EPA
ICR
Number:
1912.01
EPA
Document
Number:
OMB
Control
Number:

Information
Collection
Request:
National
Primary
Drinking
Water
Regulations
For
Lead
and
Copper
Prepared
By:

The
Cadmus
Group
135
Beaver
Street
Waltham,
MA
02154
EPA
Contract
No.
68­
C4­
0051
Work
Assignment
4­
29
Ms.
Tangela
Cooper
Project
Officer
Ms.
Judy
Lebowich
Technical
Project
Monitor
U.
S.
Environmental
Protection
Agency
Office
of
Ground
Water
and
Drinking
Water
Washington
D.
C.

June
1999
June
1999
i
TABLE
OF
CONTENTS
PAGE
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
1(
a)
Title
And
Number
Of
The
Information
Collection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
1(
b)
Short
Characterization/
Abstract
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3
2(
a)
Need/
Authority
For
The
Collection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3
2(
b)
Practical
Utility/
Users
Of
The
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
3
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
.
.
.
.
.
6
3(
a)
Non­
duplication
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3(
c)
Consultations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3(
d)
Effects
Of
Less
Frequent
Collection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8
3(
e)
General
Guidelines
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8
3(
f)
Confidentiality
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
3(
g)
Sensitive
Questions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
4
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
4(
a)
Respondents/
SIC
Codes
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
4(
b)
Information
Requested
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
4(
b)(
i)
Data
Items,
Including
Record
Keeping
and
Reporting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
4(
b)(
ii)
Respondent
Activities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
17
5
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
23
5(
a)
Agency
Activities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
23
5(
b)
Collection
Methodology
And
Management
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
24
5(
c)
Small
Entity
Flexibility
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
24
5(
d)
Collection
Schedule
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
27
6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
27
6(
a)
Estimating
Respondent
Burden
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
28
6(
a)(
i)
Burden
To
Public
Water
Systems
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
28
6(
a)(
ii)
Burden
To
States
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
41
6(
b)
Estimating
Respondent
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
51
6(
b)(
i)
Costs
To
Public
Water
Systems
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
51
6(
b)(
ii)
Costs
to
States
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
54
6(
c)
Estimating
Agency
Burden
And
Cost
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
56
6(
c)(
i)
Burden
and
Costs
to
Headquarters
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
56
6(
c)(
ii)
Burdens
and
Costs
to
Regional
Staff
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
57
6(
c)(
iii)
Contractor
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
58
June
1999
ii
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
58
6(
e)
Bottom
Line
Burden
Hours
And
Cost
Table
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
58
6(
f)
Reasons
For
Change
In
Burden
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
60
6(
f)(
i)
Explanation
of
Differences
between
Currently­
Approved
Baseline
and
the
Revised
Baseline
Estimates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
60
6(
f)(
ii)
Differences
between
the
LCRMR
and
LCR
Burdens
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
64
6(
g)
Burden
Statement
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
65
June
1999
iii
LIST
OF
FIGURES
Figure
5­
1:
Annual
Burden
Indicators
for
the
LCR
Minor
Revisions
(
for
ICR
period
1999­
2001)
.
.
.
.
.
26
Figure
6­
1:
Change
in
Annual
System
Burden
for
1999
through
2001
due
to
LCRMR
(
in
hours)
.
.
.
.
.
29
Figure
6­
2:
Change
in
Annual
State
Burden
for
1999
through
2001
due
to
LCRMR
(
in
hours)
.
.
.
.
.
.
.
42
Figure
6­
3:
Analytical
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
52
Figure
6­
4:
Change
in
Annual
System
Cost
for
1999
through
2001
due
to
LCRMR
(
in
$
1,000'
s)
.
.
.
.
.
53
Figure
6­
5:
Change
in
Annual
State
Costs
for
1999
through
2001
due
to
LCRMR
(
in
$
1,000'
s)
.
.
.
.
.
.
55
Figure
6­
6:
Average
Annual
Agency
Burdens
and
Costs,
1999­
2001
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
56
Figure
6­
7:
Change
in
Respondent
Average
Annual
Burdens
and
Costs
for
1999­
2001
.
.
.
.
.
.
.
.
.
.
.
.
.
59
Figure
6­
8:
Annual
Burden
and
Costs
by
Year
for
1999
­
2001
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
60
Figure
6­
9:
Comparison
of
System
Burden
and
Costs
Estimates
of
the
Drinking
Water
ICR
and
Revised
Baselines
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
61
Figure
6­
10:
Assumptions
that
Differ
between
the
Currently
Approved
Baseline
and
Revised
Baseline
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
62
Figure
6­
11:
Detailed
State
Cost
Comparison
between
the
Currently­
Approved
Baseline
and
the
Revised
Baseline
(
Costs
are
in
$
millions)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
63
Figure
6­
12:
Change
in
Annual
Respondent
Burden
(
in
hours)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
65
Figure
6­
13:
Change
in
Annual
Non­
Labor
Respondent
Costs
($)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
65
June
1999
1
Community
water
systems
(
CWSs)
are
public
water
systems
(
PWSs)
that
have
at
least
15
service
connections
used
by
year
round
residents
or
regularly
serve
at
least
25
year­
round
residents.
Nontransient
non­
community
water
systems
(
NTNCWSs)
are
PWSs
that
are
not
CWSs
but
regularly
serve
at
least
25
of
the
same
persons
over
six
months
a
year.
Throughout
the
rest
of
this
document,
the
reference
to
water
systems,
systems,
and
PWSs
include
only
these
two
types
of
PWS.

2
Throughout
the
rest
of
this
document,
the
term
State
refers
to
a
State
or
federally­
recognized
Indian
Tribe
that
has
been
granted
primacy
with
respect
to
the
LCR
or
the
appropriate
EPA
Region
(
where
the
State
or
Tribe
does
not
have
primacy).

1
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
And
Number
Of
The
Information
Collection
TITLE:
Information
Collection
Request
for
the
National
Primary
Drinking
Water
Regulations
for
Lead
and
Copper
U.
S.
EPA
ICR
Number:
1912.01
OMB
Control
Number:_____

1(
b)
Short
Characterization/
Abstract
The
National
Primary
Drinking
Water
Regulations
(
NPDWRs)
for
Lead
and
Copper
(
The
Lead
and
Copper
Rule
or
LCR),
promulgated
by
EPA
in
1991,
is
a
regulatory
program
mandated
by
the
Safe
Drinking
Water
Act
(
SDWA).
The
LCR's
goal
is
to
reduce
the
levels
of
lead
and
copper
at
the
tap
to
as
close
to
the
maximum
contaminant
level
goals
of
0
parts
per
billion
(
ppb)
of
lead
and
1.3
ppb
of
copper
as
possible.
To
accomplish
this,
the
LCR
requires
community
and
non­
transient
non­
community
water
systems1
to
optimize
corrosion
control
and,
under
specified
conditions,
install
source
water
treatment,
conduct
public
education,
and/
or
replace
lead
service
lines
in
the
distribution
system.

Water
systems
include
Federal,
State,
Tribal,
and
local
governmental
entities
as
well
as
private
entities.
States
(
and
Tribes)
that
have
been
granted
primary
enforcement
authority
(
i.
e.,
primacy)
for
the
LCR
are
responsible
for
overseeing
rule
implementation
by
systems
within
their
jurisdiction.
In
instances
where
a
State
or
Tribe
does
not
have
primacy,
the
EPA
Region
is
the
Primacy
Agent.
2
Systems
demonstrate
compliance
through
reporting
the
analytical
results
of
collected
samples
and
other
information
to
the
State.
Systems
use
these
data
to
demonstrate
compliance,
assess
treatment
options,
operate
and
maintain
installed
treatment,
and
communicate
water
quality
information
to
consumers
served
by
the
system.
States
utilize
the
data
to
determine
compliance
and
designate
treatment
to
be
installed
and
enforceable
operating
parameters.
States
also
are
required
to
report
a
subset
of
the
data
to
EPA
which
utilizes
this
information
to
protect
public
health
by
ensuring
compliance
with
the
LCR,
measuring
progress
toward
meeting
the
LCR's
goals,
and
evaluating
the
appropriateness
of
State
implementation
activities.
EPA
stores
the
information
reported
by
States
in
the
Safe
Drinking
Water
Information
System
(
SDWIS).
June
1999
3
The
LCR
defines
action
levels
for
lead
and
copper
in
tap
water
samples.
These
levels
are
set
at
the
90th
percentile
level
and
establish
a
limit,
which
cannot
be
exceeded
by
more
than
ten
percent
of
the
tap
water
samples.
The
lead
action
level
is
0.015
mg/
L
and
the
copper
action
level
is
1.3
mg/
L.

2
System
implementation
of
the
LCR
begins
with
initial
monitoring
for
lead
and
copper
at
the
tap
and,
in
some
cases,
for
water
quality
parameters
(
WQPs)
and/
or
source
water
lead/
copper
concentrations.
States
deem
some
systems
to
have
optimized
corrosion
control
based
on
the
results
of
this
initial
monitoring.
Deemed
systems
must
continue
to
monitor
periodically
for
lead
and
copper
at
the
tap
and,
in
some
cases
for
lead
and
copper
in
source
water,
but
are
not
required
to
conduct
routine
WQP
monitoring
or
to
implement
the
LCR's
other
treatment
technique
requirements.
All
other
systems
are
required
to
assess
alternative
corrosion
control
technologies,
and
to
make
corrosion
control
treatment
and
source
water
treatment
recommendations
to
the
State
who
then
must
specify
what
treatment
the
system
is
to
install.
Systems
exceeding
the
lead
action
level
also
must
conduct
public
education
programs.
3
Following
installation
of
required
treatment,
systems
must
conduct
follow­
up
monitoring,
after
which
the
State
specifies
the
optimal
water
quality
parameter
levels
or
ranges
and,
if
appropriate,
maximum
permissible
source
water
levels,
within
which
the
system
must
then
operate.
Such
systems
must
continue
periodic
lead/
copper
tap
water
monitoring
and,
in
some
cases,
WQP
and
source
water
monitoring.
Systems
with
lead
service
lines
in
the
distribution
system
must
implement
a
lead
service
line
replacement
program
if
they
continue
to
exceed
the
lead
action
level
after
the
installation
of
corrosion
control
and/
or
source
water
treatment.

The
Final
Information
Collection
Request
for
the
National
Primary
Drinking
Water
Regulations
for
Lead
and
Copper,
April
1991,
supports
the
1991
LCR
rule
and
contains
the
system,
State,
and
Agency
record
keeping
and
reporting
burden
and
costs
for
the
LCR
(
hereafter
referred
to
as
the
1991
ICR).
The
LCR
burdens
and
costs
were
subsequently
incorporated
into
a
comprehensive
Information
Collection
Request
(
ICR)
document
for
the
drinking
water
program,
entitled,
the
Collection
Request
for
the
Public
Water
System
Supply
Program,
December
1993,
EPA
tracking
number
0270.39
and
OMB
number
2040­
0090
(
hereafter
referred
to
as
the
Drinking
Water
ICR).

The
purpose
of
this
ICR
document
is
threefold.
First,
it
amends
the
Drinking
Water
ICR
to
remove
the
LCR
burden
and
costs.
Second,
it
presents,
in
a
stand­
alone
Lead
and
Copper
Rule
ICR,
the
LCR
burden
and
costs
for
the
three­
year
period
of
1999
through
2001.
These
impacts
have
been
recalculated
based
on
updated
assumptions
reflecting
actual
experience
with
rule
implementation
to
date
and
current
pricing
factors
(
e.
g.,
labor
rates).
Finally,
this
ICR
presents
the
impacts
of
the
Lead
and
Copper
Rule
Minor
Revisions
(
LCRMR)
on
the
LCR
burden
and
costs
for
the
same
three­
year
period.
The
intent
of
the
LCRMR
is
to
streamline
and
reduce
burden,
address
implementation
issues,
and
respond
to
judicially­
remanded
issues.
These
modifications
still
require
PWSs
and
States
to
collect
and
report
monitoring­
related
and
treatment­
related
information;
however,
some
of
the
specific
requirements
have
changed.
Under
the
LCRMR,
information
still
must
be
collected
and/
or
reported
every
two
weeks
(
biweekly
quarterly,
semi­
annually,
triennially,
and
every
nine
years.

For
the
three­
year
period
of
1999­
2001,
the
average
annual
burden
associated
with
the
1991
LCR
is
1,990,330
hours
for
the
75,945
system
respondents
and
428,116
hours
for
the
56
State
respondents.
The
average
annual
costs
for
systems
and
States
is
$
49,921,200
and
$
10,848,500,
respectively.
The
average
June
1999
3
annual
system
and
State
burden
per
response
is
42
hours
and
the
average
annual
cost
per
response
is
$
1,067.
These
burden
and
cost
estimates
represent
those
EPA
expects
would
occur
in
this
three­
year
period
only,
assuming
systems
are
in
compliance
with
the
implementation
schedule
in
the
1991
LCR.

The
burden
impacts
for
the
LCRMR
have
been
calculated
on
the
same
basis.
Thus,
start­
up
burden
and
costs
associated
with
the
LCRMR
are
reflected
in
the
year(
s)
they
are
estimated
to
occur
and
not
pro­
rated
throughout
an
extended
implementation
period.
The
LCRMR
represent
an
average
annual
burden
decrease
of
36,773
hours
for
the
75,945
system
respondents
and
an
increase
of
50,055
hours
for
the
56
State
respondents.
The
average
annual
cost
for
systems
decreases
by
$
2,823,900
and
the
average
annual
cost
for
States
increases
by
$
2,168,400.
The
average
annual
system
and
State
burden
per
response
increases
by
0.3
hours
and
the
average
annual
cost
per
response
decreases
by
$
14.
Most
of
the
system
reduction
results
from
revisions
to
monitoring
requirements
that
allow
less
frequent
monitoring
and
the
elimination
of
some
system
reporting
requirements.
The
increase
in
State
costs
is
concentrated
in
the
first
three
years
following
promulgation
of
the
LCRMR
and
is
due
to
the
following
five
factors:
(
1)
start­
up
activities
to
revise
State
regulations
and
to
train
State
and
system
staff
on
the
revisions;
(
2)
State
flexibility
to
specify
monitoring
sites
for
systems
on
reduced
lead
and
copper
tap
monitoring;
(
3)
significant
changes
in
the
State
reporting
requirements
that
should
reduce
overall
State
reporting
burden
and
costs
in
the
outyears
while
improving
the
usefulness
of
the
data
to
EPA;
(
4)
State
flexibility
to
calculate
90th
percentile
levels
for
systems;
and
(
5)
increased
State
flexibility
to
allow
some
systems
to
avoid
some
burden/
costs
that
will
require
the
State
to
make
additional
system­
specific
determinations
(
e.
g.,
approve
monitoring
waivers
for
small
water
systems
that
are
free
of
lead­
containing
and/
or
copper­
containing
materials).

2
NEED
FOR
AND
USE
OF
THE
COLLECTION
The
following
sections
describe
the
need
for
this
information
collection,
the
legal
authority
under
which
this
information
can
be
collected,
and
how
collecting
this
information
will
support
drinking
water
program
objectives.

2(
a)
Need/
Authority
For
The
Collection
EPA
needs
comprehensive
and
current
information
on
lead
and
copper
contamination
and
associated
enforcement
activities
to
implement
its
program
oversight
and
enforcement
responsibilities
mandated
by
the
Safe
Drinking
Water
Act
(
SDWA).
EPA
will
use
the
information
collected
as
a
result
of
the
LCRMR
to
support
these
responsibilities.

The
modifications
outlined
in
this
document
are
intended
to
improve
the
implementation
of
the
LCR,
and
do
not
alter
the
original
maximum
contaminant
level
goals
or
the
fundamental
approach
to
controlling
lead
and
copper
in
drinking
water.
The
modifications
address
the
following
topics:
requirements
for
systems
deemed
to
optimize
corrosion
control
under
§
141.81(
b)(
1)
through
§
141.86(
b)(
3),
systems
on
reduced
monitoring
that
change
treatment
or
add
a
new
source,
replacement
and
notification
requirements
for
systems
subject
to
lead
service
line
replacement,
public
education
reporting
and
delivery
requirements,
sampling
sites,
reduced
monitoring,
sample
invalidation,
monitoring
waivers,
entry
point
monitoring
for
WQPs,
compliance
with
State­
designated
optimal
water
quality
parameter
(
OWQP)
ranges
or
values,
resampling
triggers
for
composited
source
water
samples,
laboratory
certifications,
analytical
June
1999
4
methods,
and
reporting
requirements
for
systems
and
States.
The
information
associated
with
these
modifications
will
assist
the
Agency
in
meeting
its
statutory
mandates,
which
are
ultimately
designed
to
protect
public
health.

Section
1401(
1)(
D)
of
the
SDWA
requires
that
"
there
must
be
criteria
and
procedures
to
assure
a
supply
of
drinking
water
which
dependably
complies
with
such
maximum
contaminant
levels,
including
quality
control
and
testing
procedures
to
insure
compliance
with
such
levels
and
to
insure
proper
operation
and
maintenance
of
the
system..."
Furthermore,
Section
1445(
a)(
1)
of
the
SDWA
requires
that
"
every
person
who
is
a
supplier
of
water...
shall
establish
and
maintain
such
records,
make
such
reports,
conduct
such
monitoring,
and
provide
such
information
as
the
Administrator
may
reasonably
require
by
regulation
to
assist
him
in
establishing
regulations,
in
determining
whether
such
person
has
acted
or
is
in
compliance
with
this
title..."
In
addition,
Section
1413(
a)(
3)
of
the
SDWA
requires
States
to
"
keep
such
records
and
make
such
reports...
as
the
Administrator
may
require
by
regulation."

Section
1412(
b)
of
the
1986
SDWA,
as
amended
in
1996,
requires
the
Agency
to
publish
maximum
contaminant
level
goals
and
promulgate
NPDWRs
for
contaminants
that
may
have
an
adverse
effect
on
healths
of
persons,
are
known
to
or
anticipated
to
occur
in
PWSs,
or,
in
the
opinion
of
the
Administrator,
present
an
opportunity
for
health
risk
reduction.
The
NPDWRs
specify
maximum
contaminant
levels
or
treatment
techniques
for
drinking
water
contaminants
(
42
USC
300g­
1).
Promulgation
of
the
LCR
complies
with
statutory
requirements.

The
sections
from
the
SDWA
1996
Amendments,
discussed
above,
are
included
as
Appendix
C
to
this
document.

2(
b)
Practical
Utility/
Users
Of
The
Data
PWSs
must
maintain
records
of
the
results
of
analytical
monitoring.
PWSs
use
these
data
to:


Evaluate
system­
specific
needs,
including
examining
treatment
effectiveness;


Adjust
monitoring
frequencies
and
schedules,
to
address
possible
public
health
concerns;
and

Assess
compliance
and
to
determine
when
it
is
necessary
to
alert
the
public
of
possible
health
risks
resulting
from
non­
compliance
with
federal
or
State
regulations.

State­
level
record
keeping
consists
of
maintaining
records
on
each
system's
monitoring
requirements
and
analytical
results,
and
associated
State
decisions
regarding
the
designation
of
WQP
levels
in
the
distribution
system
and
maximum
permissible
levels
(
MPLs)
of
lead
and
copper
in
source
water,
which
systems
must
conduct
corrosion
control
studies,
treatment(
s)
to
be
installed,
and
the
need
for
an
accelerated
lead
service
line
replacement
schedule.
Such
records
assist
managers
in
evaluating
system
compliance
and
in
identifying
system
needs
and
problem
areas.
The
data
are
also
used
to
construct
enforcement
targets
and
identify
systems
requiring
remedial
action.
June
1999
5
Information
provided
to
EPA
by
the
States
is
stored
in
SDWIS.
This
centralized
storage
allows
the
Agency
to
conduct
various
program
analyses.
For
example,
SDWIS
can
characterize
compliance
trends
at
the
system,
State,
and
national
program
levels.
SDWIS
supports
the
critical
Agency
function
of
maintaining
program
oversight,
including
ensuring
consistent
implementation
of
the
LCR's
requirements
and
related
State
and
federal
enforcement
actions.

The
States
and
Agency
have
a
number
of
mission­
critical
questions
to
answer
regarding
their
supervision
of
regulated
PWSs.
Several
of
these
questions
are
listed
below.

At
the
system
level:


Is
each
PWS
complying
with
all
applicable
NPDWR
requirements?


For
systems
not
in
compliance,
what
particular
rules
have
been
violated
and
to
what
extent?


For
systems
not
in
compliance,
have
appropriate
steps,
including
enforcement
actions,
been
taken
to
return
such
systems
to
compliance?


What
public
health
threats,
if
any,
have
resulted
from
noncompliance?

At
the
national
and
State
level:


What
are
the
national
and
State
compliance
trends?


What
changes
in
national
policy
or
regulations
may
be
needed
to
increase
compliance
rates?


What
factors
are
contributing
to
noncompliance?

EPA's
Office
of
Ground
Water
and
Drinking
Water
(
OGWDW)
and
other
EPA
offices
that
implement
regulatory
programs
mandated
by
several
environmental
statutes
(
e.
g.,
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act;
Resource
Conservation
and
Recovery
Act;
and
the
Toxic
Substances
Control
Act)
use
LCR
data
to
support
program
implementation.
Non­
EPA
organizations
also
use
these
data.
These
organizations
include
the
Rural
Development
Administration
(
formerly
Farmers
Home
Administration),
the
Department
of
the
Interior,
the
Department
of
Housing
and
Urban
Development,
the
U.
S.
Army
Corps
of
Engineers,
the
Federal
Emergency
Management
Agency,
the
Small
Business
Administration,
White
House
Task
forces,
environmental
and
industry
groups,
and
many
private
companies
and
individuals.

EPA
often
receives
requests
for
PWS
monitoring
data
under
the
Freedom
of
Information
Act
(
FOIA).
Many
FOIA
Act
requests
require
extracting
information
contained
in
the
SDWIS
regarding
the
number
of
PWSs
in
violation
of
drinking
water
standards
in
a
particular
geographic
area
and
those
PWSs
that
have
exceeded
the
lead
or
copper
action
level.
The
LCRMR
will
improve
the
implementation
of
the
June
1999
4
This
document
is
entitled,
Information
Collection
Request
Proposed
Changes
to
National
Primary
Drinking
Water
Regulations
for
Lead
and
Copper,
EPA
812­
B­
96­
003,
January
1996.

5
In
developing
the
final
version
of
the
1991
LCR,
EPA
consulted
with
the
National
Drinking
Water
Advisory
Council
and
requested
comments
from
its
Science
Advisory
Board.
The
monitoring
requirements
reflect
comments
by
the
drinking
water
industry.
In
addition,
during
the
comment
period
for
the
1991
LCR,
approximately
28,000
comments
were
received
from
approximately
3,000
individuals
and
organizations.

6
LCR
and
assist
the
Agency
in
these
program
management
functions.
The
revised
State
reporting
requirement
specified
by
the
LCRMR
should
also
make
it
easier
for
the
public
to
understand
how
levels
of
lead
at
the
tap,
for
systems
serving
more
than
3,300
people,
have
been
affected
by
the
LCR.

3
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
The
following
sections
verify
and
affirm
that
this
information
collection
satisfies
the
Office
of
Management
and
Budget's
(
OMB's)
collection
guidelines,
has
public
support,
and
does
not
duplicate
another
collection.
EPA
has
consulted
with
other
federal
agencies,
State
agencies,
industry
organizations,
water
systems,
and
tribal
organizations
to
ensure
non­
duplication
of
this
information
collection.

3(
a)
Non­
duplication
To
the
best
of
the
Agency's
knowledge,
data
required
by
the
LCR
and
the
LCRMR
are
not
available
from
any
other
source.
The
revisions
are
not
unnecessarily
duplicative
of
information
otherwise
reasonably
accessible
to
the
Agency.
Instead,
the
LCRMR
eliminate
some
reporting
requirements
which
the
Agency
has
found
to
be
redundant
or
no
longer
necessary.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
To
comply
with
the
1995
Amendments
to
the
Paperwork
Reduction
Act,
the
Agency
solicited
public
comment
on
the
draft
ICR4
during
a
60­
day
public
comment
period
coincident
with
the
comment
period
for
the
proposed
LCRMR.
The
Agency
published
notice
in
the
Federal
Register
(
60
FR
16348,
April
12,
1996)
that
requested
comment
on
the
respondent
burden
and
other
aspects
of
this
information
collection.
Comments
received
were
considered
by
the
Agency
and
used
to
adjust
the
burden
and
costs
estimates
presented
in
this
ICR.

3(
c)
Consultations5
The
regulatory
modifications
in
the
LCRMR
represent
the
product
of
numerous
work
group
discussions.
The
work
group
established
in
1993
was
comprised
of
Headquarters
and
Regional
EPA
staff,
and
State
drinking
water
officials.
In
addition,
prior
to
proposing
the
LCRMR,
EPA
distributed
a
draft
of
the
proposed
modifications
to
the
Association
of
State
Drinking
Water
Administrators
(
ASDWA)
and
June
1999
6
The
notices
refer
to
63
FR
20038,
April
22,
1998
and
63
FR
44214,
August
18,
1998.

7
major
water
utility
trade
associations.
These
groups,
in
turn,
circulated
the
draft
to
their
members
and
requested
written
comment.
Written
comments
were
received
from
numerous
Regional
offices
and
State
agencies.
PWS
input
was
gathered
through
State
comments,
as
well
as
comments
submitted
by
the
Association
of
Metropolitan
Water
Agencies
and
the
American
Water
Works
Association.
Further,
several
of
the
revisions
in
the
LCRMR,
which
include
the
elimination
of
some
of
the
system
reporting
requirements,
are
the
result
of
Stakeholders
meetings
that
the
Agency
held
relative
to
its
burden
reduction
efforts.

In
1997,
in
response
to
the
comments
received
on
the
April
1996
proposed
changes
to
State
reporting
requirements,
EPA
worked
with
States
through
the
OGWDW
'
s
Data
Sharing
Committee
to
substantially
revise
these
requirements.
Several
States
and
the
ASDWA
participated
actively
in
this
effort.
The
recommendations
developed
by
the
Data
Sharing
Committee
have
been
incorporated
into
the
LCRMR.

In
April
1998
and
August
1998,
prior
to
publishing
additional
Notices
for
comment,
EPA
provided
national,
local,
and
tribal
organizations
brief
articles
for
inclusion
in
their
newsletters
announcing
upcoming
plans
to
publish
the
Notices
and
encouraging
readers
to
provide
EPA
comment
on
the
additional
regulatory
options
described
in
those
notices.
6
In
addition,
EPA
coordinated
closely
with
several
national
organizations
and
the
States
to
provide
copies
of
the
August
18,
1998,
Notice
directly
to
those
water
systems
most
likely
to
be
affected
by
the
regulatory
option
discussed
in
that
Notice,
including
all
water
systems
serving
more
than
50,000
people
and
any
smaller­
size
water
system
that
is
likely
to
continue
to
exceed
an
action
level
after
the
installation
of
corrosion
control
treatment.
Many
of
the
suggestions
made
by
these
commenters
have
been
incorporated
into
the
final
rule.
Finally,
during
February
1999,
EPA
consulted
with
a
State
Unfunded
Mandates
Reform
Act
(
UMRA)
panel
regarding
the
Agency's
revised
ICR
burden
and
costs
estimates
for
the
LCR
and
LCRMR
and
assumptions
used
to
derive
these
estimates.
EPA
adjusted
the
burden
and
costs
estimated
presented
in
this
ICR
based
on
comments
from
the
UMRA
panel.
A
list
of
the
State
UMRA
panel
is
provided
below:

UMRA
Panel
Member
State
Represented
Phone
Number
Dennis
Alt
Iowa
(
515)
281­
8998
Alton
Boozer
South
Carolina
(
803)
898­
4300
James
Cleland
Michigan
(
515)
335­
9216
Dave
Leland
Oregon
(
503)
731­
4317
June
Swallow
Rhode
Island
(
401)
222­
6867
Steve
Walden
Texas
(
512)
239­
6096
June
1999
7
While
some
commenters
supported
a
reduced
reporting
frequency,
a
number
of
States
noted
that
as
long
as
they
could
continue
to
submit
their
data
to
EPA
quarterly,
less
frequent
reporting
would
not
be
problematic.
At
least
one
State
requested
that
the
current
requirements
be
retained.

8
3(
d)
Effects
Of
Less
Frequent
Collection
The
Agency
considered
numerous
alternatives
regarding
the
number
and
frequency
of
samples
to
be
collected.
It
has
selected
the
approach
that
minimizes
the
data
collection
burden
to
the
maximum
extent
possible
without
jeopardizing
public
health
protection
objectives.
The
Agency
is
concerned
that
further
reducing
monitoring
requirements
beyond
those
in
the
LCRMR,
would
fail
to
capture
the
variability
in
lead
and
copper
levels
within
systems
or
within
homes
and,
consequently,
would
increase
the
possibility
of
not
detecting
the
presence
of
high
lead
and
copper
concentrations.

The
LCRMR
contain
provisions
to
lessen
some
of
the
monitoring
requirements
of
the
1991
LCR.
These
provisions
allow
accelerated
reduced
lead
and
copper
tap
and
WQP
monitoring,
monitoring
waivers
for
some
small
systems,
entry
point
WQP
monitoring
at
representative
sites,
and
reduced
source
water
monitoring
for
systems
for
which
source
water
treatment
is
not
required.
The
Agency
has
determined
that
less
frequent
monitoring
is
warranted
for
these
systems
because
they
meet
stringent
criteria,
which
the
Agency
believes
are
protective
of
public
health.
As
mentioned
in
Section
5(
d),
the
Agency
also
has
added,
as
a
contingency,
a
provision
that
requires
systems
to
provide
timely
notification
to
States
when
systems
on
reduced
monitoring
change
treatment
or
add
a
source
of
water
so
that
the
State
can
detect
early
whether
these
changes
affect
water
quality
and
require
the
system
to
return
to
more
frequent
monitoring.

The
Agency
also
considered
reducing
the
frequency
with
which
States
are
required
to
report
90th
percentile
and
milestone
data
from
quarterly
to
once
or
twice
a
year
and
requested
comment
on
this
possible
revision
in
the
April
1996
Proposal.
EPA
received
mixed
comments
on
this
suggestion.
7
The
Agency
decided
to
retain
the
requirement
to
report
90th
percentile
and
milestone
data
quarterly.
In
the
Drinking
Water
Program,
EPA
reviews
violations
quarterly
to
ensure
that
timely
and
appropriate
follow­
up
action
is
occurring.
The
Agency
considers
a
water
system's
most
recently
reported
90th
percentile
lead
value
in
assessing
the
severity
of
many
LCR
violations.
Moreover,
the
Agency
needs
to
have
available
in
the
national
data
base
sufficient
up­
to­
date
information
to
provide
a
degree
of
oversight
and
to
answer
some
basic
questions.

3(
e)
General
Guidelines
The
LCR
and
LCRMR
comply
with
the
guidelines
published
under
the
Paperwork
Reduction
Act,
with
the
exception
that
records
are
required
to
be
retained
for
a
period
greater
than
three
years.
In
particular,
the
1991
LCR
requires
all
PWSs
to
retain
on
their
premises
original
records
of
all
sampling
data
and
analyses,
reports,
surveys,
letters,
evaluations,
schedules
and
any
other
information
required
by
the
State
for
no
fewer
than
12
years.
States
are
subject
to
the
same
record
retention
period,
except
that
States
are
required
to
retain
information
relating
to
the
decisions
in
§
142.14(
d)(
8)
until
a
new
decision,
determination,
or
designation
has
been
issued,
if
no
change
is
made
to
the
State
decision
during
the
12­
year
retention
period.
The
Agency
justified
these
record
retention
periods
and
received
approval
for
them
under
the
original
1991
ICR.
The
LCRMR
do
not
alter
the
system
or
State
record­
keeping
requirements.
June
1999
9
3(
f)
Confidentiality
This
ICR
does
not
raise
confidentiality
issues.

3(
g)
Sensitive
Questions
This
ICR
does
not
ask
sensitive
questions.

4
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
The
following
sections
contain
information
on
the
respondents
and
the
information
they
are
requested
to
provide.

4(
a)
Respondents/
SIC
Codes
Under
the
LCR,
respondents
include
owners
and
operators
of
PWSs
classified
as
community
water
systems
(
CWSs)
and
non­
transient
non­
community
water
systems
(
NTNCWSs).
The
Standard
Industrial
Classification
(
SIC)
code
for
investor­
owned
water
systems
is
4941.
The
SIC
code
for
both
publiclyowned
water
systems
and
State
agencies
is
9511.
Ancillary
systems
(
a
system
where
providing
water
is
ancillary
to
its
primary
business,
e.
g.,
a
mobile
home
park)
cannot
be
categorized
in
a
single
SIC
coded.
States
are
respondents
when
reporting
compliance
data
to
EPA
and
when
retaining
federally­
required
records.
The
LCRMR
affect
the
same
respondent
classes
as
the
LCR.

4(
b)
Information
Requested
The
following
sections
provide
detail
on
the
data
items
requested
and
associated
activities
respondents
must
undertake
in
providing
information
to
satisfy
the
LCRMR
requirements.
These
sections
include
a
brief
discussion
of
the
1991
requirements
of
the
rule
and
a
more
detailed
description
of
the
LCRMR
modifications.

4(
b)(
i)
Data
Items,
Including
Record
Keeping
and
Reporting
A
discussion
of
data
and
information
that
are
part
of
the
reporting
and
record
keeping
requirements
for
systems
is
found
below
in
Section
4(
b)(
i)(
a).
The
requirements
for
States
are
discussed
below
in
Section
4(
b)(
i)(
b).

4(
b)(
i)(
a)
Public
Water
System
Record
Keeping
And
Reporting
Under
the
1991
rule,
PWSs
have
to
maintain
and
report
to
the
State
the
following
information:


Monitoring
results
for
lead
and
copper
and
WQPs
within
10
days
following
the
end
of
the
monitoring
period;
June
1999
8
This
12­
year
retention
period
was
justified
and
approved
under
the
original
1991
ICR.

9
The
LCRMR
correct
an
oversight
in
the
1991
rule
by
requiring
(
b)(
3)
systems
to
continue
routine
monitoring
for
lead
and
copper
at
the
tap
at
least
once
every
three
calendar
years
(
triennially).

10

Identification
and
location
of
sampling
sites
and
the
rationale
for
choosing
the
sites;


Certification
regarding
appropriate
sample
collection;


State
determinations
(
e.
g.,
designation
of
optimal
corrosion
control
treatment);
and

Any
records,
reports,
or
information
the
Administrator
deems
necessary.

If
applicable,
the
1991
rule
also
requires
PWSs
that
exceed
the
lead
and/
or
copper
action
level
to
maintain
records
on
and
report
to
the
State
the
following
information:


Monitoring
results
for
lead
and
copper
in
source
water
within
10
days
following
the
end
of
the
monitoring
period;


Corrosion
control
and/
or
source
water
treatment
recommendation(
s)
and
certification(
s)
that
treatment(
s)
is(
are)
installed;


Progress
in
completing
a
public
education
program
(
report
due
at
the
end
of
the
calendar
year);
and

Identification
of
lead
service
lines
and
submission
of
an
annual
report
of
progress
in
their
replacement.

The
LCRMR
do
not
alter
the
record
keeping
retention
requirements
under
§
141.91
which
specifies
that
systems
must
retain
records
for
no
fewer
than
12
years.
8
However,
the
LCRMR
affect
the
number
of
records
to
be
maintained.
In
addition,
the
LCRMR
affect
the
systems'
reporting
requirements
to
the
State.
In
general,
systems
must
report
all
the
information
described
in
this
section
for
all
lead
and
copper
tap
samples
and
WQP
samples
within
the
first
10
days
following
the
end
of
each
applicable
monitoring
period.

In
some
instances,
systems
are
now
also
required
to
submit
and
maintain
records
of
documents
that
demonstrate
to
the
State
that
they
meet
the
criteria
of
a
provision
and
to
keep
records
of
the
State's
response
to
their
submissions.
In
addition,
the
LCRMR
require
some
systems
to
maintain
additional
records
as
follows:


Systems
deemed
to
have
optimized
corrosion
control
under
§
141.81(
b)(
3)
must
maintain
additional
lead
and
copper
monitoring
results;
9
June
1999
10
Under
the
1991
rule,
a
system
was
considered
to
be
a
(
b)(
3)
system
if
it
could
demonstrate
that
the
difference
between
the
90th
percentile
lead
level
as
measured
at
the
tap
and
the
highest
lead
level
measured
in
source
water
is
below
the
lead
Practical
Quantitation
Level
of
0.005
mg/
L
for
two
consecutive
six­
month
monitoring
periods.
Under
the
LCRMR,
effective
18
months
after
promulgation,
the
system
must
also
meet
the
copper
action
level
to
be
considered
a
(
b)(
3)
system.

11
Refers
to
small
systems
that
can
demonstrate
that
their
distribution
system,
service
lines,
and
drinking
water
supply
plumbing
are
free
of
sources
of
lead
and/
or
copper
contamination.
In
addition,
these
systems
must
demonstrate
that
their
90th
percentile
levels
for
any
and
all
rounds
of
monitoring
do
not
exceed
0.005
mg/
L
for
lead
or
0.65
mg/
L
for
copper.

12
Special­
case
CWSs
are
those
facilities,
such
as
a
prison
or
a
hospital,
whose
service
population
cannot
make
plumbing
improvements
install
point­
of­
use
treatment
devices,
which
provide
water
as
part
of
the
covered
services,
and
do
not
directly
bill
for
water
consumption.

13
Partial
lead
service
line
replacement
occurs
when
a
system
does
not
own
the
entire
lead
service
line
up
to
the
building
inlet
and
the
homeowner
does
not
elect
to
have
the
system
replace
its
private
portion.

11

Systems
no
longer
meeting
the
(
b)(
3)
criteria
must
maintain
records
of
additional
activities
required
by
the
State;
10

Systems
seeking
to
invalidate
samples
must
submit
documentation
to
the
State
which
demonstrates
that
the
samples
meet
one
of
the
criteria
outlined
in
the
new
§
141.86(
f)(
1)
along
with
reporting
the
results
of
all
such
samples
to
the
State;


Systems
serving
3,300
or
fewer
people
may
submit
documentation
that
demonstrates
they
are
eligible
for
a
lead
and/
or
copper
monitoring
waiver,
and
if
a
waiver
is
granted
must
resubmit
a
certification
every
nine
years;
11

Ground
water
systems
wishing
to
limit
entry
point
WQP
monitoring
to
those
entry
points
that
are
representative
of
water
quality
throughout
the
system,
must
provide
detailed
records
to
the
State
that
document
chemicals
used
in
treatment
and
that
demonstrate
that
those
sites
are
representative;


NTNCWSs
and
special­
case
CWSs12
that
cannot
provide
enough
first­
draw
samples
can
request
State
approval
to
monitor
at
locations
where
the
water
has
not
stood
motionless
for
at
least
six
hours
by
submitting
a
sampling
plan
that
identifies
where
and
when
these
"
nonfirst
draw"
samples
will
be
collected;
or,
if
the
State
does
not
require
prior
State
approval,
such
systems
can
send
to
the
State,
with
their
tap
results,
an
identification
in
writing
of
each
"
non­
first­
draw"
sample
and
the
length
of
standing
time
for
that
particular
sample;


Systems
collecting
lead
service
line
samples
following
partial
lead
service
line
replacement
must
report
the
results
to
the
State
within
the
first
10
days
of
the
month
following
the
month
in
which
the
system
receives
the
results,
or
as
specified
by
the
State.
13
(
However,
a
State
can
eliminate
this
reporting
requirement
at
its
discretion.)
Systems
must
also
report
June
1999
14
This
includes
the
same
subset
of
CWSs
as
those
that
can
collect
non­
first
draw
samples
with
State
approval.
Refer
to
footnote
12
for
the
definition
of
these
CWSs.
Eligible
CWSs
may
be
required
to
obtain
prior
State
approval
before
using
the
alternative
language.

15
States
may
require
that
these
systems
conduct
more
frequent
lead
and
copper
tap
monitoring.

16
This
modification
affects
CWSs
serving
3,300
or
more
persons
that
remain
above
the
lead
action
level
for
more
than
one
monitoring
period
because
these
systems
must
perform
some
public
education
tasks
on
a
semi­
annual
basis
for
as
long
they
exceed
the
lead
action
level.

12
additional
information
as
specified
by
the
State
to
verify
that
they
have
completed
all
partial
lead
service
line
replacement
requirements;


Systems
required
to
deliver
public
education
may
be
required
to
receive
prior
State
approval
before
implementing
the
following
revisions:
CWSs
serving
501
to
3,300
to
omit
providing
notices
to
the
local
newspapers
and/
or
limit
the
distribution
of
educational
materials,
special­
case
CWSs14
to
use
NTNCWSs
alternative
language
and
to
be
subject
to
NTNCWSs
delivery
requirements,
NTNCWSs
to
deliver
public
education
information
electronically,
and
systems
to
omit
reference
to
lead
service
lines
and/
or
building
permit
record
availability;


Some
systems
will
be
required
to
maintain
records
of
which
sampling
sites
a
system
should
include
in
its
reduced
lead
and
copper
tap
sampling
pool;
and

Systems
which
are
required
to
replace
lead
service
lines
must
document,
in
system
files,
the
portion(
s)
of
the
lead
service
line(
s)
they
own.

Some
of
the
modifications
alter
the
reporting
requirements
to
provide
more
timely
information:


Systems
on
a
reduced
monitoring
schedule
that
add
a
source
or
change
their
treatment
must
report
such
changes
and
any
appropriate
monitoring
results
to
the
State
no
later
than
60
days
of
the
change
(
unless
the
State
requires
earlier
notification)
15;
and

Systems
that
are
required
to
deliver
public
education
must
report
requirements
for
compliance
with
public
education
to
the
State
within
10
days
after
the
end
of
the
period
in
which
public
education
was
required
to
be
performed;
as
opposed
to
reporting
this
information
at
the
end
of
the
calendar
year.
16
Other
revisions
eliminate
some
of
the
data
to
be
submitted
by
a
system
to
the
State:


Systems
no
longer
need
to
provide
that
State
with
a
list
of
the
newspapers,
radio
stations,
television
stations,
and
facilities/
organizations
to
which
delivered
public
education
materials
unless
there
is
a
change
in
the
information
or
the
State
requires
that
the
documentation
be
included
with
each
submission;
June
1999
13

Systems
are
no
longer
required
to
submit
certifications
that
samples
meet
the
first­
draw
criteria
contained
in
§
141.86(
b)(
2)
and
if
samples
were
collected
by
the
customers,
that
they
were
done
so
only
after
being
instructed
by
the
system
about
proper
collection
methods;


Systems
are
no
longer
required
to
submit
information
justifying
the
use
of
non­
Tier
1
sites
or
to
demonstrate
why
the
sampling
pool
was
comprised
of
fewer
than
50
percent
of
samples
collected
from
lead
service
lines;


Systems
which
qualify
for
monitoring
waivers,
for
accelerated
reduced
monitoring,
or
for
limited
entry
point
WQP
monitoring
will
submit
fewer
monitoring
results
to
the
State
and
maintain
fewer
associated
records;


Systems
meeting
their
State­
designated
WQP
ranges
no
longer
need
to
explicitly
request
State
approval
to
reduce
the
number
of
lead
and
copper
samples
and
the
frequency
of
this
monitoring,
however,
they
continue
to
require
written
State
approval
for
these
reductions;
and

Systems
no
longer
need
to
report
the
lead
and
copper
90th
percentile
calculations
in
cases
where
the
State
has
notified
the
system
that
it
will
perform
the
calculations
and
provide
the
results
of
these
calculations
to
the
system
in
writing
before
the
end
of
the
monitoring
period.

4(
b)(
i)(
b)
State
Record
Keeping
And
Reporting
State
Record
Keeping
The
1991
LCR
requires
States
to
retain
records
regarding
the
currently
applicable
or
most
recent
determinations
for
no
fewer
than
12
years.
States
are
required
to
retain
information
relating
to
the
decisions
until
a
new
decision,
determination,
or
designation
has
been
issued
if
no
change
is
made
to
the
State
decision
during
the
12­
year
retention
period.
States
must
maintain
the
following
system­
level
records
of
currently
applicable
or
most
recent
State
determinations
pertaining
to
the
control
of
lead
and
copper,
including
all
supporting
information
and
an
explanation
of
the
technical
basis
for
each
decision:


Current
monitoring
requirements
for
each
PWS;


Decisions
to
require
conduct
of
corrosion
control
treatment
studies;


Determinations
of
optimal
corrosion
control
and
source
water
treatment;


Determinations
of
maximum
permissible
lead
and
copper
concentrations
in
source
water
and
of
WQPs
that
demonstrate
that
corrosion
control
treatment
has
been
optimized
(
i.
e.,
optimal
water
quality
parameters
or
OWQPs);
June
1999
17
The
revisions
add
language
that
requires
systems
to
also
meet
the
copper
action
level
for
two
consecutive
six­
month
monitoring
periods.

18
The
1991
LCR
required
systems
to
conduct
reduced
monitoring
during
June
through
September.
This
created
unintentional
problems
for
systems
that
are
not
open
during
the
summer
months.
The
LCRMR
allow
States
to
designate
an
alternative
monitoring
period
when
lead
levels
are
likely
to
be
their
highest.

14

Results
of
State
activities
designed
to
verify
compliance
with
State
determinations;
and

Reports
and
any
other
information
submitted
by
PWSs.

The
LCRMR
do
not
alter
the
length
of
time
that
records
must
be
retained.
Instead,
they
may
require
the
State
to
maintain
additional
records
for
some
systems
and
fewer
records
for
others.
The
revisions
require
the
State
to
retain
records
related
to
new
decisions
regarding
monitoring
requirements
for
systems
in
several
areas.
States
are
required
to:


Maintain
additional
lead
and
copper
tap
monitoring
results
for
(
b)(
3)
systems
and
additional
records
for
those
systems
no
longer
meeting
the
(
b)(
3)
criteria,
that
may
be
required
to
conduct
a
study,
install
treatment,
and/
or
monitor
for
WQPs.
17

Retain
correspondence
relating
to
sample
site
selection
for
those
systems
where
the
State
designated
reduced
sampling
locations;


Review
and
maintain
sampling
plans
for
systems
requesting
approval
to
collect
"
non­
firstdraw
samples;


Maintain
determinations
regarding
whether
small
systems
requesting
a
monitoring
waiver
for
lead
and/
or
copper
meet
the
requirements
and
the
continued
eligibility
of
these
systems;


Maintain
decisions
on
which
systems
exceeding
the
action
level
and
are
not
required
to
install
source
water
treatment
can
be
placed
on
reduced
source
water
monitoring;


Document
decisions
related
to
sample
invalidation
and
maintain
data
submitted
by
systems
demonstrating
the
need
for
sample
invalidation;


Maintain
records
on
decisions
regarding
which
systems
should
be
placed
on
an
alternative
reduced
monitoring
schedule
for
the
collection
of
lead
and
copper
tap
samples;
18

Determine
eligibility
and
maintain
records
related
to
the
need
for
systems
on
reduced
monitoring
that
change
their
source
or
add
a
treatment
to
return
to
standard
monitoring
or
take
other
action;
and

Review
and
maintain
documentation
from
ground
water
systems
wishing
to
restrict
entry
point
WQP
monitoring
to
representative
locations.
June
1999
15
Other
modifications
increase
the
State's
record
keeping
requirements:


States
are
required
to
document
several
public
education
decisions
regarding
whether:
1)
CWSs
qualify
to
use
the
alternative
public
education
language
and
delivery
requirements
specified
for
NTNCWSs,
2)
systems
can
delete
reference
to
lead
service
lines
and/
or
building
permit
record
availability,
3)
CWSs
serving
501
to
3,300
people
can
discontinue
publishing
notices
in
local
papers
and/
or
may
limit
the
distribution
of
public
education
materials,
and
4)
NTNCWSs
can
deliver
public
education
information
electronically;


States
must
maintain
additional
records
for
CWSs
serving
more
than
3,300
people
due
to
more
frequent
reporting
of
compliance
with
public
education
requirements;
and

States
must
maintain
records
that
document
a
system's
compliance
with
partial
lead
service
line
replacement
notification
and
monitoring
activities.

Other
revisions
related
to
accelerated
reduced
monitoring,
monitoring
waivers,
and
entry
point
WQP
monitoring
decrease
State
record
keeping
requirements
because
the
States
will
review
and
maintain
fewer
monitoring
results.
In
addition,
the
LCRMR
eliminate
some
of
the
records
that
would
have
been
retained
by
the
State.
More
specifically,
States
no
longer
have
to
retain
records
related
to
a
system's
certification
of
first­
draw
or
customer­
collected
samples
or
a
systems
justification
explaining
why
samples
were
collected
from
non­
Tier
1
sites
or
an
insufficient
number
of
samples
were
collected
from
residences
served
by
lead
service
lines.

State
Reporting
Under
the
1991
LCR,
States
were
required
to
report
quarterly
to
the
Agency
information
on
each
system's
compliance
with
monitoring
and
reporting,
and
treatment
technique
requirements.
In
addition,
the
State
had
to
report
certain
milestone
events
as
required
under
§
142.15.
In
particular,
States
had
to
report
the
name
and
identification
number
of
each
PWS
that:


Exceeded
the
lead
or
copper
action
levels
and
the
date
the
exceedance
occurred;


Was
required
to
complete
a
corrosion
control
study;


Received
a
State
determination
regarding
optimal
corrosion
control
treatment,
OWQPs,
source
water
treatment
requirement,
or
maximum
permissible
source
water
levels;


Completed
installation
of
corrosion
control
or
source
water
treatment;
and

Was
required
to
replace
lead
service
lines,
had
a
State­
designated
accelerated
replacement
schedule,
or
reported
compliance
with
its
schedule.
June
1999
16
Overall,
the
LCRMR
reduce
the
number
of
milestones
that
States
are
required
to
report
to
the
Agency,
but
do
not
impact
the
reporting
requirements
for
violations
or
enforcement
actions.
Further,
the
LCRMR
do
not
alter
the
reporting
frequency
or
change
the
information
the
States
are
required
to
keep
in
State
files
or
data
systems,
only
the
information
which
they
must
report
on
a
regular
basis
to
EPA.
The
Agency
believes
that
the
reporting
revisions
will
provide
better
information
than
the
previous
reporting
requirements.
In
addition,
the
modifications
also
clarify
that
States
must
report
the
information
to
EPA
in
a
format
prescribed
by
the
EPA
Administrator.
The
specific
reporting
changes
are
explained
in
more
detail
below:

90th
Percentile
Levels
The
1991
LCR
required
States
to
report
each
system
that
exceeded
the
lead
and
copper
action
level.
The
LCRMR
replace
the
requirement
to
report
lead
and
copper
action
level
exceedances.
Under
the
LCRMR,
the
Agency
requires
States
to
report
all
90th
percentile
lead
levels
for
all
large
and
medium
water
systems
and
those
lead
levels
in
excess
of
the
action
level
for
small
systems.
EPA
believes
requiring
the
reporting
of
additional
90th
percentile
lead
levels
for
large
and
medium
systems
is
essential
because
such
data
will
support
analysis
of
corrosion
control
and
source
water
treatment
effectiveness.
Further,
the
LCRMR
explicitly
require
the
States
to
report
those
90th
percentile
copper
levels
in
excess
of
the
action
level
for
all
systems
sizes.

Corrosion
Control
Study
Required
and
Completed
Milestones
States
were
required
under
the
1991
rule
to
submit
the
name
and
identification
number
of
each
system
required
to
conduct
a
corrosion
control
study
and
the
date
the
study
was
completed.
EPA
has
eliminated
these
requirements
because
failure
to
conduct
a
corrosion
control
treatment
study
is
a
violation
of
the
LCR
that
must
be
reported
to
SDWIS.

"
Deemed"
Milestone
EPA
has
added
a
"
Deemed"
milestone
to
indicate
when
a
system
has
optimized
corrosion
control.
This
"
Deemed"
milestone
must
be
reported
for
every
water
system.
Under
this
milestone,
the
State
must
report
every
system
for
which
the
State
has
designated
OWQPs,
or
which
the
State
has
deemed
to
have
optimized
corrosion
control
under
§
141.81(
b)(
1)
or
§
141.81(
b)(
3).
The
State
must
also
report
for
these
systems,
the
date
and
basis
of
such
a
determination.

"
Done"
Milestone
EPA
has
created
a
new
milestone
to
indicate
when
a
system
has
completed
all
applicable
corrosion
control,
source
water
treatment,
and
lead
service
line
replacement
requirements.
The
State
must
report
this
"
Done"
milestone
for
all
water
systems.
For
this
milestone,
the
State
must
report
the
latest
event
from
among
all
the
following
events:


The
date
the
State
designates
OWQPs
under
§
141.82(
f)
or
deems
the
system
to
have
optimized
corrosion
control
under
§
141.81(
b)(
1)
or
§
141.81(
b)(
3);
June
1999
17

For
systems
triggered
into
source
water
treatment,
the
date
the
State
designates
maximum
permissible
source
water
levels
or
that
source
water
treatment
is
not
required;
OR

For
systems
triggered
into
lead
service
line
replacement,
the
date
the
system
completes
lead
service
line
replacement
or
becomes
eligible
to
cease
lead
service
line
replacement.

The
"
Done"
milestone
replaces
the
requirement
to
report
separate
milestones
for
each
system:
that
is
required
to
install
source
water
treatment,
that
has
installed
the
State­
designated
source
water
treatment,
that
is
required
to
install
corrosion
control
treatment,
that
has
installed
State­
designated
corrosion
control
treatment,
and
for
which
the
State
has
specified
maximum
permissible
source
water
levels,
and/
or
OWQPs.

Lead
Service
Line
Replacement
States
were
required
under
the
1991
rule
to
submit
the
name
and
identification
number
of
each
system:
(
1)
that
must
replace
lead
service
lines;
(
2)
for
which
the
State
has
established
an
accelerated
replacement
schedule;
and
(
3)
reporting
compliance
with
its
replacement
schedule.
EPA
has
revised
this
lead
service
line
reporting
milestone
to
require
States
to
report
only
the
name
and
identification
number
of
each
water
system
that
must
replace
lead
service
lines
and
the
date
replacement
must
begin.

EPA
has
determined
that
it
is
not
necessary
to
collect
information
about
accelerated
lead
service
line
replacement
schedules
because
EPA
can
request
this
information
from
States,
if
needed.
EPA
has
eliminated
the
portion
of
this
milestone
associated
with
reporting
a
system's
compliance
with
its
lead
service
line
replacement
schedule
because
EPA
will
be
able
to
determine
system
compliance
using
information
already
reported
to
the
SDWIS.
In
particular,
because
failure
to
comply
with
an
accelerated
or
other
replacement
schedule
constitutes
a
LCR
violation,
it
must
be
reported
to
SDWIS.

4(
b)(
ii)
Respondent
Activities
Respondents
include
both
PWSs
and
State
primacy
agencies.
CWS
and
NTNCWS
owners
and
operators
are
required
to
comply
with
the
LCR.
In
general,
the
LCR
requires
each
of
these
water
systems
to
undertake
the
following
activities:


Read
the
regulations;


Plan
monitoring
and
other
activities;


Provide
training
to
appropriate
staff
and
to
residents
collecting
samples;


Identify
appropriate
sampling
sites
and
collect
samples;


Review
sample
data,
including
the
calculation
of
lead
and
copper
90th
percentile
levels;


Submit
to
the
State,
monitoring
data
or
any
other
documents/
reports;
and
June
1999
18

Record
and
maintain
information.

In
addition,
some
systems
must
submit
corrosion
control
studies,
recommend
and
submit
information
regarding
the
completion
of
corrosion
control
treatment
and/
or
source
water
treatment
installation,
conduct
public
education,
and/
or
conduct
lead
service
lines
monitoring
and
notification.

The
rule
revisions
are
consistent
and
compatible
with
the
existing
reporting
and
record
keeping
practices
of
these
respondents.
They
do
not
alter
the
retention
periods
for
maintaining
records.
The
revisions
result
in
less
frequent
reporting
and
fewer
records
to
be
maintained
for
some
systems
and
a
corresponding
decrease
in
the
number
of
records
to
be
reviewed
or
retained
by
the
State.
The
expected
impact
that
each
revision
has
on
respondent
activity
is
described
below.
The
record
keeping
and
reporting
impacts
were
discussed
in
more
detail
in
Section
3(
b)(
i)
of
this
document.

4(
b)(
ii)(
a)
Systems
Deemed
to
Have
Optimized
Corrosion
Control
under
§
141.81(
b)(
3)

Several
of
the
provisions
in
§
141.81(
b)(
3)
have
been
revised
under
the
LCRMR
as
follows:


Systems
with
source
water
levels
below
the
Method
Detection
Limit
may
be
deemed
to
have
optimized
corrosion
control.
With
this
revision,
more
systems
can
potentially
qualify
as
(
b)(
3)
systems.


The
LCRMR
correct
an
oversight
and
explicitly
require
(
b)(
3)
systems
to
continue
lead
and
copper
tap
water
monitoring
on
a
triennial
basis.


The
LCRMR
clarify
EPA's
intention
that
(
b)(
3)
systems
also
meet
the
copper
action
level).
A
(
b)(
3)
system
that
exceeds
the
copper
action
level
no
longer
qualifies
for
this
designation,
and
may
be
required
to
provide
the
State
with
a
treatment
recommendation,
conduct
a
corrosion
control
study,
and
install
corrosion
control
treatment.


A
(
b)(
3)
system
must
report
a
change
in
treatment
or
addition
of
a
source
to
the
State
within
60
days
of
the
change/
treatment.
The
State
can
require
the
system
to
conduct
additional
monitoring
or
take
other
appropriate
action
to
ensure
the
system
is
maintaining
minimal
levels
of
corrosion
in
the
distribution
system.

4(
b)(
ii)(
b)
Compliance
with
Optimal
Water
Quality
Parameters
The
LCRMR
change
the
requirements
for
compliance
determination
regarding
optimal
corrosion
control
and
WQPs.
Under
the
LCR,
a
single
sample
outside
the
OWQP
range
could
result
in
a
violation.
Under
the
LCRMR,
a
water
system
is
in
violation
when
a
sample
fails
to
meet
the
State­
designated
OWQP
ranges
or
values
for
more
than
nine
days
during
a
six­
month
period.
The
change
in
compliance
criteria
June
1999
19
Systems
meeting
OWQPs
can
qualify
for
reduced
lead
and
copper
tap
monitoring
and
WQP
tap
monitoring.
Systems
no
longer
meeting
OWQPs
are
in
violation
and
no
longer
qualify
for
reduced
monitoring
until
they
can
again
meet
OWQPs
for
two
consecutive
6­
month
monitoring
periods.

20
This
provision
does
not
impact
the
frequency
of
WQP
monitoring
at
entry
points.
This
monitoring
remains
at
a
frequency
of
at
least
once
every
two
weeks
(
biweekly).

19
should
result
in
fewer
systems
incurring
violations,
and
allow
more
systems
to
remain
on
reduced
monitoring.
19
4(
b)(
ii)(
c)
Accelerated
Reduced
Monitoring
The
LCRMR
allow
systems
with
very
low
lead
and
copper
levels
for
two
consecutive
six­
month
monitoring
periods
to
monitor
triennially
without
first
monitoring
on
an
annual
schedule
(
as
required
under
the
1991
rule).
Systems
that
qualify
for
accelerated
reduced
lead
and
copper
tap
monitoring
and
meet
their
OWQPs
also
qualify
for
accelerated
reduced
WQP
tap
monitoring.
20
This
allows
systems
to
also
collect
WQPs
at
reduced
number
of
taps
every
three
years,
instead
of
first
monitoring
at
a
reduced
number
of
sites
semi­
annually
and
then
annually.

4(
b)(
ii)(
d)
Sample
Invalidation
Systems
wishing
to
have
a
sample
invalidated
must
demonstrate
to
the
State
that
they
meet
at
least
one
of
the
criteria
listed
in
§
141.86(
f)(
1).
The
system
must
submit
the
results
of
all
samples
to
the
State
and
all
supporting
documentation
for
samples
they
believe
should
be
invalidated.
The
State
must
document
its
decision
in
writing.

4(
b)(
ii)(
e)
Monitoring
Waivers
for
Small
Systems
Small
systems
serving
3,300
or
fewer
people
with
low
levels
of
lead
and/
or
copper
at
the
tap
and
that
can
demonstrate
that
their
water
system
is
free
of
lead­
and/
or
copper­
containing
materials
can
qualify
for
a
monitoring
waiver
for
lead
and/
or
copper.
Systems
qualifying
for
a
monitoring
waiver
would
be
required
to
monitor
at
a
frequency
of
once
every
nine
years
for
the
contaminant(
s)
for
which
they
received
a
monitoring
waiver.
They
must
also
continue
to
certify
once
every
nine
years
that
they
still
qualify
for
a
monitoring
waiver.
Also,
as
a
condition
of
the
waiver,
the
State
may
require
a
system
to
perform
certain
activities,
such
as
outreach
to
remind
people
to
only
use
"
lead­
free"
faucets.
If
a
system
continues
to
satisfy
the
requirements
of
the
monitoring
waiver,
the
waiver
will
be
automatically
renewed
unless
the
State
notifies
the
system
otherwise.
Systems
are
also
required
to
notify
the
State
when
they
change
treatment
or
add
a
new
source
or
become
aware
that
they
no
longer
met
the
criteria
for
a
monitoring
waiver.

4(
b)(
ii)(
f)
Sample
Site
Location
Systems
with
Insufficient
Tiered
Sites
June
1999
21
Refer
to
footnote
12
for
a
definition
of
special­
case
CWSs.

20
The
LCRMR
clarify
that
systems
without
sufficient
Tier
1,
2,
or
3
sites
must
sample
from
nontiered
sites
that
are
representative
of
sites
throughout
the
distribution
system.
The
system
is
not
required
to
request
or
receive
approval
from
the
State
to
sample
from
non­
tiered
sites.

NTNCWSs
and
Special­
Case
CWSs
with
Insufficient
Number
of
First­
Draw
Samples
NTNCWSs
and
special­
case
CWSs
without
a
sufficient
number
of
sampling
sites
that
can
provide
first­
draw
samples
can
request
written
approval
from
the
State
to
collect
non­
first­
draw
samples.
21
States
can
waive
the
requirement
that
prior
State
approval
be
granted
before
the
system
is
allowed
to
conduct
such
sampling.

Sample
Site
Justifications
The
LCRMR
eliminate
the
requirement
for
systems
to
notify
the
State
if
they
were
unable
to
complete
their
sampling
pool
with
Tier
1
sites
or
to
collect
50
percent
of
the
samples
from
sites
served
by
lead
service
lines.
EPA
has
eliminated
these
reporting
requirements
because
States
can
use
other
mechanisms
such
as
on­
site
inspections
or
file
reviews
to
determine
if
systems
are
sampling
at
appropriate
locations.

4(
b)(
ii)(
g)
Systems
that
Change
Treatment
or
Add
a
New
Source
Water
Systems
monitoring
less
frequently
than
every
six
months
that
change
their
treatment
or
add
a
new
source
must
report
the
change
to
the
State,
no
later
than
60
days
of
the
change,
unless
a
shorter
notification
period
is
required
by
the
State.
Because
these
systems
would
be
monitoring
at
a
reduced
frequency,
any
increase
in
lead
or
copper
levels
may
occur
within
a
relatively
short
period
of
time
and
may
go
undetected
for
up
to
nine
years
by
some
systems.

4(
b)(
ii)(
h)
Entry
Point
Monitoring
for
Water
Quality
Parameters
at
Ground
Water
Systems
The
Agency
is
allowing
ground
water
systems
required
to
monitor
for
WQPs
to
limit
entry
point
monitoring
to
those
locations
that
are
representative
of
water
quality
and
corrosion
control
treatment
conditions
throughout
the
distribution
system.
To
take
advantage
of
this
provision,
systems
must
provide
to
the
State
identification
of
the
selected
entry
points
and
documentation
showing
that
these
locations
are
representative
of
water
quality
and
treatment
conditions
throughout
the
distribution
system.

4(
b)(
ii)(
i)
Other
Changes
Pertaining
to
Lead
and
Copper
Tap
Water
Monitoring
Sample
Certification
Under
the
1991
regulations,
systems
were
required
to
submit
a
certification
with
their
lead
and
copper
monitoring
results
that
each
sample
met
the
first
draw
specifications
outlined
in
§
141.86(
b)
and
that
June
1999
22
NTNCWSs
are
required
to
post
informational
materials
and
to
distribute
public
education
materials
to
each
person
served
by
the
system.

21
any
sample
collected
by
residents
was
taken
only
after
they
received
proper
instructions
from
the
water
system.
EPA
has
eliminated
these
reporting
requirements,
but
systems
must
still
maintain
these
records.

State
Approval
for
Reduced
Monitoring
Under
the
1991
regulations,
systems
meeting
their
OWQP
ranges
must
first
request
approval
from
the
State
before
assuming
a
reduced
lead
and
copper
tap
monitoring
schedule.
The
Agency
has
eliminated
this
requirement
because
States
routinely
review
system
eligibility
for
reduced
monitoring
and
notify
systems
in
writing
of
changes
in
their
monitoring
requirements
as
part
of
their
compliance
oversight
function.
Systems
must
still
receive
written
State
approval
before
collecting
lead
and
copper
samples
at
a
reduced
number
and
frequency,
and
must
also
maintain
the
State
decisions
in
their
records.

Timing
of
Reduced
Monitoring
The
State
may
approve
a
different
period
of
monitoring
than
June
through
September
for
systems
on
annual
or
less
frequent
(
reduced)
monitoring.
For
a
seasonal
system,
this
revision
may
eliminate
the
unintended
burden
for
a
system
to
sample
during
periods
that
are
not
representative
of
normal
operations
and
allow
States
to
make
treatment
decisions
based
on
more
relevant
information.

4(
b)(
ii)(
j)
Public
Education
Content
of
Public
Education
Language
Under
the
1991
regulations,
the
mandatory
public
education
language
was
the
same
for
CWSs
and
NTNCWSs.
The
LCRMR
provide
alternative
public
education
language
that
can
be
used
by
NTNCWSs
and
certain
CWSs.
CWSs
must
apply
to
the
State,
in
writing,
to
use
this
alternative
language,
unless
the
State
has
waived
the
requirement
for
prior
approval.
Further,
both
CWSs
and
NTNCWSs
can
delete
information
pertaining
to
lead
service
lines,
if
approved
by
the
State
and
if
no
lead
service
lines
exist
in
a
system's
service
area.
In
addition,
CWSs
may
modify
public
education
language
pertaining
to
permit
record
availability
and
accessibility,
if
approved
by
the
State.
The
revisions
to
the
public
education
mandatory
language
are
intended
to
provide
more
pertinent
information
and
to
minimize
confusion
by
the
individuals
receiving
the
public
education
materials.

Distribution
of
Materials
The
LCRMR
permit
systems
using
billing
formats
that
do
not
allow
for
enclosures
of
additional
materials
to
mail
public
education
materials
separately
from
water
bills,
so
long
as
the
mailing
is
completed
within
the
required
time
frame
and
achieves
equal
coverage.
In
addition,
with
State
permission,
NTNCWSs
can
distribute
public
education
materials
electronically.
Further,
CWSs
using
the
NTNCWS
alternative
language,
may
also
follow
the
NTNCWS
requirements
for
public
education
delivery.
22
June
1999
23
The
1991
rule
required
all
CWSs
to
deliver
public
service
announcements
semiannually
for
as
long
as
these
systems
exceed
the
lead
action
level.
As
mentioned
above,
the
revisions
allow
CWSs
serving
3,300
or
fewer
persons
to
forego
delivering
public
service
announcements
and
to
deliver
public
education
on
an
annual
basis.
NTNCWSs
under
the
LCR
and
LCRMR
are
required
to
conduct
public
education
annually.

24
Systems
exceeding
the
lead
action
level
after
installing
optimal
corrosion
control
treatment
and/
or
source
water
must
begin
lead
service
line
replacement.
A
system
may
avoid
replacing
a
lead
service
line
by
demonstrating
that
the
lead
concentration
in
any
sample
collected
from
that
line
is
0.015
mg/
L
or
less.
The
system
may
count
lines
with
such
levels
toward
the
annual
seven
percent
replacement
requirements.
The
LCRMR
do
not
alter
these
lead
service
line
monitoring
provisions.

25
AWWA
v.
EPA,
40
F.
3d
1266
(
D.
C.
Cir.
1994)

22
Community
Water
Systems
Serving
3,300
or
Fewer
People
The
LCRMR
limit
or
omit
some
of
the
required
public
education
tasks
for
CWSs
serving
3,300
or
fewer
people.
In
particular,
these
systems
are
no
longer
required
to
deliver
public
service
announcements,
which
had
to
be
performed
semi­
annually.
Systems
serving
500
or
fewer
people
may
omit
submitting
information
to
newspapers
and
limit
the
distribution
of
informational
pamphlets
to
appropriate
facilities
and
organizations
served
by
the
water
system.
In
addition
to
mailing
lead
public
education
materials
to
billing
units,
systems
electing
to
limit/
omit
these
activities
must
also
mail
or
hand
deliver
the
required
public
education
materials
to
all
other
regular
customers
of
the
system.
Systems
serving
501
to
3,300
may
do
so
with
State
permission.

Reporting
Completion
of
Public
Education
Tasks
The
LCRMR
change
the
deadline
for
reporting
compliance
with
public
education
tasks
from
the
end
of
the
calendar
year
to
within
10
days
after
the
end
of
the
period
in
which
the
system
is
required
to
perform
public
education.
EPA
changed
this
requirement
to
provide
the
Agency
and
States
with
more
timely
information
on
which
to
assess
compliance.
CWSs
serving
more
than
3,300
persons
will
now
be
required
to
submit
two
public
education
compliance
letters
per
year
instead
of
one.
23
The
LCRMR
eliminate
the
need
for
systems
to
submit
supporting
documentation
that
has
been
submitted
previously
unless
there
is
a
change
in
the
information
or
the
State
requires
that
the
documentation
be
included
with
each
submission.

4(
b)(
ii)(
k)
Lead
Service
Line
Replacement
The
1991
LCR
required
a
water
system
to
replace
the
entire
lead
service
line,
up
to
the
building
inlet,
unless
the
system
demonstrated
to
the
satisfaction
of
the
State
that
it
controlled
less
than
the
entire
service
line.
24
This
broad
definition
of
"
control"
was
subsequently
remanded
and
vacated
by
the
Court
as
it
applies
to
portions
of
the
line
beyond
a
water
system's
ownership.
25
Because
lead
service
lines
are
not
required
to
be
replaced
until
treatment
has
been
installed
and
is
unsuccessful
at
bringing
the
lead
90th
percentile
level
below
the
action
level,
few
if
any
systems
would
have
replaced
lead
service
lines
under
the
broader
definition.
June
1999
23
The
LCRMR
eliminate
the
"
control"
terminology
and
require
the
water
system
to
replace
only
the
portion
of
the
lead
service
line
that
it
owns.
Because
the
proposed
revised
definition
of
"
control"
is
much
narrower
than
the
original
definition,
the
LCRMR
also
remove
the
rebuttable
presumption
that
the
water
system
controls
the
entire
length
of
the
lead
service
line.
The
LCRMR
also
revise
the
requirements
a
water
system
must
satisfy
when
replacing
only
a
portion
of
the
lead
service
line
(
i.
e.,
partial
lead
service
line
replacement).
Under
the
LCR,
systems
were
required
to
offer
to
collect
a
post­
replacement
sample
within
14
days
of
the
partial
replacement.
The
LCRMR
require
systems
to:
1)
notify
resident(
s)
served
by
the
line
of
the
potential
of
a
temporary
increase
in
lead
levels
in
their
drinking
water
and
to
provide
the
resident(
s)
guidance
on
minimizing
exposure
to
lead;
2)
inform
the
resident(
s)
that
it
will,
at
its
expense,
collect
a
tap
sample
representative
of
the
water
in
the
service
line
for
lead
analysis
within
three
days
following
the
replacement,
and
report
the
results
to
the
owner
and
the
resident(
s)
within
three
business
days
of
receiving
the
results;
and
3)
report
the
results
of
the
post­
partial
replacement
sampling
to
the
State
within
the
first
ten
days
of
the
month
following
the
month
in
which
the
system
receives
the
laboratory
results,
unless
the
State
has
eliminated
this
reporting
requirement.

4(
b)(
ii)(
l)
Source
Water
Monitoring
Composite
Samples
The
LCRMR
increase
the
copper
resampling
trigger
for
compositing
source
water
samples.
Therefore,
some
systems
may
avoid
additional
costs
associated
with
resampling
and
analyzing
each
site
comprising
the
composite
sample.

Reduced
Source
Water
Monitoring
Under
the
LCRMR,
systems
exceeding
the
action
level
for
which
the
State
has
determined
source
water
treatment
is
not
needed
are
allowed
to
sample
source
water
once
every
nine
years,
if
they
maintain
very
low
source
water
lead
and
copper
levels
for
three
consecutive
monitoring
periods.
Under
the
1991
rule
these
systems
were
required
to
monitor
annually
or
triennially.

5
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
following
sections
describe
the
Agency
activities
related
to
analyzing,
maintaining,
and
distributing
the
information
collected.

5(
a)
Agency
Activities
The
Agency
is
responsible
for
promulgating
and
overseeing
the
implementation
of
the
minor
revisions
to
the
LCR.
The
Agency
is
involved
in
the
following
activities
that
assist
States
in
implementing
the
modifications:
June
1999
26
SBREFA
impacts
were
not
estimated
for
the
LCR
because
SBREFA
became
effective
after
the
original
LCR
provisions
became
effective.

24

Develop
the
regulations
and
necessary
guidance
materials;


Respond
to
questions
on
the
regulations
or
guidance
materials;


Review
and
analyze
data
submissions
from
States
to
ensure
consistent
and
appropriate
implementation
of
the
requirements;
and

Process
and
maintain
the
SDWIS
data
associated
with
State
submissions.

5(
b)
Collection
Methodology
And
Management
The
LCRMR
provide
EPA
with
the
authority
to
specify
the
format
in
which
the
States
must
report
information
to
EPA.
The
Agency
will
specify
in
guidance,
that
this
information
be
provided
in
an
electronic
format.
OGWDW
has
established
procedures
and
allocated
resources
for
States
to
submit
information
in
electronic
format
to
SDWIS.
This
data
system
already
has
the
capability
to
accept
some
of
the
additional
State
data
that
would
be
required
by
the
revisions.
For
example,
SDWIS
can
currently
accept
the
reporting
of
all
90th
percentile
lead
data
for
any
system
and
dates
associated
with
various
milestones.
However,
modifications
to
SDWIS
are
needed
to
accept
the
new
"
Done"
and
"
Deemed"
milestones.

The
data
generated
as
a
result
of
the
modifications
will
be
integrated
in
the
existing
quarterly
SDWIS
reporting
cycle.
This
integration
will
result
in
efficiencies
because
fixed
reporting
costs
will
be
distributed
among
all
data
requirements.
In
addition,
having
these
data
in
a
national
automated
data
base
allows
the
Agency
to
readily
access
needed
information
and
provides
sorting
capabilities
to
more
readily
compile
and
analyze
data
for
Agency
use
and
response
to
the
public
and
outside
agencies.

5(
c)
Small
Entity
Flexibility
As
indicated
in
earlier
sections
of
this
ICR,
EPA
has
made
revisions
to
the
1991
LCR
which
reduce
to
the
extent
practicable
and
appropriate
the
burden
on
PWSs,
especially
smaller
systems.
These
revisions
establish
differing
compliance
or
reporting
requirements
or
schedules
that
take
into
account
the
resources
available
to
smaller
water
systems;
clarify,
consolidate
or
simplify
compliance
and
reporting
requirements;
and
eliminate
unnecessary
or
redundant
requirements.
Such
objectives
are
consistent
with
the
Regulatory
Flexibility
Act
(
RFA)
which
requires
all
executive
agencies
to
consider
small
entities
in
their
regulatory
design
and
implementation
processes.
EPA
has
previously
described
considerations
pertaining
to
small
systems
in
the
1991
ICR,
(
refer
to
pages
14­
18).

The
RFA,
as
amended
in
March
1996
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA),
requires
that
EPA
specifically
consider
the
effect
of
this
revised
regulation
on
small
entities.
26
The
Agency
must
assess
the
impact
of
the
revised
rule
on
small
entities
and
consider
regulatory
alternatives
if
a
rule
has
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
Under
the
RFA,
5
June
1999
27
The
RFA
analysis
of
the
1991
LCR
was
based
on
an
older
definition
for
small
entities
that
included
water
systems
serving
50,000
or
fewer
people.

28
Assumes
exceedance
occurs
in
first
round
of
monitoring
and
that
the
small
system
is
adhering
to
the
schedule
outlined
in
the
regulation.

29
As
indicated
in
this
paragraph,
small
entities
are
defined
as
water
systems
serving
10,000
or
fewer
people
for
RFA
analyses.
The
LCR
and
LCRMR
define
small
water
systems
as
serving
3,300
or
fewer
people.
For
all
sections
of
this
ICR
other
than
5(
c),
small
systems
refer
to
those
systems
serving
3,300
or
fewer
people.

25
U.
S.
C.
601
et
seq.,
the
Agency
must
prepare
a
regulatory
flexibility
analysis
describing
the
economic
impact
of
a
rule
on
small
entities
as
part
of
a
rulemaking.
However,
under
section
605(
b)
of
the
RFA,
if
EPA
certifies
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities,
EPA
is
not
required
to
prepare
a
regulatory
flexibility
analysis.

For
purposes
of
RFA
analyses
for
SDWA
rulemakings,
the
Agency
defines
small
entities
as
systems
serving
10,000
or
fewer
customers.
27
EPA
has
selected
systems
serving
10,000
or
fewer
persons
as
the
criterion
for
small
water
systems
for
the
definition
of
small
entity
because
this
is
the
system
size
category
specified
in
SDWA
for
small
system
flexibility.
This
definition
was
established
in
the
Consumer
Confidence
Reports
rulemaking
(
63
FR
444511,
Aug.
19,
1998).
For
further
information
regarding
this
definition
of
small
entities,
see
the
referenced
Federal
Register
notice.
Given
this
service
population
size,
more
than
95
percent
of
PWSs
would
be
considered
small
entities.
Examples
of
small
entity
flexibility
provided
by
the
revisions
are
discussed
in
sections
5(
c)(
i)
and
5(
c)(
ii)
below.

EPA
has
determined
that
the
LCRMR
will
affect
25,966
publicly­
owned
and
46,450
privatelyowned
small
water
utilities.
These
systems
will
be
required
to
conduct
monitoring,
submit
reports
to
the
State,
maintain
records,
and
in
some
instances
to
provide
information
to
their
users.
Most
of
the
quantifiable
cost
impacts
described
in
Section
6.0
affect
systems
serving
10,000
or
fewer
people.
Annual
system
costs
are
expected
to
decrease
and
small
systems
(
those
serving
3,300
or
fewer
persons)
will
derive
all
the
cost
savings
associated
with
the
monitoring
waivers.
Systems
qualifying
for
a
monitoring
waiver
will
be
able
to
reduce
lead
and/
or
copper
tap
water
monitoring
to
once
every
nine
years.
Small
systems
will
also
receive
most
of
the
cost
savings
associated
with
accelerated
reduced
lead
and
copper
monitoring.
In
particular,
small
systems
installing
treatment
that
demonstrate
very
low
lead
and
copper
levels
(
i.
e.,
those
systems
having
90th
percentile
lead
levels
of
0.005
mg/
L
or
less
and
90th
percentile
copper
levels
of
0.65
mg/
L
or
less)
for
two
consecutive
6­
month
monitoring
periods
will
avoid
three
rounds
of
monitoring.
28
Further,
CWSs
serving
3,300
or
fewer
people
that
exceed
the
lead
action
level
will
be
able
to
narrow
the
scope
of
their
public
education
efforts.
29
EPA
has
estimated
the
impact
of
the
LCRMR
and
concludes
that
the
impact
of
the
rule
on
small
water
systems
will
not
be
significant.
Therefore,
the
Administrator
is
certifying,
pursuant
to
section
605(
b)
of
the
RFA,
that
the
LCRMR
do
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities;
thereby
no
regulatory
flexibility
analysis
is
required.
The
basis
for
the
LCRMR
certification
is
as
follows:
the
annual
compliance
costs
of
the
rule
represent
less
than
1
percent
of
revenues
for
25,966
publicly­
owned
small
systems
and
less
than
1
percent
of
sales
for
the
46,450
privately­
owned
small
June
1999
26
systems.
As
seen
in
Figure
5­
1,
all
but
those
in
the
smallest
system
size
category
(
serving
500
or
fewer
people)
realize
an
average
annual
savings
for
the
first
three
years
of
the
LCRMR
(
1999­
2001).
The
cost
increase
for
these
smallest
systems
is
less
than
1
percent
of
median
annual
income
for
both
publicly­
and
privately­
owned
systems.
Looking
beyond
the
first
three
years
of
the
revised
program,
all
small
systems
will
realize
a
cost
and
burden
savings
as
a
result
of
the
LCR
revisions.
Therefore,
as
stated
above,
the
Administrator
has
certified
that
this
rule
will
not
have
a
significant
economic
impact
on
small
entities.
For
more
detail
regarding
the
assumptions
and
procedures
used
to
develop
system
cost
estimates,
refer
to
section
6(
b)(
i).

Figure
5­
1:
Annual
Burden
Indicators
for
the
LCR
Minor
Revisions
(
for
ICR
period
1999­
2001)

SBREFA
Summary
for
Publicly­
and
Privately­
Owned
Systems
Serving
25­
10,000
People
System
Size
Number
of
Systems
Impacted
(
a)
Average
Annual
Hours
per
System
(
1999­
2001)
Average
Annual
Cost
per
System
(
1999­
2001,
in
$
1,000'
s)
Savings
(
Costs)
as
a
percentage
of
Revenue/
Sales
(
b)

PUBLICLY­
OWNED
WATER
SYSTEMS
(
Revenue
Test)

500
and
under
10,978
1.2
$
0.01
0.07%

501
to
3,300
11,612
­
0.3
­$
0.02
­
0.01%

3,301
to
10,000
3,376
­
0.9
­$
0.07
­
0.01%

10,000
and
under
25,966
0.7
$
0.0005
0.0004%

PRIVATELY­
OWNED
WATER
SYSTEMS
(
Sales
Test)

500
and
under
40,213
1.2
$
0.01
0.08%

501
to
3,300
5,290
­
0.3
­$
0.02
­
0.01%

3,301
to
10,000
947
­
0.9
­$
0.07
­
0.01%

10,000
and
under
46,450
0.7
$
0.0005
0.0014%

(
a)
Numbers
of
publicly­
and
privately­
owned
systems
originate
from
January
1997
SDWIS
inventory.
The
median
annual
sales
and
revenue
figures
were
based
on
information
from
the
1995
Community
Water
System
Survey.
The
median
sales
figures
used
in
the
above
calculation
are:
25­
500:
$
15,973;
501­
3,300:
$
117,048;
and
3,301­
10,000:
$
608,194.
The
median
revenue
figures
used
in
the
above
calculation
are:
25­
500:
$
16,915;
501­
3,300:
$
116,588;
and
3,301
­
10,000:
$
547,409.

(
b)
The
Revenue
and
Sales
Tests
used
to
measure
small
business
impacts
are
recommended
in
the
EPA
Interim
Guidance
for
Implementing
the
Small
Business
Regulatory
Enforcement
Fairness
Act
and
Related
Provisions
of
the
Regulatory
Flexibility
Act,
February
1997.
All
systems
are
estimated
to
incur
cost
and
burden
savings
attributed
to
the
LCRMR.
To
present
a
relative
measure,
these
savings
are
shown
as
a
percentage
of
median
annual
revenue/
sales
for
each
size
category.
Savings
are
shown
as
a
negative
percentage.

(
c)
A
slight
burden
and
cost
increase
is
projected
for
systems
serving
500
and
fewer
for
the
three­
year
ICR
period.
The
burden
and
cost
for
reading
the
regulation
and
training
outweigh
the
savings
resulting
from
other
provisions
of
the
LCRMR.
The
other
size
categories
are
proportionally
less
impacted
by
the
burden
and
cost
to
read
the
June
1999
30
Prior
to
the
1995
Paperwork
Reduction
Act,
third­
party
notification
activities,
such
as
public
notification
and
public
education
were
not
subject
to
OMB
review.
Public
notification
burdens
and
costs
are
not
included
in
this
ICR,
but
are
included
in
the
ICR
for
the
revised
Public
Notification
regulation.

31
The
ICR
prepared
to
support
the
original
1991
LCR,
entitled
Final
Information
Collection
Request
for
National
Primary
Drinking
Water
Regulations
for
Lead
and
Copper,
April
1991,
estimated
burdens
and
costs
over
18
years
from
1992
through
2009
(
i.
e.,
two
nine­
year
source
water
monitoring
cycles).
The
estimates
presented
in
the
Drinking
Water
ICR
are
based
on
the
assumptions
used
to
develop
the
1991
27
regulations
and
training.
Looking
beyond
the
ICR
period,
all
small
systems
will
realize
a
burden
and
cost
savings
as
a
result
of
the
LCRMR.

5(
d)
Collection
Schedule
For
both
the
LCR
and
LCRMR,
the
Agency
considered
a
wide
range
of
alternatives
for
frequency
of
data
collection,
and
has
chosen
the
option
that
requires
the
least
frequent
collection
possible
while
still
remaining
consistent
with
its
overall
objective
of
protecting
public
health.
Where
possible,
State
discretion
in
adjusting
these
frequencies
has
been
allowed.
Monitoring
frequencies
for
PWSs
have
been
carefully
devised
based
on
the
following
factors:
system
size,
source
type,
system
construction,
and
contaminant
history.

The
consequences
of
less
frequent
data
collection
include
the
possibility
of
failing
to
identify
in
a
timely
fashion
significant
contaminant
concentrations
which
might
threaten
public
health
and
safety.
Although
the
modifications
allow
accelerated
reduced
monitoring
frequencies
and
monitoring
waivers,
they
require
that
a
system
first
meet
stringent
criteria
that
the
Agency
believes
are
protective
of
public
health.
The
LCRMR
add
a
provision
that
requires
systems
monitoring
annually
or
less
frequently
to
notify
the
State
within
60
days
of
changes
in
their
treatment(
s)
or
an
addition
of
a
new
source
of
water.
This
allows
the
State
to
detect
in
a
timely
fashion
whether
the
corrosivity
of
the
water
has
increased
due
to
these
changes.
Otherwise,
a
State
would
be
unaware
of
changes
in
lead
and
copper
levels
until
the
next
monitoring
results
were
submitted,
which
could
be
as
long
as
nine
years
under
the
revised
rule.
The
provision
also
would
allow
a
State
to
require
a
system
to
monitor
more
frequently
or
take
other
appropriate
actions
if
deemed
necessary.

6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
In
its
efforts
to
quantify
the
impact
of
the
LCRMR,
EPA
revised
its
burden
and
cost
estimates
of
the
LCR
from
those
presented
in
the
Drinking
Water
ICR.
Revisions
to
these
burden
and
cost
estimates
were
needed
to
more
accurately
reflect
the
outcome
of
the
implementation
of
the
regulation,
to
incorporate
public
education
activities,
and
to
allow
the
impacts
of
the
LCRMR
to
be
assessed
by
better
delineating
the
various
requirements
of
the
current
regulation.
30
To
quantify
the
requirements
of
the
LCR
and
LCRMR,
EPA
developed
six
system
burden/
cost
models
(
lead
and
copper
tap
monitoring,
source
water
monitoring,
water
quality
parameter
monitoring,
lead
service
line
monitoring,
reporting,
and
public
education)
and
three
State
models
(
oversight,
reporting,
and
record
keeping).
For
each
of
these
nine
models,
two
versions
were
developed
to
estimate
costs
and
burdens
for
1999
through
2009.31
One
serves
as
the
baseline
and
June
1999
LCR
estimates.
The
revised
baseline
used
in
this
May
1999
ICR
contains
burdens
and
costs
for
the
remaining
11
years
of
the
18­
year
time
period
(
i.
e.,
1999
through
2009).
Only
those
burdens
and
costs
for
1999
through
2001
apply
to
this
ICR.

32
The
Agency
recognizes
that
some
systems
may
exceed
in
later
monitoring
periods
or
may
have
intermittent
exceedances.
An
exceedance
of
the
action
level
based
on
the
first
round
of
monitoring
is
a
conservative
assumption.
The
Agency
believes
this
assumption
provides
a
reasonable
approach
for
estimating
burden
and
costs.

28
depicts
the
1991
LCR
requirements.
The
second
set
is
adjusted
to
reflect
the
requirements
of
the
LCRMR.
Appendix
D
contains
a
brief
narrative
and
summary
tables
of
the
number
of
events,
burdens,
and
costs
for
each
system
model.
Appendix
E
provides
this
information
for
the
State
models.

EPA
assumes
that
any
exceedance
of
an
action
level
would
occur
during
the
first
round
of
monitoring
(
on
June
1992
for
systems
serving
more
than
50,000
people,
on
December
1992
for
systems
serving
3,301
to
50,000
people,
and
on
December
1993
for
systems
serving
3,300
or
fewer
people).
32
The
percentage
of
systems
exceeding
the
lead
or
copper
action
level
was
based
on
initial
monitoring
data
reported
to
SDWIS.
Systems
and
States
are
assumed
to
follow
the
schedule
outlined
in
the
1991
LCR
and
to
require
the
maximum
time
to
complete
an
activity
that
was
allowed
under
the
LCR
or
LCRMR
(
e.
g.,
18
months
to
conduct
a
study,
6
months
for
systems
to
designate
OWQPs).
After
treatment
installation,
25
percent
of
systems
were
assumed
to
continue
to
exceed.
As
a
simplifying
assumption,
all
systems
that
were
required
to
install
corrosion
control
treatment
were
assumed
to
meet
their
WQPs
and
qualify
for
reduced
monitoring.
Based
on
these
assumptions,
systems
were
divided
into
compliance
pathways
that
dictated
their
monitoring,
lead
service
line
notification,
public
education,
or
reporting­
schedules.
This
in
turn
determined
the
timing
and
extent
of
State
oversight,
reporting,
and
record
keeping
activities.

Appendix
A
to
this
document
provides
a
more
detailed
discussion
of
the
assumptions
used
to
develop
the
revised
LCR
burden
and
cost
estimates
presented
in
this
ICR.
Appendix
B
provides
a
more
long­
term
picture
of
the
burden
impact
on
systems
and
States.
It
contains
year­
by­
year
system
and
State
burden
estimates
for
1999
through
2003
and
an
average
annual
burden
for
2004
through
2009.

Sections
6(
a)­(
e)
describe
the
change
in
respondent
burden
and
cost
for
information
collection
activities
under
the
LCRMR.
All
burden
and
costs
are
expressed
as
the
net
change
between
the
LCRMR
requirements
and
the
1991
LCR
requirements,
averaged
over
1999
through
2001.
Section
6(
f)
provides
an
explanation
of
the
changes
to
the
baseline
ICR
from
those
presented
in
the
Drinking
Water
ICR.

6(
a)
Estimating
Respondent
Burden
The
information
collection
burden
is
estimated
separately
for
PWSs
and
States
below.
Respondent
costs
are
presented
in
section
6(
b).

6(
a)(
i)
Burden
To
Public
Water
Systems
EPA
estimates
that
the
modifications
to
the
LCR
will
affect
75,945
PWSs,
although
individual
requirements
will
apply
to
subsets
of
drinking
water
systems.
PWSs
include
both
CWSs
and
NTNCWSs.
June
1999
29
Record
keeping
and
reporting
activities
under
the
LCRMR
will
decrease
annual
burden
to
PWSs
by
an
average
of
36,773
hours
over
the
three­
year
period
of
this
ICR.
Figure
6­
1
summarizes
the
change
in
burden
to
PWSs.
The
assumptions
and
methodologies
for
deriving
each
estimate
are
also
presented
in
this
section.
June
1999
30
Figure
6­
1:
Change
in
Annual
System
Burden
for
1999
through
2001
due
to
LCRMR
(
in
hours)

Activity
Average
Burden
Initial
Activities
Read
regulations
and
train
staff
202,520
Tap
and
WQP
Monitoring
Requirements
(
b)(
3)
system
monitoring
7,968
Alternate
monitoring
schedule
for
systems
on
reduced
monitoring
­
1,430
Accelerated
lead
and
copper
monitoring
­
54,670
Monitoring
waivers
­
47,308
Accelerated
WQP
monitoring
­
4,949
Entry
point
monitoring
at
representative
sites
­
40,535
Source
Water
Monitoring
Requirements
Reduced
source
water
monitoring
for
PWSs
w/
o
MPLs
­
1,408
Public
Education
Delivery
of
public
education
materials
­
5,966
Lead
Service
Line
Monitoring
and
Notification
Requirements
Partial
lead
service
line
monitoring
­
78,733
Partial
lead
service
line
notification
8,411
Revisions
to
System
Reporting
Requirements
Eliminate
first­
draw/
customer­
collected
certifications
­
5,567
Eliminate
sample
site
justification
­
2,027
Remove
request
for
reduced
monitoring
­
2,227
State
flexibility
to
calculate
90th
percentile
values
­
9,394
Report
changes
in
treatment
or
addition
of
new
source
264
Evaluate/
report
WQPs
compliance
using
new
compliance
criteria
3,463
Change
public
education
reporting
deadline
388
Report
compliance
with
partial
lead
service
line
replacement
requirements
2,405
June
1999
Figure
6­
1:
Change
in
Annual
System
Burden
for
1999
through
2001
due
to
LCRMR
(
in
hours)

Activity
Average
Burden
31
Impacts
resulting
from
changes
in
other
provisions
Reporting
of
lead
and
copper
results
­
6,072
Reporting
of
source
water
monitoring
results
­
463
Specify
lead
and
copper
monitoring
location
changes
­
1,443
TOTAL
­
36,773
6(
a)(
i)(
a)
Read
the
Regulations
and
Training
Activities
States
will
be
mainly
responsible
for
understanding
and
adopting
these
regulations
and
for
notifying
PWSs
of
changes
in
specific
rule
requirements.
Therefore,
PWSs
are
assumed
to
bear
a
relatively
minor
burden
for
activities
such
as
reading
the
regulations
and
training.
EPA
assumes
that
each
system
will
require
4
hours
to
read
the
revised
regulations
and
an
additional
4
hours
to
attend
training
on
the
revisions.
This
equals
a
total
burden
of
607,560
hours
or
an
average
annual
burden
of
202,520
hours
for
reading
these
two
activities
over
the
three­
year
ICR
period.

6(
a)(
i)(
b)
Monitoring
The
estimates
of
PWS
monitoring
burden
include
the
following
activities:


Gather
information
(
i.
e.,
identify
sample
sites
and
take
samples);


Create
information
(
i.
e.,
conduct
tests
on
samples
collected);


Process,
compile,
and
review
information
created.

The
burden
to
record
and
mantain
the
monitoring
results
and
to
submit
these
data
to
the
State
are
estimated
separately
and
are
discussed
later
in
this
section.

EPA
estimated
burdens
separately
for
lead
and
copper
monitoring
at
the
tap,
WQP
monitoring,
lead
and
copper
monitoring
at
the
source,
and
lead
service
line
monitoring
and
notification
requirements.
The
PWS
burden
for
all
monitoring­
related
activities
will
decrease
by
an
average
of
212,654
hours
per
year.
The
procedure
for
estimating
burden
for
these
four
monitoring
categories
is
discussed
in
more
detail
below.

Lead
and
Copper
Tap
Water
Monitoring.
June
1999
33
The
1991
ICR
and
the
Drinking
Water
ICR
assumed
that
all
analyses
were
conducted
in­
house.
Per
the
Office
of
Management
and
Budget
(
OMB)
guidance,
EPA
has
retained
this
assumption
to
estimate
the
revised
baseline
and
LCRMR
burdens/
costs.
This
will
allow
OMB
to
better
identify
changes
in
burdens/
costs
due
to
the
impacts
of
the
revisions
as
opposed
to
changes
in
the
procedure
for
estimating
burdens/
costs.

32
EPA
estimates
that
overall
the
annual
lead
and
copper
tap
water
monitoring
burden
will
decrease
by
average
of
95,440
hours
over
the
three
years.
This
reduction
is
due
to
accelerated
reduced
monitoring,
monitoring
waivers,
and
the
flexibility
to
allow
alternative
monitoring
schedules
for
systems
on
reduced
monitoring.
The
general
assumptions
used
to
estimate
the
burden
are
presented
below.
In
addition,
the
procedure
used
to
estimate
the
impact
of
specific
revisions
affecting
lead
and
copper
monitoring
are
also
discussed.


By
1999,
all
systems
will
have
completed
initial
monitoring
and
if
applicable,
have
completed
a
corrosion
control
study,
the
installation
of
corrosion
control
treatment,
and/
or
the
installation
of
source
water
treatment.


Any
exceedance
will
have
occurred
in
the
first
round
of
initial
monitoring
(
i.
e.,
1992
for
large
and
medium
systems
and
1993
for
small
systems);


Monitoring
will
be
an
ongoing
burden,
and
is
averaged
over
an
1999
through
2001
to
obtain
average
annual
burdens;


Sample
collection
(
the
labor
required
for
travel,
gaining
access
to
the
sampling
station,
and
sample
collection)
takes
2.5
hours
per
sample
(
except
where
noted
for
seasonal
systems);


Systems
will
collect
the
minimum
number
of
samples
required
under
the
regulation;


Lead
and
copper
analyses
will
be
conducted
by
the
system
and
will
require
a
total
of
1
hour
per
sample
for
the
analysis
of
both
parameters;
33

The
time
for
designing
the
targeted
sampling
strategy
and
interpreting
results
has
not
been
estimated
separately
and
is
assumed
to
be
included
in
the
sample
collection
burden;
and

The
time
for
interpreting
the
results
is
included
as
part
of
the
reporting
burden.

Continued
monitoring
for
(
b)(
3)
systems
The
LCRMR
clarify
EPA's
intent
that
(
b)(
3)
systems
continue
lead
and
copper
tap
monitoring
after
initial
monitoring,
by
adding
language
that
explicitly
requires
these
systems
to
conduct
monitoring
on
a
triennial
basis.
The
Agency
assumes
that
all
(
b)(
3)
systems
are
large
systems
and
that
these
systems
would
have
discontinued
lead
and
copper
tap
monitoring
after
initial
monitoring
under
the
LCR.
The
lead
and
copper
monitoring
model
for
the
LCRMR
project
that
these
systems
will
conduct
one
round
of
monitoring
during
the
three­
year
ICR
period.
Over
the
three
years
this
equals
an
average
of
2,227
samples
June
1999
34
EPA
assumes
that
if
these
systems
had
not
qualified
for
a
waiver,
they
would
be
on
reduced
monitoring
(
due
to
the
low
levels
needed
to
qualify
for
a
waiver)
and
would
have
been
required
to
conduct
a
round
of
monitoring
during
1999.

33
at
a
burden
of
3.5
hours
per
lead
and
copper
sample.
This
translates
to
an
average
annual
burden
increase
of
7,968
hours
over
the
three
years.

Alternative
monitoring
schedule
for
systems
on
reduced
monitoring
According
to
SDWIS
(
April
23,
1999),
112
NTNCWSs
do
not
operate
during
the
summer
months.
During
the
ICR
period,
110
of
these
systems
would
be
on
reduced
monitoring
and
would
have
been
required
to
make
special
arrangements
to
collect
samples.
EPA
assumes
that
these
systems
would
have
required
8
hours
to
collect
the
sample
(
includes
travel
time,
flushing
the
system,
and
allowing
a
6­
hour
standing
time)
and
1
hour
to
analyze
it.
During
the
1999
through
2001
time
frame,
these
systems
would
have
collected
an
average
of
260
samples
at
a
burden
of
9
hours
per
sample.
Under
the
LCRMR,
these
systems
can
monitor
during
times
of
normal
operation
and
will
no
longer
be
required
to
make
special
arrangement
to
collect
samples.
Therefore,
the
monitoring
and
analysis
of
a
sample
are
assumed
to
be
completed
in
3.5
hours
(
saves
5.5
hours
per
sample).
This
translates
to
an
average
annual
savings
of
1,430
hours
over
the
three
years.
No
burden
impact
is
assumed
for
CWSs
because
they
are
in
operation
yearround
and
States
will
only
require
these
systems
to
change
monitoring
schedules
if
the
States
believe
an
alternative
time
frame
would
be
more
likely
to
yield
samples
with
higher
lead
levels
(
e.
g.,
higher
levels
in
winter
due
to
heating
tapes
on
pipes).

Accelerated
reduced
lead
and
copper
monitoring
Because
of
the
timing
of
this
revision,
small
and
medium
systems
that
did
not
exceed
the
lead
or
copper
action
level
during
initial
monitoring
would
not
benefit
from
this
revision.
However,
EPA
believes
there
are
still
systems
that
will
benefit.
EPA
estimates
that
20
percent
of
the
large
non­(
b)(
3)
systems
and
20
percent
of
those
medium
and
small
systems
required
to
install
treatment
will
qualify
for
accelerated
reduced
monitoring.
These
systems
will
save
an
average
of
about
15,620
samples
over
the
three
years
at
a
burden
savings
of
3.5
hours
per
sample.
This
translates
to
an
average
annual
reduction
in
burden
of
54,670
hours
over
three
years.

Monitoring
waivers
EPA
assumes
that
approximately
10
percent
of
small
systems
(
or
6,809
systems)
will
be
eligible
for
a
monitoring
waiver.
Systems
will
spend
1.0
hour
preparing
each
monitoring
waiver
request.
During
the
1999
through
2001
period,
each
of
the
6,809
systems
will
prepare
one
monitoring
waiver
application.
Thus,
systems
will
spend
a
total
of
6,809
hours
over
the
three
years
or
an
average
of
2,270
hours
applying
for
the
waivers.
In
addition,
EPA
estimates
that
these
systems
will
collect
an
average
of
14,165
fewer
samples
over
the
three­
year
ICR
period
and
would
have
required
3.5
hours
per
lead
and
copper
sample.
34
The
corresponding
annual
reduction
in
burden
for
less
frequent
monitoring
is
estimated
to
be
49,578
hours.
The
net
reduction
in
burden
associated
with
the
monitoring
waiver
provision
is
a
three­
year
average
of
47,308
hours.
June
1999
35
Under
the
LCR,
States
were
not
required
to
report
90th
percentile
copper
or
lead
levels
that
were
below
the
action
level
to
EPA.
Hence,
the
Agency
cannot
estimate
how
many
systems
have
low
levels
of
only
one
of
the
two
contaminants
and
may
qualify
for
a
partial
waiver.

36
The
5
samples
apply
to
a
system
serving
500
or
fewer
people
that
is
on
triennial
monitoring.
The
lead
and
copper
tap
model
estimates
that
80
samples
would
have
been
collected
between
1999­
2001
for
systems
serving
501­
3,300
people
that
exceeded
after
installing
treatment
(
i.
e.,
4
rounds
of
monitoring
of
20
samples
per
round.)

37
Systems
are
deemed
to
have
optimized
corrosion
control
under
§
141.81(
b)(
2)
if
in
advance
of
the
LCR,
they
had
conducted
corrosion
control
activities
that
were
equivalent
to
the
requirements
under
the
LCR
(
i.
e.,
conducted
a
corrosion
control
study,
installed
corrosion
control
treatment).

34
The
Agency
expects
that
some
small
systems
will
qualify
for
a
monitoring
waiver
for
lead
or
copper
only
(
i.
e.,
a
partial
waiver),
but
could
not
estimate
the
number
of
systems
that
will
be
impacted.
35
During
the
three­
year
ICR
period,
systems
would
have
collected
a
total
of
5
samples
to
80
samples.
36
The
analytical
burden
per
lead
or
copper
sample
is
0.5
hour
and
the
corresponding
reduction
in
system
burden
would
range
between
2.5
hours
to
40
hours
per
system
or
an
average
of
0.8
hours
to
13.3
hours
per
year.
No
collection
burden
savings
is
expected
because
systems
must
continue
to
monitor
more
frequently
than
every
nine
years
for
the
non­
waivered
contaminant.
Systems
requesting
a
partial
monitoring
waiver
are
also
assumed
to
require
1
hour
to
prepare
and
submit
this
request.

Monitoring
provisions
that
will
not
have
a
quantifiable
impact
The
following
LCRMR
provisions
are
not
expected
to
have
a
quantifiable
effect
on
lead
and
copper
tap
water
monitoring
burdens:


(
b)(
2)
systems.
The
Agency
did
not
quantify
the
impact
of
the
LCRMR
revisions
that
require
systems
deemed
to
have
optimize
treatment
under
§
141.81(
b)(
2)
to
continue
to
conduct
tap
and
WQP
monitoring.
37
EPA
assumes
that
fewer
than
1
percent
of
large
systems
(
about
7
systems)
meet
the
criteria
under
§
141.81(
b)(
2).


(
b)(
3)
systems.
The
Agency
did
not
quantify
the
impact
of
two
of
the
revisions
that
pertain
to
(
b)(
3)
systems.
First,
EPA
assumed
that
the
new
requirement
to
meet
the
copper
action
level
to
maintain
or
attain
(
b)(
3)
status
would
not
have
an
appreciable
burden
on
systems.
The
Agency
believes
that
few
of
the
estimated
171
large
(
b)(
3)
systems
will
exceed
the
copper
action
level
and
be
required
to
conduct
increased
monitoring
or
to
undertake
other
significant
actions.


Non­
first­
draw
samples.
EPA
assumes
that
1,000
water
systems
in
total
will
request
State
permission
to
use
taps
that
cannot
provide
first­
draw
samples.
EPA
also
assumes
that
the
transaction
cost
to
request
this
flexibility
will
be
more
than
offset
by
the
cost
to
shut
down
operations
to
provide
first­
draw
samples.
Therefore,
the
net
change
to
system
burden
is
zero.
June
1999
38
The
analytical
burden
for
entry
point
WQPs
is
lower
because
pH
and
inhibitor
concentration
are
assumed
to
be
measured
using
in­
line
meters.

35

State
specifies
reduced
tap
water
monitoring
sites.
The
LCRMR
clarify
that
systems
must
collect
samples
from
representative
sites.
In
addition,
the
LCRMR
allow
States
the
flexibility
to
identify
from
which
sites
a
system
on
reduced
monitoring
must
sample.
No
burden
impact
is
assumed
because
the
system
is
not
required
to
collect
additional
samples
or
submit
any
documentation
in
response
to
this
revision.


Sample
invalidation.
EPA
estimates
that
less
than
0.5
percent
of
systems
each
monitoring
period
will
seek
to
have
samples
invalidated.
Systems
are
assumed
to
require
1.0
hour
to
prepare
the
documentation
to
request
sample
invalidation.
In
addition,
some
systems
may
potentially
avoid
the
burden
associated
with
having
to
install
corrosion
control
treatment,
conducting
public
education,
or
resuming
a
standard
monitoring
schedule
(
once
on
reduced
monitoring).
EPA
estimates
that
they
will
more
than
offset
the
transaction
costs
associated
with
requesting
sample
invalidation.


Decrease
holding
time
for
acidified
samples.
No
burden
impact
is
estimated
because
this
change
will
not
affect
the
amount
of
labor
associated
with
analyzing
the
sample,
but
may
allow
more
flexibility
in
scheduling
when
an
analysis
must
be
completed.

Water
Quality
Parameter
Monitoring
The
WQP
monitoring
model
assumes
that
a
collection
burden
of
0.5
hours
per
entry
point
will
be
applicable
to
those
systems
that
chlorinate
only
or
apply
no
treatment
(
i.
e.,
80
percent
of
ground
water
systems,
based
on
treatment
information
in
SDWIS).
For
the
other
20
percent
of
ground
water
systems
and
all
surface
water
systems,
no
collection
burden
is
assumed
because
these
systems
are
already
presumably
collecting
WQP
samples
to
monitor
treatment
effectiveness.
All
distribution
tap
WQP
samples
are
assumed
to
be
collected
with
lead
and
copper
tap
samples
or
coliform
samples
and
to
incur
no
additional
collection
burden.
The
analytical
burden
per
WQP
tap
sample
is
2
hours
and
0.5
hours
per
entry
point
WQP
sample.
38
Entry
point
monitoring
at
representative
sites
All
157
large
and
240
medium­
size
ground
water
systems
are
expected
to
collect
entry
point
samples
from
fewer
sites.
The
Agency
assumes
that
small
water
systems
have
too
few
entry
points
to
benefit
from
the
provision
that
allows
entry
point
monitoring
to
be
limited
to
representative
locations
instead
of
monitoring
at
all
entry
points.
EPA
estimates
that
large
ground
water
systems
will
reduce
the
number
of
samples
by
two­
thirds
and
medium
ground
water
systems
by
one­
half.
EPA
assumes
that
these
ground
water
systems
will
require
1
hour
to
request
this
monitoring
for
a
total
of
397
hours
or
an
average
annual
burden
of
132
hours.
These
systems
in
turn
are
expected
to
realize
a
reduction
in
burden
associated
with
sample
collection,
for
an
annual
average
reduction
in
collection/
analytical
burden
of
40,667
hours.
June
1999
36
The
net
average
annual
reduction
in
burden
associated
with
this
provision
is
an
average
of
40,535
hours
over
the
three
years.

Accelerated
reduced
WQP
tap
monitoring
Only
large
systems
will
benefit
from
accelerated
reduced
WQP
monitoring,
because
small
and
medium
systems
with
very
low
lead
and
copper
levels
do
not
exceed
the
action
levels
and
therefore,
are
not
required
to
perform
WQP
monitoring.
The
same
112
large
systems
that
qualify
for
accelerated
reduced
lead
and
copper
monitoring
will
qualify
for
accelerated
reduced
monitoring
for
WQPs
at
the
tap.
These
systems
would
have
collected
an
average
of
2,474
samples
during
1999
through
2001
and
would
have
incurred
an
analytical
burden
of
2
hours
per
sample.
These
systems
will
realize
an
average
annual
reduction
in
analytical
burden
of
4,949
hours.
No
sample
collection
burden
reduction
is
estimated
because
tap
WQP
samples
are
assumed
to
be
collected
with
lead
and
copper
tap
samples
or
coliform
samples.

Source
Water
Lead
and
Copper
Monitoring
The
source
water
monitoring
model
assumes
that
by
1999
all
systems
will
be
monitoring
no
more
frequently
than
annually.
No
source
water
collection
burden
is
assumed
because
lead
and
copper
source
water
samples
are
assumed
to
be
collected
with
other
inorganic
samples,
such
as
nitrate.
The
analytical
burden
is
assumed
to
be
1
hour
per
sample
and
to
include
the
analysis
of
both
lead
and
copper.

Reduced
source
water
monitoring
Systems
that
exceed
the
lead
or
copper
action
level
and
which
have
low
levels
of
lead
and
copper
in
their
source
water
can
now
conduct
source
water
monitoring
at
a
reduced
frequency.
Based
on
the
source
water
monitoring
model,
5,384
systems
will
be
impacted
by
this
revision
and
collect
an
average
of
1,408
fewer
lead
and
copper
samples.
These
systems
will
realize
an
average
annual
reduction
in
burden
of
1,408
hours.
The
burden
reduction
is
due
to
labor
associated
with
analyzing
fewer
samples
of
1
hour
per
sample.
No
reduction
in
collection
burden
is
expected
because
by
1999,
systems
will
be
monitoring
no
less
frequently
than
annually.
Source
water
lead
and
copper
samples
are
assumed
to
be
collected
with
nitrate
samples
or
other
source
water
samples.

Resampling
triggers
for
composited
samples
The
LCRMR
increase
the
copper
source
water
resampling
trigger.
EPA
anticipates
that
this
revision
may
reduce
burden
because
it
may
decrease
the
number
of
instances
when
source
water
samples
must
be
reanalyzed.
EPA
could
not
quantify
the
magnitude
of
this
reduction.

Lead
Service
Line
Replacement
Monitoring
and
Notification
Requirements
June
1999
39
The
1991
RIA
is
entitled,
Final
Regulatory
Impact
Analysis
of
National
Primary
Drinking
Water
Regulations
for
Lead
and
Copper,
April
1991.

40
EPA
estimates
that
25%
of
small
systems
and
20%
of
medium
and
large
systems
will
exceed
the
lead
action
level
only.
The
estimate
for
medium
and
large
systems
are
based
on
initial
monitoring
results
reported
to
EPA
Headquarters
during
1992
and
1993.
This
information
was
used
in
press
releases
issued
by
the
Agency
in
October
1992
and
May
1993.
Comparable
data
does
not
exist
for
small
systems
and
EPA
conservatively
estimated
the
exceedance
rate
to
be
slightly
higher
for
this
group
of
systems.

41
For
systems
serving
100
or
more
people,
EPA
assumes
that
lead
service
line
monitoring
results
for
40
percent
of
the
lines
would
indicate
that
these
line
did
not
need
to
be
replaced
(
i.
e.,
results
are
<
15
ppb).
Systems
serving
100
or
fewer
people
only
have
26
lines
to
replace
over
15
years
and
these
systems
were
conservatively
assumed
to
replace
all
these
lines.

42
As
previously
discussed,
the
court
vacated
EPA's
1991
definition
of
control
beyond
"
control"
equals
"
ownership".
Because
lead
service
line
replacement
does
not
begin
until
after
treatment
has
been
installed,
EPA
assumes
that
the
1994
court
decision
would
have
been
in
effect
when
systems
began
replacement
under
the
LCR.

43
Under
the
LCR,
systems
must
offer
to
collect
a
post­
replacement
sample
at
each
residence
served
by
the
line.
EPA
assumed
that
all
residence
would
want
to
know
the
impact
of
partial
replacement
on
their
lead
levels
and
would
accept
the
offer
to
have
their
water
tested.

37
EPA
assumes
that
762
systems
will
be
required
to
replace
lead
service
lines
(
LSLs).
This
number
was
adjusted
from
the
8,281
systems
estimated
to
replace
LSLs
in
the
1991
RIA39,
because
fewer
systems
exceeded
the
lead
action
level
than
originally
projected.
40
Based
on
assumptions
used
in
the
1991
RIA,
EPA
assumed
that
systems
serving
more
than
100
people
would
replace
60
percent
of
their
lead
service
lines;
those
serving
100
or
fewer
people
would
replace
all
of
their
lines.
41
EPA
also
assumed
that
systems
would
require
15
years
to
replace
the
lines.
The
baseline
and
LCRMR
models
assume
that
there
are
two
types
of
monitoring
and
that
both
will
occur
over
a
15­
year
period
(
no
system
is
assumed
to
be
on
an
accelerated
replacement
schedule
or
to
cease
replacement
once
being
triggered
into
lead
service
line
replacement):
1)
Monitoring
to
determine
whether
a
line
needs
to
be
replaced,
and
2)
Monitoring
required
because
only
a
portion
of
a
line
will
be
replaced.

The
LCRMR
do
not
impact
the
provisions
that
allow
a
system
to
collect
a
lead
service
line
sample
to
determine
whether
a
line
needs
to
be
replaced.
However,
the
LCRMR
revise
the
monitoring
and
notification
requirements
following
partial
replacement
of
a
lead
service
line.
EPA
assumes
that
under
both
the
LCR
and
LCRMR,
the
system
will
only
replace
the
portion
of
the
line
it
owns.
42
The
Agency
also
conservatively
assumes
that
no
homeowner
will
request
that
his/
her
portion
of
the
line
be
replaced.
Therefore,
partial
lead
service
line
replacement
will
occur
in
all
instances.
Under
the
LCRMR,
following
the
partial
replacement
of
a
line,
systems
must
collect
a
post­
replacement
sample
that
is
representative
of
each
line
replaced.
EPA
estimates
a
burden
reduction
associated
with
the
collection
and
analysis
of
postreplacement
samples
under
the
LCR
because
systems
are
assumed
to
collect
one
sample
per
line
compared
to
one
sample
per
residence
served
by
the
line
as
specified
under
the
LCR.
43
The
Agency
estimates
that
each
line
serves
an
average
of
2.3
residences.
Each
sample
will
require
a
collection
burden
of
2
hours
and
June
1999
44
Refer
back
to
section
4(
b)(
ii)(
k)
for
a
discussion
of
the
revisions
to
the
partial
lead
service
replacement
notification
requirements
under
the
LCRMR.

45
Under
the
LCRMR,
systems
serving
500
and
fewer
people
are
not
required
to
deliver
public
service
announcements
or
provide
notice
to
newspapers.
Systems
serving
501
to
3,300
people
can
also
forego
public
service
announcement,
but
must
receive
State
approval
to
omit
newspaper
notification.

38
an
analytical
burden
of
0.5
hours.
This
translates
to
an
average
annual
burden
reduction
of
78,733
hours
per
year
over
the
three­
year
ICR
period.

The
lead
service
line
monitoring
model
also
calculates
as
part
of
the
monitoring
burden,
the
burden
needed
to
conduct
partial
lead
service
line
notification
requirements.
Due
to
the
more
extensive
notification
requirements
associated
with
partial
lead
service
line
replacement
under
the
LCRMR,
large
systems
are
assumed
to
require
an
additional
15
minutes
to
complete
these
revised
requirements.
44
The
estimated
average
annual
increase
in
burden
is
8,411
hours
per
year.
Taking
into
account
both
the
monitoring
and
notification
requirements,
systems
are
expected
to
experience
an
average
annual
reduction
in
burden
of
70,322
hours
over
the
three
years.

6(
a)(
i)(
c)
Public
Education
By
1999,
EPA
assumes
that
only
those
systems
that
continue
to
exceed
the
lead
action
level
will
deliver
public
education
(
4,649
systems).
Under
the
LCRMR,
CWSs
serving
3,300
or
fewer
people
are
expected
to
experience
a
burden
reduction.
The
2,983
small
CWSs
are
no
longer
required
to
deliver
public
service
announcements.
In
addition,
EPA
assumes
that
States
will
no
longer
require
newspaper
notification
and
will
allow
these
systems
to
limit
the
distribution
of
pamphlets.
45
EPA
also
assumes
that
these
systems
would
have
spent
1
hour
every
6
months
to
complete
these
activities.
The
average
annual
burden
reduction
associated
with
this
provision
is
5,966
hours.

The
public
education
models
do
not
quantify
changes
associated
with
alternative
language
for
NTNCWSs
and
special
CWSs,
allowing
flexibility
in
delivery
for
NTNCWSs,
and
State
flexibility
to
approve
minor
changes
in
language.
EPA
believes
that
these
changes
should
reduce
burden
for
some
systems,
but
is
unable
to
quantify
these
reductions.

6(
a)(
i)(
d)
Reporting
and
Record
Keeping
Many
of
the
revisions
impact
system
reporting
and
record
keeping
burden.
Several
of
the
provisions
eliminate
unnecessary
reporting
requirements.
Some
of
the
provisions
have
been
added
to
provide
States
with
more
timely
information
or
with
data
necessary
to
make
new
determinations
under
the
LCRMR.
In
addition,
some
of
the
reporting
requirements
are
impacted
from
changes
in
other
provisions.
June
1999
46
This
average
estimate
does
not
include
the
application
for
a
monitoring
waiver
(
2,270
hours)
or
for
requests
to
collect
WQPs
and
representative
sites
(
132
hours).
Estimates
for
these
activities
were
included
under
the
monitoring
burden.
If
these
estimates
were
included
under
reporting,
the
total
average
annual
burden
reduction
would
be
18,273
hours.

47
EPA
determined
the
number
of
certifications
by
multiplying
the
number
of
systems
conducting
lead
and
copper
monitoring
identified
in
the
monitoring
model
during
1999
through
2001
times
the
burden
of
10
minutes.

48
Two
consecutive
six­
months
of
semi­
annual
monitoring
in
which
the
system
no
longer
exceed
an
action
level
was
counted
as
one
year
toward
the
three
years
of
consecutive
monitoring
needed
to
qualify
for
triennial
monitoring.

39
The
Agency
estimates
that
overall,
the
reporting
burden
will
decrease
by
20,673
hours.
46
Each
of
the
revisions
is
discussed
in
more
detail
below.


Eliminate
certifications
for
first­
draw
samples.
EPA
estimates
that
systems
will
no
longer
complete
an
average
of
33,401
certifications
per
year
and
that
each
certification
would
have
required
10
minutes
to
prepare.
The
average
reduction
in
burden
over
the
three
years
is
estimated
to
be
5,567
hours.
47

Eliminate
justifications.
EPA
estimates
that
50
percent
of
CWSs
on
reduced
monitoring
would
have
sent
in
an
average
of
12,163
justifications
over
the
three­
year
ICR
period
that
explain
why
samples
were
collected
from
non­
Tier
1
sites
or
why
the
sampling
pool
was
comprised
of
fewer
than
50
percent
of
sites
served
by
lead
service
lines.
EPA
assumes
that
these
justifications
would
have
required
10
minutes.
This
translates
to
an
average
annual
burden
of
2,027
hours.


Remove
need
to
request
approval
for
reduced
monitoring.
Over
1999
through
2001
the
lead
and
copper
tap
monitoring
model
predicts
that
6,116
systems
will
meet
their
OWQPs
and
qualify
for
annual
monitoring.
A
total
of
564
systems
will
also
qualify
for
triennial
monitoring.
48
The
LCRMR
eliminate
the
requirement
for
systems
to
specifically
request
State
permission
to
assume
a
reduced
monitoring
schedule.
These
systems
include
all
large
systems,
except
(
b)(
3)
systems,
and
small
and
medium
systems
that
continue
to
exceed
either
action
level
after
installing
treatment.
The
monitoring
model
also
assumes
that
all
systems
that
install
treatment
will
meet
their
WQP
levels.
Systems
would
have
submitted
a
total
of
6,680
requests
and
would
have
required
1
hour
to
prepare
and
submit
these
requests
to
the
State.
This
translates
into
an
annual
burden
reduction
over
the
three
years
of
2,227
hours.


State
flexibility
to
calculate
90th
percentile
level.
Based
on
information
collected
during
data
verifications
conducted
in
State
program
offices,
EPA
estimates
that
50
percent
of
States
will
elect
to
calculate
the
90th
percentile
level
for
all
water
systems
under
their
jurisdiction
and
as
a
simplifying
assumption
that
these
water
systems
are
distributed
evenly
among
these
States.
Systems
are
estimated
to
have
required
between
0.5
hours
and
June
1999
40
2
hours
to
perform
this
calculation
depending
on
the
number
of
samples
collected.
This
results
in
an
average
burden
reduction
of
9,394
hours
over
the
three­
year
ICR
period.


Changes
in
Treatment
or
Addition
of
a
New
Source.
EPA
assumes
that
annually
2
percent
of
systems
subject
to
reduced
monitoring
(
527
systems
on
average
during
1999
­
2001)
will
report
a
change
in
treatment
or
an
addition
of
a
new
source.
Further,
EPA
estimates
that
systems
will
require
0.5
hours
to
prepare
and
report
the
information
to
the
State,
resulting
in
an
average
annual
increase
in
burden
of
264
hours.
Although,
in
some
instances
the
State
may
determine
that
the
change
warrants
a
system's
returning
to
standard
monitoring,
EPA
expects
this
will
occur
in
rare
instances
especially
if
the
system
notifies
the
State
prior
to
making
the
change
(
as
EPA
recommends),
so
that
adverse
impacts
on
tap
water
lead
and
copper
levels
can
be
minimized
or
prevented.
Therefore,
any
associated
increase
in
burden
is
expected
to
be
negligible.


Evaluate/
Report
WQPs
Using
New
Compliance
Procedures.
Under
the
LCRMR,
systems
are
assumed
to
continue
to
report
WQP
results
every
6
months
and
to
require
an
extra
10
minutes
each
6­
month
monitoring
period
to
assess
compliance
using
the
new
compliance
criteria.
This
translates
to
an
increase
in
annual
burden
of
0.33
hours
per
system.
During
1999
through
2001,
systems
are
estimated
to
submit
an
average
of
10,493
reports
per
year.
The
burden
increase
to
systems
over
the
three­
year
ICR
period
is
estimated
to
average
3,463
hours.
EPA
anticipates
that
the
revised
compliance
criteria
should
result
in
fewer
violations
for
failure
to
meet
OWQP
values
or
ranges
and
therefore,
should
offset
some
of
the
burden
to
assess
compliance.
However,
the
Agency
could
not
quantify
this
burden
reduction
impact
for
systems.


Changes
in
Deadline
for
Reporting
Compliance
with
Public
Education
Requirements.
Under
the
LCRMR,
systems
are
required
to
submit
information
demonstrating
compliance
within
10
days
after
the
end
of
the
period
in
which
public
education
was
required
to
be
performed.
Under
the
1991
LCR,
systems
do
not
have
to
submit
this
information
until
December
31
of
each
year.
This
modification
will
impact
CWSs
serving
more
than
3,300
people
that
remain
above
the
action
level
for
more
than
one
monitoring
period
because
these
systems
must
perform
some
public
education
tasks
on
a
semi­
annual
basis
for
as
long
they
exceed
the
lead
action
level.

EPA
assumes
water
systems
will
require
1
hour
to
prepare
the
letter/
report
demonstrating
compliance
with
public
education
requirements.
To
calculate
the
change
in
burden,
EPA
estimated
the
number
of
additional
reports
that
would
be
required
by
determining
the
number
of
CWSs
serving
more
than
3,300
persons
that
would
remain
above
the
lead
action
level.
The
model
predicts
that
388
of
these
systems
meet
these
criteria.
This
translates
to
351
and
37
additional
reports
per
year
for
large
and
medium
system,
respectively.
The
average
annual
increase
in
burden
over
the
3
years
is
estimated
to
be
388
hours.


Reporting
Compliance
with
Partial
Lead
Service
Line
Notification
and
Monitoring
Requirements.
Based
on
State
comments
received
on
the
April
1998
Notice
of
Data
June
1999
49
EPA
estimated
the
number
of
letters
by
dividing
the
number
of
lead
service
lines
from
the
1991
RIA
for
each
system
size
and
dividing
it
by
15
to
get
the
annual
number
of
lines
replaced
each
year.
Lead
service
line
replacement
was
assumed
to
occur
evenly
throughout
the
year
and
that
systems
would
require
between
2
months
to
12
months
each
year
to
replace
the
lines.
The
number
of
months
was
multiplied
by
the
number
of
systems
in
each
size
category
to
obtain
the
average
number
of
months
of
replacement
(
9
months).
One
letter
was
assumed
to
be
submitted
for
each
month
of
replacement.

41
Availability,
EPA
assumes
that
75
percent
of
States
will
require
systems
to
submit
a
letter
that
demonstrates
compliance
with
partial
lead
service
line
replacement
monitoring
and
notification
requirements.
During
the
ICR
period,
an
average
of
534
systems
will
submit
an
average
of
9
letters
each
year
(
i.
e.,
4,809
letters).
49
Systems
are
assumed
to
require
0.5
hours
per
letter.
This
translates
to
an
average
annual
burden
of
2,405
hours.

Some
of
the
requirements
of
the
regulation
are
not
directly
modified
by
the
LCRMR,
but
are
impacted
by
other
LCRMR
provisions.
In
particular,
systems
will
conduct
less
lead
and
copper
tap
and
source
monitoring
under
the
LCRMR.
This
will
potentially
reduce
the
number
of
reports
to
the
State
as
follows:


Reporting
Lead
and
Copper
Monitoring
Results.
Systems
will
submit
fewer
reports
due
to
the
accelerated
reduced
monitoring
and
monitoring
waiver
provisions.
During
1999
through
2001,
systems
are
estimated
to
submit
an
average
of
6,072
fewer
reports
and
would
have
required
1
hour
of
burden
per
report.
This
equals
an
average
annual
reduction
in
reporting
burden
of
6,072
hours.


Reporting
Source
Water
Monitoring
Results.
Systems
will
submit
fewer
reports
due
to
the
provision
that
allows
systems
with
low
source
water
lead
and
copper
levels
to
monitor
for
source
water
less
frequently.
Systems
would
have
required
0.5
hours
per
monitoring
event
to
report
the
results.
During
1999
through
2001,
the
average
annual
burden
reduction
is
estimated
to
be
463
hours.


Reporting
Changes
in
Monitoring
Location.
Due
to
the
reduction
in
the
number
of
monitoring
events,
systems
are
also
expected
to
submit
fewer
reports
that
explain
the
reasons
for
changes
in
lead
and
copper
tap
monitoring
locations.
EPA
estimates
that
50
percent
of
CWSs,
collecting
lead
and
copper
tap
samples,
will
report
a
change
in
monitoring
location
each
year.
During
the
ICR
period,
an
average
of
1,443
CWSs
would
have
reported
a
change.
These
systems
would
have
required
1
hour
per
report.
This
equals
an
average
annual
reduction
in
burden
of
1,443
hours
over
the
three
years.
Note
that
systems
are
also
expected
to
submit
fewer
reports
explaining
reasons
for
changes
in
source
water
monitoring
location,
but
EPA
estimates
that
only
1
percent
of
systems
(
or
an
annual
average
of
9
fewer
systems)
required
to
conduct
source
water
would
report
this
change.
Therefore,
this
burden
reduction
was
not
quantified.

Some
of
the
changes
in
system
reporting
requirements
are
not
assumed
to
have
a
quantifiable
impact
on
burden
as
follows:
June
1999
42

Removal
of
rebuttable
presumptions.
No
burden
impact
is
assumed
regarding
the
elimination
of
the
provision
that
allowed
a
system
to
submit
documentation
that
demonstrated
limited
control
of
a
line.
In
1994,
the
court
vacated
the
Agency's
definition
of
"
control"
except
for
that
portion
owned
by
the
water
system.
EPA
believes
that
few
systems
would
have
replaced
lead
service
lines
in
response
to
the
LCR
prior
to
1994
and
the
lead
service
line
replacement
model
predicts
that
replacement
would
not
begin
until
1997
at
the
earliest.
Therefore,
all
systems
are
assumed
to
have
commenced
lead
service
line
replacement
under
the
narrower
definition
of
control,
eliminating
the
need
to
submit
documentation
that
rebutted
control
of
the
entire
line.


Deletion
of
reference
to
information
on
homeowner
plumbing
from
mandatory
language.
The
Agency
assumes
that
10
percent
of
CWSs
required
to
deliver
public
education
(
337
systems)
will
request
States
to
allow
them
to
remove
reference
to
building
permit
records
from
their
mandatory
public
education
language
because
of
unavailability
of
these
records.
The
burden
to
make
this
request
is
assumed
to
be
offset
by
the
burden
that
would
have
been
incurred
to
respond
to
inquiries
regarding
records
that
the
system
does
not
have.

6(
a)(
ii)
Burden
To
States
The
procedure
for
developing
State
burdens
was
based
on
the
Resource
Analysis
Computer
Program
for
State
Drinking
Water
Agencies
(
i.
e.,
the
State
Resource
Model),
which
is
documented
in
the
Resource
Analysis
Computer
Program
for
State
Drinking
Water
Agencies,
January
1993.
The
model
was
designed
by
OGWDW
and
enables
States
to
estimate
the
resources
needed
to
fund
their
drinking
water
agencies
for
fiscal
years
1993
through
1998
and
to
allow
EPA
to
prepare
national
costs
estimates.
Assumptions
needed
to
be
developed
for
activities
that
occurred
outside
the
model's
time
frame
and
to
include
new
requirements
under
the
LCRMR.

The
model
includes
a
comprehensive
list
of
activities
that
are
required
by
a
State
to
operate
a
drinking
water
program,
estimates
of
the
number
of
systems
impacted,
and
the
estimated
resources
associated
with
each
activity.
The
assumptions
represent
a
national
average
based
on
input
from
a
workgroup
of
39
States,
the
Association
of
State
Drinking
Water
Administrators
(
ASDWA),
and
EPA.

The
State
Resource
Model
calculates
burden
in
terms
of
full­
time
equivalents
(
FTEs)
and
is
based
on
2,080
hours
per
year.
The
State
Resource
Model
applies
overhead
after
the
total
number
of
technical
FTEs
have
been
derived,
including
State
reporting
and
record
keeping
which
are
added
into
the
FTE
calculation.
The
overhead
calculation
is
discussed
in
more
detail
in
section
6(
a)(
ii)(
a).

Figure
6­
2
presents
the
average
State
burden
over
the
three­
year
ICR
period.
Some
of
the
revisions
to
the
LCR
are
expected
to
decrease
State
burden;
others
are
projected
to
increase
it.
The
net
result
of
the
modifications
will
be
an
average
increase
in
State
burden
over
the
three­
year
ICR
period
of
50,055
hours
per
year.
The
main
reason
for
this
increase
is
due
to
"
start­
up
activities"
such
as
regulatory
adoption,
training,
and
the
reporting
of
the
new
"
Done"
and
"
Deemed"
milestones.
As
shown
in
Appendix
B
of
this
document,
the
increase
to
State
burden
over
the
out­
years
of
2002
through
2009
for
all
activities
is
estimated
to
be
an
average
of
2,333
hours.
The
estimated
burden
impact
for
each
of
the
LCRMR
provisions
is
discussed
in
more
detail
following
the
table.
June
1999
43
Figure
6­
2:
Change
in
Annual
State
Burden
for
1999
through
2001
due
to
LCRMR
(
in
hours)

Activity
Average
Burden
Overhead
8,029
Notify
systems
of
requirements
3,771
Initial
Activities
Regulation
adoption
9,707
Train
staff
7,000
Modify
the
data
system
14,976
Review
of
Lead
and
Copper
Tap
and
WQP
Monitoring
Data
and
Related
Information
Review
of
monitoring
results
for
(
b)(
3)
systems
57
Request
use
of
non­
first­
draw
samples
250
Specify
reduced
monitoring
sites
1,642
Accelerated
lead
and
copper
monitoring
­
1,807
Monitoring
waivers
(
review
of
applications
&
less
monitoring
data)
­
1,135
Accelerated
reduced
WQP
tap
monitoring
0
WQP
monitoring
at
representative
entry
points
66
State
flexibility
to
calculate
90th
percentile
level
2,077
Changes
in
treatment
or
addition
of
new
source
264
Review
of
compliance
with
optimal
WQP
levels
1,740
Review
of
reasons
for
changes
in
lead
and
copper
tap
monitoring
location
­
241
Source
Water
Monitoring
Requirements
Reduced
source
water
monitoring
for
PWSs
w/
o
MPLs
­
463
Public
Education
Review
of
public
education
compliance
letters
129
Request
to
remove
reference
to
building
permit
record
availability
from
mandatory
language
56
Lead
Service
Line
Replacement
(
LSLR)

Review
of
compliance
letter
for
partial
LSLR
requirements
2,405
June
1999
Figure
6­
2:
Change
in
Annual
State
Burden
for
1999
through
2001
due
to
LCRMR
(
in
hours)

Activity
Average
Burden
44
Enforcement
­
3,539
June
1999
Figure
6­
2:
Change
in
Annual
State
Burden
for
1999
through
2001
due
to
LCRMR
(
in
hours)

Activity
Average
Burden
45
Revisions
to
State
Reporting
Requirements
Report
90th
percentile
lead
levels
for
large
and
medium
PWSs
1,403
Modify
milestones/
delete
requirement
to
report
compliance
with
LSLR
schedule
15,724
Changes
in
violation
and
enforcement
reporting
­
4,167
Reporting
to
State
data
base
(
Record
Keeping)
­
7,889
TOTAL
50,055
6(
a)(
ii)(
a)
Overhead
Overhead
includes
supervisory
staff
and
clerical
staff
to
support
the
LCRMR,
and
annual
nonrule
specific
training
for
all
staff
involved
in
the
implementation/
oversight
of
the
rule
(
including
supervisory
and
clerical
staff).
Overhead
is
determined
by
first
estimating
the
number
of
technical
FTEs
nationally
from
all
the
State
models
(
oversight,
reporting,
record
keeping)
and
applying
the
following
percentages:

Supervision
10%
Clerical
11%
On­
going
Training
for
State
personnel
1.9%
(
5
days
per
FTE)

As
an
example,
if
100
technical
FTEs
were
needed
in
X
year,
then
10
supervisors,
11
clerical
staff,
and
1.9
FTEs
worth
of
training
or
a
total
of
22.9
FTEs
in
overhead
would
be
needed
to
support
the
LCRMR.
For
1999
through
2001,
the
overhead
is
estimated
to
average
8,029
hours
per
year.
The
amount
of
overhead
greatly
fluctuates
from
year
to
year
due
to
changes
in
the
number
of
technical
FTEs
estimated
over
time.
These
fluctuations
correspond
primarily
to
start­
up
activities
and
the
lead
and
copper
monitoring
cycles.

6(
a)(
ii)(
b)
Notify
Systems
of
Requirements
The
1991
ICR
assumed
that
$
1.0
million
would
be
required
to
notify
systems
of
the
original
rule
requirements
and
$
0.7
million
to
notify
systems
of
the
requirements,
thereafter.
The
Agency
estimates
States
will
also
require
$
1.0
million
to
notify
systems
of
the
LCRMR
requirements
in
1999
and
$
0.7
million
thereafter.
The
1991
ICR
assumed
a
work­
year
of
1,920
hours
per
year
per
FTE
and
$
50,000
per
year
(
fully
burdened
cost)
or
an
average
hourly
rate
of
$
26.04.
Based
on
these
assumptions,
the
$
1.0
million
equals
approximately
674
hours
per
State
($
1.0
million
/$
26.04/
57
respondents)
and
$
0.7
million
June
1999
50
The
State
estimates
presented
in
the
1991
LCR
ICR
and
Drinking
Water
ICR
were
based
on
57
State
respondents.
Since
the
1991
ICR
was
prepared,
the
number
of
U.
S.
Territories
has
dropped
to
6,
resulting
in
a
total
of
56
State
respondents.

51
SDWIS/
State
is
a
data
base
that
is
currently
being
developed
by
EPA
for
use
by
the
States
to
track
compliance
with
the
drinking
water
regulations.
It
is
scheduled
to
be
completed
in
2000.
Approximately
20
States
are
anticipated
to
use
SDWIS/
State
to
manage
their
LCR
tracking.

46
equals
approximately
472
hours
per
State
($
0.7
million
/$
26.04/
57
respondents).
50
The
net
increase
to
States
resulting
from
the
LCRMR
will
be
an
increase
in
1999
of
202
hours
per
State
(
i.
e.,
674
hours
­
472
hours)
or
a
total
of
11,312
hours.
Expressed
as
a
three­
year
average,
States
will
incur
an
average
increase
in
burden
of
3,771
hours.

6(
a)(
ii)(
c)
Initial
Activities
During
the
1999
through
2001
time
frame,
States
will
adopt
the
regulation,
learn
the
new
requirements,
and
modify
the
State
data
system
to
allow
automated
reporting
of
the
new
milestones
to
SDWIS.
These
activities
are
assumed
to
be
"
start­
up"
activities
and
to
occur
in
the
three­
year
ICR
period
only.
Each
of
these
activities
is
discussed
in
more
detail
below.


Regulatory
Adoption.
Each
State
is
assumed
to
require
0.25
FTEs
(
520
hours)
in
1999
for
adoption
of
the
LCRMR.
This
equals
a
total
burden
of
29,120
hours
or
an
average
of
9,707
hours
over
the
three
years.


Training.
Each
State
is
assumed
to
require
a
total
of
375
hours
of
training
on
the
LCRMR
in
1999.
EPA
assumed
that
States
would
require
50
percent
less
time
to
become
familiar
with
the
requirements
of
the
LCRMR
than
the
1991
LCR.
The
initial
burden
to
review
the
LCR
was
derived
from
Table
10
of
the
ICR
for
the
original
LCR.
The
1991
ICR
assumed
that
$
1.1
million
would
be
required
to
train
staff.
Based
on
the
1991
State
hourly
rate
of
$
26.04
and
57
respondents,
the
$
1.1
million
equals
approximately
42,240
hours
or
741
hours
per
system
($
1.1
million
/$
26.04/
57
respondents).
Assuming
50
percent
of
this
effort
is
needed
to
learn
the
LCRMR
requirements,
each
State
would
require
about
375
hours
of
training.
Over
1999
through
2001,
this
will
result
in
an
average
increase
in
burden
of
7,000
hours.


Modify
the
State
data
system
to
accommodate
new
requirements.
The
Agency
assumes
that
36
of
the
56
States
will
modify
their
existing
data
system
to
accommodate
the
new
"
Done"
and
"
Deemed"
milestone
and
will
require
0.6
FTEs
(
1,248
hours)
and
contractor
support
to
complete
this
effort.
This
equals
an
average
annual
burden
of
14,976
hours.
The
remaining
20
States
will
use
SDWIS/
State
as
their
data
system.
51
The
burden
and
cost
to
modify
SDWIS/
State
will
be
incurred
by
EPA
and
is
discussed
in
more
detail
in
Section
6(
c).

6(
a)(
ii)(
d)
Review
of
Lead
and
Copper
Tap
and
WQP
Monitoring
Data
and
Related
Information
June
1999
52
Systems
serving
100
or
fewer
people
can
only
reduce
the
frequency
of
their
lead
and
copper
tap
monitoring
collection
but
not
the
number
of
samples.
These
systems
must
collect
5
samples
whether
they
are
on
standard
or
reduced
monitoring.

47
Overall
States
are
estimated
to
incur
an
average
annual
increase
in
burden
associated
with
the
review
of
lead
and
copper
tap
and
WQP
monitoring
data,
and
other
related
information
of
2,913
hours.
The
reasons
for
this
increase
are
discussed
in
more
detail
below.


Review
of
monitoring
results
for
(
b)(
3)
systems.
Under
the
LCRMR,
States
are
assumed
to
review
lead
and
copper
data
for
the
171
large
(
b)(
3)
systems.
These
systems
will
monitor
once
during
the
three­
year
ICR
period
and
submit
an
average
of
57
sets
of
results
and
supporting
documentation.
States
are
assumed
to
require
1
hour
to
review
this
information.
Over
the
ICR
period,
this
will
equal
a
burden
increase
of
57
hours
per
year.


Request
use
of
non­
first­
draw
samples.
The
Agency
assumes
that
a
total
of
1,000
systems
will
provide
documentation
to
the
State
that
supports
the
need
for
the
systems
to
collect
non­
first­
draw
samples.
Fifty
percent
of
the
States
are
assumed
to
review
and
approve
this
monitoring
prior
to
its
start
and
would
require
1
hour
per
system.
The
other
50
percent
are
assumed
to
review
this
information
with
the
sample
results
and
to
require
0.5
hours
to
review
the
justification.
Therefore,
an
average
of
45
minutes
per
system
was
used
in
this
calculation.
This
translates
to
a
total
burden
of
750
hours
or
an
average
of
250
hours.


Specify
reduced
monitoring
sites.
The
Agency
assumes
that
States
would
designate
reduced
sampling
sites
for
9,847
systems
in
total
(
i.
e.,
20%
of
the
49,239
systems
serving
>
100
people).
52
States
are
also
assumed
to
require
0.5
hours
per
system
to
complete
this
activity.
This
equals
an
average
annual
burden
increase
of
1,642
hours.


Accelerated
reduced
monitoring.
States
are
estimated
to
review
fewer
rounds
of
monitoring
at
an
average
burden
of
1
hour
per
monitoring
event.
The
average
burden
reduction
for
1999
through
2001
is
estimated
to
be
1,807
hours.


Monitoring
waivers.
State
will
experience
an
overall
reduction
in
burden
associated
with
this
provision.
States
will
incur
a
burden
for
reviewing
and
replying
to
each
waiver
request.
States
are
assumed
to
require
0.5
hours
to
review
these
applications.
The
model
estimates
that
6,809
systems
will
apply
for
a
waiver
in
1999.
States
will
spend
an
estimated
3,405
hours
for
this
effort
or
an
average
of
1,135
hours
over
the
three
years,
but
will
experience
an
annual
reduction
in
burden
associated
with
the
review
of
less
data
of
2,270
hours.
The
net
average
annual
burden
reduction
for
1999
through
2001
is
estimated
to
be
1,135.


WQP
tap
monitoring
at
representative
entry
points
by
ground
water
systems.
States
are
assumed
to
spend
0.5
hours
reviewing
a
system's
request
to
limit
entry
point
monitoring
to
representative
sites.
A
total
of
397
systems
is
expected
to
make
this
request.
This
equals
a
total
burden
of
199
hours
or
an
average
of
66
hours
over
the
three
years.
The
procedure
June
1999
48
for
estimating
State
burden
and
cost
associated
with
the
review
of
WQP
monitoring
data
is
to
assume
that
the
State
requires
3.42
hours
per
6­
month
monitoring
period
to
conduct
this
review.
No
reduction
in
burden
or
cost
is
assumed
because
the
revision
does
not
change
the
number
of
WQP
entry
point
monitoring
events.


State
flexibility
to
calculate
90th
percentile
levels.
Based
on
data
verification
reviews
conducted
in
State
drinking
water
offices,
the
Agency
estimates
that
approximately
50
percent
of
the
States
will
calculate
the
90th
percentile
levels
for
the
systems.
As
a
simplifying
assumption,
the
number
of
systems
are
assumed
to
be
evenly
distributed
among
the
States
and
therefore,
this
calculation
will
be
performed
for
half
of
the
systems.
The
State
burden
associated
with
determining
the
90th
percentile
lead
and
copper
values
is
assumed
to
be
10
minutes
to
2
hours.
This
equals
an
average
annual
burden
increase
of
2,077
hours
over
the
three­
year
ICR
period.
The
actual
additional
burden
to
States
may
be
negligible
because
many
States
already
perform
or
validate
this
calculation.


Changes
in
treatment
or
addition
of
a
new
source
for
systems
on
reduced
monitoring.
States
are
assumed
to
require
0.5
hours
to
review
documentation
explaining
changes
in
treatment
or
an
addition
of
a
new
source
and
to
determine
whether
additional
action
by
the
system
is
needed.
EPA
assumes
in
most
cases
that
States
will
not
require
systems
to
take
additional
action.
Two
percent
of
systems
per
year
that
collect
lead
and
copper
tap
samples
on
a
reduced
schedule
are
assumed
to
report
a
change
in
treatment
or
an
addition
of
a
new
source.
During
the
1999
­
2001
time
period,
systems
will
submit
an
average
of
527
reports
per
year.
The
burden
associated
with
this
review
averages
264
hours
over
the
three
years.


Review
of
compliance
with
optimal
WQPs.
States
are
assumed
to
require
an
average
of
6.83
hours
per
system
per
year
to
review
compliance
with
OWQPs
using
the
revised
criteria
for
OWQP
compliance.
This
translates
to
an
extra
10
minutes
per
report.
Over
the
three­
year
ICR
period,
States
will
review
an
average
of
10,493
reports
per
year
and
will
incur
an
average
of
1,740
additional
hours
to
assess
compliance.
Although,
the
new
criteria
to
assess
compliance
is
projected
to
increase
burden,
the
new
compliance
criteria
is
expected
to
reduce
the
number
of
treatment
technique
violations
and
associated
enforcement
actions,
and
could
result
in
fewer
systems
being
triggered
back
into
standard
lead
and
copper
tap
monitoring.
These
burden
reductions
are
discussed
below
under
the
sections
6(
a)(
ii)(
h)
and
6(
a)(
ii)(
i).


Review
of
reasons
for
changes
in
lead
and
copper
tap
monitoring
location.
States
are
also
expected
to
experience
burden
reductions
in
areas
that
have
not
been
directly
revised
by
LCRMR.
One
of
these
is
the
review
of
reasons
for
changes
in
lead
and
copper
tap
monitoring
location.
Fewer
letters
are
expected
to
be
submitted
by
systems
because
there
are
fewer
monitoring
events
due
to
monitoring
waivers
and
accelerated
reduced
lead
and
copper
monitoring.
The
model
assumes
that
50
percent
of
CWSs,
conducting
lead
and
copper
tap
monitoring,
will
submit
letters
explaining
the
need
to
change
monitoring
locations.
NTNCWSs
are
assumed
to
control
access
to
their
monitoring
locations
and
not
to
submit
such
explanations.
During
1999
through
2001,
States
are
estimated
to
review
a
June
1999
49
total
of
4,331
fewer
letters
explaining
reasons
for
changes
in
lead
and
copper
tap
monitoring
location.
States
would
have
required
10
minutes
to
review
these
explanations.
This
translates
to
an
average
burden
reduction
of
241
hours.

Some
of
the
lead
and
copper
tap­
and
WQP­
related
revisions
are
not
expected
to
have
a
quantifiable
impact
on
State
burden
or
are
captured
under
other
activities.
These
provisions
are
discussed
in
more
detail
below:


Meet
copper
action
level
for
(
b)(
3)
systems.
This
revision
is
not
expected
to
have
a
quantifiable
impact
on
State
oversight,
reporting,
or
record
keeping
burden
because
EPA
assumes
that
few
of
the
estimated
171
(
b)(
3)
systems
will
exceed
the
copper
action
level
and
be
triggered
into
increased
monitoring
or
be
required
to
install
corrosion
control
treatment.


Designation
of
alternative
monitoring
schedule
for
systems
on
reduced
monitoring.
EPA
assumes
that
States
will
make
blanket
decisions
regarding
which
systems
should
conduct
reduced
monitoring
in
months
other
than
June
­
September.
EPA
also
assumes
that
States
will
have
a
data
base
that
will
allow
them
to
easily
identify
seasonal
NTNCWSs
that
do
not
operate
during
the
summer
months.
States
are
assumed
to
incorporate
their
policy
into
their
regulation
or
to
provide
a
form
letter
to
the
systems.
This
burden
is
assumed
to
be
captured
under
the
burden
to
adopt
the
regulation
or
to
notify
the
system
of
requirements.


Requests
for
reduced
monitoring
for
PWSs
meeting
optimal
WQPs.
No
burden
reduction
is
assumed
for
States
to
no
longer
review
requests
from
systems
meeting
their
OWQPs
to
be
placed
on
reduced
monitoring.
States
are
still
required
to
determine
whether
such
systems
qualify
for
reduced
monitoring
and
to
notify
the
systems
in
writing
of
these
determinations.


Sample
Invalidation.
EPA
that
less
than
0.5
percent
of
systems
each
monitorng
period
(
about
380
systems)
will
seek
to
have
samples
invalidated.
EPA
assumes
that
States
will
need
0.5
hours
to
review
these
submissions.
EPA
also
anticipates
that
some
systems
will
be
able
to
avoid
the
burden
associated
with
increased
monitoring
or
the
installation
of
treatment,
and
that
States
will
avoid
the
oversight,
reporting,
and
record
keeping
burden
associated
with
these
activities.
The
Agency,
therefore,
estimates
no
net
change
in
burden
resulting
from
this
provision.


Accelerated
reduced
WQP
tap
monitoring.
States
must
review
both
tap
and
entry
point
WQP
results
to
assess
compliance.
The
accelerated
reduced
WQP
tap
monitoring
provision
does
not
impact
the
number
of
entry
point
monitoring
events,
which
constitutes
most
of
the
WQP
monitoring
data.
Therefore,
no
quantifiable
impact
on
States
is
expected.


Sample
certification
and
justifications.
Under
the
LCRMR,
States
will
no
longer
be
required
to
review
a
system's
justification
explaining
why
its
sampling
pool
contained
insufficient
Tier
1
sites
or
sites
served
by
lead
service
lines
or
certifications
that
a
sample
June
1999
50
is
first­
draw
or
was
collected
properly
by
the
homeowner.
The
Agency
assumes
the
burden
to
review
these
justifications
to
be
negligible
and
assumes
there
to
be
no
quantifiable
State
burden
resulting
from
this
revision.

6(
a)(
ii)(
e)
Source
Water
Monitoring
States
will
review
less
source
water
monitoring
data
for
the
5,384
systems
that
are
now
expected
to
be
eligible
for
reduced
source
water
monitoring.
During
the
1999
through
2001
time
frame,
an
average
of
926
of
these
systems
would
have
submitted
source
water
monitoring
results
during
each
of
the
three
years.
States
are
assumed
to
save
0.5
hours
per
monitoring
event
and
incur
an
average
reduction
in
burden
of
463
hours
over
the
1999
through
2001
time
period.

6(
a)(
ii)(
f)
Public
Education

Change
in
reporting
deadline.
Due
to
the
change
in
the
deadline
for
reporting
compliance
with
public
education
requirements,
medium
and
large
systems
are
expected
to
submit
one
additional
report
each
year.
Under
the
LCRMR,
small
systems
are
no
longer
required
to
deliver
public
service
announcements
and
therefore,
would
continue
to
submit
only
one
report
(
public
service
announcements
are
required
every
six
months).
By
1999,
only
those
systems
continuing
to
exceed
after
treatment
are
expected
to
be
delivering
public
education
materials.
A
total
of
397
medium
and
large
systems
are
estimated
to
submit
one
additional
reports
each
year.
States
are
assumed
to
require
20
minutes
to
review
each
letter.
This
translates
to
an
average
increase
in
burden
of
129
hours.


Deletion
of
reference
to
information
on
building
permit
record
availability
from
mandatory
language.
States
are
assumed
to
incur
a
one­
time
burden
in
2000
to
review
requests
from
10
percent
of
CWSs
required
to
deliver
public
education
(
337
systems)
to
remove
reference
building
permit
record
availability
from
their
mandatory
public
education
language.
States
are
assumed
to
require
0.5
hours
to
review
these
requests.
This
equals
an
average
annual
burden
of
56
hours
per
year.


Public
education
provisions
for
which
no
burden
is
quantified.
The
following
revisions
to
the
public
education
provisions
are
not
expected
to
have
a
quantifiable
impact
on
State
burden
because
States
are
assumed
to
identify
in
their
regulations
when
and
to
which
systems
such
provisions
apply,
as
follows:

S
Use
of
alternative
mandatory
language
for
NTNCWSs
and
special
CWSs;

S
Removal
of
reference
to
lead
service
lines
from
the
mandatory
language;
and,

S
NTNCWSs
use
of
e­
mail
to
distribute
public
education
information.

In
addition,
the
Agency
could
not
quantify
the
burden
to
States
to
allow
systems
to
no
longer
include
a
distribution
list
as
part
of
their
public
education
compliance
letter,
in
those
instances
where
systems
have
not
made
changes
to
this
list.
However,
the
Agency
does
June
1999
51
anticipate
some
change
in
record
keeping
burden
for
the
State
to
track
to
which
systems
this
provision
applies.

6(
a)(
ii)(
g)
Lead
Service
Line
Replacement

Review
of
Partial
Lead
Service
Line
Compliance
Letters.
Based
on
comments
received
on
the
April
1998
Notice
of
Data
Availability,
EPA
assumes
that
75
percent
of
the
States
will
require
those
systems
replacing
lead
service
lines
to
submit
information
that
demonstrates
compliance
with
partial
lead
service
line
monitoring
and
notification
requirements.
As
a
simplifying
assumption,
the
number
of
systems
are
assumed
to
be
evenly
distributed
among
States
and
therefore,
this
provision
will
impact
75
percent
of
systems.
States
are
also
assumed
to
review
an
average
of
4,809
letters
during
the
threeyear
ICR
period
and
to
require
0.5
hours
to
review
each
letter.
This
equals
an
average
annual
burden
of
2,405
hours.


Flexibility
to
Allow
Shorter
Notification
Period.
States
have
the
discretion
to
allow
less
than
a
45­
day
advance
notice
in
those
instances
where
the
partial
replacement
is
being
performed
in
conjunction
with
emergency
repairs.
EPA
assumes
that
States
electing
to
exercise
this
flexibility
will
incorporate
this
provision
into
their
regulations
versus
making
case­
by­
case
decisions.
This
burden
is
assumed
to
be
covered
in
0.25
FTEs
needed
for
regulatory
adoption.

6(
a)(
ii)(
h)
Enforcement
A
decrease
in
the
number
of
violations
is
expected
in
some
years
due
to
a
reduction
in
the
amount
of
monitoring
and
changes
in
criteria
for
determining
compliance
with
OWQPs.
A
notice
of
violation
(
NOV)
is
assumed
to
be
issued
for
each
system
in
violation.
States
are
assumed
to
use
form
letters
and
to
require
1
hour
of
burden
to
prepare
and
send
each
NOV.
This
equals
an
average
annual
reduction
in
burden
of
3,539
hours
over
the
three
years.

6(
a)(
ii)(
i)
State
Reporting
The
major
revisions
to
the
State
reporting
requirements
that
impact
burden
during
the
ICR
period
are
the
addition
of
a
"
Done"
and
"
Deemed"
milestone,
the
elimination
of
the
lead
service
line
compliance
letter,
and
the
requirement
for
States
to
report
all
lead
90th
percentile
values
for
large
and
medium
systems.
In
addition,
as
mentioned
above,
the
number
of
violations
are
assumed
to
decline
during
some
years,
and
will
result
in
a
corresponding
decrease
in
the
number
of
violations
and
enforcement
actions
reported
by
the
State.
Each
of
the
burden
impacts
are
discussed
in
more
detail
below

Report
all
90th
percentile
lead
levels
for
all
large
and
medium
systems.
The
LCRMR
require
the
reporting
of
all
90th
lead
percentile
values
for
large
and
medium
systems.
States
are
assumed
to
require
0.5
hours
to
report
each
90th
percentile
lead
value
to
SDWIS.
Based
on
the
number
of
systems
projected
to
monitor
for
lead
and
copper,
but
be
below
the
lead
action
level,
EPA
estimates
that
States
will
incur
an
average
added
burden
of
1,403
hours
during
the
1999
through
2001
time
period.
June
1999
53
The
LCRMR
also
eliminate
the
reporting
of
the
milestones
that
indicate
for
which
systems
the
States
have
required
a
corrosion
control
study,
designated
optimal
corrosion
control
treatment,
designated
source
water
treatment,
set
MPLs,
and
those
systems
that
have
completed
their
corrosion
control
study,
and
have
installed
source
water
treatment.
EPA
assumes
that
this
information
would
have
already
been
reported
to
SDWIS
by
1999
and
therefore,
no
burden
reduction
is
estimated
for
the
elimination
of
these
milestones.

52

Changes
to
milestone
reporting
and
deletion
of
LSLR
compliance
letter.
The
LCRMR
eliminate
several
of
the
interim
milestones,
including
the
milestone
that
denotes
when
the
State
has
set
OWQP
ranges
or
limits
(
i.
e.,
WQPS
milestone);
require
the
reporting
of
a
new
"
Done"
and
"
Deemed"
milestone;
and
eliminate
the
requirement
for
States
to
submit
a
separate
report
that
documents
each
system
that
is
in
compliance
with
its
lead
service
line
replacement
schedule.
53
Under
the
LCRMR,
States
will
still
be
required
to
report
the
milestone
that
denotes
those
systems
that
must
begin
lead
service
line
replacement
(
i.
e.,
LSLR
milestone).
During
the
3­
year
ICR
period,
EPA
estimates
that
States
will
no
longer
be
required
to
report
WQPS
milestone
for
5,218
systems
at
a
burden
of
0.5
hours
per
year.
This
translates
to
an
annual
reduction
in
burden
of
870
hours.
In
addition,
each
State
is
assumed
to
no
longer
submit
two
lead
service
line
replacement
reports
per
year;
one
that
summarizes
compliance
for
systems
on
a
January
through
December
replacement
schedule,
and
a
second
for
those
systems
on
a
July
through
June
replacement
schedule.
Systems
are
estimated
to
have
required
2
hours
to
prepare
and
submit
each
report.
The
reduction
in
burden
associated
with
the
elimination
of
the
lead
service
line
replacement
compliance
report
is
an
average
of
224
hours
per
year.

EPA
also
estimates
that
States
will
report
the
"
Deemed"
milestone
for
all
75,945
systems
sometime
in
the
2000
through
2001
time
frame.
The
"
Done"
milestone
is
also
assumed
to
be
reported
during
these
two
years
for
all
75,813
systems
that
are
not
required
to
replace
lead
service
lines.
Those
systems
are
not
expected
to
be
"
done"
until
sometime
outside
the
2009
time
frame.
States
will
incur
a
burden
of
0.5
hours
per
milestone,
except
when
the
"
Done"
and
"
Deemed
milestones
or
"
Deemed"
and
LSLR
milestones
can
be
reported
during
the
same
period
for
a
given
system.
In
those
instances,
the
combined
burden
for
the
two
milestones
is
40
minutes.
During
this
three­
year
ICR
period,
States
will
incur
a
total
burden
of
50,454
hours
to
report
these
milestones
or
an
annual
average
of
16,818
hours
over
the
three
years.

The
overall
impact
of
the
revisions
to
the
State
milestone
reporting
requirements
is
an
average
annual
increase
of
15,724
hours.
During
the
out­
years
of
2002
through
2009,
States
are
expected
to
incur
a
reduction
in
milestone
reporting
burden
of
224
hours
per
year.


Changes
in
violation
and
enforcement
reporting.
States
are
projected
to
report
fewer
violations
and
enforcement
actions
due
a
reduction
in
the
amount
of
monitoring
required
under
the
LCRMR
and
from
revisions
to
the
criteria
for
determining
compliance
with
OWQPs.
States
would
have
required
0.5
hours
to
enter
violation
information
into
SDWIS
and
another
0.5
hours
to
enter
related
enforcement
information.
The
Agency
anticipates
June
1999
54
The
junior
and
chemist
labor
rates
are
Bureau
of
Labor
Statistics
March
1998
estimates.
The
labor
rates
for
a
trained
operated
are
based
on
a
discussion
summary
of
the
EPA
Technology
Design
Workshop,
held
on
November
6
and
7,
1997
in
Denver,
Colorado.

53
that
States
will
realize
an
average
annual
reduction
in
burden
of
4,167
hours
during
1999
through
2001.

6(
a)(
ii)(
j)
Record
Keeping
States
are
assumed
to
maintain
a
subset
of
data
in
their
data
bases
that
includes:
90th
percentile
lead
and
copper
values,
reduced
monitoring
schedules,
milestones,
OWQP
values
or
ranges,
MPLs,
violations,
and
enforcement
actions.
The
Agency
estimates
a
burden
of
0.5
hours
is
needed
to
report
each
system­
specific
record
to
the
State
data
base.
The
estimated
average
burden
reduction
over
the
3
years
is
7,889
hours.
This
burden
reduction
is
due
to
the
overall
decrease
in
the
amount
of
monitoring
and
expected
decrease
in
violation
rate
under
the
LCRMR.
The
States
are
also
assumed
to
maintain
paper
copies
of
a
larger
set
of
data.
(
Refer
to
Appendix
A
for
this
list.)
The
burden
associated
with
maintaining
paper
files
is
captured
under
overhead
(
i.
e.,
clerical
staff).

6(
b)
Estimating
Respondent
Costs
This
section
discusses
the
Agency's
procedure
for
estimating
system
and
State
costs.
Sections
6(
b)(
i)
and
6(
b)(
ii)
pertain
to
system
and
State
costs,
respectively.
For
each
respondent
type,
a
distinction
is
made
between
labor
and
non­
labor
costs.

6(
b)(
i)
Costs
To
Public
Water
Systems
EPA
estimates
that
the
annual
cost
to
PWSs
for
these
modifications
will
decrease
by
an
average
of
$
2,823,900
each
year
over
1999
through
2001.
EPA
estimates
that
non­
labor
costs
comprise
$
1,933,300
(
about
69
percent)
of
this
cost
reduction.
These
costs
correspond
to
the
purchase
of
reagents
to
analyze
samples,
buying
preprinted
public
education
materials,
and
mailing
costs
to
submit
reports
to
the
State
and
to
mail
public
education
materials
to
people/
facilities
served
by
the
system.

6(
b)(
i)(
a)
Estimating
Labor
Costs
for
Water
Systems
The
Agency
applied
an
average
labor
rate
that
is
dependent
on
system
size
and
whether
the
respondent
activity
involved
the
collection
and
analysis
of
samples
as
follows:


Sample
Collection
and
Analysis.
For
monitoring
and
analytical
activities,
the
Agency
assumed
a
labor
mix
of
junior
(
non­
specialized)
labor,
chemist
labor,
and
a
trained
operator/
senior
staff
as
follows:
33
percent
of
the
labor
was
assumed
to
be
chemist
time
at
a
rate
of
$
22.69;
7
percent
was
assumed
to
be
management
time
at
a
rate
of
$
28
for
systems
serving
3,300
or
fewer
people)
and
$
52
for
systems
serving
more
than
3,300
people;
and
60
percent
to
be
non­
specialized
labor
at
a
rate
of
$
12.77.
54
This
translates
to
an
average
hourly
labor
rate
for
monitoring
activities
of
$
17.11
for
small
systems
and
$
18.79
for
medium
and
large
systems,
as
shown
below:
June
1999
54
Small
(<
3,300)
=
($
12.77
*
0.60)
+
($
28.00
*
0.07)
+
($
22.69
*
0.33)
=
$
17.11.
Medium/
Large
=
($
12.77
*
0.60)
+
($
52.00
*
0.07)
+
($
22.69
*
0.33)
=
$
18.79

Non­
Monitoring
Activities.
The
hourly
labor
rate
for
activities
that
did
not
involve
sample
collection
and
analyses,
were
based
on
a
90
percent
junior
and
10
percent
senior
labor
mix.
The
same
labor
rates
as
discussed
above
were
applied.
The
average
small
system
labor
rate
is
$
14.29
and
$
16.69
for
medium
and
large
systems,
as
shown
below:

Small
(<
3,300)
=
($
12.77
*
0.90)
+
($
28.00
*
0.10)
=
$
14.29
Medium/
Large
=
($
12.77
*
0.90)
+
($
52.00
*
0.10)
=
$
16.69
6(
b)(
i)(
b)
Estimating
Non­
Labor
Costs
for
Water
Systems
All
of
the
non­
labor
cost
savings
are
attributed
to
the
reduction
in
the
number
of
samples
to
be
analyzed
each
year.
Estimates
of
analytical
costs
were
based
on
current
industry
prices.
The
analysis
for
lead
and
copper
were
adjusted
to
eliminate
the
labor
component
to
avoid
double
counting
because
all
analyses
are
assumed
to
be
performed
in­
house.
For
example,
an
outside
laboratory
charges
$
30
for
the
analysis
of
lead
and
copper
tap
samples.
This
analysis
is
assumed
to
require
one
hour
of
a
chemist's
time
to
perform
the
analysis.
The
analytical
cost
of
$
7.31
is
used
(
i.
e.,
$
30
­
$
22.69).
The
specific
analytical
costs
are
presented
in
Figure
6­
3
below.

Figure
6­
3:
Analytical
Costs
(
Assumes
analysis
conducted
by
systems)

Column
A
Column
B
Column
C
Column
D
Type
of
Analysis
Analytical
Cost
Labor
Cost
(
burden
*
chemist
rate
of
$
22.69/
hour)
Net
Cost
Used
in
Calculation
(
Column
B
­
Column
C)

Lead
and/
or
Copper
(
analytical
cost
based
on
survey
of
laboratories)

Lead
and
Copper
(
at
the
tap
and
source
water)
$
30a
$
22.69
$
7.31
Lead
only
(
LSL
monitoring)
$
15b
$
11.35
$
3.65
WQPs
(
analytical
cost
based
on
1991
LCR
ICR)

Tap
(
initial)
$
51c
N/
A
$
51
Tap
(
post­
initial)
$
40d
N/
A
$
40
Entry
point
$
25e
N/
A
$
25
a
Includes
the
analysis
of
both
lead
and
copper.
b
Includes
the
analysis
of
lead
only.
c
Includes
the
analysis
of
pH,
alkalinity,
orthophosphate
(
if
applicable),
silica
(
if
applicable),
calcium,
conductivity,
and
temperature.
June
1999
55
Systems
do
not
need
to
purchase
new
laboratory
equipment,
in­
line
meters,
or
computers
in
response
to
the
LCRMR.

55
d
Includes
the
analysis
of
pH,
alkalinity,
orthophosphate
(
if
applicable),
silica
(
if
applicable),
and
calcium.
e
Includes
the
analysis
of
alkalinity.
The
pH
and
corrosion
inhibitor
are
assumed
to
be
read
by
an
in­
line
meter.

The
remainder
of
the
non­
labor
costs
are
due
to
postage
costs
of
$
0.33
for
systems
to
submit
reports
to
the
State
and
to
send
public
education
materials
to
consumers,
and
to
purchase
of
pre­
printed
public
education
materials.
No
capital/
start­
up
costs
are
incurred
as
a
result
of
the
LCRMR.
55
Figure
6­
4
below
contains
the
change
in
system
cost
resulting
from
the
LCRMR
(
i.
e.,
LCRMR
cost
minus
the
revised
baseline
costs),
averaged
over
1999
through
2001.

Figure
6­
4:
Change
in
Annual
System
Cost
for
1999
through
2001
due
to
LCRMR
(
in
$
1,000'
s)

Activity
Labor
Cost
Non­
Labor
Cost
Total
Average
Cost
Initial
Activities
Read
regulations
and
train
staff
2,944.3
0.0
2,944.3
Tap
and
WQP
Monitoring
Requirements
(
b)(
3)
system
monitoring
149.7
16.7
166.4
Alternative
schedule
for
systems
on
reduced
monitoring
­
24.5
0
­
24.5
Accelerated
lead
and
copper
monitoring
­
578.4
­
500.7
­
1079.1
Monitoring
waivers
­
815.8
­
102.8
­
918.6
Accelerated
WQP
monitoring
­
93.0
­
99.0
­
192.0
Entry
point
monitoring
at
representative
sites
­
761.7
­
1,129.8
­
1,891.5
Source
Water
Monitoring
Requirements
Reduced
source
water
monitoring
for
PWSs
w/
o
MPLs
­
25.1
­
10.1
­
35.2
Public
Education
Delivery
of
public
education
materials
­
85.3
­
5.9
­
91.2
Lead
Service
Line
Monitoring
and
Notification
Requirements
Partial
lead
service
line
monitoring
­
1,460.7
­
114.9
­
1575.6
Partial
lead
service
line
notification
158.0
12.8
170.8
June
1999
Figure
6­
4:
Change
in
Annual
System
Cost
for
1999
through
2001
due
to
LCRMR
(
in
$
1,000'
s)

Activity
Labor
Cost
Non­
Labor
Cost
Total
Average
Cost
56
This
rate
is
the
mean
Technical
labor
rate
based
on
a
draft
analysis
of
a
recent
ASDWA
survey
that
was
completed
by
37
States.

56
Revisions
to
System
Reporting
Requirements
Eliminate
first­
draw/
customer­
collected
certifications
­
80.8
0.0
­
80.8
Eliminate
sample
site
justifications
­
29.6
0.0
­
29.6
Remove
request
for
reduced
monitoring
­
33.1
0.0
­
33.1
State
flexibility
to
calculate
90th
percentile
values
­
136.9
0.0
­
136.9
Report
changes
in
treatment
or
addition
of
new
source
3.8
0.2
4.0
Evaluate/
report
WQPs
using
new
compliance
criteria
51.0
0.1
51.1
Change
public
education
reporting
deadline
6.5
0.1
6.6
Report
compliance
with
partial
LSL
replacement
requirements
35.7
1.6
37.3
Impacts
resulting
from
changes
in
other
provisions
Reporting
of
lead
and
copper
results
­
87.0
­
1.3
­
88.3
Reporting
of
source
water
monitoring
results
­
6.9
­
0.3
­
7.2
Specify
lead
and
copper
monitoring
location
changes
­
20.8
0.0
­
20.8
TOTAL
­
890.6
­
1933.3
­
2823.9
Note:
Some
of
the
information
to
be
submitted
to
the
State
was
assumed
to
be
included
with
other
information
(
e.
g.,
certifications
with
lead
and
copper
monitoring
results)
and
hence,
no
postage
costs
were
estimated
(
i.
e.,
nonlabor
costs).

6(
b)(
ii)
Costs
to
States
State
costs
were
determined
by
multiplying
the
labor
hours
by
$
25.34
($
52,696/
2,080
hours).
56
The
average
annual
cost
of
labor
to
the
State
over
the
three
years
is
estimated
to
be
$
1,268,400.
States
will
also
incur,
during
the
first
year
of
implementation,
non­
labor
costs
for
contractor
services
to
modify
State
data
systems
to
accommodate
the
reporting
of
the
new
"
Done"
and
"
Deemed"
milestone.
A
total
of
$
75,000
is
estimated
for
each
of
the
36
State
respondents.
This
equals
an
average
annual
total
of
$
900,000
over
the
three­
year
ICR
period.
The
total
average
annual
increase
in
costs
to
States
is
estimated
to
be
$
2,168,400.
Figure
6­
5
presents
the
State
costs
by
revision.
June
1999
57
Figure
6­
5:
Change
in
Annual
State
Costs
for
1999
through
2001
due
to
LCRMR
(
in
$
1,000'
s)

Activity
Average
Costs
Overhead
203.5
Notify
systems
of
requirements
95.6
Initial
Activities
Regulation
adoption
246.0
Train
staff
177.4
Modify
the
data
system
1,279.5
Review
of
Lead
and
Copper
Tap
and
WQP
Monitoring
Data
and
Related
Information
Review
of
monitoring
results
for
(
b)(
3)
systems
1.4
Request
use
of
non­
first­
draw
samples
6.3
Specify
reduced
monitoring
sites
41.6
Accelerated
lead
and
copper
monitoring
­
45.8
Monitoring
waivers
(
review
of
applications
&
less
monitoring
data)
­
28.7
Accelerated
reduced
WQP
tap
monitoring
0.0
WQP
monitoring
at
representative
entry
points
1.7
State
flexibility
to
calculate
90th
percentile
level
52.6
Changes
in
treatment
or
addition
of
a
new
source
6.7
Review
of
compliance
with
optimal
WQP
levels
44.1
Review
of
reasons
for
changes
in
lead
and
copper
tap
monitoring
location
­
6.1
Source
Water
Monitoring
Requirements
Reduced
source
water
monitoring
for
PWSs
w/
o
MPLs
­
11.7
Public
Education
Review
of
public
education
compliance
letters
3.3
Request
to
remove
reference
to
building
permit
record
availability
from
mandatory
language
1.4
Lead
Service
Line
Replacement
Review
of
compliance
letter
for
partial
LSLR
requirements
60.9
Enforcement
­
89.7
June
1999
Activity
Average
Costs
58
Revisions
to
§
142.15
Requirements
Report
90th
percentile
lead
levels
for
large
and
medium
PWSs
35.5
Modify
milestones
&
delete
requirement
to
report
compliance
with
LSLR
schedule
398.4
Changes
in
violation
and
enforcement
reporting
­
105.6
Reporting
to
State
data
base
(
Record
Keeping)
­
199.9
TOTAL
2,168.4
Note:
All
costs
are
labor
with
the
exception
that
$
900,000
of
the
$
1,279,500
to
modify
the
data
system
are
contractor
costs.

6(
c)
Estimating
Agency
Burden
And
Cost
EPA
Headquarters
and
Regional
offices
will
incur
burdens
and
costs
to
develop
guidance
documents,
address
policy
issues,
oversee
State
Public
Water
System
Supply
Programs,
modify
SDWIS,
and
to
process
and
analyze
the
LCRMR
data.
These
functions
will
involve
a
mix
of
Headquarters,
Regions,
and
contractor
effort.
Each
is
described
in
more
detail
below
and
summarized
in
Figure
6­
6.

Figure
6­
6:
Average
Annual
Agency
Burdens
and
Costs,
1999­
2001
Burden
Cost
s
(
in
$
1,000'
s)

Headquarters
1,733
81.3
Region
5,616
221.5
Contractor
N/
A
98.3
TOTAL
7,349
401.1
6(
c)(
i)
Burden
and
Costs
to
Headquarters
Headquarters
is
expected
to
undertake
the
following
activities
during
the
1999
through
2001
resulting
from
the
LCRMR.


Develop
Guidance
Documents/
Address
Policy
Issues.
Headquarters
will
be
responsible
for
developing
guidance
documents
that
will
assist
the
States
and
systems
in
implementing
the
new
requirements.
Some
of
these
guidance
documents
will
include:
determining
compliance
with
OWQPs
using
the
new
criteria
and
changes
to
Federal
reporting
June
1999
57
This
calculation
is
outlined
on
page
A­
36
of
the
ICR
Handbook
 
EPA's
Guide
to
Writing
Information
Collection
Requests
Under
the
Paperwork
Reduction
Act
of
1995,
12/
96.

59
requirements.
The
Agency
assumes
that
it
will
also
need
to
address
policy
issues
that
will
arise
as
systems
and
States
implement
the
new
requirements.
The
Agency
will
also
develop
fact
sheets.
However,
these
documents
are
expected
to
be
completed
prior
to
the
promulgation
of
the
LCRMR,
and
are
not
included
in
the
burdens
and
costs
discussed
below.


Modify
SDWIS.
SDWIS
and
the
Data
Transfer
File
format
program
that
allows
States
to
report
to
SDWIS
will
need
to
be
modified
to
accommodate
reporting
of
the
new
"
Done"
and
"
Deemed"
milestones.
No
revisions
will
be
needed
to
accept
all
lead
90th
percentile
values
as
SDWIS
can
already
accept
these
data.


Analyze
SDWIS
data.
On
a
national
level,
Headquarters
will
evaluate
the
status
of
systems
using
the
new
"
Done"
and
"
Deemed"
milestones,
and
evaluate
how
levels
of
lead
at
the
tap
have
changed
over
time
using
the
90th
percentile
levels
reported
for
large
and
medium­
size
systems.

The
bulk
of
these
activities
is
assumed
to
occur
in
1999
through
2001.
EPA
estimates
that
these
activities
will
require
1.0
FTE
in
1999
and
2000
and
0.5
FTEs
in
2001,
for
a
total
of
2.5
FTEs
over
the
three­
year
ICR
period.
This
translates
to
a
total
burden
of
5,200
hours
over
the
three
years
(
i.
e,
2.5
FTEs
*
2,080
hours
per
FTE)
or
an
average
of
1,733
hours.

These
FTEs
are
assumed
to
be
a
GS
13,
Step
5.
Based
on
the
1999
General
Schedule,
this
equals
a
salary
of
$
60,965.
The
hourly
rate
for
a
GS
level
is
determined
by
dividing
the
annual
pay
rate
for
the
GS
level
by
2,080,
which
represents
the
average
number
of
hours
worked
during
a
calendar
year
(
including
holidays
and
vacations).
The
answer
is
then
multiplied
by
1.6,
the
benefits
multiplication
factor.
57
Based
on
this
procedure,
the
hourly
rate
equals
$
46.90
(
i.
e.,
$
60,965/
2,080
*
1.6).
Multiplied
by
the
average
annual
burden
of
1,733
hours,
the
average
cost
for
Headquarters
equals
$
81,278.

6(
c)(
ii)
Burdens
and
Costs
to
Regional
Staff
During
the
first
two
years
of
LCRMR
implementation,
EPA
Regional
staff
will
assist
States
in
understanding
the
requirements
of
the
LCRMR.
Regions
will
also
evaluate
progress
on
a
Regional
level
using
the
new
milestone
and
lead
data.
The
Agency
assumes
that
0.33
FTEs
per
Region
will
be
required
during
1999
and
2000,
and
then
decrease
to
0.15
FTEs
in
2001.
This
equals
a
total
burden
of
16,848
hours
(
2,080
hours
per
FTE
*
0.81
*
10
FTEs)
or
an
average
burden
of
5,616
hours
over
the
three­
year
ICR
period.

The
Regional
FTEs
are
assumed
to
be
a
GS
12,
Step
5.
Based
on
the
1999
General
Schedule,
this
equals
a
salary
of
$
51,268.
Using
the
procedure
described
in
section
6(
c)(
i),
the
hourly
rate
would
equal
$
39.44
(
i.
e.,
$
51,268/
2,080
*
1.6).
Multiplied
by
the
average
annual
burden
of
5,616
hours,
the
average
annual
cost
to
Regions
would
equal
$
221,495.
June
1999
60
6(
c)(
iii)
Contractor
Costs
The
Agency
estimates
contractor
support
will
be
needed
in
three
general
areas:


Guidance
Document
Development
Support
The
Agency
estimates
that
it
will
require
$
100,000
in
contractor
support
to
develop
guidance
document
during
1999.


Modify
SDWIS/
State.
Approximately
20
systems
will
use
SDWIS/
State
to
maintain
and
report
LCRMR
data.
EPA
estimates
that
during
2000,
the
Agency
will
expend
a
total
of
$
35,000
in
contractor
costs
to
modify
SDWIS/
State
to
accept
and
report
the
new
LCRMR
milestones.


Modify
SDWIS/
Fed.
Contractor
support
will
be
required
to
modify
SDWIS
and
DTF
to
accept
the
new
milestone
data.
EPA
estimates
that
$
20,000
will
be
needed
in
1999
to
identify
the
needed
changes.
An
additional
$
140,000
will
be
required
to
modify
SDWIS
in
2000.

No
additional
contractor
support
is
anticipated
in
2001
as
a
result
of
the
LCRMR.
The
total
contractor
costs
is
estimated
to
be
$
295,000
or
an
annual
average
of
$
98,300
over
the
three­
year
ICR
period.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
universe
of
respondents
for
this
ICR
is
comprised
of
the
75,945
CWSs
and
NTNCWSs,
and
the
56
State
primacy
agencies.
Exhibit
6­
7
presents
a
summary
of
total
burdens
and
costs
for
the
ICR
period
of
1999­
2001.

The
annual
system
burden
is
estimated
to
decrease
an
average
of
36,773
hours
over
the
3­
year
ICR
cycle.
The
annual
system
costs
are
projected
to
decrease
an
average
of
$
2,823,900
and
to
be
comprised
of
$
890,600
in
labor
and
$
1,933,300
in
non­
labor
costs.

The
average
annual
burden
over
the
three
years
for
States
to
carry
out
the
LCRMR
is
estimated
to
increase
by
50,055
hours.
The
average
annual
costs
are
estimated
to
increase
by
$
2,168,400,
with
labor
costs
equaling
$
1,268,400
and
non­
labor
costs
equaling
$
900,000.

The
average
Agency
burden
over
the
three­
year
ICR
period
is
estimated
to
increase
by
an
average
of
7,349
hours
per
year,
and
costs
are
estimated
to
increase
an
average
of
$
401,100
($
302,800
in
labor
costs
and
$
98,300
in
contractor
costs.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Table
The
national
annual
average
burden
and
cost
estimates
for
the
LCRMR
are
presented
in
Figure
6­
7
below.
The
average
system
and
State
burden
per
response
is
an
increase
of
0.3
hours
and
the
cost
per
response
is
a
reduction
of
$
14.
June
1999
61
Figure
6­
7:
Change
in
Respondent
Average
Annual
Burdens
and
Costs
for
1999­
2001
Respondent
Number
of
Respondents
Total
Responses
Total
Burden
(
hrs)
Total
Cost
($)

Public
Water
System
75,945
2,654
­
36,773
­
2,823,900
State
56
42,996
50,055
2,168,400
TOTAL
76,001
45,650
13,282
(
655,500)

Burden
per
Response
0.3
hours
Cost
per
Response
(
in
$)
­$
14
1.
The
number
of
system
responses
was
determined
by
subtracting
the
total
number
of
system
reports
to
the
State
required
under
the
LCRMR
(
59,824)
from
the
number
of
reports
required
under
the
1991
LCR
(
57,170),
and
then
averaging
the
difference
over
three
years.
The
number
of
reports
was
based
on
the
LCRMR
and
revised
baseline
system
reporting
models
and
included
the
reporting
of
lead
and
copper
monitoring
data,
WQP
monitoring
data,
source
water
monitoring
results,
public
education
compliance
letter,
annual
lead
service
line
letter,
monitoring
waiver
application
(
LCRMR
only);
demonstration
of
representative
entry
points
for
WQPs
(
LCRMR
only),
and
partial
lead
service
line
replacement
monitoring
results/
demonstration
of
compliance
with
notification
requirements
(
LCRMR
only).
All
other
reporting
requirements
were
assumed
to
be
included
with
the
reporting
of
lead
and
copper
monitoring
data
and
were
not
considered
to
be
separate
responses.
All
system
reports
were
assumed
to
be
submitted
in
hard
copy
format.
2.
The
number
of
State
responses
was
similarly
derived
by
subtracting
the
total
number
of
State
reports
to
EPA
required
under
the
LCRMR
(
100,105)
from
the
number
of
reports
required
under
the
1991
LCR
(
57,109),
and
then
averaging
the
difference
over
three
years.
The
number
of
reports
was
based
on
the
LCRMR
and
revised
baseline
State
reporting
models.
A
report
consisted
of
a
single
milestone,
violation,
or
enforcement
action,
and
each
report
that
indicated
which
systems
were
in
compliance
with
their
lead
service
line
replacement
schedules.
All
State
reports,
except
the
112
lead
service
line
compliance
letters,
were
assumed
to
be
submitted
electronically.

Figure
6­
8
below
shows
the
estimated
respondent
and
Agency
burden
and
cost
for
each
of
the
3
years
in
the
ICR
period.
Systems
and
States
are
estimated
to
experience
an
increase
in
burden
in
1999
due
to
initial
implementation
activities
such
as
training,
reading
the
regulations,
and
regulatory
adoption.
The
initial
activities
are
not
expected
to
continue
outside
the
ICR
period.
During
2002
through
2009,
systems
are
expected
to
realize
an
annual
average
reduction
in
burden
of
170,629
hours
and
a
reduction
in
cost
of
$
4,401,400.
The
increase
in
burden
and
costs
to
States
is
estimated
to
drop
to
an
annual
average
increase
of
2,333
hours
and
$
58,900
during
2002
through
2009.
June
1999
62
Figure
6­
8:
Annual
Burden
and
Costs
by
Year
for
1999
­
2001
Respondent/
Agency
1999
2000
2001
Burden
(
hrs)
Costs
(
in
$
K)
Burden
(
hrs)
Costs
(
in
$
K)
Burden
(
hrs)
Costs
(
in
$
K)

Systems
169,554
­
668
­
230,789
­
5,667
­
49,090
­
2,137
States
70,230
2,680
49,634
3,058
30,300
768
EPA
8,944
488
8,944
544
4,160
172
Total
248,728
2,500.0
(
172,211)
(
2,065.0)
(
14,630)
(
1,197.0)

6(
f)
Reasons
For
Change
In
Burden
This
ICR
reflects
two
sets
of
changes
in
burdens
and
costs.
First,
section
6(
f)(
i)
provides
an
explanation
of
the
differences
between
the
currently­
approved
baseline
and
the
revised
baseline
burden
estimates.
Secondly,
section
6(
f)(
ii)
provides
the
changes
in
the
burden
resulting
from
LCRMR,
as
compared
to
the
revised
baseline
for
the
LCR.

6(
f)(
i)
Explanation
of
Differences
between
Currently­
Approved
Baseline
and
the
Revised
Baseline
Estimates
This
ICR
amends
the
approved
Drinking
Water
ICR
(
EPA
#
0270.39,
OMB
#
2040­
0090).
As
discussed
previously,
the
burden
and
cost
estimates
for
the
LCR
contained
in
the
current
Drinking
Water
ICR
are
not
used
as
the
baseline
for
this
revised
May
1999
ICR.
At
the
time
of
promulgation
in
1991,
the
Agency
estimated
the
record
keeping
and
reporting
burden
associated
with
the
LCR,
assuming
that
approximately
50
percent
of
systems
would
exceed
the
lead
or
copper
action
levels,
based
on
data
from
a
select
group
of
U.
S.
cities.
Now
that
water
systems
have
collected
lead
and
copper
samples
from
hundreds
of
thousands
of
household
taps
around
the
country
to
comply
with
the
monitoring
requirements
of
the
rule,
much
more
reliable
predictions
of
burden
can
be
made.
Based
on
data
reported
to
the
SDWIS,
EPA
now
estimates
that
approximately
29
percent
of
systems
will
exceed
the
lead
or
copper
action
level,
resulting
in
significantly
more
systems
able
to
reduce
the
number
and
frequency
of
monitoring
sooner
than
originally
predicted,
and
fewer
systems
triggered
into
public
education
and
lead
service
line
replacement
requirements.

To
more
accurately
assess
the
impact
of
the
LCRMR,
EPA
has
revised
the
models
used
to
estimate
the
burden
and
cost
of
the
1991
LCR
(
i.
e.,
the
revised
baseline).
These
models
incorporate
the
revised
lead
and
copper
exceedance
estimates,
use
a
standard
EPA
inventory
data
set,
include
public
education
activities,
use
more
current
costing
factors,
and
more
clearly
distinguish
the
burden
and
cost
associated
with
monitoring,
reporting,
and
record
keeping.

Exhibit
6­
9
below
contains
a
comparison
of
the
burden
and
costs
for
the
LCR
portion
of
the
currentlyapproved
ICR,
to
those
estimated
for
the
revised
baseline.
The
currently­
approved
baseline
is
the
total
of
the
LCRrelated
burden
and
costs
in
Exhibits
8
and
9
of
the
1993
Program
ICR
and
the
public
education
burdens
and
costs
from
The
Public
Water
System
Supervision
Program
Public
Notification
and
Education
Requirements,
ICR
No.
270.34,
September
27,
1995.
A
detailed
description
of
assumptions
used
to
recalculate
the
burdens
and
costs
associated
with
the
original
LCR
(
i.
e.,
the
baseline)
and
used
to
estimate
those
resulting
from
the
LCRMR
are
contained
in
Appendix
A.
Sections
6(
f)(
i)(
a)
and
6(
f)(
ii)(
b)
provide
an
explanation
for
differences
in
the
two
baselines
pertaining
to
system
and
State
estimates,
respectively.
June
1999
63
Figure
6­
9:
Comparison
of
System
Burden
and
Costs
Estimates
of
the
Drinking
Water
ICR
and
Revised
Baselines
Respondent
Revised
Baseline
Currently­
Approved
Baseline
Difference
Burden
(
hrs)
Costs
($)
Burden
(
hrs)
Costs
($)
Burden
(
hrs)
Costs
($)

Public
Water
System
1,990,330
49,921,200
1,557,238
33,482,083
433,092
16,439,117
States
428,116
10,848,500
1,420,000
43,200,000
(
991,884)
(
32,351,500)

TOTAL
2,418,446
60,769,700
2,977,238
76,682,083
(
558,792)
(
15,912,383)

1.
The
burden
for
the
currently­
approved
baseline
is
comprised
of
1,235,694
hours
for
non­
public
education
activities
and
321,544
hours
for
public
education.
The
costs
are
divided
between
$
21,424,333
for
non­
public
education
activities
and
$
12,057,750
for
public
education.
2.
Only
the
public
education
burden
and
costs
from
the
The
Public
Water
System
Supervision
Program
Public
Notification
and
Education
Requirements
are
included
in
Exhibit
6­
9
above.
Public
notification
burdens
and
costs
are
not
included
in
this
May
1999
ICR,
but
will
be
included
in
the
ICR
being
developed
for
the
revised
Public
Notification
Regulation.
3.
To
estimate
non­
labor
costs
for
the
currently­
approved
baseline,
(
as
presented
under
line
14.
d
of
the
OMB
form
83­
I
that
accompanies
this
May
1999
ICR),
EPA
assumes
that
the
hourly
system
labor
rate
is
$
10
and
the
State
labor
rate
is
$
26.04.

6(
f)(
i)(
a)
Explanation
of
Differences
in
System
Burdens
and
Costs
The
Drinking
Water
ICR
does
not
provide
detail
on
the
specific
activities
that
comprise
the
system
burden
and
cost
estimates.
These
estimates,
however,
are
based
on
the
1991
LCR
ICR.
Appendix
E
of
the
1991
LCR
ICR
provides
year­
by­
year
cost
estimates
for
monitoring
and
non­
monitoring
activities
(
i.
e.,
read
regulations,
plan
and
review,
and
training).
Burden
estimates
are
not
specified
for
each
year,
but
are
provided
as
an
annual
average
burden.
The
LCR
costs
presented
in
the
Drinking
Water
ICR
appear
to
include
about
$
20
million
in
monitoring
costs
and
$
1.4
million
in
non­
monitoring
costs.
Monitoring
from
lead
service
lines
does
not
appear
to
be
included
in
the
monitoring
total.
A
possible
explanation
is
that
lead
service
line
replacement
and
associated
monitoring
occur
beyond
the
three­
year
Drinking
Water
ICR
period
of
1994
through
1996.
Public
education
costs
and
burdens
from
the
Public
Water
System
Supervision
Program
Public
Notification
and
Education
Requirements,
add
321,544
hours
and
approximately
$
12
million
in
costs.
The
total
system
burden
and
costs
for
the
currently­
approved
baseline
are
approximately
1.6
million
hours
and
$
33.5
million.
The
revised
baseline
estimate
for
systems
is
approximately
2
million
hours
and
$
50
million.
Exhibit
6­
10
summarizes
the
differences
in
key
assumptions
used
to
estimate
the
two
sets
of
baseline
estimates.
June
1999
58
The
number
of
entry
points
was
derived
from
a
1993
survey
sponsored
by
the
Association
of
State
Drinking
Water
Administrators.

64
Figure
6­
10:
Assumptions
that
Differ
between
the
Currently
Approved
Baseline
and
Revised
Baseline
Assumption
Currently­
Approved
Baseline
Revised
Baseline
System
Assumptions
Number
of
PWS
respondents
78,703
75,945
System
labor
rate
$
40
for
senior,
$
10
for
junior
staff.
Most
activities
were
estimated
at
the
junior
rate.
$
14.29­$
18.79
depending
on
system
size
and
collection
activity.

Exceedance
rate
about
50%
30%
for
small
PWSs,
25%
for
medium
and
large
Collection/
analytical
burden
for
lead
and
copper
tap
samples
3
hours.
This
burden
also
includes
reporting
results
to
the
State.
3.5
hours
and
reporting
burden
is
estimated
separately.

Number
of
entry
points
used
to
determine
number
of
source
water
samples
and
WQP
entry
point
samples
to
be
collected
1
to
54
entry
points
for
ground
water
systems
1
entry
point
for
surface
water
1.2
to
36.3
entry
points
for
ground
water
1.3
to
4.7
entry
points
for
surface
water58
Lead
Service
Line
Samples
Not
included
in
the
Drinking
Water
ICR
Includes
two
types
of
monitoring:
1)
monitoring
to
determine
if
a
line
needs
to
be
replaced
and
2)
monitoring
and
notification
due
to
partial
lead
service
line
replacement.

Reporting
Included
as
part
of
the
collection/
analytical
burden
Estimated
as
a
separate
burden
for
the
collection/
analytical
burden.
The
estimated
burden
for
most
reports
is
0.5
hours
to
1
hour
per
report.

6(
f)(
i)(
b)
Explanation
of
Differences
in
State
Burdens
and
Costs
The
1991
LCR
ICR
did
not
specify
the
assumptions
used
to
develop
the
State
burden.
The
1991
ICR
presents
State
burden
as
two
aggregate
totals;
one
for
initial,
and
a
second
for
on­
going
activities.
States
were
estimated
to
require
793
FTEs
per
year
for
initial
activities
and
696
FTEs
for
on­
going
activities.
An
FTE
was
assumed
to
equal
1,920
hours
per
FTE.
The
initial
and
on­
going
burdens
were
averaged
over
1992
through
2009,
for
an
annual
average
of
1.42
million
hours
[(
793
*
1,920)
+
(
696
*
1,920)].
No
adjustments
to
this
burden
were
made
in
the
Drinking
Water
ICR.
June
1999
65
Based
on
the
level
of
detail
provided
in
the
1991
ICR,
the
reasons
for
the
difference
in
burden
between
the
currently
approved
baseline
and
revised
baseline
cannot
be
specified,
with
the
following
exceptions:
1)
In
the
revised
baseline,
an
FTE
equals
2,080
hours
per
year;
2)
The
number
of
State
respondents
is
57
in
the
revised
baseline
compared
to
56
State
respondents
in
the
revised
baseline.

The
costs
presented
in
the
1991
ICR
are
presented
in
more
detail
and
were
based
on
the
survey
entitled,
State
Costs
of
Implementing
the
1986
Safe
Drinking
Water
Act
Amendments,
Association
of
State
Drinking
Water
Administrators,
August
1989.
Initial
and
on­
going
cost
estimates
were
provided
for
13
collection
activities.
The
initial
costs
were
divided
by
18
years
and
then
added
to
the
on­
going
costs
estimates
for
each
of
the
13
categories.
No
adjustments
to
State
cost
estimates
were
made
in
the
Drinking
Water
ICR.

Unlike
the
currently­
approved
ICR,
the
revised
baseline
contains
costs
that
are
specific
to
a
given
year,
and
only
includes
costs
incurred
during
1999
through
2001.
Many
of
the
State
activities
included
in
the
currentlyapproved
baseline
are
assumed
to
occur
prior
to
1999
and
are
not
included
in
the
revised
baseline.
More
specifically,
the
revised
baseline
models
assume
that
the
following
State
activities
have
been
completed
prior
to
1999:
rule­
specific
training,
data
system
modification
to
accommodate
LCR
reporting,
regulatory
adoption
activities,
review
of
lead
and
copper
sampling
plan
and
initial
tap/
WQP
data,
decision
regarding
systems
required
to
conduct
corrosion
control
study,
decision
regarding
type
of
corrosion
control
treatment
to
be
installed,
review
of
tap
and
WQP
follow­
up
samples
and
setting
of
WQP
levels
for
medium
and
large
systems,
and
review
of
initial
source
water
monitoring
results,
decision
regarding
source
water
treatment,
review
of
follow­
up
source
water
results,
and
assignment
of
MPLs.
The
currently­
approved
baseline
captures
many
of
the
initial
activities
that
are
no
longer
relevant
and/
or
are
more
labor­
intensive.
For
example,
States
would
review
more
monitoring
data
in
the
early
years
of
implementation
because
systems
would
not
have
qualified
for
reduced
monitoring.

Figure
6­
11
is
a
comparison
of
State
costs
under
the
currently­
approved
baseline
against
the
revised
baseline.

Figure
6­
11:
Detailed
State
Cost
Comparison
between
the
Currently­
Approved
Baseline
and
the
Revised
Baseline
(
Costs
are
in
$
millions)

Collection
Activity
Currently
Approved
Baseline
Revised
Baseline
Cost
Reason
for
Difference
Adopt
regulation
$
0.8
$
0.0
Revised
baseline
assumes
activity
will
only
occur
in
the
first
year
of
implementation
instead
of
each
year.

DW
Staff
Training
$
0.7
$
0.0
Revised
baseline
assumes
rule­
specific
training
was
completed
prior
to
1999,
but
overhead
in
revised
baseline
includes
general
training.

Expand
lab
capacity
$
7.0
$
0.0
Revised
baseline
assumes
this
activity
was
completed
prior
to
1999.

Modify
Data
Management
System
$
0.8
$
0.0
Revised
baseline
assumes
this
activity
was
completed
prior
to
1999.

Lab
Certification
$
0.7
0.7
N/
A
June
1999
Collection
Activity
Currently
Approved
Baseline
Revised
Baseline
Cost
Reason
for
Difference
66
Notify
systems
of
requirements
$
0.8
0.7
Similar
assumptions
were
used
in
both
baselines.

Assist
High
Risk
Identification
$
6.0
0.0
Revised
baseline
assumes
identification
of
sites
would
be
essentially
completed
by
1999.
Revised
baseline
includes
State
burden
to
identify
reduced
sampling
sites.

Plan
&
Construction
Review
$
3.7
0.0
Revised
baseline
assumes
that
treatment
decisions
were
completed
prior
to
1999.

Treatment
Plans
for
Small
Systems
$
5.9
0.0
Corrosion
Control
Review
$
6.5
0.0
Revised
baseline
assumes
this
activity
was
completed
by
1999.

Public
Education/
Other
$
3.7
0.1
Revised
baseline
assumes
States
are
reviewing
compliance
letters
only.
Unclear
what
activities
are
included
in
the
currently­
approved
baseline.

Formal
Enforcement
$
5.0
0.6
Revised
baseline
includes
NOVs
only.
Enforcement
beyond
this
level
is
considered
outside
the
scope
of
ICR.
The
currently­
approved
baseline
may
have
included
other
types
of
enforcement.

Review
monitoring
data
0.0
$
4.8
The
burden
for
this
activity
under
currently­
approved
baseline
may
be
included
under
other
activities.

Overhead
adjustment
N/
A
$
2.0
Benefits
adjustment
may
have
already
been
included
in
the
salary
for
the
currently­
approved
baseline.

Data
Entry
and
Reporting
$
2.8
$
2.0
Reason
for
difference
cannot
be
assessed
beyond
differences
in
number
of
respondents
and
State
average
hourly
rate
between
the
two
baselines.

TOTAL
44.4
10.9
Note:
Totals
presented
in
the
above
table
do
not
match
those
in
Figure
6­
9
due
to
independent
rounding.

6(
f)(
ii)
Differences
between
the
LCRMR
and
LCR
Burdens
June
1999
67
This
ICR
subtracts
2,418,446
hours
in
system
and
State
respondent
burden
that
reflect
the
revised
burden
estimates
for
the
LCR
and
adds
2,431,728
hours
of
respondent
burden
to
implement
the
reporting
and
record
keeping
requirements
of
the
LCRMR.
The
net
impact
of
this
program
change
is
an
overall
increase
of
13,282
hours
in
system
and
State
burden
per
year.
The
change
in
respondent
burden
is
summarized
in
Figure
6­
12
below.

Figure
6­
12:
Change
in
Annual
Respondent
Burden
(
in
hours)

Respondent
LCRMR
LCR
(
revised
baseline)
Difference
Public
Water
System
1,953,557
1,990,330
(
36,773)

States
478,171
428,116
50,055
TOTAL
2,431,728
2,418,446
13,282
This
ICR
subtracts
$
15,059,200
in
system
and
State
respondent
non­
labor
costs
that
reflect
the
revised
burden
estimates
for
the
LCR
and
adds
$
14,025,900
in
non­
labor
respondent
costs
to
implement
the
reporting
and
record
keeping
requirements
of
the
LCRMR.
The
net
impact
of
this
program
change
is
an
overall
decrease
of
$
1,033,300
in
system
and
State
non­
labor
costs
per
year.
The
change
in
these
respondent
costs
is
summarized
in
Figure
6­
12
below.

Figure
6­
13:
Change
in
Annual
Non­
Labor
Respondent
Costs
($)

Respondent
LCRMR
LCR
(
revised
baseline)
Difference
Public
Water
System
13,125,900
15,059,200
(
1,933,300)

States
900,000
0
900,000
TOTAL
14,025,900
15,059,200
(
1,033,300)

6(
g)
Burden
Statement
For
the
ICR
period
of
1999
through
2001,
the
average
burden
for
systems
to
implement
the
requirements
of
the
LCR
(
i.
e.,
the
revised
baseline)
is
estimated
to
be
26
hours
per
system
per
year.
The
average
annual
cost
to
systems
is
$
657.
System
burden
includes
time
required
to
collect
and
analyze
samples,
report
results,
maintain
records,
and
deliver
public
education.
The
average
burden
for
State
agencies
is
estimated
to
be
7,645
hours
per
State
per
year.
This
burden
includes
the
time
to
inform
systems
of
the
requirements,
review
and
monitoring
results
and
other
system
submissions,
take
appropriate
follow­
June
1999
68
up
action,
maintain
records,
and
report
results
to
EPA.
The
estimated
annual
State
cost
is
estimated
to
be
$
193,700
per
State
per
year.

The
average
system
burden
associated
with
the
LCRMR
for
the
ICR
period
of
1999
through
2001
is
estimated
to
decrease
by
0.5
hours
per
system
per
year,
with
an
associated
average
annual
decrease
in
cost
of
$
37
per
system.
System
burden
includes
time
required
to
read
the
regulations,
attend
training,
collect
and
analyze
samples,
report
results,
maintain
records,
and
deliver
public
education.
The
average
burden
for
State
agencies
is
estimated
to
be
an
increase
of
894
hours
per
State
per
year.
This
burden
includes
the
time
to
read
the
regulation,
attend
training,
inform
systems
of
the
requirements,
review
and
monitoring
results
and
other
system
submissions,
take
appropriate
follow­
up
action,
maintain
records,
and
report
results
to
EPA.
The
estimated
annual
State
cost
is
estimated
to
increase
by
about
$
38,700
per
State
per
year.
Much
of
this
increase
can
be
attributed
to
one­
time
start­
up
costs.
During
2002
to
2009
the
average
burden
and
cost
increase
drops
significantly
to
an
average
increase
of
42
hours
and
$
1,052
per
State
per
year.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
OPPE
Regulatory
Information
Division,
U.
S.
Environmental
Protection
Agency
(
2137),
401
M
Street,
SW,
Washington,
DC
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
