exhibit 5-42 and Exhibit 5-43 provide the likelihoods used in the SafeWater LCR model for the data variable p_copper_ale. As shown in these exhibits, no CWS or NTNCWS serving more than 50,000 people is assumed to have a copper ALE and be subject to copper WQP monitoring. However, as discussed in Section <IP_ADDRESS>, these systems are assumed to conduct lead WQP monitoring with the exception of those designated as "b3" systems.
Exhibit 5-42: Estimated Likelihood a CWS Will Have a Copper Only ALE
                                  System Size
                              (Population Served)
                                 p_copper_ale

                                  with CCT[1]
                                without CCT[2]

                                 Ground Water
                                 Surface Water
                                 Ground Water
                                 Surface Water
<=100
                                                                          0.000
                                                                          0.000
                                                                          0.004
                                                                          0.007
101 - 500
                                                                          0.000
                                                                          0.000
                                                                          0.004
                                                                          0.008
501 - 1,000
                                                                          0.000
                                                                          0.000
                                                                          0.004
                                                                          0.006
1,001 - 3,300
                                                                          0.000
                                                                          0.000
                                                                          0.005
                                                                          0.005
3,301 - 10,000
                                                                          0.000
                                                                          0.000
                                                                          0.003
                                                                          0.003
10,001 - 50,000
                                                                          0.000
                                                                          0.000
                                                                          0.002
                                                                          0.003
50,001 - 100,000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
100,001 - 1,000,000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
>1,000,000
                                                                          0.000
                                                                          0.000

Source:
SDWIS/Fed third quarter frozen data set, current through June 30, 2016. Also see "Derivation of CWS Inventory Characteristics_Final Rule.xlsx" for additional detail.
Notes:
General: EPA estimated that 11 CWSs are b3 systems, serve 50,001  -  1 million people, and have no CCT. No b3 systems serve more than 1 million people.
[1] Note that for modeling purposes, EPA assumed that no system with CCT would have a copper ALE and thus, would have a likelihood of 0 percent.
2 For each year during 2012 - 2015, EPA identified the number of CWSs with a reported copper 90[th] percentile value above the copper AL and no reported lead 90[th] percentile values above the AL for the 9 size categories and two source types. EPA then divided the number of systems by the number of CWSs in each size and source strata to develop a percentage. Each percentage was divided by 100 to derive the likelihood. Note that all systems serving > 50,000 people without CCT (11 systems) are categorized as "b3" systems and have no copper ALEs (see Section 4.3.3 for additional detail).

Exhibit 5-43: Estimated Likelihood a NTNCWS Will Have a Copper Only ALE
                                  System Size
                              (Population Served)
                                 p_copper_ale

                                  with CCT[1]
                                without CCT[2]

                                 Ground Water
                                 Surface Water
                                 Ground Water
                                 Surface Water
<=100
                                                                          0.000
                                                                          0.000
                                                                          0.007
                                                                          0.011
101 - 500
                                                                          0.000
                                                                          0.000
                                                                          0.007
                                                                          0.013
501 - 1,000
                                                                          0.000
                                                                          0.000
                                                                          0.007
                                                                          0.016
1,001 - 3,300
                                                                          0.000
                                                                          0.000
                                                                          0.008
                                                                          0.008
3,301 - 10,000
                                                                          0.000
                                                                          0.000
                                                                          0.010
                                                                          0.000
10,001 - 50,000
                                                                          0.000
                                                                          0.000
                                                                          0.000
                                                                          0.000
50,001 - 100,000
                                                                          0.000
                                                                          0.000

100,001 - 1,000,000
                                                                          0.000
                                                                          0.000

>1,000,000

Source:
SDWIS/Fed third quarter frozen data set, current through June 30, 2016. Also see "Derivation of NTNCWS Inventory Characteristics_Final Rule.xlsx" for additional detail.
Notes:
General: Three NTNCWSs serve 50,001  -  1 million people and each have CCT. No NTNCWS serves > 1 million people.
[1] Note that for modeling purposes, EPA assumed that no system with CCT would have a copper ALE and thus, would have a likelihood of 0 percent.
2 For each year during 2012 - 2015, EPA identified the number of NTNCWSs with a reported copper 90[th] percentile value above the copper AL and no reported lead 90[th] percentile values above the AL for the 9 size categories and two source types. EPA then divided the number of systems by the number of NTNCWSs in each size and source strata to develop a percentage. Each percentage was divided by 100 to derive the likelihood.

Copper WQP Monitoring Activities
 The activities, unit burden and costs, and data variables used to estimate copper WQP monitoring costs are identical to those for copper, as shown in Exhibit 5-44, with the exception that they are triggered in response to a copper ALE.
Exhibit 5-44: PWS Copper WQP Monitoring Unit Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
Collect copper WQP samples in the distribution system
                      Same as Exhibit 5-24, activity p).
Analyze distribution system copper WQP samples
                      Same as Exhibit 5-24, activity q).
Collect copper WQP samples from entry points
                      Same as Exhibit 5-24, activity r).
Analyze entry point copper WQP samples
                      Same as Exhibit 5-24, activity s).
Report copper WQP sampling data and compliance with OWQPs to Primacy Agency
                      Same as Exhibit 5-24, activity t).
Acronyms: ALE = action level exceedance; OWQP = optimal water qualify parameter; WQP = water qualify parameter.
Source: "Derivation of WQP Analytical Burden and Costs_Final Rule.xlsx."

Exhibit 5-45 shows the SafeWater LCR model cost estimation approach for system WQP monitoring activities in response to a copper ALE including additional cost inputs that are required to calculate these costs.

Exhibit 5-45: PWS Copper WQP Monitoring Cost Estimation in SafeWater LCR by Activity[1]

                           NTNCWS Cost Per Activity
                  Conditions for Cost to Apply to a Model PWS
                             Frequency of Activity
                             CWS Cost Per Activity

                              Lead 90[th] - Range
                               Other Conditions

    Collect copper WQP samples in the distribution system
Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material))
Cost applies as written to NTNCWSs.
At or below AL
Model PWSs serving <=50,000 without CCT and have a copper ALE

p_copper_ale
Twice per event
Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material_ph))

Model PWSs serving <=50,000 that have pH adjustment and a copper ALE

p_copper_ale, pbaseph

Number of samples multiplied by the total of the hours per sample times the system labor rate, plus the cost of materials per sample.

(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_material_ortho))

Model PWSs serving <=50,000 that have PO4 or both PO4 and pH adjustment and a copper ALE

p_copper_ale, pbasepo4, pbasephpo4

    Analyze distribution system copper WQP samples
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_dist_op*rate_op)+cost_wqp_analyze))+((numb_enhance_wqp*pp_commercial_samp)*cost_lab_wqp))
Cost applies as written to NTNCWSs.
At or below AL
Model PWSs serving <=50,000 without CCT and have a copper ALE

p_copper_ale

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

(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ph_op*rate_op)+cost_wqp_ph_analyze))+((numb_enhance_wqp*pp_commercial_samp)*cost_lab_ph_wqp))

Model PWSs serving <=50,000 that have pH adjustment and a copper ALE

p_copper_ale, pbaseph

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

(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ortho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_enhance_wqp*pp_commercial_samp)*cost_lab_ortho_wqp))

Model PWSs serving <=50,000 that have PO4 or both PO4 and pH adjustment and have a copper ALE

p_copper_ale, pbasepo4, pbasephpo4

    Collect copper WQP samples from entry points
The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_ep_wqp_material))
Cost applies as written to NTNCWSs.
At or below AL
Model PWSs serving <=50,000 without CCT and have a copper ALE

p_copper_ale

Every 2 weeks per event
The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_ep_wqp_ph_material))

Model PWSs serving <=50,000 that have pH adjustment and a copper ALE

p_copper_ale, pbaseph

The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_ep_wqp_ortho_material))

Model PWSs serving <=50,000 that have PO4 or both PO4 and pH adjustment and have a copper ALE

p_copper_ale, pbasepo4, pbasephpo4

    Analyze entry point copper WQP samples
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analyze_ep_op*rate_op)+cost_wqp_analyze_ep))+(((numb_ep*numb_ep_wqp)*pp_commercial_samp)* cost_lab_wqp_ep))
Cost applies as written to NTNCWSs.
Above AL
Model PWSs serving <=50,000 without CCT and have a copper ALE

p_copper_ale

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

((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analyze_ph_ep_op*rate_op)+cost_wqp_analyze_ph_ep))+(((numb_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ph_ep))

Model PWSs serving <=50,000 that have pH adjustment and a copper ALE

p_copper_ale, pbaseph

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

((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analyze_ortho_ep_op*rate_op)+cost_wqp_analyze_ortho_ep))+(((numb_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ortho_ep))

Model PWSs serving <=50,000 that have PO4 or both PO4 and pH adjustment and have a copper ALE

p_copper_ale, pbasepo4, pbasephpo4

    Report  copper WQP sampling data and compliance with OWQPs to Primacy Agency
The labor hours for reporting per system multiplied by the labor rate.

(hrs_report_wqp_op*rate_op)
Cost applies as written to NTNCWSs.
At or below AL
Model PWSs serving <=50,000 without CCT and have a copper ALE

p_copper_ale
Twice per event

Model PWSs serving <=50,000 that have pH adjustment and a copper ALE

p_copper_ale, pbaseph

Model PWSs serving <=50,000 that have PO4 or both PO4 and pH adjustment and have a copper ALE

p_copper_ale, pbasepo4, pbasephpo4

Acronyms: AL = action level; ALE = action level exceedance; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-community water system; PO4 = orthophosphate; OWQP = optimal water quality parameter; PWS = public water system; WQP = water quality parameter.
Note:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 numb_enhance_wqp: number of distribution system samples for systems on routine WQP monitoring (Section <IP_ADDRESS>.3).
 numb_ep: number of entry points per systems (Section <IP_ADDRESS>.3).
 numb_reduced_wqp: number of distribution system samples for systems on reduced WQP monitoring (Section <IP_ADDRESS>.3).
 pbaseph: likelihood a system has an existing CCT of modify pH (Section <IP_ADDRESS>.1).
 pbasepo4: likelihood a system has existing CCT of adding PO4 without pH post treatment (Section <IP_ADDRESS>.1).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).

PWS Source Water Monitoring
This discussion of source water monitoring costs for water systems is presented in the following subsections:
         <IP_ADDRESS>.1: Applicability and Required Number of Samples
         <IP_ADDRESS>.2: Source Water Monitoring Activities
Applicability and Required Number of Samples
Under the LCRR, CWSs and NTNCWSs must sample at each entry point if the system experiences a significant source water change and/or has not already conducted source water monitoring for a previous lead or copper AL. The likelihood of a significant source change or ALE, as well as the required number of source water samples, are described below.
Applicability
Section <IP_ADDRESS> in Chapter 4 provides EPA's approach for using historical SDWIS/Fed data to estimate the likelihood that systems would have a source change in any given year (p_source_chng) of 0.05 for all CWSs and NTNCWSs. EPA developed a second related data input, p_source_sig, using the same data set to estimate the likelihood that a source change would be a significant change, i.e., one in which a system changed its primary source. EPA set p_source_sig to 0.01 for CWSs and NTNCWSs. The likelihoods p_source_chng and p_source_sig are multiplied to determine the joint likelihood that a system that makes a source change will be required to take additional action such as source water monitoring.
Lead and/or Copper ALE
Under the LCRR, the SafeWater LCR model assigns the source water monitoring burden and costs described in Section <IP_ADDRESS>.2 to any system the first time they exceed the lead and/or copper AL. A discussion of EPA's approach for estimating the likelihood a system will initially have a lead ALE under the LCRR is provided in Section <IP_ADDRESS>, with the estimated percentages provided in Exhibit 4-20. The likelihood a system will have a copper ALE is provided in Section <IP_ADDRESS>.1. Note that this approach may result in an overestimation of cost because the LCRR allows systems to forego source water monitoring if they previously sampled source water in response to an ALE, the Primacy Agency has not required source water treatment, and they have not added any new water sources that change their primacy source type. For modeling purposes no system is assumed to have source water treatment.
Number of Samples
As described in Sections 4.2.2 and 4.3.6, EPA developed likelihoods of a CWS having 1 to 50 entry points for the eight system size categories serving 1,000,000 or fewer people and for ground water and surface water systems. Note that systems in the 9[th] system size category serving greater than 1 million were modeled separately using information provided by the 21 water systems in this largest population category. See the file, "Derivation of Baseline CCT Characteristics_Final Rule.xlsx," for the results. For example, ground water CWSs serving 101 to 500 people have a 72 percent chance of having one entry point, a 12 percent chance of having two entry points, and a 10 percent chance of having three entry points. EPA assumed that NTNCWSs always have one entry point since they tend to be single facilities covering a small geographical area.
The rule does not specify that systems must collect multiple samples per entry point. Thus, for the cost model the Agency assumed each system would collect one sample per entry point (numb_st_sample).
Source Water Monitoring Activities
EPA has developed system costs for three source water monitoring activities as shown in Exhibit 5-46. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of each activity follows the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font. In a few instances, some of these activities are conducted by the state instead of the water system. These activities are identified in the exhibit and further explained in the exhibit notes.
Exhibit 5-46: PWS Source Monitoring Burden and Cost Estimates
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
    Collect source water sample
Burden
0.5 hrs/sample

Cost
$1.83/sample for CWSs serving > 100K

Burden
hrs_source_op

Cost
cost_source_material[1]
Analyze source water sample
In-House Burden
0.44 hrs/sample for CWSs serving > 100K

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

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

In-House Cost
cost_source_analyze[1]

Commercial Cost
cost_source[1]
Report source water monitoring results to Primacy Agency
1 hour/report
hrs_report_source_op[1]
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system; PWS = public water system.
Sources:
z), bb): See Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 15 in Appendix H for burden (USEPA, 2015b); "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx," worksheet: "In-House Bottle_$" for costs.
aa): See "Derivation of Lead Analytical Burden and Costs_Final Rule.xlsx," worksheets: "In-House Burden_hrs," "In-House_Consumables_Summary_$," and "Commercial Analytical_$."
Note:
1 The burden and costs for these activities are incurred by the state versus in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.

 Collect source water sample (hrs_source_op, cost_source_material). CWSs and NTNCWSs with a significant source change and/or in response to their first lead or copper ALE will incur a burden of 0.5 hours to collect one source water sample at each entry point (hrs_source_op). This estimate is based on the system burden for source water sample collection in the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 15 in Appendix H (USEPA, 2015b).
   Based on input from laboratories, EPA assumed only CWSs serving more than 100,000 people will conduct analyses in-house, i.e., pp_lab_samp is 1 for CWSs serving more than 100,000 people and 0 for all other CWSs and NTNCWSs. Conversely, the assigned probability a system will use a commercial laboratory, i.e., pp_commercial_samp is 0 for CWSs serving more than 100,000 people and 1 for all other systems.
   Commercial laboratories provide bottles as part of their services. Thus, CWSs serving 100,000 or fewer people and NTNCWSs will not incur bottle costs. CWSs serving more than 100,000 people are assumed to purchase a 250-ml sample bottle in bulk at a per bottle cost of $1.83 based on quotes from three vendors (cost_source_material).
 Analyze source water samples (hrs_analyze_samp_op, cost_source_analyze, cost_source). EPA assumed only CWSs serving more than 100,000 people will conduct analyses in-house and require 0.44 hours based on quotes from three laboratories. They will also incur in-house consumable costs of $2.38 based on information from three vendors (cost_source_analyze). CWSs serving 100,000 or fewer people and NTNCWSs will incur a cost of $21.58 per sample to have a commercial laboratory conduct the lead analyses (cost_source).
 Report source water monitoring results to Primacy Agency (hrs_report_source_op). Water systems are required to report their source water monitoring results to the Primacy Agency. EPA assumed that both CWSs and NTNCWSs would report electronically and would not incur costs for paper, an envelope, or postage. The Agency did not have specific data on the time it would take to develop and submit a report for the source water sampling results. Instead, in order to estimate this value, EPA employed the general assumption that a water system would require twice the time to prepare the report as that needed for the Primacy Agency to review the report. EPA used an estimate from Exhibit 48 in Appendix H of the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal) indicating a Primacy Agency burden of 0.5 hours for review of a "Source Water Monitoring Letter" submitted from a water system (USEPA, 2015b). Therefore, EPA assumed that systems would incur an average burden of 1 hour to produce and submit this report for each monitoring period in which they conduct source water monitoring (hrs_report_source_op).
Exhibit 5-47 provides the SafeWater LCR model cost estimation approach for system source water monitoring activities including additional cost inputs required to calculate these costs.

Exhibit 5-47: PWS Source Water Monitoring Cost Estimation in SafeWater LCR by Activity[1]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

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

    Collect source water sample[3]
The number of entry points per system multiplied by the number of samples, then multiplied by the total of the labor hours per sample times the system labor rate, plus the cost per sample.

((numb_ep*numb_st_sample)*((hrs_source_op*rate_op)+cost_source_material))
Cost applies as written to NTNCWSs.
All
Model PWSs with a significant change in source water

p_source_chng * p_source_sig
Once per event

At or below AL
Model PWSs with a copper ALE but no lead ALE

p_copper_ale
One time

Above AL
All model PWSs

    Analyze source water samples[3]
The number of samples multiplied by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((pp_lab_samp*(numb_ep*numb_st_sample))*((hrs_analyze_samp_op*rate_op)+cost_source_analyze))+((pp_commercial_samp*(numb_ep*numb_st_sample))*cost_source)

All
Model PWSs with a significant change in source water

p_source_chng *  p_source_sig
Once per event

Cost applies as written to NTNCWSs.
At or below AL
Model PWSs with a copper ALE but no lead ALE

p_copper_ale
One time

Above AL
All model PWSs

    Report source water monitoring results to Primacy Agency[3]
The total reporting hours per system multiplied by the labor rate.

(hrs_report_source_op*rate_op)
Cost applies as written to NTNCWSs.
All
Model PWSs with a significant change in source water

p_source_chng * p_source_sig
Once per event

At or below AL
Model PWSs with a copper ALE but no lead ALE

p_copper_ale
One time

Above AL
All model PWSs

Acronyms: AL = action level; ALE = action level exceedance; CWS = community water system; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
 numb_ep: number of entry points per systems (Section <IP_ADDRESS>.3).
 numb_st_samp: number of samples per entry point for source water monitoring (Section <IP_ADDRESS>.1).
 p_copper_ale: likelihood a system with exceed the copper action level (Section <IP_ADDRESS>.1).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
 p_source_chng: Likelihood a system will have a source change (Section <IP_ADDRESS>).
 p_source_sig: Likelihood that the system will have a significant change in which it changes its primary source, e.g., for ground water to surface water (Section <IP_ADDRESS>).
2 The likelihoods of p_source_chng and p_source_sig are multiplied to determine the joint likelihood that a system that makes a source change will be required to conduct source water monitoring.
[3] The burden and cost to provide sample bottles (cost_source_material) under activity z), conduct analyses under activity aa), and report source water sample results to the system under activity bb) are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.
PWS School and Child Care Lead Sampling Costs
The final LCRR requires CWSs to implement a lead in drinking water testing program at K-12 schools and licensed child cares. CWSs must collect five samples per tested school (numb_samp_five) and two samples at each tested child care (numb_samp_two). The final rule splits this testing program into two phases. The "mandatory testing" phase occurs at elementary schools and child cares during the first 5 years of rule implementation, which is assumed to occur in years 4 through 8. Under the mandatory testing program, systems must annually conduct testing at 20 percent of eligible schools and child cares (pp_mand_twenty_partic) such that each would be tested once in the 5-year period. In years 9 onward, CWSs must implement an "on request" program in which they are only required to test those elementary schools and child cares that request testing. In addition, CWSs are only required to test secondary schools that request testing starting in years 4 onward. For the on request program, EPA assumed 5 percent of elementary and secondary schools and child cares would request testing each year (pp_voluntary_partic).
Exhibit 4-50 in Chapter 4 provides the estimated number of public elementary schools (numb_elem_schools_pub), public secondary schools (numb_second_schools_pub), private elementary schools, (numb_elem_schools_priv), private secondary schools (numb_second_schools_priv), and child cares (numb_daycares) served by CWSs for states, territories, and the Navajo Nation. As previously discussed in Section <IP_ADDRESS>, states with existing lead in drinking water programs at schools and/or child cares that are at least as stringent as the LCRR requirements can waive these requirements for CWSs. EPA assumed schools and/or child cares in these states are already conducting this monitoring and that CWSs in these states would incur no additional burden or cost to implement these programs under the LCRR. Exhibit 4-52 lists the states meeting the mandatory testing program requirements for public and private schools (p_grandfather_mand_pub + p_grandfather_mand_priv) or public only (p_grandfather_mand_pub), and Exhibit 4-55 lists states meeting the mandatory testing requirements for child cares (p_grandfather_mand_child). States that meet the on request program requirements and are assumed to waive testing requirements for CWSs in years 4 onward for secondary schools and years 9 onward for elementary schools and child cares. Exhibit 4-53 provides the list of schools meeting the on request program requirements for public and private schools (p_grandfather_opt_pub + p_grandfather_opt_priv) or public only (p_grandfather_opt_pub), and Exhibit 4-56 lists the states meeting the on request testing requirements for child cares (p_grandfather_opt_child). For additional detail, refer to Chapter 4, Section <IP_ADDRESS> and the file, "Derivation of School_Child Care Inputs_Final Rule.xlsx" (available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov) for additional information.
The requirements and associated costing inputs are described in more detail for the mandatory testing program in Section <IP_ADDRESS>.1 and upon request program in Section <IP_ADDRESS>.2.
Mandatory Testing Program
EPA has developed system burden and costs to implement a lead in drinking water testing program at elementary schools and child cares for the first 5 years associated with the mandatory program phase as shown in Exhibit 5-48. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of each activity follows the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font. In a few instances, some of these activities are conducted by the state instead of the water system. These activities are identified in the exhibit and further explained in the exhibit notes.
Exhibit 5-48: CWS Elementary School and Child Care Sampling Unit Burden and Cost Estimates for the Mandatory Program Phase (Years 4 - 8)
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
Create a contact list of schools and child cares served by the CWS and submit to Primacy Agency (one-time)
0.08 hrs/school or child care
hrs_school_identify_op
Develop lead outreach materials for schools and child cares (one-time)
3.5 hrs/CWS serving <= people;
20 hrs/CWS serving > 50,000 people
hrs_devel_pe_school_op
Prepare and distribute initial letter explaining the sampling program and the 3Ts Toolkit (one-time)
Burden
0.05 hrs/school or child care

Cost
$0.39 to $0.58/school or child care
Burden
hrs_school_letter_op

Cost
cost_school_letter
Contact school or child care to determine and finalize its sampling schedule (one-time)
School
0.5 hrs/school

Child Care
1 hr/child care
School
hrs_school_call_op

Child Care
hrs_childcare_call_op
Contact school or child care to coordinate sample collection logistics
0.25 hrs/school or child care

hrs_school_coor_sample_op
Conduct walkthrough at school or child care before the start of sampling
Burden
1.39 to 1.67 hrs/school or child care

Cost
$5.29 to $9.07/school or child care
Burden
hrs_walkthrough_school_op

Cost
cost_walkthrough_school
Travel to collect samples
Burden
0.39 to 0.67 hrs/school or child care

Cost
$5.29 to $9.07/school or child care
Burden
hrs_travel_samp_school_op

Cost
cost_travel_samp_school
Collect samples
Burden
0.17 hrs/sample

Cost
$1.83/sample for CWSs serving > 100,000 people
Burden
hrs_collect_samp_school_op

Cost
cost_collect_samp_school[1]
Analyze samples
In-House Analysis (CWSs > 100K only)
Burden: 0.44 hrs/sample
Cost: $2.38/sample

Commercial Analysis
$21.58/sample
In-House Analysis
hrs_analyze_samp_op[1]
cost_lab_lt_samp[1]

Commercial Analysis
cost_commercial_lab[1]
Provide sampling results to tested facilities
Burden
0.05 hrs/tested facility

Cost
$0.58/ tested facility
Burden
hrs_inform_samp_pe_school_op

Cost
cost_inform_samp_pe_school
Discuss sampling results with school and child care
1 hr/school or child care
hrs_result_discuss_op
Conduct detailed discussion of high sampling results with school and child cares
5 hr/sample
Burden
hrs_school_help_op
Prepare and provide annual report on school and child care sampling program to the Primacy Agency
Burden
1 to 8 hrs/CWS

Cost
$0.58/CWS
Burden
hrs_annual_report_school_prepare_op

Cost
cost_annual_report_school_dist
Acronyms: AL = action level; 3Ts Toolkit = "3Ts for Reducing Lead in Drinking Water Toolkit"; CWS = community water system; PWS = public water system.
Source: "Derivation of School_Child Care Inputs_Final Rule.xlsx." Other data sources are provided following this exhibit for each activity shown.
Note:
1 The burden and costs for these activities are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.

    Create a contact list of schools and child cares served by CWS and submit to Primacy Agency (hrs_school_identify_op). EPA assumed all CWSs would incur a one-time burden at the start of the program to create a contact list of schools and child cares in their service area and spend an average of 5 minutes (0.08 hours) per school or child care. EPA assumed a system can use its customer database and obtain needed additional information online. Although systems serving more than 10,000 people may spend less time to identify each facility, they are assumed to use additional hours to create an electronic tracking system. Thus, EPA also applied the 0.08 hours per facility to these larger systems.
    Develop lead outreach for schools and child cares (hrs_devel_pe_school_op). EPA assumed all CWSs would prepare outreach materials that describe the importance of lead testing and the systems lead in drinking water testing program. EPA assumed systems serving 50,000 or fewer people will require 3.5 hours to prepare and submit these materials for Primacy Agency review and those serving more than 50,000 people will require 20 hours. Burden estimates for systems serving 50,000 or fewer people are based on tier 2 public notice (PN) preparation burden (3.5 hours), and burden estimates for systems serving more than 50,000 people are based on tier 1 PN preparation burden for systems serving more than 10,000 people (30 hours) from the Public Water System Supervision Program Information Collection Request (ICR) (Renewal) (USEPA, 2015a). EPA assumed that all PWSs will use an EPA-developed template. Those serving 50,000 or fewer people would not modify the content. However, systems serving more than 50,000 people would adapt the template for their use but would require 20 hours as opposed to the 30-hour estimate for Tier 1 PN.
    Prepare and distribute the initial letter (hrs_school_letter_op, cost_school_letter). EPA assumed all CWSs would incur a one-time burden at the start of the program to prepare and distribute an initial letter explaining the sampling program and providing a link to the "3Ts for Reducing Lead in Drinking Water Toolkit" (3Ts Toolkit) (USEPA, 2018). EPA estimated on average systems would spend 1 hour per 20 letters or 0.05 hours per school or child care (hrs_school_letter_op). This estimate is based on the burden for a system to inform customers of their lead testing results as documented in the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 35 in Appendix H (USEPA, 2015b). Note that EPA conservatively assumed that systems will send letters to every school. However, the system may be able to send a letter to a single school district instead of individual schools as a cost savings.
   Systems will also incur paper ($0.025), envelope ($0.067), and first class ($0.49) or bulk rate postage costs ($0.30) to distribute the letter (cost_school_letter). CWSs serving 100,000 or fewer people will incur total materials cost per letter of $0.58 and those serving more than 100,000 will incur a total cost of $0.39 due to the bulk rate discount.
    Contact school or child care to determine and finalize its sampling schedule (hrs_school_call_op, hrs_childcare_call_op). EPA assumed systems would coordinate with each school or child care at the start of the program to plan when each facility will be sampled. EPA estimated systems would require two phone calls to reach the appropriate person at an average of 15 minutes (0.25 hours) per call for a total of 0.5 hours per school for this one-time activity. EPA assumed systems would require additional time to contact the child care at the start of the program to plan when each will be sampled. Some licensed day cares are home-based facilities that may not have additional support staff and may require multiple calls to reach the needed individual. EPA estimated systems would require four calls at an average of 15 minutes per call for a total of 1 hour for this one-time activity.
    Contact school or child care to coordinate sample collection logistics (hrs_school_coor_sample_op). EPA assumed systems will spend an average of 15 minutes (0.25 hours) calling each facility to coordinate sample collection logistics including scheduling a walkthrough.
    Conduct walkthrough at school or child care before the start of sampling (hrs_walkthrough_school_op, cost_walkthrough_school). EPA assumed systems will conduct a walkthrough with each school or child care to become familiar with the facility and to identify sampling sites. EPA assumed the following burden, which includes travel time roundtrip to each facility plus one hour spent conducting the walkthrough (hrs_walkthrough_school_op) given the equations below:
         CWSs serving 100,000 or fewer people: 1.39 hours = ((4.9 miles * 2)/25 miles per hr) + 1 hr
         CWSs serving 100,001 to 1,000,000 people: 1.5 hours = ((6.3 miles * 2)/25 miles per hr) + 1 hr
         CWSs serving more than 1,000,000 people: 1.67 hours = ((8.4 miles * 2)/25 miles per hr) + 1 hr.
    These estimates are based on census data and zip codes from the 2006 Community Water System Survey, assumed the following one-way driving distances for CWSs: 4.9 miles for those serving <= 100,000 people, 6.3 miles for those serving 100,001  -  1,000,000 people, and 8.4 miles for those serving greater than 1,000,000 people. For additional detail on how these estimates were derived, see "Derivation of Estimated Driving Distances_Final Rule.xlsx" EPA assumed an average speed of 25 miles per hour.
    Systems will also incur travel costs to conduct this walkthrough (cost_walkthrough_school) as follows:
        CWSs serving 100,000 or fewer people: $5.29 = (4.9 miles * 2) * $0.54 per mile
        CWSs serving 100,001 to 1,000,000 people: $6.80 = (6.3 miles * 2) * $0.54 per mile
        CWSs serving more than 1,000,000 people: $9.07 = (8.4 miles * 2) * $0.54 per mile.
   EPA assumed a mileage cost of $0.54 per mile using the 2016 federal reimbursement rate from the United States General Services Administration (GSA) (available in the docket at EPA-HQ-OW-2017-0300 at www.regulations.gov).
    Travel to collect samples (hrs_travel_samp_school_op, cost_travel_samp_school). Systems will incur burden to travel to a school or child care to collect samples (hrs_travel_samp_school_op). EPA assumed CWSs serving 100,000 or fewer people will spend 0.39 hours traveling round trip, those serving 100,001 to 1 million people will spend 0.50 hours, and those serving more than 1 million people will spend 0.67 hours. EPA used the same assumptions as those used to develop hrs_walkthrough_school_op that is discussed in activity hh) above excluding the 1 hour to conduct a walkthrough.
   CWSs will also incur vehicle costs for this roundtrip travel (cost_travel_samp_school). EPA used the same assumptions as those for cost_walkthrough_school that is discussed in activity hh)). EPA assumed the following costs: $5.29 for CWSs serving 100,000 or fewer people, $6.80 for those serving 100,001 to 1 million people, and $9.07 for those serving more than 1 million people.
    Collect samples (hrs_collect_samp_school_op, cost_collect_samp_school). The final LCRR requires systems to provide instructions to facilities on how to identify outlets for sampling at least 30 days prior to sampling. For cost modeling purposes, EPA assumed systems would collect the samples and would require 10 minutes (0.17 hours) per sample (hrs_collect_samp_school_op). This estimate is based on the assumption that the sample locations will be in the same building and the CWS has previously conducted a walkthrough to identify sampling locations.
    Based on information from laboratories, only CWSs serving more than 100,000 people are assumed to conduct in-house analyses for lead; whereas those serving 100,000 or fewer people will use a commercial lab. Bottles are supplied by the commercial lab. Thus, CWSs serving more than 100,000 people will incur a $1.83 per 250-mL wide mouth bottle assuming a bulk discount rate of 15 percent based on three vendors.
    Analyze samples (hrs_analyze_samp_op, cost_lab_lt_samp, cost_commercial_lab). CWSs will incur the same burden and cost to analyze the school and child care lead samples as they do analyzing compliance lead tap samples. Therefore, EPA used the same cost data variables for both in-house and commercial laboratory analysis of lead tap samples. Specifically, CWSs serving more than 100,000 people will incur a burden of 0.44 hrs per sample (hrs_analyze_samp_op) and a cost of $2.38 per sample (cost_lab_lt_samp) to analyze lead samples in-house. For these systems the likelihood that a sample will be analyzed in-house is 1 (pp_lab_samp_school) and the likelihood that the sample will be analyzed commercially is 0 (pp_commercial_samp_school). CWSs serving 100,000 or fewer will use a commercial lab at a cost of $21.58 per sample (cost_commercial_lab). For these systems pp_lab_samp_school is 0 and pp_commercial_samp_school is 1. See Section <IP_ADDRESS>.2, activity j) for additional detail.
    Provide sampling results to tested facilities (hrs_inform_samp_pe_school_op, cost_inform_samp_pe_school). CWSs must provide sampling results to each tested facility. EPA assumed systems will spend 0.05 hours or 1 hour per 20 letters (hrs_inform_samp_pe_school_op) based on the public education burden for systems to notify occupants of monitoring results from the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 35 (USEPA, 2015b). EPA also assumed CWSs will incur a material cost of $0.58/letter (cost_inform_samp_pe_school). EPA assumed information will be provided via mail (1 page of information, double-sided). Material costs include paper ($0.025), first class postage ($0.49), and an envelope ($0.067). Systems will provide the results of all testing to their Primacy Agency as part of an annual report that is discussed under activity oo). Systems must also provide results annually to state and local health officials and EPA assumed the results will be provided with the required lead outreach materials to these agencies and is captured in the data variable, cost_hc (see Section <IP_ADDRESS>, activity l)).
 Discuss sampling results with school and child cares (hrs_result_discuss_op). EPA assumed systems will incur additional burden to discuss the sampling results with each school and child care at an average burden of 1 hour per tested facility.
    Conduct detailed discussion of high sampling results with school and child cares (hrs_school_help_op). In response to comments received on the proposed rule EA EPA added an additional cost element designed to capture the additional burden to systems for discussing in greater detail high sampling results and the 3Ts Toolkit (USEPA, 2018) with school and child cares. EPA assumed systems will spend an additional 5 hours with each school or child care in which one or more samples are found to be high. The estimate includes time for the system to explain the relevant portions of the 3Ts Toolkit and to address any follow-up questions that school or child care might have after the initial discussion.
    Prepare and provide an annual report on testing program to Primacy Agencies (hrs_annual_report_school_prepare_op, cost_annual_report_school_dist). Systems are required to prepare and provide an annual report to their Primacy Agency regarding their testing program at schools and child cares. The report certifies the CWS made a good faith effort to identify all schools and child cares they serve, summarizes all sampling activities conducted at schools and child cares in a system's service area, and documents attempts that resulted in no response. Every five years, the system must include any updates to the list of schools or child cares facilities on confirmation of no change and is provided to the Primacy Agency. CWSs must keep documentation regarding schools and child cares that are non-responsive or decline to participate in the testing program. For modeling purposes, EPA assumed all schools and child cares would elect to participate in the testing program because the testing if free and they would want to better understand their potential sources of lead in drinking water.
   EPA assumed systems would incur the following burden to prepare and distribute the annual report (hrs_annual_report_school_prepare_op):
CWSs serving 100,000 or fewer people will incur a burden of 1 hour to prepare this report. This effort is similar to the estimated burden for a system of this size to report lead tap results and the 90[th] percentile calculation.
CWSs serving more than 100,000 people will be conducting sampling at a much larger number of schools and child cares per year than smaller systems. CWSs serving more than 100,000 people are assumed to have sophisticated tracking systems that can be used to generate their reports. EPA assumed systems serving 100,001  -  1,000,000 will require 2 hours and those serving more than 1,000,000 will require 8 hours to prepare the annual report.
   Systems also will incur mailing costs for paper ($0.025), an envelope ($0.067), and first-class postage ($0.49) to send a report to the Primacy Agency (cost_annual_report_school_dist). The material cost for this report is $0.58.
Exhibit 5-49 provides the SafeWater LCR model cost estimation approach for each activity under the mandatory program phase including additional cost inputs required to calculate these costs.
Exhibit 5-49: PWS Mandatory School and Child Care Sampling Phase Cost Estimation in SafeWater LCR by Activity[1][, 2]
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a Model PWS
Frequency of Activity

Lead 90[th] - Range
Other Conditions

 Create a contact list of schools and child cares and submit to Primacy Agency
The number of public elementary schools per system population times the system population multiplied by the hours to identify each facility and the system labor rate.

numb_elem_schools_pub*pws_pop*(hrs_school_identify_op*rate_op)

All
Model PWS that does not meet waiver requirements for public elementary school sampling

1 - p_grandfather_mand_pub
One time

The number of public secondary schools per system population times the system population multiplied by the hours to identify each school and the system labor rate.

numb_second_schools_pub*pws_pop *(hrs_school_identify_op*rate_op)
Cost does not apply to NTNCWSs.

Model PWS that does not meet waiver requirements for public secondary school sampling

1 - p_grandfather_mand_pub

The number of child cares per system population times the system population multiplied by the hours to identify each facility and the system labor rate.

numb_daycares*pws_pop *(hrs_school_identify_op*rate_op)

Model PWS that does not meet waiver requirements for child care sampling

1 - p_grand_mand_child

The number of private elementary schools per system population times the system population multiplied by the hours to identify each facility and the system labor rate.

numb_elem_schools_priv*pws_pop *(hrs_school_identify_op*rate_op)

Model PWS that does not meet waiver requirements for private elementary school sampling

1 - p_grandfather_mand_priv

The number of private secondary schools per system population times the system population multiplied by the hours to identify each school and the system labor rate.

numb_second_schools_priv*pws_pop *(hrs_school_identify_op*rate_op)

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

1 - p_grandfather_mand_priv

    Develop lead outreach materials for schools and child cares
The number of public elementary schools per system population times the system population multiplied by the hours per school times the system labor rate, plus the cost of materials.

numb_elem_schools_pub*pws_pop * (hrs_devel_pe_school_op)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet waiver requirements for public elementary school sampling

1 - p_grandfather_mand_pub
One time

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

numb_second_schools_pub*pws_pop *(hrs_devel_pe_school_op)

Model PWS that does not meet waiver requirements for public secondary school sampling

1 - p_grandfather_mand_pub

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

numb_daycares*pws_pop *(hrs_devel_pe_school_op)

Model PWS that does not meet waiver requirements for child care sampling

1 - p_grand_mand_child

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

numb_elem_schools_priv*pws_pop * (hrs_devel_pe_school_op)

Model PWS that does not meet waiver requirements for private elementary school sampling

1 - p_grandfather_mand_priv

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

numb_second_schools_priv*pws_pop v*(hrs_devel_pe_school_op)

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

1 - p_grandfather_mand_priv

    Prepare and distribute initial letter explaining the sampling program and the 3Ts Toolkit
The number of public elementary schools per system population times the system population multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

1 - p_grandfather_mand_pub
One time

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

numb_second_schools_pub*pws_pop*((hrs_school_letter_op*rate_op)+cost_school_letter)

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

1 - p_grandfather_mand_pub

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

numb_daycares*pws_pop*((hrs_school_letter_op*rate_op)+cost_school_letter)

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

1 - p_grandfather_mand_child

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

numb_elem_schools_priv*pws_pop*((hrs_school_letter_op*rate_op)+cost_school_letter)

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

1 - p_grandfather_mand_priv

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

numb_second_schools_priv*pws_pop*((hrs_school_letter_op*rate_op)+cost_school_letter)

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

1 - p_grandfather_mand_priv

    Contact school or child care to determine and finalize its sampling schedule
The number of public elementary schools per system population times the system population multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

1 - p_grandfather_mand_pub
One time

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

numb_second_schools_pub*pws_pop*(hrs_school_call_op*rate_op)

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

1 - p_grandfather_mand_pub

The number of child cares per system population times the system population multiplied by the hours per facility and the system labor rate.

numb_daycares *(hrs_childcare_call_op*rate_op)

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

1 - p_grandfather_mand_child

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

numb_elem_schools_priv*pws_pop*(hrs_school_call_op*rate_op)

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

1 - p_grandfather_mand_priv

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

numb_second_schools_priv*pws_pop*(hrs_school_call_op*rate_op)

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

1 - p_grandfather_mand_priv

    Contact school or child care to coordinate sample collection logistics
20% of public elementary schools multiplied by the hours per school and the system labor rate.

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

1 - p_grandfather_mand_pub
Once a year

20% of public secondary schools multiplied by the hours per school and the system labor rate.

(numb_second_schools_pub*pws_pop*pp_mand_twenty_partic)*(hrs_school_coor_sample_op*rate_op)

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the hours per facility and the system labor rate.

(numb_daycares*pws_pop*pp_mand_twenty_partic)*(hrs_school_coor_sample_op*rate_op)

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

1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the hours per school and the system labor rate.

(numb_elem_schools_priv*pws_pop*pp_mand_twenty_partic)*(hrs_school_coor_sample_op*rate_op)

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the hours per school and the system labor rate.

(numb_second_schools_priv*pws_pop*pp_mand_twenty_partic)*(hrs_school_coor_sample_op*rate_op)

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

1 - p_grandfather_mand_priv

    Conduct walkthrough at school or child care before start of sampling
20% of public elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

1 - p_grandfather_mand_pub
Once a year

20% of public secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the hours per facility times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_priv

    Travel to collect samples
20% of public elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

1 - p_grandfather_mand_pub
Once a year

20% of public secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the hours per facility times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_priv

    Collect samples[3]
20% of public elementary schools multiplied by the number of samples per school, is multiplied by the number of hours per school times the system labor rate, plus the material cost.

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

1 - p_grandfather_mand_pub
Once a year

20% of public secondary schools multiplied by the number of samples per school, is multiplied by the number of hours per school times the system labor rate, plus the material cost.

(numb_second_schools_pub*pws_popl*pp_mand_twenty_partic)*numb_samp_five)*((hrs_collect_samp_school_op*rate_op)+cost_collect_samp_school)

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the number of samples per facility, is multiplied by the number of hours per facility times the system labor rate, plus the material cost.

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

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

1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the number of samples per school, is multiplied by the number of hours per school times the system labor rate, plus the material cost.

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

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the number of samples per school, is multiplied by the number of hours per school times the system labor rate, plus the material cost.

(numb_second_schools_priv*pws_popl*pp_mand_twenty_partic)*numb_samp_five)*((hrs_collect_samp_school_op*rate_op)+cost_collect_samp_school)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for private secondary school sampling

1 - p_grandfather_mand_priv

    Analyze samples[3]
The number of required samples per public elementary school multiplied by 20% of elementary schools per year times by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

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

1 - p_grandfather_mand_pub
Once a year

The number of required samples per public secondary school multiplied by 20% of elementary schools per year times by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

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

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

1 - p_grandfather_mand_pub

The number of required samples per day care multiplied by 20% of elementary schools per year times by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

((((numb_daycares*pws_pop*pp_mand_twenty_partic)*numb_samp_five)*pp_lab_samp_school)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_samp))+((((numb_daycares*pws_pop*pp_mand_twenty_partic)*numb_samp_five)*pp_commercial_samp_school)*cost_commercial_lab)
Cost does not apply to NTNCWSs.
All
Model PWS that does not meet the requirements to be grandfathered into the program for child care sampling

1 - p_grandfather_mand_child

The number of required samples per private elementary school multiplied by 20% of elementary schools per year times by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

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

1 - p_grandfather_mand_priv

The number of required samples per private secondary school multiplied by 20% of elementary schools per year times by the probabilities for a sample analyzed in house and a sample analyzed in a commercial lab times the different labor and material cost burdens for each type of analysis.

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

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

1 - p_grandfather_mand_priv

    Provide sampling results to tested facilities
20% of public elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

1 - p_grandfather_mand_pub
Once a year

20% of public secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the hours per facility times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the hours per school times the system labor rate, plus the cost of materials.

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

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

1 - p_grandfather_mand_priv

    Discuss sampling results with school and child cares
20% of public elementary schools multiplied by the hours per school times the system labor rate.

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

1 - p_grandfather_mand_pub
Once a year

20% of public secondary schools multiplied by the hours per school times the system labor rate.

(numb_second_schools_pub*pws_pop*pp_mand_twenty_partic)*(hrs_result_discuss_op*rate_op)

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the hours per facility times the system labor rate.

(numb_daycares*pws_pop*pp_mand_twenty_partic)*(hrs_result_discuss_op*rate_op)

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

 1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the hours per school times the system labor rate.

(numb_elem_schools_priv*pws_pop*pp_mand_twenty_partic)*(hrs_result_discuss_op*rate_op)

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the hours per school times the system labor rate.

(numb_second_schools_priv*pws_pop*pp_mand_twenty_partic)*(hrs_result_discuss_op*rate_op)

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

1 - p_grandfather_mand_priv

    Conduct detailed discussion of high sampling results with school and child cares
20% of public elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

(numb_elem_schools_pub*pws_pop*pp_mand_twenty_partic)* ((pp_above_al_bin_three*numb_samp_five)*(hrs_school_help_op*rate_op))
 Cost does not apply to NTNCWSs.
 At or below the TL
 Model PWS that does not meet the requirements to be grandfathered into the program for public elementary school sampling

1 - p_grandfather_mand_pub
 Once a year

20% of public secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

 1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_priv

20% of public elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

1 - p_grandfather_mand_pub
 Once a year
20% of public secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

 1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_priv

20% of public elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

1 - p_grandfather_mand_pub

 Once a year

20% of public secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_pub

20% of child cares multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

 1 - p_grandfather_mand_child

20% of private elementary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_priv

20% of private secondary schools multiplied by the number of required samples per system >15 ug/L multiplied by the hours per sample times the system labor rate.

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

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

1 - p_grandfather_mand_priv

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

(hrs_annual_report_school_prepare_op*rate_op)+cost_annual_report_school_dist
Cost does not apply to NTNCWSs.
All
All model PWSs
Once a year
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
[1] The data variables in the exhibit are defined previously in this section with the exception of:
 numb_daycares, numb_elem_schools_priv, numb_elem_school_pub, numb_second_schools_priv, numb_second_school_pub: Number of child cares, number of private elementary schools, number of public elementary schools, number of public secondary schools, and number of private secondary schools, respectively that are served by CWSs (Section <IP_ADDRESS>).
 p_grandfather_mand_child, p_grandfather_mand_priv, p_grandfather_mand_pub: States that qualify to waiver child cares, private K-12 schools, and public K-12 schools for the mandatory program (Section <IP_ADDRESS>).
 pp_above_al_bin_one: Likelihood a sample will be > 15 ug/L when the system's lead 90[th] percentile level  is > 15 ug/L (Section <IP_ADDRESS>).
 pp_above_al_bin_two: Likelihood a sample will be > 15 ug/L when the system's lead 90[th] percentile level is above 10 ug/L but at or below 15 ug/L (Section <IP_ADDRESS>).
 pp_above_al_bin_three: Likelihood a sample will be > 15 ug/L when the system's lead 90[th] percentile level is <= 10 ug/L (Section <IP_ADDRESS>).
 rate_op: PWS hourly labor rate (Section <IP_ADDRESS>).
2 The mandatory testing phase is assumed to occur in years 4 through 8 at elementary schools and child cares.
[3] The burden and costs to provide sample bottles (cost_collect_samp_school) under activity kk) and conduct analyses under activity ll) are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.
On Request Program
As stated above, under the final LCRR, CWSs can discontinue mandatory testing after they complete one 5-year cycle of testing at elementary schools and child cares. After those first 5 years of mandatory testing, CWSs would only be required to sample at those facilities that request sampling. Secondary schools are not subject to mandatory testing but CWS are required to test any secondary school that request testing. EPA assumed that five percent of elementary and secondary schools and licensed child cares per year would elect to participate in the sampling program (pp_voluntary_partic). This estimate is based on EPA's discussions with GCWW about their school testing program (available in the docket). GCWW indicated that they had a low response rate from schools under their initial program that involved sending out letters to school districts offering to assist schools in testing their drinking water outlets for lead, which is similar to the on request program requirements.
EPA has developed system burden and costs for ten activities the Agency has identified as necessary to implement the on request program for drinking water testing at schools and child cares as shown in Exhibit 5-50. The exhibit provides the unit burden and/or cost for each activity. The assumptions used in the estimation of each activity follows the exhibit. The last column provides the corresponding SafeWater LCR model data variable in red/italic font. In a few instances, some of these activities are conducted by the state instead of the water system. These activities are identified in the exhibit and further explained in the exhibit notes.
Exhibit 5-50: PWS School and Child Care Sampling Unit Burden and Cost Estimates under the On Request Program
                                   Activity
                            Unit Burden and/or Cost
                          SafeWater LCR Data Variable
Contact school and child cares to offer sampling
Burden
0.05 hrs/school or child care

Cost
$0.39 to $0.58
Burden
hrs_school_annual_contact_op

Cost
cost_school_annual_contact
Contact school or child care to coordinate sample collection logistics
0.25 hrs/school or child care

hrs_school_coor_sample_op
Conduct walkthrough at school or child care before the start of sampling
Burden
1.39 to 1.67 hrs/school or child care

Cost
$5.29 to $9.07/school or child care
Burden
hrs_walkthrough_school_op

Cost
cost_walkthrough_school
Travel to collect samples
Burden
0.39 to 0.67 hrs/school or child care

Cost
$5.29 to $9.07/school or child care
Burden
hrs_travel_samp_school_op

Cost
cost_travel_samp_school
Collect samples
Burden
0.17 hrs/sample

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

Cost
cost_collect_samp_school[1]
Analyze samples
In-house Analysis (CWSs > 100K only)
Burden: 0.44 hrs/sample
Cost: $2.38/sample

Commercial Analysis
$21.58/sample
In-House Analysis
hrs_analyze_samp_op[1]
cost_lab_lt_samp[1]

Commercial Analysis
cost_commercial_lab[1]
Provide sampling results to tested facilities
Burden
0.05 hrs/tested facility

Cost
$0.58/ tested facility
Burden
hrs_inform_samp_pe_school_op

Cost
cost_inform_samp_pe_school
Discuss sampling results with school and child care
1 hr/school or child care
hrs_result_discuss_op
Detailed discussion of high sampling results with school and child cares
5 hr/sample
Burden
hrs_school_help_op
Prepare and provide annual report on school and child care sampling program to the Primacy Agency
Burden
1 to 8 hrs/CWS

Cost
$0.58/CWS
Burden
hrs_annual_report_school_prepare_op

Cost
cost_annual_report_school_dist
Acronyms: AL = action level; CWS = community water system; PWS = public water system.
Source: "Derivation of School_Child Care Inputs_Final Rule.xlsx." Other data sources are provided following this exhibit for each activity shown.
Note:
1 The burden and costs for these activities are incurred by the state in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina.

 Contact schools and child cares to offer sampling (hrs_school_annual_contact_op, cost_school_annual_contact). CWSs will send a letter to public and private elementary and secondary schools and to each child care explaining the sampling program, asking if the school/child care wants to have their taps tested, and providing health information on lead and a link to the 3Ts (USEPA, 2018). EPA assumed systems would use a template letter and spend 1 hour per 20 letters or 3 minutes (0.05 hrs) per letter for all system sizes. This assumption is consistent with the burden for the letter that goes to customers to inform them of their lead testing results (hrs_inform_samp_op) that is discussed in <IP_ADDRESS>.2, activity l). The estimate is based on the Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 35 (USEPA, 2015b).
     CWSs will also incur costs for paper, envelope, and postage. Those serving more than 100,000 people are assumed to incur a cost of $0.58 per letter and those serving more than 100,000 people will qualify for bulk rate mail and incur a cost of $0.39 per letter.