          Information Collection Request:

          Short-Term Regulatory Changes to the Lead

          and Copper Rule

    

     

Office of Water (4607M)     September 2007    www.epa.gov/safewater

TABLE OF CONTENTS

  TOC \h \z \t "Header 1,1,Header 2,2,Header 3,3"    HYPERLINK \l
"_Toc160872046"  1 	IDENTIFICATION OF THE INFORMATION COLLECTION	 
PAGEREF _Toc160872046 \h  1  

  HYPERLINK \l "_Toc160872047"  1(a) 	Title And Number Of The
Information Collection	  PAGEREF _Toc160872047 \h  1  

  HYPERLINK \l "_Toc160872048"  1(b) 	Short Characterization/Abstract	 
PAGEREF _Toc160872048 \h  1  

  HYPERLINK \l "_Toc160872049"  2 	NEED FOR AND USE OF THE COLLECTION	 
PAGEREF _Toc160872049 \h  5  

  HYPERLINK \l "_Toc160872050"  2(a) 	Need/Authority For The Collection	
 PAGEREF _Toc160872050 \h  5  

  HYPERLINK \l "_Toc160872051"  2(b) 	Uses/Users of the Data	  PAGEREF
_Toc160872051 \h  6  

  HYPERLINK \l "_Toc160872052"  2(b)(ii) Users of the Data	  PAGEREF
_Toc160872052 \h  7  

  HYPERLINK \l "_Toc160872053"  3	NON-DUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION	  PAGEREF _Toc160872053 \h  8  

  HYPERLINK \l "_Toc160872054"  3(a) 	Non-duplication	  PAGEREF
_Toc160872054 \h  8  

  HYPERLINK \l "_Toc160872055"  3(b) 	Public Notice Required Prior to
ICR Submission to OMB	  PAGEREF _Toc160872055 \h  8  

  HYPERLINK \l "_Toc160872056"  3(c) 	Consultations	  PAGEREF
_Toc160872056 \h  8  

  HYPERLINK \l "_Toc160872057"  3(d) 	Effects of Less Frequent
Collection	  PAGEREF _Toc160872057 \h  11  

  HYPERLINK \l "_Toc160872058"  3(e) 	General Guidelines	  PAGEREF
_Toc160872058 \h  12  

  HYPERLINK \l "_Toc160872059"  3(f) 	Confidentiality	  PAGEREF
_Toc160872059 \h  12  

  HYPERLINK \l "_Toc160872060"  3(g) 	Sensitive Questions	  PAGEREF
_Toc160872060 \h  12  

  HYPERLINK \l "_Toc160872061"  4 	THE RESPONDENTS AND THE INFORMATION
REQUESTED	  PAGEREF _Toc160872061 \h  13  

  HYPERLINK \l "_Toc160872062"  4(a) 	Respondents/SIC Codes	  PAGEREF
_Toc160872062 \h  13  

  HYPERLINK \l "_Toc160872063"  4(b) 	Information Requested	  PAGEREF
_Toc160872063 \h  13  

  HYPERLINK \l "_Toc160872064"  4(c)	ICR Approval Activities	  PAGEREF
_Toc160872064 \h  20  

  HYPERLINK \l "_Toc160872065"  5 	THE INFORMATION COLLECTED—AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF
_Toc160872065 \h  22  

  HYPERLINK \l "_Toc160872066"  5(a) 	Agency Activities	  PAGEREF
_Toc160872066 \h  22  

  HYPERLINK \l "_Toc160872067"  5(b) 	Collection Methodology and
Management	  PAGEREF _Toc160872067 \h  22  

  HYPERLINK \l "_Toc160872068"  5(c) 	Small Entity Flexibility	  PAGEREF
_Toc160872068 \h  22  

  HYPERLINK \l "_Toc160872069"  5(d) 	Collection Schedule	  PAGEREF
_Toc160872069 \h  23  

  HYPERLINK \l "_Toc160872070"  6. 	ESTIMATING THE BURDEN AND COST OF
THE COLLECTION	  PAGEREF _Toc160872070 \h  25  

  HYPERLINK \l "_Toc160872071"  6(a) 	Estimating Respondent Burden	 
PAGEREF _Toc160872071 \h  25  

  HYPERLINK \l "_Toc160872072"  6a(i)	Burden and Cost to PWSs	  PAGEREF
_Toc160872072 \h  26  

  HYPERLINK \l "_Toc160872073"  6a(ii)	Burden and Cost to States	 
PAGEREF _Toc160872073 \h  27  

  HYPERLINK \l "_Toc160872074"  6(b)	Time Frame for Cost and Burden
Estimates	  PAGEREF _Toc160872074 \h  27  

  HYPERLINK \l "_Toc160872075"  6(c) 	Estimating Agency Burden and Cost	
 PAGEREF _Toc160872075 \h  33  

  HYPERLINK \l "_Toc160872076"  6(d)	Respondent Universe	  PAGEREF
_Toc160872076 \h  33  

  HYPERLINK \l "_Toc160872077"  6(e)	Bottom Line Burden Hours and Costs	
 PAGEREF _Toc160872077 \h  33  

  HYPERLINK \l "_Toc160872078"  6e(i)	Bottom Line Burden and Cost
Estimates for Respondents	  PAGEREF _Toc160872078 \h  34  

  HYPERLINK \l "_Toc160872079"  6e(ii)	Bottom Line Estimate for Agency	 
PAGEREF _Toc160872079 \h  35  

  HYPERLINK \l "_Toc160872080"  6(f) 	Reasons For Change In Burden	 
PAGEREF _Toc160872080 \h  35  

  HYPERLINK \l "_Toc160872081"  6(g) 	Burden Statement	  PAGEREF
_Toc160872081 \h  35  

 

APPENDICES

Appendix A: Relevant Authorities in the SDWA 1996 Amendments

Appendix B: Detailed Assumptions Used to Estimate Burdens and Costs 

Appendix C: Detailed Calculations Used to Estimate Burden and Costs



1 	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) 	Title And Number Of The Information Collection

TITLE: Information Collection Request for Final Short Term Regulatory
Revisions and Clarifications to the National Primary Drinking Water
Regulations for Lead and Copper 

U.S. EPA ICR Number: 1896.07			OMB Control Number: 2040-0204

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 as
close to the maximum contaminant level goals (MCLG) 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
systems 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. 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).

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. 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 2040-090. A stand-alone Lead and Copper Rule ICR,
entitled, Information Collection Request for the National Primary
Drinking Water Regulations for Lead and Copper, June 1999, EPA tracking
number 1912.01 and OMB number 2040-0210, addressed the impacts of the
Lead and Copper Rule Minor Revisions (LCRMR) on the LCR burden and costs
for 1999 through 2001(hereafter referred to as the 1999 ICR). OMB
extended the expiration date of the 1999 ICR through the end of 2003.
The most recent ICR regarding lead and copper, entitled,
Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides
Rules, September 2004, EPA tracking number 1896.05 and OMB number
2040-0204, estimates burden and costs from of the LCR, as well as other
rules, from 2005-2007 (hereafter referred to as the 2004 ICR).

	The purpose of this ICR document is to present the impacts of the Short
Term Regulatory Revisions and Clarifications to the Lead and Copper Rule
(hereafter referred to as LCRSTR) in terms of the burden and costs for
the first three years after the final rule is published (estimated as
late September 2007 through late September 2010).   The LCRSTR is
intended to strengthen the implementation of the LCR in the areas of
monitoring, customer awareness, and lead service line replacement in the
short-term. Some of the changes clarify the intent of the LCR for
provisions that have generated questions. Other provisions reconsider
LCR requirements in light of recent experience. These changes are
expected to ensure and enhance more effective protection of public
health through the reduction in lead exposure. Action Levels and MCLGs
are not changed in the LCRSTR. The specific regulatory changes that are
the subject of the LCRSTR are as follows.

#	Final Revision	Purpose of Revision

Monitoring

III.A	Minimum number of samples required	To address confusion about
sample collection

III.B	Definitions for compliance and monitoring periods	To clarify when
compliance and monitoring periods begin and end

III.C	Reduced monitoring criteria	To prohibit systems that exceed the
lead Action Level from initiating or remaining on reduced monitoring
based solely on results of water quality parameter monitoring

Treatment Processes

III.D	Advanced notification and approval requirement for water systems
that intend to make any change in water treatment or add a new source of
water that could affect the system’s optimal corrosion control	To
require systems to obtain state approval to add a new source of water or
change a treatment process prior to implementation

Customer Awareness

III.E	Notification of sampling results	To require utilities to provide
sampling results to consumers at sampling sites that are tested for lead
and copper, as part of the utility’s monitoring program

III.F	Public Education Requirements	To modify public education
requirements by changing the content of the message to be provided to
consumers, how the materials are delivered to consumers, and the
timeframe for delivery

Lead Service Line Replacement

III.G	Reevaluation of lead service lines deemed replaced through testing
To require that systems reevaluate lead service lines classified as
“replaced” through testing if the system resumes a lead service line
replacement program



For the three-year period of late September 2007 to late September 2010,
the average annual burden associated with the LCRSTR is 189,369 –
271,997 hours for the 72,213 system respondents, depending on the
assumed timing of early implementation.  The annual burden is estimated
at 17,628 – 25,125 hours for the 57 State and Primacy Agency
respondents. The average annual costs for systems and States are $5.6
– $8.4 million per year and $0.8 – $1.1 million per year,
respectively. The average annual burden per system is 2.6 – 3.8 hours
per year and the average annual costs per system are $77 - $117 per
year. The average annual burden per State is estimated to be 309 - 441
hours per year and the average annual costs per State are estimated to
be $13,500 - $19,300 per year. 

These burden and cost estimates represent those activities that EPA
expects would occur in the initial three-year period.  During this
period, systems and States would perform the initial, one-time
activities related to rule review and primacy requirements and
activities directly triggered by the seven targeted regulatory changes. 
EPA assumes that the timing of implementation activities and activities
related to the regulatory changes will vary, depending on the early
adoption practices of States.  However, EPA expects that the upper bound
estimates of burden and cost are more reflective of the actual burden
and costs to public water systems and States given that many States will
likely opt for early implementation of the regulatory changes to
increase public health protection from exposure to lead and copper.  

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). Recent highly publicized incidences of
elevated drinking water lead levels prompted EPA to review and evaluate
the implementation and effectiveness of the LCR on a national basis. As
a result this multi-part review, EPA identified seven targeted rule
changes that clarify the intent of the LCR and ensure and enhance
protection of public health through reduction in lead exposure. EPA will
use the information collected as a result of the LCRSTR to support the
responsibilities outlined in SDWA by strengthening the implementation of
the LCR in the areas of monitoring, customer awareness, and lead service
line replacement. 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. 

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 the health 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 A to this document.

2(b) 	Uses/Users of the Data

2(b)(i) 	 Uses of the Data

Primary users of the data collected under this ICR are EPA Headquarters,
PWS managers, consumers, and primacy agencies, which include State
regulators, Indian Tribes, and, in some instances, EPA Regional
Administrators. This section contains more information about how the
lead and copper data generated by the regulatory changes will be used.

Under Regulatory change III.A, systems with fewer than 5 taps in States
that allow 1 sample per tap will generate and submit to the State a
letter documenting the number of applicable taps for future sampling. 
States will use these letters to determine the appropriateness of a
system submitting fewer than 5 samples per monitoring cycle.

	Under Regulatory change III.C, systems that exceed the lead Action
Level collect additional tap monitoring data when they resume regular
monitoring after having previously been on reduced monitoring. Tap
monitoring data is used for the following purposes.

Evaluate the quality of water delivered to customers;

Evaluate system-specific needs, including examining treatment
effectiveness;

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;

Modify monitoring frequencies, schedules, and variances to address
potential health risks; and,

Alert the public, through notices in the mass media or water bills, when
the system is not in compliance with Federal and State regulations so
that they may take actions to minimize exposure to potentially harmful
drinking water contaminants.

Regulatory change III.D provides States with information on treatment
changes or source additions in a timely manner – before the change has
been made rather than after the fact. States use this information to
assist systems in evaluating potential impacts of these modifications on
corrosion control and identifying system needs and problem areas through
a review and approval process.

Regulatory change III.E provides customers with information on lead tap
sampling results for individual establishments. Regulatory change III.F
provides customers with more timely and understandable information on
lead levels within a system, particularly after an Action Level
exceedance. Consumers use this information to evaluate health risks and
take action to minimize exposure to potentially harmful levels of lead
or copper.

Regulatory change III.G provides systems with additional information on
the lead levels from a subset of lead service lines under current water
quality conditions. Systems use this information to evaluate whether
these lines continue to contribute low lead levels or whether changed
conditions have impacted corrosivity.

2(b)(ii) Users of the Data

Primary users of the data generated under the seven regulatory changes
are systems and their customers, States and primacy agencies, and EPA.
EPA often receives requests for PWS monitoring data under the Freedom of
Information Act (FOIA; 40 CFR, Chapter 1, Part 2). 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. 

Other agencies that may utilize the data include the following.

News Organizations

Staff from other EPA programs (such as Superfund, the Resource
Conservation and Recovery Act, and the OECA)

The Federal Emergency Management Administration

Centers for Disease Control and Prevention (CDC)

Military bases

Farmers Home Administration

Department of Interior

Department of Housing and Urban Development

U.S. Army Corps of Engineers

White House Task Forces

American Water Works Association

Association of Metropolitan Water Agencies

National Rural Water Association

National Association of Water Companies

Association of State Drinking Water Administrators

Natural Resources Defense Council

Consumers Federation of America

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 LCRSTR are
not available from any other source.

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 ICR during a 60-day public
comment period coincident with the comment period for the proposed
LCRSTR. The Agency published notice in the Federal Register (71 FR 137,
July 18, 2006) 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) 	Consultations

The short term changes to the Lead and Copper Rule described in this
document were identified through a comprehensive national review of
compliance and implementation of the LCR. In conducting this review, EPA
consulted with a wide range of interested parties. The comprehensive
review consisted of several elements, including a series of workshops
designed to elicit issues, comments, and suggestions from stakeholders
on particular topics, and a review of LCR implementation by States and
utilities. These activities are described below. 

Workshops

		One method that EPA used to elicit comments and suggestions from
stakeholders was to hold five workshops in 2004-2005 on various issues
related to lead in drinking water. Participant information for each
workshop is available in the publicly available meeting summary.  These
workshops include the following.

	Simultaneous Compliance, May 2004, St. Louis, MO: Expert participants
from utilities, academia, state governments, and other stakeholder
groups identified issues, proposed solutions, and identified information
gaps with respect to simultaneous compliance with the LCR and other
rules such as the Total Coliform Rule, the Surface Water Treatment
Rules, and the Disinfection Byproducts Rules. Issues and suggestions
were developed for four topic areas: coagulation impacts on corrosion
control; impacts of disinfectant changes on corrosion control; corrosion
inhibitor; and distribution system management. Among the issues
identified by the group were information gaps on impacts of treatment
changes under various water quality conditions/chemistries and the need
for additional guidance on a variety of topics.

	Sampling Protocols, May 2004, St. Louis, MO: Expert participants from
utilities, academia, state governments, and other stakeholder groups
identified issues, proposed solutions, and identified information gaps
with respect monitoring and sampling under the LCR. Topic areas included
sampling frequency and triggers; sampling site selection/location;
sampling protocol; and sampling of water quality parameters. The issues
included sampling after treatment changes and Action Level exceedances
and the re-examination of flushing instructions.

	Public Education, September 2004, Philadelphia, PA: Expert participants
from utilities, governments, consumer and environmental groups, and
other stakeholder groups discussed the public education requirements
under the lead and copper rule, drinking water risk communication, and
effective communication with the public. Participants suggested ways to
improve risk communication to the public through establishing
partnerships with health departments and other groups, refining the
message content, improving delivery of the message, and spending more
time planning and evaluating the effectiveness of the risk
communication. 

	Lead Service Line Replacement, October 2004, Atlanta, GA:  Expert
participants from utilities, academia, state governments, and other
stakeholder groups discussed the challenges and problems encountered by
the participants in implementing lead service line replacement, as well
as strategies and solutions for overcoming those difficulties. Specific
topic areas addressed included monitoring, customer communications,
replacement technologies, and managing inventory. Continued sampling
after lead service line replacement and the need to notify customers of
testing results were mentioned during the discussions.

	Lead in Plumbing, July 2005, Washington, DC: Expert participants from
utilities, academia, state governments, and other stakeholder groups
discussed lead in plumbing fittings and fixtures. Topic areas included
NSF standards and testing protocols, alternative materials,
national/state/local/industry/consumer practices, and miscellaneous
issues

		Review of Implementation and Consultation with States

		In 2004, EPA carried out a review of the implementation of LCR
requirements by States. EPA asked State programs who have primary
oversight responsibility a number of questions about how they implement
different aspects of the LCR. The questions were centered on the
following general categories: sampling issues, calculation of the 90th
percentile value, treatment issues, lead service line replacement,
public education and enforcement. 

		Generally, the State responses to the survey indicate that the States
are following the minimum State requirements of the LCR. However, the
information provided to EPA indicates that many States may not be taking
full advantage of the opportunities to oversee implementation of the
rule. Also, the States’ responses did highlight a few areas in which
there is some confusion about the requirements of the rule as well as
areas in which some States are going above and beyond the minimum
obligations.

Future Consultations

		It should be noted that EPA has also identified a number of issues
that require longer-term consideration that will continue to be reviewed
as part of potential, more comprehensive revisions to the rule or
guidance. In many cases, these issues require additional data
collection, research, and analysis to fill critical data gaps. Also,
some issues require full stakeholder involvement to support decisions.
Issues that are the subject of longer-term consideration include the
following:

Requirements for consecutive systems

Broader revisions to monitoring and lead service line replacement
requirements

Revision to lead content in plumbing fittings and fixture requirements

LCRSTR Workgroup

In addition, EPA also consulted with States and EPA Regional Offices. In
May 2005, EPA formed a work group to consider issues related to the
regulatory changes, called the Short-term Regulatory Revisions and
Clarifications to The Lead & Copper Rule Workgroup (LCRSTR Workgroup).
The LCRSTR Workgroup included EPA staff from a variety of Headquarters
and Regional offices, as well as representatives from State drinking
water lead programs. The LCRSTR Workgroup identified alternatives,
drafted regulatory language, and discussed issues related to the
changes.

National Drinking Water Advisory Committee Working Group on Public
Education Requirements of the Lead and Copper Rule

		

As part of the review of the LCR, EPA identified a number of issues
relating to the public education requirements of the LCR. In order to
address these concerns, the National Drinking Water Advisory Council
(NDWAC), EPA’s advisory body on the Safe Drinking Water Act, formed a
working group to consider possible revisions to the public education
requirements.   SEQ CHAPTER \h \r 1 The charge for the NDWAC Working
Group was to 1) review the current public education requirements for
lead in drinking water to make recommendations for improvements; 2)
develop recommended revised language for communicating to the public the
risk of lead in drinking water and how affected persons should respond;
and 3) review and make recommendations for changes to the means of
delivery of lead information to the public. 

The NDWAC Working Group met in person four times between October 2005
and April 2006. The Working Group was comprised of 16 individuals
representing an array of backgrounds and perspectives. Collectively,
these individuals brought into the discussion the perspectives of State
drinking water agencies, environmental and consumer groups, drinking
water utilities, small system advocates, State health officials, and
risk communication experts. The recommendations from the NDWAC Working
Group form the basis of the regulatory changes on public education
(III.F).

3(d) 	Effects of Less Frequent Collection

EPA has considered a wide range of alternatives for frequency of data
collection. EPA has chosen to require the least frequent collection that
remains consistent with the overall goal of protecting public health. If
data are collected less frequently, primacy agencies may not identify in
a timely fashion significant contaminant concentrations that might
threaten the health and safety of drinking water consumers. Monitoring
frequencies have been carefully devised based on the following
factors—

Data quality needed for a representative sample.

Precision and accuracy needed from the representative sample.

Number of people served by the system.

Source of the supply (e.g., surface water or ground water).

Contaminants likely to be found.

Temporal variability in occurrence.

Specific changes to monitoring frequencies that may result from the
LCRSTR are discussed in the following section.

Regulatory change III.A restates EPA’s position on the frequency of
sampling for small systems, but allows for States to reduce the number
of samples to 1 per tap for systems on a case by case basis.  This issue
is discussed more fully in the Federal Register Notice on the regulatory
changes.

Regulatory change III.C increases the frequency of data collection for
systems that had been on reduced monitoring and then exceeded the lead
Action Level. EPA believes that the additional data is critical in the
timely evaluation of health risks and treatment effectiveness for
systems that have lead levels over the Action Level.

Regulatory change III.F increases how often materials are delivered to
customers and shortens the timeframe in which they must be delivered.
EPA believes this increase in frequency is necessary for consumers,
especially at-risk populations, to receive information they need to
limit their exposure to lead in drinking water.

Regulatory change III.G increases the frequency of data collection for
systems that initiated a required lead service line replacement program,
“tested-out” lines to meet replacement targets, brought lead levels
under the Action Level and suspended lead service line replacement, and
then subsequently re-exceeded the Action Level. The additional data is
necessary to confirm that previously “tested-out” lines continue to
contribute low levels of lead under the possibly changed conditions
after an exceedance.

3(e) 	General Guidelines

The LCRSTR comply with the guidelines published under the Paperwork
Reduction Act and in accordance with the April 2005 version of the ICR
Handbook prepared by EPA’s Office of Environmental Information, Office
of Information Collection, Collection Strategies Division, 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
LCRSTR do not alter the system or State record-keeping requirements.

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

Data associated with this ICR are collected and maintained at the PWS,
State, and Federal levels. Respondents include—

Owners/operators of PWSs, classified as community water systems (CWSs)
and non-transient non-community water systems (NTNCWSs)

Primacy agencies that must report to EPA Headquarters.

The Standard Industrial Classification (SIC) code for investor-owned
water systems is 4941. The SIC code for both publicly-owned 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 code. States are
respondents when reporting compliance data to EPA and when retaining
federally-required records. The LCRSTR affects the same respondent
classes as the LCR.

4(b) 	Information Requested

(i) Data items

For each of the final regulatory changes, we list the changed data item
requirements for PWSs and States in Exhibits 1 and 2, respectively.
Regulatory change III.B does not request additional information.
Instead, it clarifies existing requests.  The remaining changes either
request addition information or modify in some way the reporting or
distribution of existing information. 

A summary of the data items required by the LCRSTR is discussed below.

Exhibit 1. Changes in PWSs Reporting Data Items

 Regulatory Change	Requirement 	Change in Requirement	New Requirement
Regulatory Citation	Frequency

III.A	For systems with fewer than 5 taps, clarifies that  water systems
must sample all taps at least once and take repeat samples on different
days until five samples are obtained.  	Gives States the discretion to
allow 1 sample per tap for systems that have fewer than 5 taps	NTNCWSs
and CWSs serving <101 with fewer than 5 taps request approval to take
one sample per tap	40 CFR

 141.86 (c)	One time

III.C	For a water system, prohibit systems that exceed the lead Action
Level from initiating or remaining on reduced monitoring based solely on
results of water quality parameter monitoring

Additional tap monitoring  information is generated and reported	40 CFR
141.90(a)(3)

	As necessary

III.D	For systems deemed to have optimized corrosion control, notify the
State in writing prior to any change in treatment or the addition of a
new source.	Changes the timing of notification from after the treatment
change or source addition under the existing regulation to before the
change

40 CFR 141.81(b)(3)(iii)

	As necessary

III.E	Water systems must provide consumers who occupy homes or buildings
that are part of the utility’s monitoring program, with testing
results when their drinking water is tested for lead and copper.  Water
systems certify to State that results have been distributed.	Requires
the distribution of currently available data. No new data is required.
Certification that results have been delivered is provided to State.	40
CFR 141.85(d)	As necessary

III.F	Water systems that exceed the lead action level must provide
information to additional at-risk populations and must conduct specified
public education activities.  Water systems must include a statement on
lead in their CCR.  Water systems certify to State that activities have
been conducted.	Requires the distribution of specified information to
additional at-risk populations and additional public education
activities.	Additional statement on lead is added to the CCR. 
Certification that activities have been conducted is provided to State.
40 CFR 141.85(a) & (b)	As necessary

III.G	Water systems that exceed the lead Action Level must reevaluate
lead service lines classified as “replaced” through testing if they
resume lead service line replacement programs.

Additional lead service line sampling data is generated.	40 CFR
141.84(b) & (c)	As necessary



Exhibit 2. State/Primacy Agency Reporting Data Items

 Regulatory Change	Requirement 	Change in Requirement	New Requirement
Regulatory Citation	Frequency

III.A	If applicable, review system request and approve in writing or by
site verification the number of taps for sampling.	Gives States
discretion to allow certain systems with fewer than 5 taps to take 1
sample per tap	States review systems’ request and approve in writing
or through onsite verification	40 CFR

 141.86 (c)	One time

III.C	Review additional monitoring data and reports from systems that
have exceeded the lead Action Level.

Additional tap monitoring  information is generated and reported	40 CFR
141.90(a)(3)

	As necessary

III.D	Notify the system after an approval decision has been made in
regards to the system’s request to add a new source of water or change
a treatment process prior to implementation. 	Changes the timing of
notification from after the treatment change or source addition under
the existing regulation to before the change	Additional requirement for
approval, rather than simply review.	40 CFR 141.81(b)(3)(iii)

	As necessary

III.E	Review and track system certification regarding distribution of
tap samples to individual monitoring locations.

Additional requirement for review and tracking.	40 CFR 141.85(d)	As
necessary

III.F	Review public education materials content and consult on
activities.  Review and track system certification.

Additional requirement for review, consultation, and tracking.	40 CFR
141.84(b) & (c)	As necessary



(ii) Respondent Activities

Activities from Regulatory Change III.A

		Regulatory Change III.A clarifies EPA’s intent that systems with
fewer than 5 taps take 5 samples per monitoring period. However, III.A
gives States the discretion to allow systems with fewer than 5 taps on a
case by case basis to take 1 sample per tap.  

		Additional Activities for Utilities

		Systems with fewer than 5 taps that are in States that allow 1 sample
per tap will undertake a one time activity to document the number of
appropriate taps, communicate this information with the State, and
request approval to take 1 sample per tap.

		Additional Activities for States

		States that will allow 1 sample per tap will engage in a one time
effort to review, track, and approve submittals from the systems with
fewer than 5 taps on the number of appropriate taps for future sampling.

Activities for Regulatory Change III.B

Regulatory Change III.B should not result in new net activity, although
the timing of activities may be altered in response to the modified
definitions of reporting and compliance periods.  

Activities for Regulatory Change III.C

Regulatory Change III.C specifies that if a system on reduced monitoring
exceeds the lead Action Level with their tap water samples, the system
must revert to the regular monitoring schedule for lead tap sampling.
State/Primacy agencies will be involved in review of utility monitoring
reports. 

		Additional Activities for Utilities

	

If utilities are triggered into regular monitoring, they will need to
collect and analyze additional samples. Specifically, each utility will
conduct additional monitoring events in each three year period by
switching from a reduced monitoring schedule (annual or triennial) to
standard tap monitoring (semi-annual). In addition, the number of
samples collected in each monitoring period will change when the utility
switches from reduced monitoring to standard monitoring. 

In addition to new monitoring activities, utilities will have to meet
reporting requirements to the State/Primacy agency. For example,
utilities will need to analyze and summarize monitoring results from the
additional monitoring events in a report to the State/Primacy agency.

		

		Additional Activities for States

Regulatory Change III.C will require State/Primacy agencies to review
additional utility monitoring reports as a result of resuming the
standard monitoring schedule. 

		Activities for Regulatory Change III.D

		The current rule in Section 141.90(a)(3) requires that systems deemed
to have optimized corrosion control under §141.81(b)(3), systems
subject to reduced monitoring pursuant to §141.86(d)(4), or systems
subject to a monitoring waiver pursuant to §141.86(g) must notify
States no later than 60 days after of a treatment change or the addition
of a new source. The rule modification requires that these systems
notify States of treatment changes or additions of new sources in
advance and the States determine when and if these changes may be made
through a formal review and approval process. This gives water systems
the opportunity to consult with their States as much as they want and to
take other measures necessary to avoid problems with corrosion. It also
allows States to design monitoring programs upfront or require
additional actions for the systems for those situations when it is
necessary to ensure that corrosion control is being maintained
adequately after the change has been made.

	Additional Activities for Utilities

System activities will include the preparation of a submittal to the
State (e.g. water quality data, LCR tap monitoring data, description of
existing treatment and proposed treatment); and coordination with the
State/Primacy agency during the review. These are all reporting
activities.

		Additional Activities for States

The activities associated with the formal review and approval process
for changes in treatment that may influence optimal corrosion control
are a new requirement for those States that do not currently have such a
requirement. Other State/Primacy agency activities will include review
of system data/reports, internal meetings regarding approval, and
coordination with systems. These activities are all review activities. 

 		Activities Associated with Regulatory Change III.E

		Systems take tap samples to test for lead for several purposes, most
notably to calculate compliance with the Action Level. The purpose of
this change in rule language is to add the requirement that systems
provide consumers (owners and occupants) with the tap monitoring results
for samples taken at routine lead and copper monitoring sites. The
change modifies Sections 141.80(g) and 141.85, and adds a new Section
41.85(e) on the notification of results. This new section specifies the
timing (within 30 days of learning of the results), the content of the
notification, and the method of delivery for the notification.

		Additional Activities for Utilities

		Regulatory Change III.E will require CWSs to provide written
notification to each owner/occupant of the lead level found in the tap
sample collected for LCR compliance monitoring. The notification burden
for NTNCWSs will be different, and may consist of posting a notice on
community bulletin boards or web sites. 

		New activities will not be triggered for utilities that are already
required by their State/Primacy agency to notify individual
owners/occupants of lead results or are already notifying on a voluntary
basis. 

		Specific activities for CWSs include the increase in labor in order to
prepare and distribute a customer letter containing monitoring results
and the preparation and submittal of a letter to the State certifying
that customers have been notified.

		Specific activities for NTNCWSs include the labor required to prepare
a consumer notice, post the notice, and prepare and submit a letter to
the State certifying that consumers have been notified.

		Additional Activities for States

		Specific activities for States include reviewing and tracking
self-certifications from water systems.

		Activities Associated with Regulatory Change III.F

The purpose of this regulatory change is to modify the public education
requirements of the Lead and Copper Rule (LCR) in the Code of Federal
Regulations §141.85. Water systems would still be required to deliver
public education materials after a lead Action Level exceedance.
However, the content of the message to be provided to consumers, how the
materials are delivered, and the timeframe for delivery will be
modified. The changes to the delivery requirements include additional
organizations that systems must partner with to disseminate the message
to at-risk populations as well as changes to the media used to
disseminate information to ensure water systems reach consumers when
there is an Action Level exceedance.

Additional Activities for Utilities

	Regulatory Change III.F will require systems that exceed the lead
Action Level to change mandatory language of public notification,
deliver materials to additional at-risk populations, include information
on quarterly billings, and conduct additional public education
activities.  All CWSs are required to include language on lead in their
CCRs.

	Specific activities for CWSs that exceed the lead Action Level include
preparing notification language, identifying additional at-risk
populations and distributing materials to these populations, conducting
additional public education activities, including a notice on quarterly
billings, and posting a notice on a website.  All CWSs will include
mandatory language on lead in the CCR.  Systems will also consult with
States on the content of public education materials and the choice of
public education activities.  Systems will also prepare a letter
certifying the activities have been undertaken.

	Specific activities for NTNCWSs that exceed the lead Action Level
include preparing notification language and conducting additional public
education activities.  Systems will also consult with States on the
content of public education materials and the choice of public education
activities.  Systems will also prepare a letter certifying the
activities have been undertaken.

Additional Activities for Utilities

	Specific activities for States include consulting with systems on the
content of public education materials and the choice of public education
activities, and reviewing and tracking self-certifications from water
systems.

Activities Associated with Regulatory Change III.G

		Under the existing rule, systems that are replacing lead service lines
in response to an Action Level exceedance may sample lead levels from
lead lines. If the sampled lead levels from an individual service lines
is below the Action Level (15 ppb), that line would not have to be
physically replaced, but could be considered replaced towards meeting
the goal of 7 percent replacement. Since these “tested-out” lines
are considered replaced, they do not have to re-evaluated if water
quality conditions or treatments change.

		Regulatory Change III.G requires that these “tested-out” lines be
re-evaluated if a system subsequently exceeds the Action Level and is
triggered back into further lead service line replacements. The
tested-out lines are put back into the inventory of lead service lines
and are then treated as any other line in the inventory, to be either
re-tested and “tested-out” or re-tested and replaced if the lead
levels for the line exceed the Action Level.

		Additional Activities for Utilities

		The primary activities as a result of this regulatory change include
collecting samples from previously “tested-out” lead service lines
(LSLs) and analyzing them for lead. 

		One-Time Activities to Review and Implement Regulatory Changes

Systems and State/Primacy Agencies will conduct one-time activities
associated with reviewing and implementing the overall LCR regulatory
changes. 

		New Activities for Utilities

For systems, implementation activities include reviewing the rule
changes and communicating the requirements with staff. 

		New Activities for States

For States/Primacy Agencies, activities will include regulation
adoption, program development, and miscellaneous communication with
systems.

Summary of Additional Activities Required by LCRSTR

A summary of the types of new activities required by LCRSTR is
summarized in Exhibit 3. 

Exhibit 3. Summary of Additional Activities Required by LCRSTR

Regulatory 

Change	System Costs	State Costs

	System Reporting	Tap Water Monitoring	Public Education	State Review

Regulatory Change III.A	X

	X

Regulatory Change III.B	None – Included in existing information
collection requests

Regulatory Change III.C	X	X

X

Regulatory Change III.D	X

	X

Regulatory Change III.E	X

X	X

Regulatory Change III.F	X

X	X

Regulatory Change III.G

X





4(c)	ICR Approval Activities 

The activities that will take place during the 3-year period covered by
this ICR will vary based on the timing of State implementation.  The
rule is structured to allow for early implementation by States within 6
months of rule publication.  Alternatively, States can take up to 2
years to implement the rule provisions.  Due to the uncertainty in
predicting which States will adopt early implementation and which States
will take the full two years, this ICR contains an upper bound estimate
that assumes that all States will adopt early implementation and a lower
bound estimate that assumes that all States will take the full 2 years. 
The implication for the timing of activities is described below.

Upper Bound: All States Choose Early Implementation (6 months after
publish date) for all activities

Implementation Activities take place from late November 2007 (effective
date) through early start date (after late March 2008).  All annual
costs and the one time costs for Regulatory Change III.A begin in April
1, 2008.  There will be 6 months of annual costs in Year 1 (April, May,
June, July, August, September).

Cost Element	Year 1:

Late 9/07 – Late 9/08	Year 2:

Late 9/08 – Late 9/09	Year 3:

Late 9/09 – Late 9/10

One time Implementation	100%	0%	0%

One time III.A	100%	0%	0%

Annual Costs	50% 	100%	100%



Lower Bound: All States Choose Standard Implementation (2 years after
publish date) for all activities

Implementation Activities take place from late November 2007 (effective
date) through start date (after late September 2009) a period of 22
months (10 months in Year 1 and 12 months in Year 2).  All annual costs
and the one time costs for Regulatory Change III.A begin in October 1,
2009. 

Cost Element	Year 1:

Late 9/07 – Late 9/08	Year 2:

Late 9/08 – Late 9/09	Year 3:

Late 9/09 – Late 9/10

One time Implementation	45%	55%	0%

One time III.A	0%	0%	100%

Annual Costs	0% 	0%	100%



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 short term revision to the LCR. The Agency is
involved in the following activities that assist States in implementing
the modifications:

Develop the short-term regulations; and

Respond to questions on the short-term regulations.

5(b) 	Collection Methodology and Management

The data generated as a result of the regulatory changes will be
integrated in the existing quarterly SDWIS reporting process. The
collection methodology and management of SDWIS is described in the 2004
ICR.

5(c) 	Small Entity Flexibility

EPA has previously described considerations pertaining to small systems
in the 1991 ICR, (refer to pages 14-18). In addition, 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 considered the particular needs of small business when proposing
rule changes in the LCRSTR. For example, Regulatory Change III.C
requires systems that have exceeded the lead Action Level to resume tap
monitoring for lead on a regular, rather than reduced, schedule.
Originally, EPA had considered extending this requirement to both lead
and copper monitoring. Based on suggestions from the work group to
minimize impacts on small systems, EPA limited the requirement to only
lead Action Level exceedances.

Regulatory Change III.E requires systems to provide lead monitoring
results to consumers. The work group discussed including copper
monitoring results in the notification, but deferred that suggestion for
future consideration, thereby limiting the increase in burden for small
systems. In addition, EPA continues to be interested in the potential
impacts of the rule on small entities and welcome comments on issues
related to such impacts

EPA has prepared a Regulatory Flexibility Act analysis for the short
term changes, which can be found in the Economic Analysis. 

EPA recognizes that some water systems are small entities; therefore,
the LCRSTR reduces to the extent practicable and appropriate the burden
on PWSs, especially smaller systems. The regulations include the
following examples of reduced burden for small systems:

Different compliance or reporting requirements or schedules that take
into account the resources available to smaller water systems. 

Consolidated or simplified compliance and reporting requirements.

No unnecessary or redundant requirements.

5(d) 	Collection Schedule

For both the LCR and LCRSTR 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
protecting public health. When 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.

	Some of the regulatory changes associated with the LCRSTR increase the
frequency of data collection and reporting. EPA has deemed this change
necessary to continue to protect public health and ensure the quality of
drinking water. For example, Regulatory Change III.C prevents systems
from switching to reduced monitoring based solely on results of water
quality parameter monitoring. 

Regulatory Change III.D clarifies the initial intent of the regulatory
change proposed in the LCRMR. This change requires systems monitoring
annually or less frequently to notify the State prior to changes in the
system’s 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 will increase due to these changes in the system’s
treatment. Otherwise, a State would be unaware of potential changes in
lead and copper levels until the next monitoring results were submitted,
which could be as long as nine years.

	Regulatory Change III.F requires all systems to provide specific
information language on lead in their annual CCR.   Previously, only
systems whose 95 percentile exceeded the lead action level were required
to report lead levels to their CCR. Regulatory Change III.F also
requires systems that exceed the lead action level to notify customers
more frequently than previously required. These efforts better ensure
at-risk populations receive adequate and timely lead information and are
able to act to reduce their lead exposure.  

	Regulatory Change III.G requires systems to reevaluate lead service
lines classified as “replaced” through testing if the system resumes
a lead service line replacement program. Reevaluating “replaced”
lead service lines ensures that all potential sources of lead are
examined in order to increase public health after lead exceedences. 

6. 	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

		This section describes the estimates of burden and direct costs to
implement the final regulatory changes to utilities and States.  This
ICR only focuses on the incremental changes to burden and costs that
will result from the short term regulatory changes. The burden and costs
associated the other elements of the Lead and Copper rule continue to be
described and accounted for in the 2004 ICR. 

	

	The burden and cost estimates in this ICR are based on the calculations
documented in the Economic Analysis and Supporting Analyses for the
Short Term Regulatory Revisions and Clarifications to the Lead and
Copper Rule. Major underlying assumptions and data sources are
summarized in Appendix B and detailed in the Economic Analysis. 
Detailed calculations are found in Appendix C.

	6(a) 	Estimating Respondent Burden

The following sections discuss the costs and burden faced by PWSs and
States.  Exhibit 4 presents a summary of estimated responses, burden,
and costs for the 3-year window of the ICR for the upper bound estimate.
 Exhibit 5 presents the same information for the lower bound estimate.

Exhibit 4: Average Annual Responses, Average Total Burden and Average
Total Costs for the LCRSTR - Upper Bound Estimate

(4th Quarter 2006$)

	

Responses	

Burden Hours	

Annualized Capital Costs 	Annual Labor Costs	Annual O&M Costs	Annual
Labor and O&M Costs	

Total Annual Costs



PWSs	391,671	271,997	$0	$8,129,188	$293,920	$8,423,108	$8,423,108



States & Territories	34,812	25,125	$0	$1,096,473	$1,284	$1,097,758
$1,097,758



Total	426,483	297,122	$0	$9,225,661	$295,205	$9,520,866	$9,520,866

Notes:  Detail may not add exactly to total due to independent rounding.

Exhibit 5: Average Annual Responses, Average Total Burden and Average
Total Costs for the LCRSTR - Lower Bound Estimate

(4th Quarter 2006$)

	

Responses	

Burden Hours	

Annualized Capital Costs 	Annual Labor Costs	Annual O&M Costs	Annual
Labor and O&M Costs	

Total Annual Costs



PWSs	171,849	189,369	$0	$5,466,403	$117,886	$5,584,289	$5,584,289



States & Territories	14,675	17,628	$0	$768,412	$831	$769,243	$769,243



Total	186,524	206,997	$0	$6,234,816	$118,717	$6,353,532	$6,353,532

Notes:  Detail may not add exactly to total due to independent rounding.

6a(i)	Burden and Cost to PWSs tc \l3 "6a(i)	Burden and Cost to PWSs 

Information collection activities of PWSs required under this rule will
result in average annual national cost of $8.4 million and a
corresponding annual burden of 271,997 person-hours at the upper bound
and $5.6 million and 189,369 hours at the lower bound.  Of the $8.4
million average annual cost, $8.1 million is for labor costs and $0.3
million is for O&M costs, mainly for postage, materials and laboratory
costs.  Of the $5.6 million at the lower bound, $5.5 million is for
labor costs and $0.1 million is for O&M costs (postage, materials, and
laboratory costs). Appendix B provides the detailed assumptions and
Exhibit C displays the calculations used to derive the burden and costs
estimates. 

During the initial 3-year period, systems will incur one-time startup
activities, including reading the rule and training staff, and ongoing
annual activities after rule implementation is complete.  

	6a(i)a	Start-Up Activities tc \l4 "6a(i)a	Start-Up Activities 

Systems will incur a one-time burden associated with the upfront
activities for the   final regulatory changes, such as reviewing the
rule changes and communicating regulatory requirements to staff and
management. These activities will be undertaken by the 72,213 CWSs and
NTNCWSs that must comply with the LCR.  The burden per system is
estimated to range from 5 to 40 hours, depending on the size of the
system. The total burden, for the 3-year period, for all systems is
estimated to be 399,159 hours, at an annual average over the 3 years of
133,053 hours. Costs associated with the start-up activities are
estimated at $11.0 million over 3 years, $3.66 million annually.

	6a(i)b	Annual Activities tc \l4 "6a(i)b	Annual Activities 

After rule implementation is compete, total annual activity costs and
burden for PWSs are estimated to be $5.7 million and 165,256 burden
hours per year.  Included in this category are costs and burden for each
of the regulatory changes.  Details of these estimates can be found in
Appendix B.  

6a(ii)	Burden and Cost to States tc \l3 "6a(ii)	Burden and Cost to
States 

Total annual average State labor cost is $1.1 million and 25,125 hours
burden at the upper bound and $0.8 million and 17,628 hours burden at
the lower bound.  The vast majority of costs are for State labor, with
only $1,284 for O&M at the upper bound and $831 for O&M at the lower
bound, consisting of costs for postage and materials.

		6a(ii)a	Start-Up Activities tc \l4 "6a(ii)a	Start-Up Activities 

States will also incur a one-time burden associated with upfront
activities for the final regulatory changes, such as regulation
adoption, program development, and miscellaneous communication.
Fifty-seven primacy agencies will review and implement the final LCRSTR,
which includes 50 States, 6 territories and 1 Indian Tribe. The burden
per State is estimated to be 600 hours/State. Applying these assumptions
result in a total upfront burden of 34,200 at a cost of $1.5 million. 
The average annual burden over the 3-year period for these start-up
activities is estimated at 11,400 hours per year, $0.5 million. 

	6a(ii)b Annual Activities tc \l4 "6a(ii)b Annual Activities 

After implementation is complete, the States are expected to spend a
total of 14,993 burden hours annually performing at a cost of $0.7
million.  Details of these estimates can be found in Appendix B.		

6(b)	Time Frame for Cost and Burden Estimates tc \l2 "6b	Time Frame for
Cost and Burden Estimates 

The activities that will take place during the 3-year period covered by
this ICR will vary based on the timing of State implementation.  The
rule is structured to allow for early implementation by States within 6
months of rule publication.  Alternatively, States can take up to 2
years to implement the rule provisions.  Due to the uncertainty in
predicting which States will adopt early implementation and which States
will take the full two years, this ICR contains an upper bound estimate
that assumes that all States will adopt early implementation and a lower
bound estimate that assumes that all States will take the full 2 years. 
The implication for the timing of activities is described below.

Upper Bound: All States Choose Early Implementation (6 months after
publish date) for all activities

Cost Element	Year 1:

Late 9/07 – Late 9/08	Year 2:

Late 9/08 – Late 9/09	Year 3:

Late 9/09 – Late 9/10

One time Implementation	100%	0%	0%

One time III.A	100%	0%	0%

Annual Costs	50% 	100%	100%



Lower Bound: All States Choose Standard Implementation (2 years after
publish date) for all activities

Cost Element	Year 1:

Late 9/07 – Late 9/08	Year 2:

Late 9/08 – Late 9/09	Year 3:

Late 9/09 – Late 9/10

One time Implementation	45%	55%	0%

One time III.A	0%	0%	100%

Annual Costs	0% 	0%	100%



Based on these assumptions, Exhibits 6 - 11 display the timing of the
burden for Systems and States by year and regulatory activity.  Exhibits
12 - 17 display the costs by year and regulatory activity. 

Exhibit 6: System Burden By Year, Upper Bound

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10	Number of Respondents Per Year	Average Per
Respondent Per Year

III.A	3,692	0	0	3,692	1,231	3,692	0.3

III.B	0	0	0	0	0	N/A	0.0

III.C	42,507	85,015	85,015	212,536	70,845	903	78.5

III.D	4,003	8,006	8,006	20,015	6,672	1,067	6.3

III.E	20,118	40,236	40,236	100,590	33,530	64,273	0.5

III.F	14,368	28,737	28,737	71,842	23,947	52,257	0.5

III.G	1,632	3,263	3,263	8,158	2,719	34	80.0

Rule Review	399,159	0	0	399,159	133,053	72,213	1.8

TOTAL	485,479	165,256	165,256	815,991	271,997	72,213	3.8



Exhibit 7: State Burden By Year, Upper Bound

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10	Number of Respondents Per Year	Average Per
Respondent Per Year

III.A	3692	0	0	3,692	1,231	57	22

III.B	0	0	0	0	0	N/A	0

III.C	930	1,860	1,860	4,651	1,550	57	27

III.D	4,003	8,006	8,006	20,015	6,672	57	117

III.E	1,835	3,671	3,671	9,177	3,059	57	54

III.F	728	1,456	1,456	3,640	1,213	57	21

III.G	0	0	0	0	0	57	0

Rule Review	34,200	0	0	34,200	11,400	57	200

TOTAL	45,389	14,993	14,993	75,375	25,125	57	441



Exhibit 8: Total Burden By Year, Upper Bound 

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10

III.A	7,384	0	0	7,384	2,461

III.B	0	0	0	0	0

III.C	43,438	86,875	86,875	217,188	72,396

III.D	8,006	16,012	16,012	40,029	13,343

III.E	21,953	43,907	43,907	109,767	36,589

III.F	15,096	30,193	30,193	75,482	25,161

III.G	1,632	3,263	3,263	8,158	2,719

Rule Review	433,359	0	0	433,359	144,453

TOTAL	530,868	180,249	180,249	891,366	297,122



 

Exhibit 9: System Burden By Year, Lower Bound

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10	Number of Respondents Per Year	Average Per
Respondent Per Year

III.A	0	0	3,692	3,692	1,231	3,692	0.3

III.B	0	0	0	0	0	N/A	0.0

III.C	0	0	85,015	85,015	28,338	903	31.4

III.D	0	0	8,006	8,006	2,669	1,067	2.5

III.E	0	0	40,236	40,236	13,412	64,273	0.2

III.F	0	0	28,737	28,737	9,579	52,257	0.2

III.G	0	0	3,263	3,263	1,088	34	32.0

Rule Review	179,622	219,537	0	399,159	133,053	72,213	1.8

TOTAL	179,622	219,537	168,948	568,107	189,369	72,213	2.6



Exhibit 10: State Burden By Year, Lower Bound

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10	Number of Respondents Per Year	Average Per
Respondent Per Year

III.A	0	0	3692	3,692	1,231	57	22

III.B	0	0	0	0	0	N/A	0

III.C	0	0	1,860	1,860	620	57	11

III.D	0	0	8,006	8,006	2,669	57	47

III.E	0	0	3,671	3,671	1,224	57	21

III.F	0	0	1,456	1,456	485	57	9

III.G	0	0	0	0	0	57	0

Rule Review	15,390	18,810	0	34,200	11,400	57	200

TOTAL	15,390	18,810	18,685	52,885	17,628	57	309



Exhibit 11: Total Burden By Year, Lower Bound 

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10

III.A	0	0	7,384	7,384	2,461

III.B	0	0	0	0	0

III.C	0	0	86,875	86,875	28,958

III.D	0	0	16,012	16,012	5,337

III.E	0	0	43,907	43,907	14,636

III.F	0	0	30,193	30,193	10,064

III.G	0	0	3,263	3,263	1,088

Rule Review	195,012	238,347	0	433,359	144,453

TOTAL	195,012	238,347	187,633	620,992	206,997

 Exhibit 12: System Cost By Year, Upper Bound 

(4th Quarter 2006$)

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10	Number of Respondents Per Year	Average Per
Respondent Per Year

III.A	$104,094	$0	$0	$104,094	$0	3,685	$28.25

III.B	$0	$0	$0	$0	$0	N/A	$0.00

III.C	$1,347,938	$2,695,876	$2,695,876	$6,739,689	$2,246,563	903
$2,487.89

III.D	$382,541	$765,083	$765,083	$1,912,707	$637,569	1,067	$597.29

III.E	$624,061	$1,248,122	$1,248,122	$3,120,306	$1,040,102	64,273	$16.18

III.F	$429,575	$859,150	$859,150	$2,147,875	$715,958	52,257	$13.70

III.G	$54,704	$109,407	$109,407	$273,519	$91,173	34	$2,681.56

Rule Review	$10,971,135	$0	$0	$10,971,135	$3,657,045	72,213	$50.64

TOTAL	$13,914,048	$5,677,638	$5,677,638	$25,269,324	$8,423,108	72,213
$116.64

 

Exhibit 13: State Cost By Year, Upper Bound

(4th Quarter 2006$)

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10	Number of Respondents Per Year	Average Per
Respondent Per Year

III.A	$162,269	$0	$0	$162,269	$54,090	57	$949

III.B	$0	$0	$0	$0	$0	N/A	$0

III.C	$40,938	$81,877	$81,877	$204,692	$68,231	57	$1,197

III.D	$174,212	$348,424	$348,424	$871,060	$290,353	57	$5,094

III.E	$81,678	$163,355	$163,355	$408,388	$136,129	57	$2,388

III.F	$31,686	$63,372	$63,372	$158,431	$52,810	57	$926

III.G	$0	$0	$0	$0	$0	N/A	$0

Rule Review	$1,488,433	$0	$0	$1,488,433	$496,144	57	$8,704

TOTAL	$1,979,216	$657,029	$657,029	$3,293,273	$1,097,758	57	$19,259



 Exhibit 14: Total Cost By Year, Upper Bound

(4th Quarter 2006$)

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10

III.A	$266,363	$0	$0	$266,363	$88,788

III.B	$0	$0	$0	$0	$0

III.C	$1,388,876	$2,777,753	$2,777,753	$6,944,382	$2,314,794

III.D	$556,753	$1,113,507	$1,113,507	$2,783,766	$927,922

III.E	$705,739	$1,411,478	$1,411,478	$3,528,694	$1,176,231

III.F	$461,261	$922,522	$922,522	$2,306,306	$768,769

III.G	$54,704	$109,407	$109,407	$273,519	$91,173

Rule Review	$12,459,568	$0	$0	$12,459,568	$4,153,189

TOTAL	$15,893,264	$6,334,667	$6,334,667	$28,562,597	$9,520,866

Exhibit 15: System Cost By Year, Lower Bound

(4th Quarter 2006$) 

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10	Number of Respondents Per Year	Average Per
Respondent Per Year

III.A	$0	$0	$104,094	$104,094	$0	3,685	$28.25

III.B	$0	$0	$0	$0	$0	N/A	$0.00

III.C	$0	$0	$2,695,876	$2,695,876	$898,625	903	$995.16

III.D	$0	$0	$765,083	$765,083	$255,028	1,067	$238.92

III.E	$0	$0	$1,248,122	$1,248,122	$416,041	64,273	$6.47

III.F	$0	$0	$859,150	$859,150	$286,383	52,257	$5.48

III.G	$0	$0	$109,407	$109,407	$36,469	34	$1,072.62

Rule Review	$4,937,011	$6,034,124	$0	$10,971,135	$3,657,045	72,213
$50.64

TOTAL	$4,937,011	$6,034,124	$5,781,732	$16,752,867	$5,584,289	72,213
$77.33



Exhibit 16: State Cost By Year, Lower Bound

(4th Quarter 2006$)

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10	Number of Respondents Per Year	Average Per
Respondent Per Year

III.A	$0	$0	$162,269	$162,269	$54,090	57	$949

III.B	$0	$0	$0	$0	$0	N/A	$0

III.C	$0	$0	$81,877	$81,877	$27,292	57	$479

III.D	$0	$0	$348,424	$348,424	$116,141	57	$2,038

III.E	$0	$0	$163,355	$163,355	$54,452	57	$955

III.F	$0	$0	$63,372	$63,372	$21,124	57	$371

III.G	$0	$0	$0	$0	$0	N/A	$0

Rule Review	$669,795	$818,638	$0	$1,488,433	$496,144	57	$8,704

TOTAL	$669,795	$818,638	$819,297	$2,307,730	$769,243	57	$13,495

 

Exhibit 17: Total Cost By Year, Lower Bound 

(4th Quarter 2006$)

Regulatory Change	Year 1: 

Late 9/07 - Late 9/08	Year 2: 

Late 9/07 - Late 9/08	Year 3: 

Late 9/09 - Late 9/10	Total 

Late 9/07 - Late 9/10	Average

Late 9/07 - Late 9/10

III.A	$0	$0	$266,363	$266,363	$88,788

III.B	$0	$0	$0	$0	$0

III.C	$0	$0	$2,777,753	$2,777,753	$925,918

III.D	$0	$0	$1,113,507	$1,113,507	$371,169

III.E	$0	$0	$1,411,478	$1,411,478	$470,493

III.F	$0	$0	$922,522	$922,522	$307,507

III.G	$0	$0	$109,407	$109,407	$36,469

Rule Review	$5,606,806	$6,852,762	$0	$12,459,568	$4,153,189

TOTAL	$5,606,806	$6,852,762	$6,601,029	$19,060,597	$6,353,532

 

6(c) 	Estimating Agency Burden and Cost

Information-related activities that may be undertaken by both EPA
headquarters and regional offices include reviewing, interpreting and
explaining the new regulations to States that ask for guidance. For
example, during the implementation process, EPA headquarters or regions
might be asked for explanations or interpretations of the intent of the
new regulations. EPA believes that these regulatory changes are
relatively straightforward and limited in scope, and expects that the
preamble language will generally be sufficient for the purpose of
explaining EPA’s intent. Therefore, the additional burden incurred by
headquarters and regional offices is expected to be minimal.

Further, the burden and costs incurred by EPA’s drinking water program
at headquarters and regional offices to assist primacy agencies in
implementing drinking water regulations are already included in existing
ICRs. EPA burden and costs for on-going regulatory development and
support activities for all EPA drinking water regulations are accounted
for under the PWSS Program ICR.  Agency activities specifically related
to the LCR have also been addressed in the 2004 ICR.  Thus, any minimal
burden that may be incurred by the Agency related to the LCRSTR has
already been adequately captured under existing ICRs.

6(d)	Respondent Universe tc \l2 "6d	Respondent Universe 

There are a total of 72,213 PWSs and 57 States and territories
considered for this Information Collection Request.

6(e)	Bottom Line Burden Hours and Costs tc \l2 "6e	Bottom Line Burden
Hours and Costs 

This section provides a description of bottom line estimates for
implementation of the rule.  The bottom line burden hours and costs for
systems and States are the summaries of the hours and costs collectively
incurred for all activities.  The first part of this section describes
the estimated average annual costs and hourly burdens for respondents to
the rule.  The second part discusses the potential cost and burden to
EPA.  Exhibit 18 presents a summary of the average annual respondent
burden over 3 years for PWSs and States.  

Exhibit 18. Bottom Line Average Annual Burden and Costs, Upper and Lower
Bound

(4th Quarter 2006$)

	Lower Bound	Upper Bound

	

Number of Respondents	

72,270 =72,213

+57	

         72,270=72,213

+57	

Public water systems

States 



Total Annual Responses	

186,524 =171,849

+14,675	

426,483 =391,671

+34,812	

Public water system responses

State responses



Number of Responses per PWS	

2.4 =171,849

 /72,213	

5.4 =391,671

/ 72,213	

Total annual PWS responses from above

Total public water systems from above



Number of Responses per State	

257 =14,675

/57	

611=34,812

/57	

Total annual State responses from above

Total States from above



Total Annual Respondent Burden Hours	

206,997 =189,369

+17,628	

297,122 =271,997

+25,125	

Public water system hours

State hours



Hours per System

for Public Water Systems	

2.6  = 189,369

/72,213	

3.8 = 271,997

/72,213	

Total PWS annual hours from above

Total PWS from above



Hours per State for States	

309 =17,628

/57	

441 =25,125

/57	

Total State annual hours from above

Total States from above



Annual O&M Costs	

$118,717 = $117,886

+$831	

 $295,205=$293,920

+$1,284	

Public water system O&M costs

State O&M costs



Total Annual Respondent Cost	

$6,353,532

=$5,584,289

+ $769,243	

$9,520,866

=$8,423,108

+$1,097,758	

Public water system costs

State costs



Total Annual Hours (respondent plus Agency)	

206,997  =206,997

+0	

297,122  =297,122

+0	

Total respondent hours

Total EPA hours



Total Annual Cost (respondent plus Agency)	

$6,353,532

=$6,353,532

+$0	

$9,520,866

 =$9,520,866

+$0	

Total respondent cost

Total EPA cost

Note: Detail may not add exactly to total due to independent rounding. 
EPA burden and cost estimated under PWSS program.

6e(i)	Bottom Line Burden and Cost Estimates for Respondents tc \l3
"6e(i)	Bottom Line Burden and Cost Estimates for Respondents 

The total annual average respondent burden associated with this ICR is
estimated to be 206,997- 297,122 burden hours.  The corresponding total
annual average respondent costs are estimated to be $6.4 to $9.5
million.

EPA estimates the annual respondent burden for PWSs to be 189,369 -
271,997 hours.  Annual respondent costs for PWSs are estimated to be
$5.6 to $8.4 million.  The Agency estimates that the annual respondent
burden for States is 17,628 – 25,125 hours.  The corresponding annual
average respondent costs for States are estimated to be $0.8 to $1.1
million.

6e(ii)	Bottom Line Estimate for Agency tc \l3 "6e(ii)	Bottom Line
Estimate for Agency 

Any additional burden or cost that EPA may incur as a result of the
LCRSTR implementation activities is expected to be minimal and is
already accounted for in existing ICRs, as explained in 6(c).

6(f) 	Reasons For Change In Burden

The LCRSTR is intended to strengthen the implementation of the LCR in
the areas of monitoring, customer awareness, and lead service line
replacement in the short-term. Some of the changes clarify the intent of
the LCR for provisions that have generated questions. Other provisions
reconsider LCR requirements in light of recent experience. These changes
are expected to ensure and enhance more effective protection of public
health through the reduction in lead exposure.

6(g) 	Burden Statement

For the ICR period of September 2007 through September 2010 associated
with the LCRSTR, the average annual burden per system for the LCRSTR is
estimated to be 2.6 to 3.8 hours per system per year. System burden
includes the time required for implementation activities, such as
reviewing the rule changes and communicating results, as well as
activities related to the regulatory changes. The average annual cost
per system is expected to be $77 - $117 per system per year. The average
annual burden per State is estimated to be 309 - 441 hours per State per
year. This burden includes the time required for implementation
activities, such as informing systems of the requirements, regulation
adoption, program development, and miscellaneous communication, as well
as activities related to the regulatory changes. The estimated average
annual cost per State is estimated to be $13,500 - $19,300 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.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under

Docket ID Number EPA-HQ-OW-2005-0034, which is available for public
viewing at the Office of Water Docket in the EPA Docket Center (EPA/DC),
EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The
EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30
p.m., Monday through Friday, excluding legal holidays. The telephone
number for the Reading Room is (202) 566-1744, and the telephone number
for the Office of Water Docket is (202) 566-2426. An electronic version
of the public docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket. Use EDOCKET to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically. When in the system, select “search,” then key in the
Docket ID Number identified above. Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA. Please include the EPA Docket ID Number
EPA-HQ-OW-2005-0034 and OMB Control Number 2040-0204 in any
correspondence.



APPENDICES

Appendix A: 

SDWA Sections that Provide Authority for the Collection

Appendix B: 

Detailed Assumptions Used to Estimate Burdens, Costs, and Number of
Responses 

Appendix C: 

Detailed Calculations for the Estimates of Burden, Cost, and Responses



APPENDIX A

Safe Drinking Water Sections that

Provide Authority for the Collection

APPENDIX A

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.

(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
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
point-of-use treatment units shall be owned, controlled and maintained
by the public water system or by a person 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
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.

APPENDIX B

Detailed Assumptions and Tables Used to Estimate Burdens, Costs, and
Number of Responses 

Overall Burden and Cost Methodologies and Assumptions

		

		As part of its comprehensive review of the Lead and Copper Rule, EPA
collected and analyzed new data on various aspects of LCR
implementation. When available, this new information is the first choice
source for use in estimating burden and costs. Sources of the new
information include the following.

Medium and Large Public Water Systems Exceeding the Lead Action Level
Summary from SDWIS/FED data as of January 27, 2005 provides up-to-date
counts of the number of medium and large systems that have exceeded the
Action Level since 2000 and 2003.

Summary, Lead Action Level exceedances for public water systems subject
to the Lead and Copper Rule (For data through September 13, 2004)
provides up-to-date counts of the number of small systems that have
exceeded the Action Level since 2000 and 2003.

State responses to EPA’s “ Survey of States Questions on State
Implementation of the Lead and Copper Rule” (July 2004) provides
information on the number of systems that are conducting lead service
line replacement under the LCR, the fraction of systems on reduced LCR
monitoring, and system practices with regard to notification of
customers of sampling results.

		If new information was not available about a cost item or assumption,
previous analyses of LCR requirements were reviewed to determine if a
suitable estimate was available. The 1991 RIA, the 1996 RIA Addendum,
and the various Information Collection Requests were all used as sources
of information and assumptions.

		Inventory of Systems

		 The primary inventory of systems that will be subject to the
information collection activities was derived from a pull of data from
the SDWIS/FED system in the 4th quarter of 2004, available at  
HYPERLINK "http://www.epa.gov/safewater/data/pivottables.html" 
http://www.epa.gov/safewater/data/pivottables.html , summarized in
FACTOIDS: Drinking Water and Ground Water Statistics for 2004, and
presented in Exhibit 1.  

Exhibit B-1: Number of Systems by Size Category and Type Subject to
Information Collection Activities SDWIS/FED 2004 Data

 	CWS	NTNCWS	TOTAL LCR

<=100	13,766	9,548	23,314

101-500	16,240	6,997	23,237

501-1,000	5,914	1,925	7,839

1,001-3,300	8,298	795	9,093

3,301-10,000	4,707	96	4,803

10,001-25,000	2,107	7	2,114

25,001-50,000	950	6	956

50,001-75,000	343	1	344

75,001-100,000	141	0	141

100,001-500,000	322	0	322

500,001-1,000,000	32	0	32

>1,000,000	18	0	18

Grand Total	52,838	19,375	72,213



		Wage Rates

		Wage rates for systems were taken from the report Labor Costs for
National Drinking Water Rules prepared by Science Applications
International Corporation (SAIC) in October 2003 for EPA’s Office of
Ground Water and Drinking Water. Exhibits 20 and 21 of that report
summarize recommended average technical and managerial wage rates by
system size for EPA to use in cost analyses. These rates are updated to
4th quarter 2006 levels using the Employment Cost Index.  To represent
the composition of staff at PWSs of smaller sizes (e.g., systems serving
fewer than3,300 people), EPA uses only the updated technical rate. For
systems serving 3,300 or more people, EPA uses a ratio of 80 percent
technical labor to 20 percent managerial labor to arrive at a weighted
labor rate. Exhibit B-2 presents the wage rates for systems used in the
cost analyses.

		

Exhibit B-2: Wage Rates for Systems

(4th Quarter 2006$)

System Size Category	Labor Rate ($/hour)



	<= 100	$23.86 

101 to 500	$25.70 

501 to 3,300	$27.54 

3,301 to 10,000	$33.96 

10,001 to 100,000	$34.59

>100,0000	$39.23



		Wage rates for States are based on information provided by the
Association of State Drinking Water Administrators (ASDWA) as presented
in the Information Collection Request for Contaminant Occurrence Data in
Support of EPA's Second Six Year Review of National Primary Drinking
Water Regulations (August 2006).  The average loaded wage rate for
States used in the analysis is $43.52 per hour.		



Detailed Assumptions and Calculations for the Regulatory Changes

	A. Burden Associated with Regulatory Change III.A 

		Regulatory change III.A clarifies EPA’s intent that a minimum of
five samples must be drawn when conducting compliance monitoring. If a
system has fewer than the minimum number of sites required for sampling,
than those systems will have to collect multiple samples on different
days from the same site so that the total number of samples per
monitoring period is at least five.  EPA does, however, give States the
discretion to allow systems with less than 5 taps to take 1 sample per
tap, on a case by case basis.  This analysis assumes that systems in a
subset of States will undertake a one-time activity to prepare and
submit to the State a letter verifying the number of applicable taps for
monitoring.  States will incur an activity to review, track, and approve
the letters.

	B. Burden Associated with Regulatory Change III.B

	Regulatory change III.B clarifies the terms monitoring period and
compliance period, which are used throughout the LCR. Based on the rule
change, if a system exceeds the Action Level during a monitoring period,
non-compliance starts at the end of the monitoring period, which for
most systems, is on September 30. Under the previous language, systems
were confused at to whether non-compliance began at the end of that
compliance period (which is typically December 31) rather than the
monitoring period (September 30). 

	As a result of the rule change, activities triggered by an Action Level
exceedance could begin three months earlier (i.e., at the end of
September rather than at the end of December), but it is not clear if
such activities would last any longer. As explained in Section 4(b)(ii),
the net result is a change in the timing of activities, including the
taking and processing of samples, determination of compliance, and
notification of the State.  A shorter time frame for processing samples
might result in systems inserting bid conditions for laboratories, but
it is not clear if this will result in a burden or cost impact.  For
this reason, EPA does not believe that regulatory change III.B will
result in increased burden.

	C. Burden Associated with Regulatory Change III.C

		Burden to utilities

	As a result of regulatory change III.C, utilities under reduced
monitoring that calculate a 90th percentile lead level that exceeds the
lead Action Level will be required to resume a standard lead and copper
monitoring schedule. In addition to these monitoring activities,
utilities will have to meet reporting requirements to the State/primacy
agency.

The subset of systems that will have additional burden under this
regulatory change are those systems that exceed the lead Action Level
and that had been on reduced monitoring.  These systems are assumed to
undertake an additional 5 monitoring events after an Action Level
exceedance covering a 3 year period (6 monitoring events in three years
under regular monitoring instead of 1 monitoring event in three years
under reduced monitoring).  Based on previous EPA documents, the labor
required to collect and analyze each lead tap sample is estimated at 3.5
hours (2.5 hours to collect and 1.0 hour to analyze), with an additional
material cost of $9.07 per sample (also referred to as the O&M cost).
The burden for calculating the 90th percentile and reporting results to
EPA range from 1.5 hours to 2 hours per monitoring event based on system
size.

The annual system burden, which includes both the reporting and
monitoring burden, associated with regulatory change III.C is 85,014
hours per year. 

		Burden to States

Regulatory change III.C will require States to review additional utility
monitoring reports as a result of systems conducting additional
monitoring events while on a standard monitoring schedule. EPA applied
the same assumptions as described in the system burden section to
estimate the number of system in each system size category that are
affected by regulatory change III.C, and the number of additional tap
monitoring events as affected systems are required to switch from a
reduced monitoring schedule (one monitoring period every 3 years) to a
standard monitoring schedule (one monitoring period every 6 months). 

The annual State review burden per monitoring event is a combination of
the time it takes for States to review a tap sample letter, 1.0 hour,
and the time it takes for States to review a tap sample calculation,
0.17 to 1.0 hour depending on the system size. These burden estimates
are based on assumptions in the 2004 ICR, page H-12. 

The annual State review burden associated with regulatory change III.C
is 1,860 hours per year. A summary of the State burden associated with
this regulatory change is described in Exhibit B-3.

Exhibit B-3: Summary of the Annual Burden Associated with Regulatory
Change III.C

	Labor per Event (hours) 	Respondent Burden (hours/year)

	Tap Monitoring	3.5	82,734

	Reporting	1.5 to 2.0 	2,280

Total System Burden	5 to 5.5	85,014







Review Costs	1.17 to 2.0	1,860

Total State Burden	1.17 to 2.0	1,860



	D. Burden Associated with Regulatory Change III.D

	Regulatory change III.D revises the notification requirement if systems
change the treatment or add new source water. Under the regulatory
change, systems must notify States in advance of making treatment
changes or adding new source water that could potentially interfere with
optimal corrosion control. In addition, the changes must undergo a
formal review and approval process by the State prior to implementation
by the system. Based on projected rule-related treatment changes and
expert judgment, this analysis assumes that approximately 20% of the
systems affected by the LCR will institute a treatment change in the
next ten years.  It is assumed that these changes occur uniformly over
that 10-year period, so that approximately one-tenth of these systems
(or 2 percent of the total) institute a treatment change or source
addition each year.  Systems that have a treatment change or source
addition in a State without an existing review and approval process
would undertake the following activities:

Utility Activity	Burden (hours)

Preparation of letter to State	4 hours

Coordination with State	4 hours

Total	8 hours 



The current LCR regulatory requirements on notification of treatment
changes cause a system burden of 0.5 hours per treatment change.
Therefore, the new system burden is expected to be 8 minus 0.5 hours or
7.5 hours per treatment change.   

In addition, 10 to 20% of medium and large CWSs will need to conduct an
engineering study in order to gain State approval for a treatment change
or new source addition at a burden of approximately 700 – 750 hours
per study. 

The total annual burden for utilities is estimated to be 8,006 hours per
year, as summarized in Exhibit B-4.

		Burden to States

The burden associated with the State’s formal review and approval
process is a new requirement for those States that do not currently have
such a requirement. Additional burden to the State will be from a review
of system data/reports, internal meetings regarding approval, and
coordination with systems. 

Applying the same assumptions as explained above, EPA assumes that there
are 1,067 affected systems. 

EPA calculated a high and low estimate of the State labor burden per
review of a system’s proposed treatment change or new source addition.
Based on the input of EPA and contractor staff familiar with State LCR
implementation, EPA assumed that States may spend from 4 to 8 hours
reviewing a system’s submission, preparing a conclusion, and
coordinating with the system. Since the current LCR requires 0.5 hours
per treatment change, net burden increase per change is 3.5 to 7.5
hours.

The annual State burden is estimated to be 8,006 hours per year after
applying the high assumptions and 3,736 hours per year after applying
the low assumptions, as summarized in Exhibit B-4.

Exhibit B-4: Summary of Burden Associated with Regulatory Change III.D



Labor per Treatment Change (hours)	Respondent Burden (hours/year)

Burden to Systems



	High Estimate 	7.5	8,006

    Low Estimate 	7.5	8,006





	Burden to State



	High Estimate 	7.5	8,006

    Low Estimate 	3.5	3,736

				Note: Only the high estimate is used in subsequent calculations in
the ICR.	

	E.  Burden Associated with Regulatory Change III.E 

		Burden to utilities

		

		Regulatory change III.E will require 52,838 CWSs to provide written
notification to each customer that participated in tap sampling of the
lead level found in the tap sample collected for LCR compliance
monitoring. The notification requirements for the 19,375 NTNCWSs that
must comply with the LCR will be different, and may consist of posting a
notice on community bulletin boards or web sites. The number of systems
required to comply with the LCR is based on SDWIS/FED data 2004.

	

		To calculate burden, EPA assumed that a fraction of utilities already
notify participants of lead sampling results. The fraction was estimated
depending on the system type, system size, and results from the USEPA
Survey of States. The utilities that already notify will not incur
additional burden as a result of regulatory change III.E

		For CWSs, burden results from the labor required to prepare and mail a
customer letter to owners/occupants describing monitoring results. The
number of tap monitoring events was estimated by assuming that 91
percent of all systems are on a reduced monitoring schedule, which
requires one monitoring event every three years, and that the remaining
9 percent of systems employ a standard monitoring schedule, which
requires six monitoring events every three years, or two monitoring
events per year.  In addition, the number of increased monitoring events
that would result from regulatory change III.C (1,692 additional
monitoring events per year) are added to the total. EPA assumed that the
number of letters reporting the sample results to customers is the
number of monitoring events multiplied by the number of samples required
for each system size on standard or reduced monitoring.  The burden to
write and send letters to consumers is assumed to be one hour per
monitoring event for systems serving <3,300 people and one hour per 20
letters for systems serving > 3,300 people. Systems will also incur a
burden of .12 hours to prepare a letter submitted to States certifying
that sampling participants have been notified.  

		The burden to NTNCWSs includes the labor required to prepare a
consumer notice and post the notice. The number of affected systems and
the number of monitoring events is calculated using the same assumptions
as explained for CWSs. However, NTNCWS will prepare and post a consumer
notice, rather than preparing and sending individual letters. Systems
will also incur a burden of .12 hours to prepare a letter submitted to
States certifying that customers have been notified. EPA estimated that
all NTNCWSs will spend one hour to prepare a notice for each monitoring
event. 

		The total annual burden for all public water systems as a result of
regulatory change III.E is estimated to be 40,236 hours per year, as
summarized in Exhibit B-5.

	Burden to State

States will incur a burden for collecting, reviewing, and tracking
self-certification letters from systems of .10 hours per system per
year.  The annual State burden is estimated to be 3,671 hours per year,
as summarized in Exhibit B-5. 

	Exhibit B-5: Summary of Burden Associated with Regulatory Change III.E



Labor per Event (hours)	Respondent Burden (hours/year)

Burden to Systems



	Public Education Activities	1 hour/monitoring event

-or -

1 hour/20 letters

(See Exhibit B-8)	35,831

	System Reporting Activities 	.12/monitoring event for
self-certification letter	4,405





	Burden to State



	Review Costs	.10 per self-certification letter	3,681



	F. Burden Associated with Regulatory Change III.F

		Burden to utilities

		

			(a) Changes to the mandatory text of the written materials

				(a)(1) Customer Notification

	Regulatory change III.F(a)(1) substantially reduces the mandatory
language required for delivery to all bill paying customers after a lead
Action Level exceedance and gives systems more flexibility in developing
the notification. Systems are required to address several topics in the
notification, namely: “sources of lead”, “steps to reduce
exposure”, “what happened”, and “what is being done”. This
analysis assumed that template language will be provided for the sources
of lead and steps to reduce exposure sections. However, by their nature,
the “what happened” and “what is being done” sections will need
to be customized by each system to reflect their specific conditions.
Therefore, the additional activity under this change is the effort
required to develop the sections specific to the system, at an
additional burden of  3.5 hours of labor per system 

(b) Changes to better reach at-risk populations

 (b)(1) Delivery of brochures to organizations

		Activities resulting from regulatory change

Regulatory change III.F(b)(1) requires that CWSs exceeding the lead
Action Level distribute brochures to three additional types of
organizations – obstetric/gynecologist offices, licensed child care
facilities, and pre-schools. Also, a cover letter must now be included
with the brochures and the public health agency must be directly
contacted by phone, rather than through a mailed brochure.  Systems
serving greater than 3,300 will incur an additional 1 hour in burden to
generate and update lists of additional facilities. These systems will
also incur production costs of 0.25 hours for every 100 additional
brochures and applicable mailing and materials costs, as well as an hour
to develop the cover letter and 0.5 hours to directly contact the public
health agency.

(b)(2) Additional activities

	Regulatory change III.F(b)(2) requires systems to perform additional
public notification activities. Systems are given a choice of 8
activities. Systems serving fewer than 3,300 must implement 1 activity
from the list while other systems must implement 3 activities.  The
burden for individual activities varies greatly and are detailed fully
in the LCRSTR Economic Analysis.  Also, determining which activity or
combination of activities systems will regularly choose is subject to
considerable uncertainty. Systems will consider many factors in choosing
activities. Certainly cost will be an important factor, but
effectiveness and ability to reach a variety of audiences may also be
considered. In the absence of information on the selection of
activities, this analysis conservatively assumes that all activities are
equally likely to be chosen.  The average burden per system to conduct
additional public education activities after an Action Level exceedance
is summarized below.

System Size Category	Average Burden per System

25-100	1.90

101-500	1.91

501-3,300	3.25

3.3K-10K	9.83

10K-50K	31.53

50K-100K	64.77

>100K	92.05



(c) Changes to help systems maintain communication with consumers
throughout the exceedance

(c)(1) Adding Note to Customer Bills for CWSs that Exceed the Lead
Action Level

	Regulatory change III.F(c)(1) requires that CWSs exceeding the lead
Action Level include a specific message on every quarterly water bill
during the period of exceedance, instead of on just one bill per year,
resulting in 3 extra billing notifications per year.  The burden
associated with each additional billing notification is 1 hour per
billing cycle, or 3 hours per year.  

(c)(2) Posting notice on website

Regulatory change III.F(c)(2) requires that CWSs serving greater than
100,000  and exceeding the lead Action Level post a notice of the
exceedance on their website, at an annual burden of 0.5 hours per
system.  

(c)(3) Public Service Announcements and Press Releases

		Activities resulting from regulatory change

Regulatory change III.F(c)(3) eliminates the need for systems to submit
public service announcements (PSAs) to radio and TV stations once every
6 months and add the requirement to submit a press release to these
entities once per year while under an Action Level exceedance. The 2004
ICR assumes that, for a PSA, a system will submit the text of a notice
to a radio or TV outlet, not produce a tape or video. Thus, the level of
effort required to submit a PSA is equivalent to the level of effort
required to submit a press release in the 2004 ICR. The substitution of
a press release for a PSA does not result in any change in burden.
However, the reduction in frequency from once every 6 months to once
every year results in reduced effort of 1 notification per year, at a
reduced burden of 1 hour per year. 

	d. Changes to the required timing

	There are no burden implications associated with changing the timing of
notifications.

e. Changes to the Consumer Confidence Report

(e)(1) Adding an informational statement on lead to Consumer Confidence
Report

		

Regulatory change III.F(e)(1) requires that all CWSs include an
informational statement on lead in their Consumer Confidence Report, at
an additional burden of 15 minutes (0.25 hours) per system per year to
include the informational statement in their CCR. 

	System Reporting Activities

	Systems will incur 2 hours per year during an Action Level exceedance
to consult with the States on the choice of activities, alternative
delivery mechanisms, and the timing of activities.  Systems will also
incur .12 hours per year to prepare and submit a letter to States
certifying that they have identified and notified the applicable at-risk
populations and have completed required activities.

Exhibit B-6: Summary of Burden to Systems Associated with Regulatory
Change III.F

Activity	Requirement	Annual Burden per System 	Total Annual Burden

a. Changes to the Mandatory Text of the Written Materials

III.F(a)(1)	Customer Notification 

3,479

b. Changes to Better Reach At-Risk Populations

III.F(b)(1)	Notify Additional Organizations

737

III.F(b)(2)	Additional Activities i-viii

9,749

c. Changes to Help Systems Maintain Communication with Consumers
Throughout the Exceedance

III.F(c)(1)	Customer Bills

1,743

III.F(c)(2)	Post on Website

4

III.F(c)(3)	PSAs and Press Releases

-108

d. Changes to the Required Timing

No burden impact

e. Changes to Consumer Confidence Report

III.F(e)(1)	CCR Statement

13,064

Systems Reporting to States

	Self Certification Letter & State Consult

70

Total Burden to Systems for PE Requirements (III.F)

TOTAL

28,737

Note: Totals may not add due to rounding.

Costs to States (for III.F)

	Under Regulatory Change, States will incur costs to review the language
of public notifications after Action Level exceedances and to consult
with systems on their additional activities. States will no longer have
to approve changes to the communication activities for systems serving
between 501-3,300, resulting in a slight decrease in burden.  The
decrease in burden for States to approve a waiver for systems serving
500-3,301 is assumed to be 0.5 (based on comparable waiver activities in
the 2004 ICR). States will incur an increase in burden to review the
language in the utility’s notice to consumers to make sure the utility
is including the necessary information of 20 minutes per review, based
on existing reviews in the 2004 ICR. States will spend an additional 2
hours to consult with each system about the choice of additional
activities after an Action Level exceedance, alternative delivery
mechanisms, and schedules.  States will also spend an additional .10
hour to review and track self-certification letters from systems.

The burden to States for compliance with Regulatory Change #III.F are
summarized in Exhibit B-7 and estimated to be 1,456 hours annually. 

Exhibit B-7: Summary of Burden Associated with Regulatory Change III.F



Labor per Event (hours)	Respondent Burden (hours/year)

Burden to Systems



	Public Education Activities	See Exhibit B-6	28,667

	System Reporting Activities 	See Exhibit B-6	70





	Burden to State



	Review Costs	.10 per self-certification letter

2 hours consultation	1,456



	G. Burden Associated with Regulatory Change III.G		 

		Burden to utilities

	

		The primary burden for systems that have recently exceeded the lead
Action Level and require LSL replacement includes the following:
collecting lead samples from LSLs that have “tested-out,” analyzing
the samples for lead, and reconsidering the LSLs for replacement. 

		EPA estimates that there are 34 systems that have been required to
conducted LSL replacement. This estimate is based on the States’
responses to a USEPA Survey. Based on the assumption that these systems
will exceed the lead Action Level at the same rate as the universe of
systems, this analysis assumes that 1.4 percent of the affected systems,
or 1 system annually, will re-exceed the lead Action Level and,
therefore, will be required to continue the LSL replacement program.

		To determine how many LSLs are sampled in each affected system per
year, EPA assumed that each utility conducts LSLs replacements at a rate
of 7 percent per year over 15 years. According to the preliminary
findings of a survey being conducted by Black & Veatch for AWWA, 26
respondent utilities had an inventory of 558,135 lead service lines in
1992. Based on this data, the average number of lead service lines per
system is 21,467. In the absence of specific information on the number
of lead service lines in the subset of systems that have been required
to do replacement, this analysis uses the average value from the Black &
Veatch study. EPA estimates that 1,431 LSLs are sampled per year in each
system.

		Costs for this regulatory change apply only to those lead service
lines that have been deemed replaced through “testing-out” in a lead
service line replacement program. Information was available for the lead
service line replacement program for one system (DC WASA) that indicated
that for one year (2003), 76 percent of the lead service lines were
deemed replaced through sampling, while 24 percent were physically
replaced. Because this was early in the replacement program, the percent
of lines tested out might be high in comparison with replacement over an
entire program. In the absence of additional data, this analysis assumes
that 76 percent of lead service lines are “tested-out” and would
then be put back into the inventory upon re-exceedance. 

		Applying these assumptions, EPA estimates that a system would
re-analyze 1,088 samples per year (1,431 LSL times 76 percent of the
LSLs that are “tested-out”) at an estimated 3 hours burden to
collect and analyze samples.  These calculations suggest that regulatory
change III.G will result in an annual burden of 3,263 hours per year as
summarized in Exhibit B-8.

		Burden to States

		No direct burden is expected for States as a result of regulatory
change III.G. Although the State will review utility LSL replacement
program annual reports, these costs were captured previously in the
Final Regulatory Impact Analysis of National Primary Drinking Water
Regulations for Lead and Copper, April 1991. 

Exhibit B-8:  Summary of the Burden Associated with Regulatory Change
III.E



Labor per Sample (hours)	Respondent Burden (hours/year)

Burden to Systems



	Tap Monitoring 	3.0	3,263





	Burden to State



	N/A	--	--



	H. Burden Associated with One Time Implementation Activities

		Burden to Systems

Systems will incur a one-time burden associated with the upfront
activities for the   regulatory changes, such as reviewing the rule
changes and communicating regulatory requirements to staff and
management. These activities will be undertaken by the 72,213 CWSs and
NTNCWSs that must comply with the LCR.  The burden per system is
estimated to range from 5 to 40 hours, depending on the size of the
system. The total burden, for the 3-year period, for all systems is
estimated to be 399,159 hours, at an annual average over the 3 years of
133,053 hours.

		Burden to States

States will also incur a one-time burden associated with upfront
activities for the regulatory changes, such as regulation adoption,
program development, and miscellaneous communication. Fifty-seven
primacy agencies will review and implement the LCRSTR, which includes 50
States, 6 territories and 1 Indian Tribe. The burden per State is
estimated to be 600 hours/State. Applying these assumptions result in a
total upfront burden of 34,200 burden for the 3-year period, at an
average of 11,400 per year.

Exhibit B-9: Summary of Burden Associated with Upfront Activities for
LCRSTR



Labor per System or State (hours)	Respondent Burden (hours/year)

Burden to Systems



	Read/Communicate Rule	5 to 40	133,053

Total Burden to Systems	--	133,053





	Burden to State



	All States	600	11,400

		

	Summary of Costs to States and Systems

The annual costs for systems associated with the upfront activities for
the regulatory changes are equal to the annual respondent burden
multiplied by the appropriate labor rate. The estimated labor rate
ranges from $22.70/hour to $33.10/hour, depending upon the system size
category, as explained in Exhibit 2.  Annual system costs are summarized
in Exhibit B-10 and one-time costs in Exhibit B-11.

		The annual labor costs for States associated with the annual
activities for all seven regulatory changes are equal to the annual
State burden multiplied by the labor rate.  Annual State costs are
summarized in Exhibit B-10 one-time costs in Exhibit B-11.

Exhibit B-10:  Summary of Annual Direct Costs to Systems and States from
Regulatory Changes

(4th Quarter 2006$)

 	System Costs	 	State Costs	 

Regulatory	System	 	Public	System	Review &	 

Change	Reporting	Monitoring	Education	Total	Consult	TOTAL

III.A	-	-	-	-	-	-

III.B	-	-	-	-	-	-

III.C	$60,688	$2,635,188	-	$2,695,876	$81,877	$2,777,753

III.D	$765,083	 	 	$765,083	$348,424	$1,113,507

III.E	$135,693	-	$1,112,429	$1,248,122	$163,355	$1,411,478

III.F	$33,734	-	$825,416	$859,150	$63,372	$922,522

III.G	-	$109,407	-	$109,407	 	$109,407

Total - High	$995,198	$2,744,596	$1,937,845	$5,677,639	$657,029
$6,334,667



Exhibit B-11:  Summary of One Time Direct Costs to Systems and States

(4th Quarter 2006$)

 	System Costs	State Costs	TOTAL

III.A	$103,897	$161,961	$265,858

Implementation	$10,971,135	$1,488,433	$12,459,568

Total	$11,075,032	$1,650,394	$12,725,426





APPENDIX C

Detailed Calculations for the Estimates of Burden, Costs and Response

Exhibit C-1: Calculation of Burden Estimates for Regulatory Change
III.A

ONE TIME BURDEN FOR SYSTEMS IN STATES THAT ALLOW 1 TAP PER SAMPLE TO
PREPARE AND SUBMIT TO STATE LETTER VERIFYING NUMBER OF TAPS

11 States that Favor 1 Sample	# Small Systems With <5 taps	One-Time
System Burden for Verification Letters (1)

AK	17	17

IN	380	380

MI	901	901

WI	511	511

IL	249	249

TX	521	521

VT	140	140

UT	45	45

WA	254	254

MD	320	320

MN	322	322

TN	32	32

Total	3692	3692

Notes:

(1) Assumes 1 hour per system to verify number of taps, prepare letter,
and submit to State

ONE TIME BURDEN FOR STATES TO REVIEW AND TRACK LETTERS

Number of Letters for State Review	One-Time Burden for State Review of
Verification Letters (1)	Respondent Burden in Year 1 (hours)

3685	3692	3692

Notes:

 (1) Assumes 1 hour of State labor required to review and track letters
from systems with <5 taps 

Exhibit C-2: Calculation of Cost Estimates for Regulatory Change III.A

(4th Quarter 2006$)

ONE TIME COSTS FOR SYSTEMS IN STATES THAT ALLOW 1 TAP PER SAMPLE TO
PREPARE AND SUBMIT TO STATE LETTER VERIFYING NUMBER OF TAPS

11 States that Favor 1 Sample	# Small Systems With <5 taps	One-Time
System Burden for Verification Letters (1)	One-Time System Labor Cost
for Verification Letters (2)	One-Time System O&M Cost for Verification
Letters (3)	Total System One-Time Cost for 'Verification Letters

AK	17	17	$472	$7	$479

IN	380	380	$10,551	$163	$10,714

MI	901	901	$25,016	$387	$25,403

WI	511	511	$14,188	$220	$14,407

IL	249	249	$6,913	$107	$7,020

TX	521	521	$14,465	$224	$14,689

VT	140	140	$3,887	$60	$3,947

UT	45	45	$1,249	$19	$1,269

WA	254	254	$7,052	$109	$7,161

MD	320	320	$8,885	$138	$9,022

MN	322	322	$8,940	$138	$9,079

TN	32	32	$888	$14	$902

Total	3692	3692	$102,507	$1,588	$104,094

Notes:

(1) Assumes 1 hour per system to verify number of taps, prepare letter,
and submit to State

(2) Assumes average labor cost per hour of $27.76

(3) Assumes O&M cost equals $0.43 per letter ($0.39 postage, $0.01 paper
and $0.03 envelope).  

ONE TIME COSTS FOR STATES TO REVIEW AND TRACK LETTERS

Number of Letters for State Review	One-Time Burden for State Review of
Verification Letters (1)	State Labor Cost to Review and Document Number
of Taps (2)	State O&M Costs to Mail Approval Letter	Total Annual State
Costs

3692	3692	$160,681	$1,588	$162,269

Notes:

 (1) Assumes 1 hour of State labor required to review, track, and
approve letters from systems with <5 taps.  Assumes $0.43 materials and
postage to mail approval letter.

(2) Assumes State labor costs of $43.52 per hour.Exhibit C-3:
Calculation of Burden Estimates for Regulatory Change III.C

ANNUAL SYSTEM BURDEN RELATED TO TAP SAMPLING

System Size Category	# Systems that Exceed Lead AL (1) (2)	# Systems
Affected by Regulatory Change (3)	Total Additional # Tap Samples Due to
Regulatory Change (4)	Total Burden for Sample Collection and Analysis
(Hrs) (5)	Annual Respondent Burden (hours/year) (5)

<= 100	402	366	9,150	32,025	10,675

101 to 500	298	271	14,905	52,168	17,389

501 to 3,300	184	167	18,370	64,295	21,432

3.3K-10K	55	50	11,000	38,500	12,833

10K-50K	41	37	12,210	42,735	14,245

50K-100K	7	6	1,980	6,930	2,310

>100K	7	6	3,300	11,550	3,850

Total	994	903	70,915	248,203	82,734

Notes:

1.  Assume 884 systems serving <3,300 people exceed the lead AL each
year based on SDWIS/Fed database for monitoring period ending after
January 2003. (Data source: USEPA Survey of States - Questions on State
Implementation of Lead and Copper Rule. July 2004)

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05. 

3.  Of systems that exceed the lead action level, assume 91% of these
systems are on reduced monitoring based on USEPA Survey of States July
2004. 

4.  Assume systems required to change from reduced monitoring schedule
(one monitoring period per 3 years) to standard monitoring (monitoring
every 6 months).  "total" means total samples per 3 year period.
Sampling schedule based on system size as summarized in Table 5.2.a
below. For example, systems serving between 101 and 500 people are
required to monitor 10 sites for standard monitoring and 5 sites for a
reduced monitoring schedule.  Since there are 271 systems in this
category that are on reduced monitoring, the total additional number of
tap samples to be collected in each 3 year period equals
(10x6x271)-(5*1*271) or 14,905.

5.  Assume 3.5 hours average labor for collection and analysis per
sample (source: 2004 ICR, page H-43).

6.  Annual burden equals total burden divided by 3

ANNUAL SYSTEM BURDEN RELATED TO REPORTING OF SAMPLING RESULTS

System Size Category	# Systems that Exceed Lead AL	# Systems Affected by
Regulatory Change	Total Additional # Monitoring Events Due to Regulatory
Change	System Reporting Burden (Hrs.)Per Monitoring Event (1)	Total
System Reporting Burden (Hrs.)	Average Annual Respondent Burden
(hours/year)

25-100	402	366	1,830	1.5	2,745	915

101-500	298	271	1,355	1.5	2,033	678

501-3,300	184	167	835	1.5	1,253	418

3.3K-10K	55	50	250	1.5	375	125

10K-50K	41	37	185	1.75	324	108

50K-100K	7	6	30	1.75	53	18

>100K	7	6	30	2	60	20

Total	994	903	4,515	--	6,841	2,280

Notes:

1.  Based on 2004 ICR Page H-27 Assumptions of Reporting Burden for Tap
Sample Letter and Tap Sample Calcs.

ANNUAL STATE BURDEN RELATED TO REVIEWING SAMPLING RESULTS

System Size Category	# Systems that Exceed Lead AL1,2	# Systems Affected
by Regulatory Change3	Additional # Monitoring Events for 3 year cycle
Due to Regulatory Change4	State Labor Burden per Monitoring Event 5,6
Respondent Burden (hours/year)7

<= 500	700	637	3,185	1.17	1,242

501-3.3K	184	167	835	1.25	348

3.3K-10K	55	50	250	1.50	125

10K-50K	41	37	185	1.75	108

50K-100K	7	6	30	1.75	18

>100K	7	6	30	2.00	20

Total	994	903	4,515	--	1,860

Notes:

1.  Assume 884 systems serving <3,300 people exceed the lead AL each
year based on SDWIS/Fed database for monitoring period ending after
January 2003. (Data source: USEPA Survey of States - Questions on State
Implementation of Lead and Copper Rule. July 2004)

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05. 

3.  Of systems that exceed the lead action level, assume 91% of these
systems are on reduced monitoring based on USEPA Survey of States July
2004. 

4.  For a 3 year monitoring cycle, assume systems have 5 additional tap
monitoring events due to switching from a reduced monitoring schedule
(once in 3 years) to standard monitoring (every 6 months).

5. Estimated burden based on 2004 ICR, Page H-12.  The ICR estimates
State burden to be 1 hour to review sample letter and between 0.17 hour
and 1 hour to review sample calculations, depending on system size. 

6. Total labor per monitoring event is equal to labor per monitoring
event for State review of the tap sample letter plus the labor per
monitoring event for the tap sample calculations. 

7. Respondent burden in hours/year is equal to the number of additional
tap monitoring events for a 3 year cycle, divided by three years,
multiplied by the total labor per monitoring event.

Exhibit C-4: Calculation of Cost Estimates for Regulatory Change III.C

(4th Quarter 2006$)

ANNUAL SYSTEM COST RELATED TO TAP SAMPLING

System Size Category	Labor per Sample (hours)1	Labor Rate ($/hour)2
Respondent Burden (hours/year)3	Annual Labor Costs4	Annual O&M Costs5
Total Annual Monitoring Costs6









<= 100	3.5	$23.86	10,675	$254,706 	$24,888 	$279,594 

101 to 500	3.5	$25.70	17,389	$446,901 	$40,542 	$487,443 

501 to 3,300	3.5	$27.54	21,432	$590,228 	$49,966 	$640,195 

3.3K-10K	3.5	$33.96	12,833	$435,794 	$29,920 	$465,714 

10K-50K	3.5	$33.96	14,245	$483,732 	$33,211 	$516,943 

50K-100K	3.5	$34.59	2,310	$79,903 	$5,386 	$85,289 

>100K	3.5	$39.23	3,850	$151,036 	$8,976 	$160,012 

Total	--	--	82,734	$2,442,299 	$192,889 	$2,635,188 

Notes:

1. Assume 3.5 hours average labor for collection and analysis per sample
(Data source: 2004 ICR, page H-43).

2. Wage rate from SAIC contract study “Labor Cost for National
Drinking Water Rules.” 2003 wage rates are updated to 4th Qtr 2006.

3. Respondent Hours/Year equals the total # of additional monitoring
events from 2006-2006, divided by 3 years, multiplied by the Total
Reporting Burden per monitoring event (which ranges from 1.5 to 2.0
hrs).

 4. Annual Labor Costs are the Respondent Hours per Year multiplied by
the labor rate. 

5. Assume average O&M cost per sample is $8.16 as described in,
"Derivation of estimates for tap monitoring” in Appendix C of the EA.

6. Total annual monitoring costs per year are the sum of the annual
labor costs for monitoring and the annual O&M costs for monitoring.

ANNUAL SYSTEM COST RELATED TO REPORTING OF SAMPLING RESULTS

System Size Category	Labor per Monitoring Event (hours)1	Labor Rate
($/hour)2	 Respondent Burden (hrs/yr)3	Annual Labor Costs4	Annual O&M
Costs5	Total Annual Reporting Costs6

25-100	1.5	$23.86	915	$21,832	$262	$22,094

101-500	1.5	$25.70	678	$17,412	$194	$17,606

501-3.3K	1.5	$27.54	418	$11,498	$120	$11,618

3.3K-10K	1.5	$33.96	125	$4,245	$36	$4,281

10K-50K	1.75	$33.96	108	$3,664	$27	$3,691

50K-100K	1.75	$34.59	17.5	$605	$4	$610

>100K	2	$39.23	20	$785	$4	$789

Total	--	--	2,280	$60,040	$647	$60,687

Notes: 

1.  Assume 1.5 - 2.0 hours average labor for reporting burden associated
with the tap sample letter and tap sample calculations. (Data source:
2004 ICR, page H-27).

2. Wage rate from SAIC contract study “Labor Cost for National
Drinking Water Rules.” 2003 wage rates are updated to 4th Qtr 2006.

3. Respondent Hours/Year equals the total # of additional monitoring
events from 2006-2006, divided by 3 years, multiplied by the Total
Reporting Burden per monitoring event (which ranges from 1.5 to 2.0
hrs).

4. Annual Labor Costs are the Respondent Hours per Year multiplied by
the labor rate. 

5. Annual O&M costs include postage and materials @ $0.43 per monitoring
event per year. 

6. Total Reporting Cost per year is the sum of the labor costs per year
and the O&M costs per year. ANNUAL STATE COST RELATED TO REVIEWING
SAMPLING RESULTS

System Size Category	Labor per Monitoring Event (hours)1,2	Respondent
Burden (hours/year)3	Annual Labor Costs 4	Annual O&M Costs5	Total Annual
Costs6

<= 500	1.17	1,242	$54,060	$639	$54,699

501 to 3,300	1.25	348	$15,142	$168	$15,309

3.3K-10K	1.50	125	$5,440	$50	$5,490

10K-50K	1.75	108	$4,697	$37	$4,734

50K-100K	1.75	18	$762	$6	$768

>100K	2.00	20	$870	$6	$876

Total	--	1,860	$80,971	$906	$81,877

Notes: 

1.  Use State labor rate of $43.52 /hour (Source: Information Collection
Request for Contaminant Occurrence Data in Support of EPA's Second Six
Year Review of National Primary Drinking Water Regulations (August
2006)).

2. Total Review Burden is equal to the burden for State review of the
tap sample letter (1.0 hr) plus burden for State review  of for the tap
sample calculations (0.17 hr; Data source: 2004 ICR, page H-12)

3.  Respondent Hrs/Year is equal to the # of additional tap monitoring
events (2006-2008) divided by three years, multiplied by the Total
Review Burden per Monitoring Event (1.17 hrs)

4. Annual Labor Costs are the Respondent Hours per Year multiplied by
the labor rate ($43.52/hour). 

5.  Unit O&M cost per event is $0.43 per letter (postage & materials)
per ICR page H-12.  Assume State sends one letter to utility for each
tap monitoring event and two additional letters to each utility
regarding WQP monitoring.

6. Total State Review Costs per year is the sum of the labor costs per
year and the O&M costs per year. Exhibit C-5: Calculation of Burden
Estimates for Regulatory Change III.D

ANNUAL SYSTEM BURDEN RELATED TO PREPARING SUBMITTALS ON CHANGES

 	# of CWSs and NTNCWSs Affected Each Year (1)	Labor per Treatment
Change (hours) (2)	Respondent Burden (hours/year) (3)

System Burden to Prepare Submittals and Coordinate with States	1,067	7.5
8,006

Notes:

1.  The number of systems affected by Regulatory Change III.D is based
on the USEPA Survey of States Questions on State Implementation of Lead
and Copper Rule (July 2004). Survey results show that 14 States
explicitly require review and approval of treatment changes.  53,372
systems in States other than these 14 States would be affected by this
Regulatory Change.  It is assumed that each year 2% of systems have a
treatment or source change that requires review and approval (per the
1999 ICR, page B-8).  Therefore the number of systems to be affected by
this regulatory change each year is estimated to be 53,372 x 0.02 = 
1,067 systems.

2.  It is assumed that all systems will spend 8 hours to prepare a
submittal letter, coordinate with State, and participate in meeting with
State. The current system of notification for treatment changes requires
0.5 hours (per 1999 ICR) so this is deducted from the 8 hours for a
total of 7.5 hours. The burden assumption is based on consensus of
expert panelists on 11.21.05.

3. Respondent burden is the number of affected systems multiplied by the
labor hours per treatment change.

ANNUAL STATE BURDEN RELATED TO REVIEWING SUBMITTALS ON CHANGES

 	# of Affected Systems (1)	Labor per Review (hours) (2) (3)	Respondent
Burden (hours/year)

State Burden to Review Submittals	1,067	7.5	8,006

Notes:

1.  The number of systems affected by Regulatory Change III.D is based
on the USEPA Survey of States Questions on State Implementation of Lead
and Copper Rule (July 2004). Survey results show that 14 States
explicitly require review and approval of treatment changes.  53,372
systems in States other than these 14 States would be affected by this
Regulatory Change.  It is assumed that each year 2% of systems have a
treatment or source change that requires review and approval (per
the1999 ICR, page B-8).  Therefore the number of systems to be affected
by this regulatory change each year is estimated to be  53,372 x 0.02 = 
1,067 systems.

2. It is assumed that States spend 7.5  hours to review each system's
data/reports, coordinate with system and make approval decision and
formalize with management.

3. State burden is the number of affected systems multiplied by the
labor hours per treatment change.

Exhibit C-6: Calculation of Cost Estimates for Regulatory Change III.D

(4th Quarter 2006$)

ANNUAL SYSTEM COST RELATED TO PREPARING SUBMITTALS ON CHANGES

 	Labor per Review (hours) 	Respondent Burden (hrs/year)	# of CWSs
Conducting an Engineering Study Each Year (2)	Cost of Engineering Study
(3)	Annual Labor Cost (1) (4)	Annual O & M Cost (4)	Total Annual Cost
(5)

System Cost	7.5	8,006	26	$20,000 	$765,083 	$0	$765,083 

Notes: 

1. Assume labor rate of $30.81 per hour, which is the average of wage
rates from SAIC contract study, "Labor Costs for National Drinking Water
Rules" (2003) updated to 4th Qtr 2006.

2.  Assume that 20 percent of medium and large systems must conduct an
engineering study due to Reg Change III.D based on consensus agreement
of expert panelists on 11.21.05. Since 99 percent of NTNCWS are small
systems (serving <3,300 people), it is assumed that only medium and
large CWSs must conduct an engineering study.  Assume 16% of CWS are
medium or large systems based on the USEPA "Factoids: Drinking Water and
Groundwater Statistics for 2004". The estimate equals 810 CWS x 0.16 x
0.20 = 26 systems.

3. Annual cost is equal to the total system burden (hours) multiplied by
a labor rate of $30.81 per hr. (average of wage rates from SAIC contract
study, "Labor Costs for National Drinking Water Rules"2003) updated to
4th Qtr 2006 plus $20,000 for an engineering study for a subset of
medium and large CWS.

4.  O&M costs assumed to be negligible.

5.  Total Annual Costs equals Labor plus O&M costs.

ANNUAL STATE COST RELATED TO REVIEWING SUBMITTALS ON CHANGES

 	Labor per Review (hours) (1)	Respondent Burden (hours)	Annual Labor
Costs (2)	Annual O&M Costs  (3)	Total Annual Costs (4)

State Cost	7.5	8,006	$348,424 	$0	$348,424 

Notes:

1. Use State labor rate of $43.52/hour (Source: Information Collection
Request for Contaminant Occurrence Data in Support of EPA's Second Six
Year Review of National Primary Drinking Water Regulations (August
2006)).

2. Annual labor costs are the State labor rate ($43.52) multiplied by
the number of respondent burden hours per year.

3. O&M costs are assumed to be negligible.

4. Total State Costs per year is the sum of the labor costs per year and
the O&M costs per year.

Exhibit C-7: Calculation of Burden Estimates for Regulatory Change
III.E

ANNUAL SYSTEM BURDEN RELATED TO NOTIFICATION OF SAMPLING RESULTS

System Size Category	Number of Systems (1)	Percentage of Systems That
Currently Do Not Notify Customers (2)	Subtotal Systems Affected by Reg
Change III.E (3)	# Systems Affected by Regulatory Change III.C That Are
Affected by Reg. Change III.E (4)	Total Annual Monitoring Events (5)
Total Customer Notification Letters (6)	Annual System Burden (hrs) (7)

CWSs:	 	 	 	 	 	 	 

<100	13,766	89%	12,252	158	6,237	31,186	6,237

101-500	16,240	90%	14,616	131	7,326	51,089	7,326

501-1K	5,914	89%	5,263	108	2,760	39,237	2,760

1k-3.3K	8,298	89%	7,385	 	3,570	48,989	3,570

3.3K-10K	4,707	90%	4,236	44	2,136	59,735	2,987

10K-50K	3,057	90%	2,751	32	1,395	58,648	2,932

50K-100K	484	90%	436	5	221	9,316	466

100K-500K	322	91%	293	5	153	10,810	541

500K-1M	32	89%	28	 	14	945	47

>1 M	18	93%	17	 	8	555	28

NTNCWSs:	 	 	 	 	 	 	 

<100	9,548	87%	8,307	189	4,393	-	4,393

101-500	6,997	88%	6,157	126	3,228	-	3,228

501-1K	1,925	89%	1,713	29	887	-	887

1k-3.3K	795	90%	716	16	378	-	378

3.3K-10K	96	93%	89	1	45	-	45

10K-50K	13	92%	12	1	8	-	8

50K-100K	1	100%	1	 	 	 	 

Total	72,213	89%	64,273	846	32,757	310,510	35,831

Notes:

1.  Number of CWS and NTNCWS systems per SDWIS/FED Data 2004. 

2.  Data source: USEPA Survey of States - Questions on State
Implementation of Lead and Copper Rule (July 2004).

3. The number of systems affected by Reg. Change III.E equals the total
number of CWS and NTNCWS systems (see Note 1) multiplied by the
percentage of systems that currently do not notify their customers. 

4.  Regulatory Change III.E will also affect systems that are affected
by regulatory change III.C that exceeded the lead action level while on
reduced monitoring and had to revert to standard monitoring, and do not
currently notify their customers of lead test results.  The number of
systems affected by regulatory change III.C is based on the number of
systems exceeding the lead action level as reported in the SDWIS Fed
data 2003.  It is also assumed that 91% of these systems are on reduced
monitoring based on USEPA Survey of States July 2004.

5. It is assumed that 9% of systems use a standard monitoring schedule
with 6 monitoring events in 3 years or 2 monitoring events each year. 
It is also assumed that 91% of systems are on a reduced monitoring
schedule with 1 monitoring event in 3 years. In addition, systems
affected by Reg. Change III.C that are also affected by Reg. Change
III.E use a standard monitoring schedule with 2 monitoring events each
year. (Source: USEPA Survey of States - Questions on State
Implementation of Lead and Copper Rule. July 2004). For systems affected
by Reg. Change III.C, assume all systems have reverted to a standard
monitoring schedule.

6.  The number of customer notification letters on lead monitoring
results is based on the sampling schedule for standard and reduced
monitoring.  It is assumed that one letter is sent for each sampling
site required by 40 CFR 141.86c.

7. For CWSs, assume burden of 1 hour per monitoring event for systems
serving <3,300 people.  For systems serving > 3,300 people, assume
burden of 1 hour per 20 letters  For NTNCWSs, assume 1 hour per
monitoring event for all system sizes.  Burden estimates based on
recommendations of Expert Review Panel (November 2005).

ANNUAL SYSTEM BURDEN RELATED TO REPORTING TO STATE

System Size Category	Number of Systems1	# Systems Affected by Regulatory
Change III.C That Are Affected by Reg. Change III.E4	Total Annual
Monitoring Events5	Total Self Certification Letters to State	Annual
System Burden (hrs)1

CWSs:	 	 	 	 	 

<100	13,766	149	6,952	6,952	834

101-500	16,240	128	8,105	8,105	973

501-1K	5,914	116	3,090	3,090	371

1k-3.3K	8,298	 	4,011	4,011	481

3.3K-10K	4,707	49	2,373	2,373	285

10K-50K	3,057	36	1,550	1,550	186

50K-100K	484	6	246	246	30

100K-500K	322	6	168	168	20

500K-1M	32	 	15	15	2

>1 M	18	 	9	9	1

 	 	 	 	 	 

NTNCWSs:	 	 	 	 	 

<100	9,548	217	5,049	5,049	606

101-500	6,997	143	3,668	3,668	440

501-1K	1,925	33	996	996	120

1k-3.3K	795	18	420	420	50

3.3K-10K	96	1	48	48	6

10K-50K	13	1	8	8	1

50K-100K	1	 	 	 	 

100K-500K	 	 	 	 	 

500K-1M	 	 	 	 	 

>1 M	 	 	 	 	 

Total	72,213	903	36,708	36,708	4,405

Notes:

1.  Assumes .12 hours to prepare self-certification letter to State
based on estimate to prepare self-certification for the CCR.

ANNUAL STATE BURDEN RELATED TO REVIEWING SELF CERTIFICATION LETTERS

System Size Category	Number of Systems	# Systems Affected by Regulatory
Change III.C That Are Affected by Reg. Change III.E	Total Annual
Monitoring Events	Total Self Certification Letters to State	Annual State
Burden for Self-Certification Letters1

CWSs:	 	 	 	 	 

<100	13,766	149	6,952	6,952	695

101-500	16,240	128	8,105	8,105	811

501-1K	5,914	116	3,090	3,090	309

1k-3.3K	8,298	 	4,011	4,011	401

3.3K-10K	4,707	49	2,373	2,373	237

10K-50K	3,057	36	1,550	1,550	155

50K-100K	484	6	246	246	25

100K-500K	322	6	168	168	17

500K-1M	32	 	15	15	2

>1 M	18	 	9	9	1

 	 	 	 	 	 

NTNCWSs:	 	 	 	 	 

<100	9,548	217	5,049	5,049	505

101-500	6,997	143	3,668	3,668	367

501-1K	1,925	33	996	996	100

1k-3.3K	795	18	420	420	42

3.3K-10K	96	1	48	48	5

10K-50K	13	1	8	8	1

50K-100K	1	 	 	 	 

100K-500K	 	 	 	 	 

500K-1M	 	 	 	 	 

>1 M	 	 	 	 	 

Total	72,213	903	36,708	36,708	3,671

Notes:

1.  Assumes .10 hours to review and files self-certification letter by
State based on estimate to review and file self-certification for the
CCR.

Exhibit C-8: Calculation of Cost Estimates for Regulatory Change III.E

(4th Quarter 2006$)

ANNUAL SYSTEM COST RELATED TO NOTIFICATION OF SAMPLING RESULTS

System Size Category	Total Customer Notification Letters	Annual System
Burden (hrs) (1)	Annual System Labor Cost ($) (2)	Annual System O&M Cost
($) (3)	Total Annual System Cost ($)

CWSs:	 	 	 	 	 

<100	31,186	6,237	$148,817 	$13,410 	$162,227 

101-500	51,089	7,326	$188,270 	$21,968 	$210,239 

501-1K	39,237	2,760	$76,015 	$16,872 	$92,887 

1k-3.3K	48,989	3,570	$98,305 	$21,065 	$119,370 

3.3K-10K	59,735	2,987	$101,423 	$25,686 	$127,109 

10K-50K	58,648	2,932	$101,431 	$25,218 	$126,649 

50K-100K	9,316	466	$16,113 	$4,006 	$20,119 

100K-500K	10,810	541	$21,205 	$4,649 	$25,853 

500K-1M	945	47	$1,853 	$406 	$2,259 

>1 M	555	28	$1,089 	$239 	$1,328 

NTNCWSs:	 	 	 	 	 

<100	-	4,393	$104,805 	$0 	$104,805 

101-500	-	3,228	$82,953 	$0 	$82,953 

501-1K	-	887	$24,423 	$0 	$24,423 

1k-3.3K	-	378	$10,416 	$0 	$10,416 

3.3K-10K	-	45	$1,529 	$0 	$1,529 

10K-50K	-	8	$264 	$0 	$264 

50K-100K	 	 	 	 	 

100K-500K	 	 	 	 	 

500K-1M	 	 	 	 	 

>1 M	 	 	 	 	 

Total	 	35,831	$978,910 	$133,519 	$1,112,429 

Notes:

1. For CWSs, assume burden of 1 hour per monitoring event for systems
serving <3,300 people.  For systems serving > 3,300 people, assume
burden of 1 hour per 20 letters.  For NTNCWSs, assume 1 hour per
monitoring event for all system sizes.  Burden estimates based on
recommendations of Expert Review Panel (November 2005).

2.  Use loaded wage rates from SAIC contract study, "Labor Costs for
National Drinking Water Rules (2003) updated to 4th Qtr 2006.  Annual
labor cost equals hourly labor rate multiplied by annual burden.

3. For CWSs, the annual system O&M cost equals $0.43 per sample letter
($0.39 postage, $0.01 paper and $0.03 envelope) multiplied by the number
of sample letters.  For NTNCWSs, the O&M cost is assumed to be
negligible.

ANNUAL SYSTEM COST RELATED TO REPORTING TO STATE

System Size Category	Number of Systems	Annual System Burden (hrs) (1)
Annual System Labor Costs ($)	Annual System O&M Cost($) (2)	Total Annual
System Cost

CWSs:	 	 	 	 	 

<100	13,766	834	$21,146 	$3,176 	$24,322 

101-500	16,240	973	$25,879 	$3,608 	$29,487 

501-1K	5,914	371	$10,550 	$1,373 	$11,923 

1k-3.3K	8,298	481	$13,255 	$1,725 	$14,979 

3.3K-10K	4,707	285	$9,678 	$1,021 	$10,700 

10K-50K	3,057	186	$6,440 	$667 	$7,107 

50K-100K	484	30	$1,021 	$106 	$1,127 

100K-500K	322	20	$789 	$72 	$861 

500K-1M	32	2	$73 	$7 	$79 

>1 M	18	1	$41 	$4 	$45 

 	 	 	 	 	 

NTNCWSs:	 	 	 	 	 

<100	9,548	606	$14,456 	$2,171 	$16,627 

101-500	6,997	440	$11,312 	$1,577 	$12,889 

501-1K	1,925	120	$3,293 	$428 	$3,721 

1k-3.3K	795	50	$1,389 	$181 	$1,570 

3.3K-10K	96	6	$197 	$21 	$218 

10K-50K	13	1	$34 	$4 	$38 

50K-100K	1	 	 	 	 

100K-500K	 	 	 	 	 

500K-1M	 	 	 	 	 

>1 M	 	 	 	 	 

Total	72,213	4,405	$119,553 	$16,140 	$135,693 

Notes:

1.  Assumes .12 hours to prepare self-certification letter to State
based on estimate to prepare self-certification for the CCR.

2.  Assumes $0.43 postage and materials cost ($0.39 postage, $0.01 paper
and $0.03 envelope.ANNUAL STATE COST RELATED TO REVIEWING SELF
CERTIFICATION LETTERS

System Size Category	Number of Systems	Total Annual Self-Certification
Letters to State	Annual State Burden (hrs)1	Annual State Labor Costs ($)
Annual State O&M Cost($)2	Total Annual State Cost

CWSs:	 	 	 	 	 	 

<100	13,766	6,952	695	$32,143 	$0 	$32,143 

101-500	16,240	8,105	811	$36,520 	$0 	$36,520 

501-1K	5,914	3,090	309	$13,894 	$0 	$13,894 

1k-3.3K	8,298	4,011	401	$17,455 	$0 	$17,455 

3.3K-10K	4,707	2,373	237	$10,337 	$0 	$10,337 

10K-50K	3,057	1,550	155	$6,753 	$0 	$6,753 

50K-100K	484	246	25	$1,070 	$0 	$1,070 

100K-500K	322	168	17	$730 	$0 	$730 

500K-1M	32	15	2	$67 	$0 	$67 

>1 M	18	9	1	$38 	$0 	$38 

 	 	 	 	 	 	 

NTNCWSs:	 	 	 	 	 	 

<100	9,548	5,049	505	$21,973 	$0 	$21,973 

101-500	6,997	3,668	367	$15,963 	$0 	$15,963 

501-1K	1,925	996	100	$4,337 	$0 	$4,337 

1k-3.3K	795	420	42	$1,829 	$0 	$1,829 

3.3K-10K	96	48	5	$211 	$0 	$211 

10K-50K	13	8	1	$36 	$0 	$36 

50K-100K	1	 	 	 	 	 

100K-500K	 	 	 	 	 	 

500K-1M	 	 	 	 	 	 

>1 M	 	 	 	 	 	 

Total	72,213	 	3,671	$163,355 	$0 	$163,355 

Notes:

1.  Assumes .10 hours to review and files self-certification letter by
State based on estimate to review and file self-certification for the
CCR.

2. Assumes no O&M costs.

Exhibit C-9: Calculation of Burden Estimates for Regulatory Change
III.F

ANNUAL SYSTEM BURDEN RELATED TO PUBLIC EDUCATION ACTIVITIES

Requirement	Affected Party	Number of Systems Affected	Annual Systems
Burden (hours)1

Customer Notification 	 Systems that Exceed LAL	994	3,479

PSAs and Press Rel.	CWS that Exceed LAL	581	-108

Customer Bills	CWS that Exceed LAL	581	1,743

Notify 3 New Orgs.	CWS that Exceed LAL	581	737

Post on Website	Large CWS that Exceed LAL	7	4

Add'l Activities 7A-H	CWS that Exceed LAL	581	9,749

State consult & letter	CWS that Exceed LAL	581	70

CCR Statement	CWS that Don’t Exceed LAL	52,257	13,064

TOTAL	 	 	28,737

Notes:

1.  Various assumption used for each requirement.  Please refer to the
LCRSTR Economic Analysis for further details.

ANNUAL STATE BURDEN RELATED TO PUBLIC EDUCATION ACTIVITIES

State Review Activity	# States (1)	Net Annual Change in State Burden
(Hrs)

 (2) (3) (4) (5)

Customer Notification Review	57	236

Review and Filing of Self-Certification Letter	57	58

Consultation on Activities	57	1,162

 	 	1,456

Notes:

1.  The LCR Regulatory Changes apply to 50 states, 6 territories and 1
Indian Tribe, for a total of 57 entities.

2.  States no longer have to approve changes for systems serving between
501 and 3,300 people.  Assume 0.5 hours savings for each of the 184
systems in this size category (Refer to Table 1 above).  The total
reduction in burden equals 92 hours (184 * 0.5 hours).

3. For customer notification, States need to review additional language
for 994 systems that are estimated to exceed the LAL at an estimated 20
minutes per system. The total new burden to States equals 328 hours (994
systems * 0.33 hours). The net new burden to States equals 328 hours
minus 92 hours equals 236 hours.

4. For consultation on activities, review of cover content, discussion
of alternative mechanisms, and discussion of extending deadlines, States
need to review activities with CWSs that exceed the LAL once per year at
2 hours per year.

5. For review and filing of letter from CWSs that exceed the LAL
self-certifying that additional PE activities have taken place, States
will require .10 hours per system per year, based on similar activity
for the CCR.

Exhibit C-10: Calculation of Cost Estimates for Regulatory Change III.F

(4th Quarter 2006$)

ANNUAL SYSTEM COSTS RELATED TO PUBLIC EDUCATION ACTIVITIES

Requirement	Affected Party	Number of Systems Affected	Annual Systems
Cost ($) (1)

Customer Notification 	 Systems that Exceed LAL	994	$91,421 

PSAs and Press Rel.	CWS that Exceed LAL	581	($4,198)

Customer Bills	CWS that Exceed LAL	581	$47,383 

Notify 3 New Orgs.	CWS that Exceed LAL	581	$43,347 

Post on Website	Large CWS that Exceed LAL	7	$137 

Add'l Activities 7A-H	CWS that Exceed LAL	581	$292,739 

State consult & letter	CWS that Exceed LAL	581	$33,734 

CCR Statement	CWS that Don’t Exceed LAL	52,257	$354,586 

TOTAL	 	 	$859,150 

Notes:

1.  Various assumption used for each requirement.  Please refer to the
LCRSTR Economic Analysis for further details.

ANNUAL STATE COSTS RELATED TO PUBLIC EDUCATION ACTIVITIES

State Review Activity	# States (1)	Net Annual Change in State Cost ($)

 (2) (3) (4) (5) (6)

Customer Notification Review	57	$10,272 

Review and Filing of Self-Certification Letter	57	$2,529 

Consultation on Activities	57	$50,572 

 	 	$63,372 

Notes:

1. The LCR Regulatory Changes apply to 50 states, 6 territories and 1
Indian Tribe, for a total of 57 entities.

2.  States no longer have to approve changes for systems serving between
501 and 3,300 people.  Assume 0.5 hours savings for each of the 184
systems in this size category.  The total reduction in burden equals 92
hours (184 * 0.5 hours).

3. For customer notification, States need to review additional language
for 994 systems that are estimated to exceed the LAL at an estimated 20
minutes per system. The total new burden to States equals 328 hours (994
systems * 0.33 hours). The net new burden to States equals 328 hours
minus 92 hours equals 236 hours.

4.  Use state labor rate of $43.52/hour (Source: Information Collection
Request for Contaminant Occurrence Data in Support of EPA's Second Six
Year Review of National Primary Drinking Water Regulations (August
2006)).

5. For consultation on activities, review of cover content, discussion
of alternative mechanisms, and discussion of extending deadlines, States
need to review activities with CWSs that exceed the LAL once per year at
2 hours per year.

6. For review and filing of letter from CWSs that exceed the LAL
self-certifying that additional PE activities have taken place, States
will require .10 hours per system per year, based on similar activity
for the CCR.

Exhibit C-11: Calculation of Burden Estimates for Regulatory Change
III.G

ANNUAL SYSTEM BURDEN RELATED TO SYSTEM MONITORING

Number of Affected Systems  (1)	# of Systems that Re-exceed Lead AL &
Continue LSL Replacement (2)	Number of LSLs per System (3)	Annual Number
of LSL Samples (4)	Annual Number of Samples that Must be Retested (5)
Labor Per Sample  (6)	Annual Burden Per Year

34	1	21,467	1,431	1,088	3	3,263

Notes:

1.  Systems that have been required to conduct a lead service line
replacement program may potentially be affected by Reg. Change III.G if
they discontinue the program, then later re-exceed the lead action
level. The number of systems was estimated based on survey responses
from the USEPA Survey of States Questions on State Implementation of
Lead and Copper Rule (July 2004).Six states indicated the specific
number of systems that have been required to initiate LSL replacement
programs (total of 28 systems).  Five other states indicated that they
had systems that were required to have LSL programs but did not indicate
the specific number of systems.  For these 5 States, it is assumed that
each State has 5 systems with LSL programs required by State, for a
total of25 systems. One system is added for DCWASA. The total number of
systems affected by Reg. Change III.G is assumed to be 28+25+1= 54
systems

2.  Assume 1.4% systems re-exceed lead action level and are required to
continue LSL replacement program (data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05).  Assumption is
based on current exceedance rate for lead action level by medium and
large systems

3.  Based on 26 utilities reporting 558,135 LSLs in 1992 or 21,467 LSLs
per system (Black and Veatch survey July 2005). Assuming each utility
conducts LSL replacements at a rate of 7% per year or over 15 years,
this equals 21,467 divided by 15 or 1,431 LSLs per system per year ( 
HYPERLINK
"http://www.epa.gov/safewater/lcrmr/pdfs/summary_lcmr_review_lead_line_r
eplacement_workshop_10-26-04.pdf" 
www.epa.gov/safewater/lcrmr/pdfs/summary_lcmr_review_lead_line_replaceme
nt_workshop_10-26-04.pdf ).

The number of samples in the sampling pool is equal to the number of
systems that re-exceed the lead AL, x (annual # samples per system) x 15
years.

5.  Assume the utility replaces 24% of LSLs and tests-out the remaining
76% based on data from DCWASA (2003). The number of samples that needs
to be retested equals the number of samples in the sampling pool x 76%

6.  Assume burden is 3 hours for sample collection and analysis.

7. Respondent burden is equal to the labor per sample (3 hours/samples)
times the number of samples that must be retested (1,088), which is
equal to 3,263 hours per year.

Exhibit C-12: Calculation of Burden Estimates for Regulatory Change
III.G

(4th Quarter 2006$)

ANNUAL SYSTEM COST RELATED TO SYSTEM MONITORING

 	Labor per Sample (hours) (1)	Respondent Burden (hours/year) 	Annual
Labor Costs (2)	Annual O&M Costs (3)	Total Annual Costs (4)

Total	3	3,263	$100,533 	$8,874 	$109,407 

Notes:

1. Assume burden is 3 hours for sample collection and analysis.

2.  Annual labor costs equals the respondent burden (3,263 hours/year)
times the labor rate ($26.81/hour). The assumed labor rate of $30.81 per
hour is the average of the wage rates from SAIC contract study, "Labor
Costs for National Drinking Water Rules"

3. O&M costs are $8.16 per sample.

4. Total annual costs are the sum of the labor costs per year and the
O&M costs per year.

 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, utilities, and PWSs include only these two types of PWS.

 Throughout the rest of this document, the term State/Primacy Agency
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).

 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.

 This document is entitled, National Primary Drinking Water Regulations
for Lead and Copper: Short-Term Regulatory Revisions and Clarifications,
May 2006, EPA-HQ-OW-2005-0034-0029.

 Consultations Prior to LCR 1991 and LCRMR: Please refer to the 1999
ICR, entitled, Information Collection Request for the National Primary
Drinking Water Regulations for Lead and Copper, June 1999, EPA tracking
number 1912.01, for a more detailed chronology of consultations used to
solicit comments and suggestions from stakeholders when creating the LCR
1991 and LCRMR 2000.

 http://www.epa.gov/safewater/lcrmr/lead_review.html

 70 FR 54375, US EPA, 2005.

 There are two types of costs that may result from the LCRSTR rule
changes – direct and indirect. Direct costs are from those activities
that are specified by the rule change, such as costs for additional
monitoring or distribution of consumer notices. A second type of cost
may also result when systems and States use the information generated by
the directly –related rule activities to modify or enhance practices
to reduce lead levels. Section 6 focuses solely on the estimation of
direct costs for implementation activities

 Date Source: SDWIS/FED database 2004; See Exhibit 1 for details. 

 Information Collection Request for the Public Water System Supervision
Program, OMB control number 2040-0090.

 http://www.epa.gov/safewater/data/pdfs/data_factoids_2004.pdf

 Source: Information Collection Request: Disinfectants/Disinfection
Byproducts, Chemical, and Radionuclides Rules, USEPA, Office of Water,
September 2004, page H-27.

  Based on agreement of expert panelists (11/21/05)

 Source: USEPA Survey of States - Questions on State Implementation of
Lead and Copper Rule. July 2004

 USEPA, Public Water System Supervision Information Collection Request,
July 2004, page B-6.

 Data source: www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05; Based
on lead exceedance data for medium and large systems. 

 Source: Notes from the EPA Lead Service Line Replacement Workshop,
December 10, 2004,
http://www.epa.gov/safewater/lcrmr/pdfs/summary_lcmr_review_lead_line_re
placement_workshop_10-26-04.pdf

 21,467 LSL’s per systems divided by 15 years equals 1,431 LSL’s per
system per year.

www.epa.gov/safewater/lcrmr/pdfs/summary_lcmr_review_lead_line_replaceme
nt_workshop_10-26-04.pdf

 Source: Lead Service Line Replacement Program Annual Report for 2003,
District of Columbia Water and Sewer Authority, September 2003.

 Date Source: SDWIS/FED database 2004; See Exhibit 1 for details. 

 Labor rates from SAIC contract study, "Labor Costs for National
Drinking Water Rules" (2003) updated to 2005 dollars.

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C- PAGE   19 

