United States
Environmental Protection
Agency
Office of Wntcr
4604
EPA812-B-96-003
January 1996
&EPA INFORMATION COLLECTION
REQUEST
Proposed Changes to National Primary
Drinking Water Regulations for Lead
and Copper
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Information Collection Request:
Proposed Changes to
National Primary Drinking Water Regulations For
Lead and Copper
Prepared By:
The Cadmus Group
4900 Seminary Road, Suite 600
Alexandria, Virginia 22311
EPA Contract No. 68-C4-0007
Work Assignment 2-18
Ms. Patricia Minami
Project Officer
Ms. Judy Lebowich
Technical Project Monitor
U.S. Environmental Protection Agency
Office of Ground Water and Drinking Water
Washington D.C.
January 26, 1996
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TABLE OF CONTENTS
PAGE
1 IDENTIFICATION OF THE INFORMATION COLLECTION 1
la Title And Number Of The Information Collection 1
Ib Short Characterization 1
2 NEED FOR AND USE OF THE COLLECTION 4
2a Need/Authority For The Collection 4
2b Practical Utility/Users Of The Data 5
3 THE RESPONDENTS AND THE INFORMATION REQUESTED 7
3a Respondents/SIC Codes 7
3b Information Requested 7
3b(i) Data Items, Including Recordkeeping and Reporting 7
3b(ii) Respondent Activities 15
4 THE INFORMATION COLLECTEDAGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT 23
4a Agency and State Activities 23
4a(i) Agency Activities 23
4a(ii) State Activities 23
4b Collection Methodology And Management 24
4c Small Entity Flexibility 25
4c(i) Minimizing Burden 25
4c(ii) Consideration of Alternatives 26
4d Collection Schedule 28
5 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA^
5a Nonduplication 29
5b Consultations 29
5c Effects Of Less Frequent Collection 29
5d General Guidelines 30
5e Confidentiality And Sensitive Questions 30
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ESTIMATING THE BURDEN AND COST OF THE COLLECTION 31
6a Estimating Respondent Burden 31
6a(i) Burden To Public Water Systems 31
6a(ii) Burden To States 39
6b Estimating Respondent Costs 44
6b(i) Costs To Public Water Systems 44
6b(ii) Costs to States 44
6c Estimating Agency Burden And Cost 46
6d Bottom Line Burden Hours And Costs 47
6e Reasons For Change In Burden 4.7
6f Burden Statement 47
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1 IDENTIFICATION OF THE INFORMATION COLLECTION
la Title And Number Of The Information Collection
TITLE: Information Collection Request for Proposed Modifications to the National
Primary Drinking Water Regulations for Lead and Copper
U.S. EPA TRACKING NUMBER:
Ib Short Characterization
The U.S. Environmental Protection Agency (EPA or Agency) is proposing minor
modifications to the National Primary Drinking Water Regulation for lead and copper. These
modifications are intended to improve the Lead and Copper Rule's (LCR) implementation and to
correct inadvertent omissions from the original rule, which was promulgated on June 7, 1991 (56
Federal Register 26460).* Two of the proposed revisions, involving sample invalidation and the
definition of "control" of a lead service line, result from legal challenges to the current LCR
brought by the American Water Works Association. Litigation brought by the Natural Resources
Defense Council regarding the Agency's exclusion of transient, non-community water system was
remanded so that the Agency could provide a more detailed justification of this exclusion. The
Agency will address this issue in a subsequent Federal Register notice.
The proposed modifications do not alter the Agency's approach expressed in the final LCR
for regulating lead and copper in drinking water. The LCR is codified in Parts 141 and 142 of
Title 40 of the Code of Federal Regulations (CFR)2
The LCR requires state and certain public water system respondents to collect or report
information related to compliance with specific monitoring and treatment provisions.3 The
In 1993, the Agency established a work group comprised of EPA Headquarters and Regional staff, and state
drinking water officials to identify implementation issues. The proposed regulatory changes are a result of
numerous work group discussions.
Unless otherwise noted, all CFR references contained in this Information Collection Request refer to
Title 40 of the CFR.
Community and non-transient non-community water systems are subject to the LCR's requirements. Any
subsequent references in this document to public water systems include only these groups of public water
systems Community water systems include water systems that serve at least 15 connections used by year-
round residents or regularly serve at least 25 year-round residents. Non-transient non-community water systems
include water systems that are not community water systems and regularly serve at least 25 of the same persons
over six months of a year. Examples of non-transient, non-community water systems include schools, factones,
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proposed regulatory modifications would still require these respondents to collect or report this
information. In some instances, the modifications will require public water systems and states to
collect or report new or additional compliance-related information. Such information must be
collected and/or reported every two weeks (bi-weekly), quarterly, semi-annually, annually,
triennially, or every nine years. In other cases, existing collection and reporting requirements have
been eliminated.
Public water systems report compliance-related information to states that have primary
authority for overseeing the LCR (i.e., primacy). In instances where a state does not have
primacy, the system reports directly to the EPA Region overseeing its jurisdiction.4 States must
maintain information submitted by public water systems to support their program implementation
and oversight activities. States also must report to EPA a subset of information submitted by
public water systems. EPA uses this information to protect public health by ensuring compliance
with the LCR and evaluating the appropriateness and consistency of state implementation
activities. EPA stores the information in the Safe Drinking Water Information System.5 The
Agency will continue to utilize the Safe Drinking Water Information System to manage the
information generated by the regulatory modifications.
At the time of promulgation in 1991, based on data from a select group of U.S. cities, the
Agency estimated the recordkeeping and reporting burden associated with the lead and copper
rule assuming that approximately 50 percent of systems would exceed the lead or copper action
levels. Now that water systems have collected lead samples from hundreds of thousands of
household taps around the country to comply with the monitoring requirements of the rule, much
more reliable predictions of burden can be made. The burden associated with the rule should be
less than originally predicted. EPA would now estimate that approximately 20 percent of systems
will exceed an action level resulting in significantly more systems able to reduce the number and
frequency of monitoring sooner than originally predicted and fewer systems triggered into public
education.
To calculate the relative magnitude of the regulatory revisions proposed here, the original
basic assumptions regarding impacts of the individual rule components were used. The total
annual burden associated with the proposed revisions is approximately (94,979 hours) for public
and hospitals.
For simplicity, the remainder of this document will use the term state to mean a state with primacy for the LCR
or the appropriate EPA Region (where the state does not have primacy for the rule) or any federally-recognized
Indian Tribe that has been granted primacy for the program.
On August 15,1995, the national drinking water information system that was called the Federal Reporting
Data System was replaced with the Safe Drinking Water Information System.
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water systems and (10,023 hours) for states.6 The total annual cost for public water systems and
states is ($1,573,700) and ($311,300), respectively. The average annual system and state burden
per response is (1.6 hours) and the average annual cost per response is ($28.71). Regardless of
the baseline used, it is clear that the projected impacts of the proposed regulatory revisions will be
minimal compared to the total national burden associated with the lead and copper regulations.
Most of the reduction results from proposed changes in monitoring and public education delivery
requirements. Proposed revisions to the information States are required to report to EPA also
contribute to the reduction in State implementation costs. Overall, EPA estimates the proposed
changes will result in a very minor reduction (less than 1 percent) to the annual drinking water
program burden and EPA does not believe this percentage reduction would change substantially if
costs for the entire rule were recalculated.
The number of respondents subject to the LCR was calculated by adding 56 states (or territories) to the 78,703
community water systems and non-transient non-community water systems estimated in the Final Information
Collection Request for National Primary Drinking Water Regulations for Lead and Copper. U.S.
Environmental Protection Agency. April, 1991. These systems are comprised of 793 large systems serving >
50,000 persons, 6,768 medium systems serving 3,301 - 50,000 persons, and 71,142 persons serving < 3,300
persons.
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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.
2a 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. EPA will use the information collected
as a result of the proposed modifications to support these responsibilities.
Section 1401(1)(D) of the Safe Drinking Water Act 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 of the Safe Drinking Water Act 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 Safe Drinking Water
Act requires states to "keep such records and make such reports...as the Administrator may
require by regulation."
The 1986 Safe Drinking Water Act Amendments require the Agency to publish maximum
contaminant level goals and promulgate National Primary Drinking Water Regulations for 83
specific contaminants, including lead and copper. Promulgation of the LCR complies with the
statutory requirements.
The proposed modifications are intended to improve the implementation of the LCR, and
do not alter the original maximum contaminant level goals or the fundamental approach to
controlling lead and copper in drinking water. The modifications address the following topics:
monitoring for systems deemed to optimize corrosion control under § 141.81(b)(2) or §
141.81(b)(3), systems on reduced monitoring that change treatment or water source, definition of
control as it pertains to lead service line replacement, public education reporting and delivery
requirements, sampling sites, reduced monitoring, sample invalidation, monitoring waivers for "all
plastic" systems, entry point monitoring for water quality parameters, resampling triggers for
composited source water samples, laboratory certification, analytical methods, and reporting
requirements for systems and states. The information associated with these modifications will
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assist the Agency in meeting its statutory mandates, which are ultimately designed to protect
public health.
2b Practical Utility/Users Of The Data
Public water systems must maintain records on the results of analytical monitoring. Public
water systems use these data to:
Evaluate system-specific needs, including examining treatment effectiveness;
Adjust monitoring frequencies and schedules, to address possible public health
concerns; and
Determine when it is necessary to alert the public of possible heaith risks resulting
from noncompliance with federal or state regulations.
State-level recordkeeping consists of maintaining records on each system's monitoring
requirements and analytical results, and associated state decisions regarding designation of water
quality parameters levels in the distribution system and maximum permissible levels of lead and
copper in source water, conduct of corrosion control treatment studies, and the need for an
accelerated lead service line replacement schedule. Such records assist managers in evaluating
system compliance and in identifying system needs and problem areas. The data are also used to
construct enforcement targets and identify systems requiring remedial action.
Information provided by the states is stored in the Safe Drinking Water Information
System; this centralized storage allows the Agency to conduct various program analyses. For
example, the Safe Drinking Water Information System can characterize compliance trends at the
system, state, and national program levels. Furthermore, the Safe Drinking Water Information
System is a data management system that states can use to maintain and track compliance data for
public water systems located in their jurisdiction. The Safe Drinking Water Information System
also supports the critical Agency function of maintaining program oversight, including ensuring
consistent implementation of the LCR's requirements and related state and federal enforcement
actions. The proposed revisions will improve the implementation of the LCR and assist the
Agency in these program management functions.
The states and Agency have a number of mission-critical questions to answer regarding
their supervision of regulated public water systems. Several of these questions are listed below.
At the system level:
Is each public water system complying with all applicable National Primary
Drinking Water Regulation requirements?
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For systems not in compliance, what particular rules have been violated and to
what extent?
For systems not in compliance, have appropriate steps, including enforcement
actions, been taken to return such systems to compliance?
What public health threats, if any, have resulted from noncompliance?
At the national and state level:
What are the national and state compliance trends?
What changes in national policy or regulations may be needed to increase
compliance rates?
What factors are contributing to noncompliance?
EPA's Office of Ground Water and Drinking Water, and other EPA offices that implement
regulatory programs mandated by several environmental statutes (e.g., Comprehensive
Environmental Response, Compensation, and Liability Act; Resource Conservation and Recovery
Act; and the Toxic Substances Control Act) use LCR data to support program implementation.
Non-EPA organizations also use these data. These organizations include: the Rural
Development Administration (formerly Farmers Home Administration), the Department of
Interior, the Department of Housing and Urban Development, the U.S. Army Corps of Engineers,
the Federal Emergency Management Agency, the Small Business Administration, White House
Task forces, environmental and industry groups, and many private companies and individuals.
EPA often receives requests for public water system monitoring data under the Freedom
of Information Act. Many Freedom of Information Act requests require extracting information
contained in the Safe Drinking Water Information System regarding the number of public water
systems in violation of drinking water standards in a particular geographic area.
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3 THE RESPONDENTS AND THE INFORMATION REQUESTED
The following sections provide information on the respondents and the information they
are requested to provide.
3a Respondents/SIC Codes
Under the LCR, respondents include owners and operators of public water systems
classified as community water systems and non-transient non-community water systems. The
Standard Industrial Classification code for investor-owned water systems is 4941. The Standard
Industrial Classification code for both publicly-owned water systems and state agencies is 9511.
States are respondents when reporting compliance data to EPA and when retaining federally-
required records. The proposed modifications affect the same respondent classes as the LCR.
3b Information Requested
The following sections provide detail on the data items requested and associated activities
respondents must undertake in providing information to satisfy the LCR requirements. These
sections include a brief discussion of the current (i.e., baseline) requirements of the rule and a
more detailed description of the proposed revisions to the rule.
3b(i) Data Items, Including Recordkeeping and Reporting
Public Water System Recordkeeping And Reporting
Under the current rule, public water systems must maintain and report to the state the
following information:
Monitoring results for lead and copper and water quality parameters within 10
days following the end of the monitoring period;
Identification and location of sampling sites and the rationale for choosing the
sites;
Certification regarding appropriate sample collection;
State determinations (e.g., designation of optimal corrosion control treatment);
and
* Any records, reports, or information the Administrator deems necessary.
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If applicable, the current rule also requires public water systems to maintain and report to
the state the following:
Monitoring results for lead and copper in source water within 10 days following
the end of the monitoring period,
Corrosion control and/or source water treatment recommendation and certification
that treatment(s) is(are) installed;
Progress in completing a public education program (report due the end of the
calendar year); and
Identification of lead service lines and annual report of progress in their
replacement. In addition, for those lead service lines which the water system
claims are beyond its control, written documentation of the specific legal authority
supporting this claim.
The proposed modifications do not alter the recordkeeping retention requirements under §
141.91 which specifies that systems must retain records for no fewer than 12 years.7 However,
the modifications impact the amount of records to be maintained: In addition, the proposed
revisions impact the systems' reporting requirements to the state.
In some instances, systems will be required to submit and maintain records of documents
that demonstrate to the state that they meet the criteria of a provision. In addition, systems will
also need to keep records of the state's response to their requests as follows:
Systems that can demonstrate to the state that their ninetieth percentile lead and
copper levels are no higher than 0.005 mg/1 and 0.65 nig/1, respectively, for two
consecutive six-month compliance periods can assume a triennial monitoring
schedule for lead and copper and water quality parameters at the tap without
having to complete three years of annual monitoring (i.e., "accelerated" reduced
monitoring);
Systems seeking to invalidate samples must submit documentation to the state that
demonstrates the samples meet one of the criteria outlined in the proposed §
141.86(f);
This 12-year retention period was justified and approved under the original 1991 ICR (Final Information
Collection Request for National Primary Drinking Water Regulations for Lead and Copper).
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Small systems serving 3,300 or fewer people may submit documentation that
demonstrates they are an "all plastic" system and eligible for a monitoring waiver;8
Ground water systems wishing to limit entry point water quality parameter
monitoring to those entry points that are representative of water quality
throughout the system must provide detailed records to the state that document
chemicals used in treatment and that demonstrate sites are representative;
Non-transient non-community water systems that cannot provide enough first-
draw samples can request state approval to monitor at locations where the water
has not stood motionless for at least six hours by submitting a sampling plan that
identifies where and when these "non-first-draw" samples will be collected; and
Systems exceeding either action level but which can demonstrate that their source
water lead and copper levels for three consecutive compliance periods are less than
0.005 mg/1 and 0.08 mg/1, respectively, and for which the state has determined that
source water treatment is not necessary, can reduce source water monitoring to
once every nine years.
In addition, some systems will be impacted by and required to maintain records of other
state decisions. These decisions are whether a system deemed to have optimized corrosion
control under § 141.81(b)(3) meets the additional criterion needed to remain a "b3" system9;
which sampling sites a system should include in its reduced lead and copper tap sampling pool;
and whether the community water system qualifies to use the alternative public education
language specified for non-transient non-community water systems.
Some of the proposed modifications alter the reporting requirements to provide more
timely information:
Systems on a reduced monitoring schedule that change their source or treatment
must report such changes to the state within 60 days; and
Systems that are required to deliver public education must report to the state
compliance with public education requirements within 10 days after the end of the
Refers to small systems that can demonstrate that their distribution system and all buildings they serve are free
of sources of lead or copper contamination. In addition, these systems must demonstrate that their ninetieth
percentile levels for any and all rounds of monitoring do not exceed 0.005 mg/1 for lead or 0.65 mg/1 for
copper.
Under the current rule, a system is considered to be a "b3" system if it can demonstrate that the difference
between the ninetieth percentile lead level as measured at the tap and the highest lead level measured in source
water is below the lead Practical Quantitation Level of 0.005 mg/1 for two consecutive six-month monitoring
periods.
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period in which public education was required to be performed instead of reporting ^^
this information at the end of the calendar year.I0
Other proposed revisions eliminate some of the data to be submitted by a system to the
state and any future need to maintain records of these data:
Systems are no longer required to submit certifications that samples meet the first-
draw criteria contained in § 141.86(b)(2) and if samples were collected by the
customers, that they were done so only after being instructed by the system about
proper collection methods;
Systems are no longer required to submit information justifying the use of non-Tier
1 sites or to demonstrate why the sampling pool was comprised of fewer than 50
percent of samples collected from lead service lines;
Systems which qualify as "all plastic" systems, for accelerated reduced monitoring,
and for limited entry point water quality parameter monitoring would submit fewer
monitoring results to the state and maintain fewer associated records;
Systems exceeding an action level but meeting their state-designated water quality
parameter ranges no longer need to request state permission before reducing the
number of lead and copper samples and the frequency of this monitoring; and
Systems which are required to replace lead service lines should no longer need to
submit documents demonstrating that they are not required to replace a portion of
a line due to limited line control because the proposed definition of "control" is
narrower.11
10 This modification would impact community water systems serving 500 or more persons that remain above the
lead action level for more than one monitoring period because these systems must perform some public
education tasks on a semi-annual basis for as long they exceed the lead action level. The LCR defines action
levels for lead and copper in tap water samples. These levels are set at the ninetieth 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/1.
1' As promulgated in 1991, the rule defined "control" as the authority to set standards for construction repair, or
maintenance of the line; authority to repair, replace, or maintain the service line; or ownership of the service
line. In December 1994, as a result of a legal challenge from the American Water Works Association, the
court vacated the definition, except for the portion of the definition that equated "control" with "ownership."
(A WWA v EPA: 40 F.3d 1266 (D.C. Cir. 1994)) The definition that EPA is not proposing equates "control" to
ownership plus the authority to replace.
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State Recordkeeping
The current LCR requires states to retain records regarding the currently applicable or
most recent determinations for no fewer than 12 years. States are required to retain information
relating to the decisions until a new decision, determination, or designation has been issued if no
change is made to the state decision during the 12-year retention period. States must maintain the
following system-level records of currently applicable or most recent state determinations
pertaining to the control of lead and copper, including all supporting information and an
explanation of the technical basis for each decision:
Current monitoring requirements for each public water system;
Decisions to require conduct of corrosion control treatment studies;
Determinations of optimal corrosion control and source water treatment;
Determinations of maximum permissible lead and copper concentrations in source
water and optimal water quality parameter values or ranges;
Determinations of system control of lead service lines and accelerated replacement
schedules;
Results of state activities designed to verify compliance with state determinations;
and
Reports and any other information submitted by public water systems.
The proposed modifications do not alter the length of time that records must be retained.
Instead, they may require the state to maintain additional records for some systems and fewer
records for others.
The proposed revisions require the state to retain records related to new decisions
regarding monitoring requirements for systems in several areas. States would be required to:
Retain correspondence relating to sample site selection for those systems where
the state designated reduced sampling locations;
Review and maintain sampling plans for non-transient non-community water
systems wishing to collect" non-first-draw" samples;
Maintain determinations regarding whether small systems requesting a monitoring
waiver meet the definition of an "all plastic" systems;
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Document decisions related to sample invalidation and maintain data submitted by
systems demonstrating the need for sample invalidation;
Maintain records of determinations regarding a system's qualification for
accelerated reduced monitoring;
on
! reduced monitoring;
Determine eligibility and maintain records related to the need for systems _..
reduced monitoring that change their source or treatment to return to standard
monitoring; and
Review and maintain documentation from ground water systems wishing to restrict
entry point monitoring to representative locations.
Other proposed modifications will increase the state's recordkeeping requirements due to
changes in system reporting or status as follows:
States will be required to document decisions regarding whether community water
systems qualify to use the alternative public education language specified for non-
transient non-community water systems;
The state will experience an increase in recordkeeping for community water
systems serving more than 500 people due to more frequent reporting of
compliance with public education requirements;
States would be required to maintain records for those systems no longer meeting
the "b3" criteria, that may be required to conduct a study, install treatment, and/or
monitor for water quality parameters.12
Those revisions related to accelerated reduced monitoring, monitoring waivers for "all
plastic" systems, and biweekly entry point water quality parameter monitoring will decrease state
recordkeeping requirements because the states will review and maintain fewer monitoring results.
Other proposed revisions will eliminate some of the records that would have been retained
by the state. The state will no longer have to retain records related to a system's:
Certification of first-draw or customer-collected samples;
Justification of non-Tier 1 sites or too few samples collected from homes served by
lead service lines; and
The proposed revisions add language that requires systems to also meet the copper action level for two
consecutive six-month monitoring periods. EPA anticipates that few systems that currently meet the "b3"
criteria will fail to meet the copper action level.
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Rebuttal of lead service line control and the state's response due to the elimination
of the provision which allowed a system to rebut the presumption that it controlled
the entire line.
State Reporting
Under the current LCR, states are required to report quarterly to the Agency information
on each system's compliance with monitoring and reporting, and treatment techniques
requirements. In addition, the state must report certain milestone events as required under §
142.15. In particular, states must report the name and identification number of each public water
system that:
Exceeded the lead or copper action levels and the date the exceedance occurred;
Is required to complete a corrosion control study;
Received a state determination regarding optimal corrosion control treatment,
optimal water quality parameters, source water treatment requirement, or
maximum permissible source water levels;
Completed installation of corrosion control or source water treatment; and
Is required to replace lead service lines, has a state-designated accelerated
replacement schedule, or reports compliance with its schedule.
The proposed modifications do not change the reporting frequency for these milestones or
significantly alter the data categories for which states must report information to EPA; however,
the modifications will eliminate unnecessary or redundant reporting (e.g., information currently in
the Safe Drinking Water Information System) for four of the milestones. The modifications also
will require additional data to be reported for two of the existing milestones. These changes are
explained in more detail below:
Ninetieth Percentile Levels
The Agency will require states to report ninetieth percentile lead levels for all large and
medium water systems. EPA is not proposing to change the requirements for small systems, but
will retain the original requirement that only those lead levels in excess of the action level be
reported for these systems. EPA believes requiring the reporting of additional ninetieth percentile
lead levels for large and medium systems is essential because such data will support analysis of
corrosion control and source water treatment effectiveness. In addition, the data will prove
invaluable when the Agency evaluates the LCR and its public health benefits.
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The proposed revision also provides two other changes intended to clarify the
requirements. First, the current wording of § 142.15(c)(4)(i) suggests that a ninetieth percentile
value be reported for systems that exceed both the lead and copper action levels. EPA is
proposing to replace the phrase "lead and copper action levels" with the phrase "lead or copper
action level." Further, EPA believes that the term "date upon which the exceedance occurred" is
confusing and is proposing to change this term with "last date of the compliance period in which
the exceedance occurred". These wording changes are not expected to significantly impact the
state reporting burden, but should help minimize confusion by the state.
Corrosion Control Study
States are currently required to submit the name and identification number of each system
required to conduct a corrosion control study and the date the study is completed. EPA is
proposing to eliminate these requirements because failure to conduct a corrosion control
treatment study is a violation of the LCR that must be reported to the Safe Drinking Water
Information System.
Optimal Corrosion Control Installation/Designation
States are currently required to submit the name of each system for which it has
designated optimal corrosion control treatment, the date of the determination, and each system
that has completed installation of this treatment. EPA is proposing to eliminate the portion of the
requirement to report those systems that have completed installing corrosion control treatment.
EPA believes that reporting of this milestone is redundant because failure of a system to complete
this installation is a violation that must be reported to the Safe Drinking Water Information
System.
Source Water Treatment Installation
States are currently required to submit the name and identification number of each system
that has installed state-designated source water treatment. EPA is proposing to expand the data
collected for this milestone to include the date the state receives certification from the system that
the treatment has been properly installed; EPA believes this information will be useful in assessing
compliance with the LCR source water treatment installation requirements and subsequent
monitoring requirements.
Maximum Permissible Source Water Levels
States are currently required to submit the name and identification number of each system
for which the state has specified maximum permissible levels. EPA is proposing to eliminate this
reporting requirement because it can determine the systems for which maximum permissible levels
have been set from other source water treatment and installation information that is reported.
Furthermore, EPA will know if a system fails to meet its maximum permissible levels because this
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constitutes an LCR violation that states must report to the Safe Drinking Water Information
System.
Lead Service Line Replacement
States are currently required to submit the name and identification number of each system:
(1) that must replace lead service lines; (2) for which the state has established an accelerated
replacement schedule; and (3) reporting compliance with its replacement schedule. EPA is
proposing to modify the current lead service line reporting requirement to include only the name
and identification number of each water system that must replace lead service lines and the date
replacement must begin.
EPA has determined that it is not necessary to collect information about accelerated lead
service line replacement schedules because EPA can request this information from states, if
needed. EPA is proposing to eliminate the portion of this milestone associated with reporting a
system's compliance with its lead service line replacement schedule because EPA will be able to
determine system compliance using information already reported to the Safe Drinking Water
Information System. In particular, because failure to comply with an accelerated or other
replacement schedule constitutes an LCR violation, it must be reported to the Safe Drinking
Water Information System.
3b(H) Respondent Activities
Respondents include both public water systems and state primacy agencies. Public water
system owners and operators are required to comply with the LCR. In general, the LCR requires
each public water system to undertake the following activities:
Read the regulations;
Plan monitoring, treatment, and other activities;
Provide training to appropriate staff and to residents collecting samples;
Identify appropriate sampling sites and collect samples;
Review sample data including the calculation of lead and copper ninetieth
percentile levels;
Submit to the state or EPA Region monitoring data or any other
documents/reports; and
Record and maintain information.
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In addition, some systems will be required to perform corrosion control studies, install
treatment and/or source water treatment, conduct public education, and/or replace lead service
lines.
The proposed rule revisions are consistent and compatible with the existing reporting and
recordkeeping practices of these respondents. They do not alter the retention periods for
maintaining records. The revisions will result in less frequent reporting and fewer records to be
maintained for some systems and a corresponding decrease in the number of records to be
reviewed or retained by the state. The expected impact that each proposed revision will have on
respondent activity is described below. The recordkeeping and reporting impacts were discussed
in more detail in Section 3b(i) of this document.
Systems Deemed to Have Optimized Corrosion Control
Systems optimizing corrosion control under § 141.81(b)(2) would be required to continue
lead and copper tap water monitoring and water quality parameter monitoring similar to other
systems required to install treatment.13 Currently, the LCR requires states to set water quality
parameters for Mb2" systems, but does not explicitly require these systems to continue water
quality parameter monitoring. Water quality parameter monitoring for small and medium systems
would be limited to those monitoring periods in which they exceeded the lead or copper action
level. Systems optimizing corrosion control under § 141.81(b)(3) would be required to continue
lead and copper tap water monitoring on a triennial basis at a reduced number of sites.
In addition, the revisions clarify EPA's intention that "b3" systems also meet the copper
action level for two consecutive six-month monitoring periods. A "b3" system that exceeds the
copper action level will no longer qualify for this designation, and may be required to provide the
state with a treatment recommendation, conduct a corrosion control study, and install corrosion
control treatment.
Accelerated Reduced Monitoring
Lead and Copper Tap Monitoring
Systems with very low lead and copper levels (i.e., those systems having ninetieth
percentile lead levels of 0.005 mg/1 or less and ninetieth percentile copper levels of 0.65 mg/1 or
less) for two consecutive six-month monitoring periods qualify for accelerated reduced
monitoring and can monitor triennially at the reduced number of sites without first monitoring on
an annual schedule (as currently required). If this proposed change becomes effective in 1997
(based on EPA's current schedule for promulgation), all systems that completed their first two
rounds of monitoring on schedule and met the action levels will not benefit from this change.
A system optimizing treatment under § 141.81(b)(2) (i.e., a "b2" system) has demonstrated that it has
conducted activities equivalent to corrosion control treatment steps in the rule.
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However, systems that will have to install corrosion control treatment because they exceeded the
lead and/or copper action levels will benefit by being able to proceed to reduced monitoring
sooner.
Water Quality Parameter Monitoring
Systems that qualify for accelerated reduced lead and copper tap monitoring would also
qualify for accelerated reduced water quality parameter tap monitoring.14 This would allow
systems to also collect water quality parameters at reduced number of taps every three years
instead of first monitoring at a reduced number of sites semi-annually and then annually.
Sample Invalidation
Systems wishing to have a sample invalidated must demonstrate to the state that:
the laboratory established that improper sampling analysis caused
erroneous results,
the sample was taken from a site that does not meet the site-selection
criteria of § 141.86;
the sample container was damaged in transit; or
the sample was subject to tampering.
In addition, systems that collected the minimum number of required samples during the
compliance period would be required to collect additional samples to replace those samples which
were invalidated. On the other hand, sample invalidation may allow some systems to avoid the
costs associated with returning to standard monitoring (once on reduced monitoring) or
unnecessary corrosion control treatment requirements which could have been triggered by invalid
results that caused an action level exceedance.
Monitoring Waivers for "All Plastic" Systems
Small systems serving 3,300 or fewer people that can demonstrate that their distribution
system and all buildings that they serve are free of sources of lead or copper contamination (i.e.,
"all plastic" systems) can qualify for a monitoring waiver. These systems must also demonstrate
that for any and all rounds of monitoring their ninetieth percentile lead levels are 0.005 mg/1 or
less and ninetieth percentile copper levels are 0.65 mg/1 or less. Systems qualifying for a
monitoring waiver would be required to monitor at a frequency of once every nine years.
This provision does not impact the frequency of water quality parameter monitoring at entry points. This
monitoring remains at a frequency of once every two weeks (biweekly).
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Sample Site Location
Systems with Insufficient Tiered Sites
Systems without sufficient Tier 1, 2, or 3 sites would be allowed to sample from non-
tiered sites that are representative of sites throughout the distribution system. This provision is
not expected to impact systems or states because the system is not required to request or receive
approval from the state to sample from non-tiered sites.
Non-transient Non-community Water System Monitoring
Non-transient non-community water systems without a sufficient number of sampling sites
that can provide first-draw samples could request written approval from the state to collect non-
first-draw samples. These systems must suggest sampling times and locations that would likely
result in the longest standing times and must sample at times and locations specified by the state.
Sample Site Justifications
Under the current rule, systems were required to notify the state if they were unable to
complete their sampling pool with Tier 1 sites or to collect 50 percent of the samples from sites
served by lead service lines. The Agency expected these to be "one-time" requirements but is
finding systems are experiencing difficulty obtaining continued access to the same sites. Changes
to the sampling pool could trigger these reporting requirements. EPA is proposing to eliminate
these reporting requirements because states can use other mechanisms such as on-site inspections
or file reviews to determine if systems are sampling at appropriate locations.
Selection of Sample Sites Under Reduced Monitoring
Systems must include representative sampling sites in their reduced monitoring sampling
pools and states may designate, when deemed appropriate, which sampling sites a system must
use when conducting reduced monitoring.
Systems thaLChange Treatment or Source Water
EPA is proposed that systems on reduced monitoring that change their source or
treatment report the change to the state within 60 days. The Agency is concerned that the current
rule may not have adequately addressed systems deemed to have optimized corrosion control who
later make changes to their treatment or monitoring. Because these systems would be monitoring
at a reduced frequency, any increase in lead or copper levels may occur within a relatively short
period of time and may go undetected for up to three years under the current rule (or nine years
under the proposed revisions.)
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Entry Point Monitoring for Water Quality Parameters in Ground Water Systems
The Agency is proposing to allow ground water systems, required to monitor for water
quality parameters to limit biweekly entry point monitoring, to those locations that are
representative of water quality throughout the distribution system. To take advantage of this
provision, systems must provide detailed records regarding chemical additions and water quality
at those entry points that are monitored and provide documentation showing that these locations
are representative of water quality throughout the distribution system.
Other Changes Pertaining to Lead and Copper Tap Water Monitoring
Sample Certification
Currently, systems are required to submit a certification with their lead and copper
monitoring results that each sample meets the first-draw specifications outlined in § 141.86(b) and
that any sample collected by residents were done only after they received proper instructions from
the water system. EPA is proposing to eliminate these reporting requirements. Although the
effort associated with each certification is minimal, it is required by all systems each time lead and
copper results are submitted.
State Approval for Reduced Monitoring
Under the current regulation, systems meeting their optimal water quality parameter
ranges must first request approval from the state before assuming a reduced lead and copper tap
monitoring schedule. The Agency is proposing to eliminate this requirement because states
routinely review system eligibility for reduced monitoring and notify systems of changes in their
monitoring requirements as part of their compliance oversight function.
Sampling for Seasonal Systems
Systems on annual or less frequent monitoring that do not operate from June through
September may monitor during their wannest months of operation.15 The cost models do not
estimate a change in burden because the volume of samples remains the same. However, some
cost savings may be realized because these system would no longer have to make special
arrangements to monitor during their "off-season."
Cuirently, § 141.86(d)(4)(iv) requires systems that monitor tap water for lead and copper annually or less
frequently to sample during the months of June, July, August, or September.
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Public Education
Alternative Public Education Language
Currently, the public education mandatory language is the same for community water
systems and non-transient non-community water systems. The proposed revisions provide
alternative public education language that can be used by non-transient non-community water
systems and some community water systems.16
Mailing and Timing of Notices
The modifications allow systems to mail public education materials on the same schedule
as their billing cycles, provided the mailings occur within six months of the lead exceedance. It
also permits systems using billing formats that do not allow for enclosures of additional materials
to mail public education materials separately from water bills, so long as the mailing is completed
within the required time frame and achieves equal coverage.
Systems Serving 500 or Fewer People
The modifications limit or omit some of the required public education tasks for systems
serving 500 or fewer people. In particular, these systems would no longer be subject to the
current public service announcement requirements, which must be performed semi-annuaily, but
will continue to be required to conduct other public education tasks on an annual basis for as long
as the lead action level is exceeded. Further, distribution of public education materials will be
limited to facilities and organizations that are located within the system's service area or that are
likely to be visited regularly by those served by the system.
Reporting Completion of Public Education Tasks
The proposed rule would require each system subject to the public education requirements
to submit to the state a letter demonstrating compliance with those requirements. The letter
would be due within 10 days after the end of the period in which the system was required to
perform public education. As is currently required, this letter must include a list of all
newspapers, radio and television stations, and facilities/organizations to which the system
delivered public education materials during the calendar year. Currently, systems do not have to
submit a letter until December 31 of each year. EPA wants to change this requirement because
the Agency and the states are not provided information in a timely manner to ensure compliance.
Includes those community water systems whose service population cannot make plumbing improvements or
install point-of-use treatment devices, which provide water as part of the covered services, and do not directly
bill for water consumption. Qualifying community water systems are required to obtain prior state approval
before using the alternative language.
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This modification would increase burden for those community water systems serving more than
500 persons that would remain above the lead action level for more than one reporting period
and, therefore, be required to continue public education delivery.17
Lead Service Line Replacement
A public water system exceeding the lead action level at the tap after installation of
optimal corrosion control treatment and/or source water treatment is required to replace the lead
service lines they "control," unless the system can demonstrate that all samples taken from the line
have lead levels of 0.015 mg/1 or less.1* The proposed modifications provide a more narrow
definition of "control" in which "control" equates to ownership plus the authority to replace. This
narrower definition of control may result in fewer lines or a smaller portion of the lines being
replaced.
Under the current rule, systems can submit documentation to the state that supports their
claim that a line or portion of a line is outside their control and, therefore, is not required to be
replaced. The Agency believes that this new definition of control is "self-implementing" and that
systems will no longer need to rebut the presumption of lead service line control. Therefore, EPA
proposes to remove this provision.
Spjiree^Water Monitoring
Composite Samples
The copper resampling trigger for composite sampling would increase from 0.001 mg/1 or
0.020 mg/I (depending on the analytical method) to 0.160 mg/1. Therefore, some systems may
avoid additional costs associated with resampling and analyzing each site comprising the
composite sample.
The current rule requires all community water systems to perform public education on a semiannual basis for
as long as these systems exceed the lead action level. As mentioned above, the proposed revisions limit some
of the public education tasks for community water systems serving 500 or fewer persons, which would include
changing the frequency of public education delivery from semiannually to annually. Non-transient non-
community water systems under the current and proposed rule are required to conduct public education
annually.
A system may avoid replacing a lead service line by demonstrating that the lead concentration in any sample
collected from that line is 0.015 mg/1 or less. The system may count lines with such levels toward the annual
seven percent replacement requirements. None of the proposed rule modifications change the lead service line
monitoring provisions.
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r
Reduced Source Water Monitoring
Systems for which the state has not set maximum permissible levels that exceed the lead or
copper action level but maintain very low source water lead and copper levels (i.e., below EPA's
recommended source water treatment threshold of 0.005 mg/1 for lead and 0.8 mg/1 for copper)
for three consecutive monitoring periods would be allowed to sample source water once every
nine years. The current rule allows a system to reduce source water monitoring when it exceeds
an action level if it meets state-designated maximum permissible source water levels. The Agency
believes that it is appropriate to allow these systems for which the state has not set maximum
permissible levels to assume a reduced monitoring schedule because the state effectively has
determined that source water treatment is not needed. The proposed change is consistent with
the protocol for reducing the frequency of source water monitoring in the current rule for systems
meeting state-designated lead and copper maximum permissible levels after the installation of
source water treatment.
Other Proposed Modifications Without Recordkeeoing or Reporting Impacts
Three other modifications are not expected to have an ICR impact on the system or state
but are included in this document to provide a comprehensive discussion of all proposed LCR
revisions. First, EPA is proposing to reduce the holding time for acidified lead or copper from 28
hours to 16 hours. This modification will increase the number of samples that can be processed in
a day and will reduce the burden on systems and laboratories to have separate holding times for
lead and copper than for other metals. Second prior references to § 141.23(a)(l)-(4), which
contain requirements associated with sample location, number, and collection method, are now
incorporated at § 141.88(a)(l)(i)-(iii), along with provisions for compositing. Third, EPA is
modifying § 141.89 to remove the requirements that laboratories achieve the copper method
detection level of 0.001 mg/1 or 0.020 mg/1 because the laboratories will be sufficiently tested on
their capabilities, as required by § 141.90(l)(ii).19
Section 141.90(l)(ii) requires laboratories to achieve a quantitative acceptable limit of ± 10 percent of the
actual amount of a performance sample when the actual amount is greater than or equal to 0.050 mg/1, which is
below the proposed copper resampling trigger of 0.160 mg/1.
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4 THE INFORMATION COLLECTEDAGENCY ACTIVITIES,
COLLECTION METHODOLOGY, AND INFORMATION
MANAGEMENT
The following sections describe the Agency activities related to analyzing, maintaining,
and distributing the information collected.
4a Agency and State Activities
4a(i) Agency Activities
The Agency is responsible for promulgating and overseeing the implementation of the
proposed modifications to the LCR. The Agency will be involved in the following activities that
assist states in implementing the proposed modifications:
Develop the regulations and necessary guidance materials;
Respond to questions on the regulations or guidance materials;
Review and analyze data submissions from states to ensure consistent and
appropriate implementation of the requirements; and
Process and maintain the Safe Drinking Water Information System data associated
with state submissions.
4a(ii) State Activities
States are required to adopt the basic requirements for primacy and to adopt any special
primacy requirements specific to a particular National Primary Drinking Water Regulation. The
special state primacy requirements associated with the LCR appear in § 142.16, and must be
adopted by states that will implement the LCR. States seeking LCR primacy must demonstrate
that the deadlines for program implementation and state determinations are enforceable under
state law and describe procedures and criteria that will be used to implement the LCR.
In addition to fulfilling the basic and special requirements for primacy, the state must
conduct specific oversight activities that ensure proper implementation of the LCR treatment
technique, monitoring, recordkeeping, and reporting requirements. Successful implementation of
the LCR requires both states and systems to be knowledgeable of the rule's requirements and to
keep abreast of any modifications. A critical responsibility of the state is to provide training to its
employees and to provide outreach and technical assistance to systems regarding these
requirements. In addition, the state must determine and track compliance with each of rule
requirements and its response to noncompliance (i.e., enforcement actions).
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The proposed modifications would require the states to make decisions and prepare
correspondence to the system regarding monitoring waivers for "all plastic" systems, instances
where the state decides to designate the sampling sites to be included in a reduced sampling pool,
"non-first-draw" samples for non-transient non-community water systems, sample invalidation,
entry point monitoring for ground water systems, instances when systems on reduced monitoring
that change their source or treatment should return to standard monitoring or take other action
the state determines appropriate, and approvals for qualifying community water systems to use the
non-transient non-community public education language..
States will be required to review additional lead and copper tap water monitoring for "b2"
and "b3" systems and water quality parameter monitoring data for "b2" systems, unless the state
had previously required such monitoring to be performed. The state will be required to notify
those "b3" systems failing to meet the new criterion and that must install corrosion control.
States will review twice as many public education compliance letters for their larger
community water systems. In addition, states will need to determine if the alternative public
education delivery method used by a system attains coverage equal to methods currently
permitted by the LCR.
On the other hand, states will be review less monitoring results for systems qualifying as
"all plastic" systems and those systems assuming an accelerated reduced lead and copper and/or
water tap monitoring schedule. States may also review fewer source water samples for systems
that avoid resampling due to a higher copper resampling trigger. In addition, states will review
fewer documents with each round of lead and copper tap water monitoring because systems will
no longer be submitting first-draw sample certifications or sampling pool justifications.
4b Collection Methodology And Management
Responsibility for promulgating and overseeing the implementation of the proposed
modifications to the LCR and for maintenance of the Safe Drinking Water Information System
resides in the Office of Ground Water and Drinking Water. The Office of Ground Water and
Drinking Water has established procedures and allocated resources to allow states to submit
information in electronic format to the Safe Drinking Water Information System. This data
system already has the capability to accept the additional state data that would be required by the
proposed revisions. For example, the Safe Drinking Water Information System can currently
accept the reporting of all ninetieth percentile lead data for any system and dates associated with
various milestones.
The data generated as a result of the modifications will be integrated in the existing
quarterly Safe Drinking Water Information System reporting cycle. This integration will result in
efficiencies because fixed reporting costs will be distributed among all data requirements. In
addition, having this data in a national automated data base allows the Agency to readily access
needed information and provides sorting capabilities to more readily compile and analyze data for
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Agency use and response to the public and outside agencies. Further, use of an electronic format
reduces burden and improves data quality because it eliminates the need for states or the Agency
to rekey data.
4c Small Entity Flexibility
As indicated in earlier sections of this ICR, EPA is proposing revisions to the current LCR
which reduce to the extent practicable and appropriate the burden on states and public water
systems, 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
which requires all executive agencies to consider small entities in their regulatory design and
implementation processes.
The Regulatory Flexibility Act recognizes the Small Business Administration's definition of
a small entity. The Small Business Administration defines a small water utility as one that serves
less than 50,000 people.20 For investor-owned water systems, the small business size standard is
an average of $3.5 million dollars in annual revenues over the previous three years. The Agency
estimates that a service population of 50,000 is consistent with the $3.5 million standard. Given
this service population size, more than 98 percent of public water systems would be considered
small businesses. Examples of small entity flexibility provided by the proposed revisions are
discussed in Sections 4c(i) and 4c(ii) below.
4c(i) Minimizing Burden
The Agency believes the monitoring requirements of the current LCR meet the goal of
achieving compliance and provide efficient use of state and public water system resources.
During the development of the original rule, the Agency took steps to minimize the reporting
burden for all regulated systems, particularly small systems. Some of these measures included
requiring:
fewer tap and water quality parameter samples for small systems;
systems serving < 50,000 persons to conduct corrosion control studies only when
specified by the state; and
systems serving < 50,000 persons to install corrosion control treatment only if they
continue to exceed the lead or copper action level.
In all other sections of this ICR, a small system refers to those community and non-transient non-community
system that serves < 3,300 persons.
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With the implementation of the LCR, the Agency realized that certain requirements could
be eliminated without impacting public health protection and that other changes would promote
consistent and flexible implementation of the rule nationwide. The proposed revisions to the LCR
will accomplish these objectives. Such objectives are consistent with the Regulatory Flexibility
Act, which requires that all executive agencies explicitly consider small entities in their regulatory
design and implementation processes.
Most of the quantifiable cost impacts described in Section 6.0 affect systems serving
50,000 or fewer people. Annual system costs are expected to decrease and small systems (those
serving 3,300 or fewer persons) would derive all the cost savings associated with the "all plastic"
system provision. Systems qualifying as an "all plastic" system would be able to reduce tap water
monitoring to once every nine years. Small systems would also receive most of the cost savings
associated with accelerated reduced lead and copper monitoring. In particular, small systems
installing treatment that demonstrate very low lead and copper levels (i.e., those systems having
ninetieth percentile lead levels of 0.005 mg/1 or less and ninetieth percentile copper levels of 0.65
mg/1 or less) for two consecutive 6-month monitoring periods would avoid two rounds of annual
monitoring. Further, community water systems serving 500 or fewer people that exceed the lead
action level would be able to narrow the scope of their public education efforts.
4c(ii) Consideration of Alternatives
The Agency proposed the modifications described in this ICR in part because it
recognized the need to correct inadvertent omissions from the original rule. These omissions may
have resulted in systems ceasing monitoring or monitoring less frequently than the Agency
originally intended. For example, the Agency intended that systems optimizing corrosion control
under § 141.81(b)(2) continue water quality parameter monitoring after the state designated
optimal water quality parameters. The Agency also intended that "b2" and "b3" systems continue
lead and copper tap water monitoring. The modifications to correct these omissions are necessary
to ensure that public health is adequately protected.
The proposed revisions also clarify and simplify some of the requirements. For example,
the Agency changed wording in § 142.15(c)(4)(i) to clarify when the state should report a lead or
copper exceedance. In addition, the definition of lead service line control has been streamlined to
clarify when a system is considered to control and thereby, required to replace a lead service line.
This change in definition also eliminates the need for a system to refute ownership, and therefore,
the rebuttable presumption of ownership provision has been deleted.
The Agency also proposed the modifications to streamline monitoring requirements for
systems meeting certain criteria. For example, the Agency believes that systems with very low
lead and copper levels (i.e., levels significantly below the action levels) should be able to assume a
triennial monitoring schedule for lead and copper and water quality parameter tap water
monitoring more quickly than permitted by the LCR. Similarly, systems that can demonstrate that
they meet the criteria of an "all plastic" system can conduct lead and copper tap monitoring once
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every nine years. Further, the proposed revisions allow ground water systems to limit biweekly
entry point monitoring to those locations that are representative of water quality throughout the
distribution system.21 In addition, systems exceeding the lead or copper action level because of
corrosive water may reduce the frequency of source water monitoring even if the state has not
established maximum permissible lead and copper source water levels. Also, the increase in the
copper resampling trigger will eliminate the need for some systems to resample.
In addition, the proposed revisions eliminate unnecessary state and system reporting
requirements. The Agency is proposing to eliminate requirements for the states to report
information that EPA can already obtain from the Safe Drinking Water Information System. For
example, the state would no longer be required to report those systems for which the state has
specified maximum permissible levels because these systems can be determined by reviewing
information reported for source water treatment designation and installation milestones. Public
water systems would no longer be required to certify to the state that they have collected first-
draw samples or to request state permission to assume a reduced lead and copper tap water
monitoring regime once they meet their optimal water quality parameters.
The proposed modifications also improve implementation by providing flexibility in how
the rule is implemented. Examples of this flexibility include allowing samples that may not
represent actual levels of lead and copper in tap water to be invalidated. The proposed
modifications also would allow non-transient non-community water systems to use samples taken
from non-first-draw sites when they do not have a sufficient number of sites that meet the first-
draw criteria or to collect samples during the warmest months of operation when the system is
closed during the summer months. Further, systems without sufficient Tier 1, 2, or 3 sites can
collect samples from representative locations. In addition, non-transient non-community water
systems and some community water systems have the option of delivering alternative public
education language. The proposed revisions also provide community water systems with
flexibility in the timing and method of delivery of their public education materials.
EPA considered including the reporting of all small system ninetieth percentile data, once
these systems exceeded the lead action level. The Agency decided this would impose too much of
a burden on states and that sufficient information regarding corrosion control treatment
effectiveness could be obtained from large and medium system data.
The LCR is different from other drinking water regulations because state-specified values
and schedules (i.e., water quality parameters, maximum permissible lead levels, and accelerated
lead service line replacement schedules) constitute federal requirements. The Agency considered
requiring the details about state-specified values and schedules be reported by states so that the
Agency can effectively evaluate and enforce compliance with the LCR. Submittal to EPA of
This provision will benefit small water systems serving 3,301 - 50,000 persons. Systems serving < 3,300
people are assumed to already be collecting a limited number of entry points samples due to their size and
configuration and would not be able to reduce the number of sampling locations.
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state-specified requirements would also provide federal staff the ability to conduct inspections
without having to coordinate with states to determine a particular system's requirements.
Despite the advantages associated with this alternative, the Agency chose not to propose
this option because it recognized that state data entry and reporting costs would increase
significantly.22 Increases were expected because many states have chosen not to automate
detailed data they possess. For example, many states have chosen not to automate specific water
quality parameter values because this information is contained in system treatment
recommendations or formal treatment studies.
4d Collection Schedule
The Agency has considered a wide range of alternatives for frequency of data collection,
and has chosen the option that requires the least frequent collection possible while still remaining
consistent with its overall objective of protecting public health. Where possible, state discretion in
adjusting these frequencies has been allowed. Monitoring frequencies for public water systems
have been carefully devised based on the following factors: type of contaminant, system type and
size, system vulnerability, and contaminant history.
The consequences of less frequent data collection include the possibility of failing to
identify in a timely fashion significant contaminant concentrations which might threaten public
health and safety. Although the proposed modifications allow accelerated reduced monitoring
frequencies and monitoring waivers for "all plastic" systems, they require that a system first meet
stringent criteria that the Agency believes are protective of public health. Further, these systems
would be required to apply for a monitoring waiver for any new source and to return to standard
monitoring if new construction or repairs made them ineligible for a monitoring waiver. In
addition, the proposed rule adds a provision that requires systems subject to reduced monitoring
to inform the state within 60 days of any changes in its source or treatment(s). This allows the
state to detect in a timely fashion whether corrosivity of the water has increased due to these
changes. Otherwise, a state would be unaware of changes in lead and copper levels until the next
monitoring results were submitted which could be as long as nine years under the proposed rule.
The provision also would allow a state to return a system to standard monitoring if deemed
necessary.
22 Due to compliance and enforcement advantages of reporting this information, the Agency is accepting public
comment on requiring this option.
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5 NONDUPLICATION, CONSULTATIONS, AND OTHER
COLLECTION CRITERIA
The following sections verify and affirm that this information collection satisfies the Office
of Management and Budget's collection guidelines, has public support, and does not duplicate
another collection.
5a Nonduplication
To the best of the Agency's knowledge, data required by the LCR and the proposed modifications
are not available from any other source. The proposed revisions are not unnecessarily duplicative
of information otherwise reasonably accessible to the Agency. Instead, the proposed revisions
would eliminate reporting requirements which the Agency has found to be redundant or no longer
necessary.
5b Consultations23
The proposed regulatory modifications represent the product of numerous work group
discussions. The work group established in 1993 was comprised of Headquarters and Regional
EPA staff, and state drinking water officials. In addition, EPA distributed a draft of the proposed
modifications to the Association of State Drinking Water Administrators (ASDWA). ASDWA, in
turn, circulated the draft to its members and requested written comment. Written comments were
received from numerous Regional and state agencies. Public water system input was gathered
through state comments, as well as comments submitted by the Association of Metropolitan
Water Agencies and the American Water Works Association. Further, several of the proposed
revisions, which include the elimination of some of the system reporting requirements are the
result of Stakeholders meetings that the Agency has held relative to its burden reduction efforts.
5c Effects Of Less Frequent Collection
The Agency considered numerous alternatives regarding the number and frequency of
samples to be collected. It has selected the approach that minimizes the data collection burden
and is consistent with monitoring objectives of protecting public health. The Agency was
concerned that monitoring once a year would not capture the variability in lead and copper levels
within systems or within homes and, consequently, would increase the possibility of not detecting
the presence of high lead and copper concentrations.
In developing the final version of the current LCR, EPA consulted with the National Drinking Water Advisory
Council and requested comments from its Science Advisory Board. The monitoring requirements reflect
comments by the drinking water industry. In addition, during the comment period, approximately 28,000
comments were received from approximately 3,000 individuals and organizations.
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The proposed modifications that allow accelerated reduced tap and water quality
parameter monitoring, monitoring waivers for "all plastic" systems, biweekly water quality
parameter monitoring at representative sites, and reduced source water monitoring for systems for
which the state has not set maximum permissible levels will result in less frequent collection of
monitoring data for certain systems. The Agency has determined that less frequent monitoring is
warranted for these systems because they meet stringent criteria, which the Agency believes are
protective of public health. As mentioned in Section 4d, the Agency also has added as a
contingency, a provision that would allow states to detect early whether treatment or source
water changes for systems on reduced monitoring would impact water quality and require the
system to return to standard monitoring.
5d General Guidelines
The LCR and proposed modifications comply with the guidelines published under the
Paperwork Reduction Act, with the exception that requires records be retained for a period
greater than three years. In particular, the current LCR requires all public water systems 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 1991ICR. The proposed revisions do not alter the system or state
recordkeeping requirements.
5e Confidentiality And Sensitive Questions
The proposed data collection does not raise confidentiality issues or ask sensitive
questions.
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6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION
This section describes the change in respondent burden and cost for information collection
activities under the proposed modifications to the LCR. In addition, the appendices include tables
that show the change in total burden and cost for public water systems and states for the entire
LCR, including the proposed modifications; and present the impact on program burden and costs
for both systems and states.
Annual burden and cost estimates for the proposed modifications are averaged over the 13
years remaining in the 18-year LCR planning period. This ICR presents burdens and costs for the
first three years of implementation of the modifications. EPA expects to promulgate the proposed
modifications to the LCR in 1997. Consequently, three-year costs and burdens are estimated for
1997 through 1999.
6a Estimating Respondent Burden
The information collection burden is estimated separately for public water systems and
states below. Respondent costs are presented in section 6b.
6a(i) Burden To Public Water Systems
EPA estimates that the modifications to the LCR will affect approximately 79,000 public
water systems, although individual requirements will apply to subsets of drinking water systems.
Public water systems include both community water systems and non-transient non-community
water systems. Recordkeeping and reporting activities under the proposed modifications will
decrease annual burden to public water systems by approximately 94,979 hours. Over the three-
year life span of this ICR, the decrease in burden to public water systems will be 284,937 hours.
Figure 6-1 summarizes the change in burden to public water systems
31
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Figure 6-1
Proposed Revisions to LCR
Annual System Burden
Collection Activity
Responses
Burden per
Response
(Hours)
Total
Burden Hours
Ongoing Activities
Plan and review
NA
NA
432
Monitoring
Certifications for first-draw samples
Approval for reduced monitoring
Accelerated reduced monitoring
Waivers for "all plastic" systems
Changes in treatment/source water
Entry point water quality parameter
monitoring
Rebuttable presumption of lead ownership
(41,170)
(923)
(7,077)
(9,557)
1,477
(2,961)
(115)
0.2
1.0
3.0
3.1
1.0
0.5
8.0
(6,862)
(923)
(21,231)
(29,750)
1,477
(1,481)
(920)
Public education
Reporting completion of public education
Systems serving 500 or fewer people
TOTAL
13,670
(19,000)
(65,656)
0.2
2.0
2.278
(38,000)
(94,979)
The change in annual burden is presented below for the following activities: reading the
regulations, planning and reviewing, monitoring, and reporting completion of public education
tasks. EPA has determined that the burden for other activities, such as training, will not be
affected by the proposed modifications. The assumptions and methodologies for deriving the
estimates are discussed in each section.
Read the Regulations and Plan/Review Activities
Since states will be mainly responsible for understanding and adopting these regulations
and for notifying public water systems of changes in specific rule requirements, public water
systems, especially small public water systems, are assumed to bear a relatively minor burden for
activities such as reading the regulations and planning and review. EPA assumes that 20 percent
of systems will incur a 0.5 percent increase in burden over the remaining 13 years from these
activities as a result of the proposed modifications. A mixture of junior and senior staff will
32
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perform them. EPA projects that senior staff will read the regulations and contribute 10 percent
of the planning and review time. Junior staff will contribute the remaining planning and review
time.
The initial or one-time burden (averaged over 13 years) of reading the regulations will
increase by an insignificant amount. The ongoing burden for planning activities is estimated to
increase by about 432 hours per year. This represents an increase in planning time of 2 seconds
per sample for all systems. EPA calculated these burdens by multiplying the number of systems in
each size category by the appropriate unit burden.
Monitoring
The estimates of public water system monitoring burden include the following activities:
Gather information (i.e., identify sample sites and take samples);
Create information (i.e., conduct tests on samples collected),
Process, compile, and review information created;
Submit report and other documents; and
Record and maintain the monitoring results.
EPA estimated burdens separately for lead and copper monitoring at the tap, water quality
parameter monitoring, and lead and copper monitoring at the source. The proposed modifications
do not affect the public water system burden and cost for lead service line replacement
monitoring. The public water system burden for all monitoring activities will decrease by about
58,770 hours per year. The estimation procedure by compliance type is outlined below. EPA
assumes that all monitoring is conducted by junior staff.
Lead and Copper Tap Water Monitoring. EPA estimates that the annual lead and
copper tap water monitoring burden will decrease by about 57,289 hours (171,867 hours over
three years). The assumptions used to estimate the burden are presented below:
All systems would conduct initial monitoring then revert to reduced monitoring, if
applicable;
Monitoring will be an ongoing burden, and is averaged over an 13-year period to
obtain average annual burdens;
Sample collection (the labor required for travel, gaining access to the sampling
station, and sample collection) takes 2.0 hours per sample;
33
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Time for designing the targeted sampling strategy, recordkeeping, and interpreting
results have not been estimated separately and are assumed to be included in the
sample collection burden; and
Sample analysis takes 1.0 hour per sample.
Thus, the unit burden per lead and copper tap water sample is 3.0 hours.
Certifications for first-draw samples. EPA estimates that systems will avoid
41,170 certifications per year and that each certification would have required 10
minutes to prepare. The total reduction in annual burden is estimated to be 6,862
hours (20,586 over three years).24
Approval for reduced monitoring. EPA estimates that 12,000 systems in total (or
an average of 923 systems per year) that meet their state-specified water quality
parameter levels would no longer need to obtain state permission to assume a
reduced monitoring schedule. These systems include all large systems (except
"b3" systems) and small and medium systems that continue to exceed either action
level after installing treatment. It also assumes that all systems that install
treatment will meet their water quality parameter levels and would have required
1.0 hour to prepare and submit their request to the state. This translates into an
annual burden reduction of 923 hours (2,769 over three years).
Accelerated reduced lead and copper monitoring. Assuming that the proposed
modifications become effective in 1997, systems that completed their first two
rounds of monitoring on schedule and met the action levels wil! not benefit from
this change. In contrast, systems that have to install corrosion control treatment
because they exceed the lead and/or copper action levels will benefit by being able
to proceed to reduced monitoring sooner than scheduled. According to the model,
approximately 7,077 fewer lead and copper samples will be taken each year and
would have required 3.0 hours per lead and copper sample collection. The annual
reduction in burden is 21,231 hours per year (63,693 hours over three years).25
"Allplastic" systems waiver. EPA assumes that approximately 7,000 systems (or
an annual average of 538 systems) will qualify as a!! plastic systems and will be
EPA determined the number of certifications by multiplying the number of systems in each of the model's three
compliance pathways by the number of monitoring events they would perform during the 13 years remaining in
the LCR planning period.
The number of samples avoided each year (7,077) was derived by multiplying the average number of samples
collected (8.2 samples) by the number of systems affected (5,600) and by the number of rounds of monitoring
avoided (2). The total of 92,000 samples was divided by 13, the remaining years in the 18-year LCR planning
period.
34
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eligible for monitoring waivers. Systems will spend 1.0 hour preparing each
monitoring waiver request. Thus, systems will spend 538 hours per year applying
for the waivers. In addition, EPA estimates that these systems will collect 10,096
fewer samples each year and would have required 3.0 hours per lead and copper
sample collection. The corresponding annual reduction in burden for less frequent
monitoring is estimated to be 30,288 hours. The net reduction in burden
associated with the "all plastic" system provision is 29,750 hours per year (89,250
hours over three years).
Changes in Treatment or Source Water. EPA assumes that an average of 1,477
systems on reduced monitoring will report a change in treatment or source water
each year. Further, EPA estimates that systems will require 1.0 hour to report the
change to the state, resulting in an annual increase in burden of 1,477 hours (4,431
hours over three years). Although this modification allows systems to return to
standard monitoring if warranted, EPA expects few systems to significantly impact
the corrosivity of their water. Therefore, any associated increase in burden is
expected to be negligible.
The following proposed modifications to the LCR are not expected to have a quantifiable
effect on lead and copper tap water monitoring burdens:
"b2" systems. No cost impact is estimated for "b2" systems to continue
monitoring for lead and copper at the tap and water quality parameters after the
state designates optima! water quality control parameters because the original
model assumed that these systems would continue such monitoring.
"b3" systems. No cost impact is estimated for "b3" systems to meet copper action
levels or to conduct continued tap monitoring because the original model assumed
that these systems would meet both action levels and would perform the
monitoring originally intended by EPA, respectively.
Sample Site Justifications. No cost impact is estimated for systems that use
representative sites because they do not have enough Tier I, 2, or 3 sites to
complete their sampling pool because the original model assumed that all systems
would have sufficient sites meeting "Tier" definitions. No cost impact is estimated
for systems that will no longer be required to send letters to the state justifying the
use of non Tier 1 sites and/or fewer than 50 percent of the sites served by lead
service lines because the original model assumed these to be primarily one-time
costs and that have already been incurred prior to the commencement of initial
monitoring.
Non-first-draw samples. EPA assumes that 500 non-transient non-community
water systems in total will request state permission to use taps that cannot provide
35
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first-draw samples. EPA also assumes that the transaction cost to request this
flexibility will be offset by the cost to shut down operations to provide first-draw
samples.
Reduced tap -water monitoring sites. Sufficient information is not available to
determine precisely the number of states that will designate sampling sites or the
number of systems that will be affected. Of the 79,000 public water systems,
46,000 systems are assumed to be capable of reducing the number of sampling
sites used.26 EPA believes, however, that no more than 20 percent of these
systems would be affected by this proposed revision (i.e., about 9,200 systems).
The burden per system to review and respond to the state letter designating
sampling sites is assumed to be offset by the time the system would have spent
determining which sites to include in its reduced sampling pool. Therefore, no
change in burden is estimated.
Reduced monitoring for seasonal systems. No cost impact is estimated for
allowing seasonal non-transient noncommunity water systems that do not operate
during the months of June - September to conduct reduced monitoring during their
warmest months of operation because the original model assumed that these
systems would not need to make special arrangements to monitor on the schedule
required by the rule.
Sample invalidation. EPA estimates that less than 0.5 percent of systems each
monitoring period will seek to have samples invalidated. Systems are assumed to
require 1.0 hour to prepare the documentation to request sample invalidation,
resulting in a transaction cost of $15 for each request. In addition, some systems
may potentially avoid the cost associated with having to install corrosion control
treatment or resuming a standard monitoring schedule (once on reduced
monitoring). The magnitude of these avoided costs cannot be estimated because
the original models assumed that costs were incurred only for necessary
compliance reasons; however, EPA estimates that they will more than offset the
transaction costs associated with requesting sample invalidation.
Decrease holding time for acidified samples. No cost impact is estimated because
it is assumed that this changes will not have a measurable effect, although the
number of samples that laboratories can process in a day will increase.
Water Quality Parameter Monitoring. Two proposed modifications affect water
quality parameter monitoring. The first provision results in a quantifiable change in system
burden. The second has no quantifiable impact.
Note that there are about 33,000 systems serving fewer than 100 people that cannot reduce the number of
sampling sites used. These systems are required to sample only five sitesthe minimum required by the LCR.
36
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Bi-weekly entry point monitoring. The modification permitting ground water
systems to limit biweekly entry point monitoring to representative entry points is
expected to reduce water quality parameter monitoring costs for all large and
medium ground water systems. EPA estimates that these large systems will reduce
the number of samples by two-thirds and medium systems by one-half. EPA
assumes that these ground water systems will require 1.0 hour to request this
monitoring for an annual transaction burden of 387 hours. These systems in turn
are expected to realize a reduction in burden associated with sample collection, for
an annual average reduction in burden of 1,868 hours. The net annual reduction in
burden associated with this provision is 1,481 hours (4,443 over three years).
Accelerated reduced monitoring. Only large systems will benefit from accelerated
reduced water quality parameter monitoring, because small and medium systems
with very low lead and copper levels do not exceed the action levels and therefore,
are not required to perform water quality parameter monitoring. Further, "b3"
large systems would not benefit from this change because they are not required to
collect water quality parameters. The reduction in burden for large systems is not
significant enough to be quantified.
Source Water Lead and Copper Monitoring. As described in Section 3.0, two of the
proposed modifications affect source water monitoring. EPA projects that neither of the
modifications will have a quantifiable effect on public water system burdens and costs.
Reduced source water monitoring. The first modification permits a reduced
monitoring frequency for systems that exceed the lead or copper action level and
for which the state has not specified maximum permissible levels for lead and
copper in source water. The source water model included in the April 1991 RIA
and ICR, implicitly assumed that all systems conducting source water monitoring
would eventually be eligible for reduced monitoring. This implies that systems do
not wait for states to designate maximum permissible levels before reducing their
monitoring. Therefore, no decrease in public water system burden is estimated for
this modification.
Resampling triggers for composited samples. The second modification revises the
copper resampling trigger upward from 0.001 mg/1 to 0.160 mg/1. EPA anticipates
that monitoring burden will decrease somewhat due to the increase in the
resampling trigger, but cannot quantify the change.
EPA assumes that only systems that exceed the lead or copper action level are required to
conduct source water monitoring; however, EPA acknowledges that potential exceptions exist.
For example, large systems qualifying as "b3" systems will need to monitor source water even if
they do not exceed an action level. In addition, a system whose continued "b3" status is
uncertain. In both cases, EPA projects that the number of affected systems is not significant.
37
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Lead Service Line Replacement. EPA assumes that 1..500 systems in total (2 percent of
systems) or an annual average of 115 systems would have submitted claims of limited lead service
line ownership to the state. The systems is assumed to have required 8.0 hours to prepare each
claim, resulting in an annual average reduction in burden of 920 hours (2,760 over three years).
Public Education. Two of the four provisions which affect public education
requirements are expected to have quantifiable impacts as explained below.
Reporting Completion of Public Education
One of the proposed modifications would change the deadline for reporting to the state
compliance with public education requirements. Systems would be required to submit
information demonstrating compliance within 10 days after the end of the period in which public
education was required to be performed. Currently, systems do not have to submit this
information until December 31 of each year. This modification would impact community water
systems serving 500 or more persons that remain above the action level for more than one
monitoring period because these systems must perform some public education tasks on a semi-
annual basis for as long they exceed the lead action level.
EPA assumes that public water systems will require 10 minutes to prepare the letter/report
demonstrating compliance with public education requirements. To calculate the change in burden,
EPA estimated the number of additional reports that would be required by determining the
number of community water systems serving more than 500 persons that would remain above the
lead action level for more than one reporting period in the three-year life span of this ICR. EPA
then estimated the period of time these systems would remain above the lead action level by
identifying LCR activities (e.g., treatment) that would result in systems no longer exceeding the
lead action level.
Approximately 39,000 systems will be required to prepare additional letters demonstrating
compliance with public education requirements. Approximately 27,400 systems of these systems
(i.e., those which no longer exceed the lead action level after installing corrosion control
treatment) will make approximately one additional report during the life of this ICR.27 In
addition, another 11,600 of these systems will continue to exceed the action level and require
continuous public education. They will make approximately three additional reports during the
life of this ICR. The total additional annual burden for this task is estimated to be 2,278 hours per
year or 6,834 hours over three years. This burden estimate corresponds to an additional 13,670
reports per year.
In contrast to the other modifications, the burden change for these systems is averaged over three years. All of
these systems would complete their public education requirements by the end of the current ICR period.
38
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Systems Serving 500 or Fewer People
Approximately 19,000 community water systems, serving less than 500 people, were
estimated by the 1991 RIA model to be required to perform public education because of a lead
action level exceedance. The proposed modifications will allow these systems to reduce their
public education requirements each year. EPA assumes these systems would have required 2.0
hours to perform these activities and will realize an annual reduction in burden of 38,000 hours
(114,000 over three years).
Two other proposed provisions are not expected to have a quantifiable impact. The
modification which allows alternative public education language for some systems is optional and
therefore, is not expected to have a burden impact. The provision to allow flexibility in timing
and method of delivery for community water systems cannot be quantified because it is not
possible to estimate how many systems would benefit from this change.
6a(ii) Burden To States
EPA projects that the following modifications to the LCR will increase state burdens.
States will incur costs for:
Reviewing sampling plans for non-first draw samples;
Designating reduced tap water monitoring sites;
Reviewing requests for monitoring waivers for "all plastic" systems;
Reviewing changes in treatment or source water for systems on reduced
monitoring;
Reviewing documentation from ground water systems demonstrating entry points
are representative of water quality; and
Reviewing reports on completion of public education tasks.
Some of the provisions will result in a decrease in burden by eliminating the need for states
to:
Review certifications related to first-draw samples or customer-collected samples;
Review requests for reduced monitoring for systems meeting optimal water quality
parameters;
39
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Review as many rounds of lead and copper monitoring data for systems qualifying
for accelerated reduced monitoring and "all plastic" systems;
Review as many water quality parameter entry point monitoring results for large
and medium ground water systems;
Respond to systems' claims of limited lead service line ownership; and
Report as many data elements to the Safe Drinking Water Information System.
EPA also expects that two provisions: 1.) sample invalidation and, 2.) the elimination of a
system's justification of its sampling pool if it contains non-Tier 1 sites and/or samples from fewer
than 50 percent lead service lines, will have no appreciable impact on burden. First, EPA assumes
that state will review requests for sample invalidation for less than 0.5 percent of systems each
monitoring period and that each review will require 0.5 hours. Second, EPA assumes that states
would have reviewed sampling pool justifications prior to the commencement of initial monitoring
and would only need to review these justifications for some of the systems that cannot gain entry
to the same sampling locations for subsequent monitoring periods.
No impact related to overhead activities for reading the revised regulation, and planning
and review are calculated for the state because the models for the current LCR built in burden and
costs for states to periodically update their regulations.
The net result of the modifications with be an overall decrease in annual state burden of
about 10,023 hours per year (30,069 hours over three years). Figure 6-2 summarizes the changes
in state burdens.
Monitoring
Non-transient non-community water system sampling sites. EPA estimates that
approximately 500 non-transient non-community water systems in total will
request state permission to use non-first draw samples. States will require six
hours per year (18 hours over three years) to review these systems requests which
include a sampling plan. Review of each request will take about 10 minutes.
Certifications forfirst-draw/customer-collected samples. The Agency estimates
that states will no longer need to review 41,170 certifications per year and that
states would have required 10 minutes to review each certification. The total
annual reduction in burden is estimated to be 6,862 hours (20,586 over three
years).
40
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Figure 6-2
Proposed Revisions to LCR
Annual State Burden
(Hours/Year)
Collection Activity
Responses
Burden Hours
Per Response
Total Burden
Hours
States as Reviewers of Data
Tap and WQP Monitoring
Non-transient noncommunity water
system sampling sites
Certifications for first-draw samples
Approval for reduced monitoring
Accelerated reduced monitoring
Reduced tap monitoring sites
Waivers for "all plastic" systems
Changes in treatment/source water
Entry point water quality parameter
monitoring
Report completion of public education
RebuOable presumption of lead ownership
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.2
0.2
1.0
1.0
0.5
0.7
0.2
0.5
0.2
4.0
States as Respondents
Compliance reporting
TOTAL:
NC2"
NC
01.7)
6
(6,862)
(923)
(862)
354
(1,346)
222
193
2,278
(462)
(2,615)
(10,023)
Approval for reduced monitoring. EPA estimates that an average of 923 systems
each year would meet their state-specified water quality parameter levels would no
longer need to obtain state permission to assume a reduced monitoring schedule 29
It is also assumed that states would have required 1.0 hour to review each request.
This translates into an annual burden reduction of 923 hours (2,769 over three
years).
28 No change in responses from baseline of 224 responses. Responses - 4 quarterly reports x 56 States and
Territories.
29 These systems include all large systems (except "b3" systems) and small and medium systems that continue to
exceed either action level after installing treatment.
41
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Accelerated reduced monitoring. Systems that were required to install corrosion
control treatment because they exceed the lead and/or copper action levels are
expected to benefit by being able to proceed to reduced monitoring sooner than
scheduled. States are expected to review 862 fewer rounds of lead and copper
monitoring each year for these systems and that this review would have required
1.0 hour per round. The annual reduction in state burden associated with this
provision is 862 hours per year (2,586 hours over three years).30
Reduced tap water monitoring sites. EPA assumes that states will designate
sampling sites for about 9,200 systems in total (i e., about 20% of the 46,000
systems serving > 100 people). The burden to designate sites for each system is
about 0.5 hours. Thus, the annual burden increase to states is estimated to be 354
hours (1,062 hours over three years).
Monitoring waivers for "all plastic" systems. States will spend 0.5 hours
reviewing each request for a monitoring waiver. A total of 7,000 systems or an
average of 538 systems per year are expected to submit a request, for an annual
burden of 269 hours. States are also expected to review 21,000 fewer rounds of
monitoring in total (or an annual average of 1,615 rounds) which would have
required 1.0 hour per review. This translates to an annual reduction in burden of
1,615 hours. The net reduction in burden is 1,346 hours (4,038 hours over three
years).
Changes in treatment/source water. A total of 17,316 systems or an annual
average of 1,332 systems are expected to report a change in treatment or source
water to the state. The state is assumed to require an average of 10 minutes to
review each submission. The annual increase in state burden is estimated to be 222
hours per year (666 hours over three years).
Entry point water quality parameter monitoring. EPA assumes that all large and
medium ground water systems (i.e., a total of 387 systems) will submit requests to
the state to limit entry point water quality parameter monitoring to representative
sites. The state is assumed to require 0.5 hours to review the documentation
associated with each request. The annual increase in state transaction burden for
this review is 193 hours (579 hours over three years). The Agency does not
expect an appreciable reduction in the time saved for the state to review the results
of fewer monitoring locations because it assumes that the state would only require
a small incremental increase in time to review data from each additional monitoring
location. Therefore, no reduction in state burden is estimated.
The annual number of rounds of monitoring data (862) was derived by multiplying the number of systems
affected (5,600) by the number of rounds avoided (2), and dividing by 13 (the number of years remaining in the
LCR planning period).
42
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Reporting Completion of Public Education
One of the proposed changes would affect the deadline for reporting to the state
compliance with public education requirements. For community water systems serving 500 or
more persons that remain above the lead action level for two monitoring periods in a calendar
year, states would be required to review an additional letter/report prepared by the system.
Currently, states review such reports only once at the end of the calendar year.
EPA assumes that the state will require 10 minutes to review the letter/report submitted by
the system demonstrating compliance with public education requirements. Consequently, the total
additional annual burden for this task is estimated to be 2,278 hours (6,834 hours over three
years); this burden estimate corresponds to an additional 13,670 reports per year.
The other three modifications to the public education requirements: alterative public
education language, flexibility in timing/delivery, and reduction in public education requirements
for small community water systems are not expected to impact state burden,
Removal ofRebuttable Presumption of Control
EPA assumes that 1,500 systems in total (2 percent of systems) would have rebutted the
presumption that they control the entire length of the service line. The state is assumed to have
required 4.0 hours to address each system's claim, resulting in an annual average reduction in
burden of 462 hours (1,386 over three years).
Modifications to State Reporting Requirements
EPA examined each reporting requirement currently contained in § 142.15 and the
proposed modifications to these requirements. First, for the 13-years remaining in the LCR
planning period, the total number of data records reported for each-milestone was identified both
for the current requirements and for the modified requirements. This task involved determining if
the milestone was a one-time or recurring event. The number of data records associated with
violations and enforcement actions was estimated and added to the total number of milestone
records.31 The resulting overall record totals for the current and modified requirements were
estimated to be 0.68 and 0.61 million, respectively. This corresponds to an annual decrease in the
number of records reported each year from about 52,200 to 47,000.
The unit burden for reporting each violation, enforcement action, or milestone record is
estimated to be approximately 0.5 hours. Reporting includes the following activities: data entry,
EPA assumed that each year, violation or enforcement action data would be reported for approximately 2.1
percent of samples submitted annually. EPA calculated that the number of samples submitted would decrease
by 6 percent as a result of the modifications to the LCR. Thus, violation/enforcement data would decrease
proportionately.
43
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quality review of entered data, and transferring the records to EPA. Given these assumptions, the
total burden hours should decrease by approximately 2,615 per year (7,845 over three years).
6b Estimating Respondent Costs
6b(i) Costs To Public Water Systems
EPA estimates that the annual cost to public water systems for recordkeeping and
reporting for these modifications will decrease by approximately $1,573,700 ($4,721,100 over
three years). EPA estimates that contracted services32 constitute approximately $515,200 of the
$1,573,700 decrease in costs. The savings that public water systems will experience is equal to
the change in burden for senior and junior staff times their hourly labor rates.
The cost estimate is based on the following assumptions:
Hourly labor rates (including overhead) are assumed to be $40 for senior staff and
$ 15 for junior staff;33 and
Estimates of analytical costs are based on current industry prices. For example,
analysis of lead and copper tap samples is estimated to cost $30 per sample.
Note that for purposes of calculating the change in public water system costs, EPA has
revised its estimate of the labor rate for junior staff from $10 to $15 per hour from the rate used
in the previous ICR.34 Public water system costs would have decreased by $1,098,700 if the labor
rate had not changed. The costs to public water systems are summarized in Figure 6-3.
6b(ii) Costs to States
The cost that states will incur as a result of the proposed modifications is equal to the
incremental burden for state staff times the average hourly labor rate. EPA estimates that the
annual cost to states for recordkeeping and reporting under the modified LCR will decrease by
approximately $311,300 ($933,900 over three years). Figure 6-4 presents the state costs.
EPA assumes that water systems will utilized contracted services to obtain sample analyses. The estimate of
contracted services is based on approximately 17,173 fewer samples requiring analysis at a cost of $30 per
sample.
These labor rates are consistent with the Information Collection Request for the 1995 Drinking Water Needs
Survey, OMB No. 2040-0176.
EPA did not adjust the estimate of current costs to public water systems.
44
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Figure 6-3
Proposed Revisions to LCR
Annual Svstem Cost
Collection Activity
Responses
Cost per Response
Total
Burden Cost
Ongoing Activities
Plan and review
NA
NA
$400
Monitoring
Certifications for first-draw samples
Approval for reduced monitoring
Accelerated reduced monitoring
Waivers for "all plastic" systems
Changes in treatment/source water
Entry point water quality parameter
monitoring
Rebuttable presumption of lead ownership
(41,170)
(923)
(7,077)
(9,557)
1,477
(2,961)
(115)
$3
$15
$50
$52
$15
$25
$120
($102,900)
($13,800)
($353,800)
($496,700)
$19,900
($77,200)
($13,800)
Public education
Reporting completion of public education
Systems serving 500 or fewer people
TOTAL
13,670
(19,000)
(65,656)
$3
$30
$34,200
($570,000)
($1^73,700)
Note that for purposes of calculating the change in state costs, EPA revised its estimate of the
hourly labor rate (including benefits) for state staff from $26.04 to $31.09 per hour.
Consequently, approximately $50,600 of the $311,300 change in state costs, is attributable to the
higher labor rate.
45
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Figure 6-4
Proposed Revisions to LCR
Annual State Cost
Collection Activity
Responses
Cost per
Response
Total Burden
Cost
State* as Reviewers of Data
Tap and WQP Monitoring
NTNCWS sampling sites
Certifications for first-draw samples
Approval for reduced monitoring
Accelerated reduced monitoring
Reduced tap monitoring sites
Waivers for "all plastic" systems
Changes in treatment/source water
Entry point water quality parameter
monitoring
Report completion of public education
Rebuttable presumption of lead ownership
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
$200
($213,300)
($28,700)
($26,800)
$11,000
($41,800)
$6,900
$6,000
$70,800
($14,300)
States as Respondents
Compliance reporting
TOTAL:
NC"
-
($362.95)
($81,300)
(S31UOP)
6c Estimating Agency Burden And Cost
EPA Headquarters and Regional offices incur burdens and costs to process, analyze, and
maintain Safe Drinking Water Information System data. These costs are presented in detail in the
Public Water System Supervision Program ICR dated December 1993. Headquarters personnel
who design and administer the Safe Drinking Water Information System believe that the net
additional cost to EPA of the proposed LCR revisions is not significant.
" No change in responses from baseline of 224 responses.
46
-------
6d Bottom Line Burden Hours And Costs
As mentioned above, the additional Agency burden and cost for implementing the
modified LCR is not significant. Hence, the Agency burden and cost estimates are not included.
National total annual burden and cost estimates for the LCR are presented in Figure 6-5. The
average system and state burden per response is 1.6 hours and the cost per response is $28.71,
Figure 6-5
Total Annual Burdens and Costs
Respondent
Public Water System
State
TOTAL
Number of
Respondents
78,703
56
78,759
Total
Responses
(65,656)
NC
(65,656)
Total Burden
(94,979)
(10,023)
(105,002)
Burden per Response
Cost per Response
Total Cost
($1,573,700)
($311,300)
($1385,000)
(1.6)
(S28.71)
6e Reasons For Change In Burden
EPA estimates that proposed modifications to the LCR will change burden and cost
estimates for the following information collection activities: read regulations, plan and review,
and monitoring. The change in the reporting deadline for public education tasks will increase the
burden for this activity, which was not quantified in the 1991 ICR. Sections 6a and 6b above
discuss the change in burden associated with each modification to the LCR.
6f
Burden Statement
Burden Statement: The average annual reporting burden for a state government that has
primacy for the Public Water System Supervision program is estimated to decrease by 46.7 hours
as a result of these modifications to the LCR. The estimate includes time required to review
instructions, search existing data sources that gather and maintain the needed data, estimate the
information required, and complete and review the collection of information. The burden for
reviewing system data is estimated to decrease by 132.3 hours per state. Thus, EPA estimates
that total state paperwork burden will decrease by 179 hours per state.
The reporting burden for a water system affected by these modifications is estimated to
decrease by 72 minutes per system. The estimate includes time required to review instructions,
search existing data sources that gather and maintain the needed data, estimate the information
required, and complete and review the collection of information.
47
-------
This information collection is necessary to evaluate system-specific needs, including
examining treatment effectiveness; to adjust monitoring frequencies and schedules to address
possible public health concerns; and to determine whether the public is receiving timely
notification of possible health risks associated with high levels of lead at the tap. The proposal
includes requirements for states to report to EPA the ninetieth percentile lead values for large and
medium-size systems that do not exceed the lead action level and dates associated with two of the
treatment technique milestones about which states are required to report. This information will be
used to develop national compliance trends and to help evaluate whether changes in national
policy or regulations are necessary to protect public health. The information collection in this
proposed rule is mandatory, is authorized under sections 1401(1 )(D), 1413(a)(3) and 1445 of the
1986 Amendments to the Safe Drinking Water Act and is considered public information. The
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.
Respondents: Any state which has primacy for the Public Water System Supervision
program and all community and non-transient non-community water systems.
Estimated Number of Respondents: 78,759 (56 States and 78,703 public water
systems).
Frequency of Collection: Quarterly for States; as required (e.g., one-time, every six
months, annually, triennially, every nine years) to demonstrate compliance with monitoring and
treatment requirements for public water systems.
Estimated Total Incremental Annual Burden on Respondents: -105,002 hours
Send comments regarding the burden estimate or any other aspects of this collection of
information, including suggestions for reducing this burden to: Director, Regulatory Information
Division, MC-2137, U.S. Environmental Protection Agency, 401 M S-treet, SW, Washington, DC
20460; and to the Office of Information and Regulatory Affairs, Office of Management and
Budget, Washington, DC 20503.
48
-------
APPENDIX
Figure A- 1
Change to Publk Water System (PWS) Annual Burden and Costs for LCR
Collection Activities
Baseline
Proposed Modifications
Revised Baseline
Burden Hours
Per PWS
34.9
-1.2
33.7
Total
2,764,235
- 94,979
2,669,256
Costs
Per PWS
$601
-520
$581
Total
$47,369,584
-$1,573,700
$45,795,884
Responses
Per PWS
13.6
-0.8
12.8
Total
1,066,672
- 65,656
1,001,016
Figure A-2
Change to State Annual Burden and Costs for LCR
Collection Activities
Baseline
Proposed Modifications
Revised Baseline
Burden Hours
Per State
25,373
-179
25,194
Total
1,420,907
- 10,023
1,410,884
Costs
Per State
$771,429
- $5,559
$765,870
Total
$43,200,000
-$311,300
$42,888,700
Responses
Per State
4
0
4
Total
224
0
224
49
-------
1 s
IE
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NOTES/ASSUMPTIONS
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impacts estimated because original model II
umed "(bX2)" systems would perform the
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umes system transaclion burden of 8 hours
state transaction burden of 4 hours.
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PROPOSED REV
Burden associated with lead public education
not included in the 1991 ICR, but has since
been estimated as part of the 3rd Party
Notification ICR.
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to benefit from this change.
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CWSs
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reduction.
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and utilize alternatives to Pi
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assumed systems would have a sufficient
number of sites meeting "Tier" definitions.
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few Tier 1,2, and 3 sites
,
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Assumes 500 NTNCWSs in total would
request state permission to use non-ftrst-draw
samples.
Assumes NTNCWS transaction cost to rcque:
this llexibility will be offset by cost to shut
down operations to provide first-draw sample;
Assumes 10 minutes for state transaction
burden.
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total would no longer need to obtain state
permission to assume a reduced monitorin
schedule; this number includes non-(bX3)
large systems and small and medium syste
that continue lo exceed either action level .
they install treatment.
Assumes all systems (hat install treatment
meet their WQPs.
Assumes 1 hour for both system and state
transactions.
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Assumes systems will be able to eliminate
approximately 7,077 lead and copper samj
per year. Assumes states would no longer
required lo review 862 rounds of monilori
per year which would have required
1 hour per review.
Model is not sufTicienlly precise lo estimat
PWS or state cost savings for those large
systems that qualify for accelerated WQP
monitoring.
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special arraniteineiits to monitor.
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Assumes approximately 7,000 systems in total
will be able to qualify for an "all plastic"
system waiver. This results in $504,800 in
monitoring cost savings for systems.
Assumes states would no longer need to
review 2 1 ,000 rounds of monitoring in total
which would have required 1 hour per review.
Assumes 1 hour for system and 0.5 hours for
slate transaction burdens; this results in a
$8,100 cost increase for systems and a $8,370
increase for states.
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must be sampled will be reduced by 2/3 for
large systems, 1/2 for medium systems, and
not at all for small systems. This results in a
£83,000 cost savings for systems.
Assumes I hour for system and 0.5 hours for
stale transaction burdens; this results in a
$5,800 cost increase for systems and a $6,000
cost increase for states.
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model did not estimate how many systems
would be required to resample because they
exceeded the lead or copper trigger level.
However, some systems may realize a cost
savings due to increase in the copper
resampling trigger.
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model assumed all systems conducting sourc
water monitoring would be eligible for reduc
monitoring.
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Assumes both systems and stales will avoid
approximately 535,200 certifications in total
(or about 4 1 , 1 70 per year).
Assumes 10 minute transaction burden for
systems and states.
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Assumes 10 minutes transaction burden for
systems and stales.
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Assumes 55,600 fewer records in total (or
4^277 per year) will be reported.
Assumes 0.5 hours reporting burden per
record.
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a.
Assumes 6% decrease in the amount of
violation and enforcement data states must
report to EPA (i.e., 12,400 records in total or
954 per year). This percentage decrease is
proportional to the expected decrease in
monitoring data associated with the LCR
revisions.
oq
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£
oc
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u
No impacts estimated for suites because
occasional rule changes were included in the
original model estimates.
Assumes that 20% of systems will incur a on
time O.S percent increase from the annual
baseline estimate included in the 1991 ICR.
Systems are expected to incur an annual cost
of < $100 lo read the regulations, which is
expressed as 0.0 in this table.
o
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o
o
o
vt
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