June
1999
APPENDICES
!
Appendix
A:
Detailed
Assumptions
Used
to
Estimate
Burdens
and
Costs
!
Appendix
B:
Year­
by­
Year
Burden
Estimates
for
Systems
and
States
!
Appendix
C:
SDWA
Sections
that
Provide
Authority
for
the
Collection
!
Appendix
D:
Spreadsheets
from
System
Burden
and
Costs
Models
!
Appendix
E:
Spreadsheets
from
State
Burden
and
Costs
Models
June
1999
APPENDIX
A
Detailed
Assumptions
Used
to
Estimate
Burdens
and
Costs
June
1999
A­
1
June
1999
A­
2
APPENDIX
A
ASSUMPTIONS
USED
TO
DEVELOP
ICR
BURDENS
AND
COSTS
FOR
THE
LCR
AND
LCRMR
Overview
In
its
efforts
to
quantify
the
impact
of
the
Lead
and
Copper
Minor
Rule
Revisions
(
LCRMR),
EPA
has
revised
its
estimates
of
the
current
Lead
and
Copper
Rule
(
LCR)
from
those
presented
in
the
1991
Information
Collection
Request
(
ICR).
Revisions
to
these
burden
and
cost
estimates
are
needed
to
more
accurately
reflect
the
outcome
of
the
implementation
of
the
regulation,
to
include
public
education
activities,
and
to
allow
the
impacts
of
the
LCRMR
to
be
assessed
by
better
delineating
the
various
requirements
of
the
current
regulation.
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.
One
serves
as
the
baseline
and
depicts
the
current
requirements.
The
second
set
was
adjusted
to
reflect
the
requirements
of
the
LCRMR.
Each
of
these
models
and
overall
assumptions
are
presented
in
more
detail
below.

Overall
Assumptions
The
following
assumptions
lay
the
foundation
of
the
burden/
cost
models.

1.
The
inventory
of
systems
is
from
SDWIS
on
January
17,
1997
and
is
as
follows:
68,093
small
systems,
7,117
medium
systems,
and
735
large
systems,
for
a
total
of
75,945
systems.
This
inventory
is
reflective
of
changes
made
to
the
inventory
after
inventory
verifications
were
conducted
in
most
States
by
EPA.

Note:
EPA
does
not
believe
that
it
is
necessary
to
use
a
1998
or
1999
data
set
because
the
inventory
is
constantly
changing
(
e.
g.,
systems
consolidate,
new
systems
come
on
line).
1998
inventory
from
SDWIS
indicate
a
decrease
of
about
1.5
percent
from
the
January
1997
inventory.

2.
30%
of
small
systems
and
25%
of
medium
and
large
systems
will
exceed
the
lead
or
copper
action
level.
25%
of
small
systems
and
20%
of
medium
and
large
systems
will
exceed
the
lead
action
level
only.
Medium
and
large
system
estimates
are
based
on
initial
monitoring
results
reported
to
EPA
during
1992
and
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.

3.
For
those
systems
exceeding
the
lead
or
copper
action
level,
the
exceedance
will
occur
during
the
first
round
of
monitoring.
June
1999
A­
3
Note:
EPA
recognizes
that
this
is
a
simplifying
assumption
and
that
some
systems
may
exceed
in
monitoring
periods
other
than
initial
monitoring
or
may
have
intermittent
exceedances.

4.
All
system
and
State
requirements
will
meet
the
schedule
outlined
in
the
regulation
and
are
assumed
to
require
the
maximum
time
allowed
by
regulation
(
e.
g.,
a
study
will
require
18
months).

5.
25%
of
systems
exceeding
the
lead
or
copper
action
level
will
continue
to
exceed
(
CTE)
after
the
installation
of
treatment.

6.
786
systems
and
66
systems
will
install
source
water
treatment
(
SOWT)
to
treat
for
lead
and
copper,
respectively.
Numbers
are
based
on
1991
RIA,
adjusted
for
the
1997
inventory.

7.
Few
systems
are
expected
to
qualify
as
(
b)(
2)
systems
(
i.
e.,
<
1%
of
large
systems).
The
monitoring
models
do
not
account
for
these
systems
separately
but
include
them
as
(
b)(
3)
systems
or
as
systems
installing
corrosion
control.

8.
25%
of
medium
and
small
systems
exceeding
the
lead
or
copper
action
level
will
be
required
to
conduct
a
corrosion
control
treatment
(
CCT)
study;
all
large
systems
except
those
deemed
to
have
optimized
treatment
under
§
141.81
(
b)(
3)
(
i.
e.,
(
b)(
3)
systems
will
be
required
to
conduct
a
study.)

9.
Based
on
data
available
in
SDWIS,
a
large
system
is
assumed
to
qualify
as
a
(
b)(
3)
system
if
during
initial
monitoring,
its
90th
percentile
lead
level
was
<
5
ppb
(
using
this
criterion,
171
systems
qualified
as
(
b)(
3)
systems).

10.
As
a
simplifying
assumption,
all
systems
installing
SOWT
will
also
install
CCT.

11.
The
1991
ICR
and
the
currently
approved
Public
Water
System
Supervision
Program
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
a
change
in
the
procedure
for
estimating
burdens/
costs.

12.
The
system
labor
rate
is
dependent
upon
size
and
activity.
The
junior
and
chemist
labor
rates
are
Bureau
of
Labor
Statistics
March
1998
estimates.
The
labor
rates
for
a
trained
operator
are
based
on
a
discussion
summary
of
the
EPA
Technology
Design
Workshop,
held
on
November
6
and
7,
1997
in
Denver,
Colorado.
a.
For
the
four
cost/
burden
monitoring
models,
the
average
hourly
system
labor
rates
were
estimated
as
follows:
$
12.77
is
assumed
for
junior
(
non­
specialized)
labor;
$
22.69
for
a
chemist,
and
$
28
to
$
52
for
a
trained
operator.
33%
of
the
labor
is
June
1999
A­
4
assumed
to
be
chemist
time,
7%
management
time,
and
60%
nonspecialized
This
translates
to:

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
b.
For
the
system
reporting
model
and
public
education
model,
the
average
hourly
rate
was
determined
as
follows:
90%
of
the
labor
is
assumed
to
be
junior
and
10%
is
comprised
of
senior
hours.
This
translates
to
an
average
system
hourly
labor
rate
of:

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
13.
The
State
labor
rate
is
$
25.34
($
52,698/
2080
hours)
and
is
the
mean
Technical
labor
rate
based
on
a
recent
ASDWA
survey
that
was
completed
by
37
States.

Assumptions
Used
to
Develop
System
Costs
Lead
and
Copper
Tap
Monitoring
1.
Two
consecutive
six­
month
periods
of
monitoring
in
which
the
system
no
longer
exceeds,
counts
as
one
year
toward
the
three
years
of
consecutive
monitoring
needed
to
qualify
for
triennial
monitoring.
2.
PWS
Collection
burden
=
2.5
hours/
sample.
3.
Analytical
burden
=
1
hour
per
sample
and
includes
the
analysis
of
both
lead
and
copper.
4.
Analytical
cost
=
$
7.31.
The
commercial
fee
of
$
30
was
adjusted
to
eliminate
the
labor
component
to
avoid
double
counting,
as
all
analyses
are
assumed
to
be
performed
in­
house
(
i.
e.,
$
30
­
$
22.69).
5.
The
same
above
assumptions
are
used
in
the
baseline
and
revised
models.
The
difference
is
in
the
number
of
monitoring
events
and
the
monitoring
schedule.

Source
Water
Monitoring
1.
All
systems
are
assumed
to
be
monitoring
at
least
annually.
No
source
water
collection
burden
is
assumed
because
lead
and
copper
source
water
samples
are
assumed
to
be
collected
with
other
inorganic
chemicals,
such
as
nitrate.
2.
The
analytical
burden
is
assumed
to
be
1
hour
and
includes
the
analysis
of
both
lead
and
copper.
The
non­
labor
analytical
cost
for
materials
is
assumed
to
be
$
7.31.
3.
The
number
of
entry
points
was
is
shown
in
Table
1
below.
The
collection
burden
is
based
on
the
non­
composited
number
of
entry
points.
The
analytical
burden
and
cost
is
based
on
the
composited
number
of
entry
points.
June
1999
A­
5
4.
Sample
collection
for
large,
medium,
small
is
assumed
to
follow
the
standardized
monitoring
framework
under
the
Phase
II/
V
rules
and
scheduling
for
monitoring
is
assumed
to
be
based
on
system
size.
States
are
assumed
to
require
different
size
systems
to
monitor
during
different
years
of
the
compliance
period
or
cycle
to
better
balance
laboratory
workload.
Large
systems
are
assumed
to
monitor
in
the
first
year
of
the
compliance
period
or
cycle,
medium
systems
in
the
second
year
of
the
compliance
period
or
fifth
year
of
the
compliance
cycle,
and
small
systems
in
the
last
year
of
the
compliance
period
or
cycle.
5.
The
baseline
and
LCRMR
models
differ
in
that
the
LCRMR
model
incorporates
the
revision
which
allows
systems
for
which
source
water
treatment
is
not
required
to
reduce
source
water
monitoring.

Table
1
Number
of
Entry
Points
(
equals
number
of
samples)

System
Size
Ground
Water
Systems
Surface
Water
Systems
Not
Composited
Composited
Not
Composited
Composited
25­
100
1.2
1.2
1.3
1.3
101­
500
1.5
1.5
1.6
1.6
501­
1,000
1.9
1.9
1.9
1.9
1,001
­
3,300
2.4
2.3
1.9
1.9
3,301
­
10K
3.8
3.8
1.7
1.7
10,001
­
25K
7.5
7.3
1.9
1.9
25,001
­
50K
7.5
7.3
1.9
1.9
50,001
­
75K
13.6
13.3
4.7
4.6
75,001
­
100K
19.2
18.8
2.9
2.9
100,001
­
500K
36.3
35.6
3.4
3.3
500,001
­
1M
36.3
36.3
3.4
3.3
>
1
M
36.3
36
3.4
3.4
1.
The
number
of
non­
composited
entry
points
was
derived
from
a
1993
survey
sponsored
by
the
Association
of
State
Drinking
Water
Administrators
(
ASDWA).
2.
Compositing
was
based
on
an
ASDWA
and
General
Accounting
Office
report
entitled,
Flexibility
in
the
Safe
Drinking
Water
Act.
June
1999
A­
6
Water
Quality
Parameters
Monitoring
1.
The
number
of
entry
points
is
the
same
as
the
number
of
non­
composited
samples
shown
in
Table
1
above.
2.
The
WQP
collection
burden
will
be
applicable
to
those
systems
that
chlorinate
only
or
apply
no
treatment
(
i.
e.,
80%
of
ground
water
systems,
based
on
treatment
information
in
SDWIS)
and
is
0.5
hours
per
entry
point.
3.
Tap
WQP
samples
are
assumed
to
be
collected
with
lead
and
copper
tap
samples
or
coliform
samples
and
to
incur
no
additional
collection
burden.
4.
The
non­
labor
analytical
costs
per
tap
sample
=
$
51
for
initial
samples
(
i.
e.,
samples
collected
in
1992
for
large
and
medium
and
1993
for
small)
and
$
40
for
all
other
samples.
5.
The
non­
labor
analytical
cost
per
entry
point
sample
=
$
25.
6.
The
analytical
burden
per
WQP
tap
sample
is
2
hours
and
0.5
hours
per
entry
point
WQP
sample.
7.
The
same
above
assumptions
are
used
in
the
baseline
and
LCRMR
models.
The
difference
between
the
two
models
is
the
number
and
schedule
of
monitoring
events
and
the
number
of
entry
point
samples
collected
by
some
ground
water
systems.

Lead
Service
Line
Monitoring
1.
The
baseline
and
LCRMR
lead
service
line
monitoring
models
are
based
on
the
1988
AWWA
Lead
Information
Survey,
as
presented
in
the
1991
RIA.
These
models
retain
the
number
of
service
connections,
the
length
of
line
replaced,
and
the
number
of
lines
replaced.

2.
762
systems
will
be
required
to
replace
lead
service
lines
(
LSLs).
This
number
was
adjusted
from
the
8,281
systems
used
in
the
1991
RIA
because
fewer
systems
exceeded
the
lead
action
level
than
originally
projected.
This
derivation
is
presented
below
in
Table
2.

3.
Once
a
system
is
triggered
into
lead
service
line
replacement
(
LSLR),
the
models
assume
that
they
will
continue
replacing
lines
for
the
full
15
years.

4.
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
reduced
schedule):
a.
Monitoring
to
determine
whether
a
line
needs
to
be
replaced.
b.
Monitoring
required
because
only
a
portion
of
a
line
will
be
replaced.
As
a
simplifying
assumption,
all
replacement
is
assumed
to
be
a
partial
replacement.

5.
Based
on
samples
collected
at
LSLs,
systems
serving
>
100
people
will
only
be
required
to
replace
60%
of
their
lines;
those
serving
<
100
people
will
replace
all
of
their
lines.

6.
The
number
of
homes
served
by
LSLs
will
be
determined
by
multiplying
the
number
of
service
connections
by
2.3
(
EPA's
estimate
for
the
number
of
households
served
by
a
June
1999
A­
7
single
service
line).

7.
Under
the
baseline,
systems
replacing
a
portion
of
the
line
must
offer
to
collect
a
sample
from
each
homeowner
and
every
homeowner
is
assumed
to
accept
this
offer.
The
number
of
samples
is
assumed
to
equal
the
number
of
homes
served
by
LSLs
(
as
described
in
point
#
6
above).

8.
Under
the
revised
rule,
systems
replacing
a
portion
of
the
line
must
collect
a
sample
from
each
line.
The
number
of
samples
is
assumed
to
equal
the
number
of
service
connections.

9.
Each
sample
will
require
a
collection
burden
of
2
hours
and
an
analytical
burden
of
0.5
hours.
The
analytical
cost
is
estimated
to
be
$
3.65.
This
is
the
commercial
fee,
less
a
chemist's
labor
of
0.5
hours
to
conduct
the
analysis
(
i.
e.,
$
15
­
($
22.69
*
0.5
hrs)).

10.
For
the
baseline,
the
model
also
assumes
that
15
minutes
is
needed
to
offer
to
collect
the
sample/
inform
people
of
the
sample
results.
These
15
minutes
are
multiplied
by
the
number
of
samples
collected
(
equals
number
of
service
connections
*
number
of
household
served
by
the
connection
or
2.3).

11.
For
the
revised
rule,
15
minutes
is
needed
to
complete
notification
requirements
for
small
systems
and
medium
systems
and
0.5
hours
for
large
systems.
This
burden
is
multiplied
the
number
of
service
connections
*
number
of
household
served
by
the
connection
or
2.3.
1
The
1991
RIA
assumed
that
mobile
home
parks
(
MHPs)
use
mostly
PVC
pipes
and
should
be
excluded
from
the
LSL
replacement
analysis.
This
assumption
has
been
retained
in
this
current
analysis.
The
number
of
mobile
home
parks
(
MHPs)
was
derived
from
the
1995
Community
Water
System
Survey
(
CWSS).
The
CWSS
data
indicates
that
about
19.4%
of
small
ground
water
CWSs
and
about
3.2%
of
small
surface
water
CWSs
are
MHPs.
Therefore,
the
number
of
ground
water
CWSs
serving
serving
<
3,300
people
was
multiplied
by
80.6%
and
surface
water
systems
serving
<
3,300
people
was
multipled
by
96.8%
to
derive
the
number
of
CWSs
exclusive
of
MHPs.

For
this
analysis
ground
water
under
the
direct
influence
was
included
under
ground
water
systems.

2
The
percentage
of
systems
required
to
replace
LSLs
is
based
on
EPA's
current
estimate
of
the
number
of
systems
that
will
continue
to
exceed
the
lead
action
level
(
AL).

Based
on
initial
monitoring
conducted
by
medium
and
large
systems,
20%
of
these
systems
exceeded
the
lead
AL.
EPA
conservatively
estimated
that
25%
of
small
systems
would
exceed
the
lead
AL.
A
total
of
25%
of
systems
installing
treatment
were
estimated
to
continue
to
exceed
the
AL
after
treatment,
irrespective
of
size.
Therefore,
6.25%

(
25%*
25%)
of
all
systems
serving
<
3,300
and
5%
(
20%*
25%)
of
those
serving
>
3,300
people
are
expected
to
replace
LSLs.

A­
8
Table
2
Adjustment
to
Number
of
Systems
Replacing
Lead
Service
Lines
System
Size
#
of
CWSs
(
minus
MHPs)

1997
Inventory1
Exhibit
4­
6
from
the
1991
RIA
Adjusted
#
of
CWSs
with
LSLs
Adjusted
#
of
CWSs
Required
to
Replace
LSLs2
Column
A
Column
B
Column
C
Column
D
Column
E
(
D/
C*
A)
Column
F
(
D/
C*
B)
Column
G
(<
3.3K:
E*
6.25%)

(>
3.3K:
E*
5.0%)
Column
H
(<
3.3K:
F*
6.25%)

(>
3.3K:
F*
5.0%)
Column
I
(
G+
H)

Ground
Water
Surface
Water
Total
CWSs
#
w/
Lead
Pipes
Ground
Water
Surface
Water
Ground
Water
Surface
Water
Total
25­
100
12,285
1,211
18,753
2,731
1,789
176
112
11
123
101­
500
12,222
1,870
18,016
3,654
2,479
379
155
24
179
501­
1K
3,805
1,129
6,777
2,624
1,473
437
92
27
119
1K­
3.3K
4,682
2,360
7,690
2,984
1,817
916
114
57
171
3.3K­
10K
2,483
1,760
4,169
1,751
1,043
739
52
37
89
10K­
25K
946
969
1,737
764
416
426
21
21
42
25K­
50K
357
503
785
346
157
222
8
11
19
50K­
75K
102
187
300
132
45
82
2
4
6
75K­
100K
36
80
154
68
16
35
1
2
3
100K­
500K
68
218
255
159
42
136
2
7
9
500K­
1M
6
22
50
31
4
14
0
1
1
>
1M
1
14
17
11
1
9
0
1
1
Total
36993
10323
58703
15255
9282
3571
559
203
762
June
1999
A­
9
Public
Education
A.
General
1.
By
1999,
only
those
systems
that
continue
to
exceed
after
treatment
will
be
required
to
conduct
public
education.
This
equals
6.25%
of
small
systems
(
4,256),
5%
of
medium
(
356),
and
5%
of
large
systems
(
37),
for
a
total
of
4,649
systems.

2.
The
annual
PWS
burden
to
demonstrate
compliance
with
public
education
requirements
to
the
State
is
1
hour
and
is
calculated
as
part
of
the
system
reporting
burden/
cost
model.

B.
NTNCWSs
1.
NTNCWSs
will
buy
pre­
printed
materials
at
a
cost
of
$
0.27
for
systems
serving
25
to1,000
people;
$
0.24
for
systems
serving
1,001
to
3,300
people,
and
$
0.19
per
piece
for
systems
serving
>
3,300
people.
Costs
were
based
on
non­
member
prices
listed
in
the
1998
AWWA
bookstore
catalogue.

2.
No
NTNCWSs
>
50,000
will
be
required
to
conduct
public
education.
Based
on
the
January
1997
inventory
numbers,
only
1
NTNCWS
serves
>
50,000
people
and
it
is
assumed
to
be
below
the
lead
action
level.

3.
The
number
of
handouts
(
i.
e.,
brochures/
pamphlets)
is
assumed
to
equal
the
average
population
served
for
each
of
the
12
size
categories.

4.
0.5
hours
of
labor
per
year
are
assumed
to
distribute
handouts
and
to
post
in
central
locations.

C.
CWSs
1.
The
number
of
households
receiving
inserts
are
assumed
to
equal
the
average
population
served
for
a
given
size
category
divided
by
2.4
(
1990
census
figure
for
the
average
number
of
people
per
household).

2.
For
systems
serving
>
3,300
people,
the
number
of
pamphlets
and
brochures
was
estimated
at
a
ratio
of
31
schools
(
includes
preschool
of
3
years
through
high
school)
per
every
100,000
people
(
based
on
1990
census)
and
58.1
doctors
(
includes
pediatricians,
obstetricians,
and
family
practitioners)
per
100,000
people
(
based
on
information
from
the
American
Medical
Association).
For
systems
serving
<
3,300
people,
the
number
of
pamphlets
and
brochures
was
estimated
at
5.

4.
All
systems
will
purchase
materials
already
printed
from
AWWA.
The
costs
were
averaged
between
the
non­
member
and
member
prices
as
follows:

System
Size
Cost
to
Purchase
25
­
500
$
0.24
501
­
3,300
$
0.215
3,301
­
50,000
$
0.18
50,001
­
75,000
$
0.15
June
1999
A­
10
>
75,000
$
0.12
5.
50%
of
CWSs
are
assumed
to
mail
the
inserts
with
their
water
bills.
For
those
mailing
separately,
the
postage
cost
is
$
0.33
cents
per
addressee.
The
labor
burden
for
preparing
these
separate
mailings
is
based
on
the
assumption
used
to
develop
the
costs
and
burdens
for
public
education
and
public
notification,
as
presented
in
the
Public
Water
System
Supervision
Program
Public
Notification
and
Education
Requirements
ICR,
September
27,
1995,
as
follows:

<
500
=
15
hours
per
system
501­
3,300
=
25
hours
per
system
>
3,300
=
60
hours
per
system
 

6.
For
the
50%
of
systems
that
mail
the
materials
with
the
water
bill,
no
postage
is
assumed.
Systems
are
assumed
to
require
only
25%
of
the
time
they
would
have
needed
to
prepare
a
separate
mailing
as
follows:

<
500
=
15
hours
*
.25
=
3.75
hours
per
system
501­
3,300
=
25
hours
*
.25
=
6.35
hours
per
system
>
3,300
=
60
hours
*
.25
=
15
hours
per
system
7.
Systems
will
require
1
hour
to
prepare
and
mail
notification
to
newspapers,
radio
and
TV
stations.
Newspapers
are
assumed
to
run
the
public
education
materials
as
a
public
service
announcement,
free
of
charge.
Systems
are
assumed
to
incur
a
postage
cost
of
$
0.33
per
mailing.

6.
The
baseline
and
LCRMR
public
education
models
use
the
same
assumptions
described
above,
except
for
the
number
of
newspaper,
radio
and
TV
stations
that
will
receive
materials.
The
baseline
assumes
that
systems
serving
<
3,300
people
will
send
these
materials
to
a
total
of
3
newspapers,
radio,
or
TV
stations
and
that
systems
serving
>
3,300
people
will
send
these
materials
to
a
total
of
8
of
these
facilities.
The
LCRMR
also
assumes
that
systems
serving
>
3,300
people
will
send
materials
to
8
facilities,
but
that
States
will
not
require
systems
serving
<
3,300
people
to
deliver
public
service
announcements
or
send
notices
to
newspapers.

7.
The
models
do
not
quantify
changes
associated
with
alternative
language
for
NTNCWSs
and
special
CWSs,
allowing
flexibility
in
delivery
for
NTNCWSs,
or
State
flexibility
to
approve
minor
changes
in
language.
EPA
believes
that
these
changes
will
reduce
burden
and
cost
for
some
systems,
but
was
unable
to
quantify
these
reductions.
States
were
assumed
to
incur
a
small
burden
to
determine
which
systems
could
use
alternative
language
or
limit
their
delivery
of
materials.
States
were
assumed
to
make
a
blanket
decision
regarding
system
eligibility
and
to
have
a
data
system
that
could
facilitate
the
identification
of
applicable
systems
(
e.
g.,
prisons,
hospitals,
etc.)
June
1999
A­
11
System
Reporting
The
reporting
requirement
and
burden
are
presented
in
Table
3
below.
Unless
otherwise
stated,
the
assumptions
apply
to
both
the
baseline
and
LCRMR
models.

Table
3
System
Reporting
Assumptions
Reporting
Requirement
Burden
Reporting
of
lead
and
copper
monitoring
data*
1
hour
per
letter
(
includes
assemble
and
organizing
monitoring
results,
completing
the
certifications,
and
preparing
the
cover
letter
to
the
State)
AND
Burden
to
calculate
the
90th
percentile
levels
as
follows:+

Routine
Reduced
<
100
0.5
hrs
0.5
hrs
101­
500
0.75
hrs
0.5
hrs
501­
10K
1
hr
0.5
hrs
10­
100K
1.5
hrs
0.75
hrs
>
100K
2
hours
1
hour
The
LCRMR
assume
States
will
not
require
50%
of
systems
to
calculate
the
90th
percentile
level
(
percentage
is
based
on
information
collected
during
data
verifications
that
were
conducted
in
State
drinking
water
program
offices.).
In
addition,
this
model
assumes
a
10
minute
burden
reduction
per
submission
to
no
longer
complete
sample
collection
certifications
and
an
additional
10
minute
burden
reduction
to
no
longer
submit
sample
site
justifications.

Follow­
up,
routine,
and
reduced
WQP
Monitoring
Results*
Baseline:
4
hours
per
year
LCRMR:
4.33
hours
per
year
(
higher
burden
due
to
revised
procedure
for
determining
compliance
with
optimal
WQPs)

Changes
in
lead
and
copper
monitoring
location
1
hour
per
letter
per
monitoring
period
(
impacts
50%
of
CWSs
subsequent
to
initial
monitoring)

Request
for
reduced
monitoring
Baseline:
1
hour
per
request
LCRMR:
No
longer
applicable
Source
water
monitoring
results*
0.5
hours
per
monitoring
event
Public
education
compliance
letter*
1
hour
per
letter
Annual
LSLR
letter*
0.5
hours
per
letter
Letter
demonstrating
completion
of
partial
lead
service
line
activities*
0.5
hours
per
letter
(
LCRMR
only).
Assumes
75%
of
States
will
require
systems
replacing
LSLs
to
report
this
information
each
year.
Percentage
is
based
on
State
comments
received
on
the
April
1998
Notice
of
Data
Availability.
June
1999
Reporting
Requirement
Burden
A­
12
Explanation
of
changes
in
treatment
type
or
addition
of
a
new
source
0.5
hours
per
letter
(
LCRMR
only).
Assumes
2%
of
systems
conducting
reduced
monitoring
per
year
will
be
impacted.

Monitoring
waiver
application*
1
hour
per
application
(
LCRMR
only)

Demonstration
that
entry
point
locations
are
representative
of
water
quality*
1
hour
per
application
(
LCRMR
only)

Note:
Those
requirements
marked
with
an
"*"
are
assumed
to
incur
a
mailing
cost
of
$
0.33
cents
per
submission.
In
addition,
the
system
reporting
models
assume
that
the
following
activities
were
completed
prior
to
1999
and
therefore
are
not
included
in
the
ICR
burden
and
cost
estimates:
Optimal
corrosion
control
treatment
recommendations,
corrosion
control
study
submission,
certification
that
corrosion
control
treatment
has
been
installed,
and
certification
that
source
water
treatment
has
been
installed.

Assumptions
Used
to
Develop
State
Costs
General
1.
The
procedure
for
developing
State
costs
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
to
enable
States
to
estimate
the
resources
needed
to
fund
their
drinking
water
agencies
for
fiscal
years
(
FY)
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.

2.
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.

3.
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.

4.
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
percentages
are:

Supervision
10%
Clerical
11%
On­
going
Training
for
State
personnel
1.9%


A
comprehensive
list
of
activities
and
assumptions
is
presented
in
Table
4
below.
Unless
otherwise
noted,
assumptions
apply
to
both
the
baseline
and
LCRMR
State
oversight
models.
June
1999
A­
13
Table
4
State
Oversight
Assumptions
Activity
Burden
Regulatory
Adoption
0.25
FTEs
in
1999
per
State
(
LCRMR
only)

Training
specific
to
the
LCRMR
375
hours
in
1999
per
State
(
LCRMR
only)

Lab
Certification
472
hours
per
year
for
baseline
and
LCRMR
Notify
systems
of
requirements
Baseline:
472
hours
per
year
LCRMR:
674
hours
in
1999;
472
hours
each
year
thereafter
Update
data
system
to
accommodate
reporting
of
new
milestones
Baseline:
Not
applicable
LCRMR:
0.6
FTEs
+
$
75,000
in
contractor
assistance
per
36
States.
33%
of
burdens/
costs
incurred
in
1999
and
67%
in
2000.

Note:
Remaining
20
States
will
use
SDWIS/
State
and
cost
to
modify
the
data
system
will
be
borne
by
EPA.

State­
employed
corrosion
control
expert
0.5
FTEs
to
1.5
FTEs
based
on
total
number
of
systems
in
the
State
Review
of
reasons
for
changes
in
lead
and
copper
tap
sampling
location
10
minutes
per
letter
Review
of
results
of
tap
and
WQP
follow­
up
samples
and
set
WQP
levels
12
hours
per
PWS
(
small
and
medium
systems
only).
Review
of
these
data
for
large
systems
was
completed
before
1999.

Review
of
routine/
reduced
lead
and
copper
tap
sample
results
1
hour
per
monitoring
event
For
LCRMR,
also
assumes
that
State
will
calculate
90th
percentile
levels
for
50%
of
the
systems
as
follows:

Routine
Reduced
25­
500
0.17
hrs
0.17
hrs
501­
3.3K
0.5
hrs
0.25
hrs
3.3­
10K
1
hr
0.5
hrs
10­
100K
1.5
hrs
0.75
hrs
>
100K
2
hours
1
hour
Review
of
routine/
reduced
tap
and
entry
point
WQP
sample
results
Baseline:
6.5
hours
per
year
LCRMR:
6.83
hours
per
year
Review
of
source
water
monitoring
results
0.5
hours
per
monitoring
event
Review
of
public
education
compliance
letters
20
minutes
per
letter
Review
request
to
delete
reference
to
homeowner's
plumbing
from
mandatory
language
0.5
hours
per
request
(
LCRMR
only)
June
1999
Activity
Burden
A­
14
Review
of
annual
LSLR
letter
0.5
hours
per
letter
Review
of
partial
LSLR
letter
0.5
hours
per
letter
(
LCRMR
only)

Review
of
changes
in
treatment
or
addition
of
new
source
0.5
hours
per
letter
(
LCRMR
only)

Review
of
system
request
for
NTNCWSs
and
special
CWSs
to
use
non­
first
draw
samples
45
minutes
per
system
(
LCRMR
only).

Specify
reduced
sampling
sites
0.5
hours
per
systems
(
LCRMR
only)
Will
apply
to
20%
of
systems
serving
>
100
people
Demonstration
that
entry
point
locations
are
representative
of
water
quality
0.5
hours
per
application
(
LCRMR
only).
Applies
to
medium
and
large
ground
water
systems
only
Review
monitoring
waiver
requests
0.5
hours
per
application
(
LCRMR
only)

Enforcement
1
hour
per
system
in
violation.
The
number
of
systems
in
violation
is
expected
to
decrease
under
the
LCRMR
due
to
changes
in
monitoring
and
treatment
technique
requirements.
(
Refer
to
Violation
Rate
discussion
in
the
State
reporting
section
below)

State
Reporting
1.
For
each
record
(
e.
g.,
one
milestone,
one
violation,
or
one
enforcement
action),
the
State
will
require
0.5
hours
to
the
record
to
SDWIS.
The
exception
is
when
the
new
"
Done"
and
"
Deemed"
milestones
or
the
"
Deemed"
and
LSLR
can
be
reported
during
the
same
reporting
period
for
a
given
system.
In
this
case,
the
combined
burden
is
40
minutes
to
report
these
two
milestones.

2.
The
effort
associated
with
reporting
a
system's
compliance
with
its
lead
service
line
replacement
schedule,
that
was
required
under
the
LCR
is
assumed
to
be
2
hours
per
report.
States
are
assumed
to
submit
this
report
during
January
and
July
because
some
systems
will
be
on
a
January
through
December
replacement
schedule
and
others
on
a
July
through
June
replacement
schedule.
This
burden
is
only
included
in
the
baseline
State
reporting
model.

3.
Under
the
LCRMR
model,
States
are
assumed
to
report
the
"
Deemed"
milestone
for
all
systems
sometime
in
the
2000
through
2001
time
frame.
The
"
Done"
milestone
is
also
assumed
to
be
reported
during
these
two
years
for
all
systems
except
those
replacing
lead
service
lines.
Those
systems
are
not
expected
to
be
"
done"
until
sometime
outside
the
2009
time
frame.

4.
The
procedure
for
estimating
violations
is
as
follows:

a.
For
each
type
of
monitoring
and
reporting
(
M/
R)
and
treatment
technique
(
TT)
June
1999
A­
15
violation
and
for
each
of
the
three
system
size
categories
(
as
defined
by
the
LCR),
EPA
estimated
a
violation
rate
for
each
year.
EPA
used
best
professional
judgment
in
estimating
these
rates
because
these
data
are
not
consistently
available
in
SDWIS.

b.
The
estimated
violation
rates
were
multiplied
by
the
number
of
systems
that
could
incur
a
particular
violation
type.
For
example,
in
1999
the
baseline
lead
and
copper
tap
monitoring
model
assumes
that
62,986
small
systems
will
conduct
lead
and
copper
tap
monitoring.
Therefore,
the
estimated
violation
rate
for
small
systems
for
failure
to
conduct
lead
and
copper
tap
monitoring
would
only
apply
to
these
62,986
systems.

c.
The
number
of
systems
in
violation
for
each
type
of
M/
R
violation
were
summed
for
a
given
year
by
size
category.
Systems
were
assumed
to
incur
one
type
of
M/
R
violation
per
year.
M/
R
violators
were
summed
separately
from
TT
violators.
The
total
number
of
M/
R
violators
for
a
given
size
category
was
divided
by
the
total
number
of
systems
in
that
size
category
to
yield
an
overall
M/
R
violation
rate
for
that
size
category.
The
percentages
were
then
rounded
to
the
nearest
5%.
The
same
procedure
was
followed
to
determine
an
overall
TT
violation
rate
per
year
per
size
category.
An
example
of
this
calculation
is
presented
for
small
systems
under
the
current
LCR
in
Table
5
below:

Table
5
Example
Annual
M/
R
Violation
Rate
Calculation
for
Small
Systems
in
1999
M/
R
violation
type
No.
of
systems
monitoring
Estimated
violation
rate
per
monitoring
period
(
mp)
No.
of
violators
Lead/
copper
tap
62,986
30%
5107
*.
30
*
2
mp
=
21,960
Entry
point
WQP
5,107
40%
(
1277
*
.40
*
2
mp)
+
(
3830
*
.40)
=
2,554
Tap
WQP
5,107
30%
(
3830
*
.30)
+
(
1277
*
.30
*
2
mp)
=
1,915
Source
water
1,003
25%
251
Total
number
of
violators
26,680
Note:
Systems
multiplied
by
2
monitoring
events
were
on
semi­
annual
monitoring.

The
number
of
violations
is
divided
by
the
total
number
of
small
systems
to
yield
an
annual
violation
M/
R
rate.
In
this
example,
26,680
is
divided
by
68,093
to
equal
a
39%
violation
rate.
When
rounded
to
the
nearest
5
percent,
the
1999
M/
R
violation
rate
for
small
systems
is
estimated
to
be
40%.

Tables
6
and
7
below
presents
the
annual
violation
rate
assumptions
used
to
develop
annual
violation
rates
for
the
baseline
and
LCRMR
models,
respectively.
June
1999
A­
16
Table
6
M/
R
Violation
Percentages
(
Apply
to
both
the
Baseline
and
LCRMR
Models)

Violation
Type
System
Size
Small
Medium
Large
Lead
and
Copper
Tap
30%
each
mp
in
1999­
2001
&
25%
in
2002­
2009
10%
each
year
10%
each
year
Entry
Point
WQP
40%
each
mp
in
1999;
35%
each
mp
in
2000;
&
30%
each
mp
in
2001­
2009
20%
each
mp
5%
each
mp
Tap
WQP
30%
each
mp
in
1999;
25%
each
mp
in
2000­
2009
15%
each
mp
5%
each
mp
Source
Water
25%
each
year
10%
each
year
5%
each
year
Table
7
Treatment
Technique
Violation
Percentages
(
Assumptions
apply
to
both
baseline
and
LCRMR
models
unless
otherwise
noted)

Violation
Type
System
Size
Small
Medium
Large
Optimal
entry
point
noncompliance
(
Baseline
only)
25%
each
mp
in
1999;
25%
in
1st
half
of
2000;
20%
in
2nd
half
of
2000
&
each
mp
in
2001­
2009
20%
in
1st
half
of
1999;
15%
in
2nd
half
of
1999
&
each
mp
in
2000­
2009
10%
each
mp
Optimal
Tap
Noncompliance
(
Baseline
only)
25%
each
mp
in
1999;
20%
each
mp
in
2000­
2009
20%
in
1st
half
of
1999;
15%
in
2nd
half
of
1999
&
each
mp
in
2001
­
2009
10%
each
mp
Compliance
with
optimal
WQPs
(
LCRMR
only)
Assumes
the
2
current
violations
for
failure
to
meet
OWQPs
(
i.
e.,
optimal
entry
point
noncompliance
and
optimal
tap
noncompliance)
will
be
reported
as
1
violation
type
under
the
LCRMR.

25%
each
mp
in
1999;
25%
in
1st
half
of
2000;
20%
in
2nd
half
of
2000
&
each
mp
in
2001­
2009
20%
in
1st
half
of
1999;
15%
in
2nd
half
of
1999
&
each
mp
in
2000­
2009
10%
each
mp
MPL
noncompliance
0%
0%
0%
June
1999
Violation
Type
System
Size
Small
Medium
Large
A­
17
Lead
Service
Line
Replacement
75%
each
year
45%
in
1999;
40%
in
2000­
2009
45%
in
1999;
40%
in
2000;
&
30%
in
2001­
2009
Public
Education
30%
each
year
10%
each
year
10%
each
year
The
resulting
violation
rates
are
presented
in
the
Tables
8
and
9
below.

Table
8
Violation
Rate
­
Baseline
Year
1999
2000
2001
2002
2003
2004
System
Size
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
Small
40%
5%
15%
10%
15%
10%
25%
5%
10%
5%
10%
5%

Medium
5%
5%
5%
5%
10%
5%
5%
5%
5%
5%
10%
5%

Large
25%
35%
25%
35%
20%
25%
10%
25%
15%
25%
20%
25%

Year
2005
2006
2007
2008
2009
System
Size
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
Small
25%
5%
10%
5%
5%
5%
25%
5%
10%
5%

Medium
5%
5%
5%
5%
10%
5%
5%
5%
5%
5%

Large
10%
15%
10%
15%
20%
25%
10%
15%
10%
15%
June
1999
A­
18
Table
9
Violation
Rate
­
LCRMR
Year
1999
2000
2001
2002
2003
2004
System
Size
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
Small
35%
5%
15%
5%
15%
5%
25%
5%
10%
5%
10%
5%

Medium
5%
5%
5%
5%
10%
5%
5%
5%
5%
5%
10%
5%

Large
20%
15%
25%
15%
20%
15%
10%
15%
15%
15%
20%
15%

Year
2005
2006
2007
2008
2009
System
Size
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
M/
R
TT
Small
25%
5%
10%
5%
5%
5%
20%
5%
10%
5%

Medium
5%
5%
5%
5%
10%
5%
5%
5%
5%
5%

Large
10%
15%
10%
15%
15%
15%
10%
15%
15%
15%

Note:
The
relatively
high
M/
R
and
TT
violation
rate
for
large
systems
is
primarily
attributed
to
the
fact
that
more
large
systems,
on
a
percentage­
basis
are
conducting
activities
that
could
results
in
a
TT
violation,
most
notably
collecting
WQPs
and
meeting
OWQP
ranges.

State
Record
Keeping
States
are
assumed
to
maintain
a
subset
of
information
in
both
their
hard
copy
files
and
their
data
system.
The
burden
to
enter
these
data
into
the
State
data
system
is
assumed
to
be
0.5
hours
per
system
per
record.
Because
EPA
assumes
that
systems
would
exceed
during
the
first
round
of
monitoring
and
would
adhere
to
the
schedule
of
outlined
in
the
LCR,
some
of
the
data
are
assumed
to
already
have
been
entered
into
the
State
system
by
1999
and
are
not
included
in
the
ICR
estimates.
Table
10
provides
a
listing
of
data
that
States
are
assumed
to
maintain
in
their
data
systems
during
the
ICR
period
of
1999­
2001.
This
exhibit
also
provides
a
listing
of
those
activities
that
are
assumed
to
be
completed
before
1999.
June
1999
A­
19
Table
10
Listing
of
Information
that
States
Maintain
in
Data
System
Occurs
during
ICR
period
Occurs
prior
to
1999
(
not
included
in
ICR)

90th
percentile
lead
and
copper
exceedances
and
non­
exceedances
for
each
round
of
tap
monitoring
Note:
0.5
hours
is
assumed
to
cover
data
entry
of
both
the
lead
and
copper
values).
(
b)(
2)
&
(
b)(
3)
designation
Note:
EPA
expects
that
the
State
will
need
to
revise
the
(
b)(
3)
designation
for
only
a
few
systems
beyond
1999,
but
that
the
impact
is
not
significant
enough
to
have
included
in
the
record
keeping
model.

System's
qualifying
for
annual
and
triennial
tap
monitoring.
Corrosion
control
study
required
System's
qualifying
for
monitoring
waivers
and
their
renewals
(
LCRMR
only).
Corrosion
control
study
completed
Optimal
water
quality
parameter
ranges
or
values.
State
decision
regarding
the
type
of
corrosion
control
treatment
to
be
installed
System's
qualifying
for
reduced
WQP
monitoring
(
i.
e.,
semiannual
monitoring
at
a
reduced
number
of
sites,
annual
monitoring,
and
triennial
monitoring)
or
when
WQP
monitoring
is
no
longer
required.

Note:
For
systems
serving
<
10,000
people
that
qualify
for
reduced
WQP
monitoring,
the
system
cannot
reduce
the
number
of
tap
WQP
locations,
therefore,
the
State
is
not
assumed
to
enter
information
into
the
system
for
these
systems
until
they
qualify
for
annual
and
triennial
monitoring.
System's
installation
of
corrosion
control
treatment
System's
qualifying
for
reduced
source
water
monitoring
or
no
longer
required
to
monitor.
State
determination
regarding
source
water
treatment
System
required
to
begin
lead
service
line
replacement
and
the
replacement
rate.
System's
installation
of
source
water
treatment
All
violations.
Maximum
permissible
source
water
levels
Enforcement
actions
(
notices
of
violation,
compliance
schedules,
and
referrals
to
Department
of
Justice).

No
additional
record
keeping
burden
is
estimated
to
record
the
"
Done"
and
"
Deemed"
milestones
under
the
LCRMR
because
this
information
is
assumed
to
exist
elsewhere
in
the
data
base
or
State
files.
The
remainder
of
the
information
for
which
States
must
maintain
records
is
assumed
to
be
kept
in
hard
copy
only.
The
burden
to
maintain
the
State
hard
copy
files
is
assumed
to
be
covered
under
overhead
costs
which
include
costs
for
clerical
staff.
June
1999
APPENDIX
B
Year­
by­
Year
Burden
Estimates
for
Systems
and
States
June
1999
B­
1
APPENDIX
B
Annual
System
and
State
Burden
Differences
in
Hours
between
the
Revised
Baseline
and
LCRMR
for
1999
through
2003
(
Numbers
in
parentheses
represent
a
burden
reduction)

PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
Initial
Activities
Read
regulations/
Regulatory
Adoption:
System
burden
303,780
0
0
0
0
60,756
None.
These
activities
are
assumed
to
be
completed
in
1999.
Each
system
requires
4
hours
in
1999
to
read
the
rule
revisions.

Each
State
will
need
0.25
FTEs
in
1999
for
adoption
of
the
revised
regulation.

State
burden
29,120
0
0
0
0
5,824
Training/
Overhead
Adjustment:

System
burden
303,780
0
0
0
0
60,756
Training
activities
are
assumed
to
be
completed
in
1999.

Average
annual
State
burden
increase
equals
681
hours
for
these
6
years.
Each
system
requires
4
hours
in
1999
to
attend
training
on
the
revisions
to
the
rule.

Each
State
will
require
375
hours
of
rule­
specific
training
in
1999.

Overhead
adjustment
assumes
changes
to
needs
in
supervisory
staff,

clerical,
and
training
based
on
the
number
of
FTEs
estimated
to
support
the
revised
rule.

State
burden
30,174
9,262
5,650
(
609)
1
8,896
Modify
State
data
system
to
accommodate
new
requirements:
System
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
None.
Activity
is
assumed
to
be
completed
by
the
end
of
2000.
36
States
will
require
$
75,000
in
contractor
support
and
0.6
FTEs
to
revise
their
data
system
to
accommodate
the
new
reporting
requirements.
Assumes
33%
of
this
activity
will
occur
in
1999
and
the
remaining
67%
will
occur
in
2000.

State
burden
14,976
29,952
0
0
0
8986
Notify
system
of
new
requirements:
System
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
None.
The
increase
in
burden
to
notify
systems
of
new
requirements
is
assumed
to
occur
in
1999
only.
In
1999,
each
State
is
assumed
to
require
202
additional
hours
to
notify
systems
of
the
new
requirements
under
the
LCRMR.
For
each
year
thereafter,
the
burden
is
assumed
to
be
the
same
as
what
would
have
been
needed
under
the
LCR.

State
burden
11,312
0
0
0
0
2262
June
1999
PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
B­
2
Tap
Monitoring
Requirements
Allow
use
of
non­
first­
draw
samples
and
State
flexibility
to
require
up­
front
approval:

System
burden
0
0
0
0
0
0
None.
Assumes
onetime
determination
completed
in
1999.
1,000
water
systems
will
request
State
permission
to
use
non­

firstdraw
samples.

System
transaction
cost
to
request
this
flexibility
is
more
than
offset
by
cost
to
shut
down
operations
to
provide
first­
draw
samples.

Assumes
45
minutes
for
State
transaction
burden.

State
burden
750
0
0
0
0
150
State
flexibility
to
specify
reduced
monitoring
sites:

System
burden
0
0
0
0
0
0
None.
Assumes
activity
would
be
completed
by
the
end
of
2001.
States
will
designate
reduced
sampling
sites
for
9,847
systems
in
total
(
i.
e.,
20%
of
the
49,239
systems
serving
>
100
people).

Assumes
0.5
hours
for
State
transaction
burden.

No
system
cost
is
assumed
because
the
system
is
not
required
to
submit
any
documentation
in
response
to
this
revision.

State
burden
4,370
476
78
0
0
985
Alternative
monitoring
schedule
for
systems
on
reduced
monitoring:

System
burden
(
3,190)
(
853)
(
246)
(
2,640)
(
770)
(
1,540)
Average
annual
system
reduction
in
burden
is
1,164
hours
for
these
6
years.
Under
the
LCR,
the
112
NTNCWSs
that
did
not
operate
during
the
summer
months
are
assumed
to
have
required
5.5
additional
hours
to
collect
each
lead
and
copper
tap
sample.
The
number
of
NTNCWSs
is
based
on
SDWIS
(
4/
23/
99).

No
impact
to
States
is
assumed
because
States
are
assumed
to
make
blanket
decisions
regarding
which
systems
should
conduct
reduced
monitoring
during
other
than
summer
months
and
to
have
data
bases
that
will
allow
them
to
easily
identify
NTNCWSs
that
do
not
operate
during
the
summer
months.
States
are
also
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.

State
burden
0
0
0
0
0
0
Continued
monitoring
for
(
b)(
3)

systems:
System
burden
0
23,905
0
0
23,905
9,562
Systens
will
monitor
in
2006
and
2009.

The
average
system
burden
increase
over
the
6
years
is
7,968
hours
and
the
average
increase
in
State
burden
is
57
hours.
Assumes
that
under
the
1991
LCR
that
all
(
b)(
3)
systems
would
not
have
continued
monitoring
after
initial
monitoring.
The
lead
and
copper
monitoring
model
projects
that
systems
will
now
monitor
during
2000,
2003,
2006,
and
2009
and
will
incur
an
average
collection/
analytical
burden
of
3.5
hours
per
sample.

States
will
require
1
hour
to
review
each
set
of
monitoring
results
and
associated
documentation.

State
burden
0
171
0
0
171
68
June
1999
PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
B­
3
Accelerated
reduced
lead
and
copper
monitoring
provisions:

System
burden
(
126,700)
(
111,632)
74,323
70
(
74,462)
(
47,680)
Average
reduction
in
burden
for
systems
and
States
for
these
six
years
is
estimated
to
be
70
and
171
hours,
respectively.
Would
benefit
20%
of
large
"
non­
b3"
systems
and
20%
of
those
medium
and
small
systems
required
to
install
treatment
for
a
total
of
4,554
systems.
These
systems
would
conduct
8,841
fewer
monitoring
events
in
total
from
1999­
2009.

Systems
and
States
would
experience
an
increase
in
burden
in
2001
and
2002
because
the
LCRMR
monitoring
model
predicts
that
more
systems
will
monitor
during
these
years
than
the
baseline
model.

Only
a
slight
increase
in
system
burden
is
estimated
in
2002
because
the
baseline
model
assumes
that
more
medium
systems
will
monitor
during
2002
than
the
LCRMR
model.
Due
to
the
difference
in
the
number
of
samples
that
must
be
collected
and
analyzed
for
small
and
medium
systems,
the
net
result
is
that
20
more
samples
will
be
collected
and
analyzed
under
the
LCRMR
than
the
baseline
model.

This
translates
to
70
hours
(
i.
e.,
2.5
hours
for
collection
and
1
hour
per
analysis
per
sample).

States
will
no
longer
review
the
8,841
rounds
of
monitoring
from
1999­
2009
at
a
burden
of
1
hour
per
monitoring
event.

State
burden
(
3,531)
(
4,287)
2,397
755
(
3,152)
(
1,564)

Monitoring
waivers
for
small
systems:
System
burden
(
141,923)
0
0
(
148,732)
0
(
58,131)
Systems
are
assumed
to
submit
a
revised
application
in
2005
and
to
monitor
in
2008.
The
average
system
and
State
burden
reduction
over
the
6
years
is
23,654
hours
and
567
hours,

respectively.
Assume
10%
of
small
systems
(
6,809
systems)
would
qualify
for
a
full
monitoring
waiver,
with
a
net
reduction
of
3
monitoring
events
per
system
during
1999­
2009.
The
number
of
systems
that
qualify
for
a
partial
waiver
was
not
quantified;
however,
these
systems
will
save
0.5
hours
in
analytical
burden
for
each
lead
or
copper
sample
that
would
have
been
analyzed.

The
burden
associated
with
applying
for
a
full
or
partial
waiver
is
1
hour.
States
are
assumed
to
require
0.5
hours
to
review
these
applications.
Systems
are
assumed
to
submit
an
applications
in
1999
and
2005.
For
systems
applying
for
a
full
waiver,
this
translates
to
a
total
system
burden
of
6,809
hours
and
a
total
State
burden
of
3,405
hours
per
waiver
application.
The
system
and
State
burden
in
1999
is
the
savings
in
monitoring
burden
net
of
the
burden
to
apply
for
or
review
a
full
monitoring
waiver
application.

State
burden
(
3,405)
0
0
(
6,809)
0
(
2,043)
June
1999
PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
B­
4
Water
Quality
Parameter
(
WQP)
Monitoring
Requirements
Accelerated
reduced
monitoring
for
WQPs:
System
burden
(
3,712)
(
7,424)
(
3,712)
0
(
3,712)
(
3,712)
Large
systems
on
accelerated
WQP
monitoring
will
collect
WQP
tap
samples
in
2005
and
2008.
The
same
112
large
systems
that
qualify
for
accelerated
reduced
lead
and
copper
monitoring
qualify
for
accelerated
reduced
WQP
monitoring.
Would
save
the
analytical
burden
associated
with
a
total
of
5
rounds
of
monitoring
per
system.
No
sample
collection
burden
reduction
is
estimated
because
tap
WQPs
are
assumed
to
be
collected
with
lead
and
copper
tap
samples
or
coliform
samples.

Minimal
impact
on
States
expected
because
this
revision
will
not
impact
the
number
of
entry
point
monitoring
events,
which
constitutes
most
of
the
WQP
monitoring
data.

State
burden
0
0
0
0
0
0
WQP
monitoring
at
representative
entry
points
by
ground
water
systems:

System
burden
(
39,078)
(
41,263)
(
41,263)
(
41,263)
(
41,263)
(
40,826)
Systems
continue
to
incur
a
monitoring
burden
reduction
of
41,263
hours
per
year.
The
number
of
WQP
entry
points
samples
are
assumed
to
decrease
by
67%
for
the
157
large
ground
water
systems
and
by
50%
for
the
240
medium
ground
water
systems
required
to
conduct
WQP
monitoring.

Based
on
the
method
for
calculating
State
burden
associated
with
the
review
of
WQP
monitoring
data
of
3.42
hours
per
6­
month
monitoring
period,
no
reduction
in
burden
or
cost
is
assumed
because
the
revision
does
not
change
the
number
of
WQP
entry
point
monitoring
events.

Systems
are
assumed
to
require
1
hour
to
prepare
a
request
for
this
reduction
in
monitoring
locations
and
0.5
hours
for
the
State
to
review
this
request.
This
equals
a
total
system
burden
of
397
hours
and
a
State
burden
of
199
hours.
The
system
monitoring
burden
savings
shown
in
this
table
for
1999
are
net
of
monitoring
burden
to
apply
to
the
State
to
use
representative
entry
points.

State
burden
199
0
0
0
0
40
Source
Water
Monitoring
Requirements
Reduction
in
source
water
monitoring
for
system
not
required
to
install
SOWT:

System
burden
(
1,408)
(
1,408)
(
1,408)
(
1,708)
(
2,534)
(
1,693)
System
burden
reduction
ranges
from
1,408
hours
to
7,972
hours
for
these
years.

State
burden
reduction
ranges
from
392
to
2,573
hours
for
these
years.
Assume
all
systems
that
exceed
but
are
not
required
to
install
source
water
treatment
(
SOWT)
or
a
total
of
5,384
systems
will
now
be
allowed
to
go
on
reduced
source
water
monitoring.

System
burden
reduction
is
due
to
labor
associated
with
analyzing
fewer
samples.
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.
States
would
have
required
0.5
hours
to
review
each
set
of
source
water
monitoring
data.

State
burden
(
604)
(
392)
(
393)
(
399)
(
427)
(
443)
June
1999
PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
B­
5
Public
Education
Delivery
Public
Education
Delivery
requirements:
System
burden
(
5,966)
(
5,966)
(
5,966)
(
5,966)
(
5,966)
(
5,966)
System
burden
reduction
continues
at
the
same
level
for
these
years.
The
reduction
in
burden
is
estimated
for
small
CWSs
to
omit
newspaper
notification
and
public
service
announcement.
Some
burden
reduction
is
also
expected
for
NTNCWSs
regarding
flexibility
in
the
delivery
method
and
use
of
mandatory
language
that
is
better
suited
to
their
facilities,
for
special
CWSs
that
can
deliver
like
NTNCWSs,
and
for
small
CWSs
to
deliver
public
education
materials
to
a
more
targeted
audience.
The
impact
of
these
revisions
however
could
not
be
quantified.
For
a
discussion
of
the
impact
of
the
revised
public
education
reporting
requirements,

refer
to
page
B­
8.

State
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Request
to
remove
reference
to
building
permit
availability:

System
burden
0
0
0
0
0
0
None.
This
activity
is
assumed
to
be
completed
by
2000.
Assumes
10%
of
CWSs,
required
to
deliver
public
education
(
337
systems),
will
request
permission
to
delete
reference
to
building
permit
record
availability
from
their
mandatory
language.
The
burden
to
request
this
information
is
assumed
to
be
more
than
offset
by
the
time
the
system
would
have
needed
to
respond
to
inquiries
concerning
records
they
do
not
have.

States
are
assumed
to
require
0.5
hours
to
review
each
request.

State
burden
0
169
0
0
0
34
Partial
LSL
monitoring
requirements:
System
burden
(
76,696)
(
79,752)
(
79,752)
(
79,752)
(
79,752)
(
79,141)
The
system
will
continue
to
save
79,752
hours
during
these
years.
System
burden
reduction
is
due
to
the
collection
of
samples
after
partial
lead
service
line
replacement
at
each
line
instead
of
at
each
customer's
home.
The
State
burden
associated
with
the
review
of
documentation
that
demonstrates
compliance
with
partial
lead
service
line
requirements
is
discussed
under
System
Reporting
Requirements
on
page
B­
8.

State
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Partial
LSL
notification
requirements:
System
burden
8,411
8,411
8,411
8,411
8,411
8,411
The
system
will
continue
to
incur
a
burden
of
8,411
each
year.
Large
systems
are
assumed
to
require
15
additional
minutes
to
complete
the
partial
lead
service
line
replacement
notification
requirements
under
the
LCRMR
than
under
the
LCR.

State
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
June
1999
PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
B­
6
State
Reporting
Requirements
to
EPA
Changes
to
Federal
reporting
requirements
Report
90th
percentile
lead
levels
for
large/
medium
PWSs:

System
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Burden
increase
continues
to
range
between
209
hours
and
3,106
hours
State
are
estimated
to
report
a
total
of
24,288
additional
records
to
SDWIS
from
1999
­
2009
at
0.5
hours
per
record.

State
burden
692
411
3,106
367
209
957
Changes
to
milestone
reporting
and
the
deletion
of
the
LSL
compliance
letter:

System
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
The
estimated
reduction
in
burden
remains
at
224
hours
for
these
years.
The
reduction
in
1999
is
due
to
the
deletion
of
the
WQP
milestone
and
elimination
of
the
requirement
for
States
to
report
those
systems
in
compliance
with
their
LSLR
schedules.
The
overall
increase
in
State
reporting
costs
in
2000
and
2001
are
due
to
the
reporting
of
the
new
"
Done"
and
"
Deemed"
milestones.

State
burden
(
2,195)
24,410
24,957
(
224)
(
224)
9,345
Changes
in
violation
and
enforcement
reporting
System
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
The
average
burden
reduction
is
estimated
to
be
607
hours
for
these
six
years.
The
number
of
violations
and
enforcement
actions
is
expected
to
decline
in
some
years
due
to
a
reduction
in
monitoring
due
to
accelerated
reduced
monitoring
and
monitoring
waivers.
The
number
of
treatment
techniques
are
also
expected
to
decline
because
more
systems
should
be
able
to
comply
with
optimal
WQPs.
Burden
is
0.5
hours
per
record
to
report
the
data
to
SDWIS.

State
burden
(
3,679)
(
4,457)
(
4,365)
(
93)
(
93)
(
2,537)

State
Record
Keeping
Changes
in
reporting
to
State
data
base:
System
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
The
average
burden
reduction
over
these
six
years
is
estimated
to
be
1,371
hours.
States
are
assumed
to
maintain
a
subset
of
data
in
their
data
bases
such
as;
90th
percentile
lead
and
copper
values,
reduced
monitoring
schedules,
milestones,
OWQP
values
or
ranges,
MPLs,
violations,

and
enforcement
actions.
Burden
is
0.5
hours
to
report
each
systemspecific
record
to
the
State
data
base.

States
are
assumed
to
also
maintain
paper
copies
of
a
larger
set
of
data.
The
burden
associated
with
maintaining
paper
files
is
captured
under
overhead
(
clerical
staff).

Note:
System
record
keeping
costs
are
included
with
reporting
burden.

State
burden
(
11,454)
(
8,013)
(
4,202)
(
3,344)
(
1,618)
(
5,726)
June
1999
PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
B­
7
Enforcement
Changes
in
State
enforcement
due
to
changes
in
M/
R
and
TT
violation
rates:
System
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
The
average
burden
reduction
over
these
six
years
is
estimated
to
be
592
hours.
Enforcement
includes
issuing
NOVs
and
ensuring
public
notice
was
provided.

As
discussed
previously,
the
violation
rates
will
decrease
in
some
years
due
to
a
reduction
in
monitoring
and
changes
to
the
criteria
for
determining
compliance
with
optimal
WQPs.

State
burden
(
3,588)
(
3,551)
(
3,478)
(
74)
(
74)
(
2,153)

System
Reporting
Requirements
Impact
resulting
from
direct
changes
to
141.90
Eliminate
certification(
s)

pertaining
to
first­
draw
and
customer­
collected
samples:

System
burden
(
10,867)
(
2,943)
(
2,891)
(
7,972)
(
1,743)
(
5,283)
Average
system
burden
reduction
over
these
six
years
is
estimated
to
be
4,002
hours.
Systems
are
assumed
to
have
required
10
minutes
to
prepare
these
certification.

Minimal
impact
on
States
is
expected
to
no
longer
review
certifications
because
the
major
focus
of
the
review
will
be
the
lead
and
copper
monitoring
data.

State
burden
0
0
0
0
0
0
Eliminate
justification(
s)

pertaining
to
non­
tier
1
sites
and
insufficient
LSL
sites:

System
burden
(
3,853)
(
1,063)
(
1,165)
(
2,813)
(
629)
(
1,905)
Average
system
burden
reduction
over
these
six
years
is
estimated
to
be
1,465
hours.
Systems
are
assumed
to
have
required
10
minutes
to
prepare
these
justifications.

Minimal
impact
on
States
is
expected
to
no
longer
review
these
justifications
because
the
major
focus
of
the
review
will
be
the
lead
and
copper
monitoring
data.

State
burden
0
0
0
0
0
0
Eliminate
requirement
for
systems
to
request
approval
to
start
reduced
monitoring:

System
burden
(
564)
(
4,275)
(
1,841)
(
3,941)
(
1,277)
(
2,380)
None.
This
activity
is
projected
to
be
completed
by
the
end
of
2003.
A
total
of
6,116
systems:
564
large
systems,
445
medium
systems,

and
5,107
small
systems
are
estimated
to
qualify
for
reduced
lead
and
copper
tap
monitoring
by
meeting
OWQPs.
During
1999­
2003,

these
systems
would
have
made
a
total
of
11,898
requests
for
annual
or
triennial
monitoring.

Systems
would
have
required
1
hour
to
prepare
their
requests.
No
reduction
in
State
burden
is
assumed
because
States
will
make
decisions
regarding
monitoring
schedules
as
part
of
their
oversight
responsibilities.

State
burden
0
0
0
0
0
0
June
1999
PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
B­
8
State
flexibility
to
calculate
90th
percentile
level:

System
burden
(
18,182)
(
5,141)
(
4,860)
(
11,999)
(
2,673)
(
8,571)
Average
system
burden
reduction
is
estimated
to
be
6,163
hours.
Average
State
burden
increase
is
estimated
to
be
1,410
hours.
Assume
State
will
not
require
50%
of
systems
to
calculate
the
90th
percentile
level
based
on
information
collecting
during
data
verifications
that
were
conducted
in
State
program
offices.

System
burden
associated
with
determining
the
90th
percentile
lead
and
copper
values
is
assumed
to
be
0.5
hours
to
2
hours.
The
corresponding
State
burden
is
estimated
to
be
between
10
minutes
to
2
hours.
The
burden
is
dependent
on
the
system
size
and
whether
the
system
is
on
reduced
monitoring.

State
burden
3,609
1,099
1,524
2,327
579
1,828
Changes
in
treatment
or
addition
of
a
new
source:

System
burden
505
125
161
479
105
275
Average
system
and
State
burden
increase
over
these
six
years
is
estimated
to
be
241
hours.
Assumes
2%
of
systems,
conducting
reduced
monitoring
lead
and
copper
tap
monitoring,
will
report
a
change
in
treatment
or
an
addition
of
a
new
source
each
year.
Assumes
0.5
hours
for
system
and
0.5
hours
for
State
transaction
burdens.

State
burden
505
125
161
479
105
275
Reporting/
reviewing
WQPs
using
the
revised
approach
for
determining
compliance:

System
burden
2,736
3,615
4,037
4,037
4,037
3,692
System
and
State
burden
increases
will
continue
at
4,037
hours
and
2,018
hours
for
each
of
these
six
years.
Under
the
LCRMR,
systems
are
assumed
to
continue
to
report
WQP
results
every
6
month
and
to
require
an
extra
10
minutes
each
6­

month
monitoring
period
to
assess
compliance
using
the
new
criteria.
This
translates
to
an
annual
burden
of
4.33
hours
per
systems.
States
are
also
assumed
to
require
an
additional
10
minutes
each
6­
month
monitoring
period
to
evaluate
compliance
using
the
new
criteria.
This
equals
an
annual
burden
of
6.83
hours
per
State
per
system.

State
burden
1,388
1,814
2,018
2,018
2,018
1,851
Change
deadline
for
reporting
completion
of
public
education
tasks:
System
burden
388
388
388
388
388
388
System
and
State
burden
increase
will
continue
at
the
same
level
for
these
years.
Translates
to
351
and
37
additional
reports
per
year
for
large
and
medium
system,
respectively.
Small
systems
are
assumed
to
omit
public
service
announcements
and
therefore,
would
only
submit
one
letter.
Burden
equals
1
hour
for
systems
and
20
minutes
for
State.

State
burden
129
129
129
129
129
129
Reporting
compliance
with
Partial
LSL
Requirements
System
burden
2,075
2,570
2,570
2,570
2,570
2,471
System
and
State
burden
increase
will
continue
at
2,570
hours
for
each
of
these
six
years.
Based
on
comments
received
on
the
April
1998
NoDA,
EPA
assumes
75%
of
States
will
require
systems
that
replace
lead
service
lines
to
submit
information
that
demonstrates
compliance
with
partial
LSL
requirements.
Assumes
that
systems
will
submit
an
average
of
9
letters
and
require
0.5
hours
to
prepare
each
letter.

States
are
assumed
to
require
0.5
hours
to
review
each
letter.

State
burden
2,075
2,570
2,570
2,570
2,570
2,471
June
1999
PROPOSED
REVISION
1999
2000
2001
2002
2003
5­
Year
Average
2004­
2009
Activities
NOTES/
ASSUMPTIONS
B­
9
Impact
resulting
from
changes
in
other
provisions
Reporting
of
lead
and
copper
monitoring
results:

System
burden
(
15,686)
(
6,160)
3,631
(
9,107)
(
4,418)
(
6,348)
The
average
system
burden
reduction
is
estimated
to
be
1,852
hours
for
these
6
years.
An
overall
decrease
in
burden
is
estimated
due
to:
Accelerated
reduced
lead
and
copper
monitoring
and
small
system
monitoring
waivers.

State
savings
associated
the
review
of
less
monitoring
data
is
captured
under
"
Accelerated
reduced
lead
and
copper
monitoring
provision"
and
"
monitoring
waivers",
presented
earlier
in
this
chart.

State
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Reporting
of
source
water
monitoring
results:

System
burden
(
604)
(
393)
(
393)
(
399)
(
428)
(
443)
The
average
system
burden
reduction
is
estimated
to
be
1,074
hours
for
these
6
years.
Decrease
due
to
reduced
source
water
monitoring
for
systems
with
low
lead
and
copper
levels
that
are
not
required
to
install
source
water
treatment.
System
are
assumed
to
require
0.5
hours
per
monitoring
event
to
report
source
water
monitoring
results.

State
savings
associated
the
review
of
less
monitoring
data
is
captured
under
"
Reduction
in
source
water
monitoring
for
systems
not
required
to
install
SOWT.
(
Rrefer
back
to
page
B­
4.)

State
burden
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Reasons
for
changes
in
lead
and
copper
monitoring
location:

System
burden
(
3,691)
(
1,530)
891
(
2,161)
(
1,117)
(
1,522)
Average
system
and
State
burden
reduction
over
these
six
years
is
estimated
to
be
458
hours
and
76
hours,

respectively.
Burden
equals
1
hour
for
systems
to
prepare
the
information
and
10
minutes
for
States
to
review
it.

50%
of
CWSs,
collecting
lead
and
copper
tap
samples,
are
assumed
to
report
a
change
in
monitoring
location
during
each
monitoring
period.

State
burden
(
615)
(
255)
148
(
361)
(
186)
(
254)

TOTAL
BURDEN
DIFFERENCE
SYSTEM
169,555
(
230,789)
(
49,085)
(
302,498)
(
181,328)
(
118,829)
The
average
system
burden
for
all
activities
is
estimated
to
be
a
reduction
of
146,867
hours
over
these
six
years.

The
average
State
burden
for
all
activities
over
these
six
years
is
estimated
to
be
an
increase
of
3,654
hours.
The
net
decrease
in
system
burden
is
primarily
due
to:
accelerated
reduced
monitoring,
monitoring
waivers,
WQP
monitoring
at
representative
entry
points,
changes
in
sampling
location
for
postpartial
lead
service
line
replacement
samples,
and
State
flexibility
to
calculate
90th
percentile
levels.

The
net
increase
in
State
burden
is
primarily
a
function
of
initial
oversight
and
implementation
activities
(
regulatory
adoption,

training,
system
notification,
and
data
system
modification),
the
reporting
of
two
new
milestones,
the
calculation
of
the
90th
percentile
levels
for
the
systems,
determining
compliance
with
optimal
WQPs
using
the
new
criteria,
and
revewing
system
compliance
with
partial
lead
service
line
replacement
and
notification
requirements.

STATE
70,228
49,633
30,300
(
3,268)
8
29,380
June
1999
APPENDIX
C
Safe
Drinking
Water
Sections
that
Provide
Authority
for
the
Collection
June
1999
C­
1
APPENDIX
C
Relevant
Authorities
in
the
SDWA
1996
Amendments
Section
1401.
For
purposes
of
this
title:

(
1)
The
term
"
primary
drinking
water
regulation"
means
a
regulation
which­

(
D)
contains
criteria
and
procedures
to
assure
a
supply
of
drinking
water
which
dependably
complies
with
such
maximum
contaminant
levels;
including
accepted
methods
for
quality
control
and
testing
procedures
to
insure
compliance
with
such
levels
and
to
insure
proper
operation
and
maintenance
of
the
system,
and
requirements
as
to
(
i)
the
minimum
quality
of
water
which
may
be
taken
into
the
system
and
(
ii)
siting
for
new
facilities
for
public
water
systems.
At
any
time
after
promulgation
of
a
regulation
referred
to
in
this
paragraph,
the
Administrator
may
add
equally
effective
quality
control
and
testing
procedures
by
guidance
published
in
the
Federal
Register.
Such
procedures
shall
be
treated
as
an
alternative
for
public
water
systems
to
the
quality
control
and
testing
procedures
listed
in
the
regulation.

Section
1412(
b)(
1)
Identification
of
contaminants
for
listing.
 
(
A)
General
authority.
 
The
Administrator
shall,
in
accordance
with
the
procedures
established
by
this
subsection,
publish
a
maximum
contaminant
level
goal
and
promulgate
a
national
primary
drinking
water
regulation
for
a
contaminant
(
other
than
a
contaminant
referred
to
in
paragraph
(
2)
for
which
a
national
primary
drinking
water
regulation
has
been
promulgated
as
of
the
date
of
enactment
of
the
Safe
Drinking
Water
Act
Amendments
of
1996)
if
the
Administrator
determines
that
 
(
i)
the
contaminant
may
have
an
adverse
effect
on
the
health
of
persons;

(
ii)
the
contaminant
is
known
to
occur
or
there
is
a
substantial
likelihood
that
the
contaminant
will
occur
in
public
water
systems
with
a
frequency
and
at
levels
of
public
health
concern;
and
(
iii)
in
the
sole
judgment
of
the
Administrator,
regulation
of
such
contaminant
presents
a
meaningful
opportunity
for
health
risk
reduction
for
persons
served
by
public
water
systems.

(
B)
Regulation
of
unregulated
contaminants.
 
(
i)
Listing
of
contaminants
for
consideration.
 
(
I)
Not
later
than
18
months
after
the
date
of
enactment
of
the
Safe
Drinking
Water
Act
Amendments
of
1996
and
every
5
years
thereafter,
the
Administrator,
after
consultation
with
the
scientific
community,
including
the
Science
Advisory
Board,
after
notice
and
opportunity
for
public
comment,
and
after
considering
the
occurrence
data
base
established
under
section
1445(
g),
shall
publish
a
list
of
contaminants
which,
at
the
time
of
publication,
are
not
subject
to
any
proposed
or
promulgated
national
primary
drinking
water
regulation,
which
are
known
or
anticipated
to
occur
in
public
water
systems,
and
which
may
require
regulation
under
this
title.

(
II)
The
unregulated
contaminants
considered
under
subclause
(
I)
shall
include,
but
not
be
limited
to,
substances
referred
to
in
section
101(
14)
of
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
of
1980,
and
substances
registered
as
pesticides
under
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act.
June
1999
C­
2
(
III)
The
Administrator's
decision
whether
or
not
to
select
an
unregulated
contaminant
for
a
list
under
this
clause
shall
not
be
subject
to
judicial
review.

(
ii)
Determination
to
regulate.
 
(
I)
Not
later
than
5
years
after
the
date
of
enactment
of
the
Safe
Drinking
Water
Act
Amendments
of
1996,
and
every
5
years
thereafter,
the
Administrator
shall,
after
notice
of
the
preliminary
determination
and
opportunity
for
public
comment,
for
not
fewer
than
5
contaminants
included
on
the
list
published
under
clause
(
i),
make
determinations
of
whether
or
not
to
regulate
such
contaminants.

(
II)
A
determination
to
regulate
a
contaminant
shall
be
based
on
findings
that
the
criteria
of
clauses
(
i),
(
ii),
and
(
iii)
of
subparagraph
(
A)
are
satisfied.
Such
findings
shall
be
based
on
the
best
available
public
health
information,
including
the
occurrence
data
base
established
under
section
1445(
g).

(
III)
The
Administrator
may
make
a
determination
to
regulate
a
contaminant
that
does
not
appear
on
a
list
under
clause
(
i)
if
the
determination
to
regulate
is
made
pursuant
to
subclause
(
II).

(
IV)
A
determination
under
this
clause
not
to
regulate
a
contaminant
shall
be
considered
final
agency
action
and
subject
to
judicial
review.

(
iii)
Review.
 
Each
document
setting
forth
the
determination
for
a
contaminant
under
clause
(
ii)
shall
be
available
for
public
comment
at
such
time
as
the
determination
is
published.

(
C)
Priorities.
 
In
selecting
unregulated
contaminants
for
consideration
under
subparagraph
(
B),
the
Administrator
shall
select
contaminants
that
present
the
greatest
public
health
concern.
The
Administrator,
in
making
such
selection,
shall
take
into
consideration,
among
other
factors
of
public
health
concern,
the
effect
of
such
contaminants
upon
subgroups
that
comprise
a
meaningful
portion
of
the
general
population
(
such
as
infants,
children,
pregnant
women,
the
elderly,
individuals
with
a
history
of
serious
illness,
or
other
subpopulations)
that
are
identifiable
as
being
at
greater
risk
of
adverse
health
effects
due
to
exposure
to
contaminants
in
drinking
water
than
the
general
population.

(
D)
Urgent
threats
to
public
health.
 
The
Administrator
may
promulgate
an
interim
national
primary
drinking
water
regulation
for
a
contaminant
without
making
a
determination
for
the
contaminant
under
paragraph
(
4)(
C),
or
completing
the
analysis
under
paragraph
(
3)(
C),
to
address
an
urgent
threat
to
public
health
as
determined
by
the
Administrator
after
consultation
with
and
written
response
to
any
comments
provided
by
the
Secretary
of
Health
and
Human
Services,
acting
through
the
director
of
the
Centers
for
Disease
Control
and
Prevention
or
the
director
of
the
National
Institutes
of
Health.
A
determination
for
any
contaminant
in
accordance
with
paragraph
(
4)(
C)
subject
to
an
interim
regulation
under
this
subparagraph
shall
be
issued,
and
a
completed
analysis
meeting
the
requirements
of
paragraph
(
3)(
C)
shall
be
published,
not
later
than
3
years
after
the
date
on
which
the
regulation
is
promulgated
and
the
regulation
shall
be
repromulgated,
or
revised
if
appropriate,
not
later
than
5
years
after
that
date.

(
E)
Regulation.
 
For
each
contaminant
that
the
Administrator
determines
to
regulate
under
subparagraph
(
B),
the
Administrator
shall
publish
maximum
contaminant
level
goals
and
promulgate,
by
rule,
national
primary
drinking
water
regulations
under
this
subsection.
The
Administrator
shall
propose
the
maximum
contaminant
level
goal
and
national
primary
drinking
water
regulation
for
a
contaminant
not
later
than
24
months
after
the
determination
to
regulate
under
subparagraph
(
B),
and
may
publish
such
proposed
regulation
concurrent
with
the
determination
to
regulate.
The
Administrator
shall
publish
a
maximum
contaminant
level
goal
and
promulgate
a
national
primary
drinking
water
regulation
within
18
months
after
the
proposal
thereof.
The
Administrator,
by
notice
in
the
Federal
Register,
may
extend
the
June
1999
C­
3
deadline
for
such
promulgation
for
up
to
9
months.

(
F)
Health
advisories
and
other
actions.
 
The
Administrator
may
publish
health
advisories
(
which
are
not
regulations)
or
take
other
appropriate
actions
for
contaminants
not
subject
to
any
national
primary
drinking
water
regulation.

Section
1412(
b)(
4)
Goals
and
standards.
 
(
A)
Maximum
contaminant
level
goals.
 
Each
maximum
contaminant
level
goal
established
under
this
subsection
shall
be
set
at
the
level
at
which
no
known
or
anticipated
adverse
effects
of
health
of
persons
occur
and
which
allows
an
adequate
margin
of
safety.

(
B)
Maximum
contaminant
levels.
 
Except
as
provided
in
paragraphs
(
5)
and
(
6),
each
national
primary
drinking
water
regulation
for
a
contaminant
for
which
a
maximum
contaminant
level
goal
is
established
under
this
subsection
shall
specify
a
maximum
contaminant
level
for
such
a
contaminant
which
is
as
close
to
the
maximum
contaminant
level
goal
as
is
feasible.

(
C)
Determination.
 
At
the
time
the
Administrator
proposes
a
national
primary
drinking
water
regulation
under
this
paragraph,
the
Administrator
shall
publish
a
determination
as
to
whether
the
benefits
of
the
maximum
contaminant
level
justify,
or
do
not
justify,
the
costs
based
on
the
analysis
conducted
under
paragraph
(
3)(
C).

(
D)
Definition
of
feasible.
 
For
the
purposes
of
this
subsection,
the
term
"
feasible'
means
feasible
with
the
use
of
the
best
technology,
treatment
techniques,
and
other
means
which
the
Administrator
finds,
after
examination
for
efficacy
under
field
conditions
and
not
solely
under
laboratory
conditions,
are
available
(
taking
cost
into
consideration).
For
the
purpose
of
this
paragraph,
granular
activated
carbon
is
feasible
for
the
control
of
synthetic
organic
chemicals,
and
any
technology,
treatment
technique,
or
other
means
found
to
be
the
best
available
for
the
control
of
synthetic
organic
chemicals
must
be
at
least
as
effective
in
controlling
synthetic
organic
chemicals
as
granular
activated
carbon.

(
E)
Feasible
technologies.
 
(
i)
In
general.
 
Each
national
primary
drinking
water
regulation
which
establishes
a
maximum
contaminant
level
shall
list
the
technology,
treatment
techniques,
and
other
means
which
the
Administrator
finds
to
be
feasible
for
purposes
of
meeting
such
maximum
contaminant
level,
but
regulation
under
this
subsection
shall
not
require
that
any
specified
technology,
treatment
technique,
or
other
means
be
used
for
purposes
of
meeting
such
maximum
contaminant
level.

(
ii)
List
of
technologies
for
small
systems.
 
The
Administrator
shall
include
in
the
list
any
technology,
treatment
technique,
or
other
means
that
is
affordable,
as
determined
by
the
Administrator
in
consultation
with
the
States,
for
small
public
water
systems
serving
 
(
I)
a
population
of
10,000
or
fewer
but
more
than
3,300;

(
II)
a
population
of
3,300
or
fewer
but
more
than
500;
and
(
III)
a
population
of
500
or
fewer
but
more
than
25;

and
that
achieves
compliance
with
the
maximum
contaminant
level
or
treatment
technique,
including
packaged
or
modular
systems
and
point­
of­
entry
or
point­
of­
use
treatment
units.
Point­
of­
entry
and
pointof
use
treatment
units
shall
be
owned,
controlled
and
maintained
by
the
public
water
system
or
by
a
person
June
1999
C­
4
under
contract
with
the
public
water
system
to
ensure
proper
operation
and
maintenance
and
compliance
with
the
maximum
contaminant
level
or
treatment
technique
and
equipped
with
mechanical
warnings
to
ensure
that
customers
are
automatically
notified
of
operational
problems.
The
Administrator
shall
not
include
in
the
list
any
point­
of­
use
treatment
technology,
treatment
technique,
or
other
means
to
achieve
compliance
with
a
maximum
contaminant
level
or
treatment
technique
requirement
for
a
microbial
contaminant
(
or
an
indicator
of
a
microbial
contaminant).
If
the
American
National
Standards
Institute
has
issued
product
standards
applicable
to
a
specific
type
of
point­
of­
entry
or
point­
of­
use
treatment
unit,
individual
units
of
that
type
shall
not
be
accepted
for
compliance
with
a
maximum
contaminant
level
or
treatment
technique
requirement
unless
they
are
independently
certified
in
accordance
with
such
standards.
In
listing
any
technology,
treatment
technique,
or
other
means
pursuant
to
this
clause,
the
Administrator
shall
consider
the
quality
of
the
source
water
to
be
treated.

(
iii)
List
of
technologies
that
achieve
compliance.
 
Except
as
provided
in
clause
(
v),
not
later
than
2
years
after
the
date
of
enactment
of
this
clause
and
after
consultation
with
the
States,
the
Administrator
shall
issue
a
list
of
technologies
that
achieve
compliance
with
the
maximum
contaminant
level
or
treatment
technique
for
each
category
of
public
water
systems
described
in
subclauses
(
I),
(
II),
and
(
III)
of
clause
(
ii)
for
each
national
primary
drinking
water
regulation
promulgated
prior
to
the
date
of
enactment
of
this
paragraph.

(
iv)
Additional
technologies.
 
The
Administrator
may,
at
any
time
after
a
national
primary
drinking
water
regulation
has
been
promulgated,
supplement
the
list
of
technologies
describing
additional
or
new
or
innovative
treatment
technologies
that
meet
the
requirements
of
this
paragraph
for
categories
of
small
public
water
systems
described
in
subclauses
(
I),
(
II),
and
(
III)
of
clause
(
ii)
that
are
subject
to
the
regulation.

(
v)
Technologies
that
meet
surface
water
treatment
rule.
 
Within
one
year
after
the
date
of
enactment
of
this
clause,
the
Administrator
shall
list
technologies
that
meet
the
Surface
Water
Treatment
Rule
for
each
category
of
public
water
systems
described
in
subclauses
(
I),
(
II),
and
(
III)
of
clause
(
ii).

Section
1413(
a)
For
purposes
of
this
title,
a
State
has
primary
enforcement
responsibility
for
public
water
systems
during
any
period
for
which
the
Administration
determines
(
pursuant
to
regulations
under
subsection
(
b))
that
such
State­

(
1)
has
adopted
drinking
water
regulations
that
are
no
less
stringent
than
the
national
primary
drinking
water
regulations
promulgated
by
the
Administrator
under
subsections
(
a)
and
(
b)
of
section
1412
not
later
than
2
years
after
the
date
on
which
the
regulations
are
promulgated
by
the
Administrator,
except
that
the
Administrator
may
provide
for
an
extension
of
not
more
than
2
years
if,
after
submission
and
review
of
appropriate,
adequate
documentation
from
the
State,
the
Administrator
determines
that
the
extension
is
necessary
and
justified;

(
2)
has
adopted
and
is
implementing
adequate
procedures
for
the
enforcement
of
such
State
regulations,
including
conducting
such
monitoring
and
making
such
inspections
as
the
Administrator
may
require
by
regulation;

(
3)
will
keep
such
records
and
make
such
reports
with
respect
to
its
activities
under
paragraphs
(
1)
and
(
2)
as
the
Administrator
may
require
by
regulation.

Section
1445
(
a)(
1)(
A)
Every
person
who
is
subject
to
any
requirement
of
this
title
or
who
is
a
grantee,
shall
establish
and
maintain
such
records,
make
such
reports,
conduct
such
monitoring,
and
provide
such
June
1999
C­
5
information
as
the
Administrator
may
reasonably
require
by
regulation
to
assist
the
Administrator
in
establishing
regulations
under
this
title,
in
determining
whether
such
person
has
acted
or
is
acting
in
compliance
with
this
title,
in
administering
any
program
of
financial
assistance
under
this
title,
in
evaluating
the
health
risks
of
unregulated
contaminants,
or
in
advising
the
public
of
such
risks.
In
requiring
a
public
water
system
to
monitor
under
this
subsection,
the
Administrator
may
take
into
consideration
the
system
size
and
the
contaminants
likely
to
be
found
in
the
system's
drinking
water.

(
B)
Every
person
who
is
subject
to
a
national
primary
drinking
water
regulation
under
section
1412
shall
provide
such
information
as
the
Administrator
may
reasonably
require,
after
consultation
with
the
State
in
which
such
person
is
located
if
such
State
has
primary
enforcement
responsibility
for
public
water
systems,
on
a
case­
by­
case
basis,
to
determine
whether
such
person
has
acted
or
is
acting
in
compliance
with
this
title.

(
C)
Every
person
who
is
subject
to
a
national
primary
drinking
water
regulation
under
section
1412
shall
provide
such
information
as
the
Administrator
may
reasonably
require
to
assist
the
Administrator
in
establishing
regulations
under
section
1412
of
this
title,
after
consultation
with
States
and
suppliers
of
water.
The
Administrator
may
not
require
under
this
subparagraph
the
installation
of
treatment
equipment
or
process
changes,
the
testing
of
treatment
technology,
or
the
analysis
or
processing
of
monitoring
samples,
except
where
the
Administrator
provides
the
funding
for
such
activities.
Before
exercising
this
authority,
the
Administrator
shall
first
seek
to
obtain
the
information
by
voluntary
submission.

(
D)
The
Administrator
shall
not
later
than
2
years
after
the
date
of
enactment
of
this
subparagraph,
after
consultation
with
public
health
experts,
representatives
of
the
general
public,
and
officials
of
State
and
local
governments,
review
the
monitoring
requirements
for
not
fewer
than
12
contaminants
identified
by
the
Administrator,
and
promulgate
any
necessary
modifications.
