SEPA
United States
Environmental Protection
Agency
Economic Analysis Appendices for the Final Lead and
Copper Rule Improvements
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Office of Water (4606M)
EPA 810-R-24-005
October 2024
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Table of Contents
Appendix A : Service Line Replacement Unit Costs A-l
A.l Introduction A-l
A.2 DWINSA Lead Service Line Replacement Unit Costs A-l
A.3 Additional Service Line Replacement Cost Data A-4
A.3.1 CDM Smith Report and Related AWWA Comments A-5
A.3.2 Safe Water Engineering Report A-9
A.3.2.1 Independent Literature Review A-9
A.3.2.2 RS Means Construction Cost Estimates A-10
A.3.2.3 Safe Water Engineering Report Conclusions A-12
A.4 References A-13
Appendix B : Modeling Costs in the SafeWater LCR Model for the Final LCRI, 2021 LCRR, and the Pre-
2021 LCR B-l
B.l Introduction B-l
B.2 Baseline Conditions and Modeling Assumptions for the Final LCRI, 2021 LCRR, and Pre-2021
LCR B-2
B.2.1 Model-PWSs B-2
B.2.2 Model PWS 90th Percentile Tap Sample-Range B-4
B.2.3 Very Large Systems B-5
B.2.4 Analysis Period and Discount Rates B-7
B.3 Estimating Compliance Activity under the Final LCRI B-8
B.3.1 Change in Source Water or Treatment Technology B-10
B.3.2 Small CWS and NTNCWS flexibility B-12
B.3.3 Corrosion Control and Point-Of-Use Technology B-12
B.3.4 Replacements of Lead Content Service Lines B-15
B.3.5 Distribution System and Site Assessments (DSSA) B-16
B.4 Estimating Compliance Activity Under the 2021 LCRR B-20
B.4.1 Small CWS and NTNCWS Flexibility B-20
B.4.2 Corrosion Control and Point-of-Use Technology B-21
B.4.3 Replacements of Lead Content Service Line under the 2021 LCRR B-24
B.4.4 Distribution System and Site Assessment (Find and Fix under the LCRR) B-26
B.5 Detailed Public Water System Costing Approach for the 2021 LCRR B-30
B.5.1 PWS Implementation and Administrative Costs under the 2021 LCRR B-36
B.5.2 PWS Sampling Costs under the 2021 LCRR B-38
B.5.2.1 PWS Lead Tap Sampling under the 2021 LCRR B-38
B.5.2.2 PWS Lead Water Quality Parameter Monitoring under the 2021 LCRR B-56
B.5.2.3 PWS Copper Water Quality Parameter Monitoring under the 2021 LCRR B-71
B.5.2.4 PWS Source Water Monitoring under the 2021 LCRR B-78
B.5.2.5 CWS School and Child Care Lead Sampling Costs under the 2021 LCRR B-80
B.5.3 PWS Corrosion Control Costs under the 2021 LCRR B-91
B.5.3.1 CCT Installation B-91
B.5.3.2 Re-optimization of Existing Corrosion Control Treatment B-93
B.5.3.3 Find-and-Fix Costs B-94
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B.5.3.4 System Lead CCT Routine Costs B-103
B.5.4 PWS Lead Service Line Inventory and Replacement Costs under the 2021 LCRR B-104
B.5.4.1 Service Line Inventory-Related Activities B-105
B.5.4.2 Service Line Replacement Plan B-107
B.5.4.3 Physical Service Line Replacements B-110
B.5.4.4 Ancillary Service Line Replacement Activities B-113
B.5.4.5 Goal-Based Replacement Program Activities B-116
B.5.5 PWS POU-Related Costs under the 2021 LCRR B-125
B.5.5.1 POU Device Installation and Maintenance B-126
B.5.5.2 POU Ancillary Activities B-126
B.5.6 PWS Lead Public Education, Outreach, and Notification Costs under the 2021 LCRR ..B-130
B.5.6.1 Consumer Notice B-130
B.5.6.2 Activities Regardless of Lead 90th Percentile Level B-131
B.5.6.3 Activities in Response to Lead ALE B-137
B.6 Detailed State Costing Approach for the 2021 LCRR B-139
B.6.1 State Implementation and Administrative Costs under the 2021 LCRR B-143
B.6.1.1 State Start-up Implementation and Administrative Activities B-143
B.6.1.2 State Annual Implementation and Administrative Activities B-145
B.6.2 State Sampling Related Costs under the 2021 LCRR B-147
B.6.2.1 State Lead Tap Sampling Costs under the 2021 LCRR B-147
B.6.2.2 State Lead WQP Sampling Costs under the 2021 LCRR B-154
B.6.2.3 State Copper WQP Monitoring Costs under the 2021 LCRR B-155
B.6.2.4 State Source Water Monitoring Costs under the 2021 LCRR B-157
B.6.2.5 State School Sampling Costs under the 2021 LCRR B-158
B.6.3 State CCT Related Costs under the 2021 LCRR B-160
B.6.3.1 State CCT Installation Costs under the 2021 LCRR B-160
B.6.3.2 State CCT Re-optimization Costs under the 2021 LCRR B-161
B.6.3.3 State Find-and-Fix Costs under the 2021 LCRR B-162
B.6.3.4 State Lead CCT Routine Costs under the 2021 LCRR B-163
B.6.4 State Service Line Inventory and Replacement Related Costs under the 2021 LCRR....B-165
B.6.4.1 SL Inventory Costs B-165
B.6.4.2 SLR Plan Review Costs B-166
B.6.4.3 SLR Report Review Costs B-168
B.6.4.4 Goal-Based Replacement Program Activities B-168
B.6.5 State POU Related Costs under the 2021 LCRR B-171
B.6.5.1 One-Time POU Program Costs B-171
B.6.5.2 Ongoing POU Program Costs B-172
B.6.6 State Lead Public Education, Outreach, and Notification Costs under the 2021 LCRR .B-173
B.6.6.1 Consumer Notice B-174
B.6.6.2 Activities Regardless of the Lead 90th Percentile Level B-174
B.6.6.3 Public Education Activities in Response to Lead ALE under the 2021 LCRR B-175
B,7 Estimating Compliance Activity Under the Pre-2021 LCR B-178
B.7.1 Corrosion Control Technology B-178
B.7.2 Replacement of Lead Content Service Lines B-181
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B.8 Detailed Public Water System Costing Approach for the Pre-2021 LCR B-184
B.8.1 PWS Sampling Costs B-190
B.8.1.1 PWS Lead Tap Sampling B-190
B.8.1.2 PWS Lead Water Quality Parameter Monitoring B-208
B.8.1.3 PWS Copper Water Quality Parameter Monitoring B-215
B.8.1.4 PWS Source Water Monitoring B-216
B.8.2 PWS Corrosion Control Costs B-221
B.8.2.1 CCT Installation B-221
B.8.2.2 Re-optimization of Existing Corrosion Control Treatment B-224
B.8.2.3 Lead CCT Routine Costs B-226
B.8.2.4 CCT Activities Unique to the Pre-2021 LCR B-228
B.8.3 PWS Lead Service Line Replacement-Related Costs B-229
B.8.3.1 Lead Service Line Replacements B-229
B.8.3.2 Ancillary Lead Service Line Replacement Activities B-234
B.8.3.3 Ancillary Service Line Replacement Activities Unique to the Pre-2021 LCR B-240
B.8.4 PWS Lead Public Education, Outreach, and Notification Costs under the Pre-2021 LCR....B-
245
B.9 Detailed State Costing Approach for the Pre-2021 LCR B-249
B.9.1 State Administrative Costs under the Pre-2021 LCR B-252
B.9.2 State Sampling Related Costs under the Pre-2021 LCR B-255
B.9.2.1 State Lead Tap Sampling Costs B-255
B.9.2.2 State Lead WQP Sampling Costs B-259
B.9.2.3 State Copper WQP Monitoring Costs B-260
B.9.2.4 State Source Water Monitoring Costs B-260
B.9.3 State CCT-Related Costs under the Pre-2021 LCR B-262
B.9.3.1 State CCT Installation Costs B-262
B.9.3.2 State CCT Re-optimization Costs B-263
B.9.3.3 State Lead CCT Routine Costs B-264
B.9.3.4 State CCT Activities Unique to the Pre-2021 LCR B-266
B.9.4 State Lead Service Line Testing and Replacement under the Pre-2021 LCR B-269
B.9.5 State Lead Public Education and Outreach under the Pre-2021 LCR B-270
B.10 References B-272
Appendix C : Costs and Benefits of the Final LCRI as Compared to the pre-2021 LCR C-l
C.l Introduction C-l
C.2 National Costs and Benefits with pre-2021 LCR Baseline C-l
C.3 References C-4
Appendix D : Adverse Health Effects Associated with Lead Exposures D-l
D.l Cardiovascular Effects D-2
D.l.l Blood Pressure and Hypertension D-3
D.1.1.1 Adults D-3
D.l.l.2 Children D-3
D.1,2 Electrocardiogram Abnormalities D-4
D.1.2.1 Adults D-4
D.l.2.2 Children D-4
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D.1.3 Clinical Cardiovascular Conditions D-5
D.1,4 Cardiovascular Mortality D-5
D.2 Renal Effects D-7
D.2.1 Adults D-7
D.2.2 Children D-8
D.3 Reproductive and Developmental Effects D-9
D.3.1 Delayed Puberty D-9
D.3.2 Postnatal Growth D-9
D.3.3 Sperm Parameters D-10
D.3.4 Fertility and Time to Conception D-ll
D.3.5 Spontaneous Abortions D-ll
D.3.6 Reduced Fetal Growth/Low Birth Weight D-12
D.3.7 Preterm Birth and Gestational Age D-13
D.4 Immune Effects D-13
D.5 Increased Hypersensitivity and Allergy Response D-14
D.5.1 Adults D-14
D.5.2 Children D-14
D.6 Resistance to Bacterial Infection D-15
D.6.1 Adults D-15
D.6.2 Children D-15
D.7 Neurological Effects D-15
D.7.1 Cognitive Function D-15
D.7.1.1 Adults D-16
D.7.1.2 Children: IQ D-16
D.7.1.3 Children: Academic Achievement D-18
D.7.2 Attention-Related Behavior D-20
D.7.3 Conduct Disorders D-22
D.7.4 Internalizing Behaviors D-23
D.7.5 Psychological Effects D-24
D.7.6 Neurodegeneration D-24
D.7.7 Auditory Function D-25
D.7.7.1 Adults D-25
D.7.7.2 Children D-26
D.7.8 Motor Function D-26
D.8 Cancer D-27
D.9 References D-28
Appendix E : Adverse Health Effects Associated with Copper Exposures E-l
E.l Acute Gastrointestinal Distress E-l
E.2 Chronic Liver Toxicity E-2
E.2.1 Wilson's Disease E-2
E.2.2 Infants and Children with Genetic Susceptibilities E-3
E.3 References E-4
Appendix F : Sensitivity Analysis for IQValuation in Children and Costs and Benefits of the Final Rule at a
3 Percent and 7 Percent Discount Rate F-l
Final LCRI Economic Analysis Appendices iv October 2024
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F.l Sensitivity Analysis for the Value of an IQ point F-l
F.2 Valuation of Avoided IQ Loss and Avoided Case of ADHD at 3 Percent and 7 Percent Discount
Rates F-3
F.3 Final Rule Costs at a 3 Percent and 7 Percent Discount Rate F-3
F.4 Final Rule Benefits at a 3 Percent and 7 Percent Discount Rate F-6
F.5 Comparison of Costs to Benefits and a 3 Percent and 7 Percent Discount Rate F-7
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List of Exhibits
Exhibit A-l: Summary of LSLR Costs Using Data from the 7th DWINSA ($/SLR, 2020$)1,2 A-4
Exhibit A-2: Summary of LSLR Costs from CDM Smith Report ($/LSLR, 2020$) A-6
Exhibit A-3: Summary of Literature Review Results from Safe Water Engineering Report ($/LSLR, 2020$)
A-10
Exhibit A-4: Summary of LSLR Scenario Costs from Safe Water Engineering Report ($/LSLR, 2020$)... A-12
Exhibit B-l: Select Baseline Characteristics Assigned from Distributional Information to Model-PWSs ..B-3
Exhibit B-2: Summary of AWWA Data for PWS Systems Serving more than 1M People B-6
Exhibit B-3: Weighted Average Cost of Capital by PWS Ownership and Size Category B-7
Exhibit B-4: Simulating Change in Source Water or Treatment Technology in SafeWater LCR B-ll
Exhibit B-5: Simulating Corrosion Control and Point-of-Use Technology under Final LCRI in SafeWater LCR
B-14
Exhibit B-6: Simulating Lead Service Line Replacements under Final LCRI in SafeWater LCR B-16
Exhibit B-7: Likelihood That a Single Tap Water Sample Will be in Each of the Five Bins Used for
Modelling Purposes under the Final LCRI B-17
Exhibit B-8: Simulating DSSA Requirements under the final LCRI in SafeWater LCR B-19
Exhibit B-9: Simulating Corrosion Control and Point-of-Use Technology under the 2021 LCRR in
SafeWater LCR B-23
Exhibit B-10: Simulating Lead Service Line Replacements under the 2021 LCRR B-26
Exhibit B-ll: Likelihood that a Single Tap Water Sample Will be in Each of the Five Bins Used for
Modelling Purposes under the 2021 LCRR B-27
Exhibit B-12: Simulating Distribution System Assessment Costs under the 2021 LCRR in SafeWater....B-29
Exhibit B-13: PWS Cost Components, Subcomponents, and Activities Organized by Section for the 2021
LCRR1 B-30
Exhibit B-14: PWS One-Time Administration Activities and Unit Burden Estimates under the 2021 LCRR B-
37
Exhibit B-15: PWS Administration and Rule Implementation Cost Estimation in SafeWater LCR by Activity
for the 2021 LCRR B-37
Exhibit B-16: PWS Lead Tap Sampling Unit Burden and Cost Estimates under the 2021 LCRR B-40
Exhibit B-17: PWS Lead Tap Sampling Cost Estimation in SafeWater LCR by Activity under 2021 LCRR1,2.B-
43
Exhibit B-18: PWS Lead WQP Monitoring Unit Burden and Cost Estimates under the 2021 LCRR B-59
Exhibit B-19: PWS Lead WQP Monitoring Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1 B-62
Exhibit B-20: PWS Copper WQP Monitoring Unit Burden and Cost Estimates under the 2021 LCRR B-72
Exhibit B-21: PWS Copper WQP Monitoring Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1 B-73
Exhibit B-22: PWS Source Monitoring Burden and Cost Estimates under the 2021 LCRR B-79
Exhibit B-23: PWS Source Water Monitoring Cost Estimation in SafeWater LCR by Activity under the
2021 LCRR1 B-80
Exhibit B-24: CWS School and Child Care Facility Sampling Unit Burden and Cost Estimates for the First
Five-Year Testing Cycle Phase under the 2021 LCRR B-81
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Exhibit B-25: CWS School and Child Care Facility First Five-Year Testing Cycle Cost Estimation in
SafeWater LCR by Activity under the 2021 LCRR1 B-84
Exhibit B-26: CWS School and Child Care Facility Sampling Unit Burden and Cost Estimates under the
Second and Subsequent Five-Year Testing Cycles under the 2021 LCRR B-86
Exhibit B-27: PWS Second Five-Year Testing Cycle On School and Child Care Facility Sampling Phase Cost
Estimation in SafeWater LCR by Activity under the 2021 LCRR1 B-89
Exhibit B-28: PWS CCT Installation-Related Unit Burden and Cost Estimates under the 2021 LCRR B-92
Exhibit B-29: PWS Ancillary CCT Installation Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1 B-92
Exhibit B-30: PWS CCT Ancillary Re-optimization Unit Burden and Cost Estimates under the 2021 LCRR.B-
93
Exhibit B-31: PWS CCT Ancillary Re-optimization Cost Estimation in SafeWater LCR by Activity under the
2021 LCRR B-94
Exhibit B-32: PWS Ancillary Find-and-Fix Unit Burden and Cost Estimates under the 2021 LCRR1 B-95
Exhibit B-33: PWS Ancillary Find-and-Fix Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR12 B-98
Exhibit B-34: PWS CCT Routine Unit Burden and Cost Estimates under the 2021 LCRR B-103
Exhibit B-35: PWS Lead CCT Routine Cost Estimation in SafeWater LCR by Activity under the 2021 LCRR1
B-104
Exhibit B-36: PWS LSL Inventory-Related Unit Burden and Cost Estimates under the 2021 LCRR B-106
Exhibit B-37: Lead Service Line Inventory Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR B-107
Exhibit B-38: PWS Service Line Replacement Plan Unit Burden and Cost Estimates under the 2021 LCRRB-
108
Exhibit B-39: Estimated Burden for Systems to Develop a SLR Plan under the 2021 LCRR B-109
Exhibit B-40: SLR Plan Cost Estimation in SafeWater LCR by Activity under the 2021 LCRR B-109
Exhibit B-41: Unit Costs for Service Line Replacement under the 2021 LCRR B-110
Exhibit B-42: Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity under the
2021 LCRR B-112
Exhibit B-43: PWS Unit Burden and Cost Estimates B-113
Exhibit B-44: Lead Service Line Inventory Ancillary Cost Estimation in SafeWater LCR by Activity under
the 2021 LCRR1 B-114
Exhibit B-45: Unit Burden and Cost Estimates for Goal-Based Replacement Program Activities under the
2021 LCRR B-117
Exhibit B-46: Estimated Annual Burden (per household) to Distribute Targeted Outreach Materials about
SLR Program for CWSs with Known or Potential Lead Content Serving > 10,000 people with a TLE
(hrs_dist_lslr_out_op) B-119
Exhibit B-47: Unit Burden and Cost to Conduct Outreach in Response to First Failure to Meet SLR Goal
(hrs/household/year) B-121
Exhibit B-48: Burden to Conduct Additional Outreach in Response to Subsequent Failure(s) to Meet LSLR
Goal (hrs/system per year) B-122
Exhibit B-49: Cost to Conduct Additional Outreach in Response to Subsequent Failure(s) to Meet LSLR
Goal ($/system per year) B-123
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Exhibit B-50: Goal-based Replacement Activities Cost Estimation in SafeWater LCR by Activity under the
2021 LCRR 12 B-123
Exhibit B-51: PWS POU Device Installation and Maintenance Unit Burden and Cost Estimates under the
2021 LCRR B-126
Exhibit B-52: Point-of-Use Device Installation and Maintenance Cost Estimation in SafeWater LCR under
the 2021 LCRR by Activity B-126
Exhibit B-53: PWS Ancillary POU-Related Burden and Cost Estimates under the 2021 LCRR1 B-127
Exhibit B-54: PWS Point-of-Use Ancillary Costing Estimation in SafeWater LCR by Activity under the 2021
LCRR1-2 B-129
Exhibit B-55: PWS Burden for Consumer Notification of Lead and Copper Tap Sampling Results under the
2021 LCRR B-130
Exhibit B-56: PWS Burden and Cost for Public Education Activities that Are Independent of Lead 90th
Percentile Levels under the 2021 LCRR B-131
Exhibit B-57: Annual CWS Burden (per system) to Conduct Outreach to Local and State Health Agencies
B-134
Exhibit B-58: PWS Lead Public Education Unit Costing Approach in SafeWater LCR by Activity under the
2021 LCRR1 B-135
Exhibit B-59: PWS PE Burden in Response to Lead ALE under the 2021 LCRR B-137
Exhibit B-60: PWS Lead ALE Public Education Unit Costing Approach in SafeWater LCR by Activity under
the 2021 LCRR1 B-139
Exhibit B-61: State Cost Components, Subcomponents, and Activities Organized by Section for the 2021
LCRR1 B-140
Exhibit B-62: State Administration Activities and Unit Burden Estimates (Occur during Years 1 and 2)
under the 2021 LCRR1-2 B-144
Exhibit B-63: State Annual Administration Activities and Unit Burden Estimates under the 2021 LCRR....B-
145
Exhibit B-64: State Administration and Rule Implementation Cost Estimation in SafeWater LCR by
Activity under the 2021 LCRR1 B-146
Exhibit B-65: State Lead Tap Sampling Burden Estimates under the 2021 LCRR B-147
Exhibit B-66: State Lead Tap Sampling Unit Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1 B-149
Exhibit B-67: State Lead WQP Monitoring Burden Estimates under the 2021 LCRR B-154
Exhibit B-68: State Lead WQP Monitoring Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1 B-155
Exhibit B-69: State Copper WQP Monitoring Burden Estimates under the 2021 LCRR B-156
Exhibit B-70: State Copper WQP Monitoring Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1 B-156
Exhibit B-71: State Source Monitoring Burden Estimates under the 2021 LCRR B-157
Exhibit B-72: State Source Water Monitoring Cost Estimation in SafeWater LCR by Activity under the
2021 LCRR B-158
Exhibit B-73: State School Sampling Burden Estimates under the 2021 LCRR1 B-158
Exhibit B-74: State School and Child Care Facility Sampling Cost Estimation in SafeWater LCR by Activity
under the 2021 LCRR B-159
Exhibit B-75: State CCT Installation Related Burden Estimates under the 2021 LCRR B-160
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Exhibit B-76: State CCT Installation Cost Estimation in SafeWater LCR by Activity under the 2021 LCRR..B-
161
Exhibit B-77: State CCT Re-Optimization-Related Burden Estimates under the 2021 LCRR B-161
Exhibit B-78: State CCT Re-optimization Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1 B-162
Exhibit B-79: State Find-and-Fix Burden under the 2021 LCRR B-162
Exhibit B-80: State CCT Find-and-Fix Cost Estimation in SafeWater LCR by Activity for the 2021 LCRR1,2..fi-
les
Exhibit B-81: State CCT Installation Related Burden Estimates under the 2021 LCRR B-164
Exhibit B-82: State CCT Re-optimization Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1 B-164
Exhibit B-83: State LSL Inventory Burden Estimates under the 2021 LCRR B-166
Exhibit B-84: State LSL Plan and Annual Report Burden Estimates under the 2021 LCRR B-166
Exhibit B-85: One-Time Burden to Review SLR Plan and Negotiate Replacement Goal under the 2021
LCRR (hrs/system) B-167
Exhibit B-86: State LSL Plan and Annual Report Burden Estimates under the 2021 LCRR B-168
Exhibit B-87: State Goal-Based Replacement Program Burden Estimates under the 2021 LCRR B-168
Exhibit B-88: State Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity under
the 2021 LCRR1-2 B-170
Exhibit B-89: State One-Time POU-Related Burden Estimates B-171
Exhibit B-90: State Ongoing POU-Related Burden Estimates under the 2021 LCRR B-172
Exhibit B-91: State POU Cost Estimation in SafeWater LCR (by Activity)1,2 B-173
Exhibit B-92: State Burden for Consumer Notification When Sample is > 15 ng/L under the 2021 LCRR ..B-
174
Exhibit B-93: State Burden for Public Education Activities that Are Independent of Lead 90th Percentile
Levels under the 2021 LCRR B-175
Exhibit B-94: State PE Burden in Response to Lead ALE under the 2021 LCRR B-176
Exhibit B-95: State Lead Public Education Cost Estimation in SafeWater LCR by Activity under the 2021
LCRR1-2 B-176
Exhibit B-96: Simulating Corrosion Control Under the Pre-2021 LCR in SafeWater LCR Model B-180
Exhibit B-97: Simulating SL replacement Under the Pre-2021 LCR in SafeWater LCR Model B-183
Exhibit B-98: PWS Cost Components, Subcomponents, and Activities Organized by Section for the Pre-
2021 LCR1 B-184
Exhibit B-99: PWS Lead Tap Sampling Unit Burden and Cost Estimates under the Pre-2021 LCR1 B-191
Exhibit B-100: Non-Labor Costs for CWS to Provide Test Kits (per Sample) B-195
Exhibit B-101: PWS Lead Tap Sampling Cost Estimation in SafeWater LCR by Activity under the Pre-2021
LCR1 B-197
Exhibit B-102: Percentage of Ground Water CWSs Serving > 50,000 People with CCT and No Lead or
Copper ALE on Various WQP Distribution System Monitoring Schedules (pre-2021 LCR) B-209
Exhibit B-103: Percentage of Surface Water CWSs Serving > 50,000 People with CCT and No Lead or
Copper ALE on Various WQP Distribution System Monitoring Schedules (pre-2021 LCR) B-210
Exhibit B-104: Percent of Surface Water NTNCWSs Serving > 50,000 People with CCT and No Lead or
Copper ALE on Various WQP Distribution System Monitoring Schedules (pre-2021 LCR) B-210
Exhibit B-105: PWS Lead WQP Monitoring Unit Burden and Cost Estimates under the Pre-2021 LCR B-211
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Exhibit B-106: CWS and NTNCWS Lead Distribution Laboratory Costs without CCT under the Pre-2021
LCR B-213
Exhibit B-107: CWS Lead Entry Point Laboratory Costs without CCT under the Pre-2021 LCR B-214
Exhibit B-108: NTNCWS Lead Entry Point Laboratory Costs without CCT under the Pre-2021 LCR B-215
Exhibit B-109: PWS Copper WQP Monitoring Unit Burden and Cost Estimates B-216
Exhibit B-110: PWS Source Monitoring Burden and Cost Estimates under the Pre-2021 LCR B-217
Exhibit B-lll: PWS Source Water Monitoring Cost Estimation in SafeWater LCR by Activity under the
Pre-2021 LCR1 B-218
Exhibit B-112: PWS CCT Installation-Related Unit Burden and Cost Estimates for the Pre-2021 LCR ..B-222
Exhibit B-113: Likelihood of CCT Study (p_cct_study) B-222
Exhibit B-114: CCT Study Costs ($2020) B-223
Exhibit B-115: Likelihood of Demonstration Study vs. a Desktop Study (p_demo_study) B-223
Exhibit B-116: PWS Ancillary CCT Cost Estimation in SafeWater LCR by Activity under the Pre-2021 LCR^-
224
Exhibit B-117: PWS CCT Ancillary Re-optimization Unit Burden and Cost Estimates under the Pre-2021
LCR B-225
Exhibit B-118: PWS CCT Ancillary Re-optimization Cost Estimation in SafeWater LCR by Activity under the
Pre-2021 LCR1 B-226
Exhibit B-119: PWS Lead CCT Routine Unit Burden and Cost Estimates under the Pre-2021 LCR B-226
Exhibit B-120: PWS Lead CCT Routine Cost Estimation in SafeWater LCR by Activity1 B-227
Exhibit B-121: PWS CCT Costs Unique to the Pre-2021 LCR B-228
Exhibit B-122: PWS CCT Cost Estimation for Activities Unique to the Pre-2021 LCR in SafeWater LCR1 ....B-
229
Exhibit B-123: Number and Percent of CWSs by Lead 90th Percentile Classification under the Pre-2021
LCR B-230
Exhibit B-124: Likelihood of Type of Replacement B-231
Exhibit B-125: PWS LSLR Cost Estimates under the Pre-2021 LCR B-232
Exhibit B-126: Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity1,2 B-233
Exhibit B-127: PWS LSL Replacement Ancillary Unit Burden and Cost Estimates under the Pre-2021 LCR B-
234
Exhibit B-128: CWS Unit Burden for LSLR-Related Sample Collection B-235
Exhibit B-129: CWS Non-labor Unit Cost to Collect Post-SLR Tap Sample B-236
Exhibit B-130: Lead Service Line Replacement Ancillary Cost Estimation in SafeWater LCR by Activity
under the Pre-2021 LCR1-2 B-238
Exhibit B-131: PWS LSL Replacement Ancillary Unit Burden and Cost Estimates under the Pre-2021 LCR1
B-240
Exhibit B-132: Lead Service Line Replacement Ancillary Cost Estimation in SafeWater LCR by Activity
under the Pre-2021 LCR1-2 B-243
Exhibit B-133: PWS Public Education Burden in Response to Lead ALE under the Pre-2021 LCR B-245
Exhibit B-134: PWS Lead ALE Public Education Unit Cost Estimation in SafeWater LCR by Activity under
the Pre-2021 LCR1 B-247
Exhibit B-135: State Cost Components, Subcomponents, and Activities Organized by Section1 B-249
Exhibit B-136: State Annual Administration Activities and Unit Burden Estimates under the Pre-2021 LCR
B-253
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Exhibit B-137: State Administration and Rule Implementation Costing Approach in SafeWater LCR by
Activity under the pre-2021 LCR1 B-254
Exhibit B-138: State Lead Tap Sampling Burden Estimates under the Pre-2021 LCR B-255
Exhibit B-139: State Lead Tap Sampling Unit Cost Estimation in SafeWater LCR by Activity under the Pre-
2021 LCR1 B-257
Exhibit B-140: State Lead WQP Monitoring Burden Estimates under the Pre-2021 LCR B-259
Exhibit B-141: State Copper WQP Monitoring Burden Estimates under the Pre-2021 LCR B-260
Exhibit B-142: State Source Monitoring Burden Estimates B-261
Exhibit B-143: State Source Water Monitoring Cost Estimation in SafeWater LCR by Activity under the
pre-2021 LCR1 B-261
Exhibit B-144: State CCT Installation-Related Burden Estimates B-263
Exhibit B-145: State CCT Installation Cost Estimation in SafeWater LCR by Activity1 B-263
Exhibit B-146: State CCT Re-Optimization-Related Burden Estimates under the Pre-2021 LCR B-263
Exhibit B-147: State CCT Re-optimization Cost Estimation in SafeWater LCR by Activity under the Pre-
2021 LCR1 B-264
Exhibit B-148: State Lead CCT Routine Burden Estimates under the Pre-2021 LCR B-264
Exhibit B-149: State Lead CCT Routine Cost Estimation in SafeWater LCR by Activity under the pre-2021
LCR1 B-265
Exhibit B-150: State CCT Activities Unique to the Pre-2021 LCR B-266
Exhibit B-151: Estimated Burden to Determine CCT for Systems with No Study B-267
Exhibit B-152: State Activities Unique to the Pre-2021 LCR Cost Estimation in SafeWater LCR by Activity1
B-268
Exhibit B-153: State Ongoing LSL Testing and Replacement-Related Costs Burden Estimates1 B-269
Exhibit B-154: State Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity1,2.B-270
Exhibit B-155: State PE Burden in Response to Lead ALE under the Pre-2021 LCR B-271
Exhibit B-156: State Lead ALE Public Education Costing Approach in SafeWater LCR by Activity under the
Pre-2021 LCR1-2 B-272
Exhibit C-l: Estimated National Annualized Monetized Incremental Costs of the Final LCRI at 2 Percent
Discount Rate (pre-2021 LCR Baseline, millions of 2022 dollars) C-2
Exhibit C-2: Estimated National Annualized Monetized Incremental Benefits of the Final LCRI at 2 Percent
Discount Rate (pre-2021 LCR Baseline, millions of 2022 dollars3) C-4
Exhibit F-l. Estimated National Annual Children's IQ Benefits, All PWSs - 2 Percent Discount Rate
(millions of 2022 USD) F-2
Exhibit F-2: ADHD Valuation at a 3 Percent and 7 Percent Discount Rate F-3
Exhibit F-3: Estimated National Annualized Rule Costs - 3 Percent Discount Rate (millions of 2022 USD) F-
4
Exhibit F-4: Estimated National Annualized Rule Costs - 7 Percent Discount Rate (millions of 2022 USD) F-
5
Exhibit F-5: Estimated National Annual Benefits - 3 Percent Discount Rate (millions of 2022 USD) F-6
Exhibit F-6: Estimated National Annual Benefits - 7 Percent Discount Rate (millions of 2022 USD) F-7
Exhibit F-7: Comparison of Estimated Monetized National Annualized Incremental Costs to Benefits of
the LCRI - 3 Percent Discount Rate (millions 2022 USD) F-7
Exhibit F-8: Comparison of Estimated Monetized National Annualized Incremental Costs to Benefits of
the LCRI - 7 Percent Discount Rate (millions 2022 USD) F-8
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List of Acronyms
Hg/dL
Micrograms per deciliter
Hg/L
Micrograms per liter
ABLES
Adult Blood Lead Epidemiology and Surveillance
ADHD
Attention-deficit/hyperactivity disorder
AL
Action level
ALAD
Delta-aminolevulinic acid dehydratase
ALE
Action level exceedance
ALS
Amyotrophic lateral sclerosis
ASCE
American Society of Civil Engineers
ASDWA
Association of State Drinking Water Administrators
ATSDR
Agency for Toxic Substances and Disease Registry
AWWA
American Water Works Association
BIL
Bipartisan Infrastructure Law
BLS
Bureau of Labor Statistics
CCR
Consumer Confidence Reports
CCT
Corrosion control treatment
CDC
Centers for Disease Control and Prevention
CFR
Code of Federal Regulations
CHD
Coronary heart disease
costs
Costs of State Transactions Study
CVD
Cardiovascular disease
cws
Community Water System
cwss
Community Water System Survey
DF
Design flow
DHHS
United States Department of Health and Human Services
DSM
Diagnostic and Statistical Manual of Mental Disorders
DSSA
Distribution System and Site Assessments
DTH
Delayed-type hypersensitivity
DWINSA
Drinking Water Infrastructure Needs Survey and Assessment
DWSRF
Drinking Water State Revolving Fund
EA
Economic analysis
EKG
Electrocardiogram
ENR
Engineering News Record
EP
Entry point
EPA
United States Environmental Protection Agency
FRN
Federal register notice
FSIQ
Full Scale Intelligence Quotient
GCI
General Cognitive Index
GFR
Glomerular filtration rate
GRR
Galvanized requiring replacement
HH
Household
HRRCA
Health Risk Reduction and Cost Analysis
IARC
International Agency for Research on Cancer
ICC
Indian Childhood Cirrhosis
ICR
Information Collection Request
ICT
Idiopathic Copper Toxicosis
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IQ
Intelligence quotient
ISA
Integrated Science Assessment for Lead
LCR
Lead and Copper Rule
LCRI
Lead and Copper Rule Improvements
LCRR
Lead and Copper Rule Revisions
LSL
Lead service line
LSLR
Lead service line replacement
MCLG
Maximum contaminant level goal
MDI
Mental Development Index
mg/L
Milligrams per liter
MMSE
Mini-Mental State Examination
MRL
Minimal Risk Level
NHANES
National Health and Nutrition Examination Survey
NLSY
National Longitudinal Survey for the year
NOAEL
No observed adverse effect level
NTNCWS
Non-transient non-community water system
NTP
National Toxicology Program
OCCT
Optimal corrosion control treatment
OMB
Office of Management and Budget
OWQP
Optimal water quality parameter
P90
Lead 90th percentile level
PE
Public education
POU
Point-of-Use
PWS
Public Water System
OA
Quality Assurance
SBAR
Small Business Advocacy Review
SDWA
Safe Drinking Water Act
SDWIS/Fed
Safe Drinking Water Information System/Federal version
SHEDS
Stochastic Human Exposure and Dose Simulation
SL
Service line
SLR
Service line replacement
TL
Trigger Level
TLE
Trigger level exceedance
UK
United Kingdom
USEPA
United States Environmental Protection Agency
USPS
United States Postal Service
WIFIA
Water Infrastructure Finance and Innovation Act
WIIN
Water Infrastructure Improvements for the Nation
wise
Wechsler Intelligence Scale for Children
WQP
Water quality parameter
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Appendix A: Service Line Replacement Unit Costs
A.l Introduction
Appendix A presents estimated costs for replacing lead service lines (LSLs) and galvanized requiring
replacement (GRR) service lines under the final Lead and Copper Rule Improvements (LCRI). Note that
this appendix provides costs for physical replacements of LSLs and GRR service lines. Costs for additional
water system activities related to service line replacement are discussed in Chapter 4, Section 4.3.4.
For the proposed LCRI, the Environmental Protection Agency (EPA) used the 7th Drinking Water
Infrastructure Needs Survey and Assessment (DWINSA) as the source of lead service line replacement
(LSLR) unit costs and included a review of other data sources in this appendix. In the comments to the
proposed LCRI, the EPA received new compiled cost data submitted by National Resource Defense
Council (NRDC) as part of their public comments. The EPA did not use these cost data to update LSLR
unit costs, as discussed in A.3.2, but did add this information to this appendix. This appendix also
includes an updated analysis of CDM Smith LSLR unit cost data that was provided by the American
Water Works Association (AWWA) prior to the proposed LCRI and referenced in their comments on the
proposed rule.
Section A.2 begins with a discussion of the data sources for service line replacement selected for this
economic analysis (EA) and the derivation of the EPA's unit cost estimates for service line replacement.
For the final LCRI, the EPA modeled costs using the reported costs of LSLRs submitted and accepted for
the 7th DWINSA. The EPA selected the 7th DWINSA as the primary source of data for unit cost estimates
because the source provided detailed project-level data that met the DWINSA data quality criteria. The
dataset also contained responses from small, medium, and large systems and from urban and rural
systems. The EPA adjusted the reported costs to account for regional differences in prices to produce a
national average. Each service line replacement cost estimate, from a given system replacement project,
is weighted by the DWINSA survey sample weights, which reflect the probability that each system is
included in the sample. Each project was also weighted by the number of service lines included in the
project to capture the relative importance of the project cost estimate in comparison with the total
dataset. The weighted values were then used to estimate descriptive statistics for the cost of service line
replacement per line. Overall, the 7th DWINSA provided the most complete picture of the range of
possible service line replacement costs in the nation for the final LCRI.
Section A.3 provides a discussion of other data sources and how they compare to the 7th DWINSA
results. References are listed in Section A.4.
A.2 DWINSA Lead Service Line Replacement Unit Costs
Every four years, the EPA works with States and community water systems (CWSs) to conduct the
DWINSA to estimate the Drinking Water State Revolving Fund (DWSRF)-eligible needs of systems by
State. The assessment of need is for the next 20 years from the time of the survey. This assessment is
the basis for allocating DWSRF grant monies to States, and the EPA presents the results in a report to
Congress (USEPA, 2023). The EPA has been working closely with water systems and States for over 25
years to conduct the DWINSA, and the survey and its methodology are widely accepted and often cited
in various literature and studies. The DWINSA collects actual project and asset data from a stratified
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random statistical sample of water systems, which minimizes bias and uncertainty in the survey and
results. A description of the DWINSA's survey methodology can be found in Chapter 3, Section 3.2.51.
For the final LCRI, the EPA reviewed the reported costs of submitted and accepted LSLR projects from
the 7th DWINSA that contain documentation that could be used to estimate the national cost of
replacing service lines2. The EPA also reviewed other non-lead service line replacement projects, such as
copper and plastic service lines, alongside LSLR projects. In past assessments, the DWINSA estimated
that the costs of replacing non-lead and LSLs were similar. After review of the current data, the EPA
decided to exclude non-lead service line replacement unit costs for purposes of the final LCRI because
they contained several very low costs and the EPA was unable to verify the reasons for the low reported
values.
For a project to be accepted by the DWINSA, water systems must provide information that supports that
they are committed to completing the project and that the project is both feasible and necessary. All
LSLR projects that were submitted under the 7th DWINSA were deemed feasible and necessary, and the
EPA assumes that systems are committed to them. To be further considered for use in the cost model
for the final LCRI, accepted service line projects must include independent documentation of the project
cost (e.g., costs documented through a Capital Improvement Plan or master plan), the month and year
of the cost estimate, and the number of service lines to be replaced, so that the EPA could calculate the
average cost per line.
Under the 7th DWINSA, systems provided information on 275 LSLR projects. Of these, 50 projects
provided sufficient documentation with information on both the number of service lines and their
replacement costs. The EPA excluded six additional projects because either (1) their cost was less than
$700 per line and the documentation did not include any explanation for the low values or (2) they
included activities other than service line replacement (e.g., water main replacement or service line
inventory development) that could not be separated from the costs for the service line replacement
activities. Additionally, the EPA combined five Pittsburgh projects into one because each project
stemmed from the same primary project.
The EPA reviewed the project documentation to determine whether the project was a "full" or "partial"
service line replacement.3 In seven cases, the documentation did not provide enough information to
1 As described in Section 3.2.5, the EPA initiated a one-time effort to update the service line data from the 7th
DWINSA. This update allowed previously surveyed water systems and States to revise their original response based
on new service line inventory information or to provide responses if they had not participated earlier. This update
did not impact the SLR project data nor did it change the original sample weights used in this analysis of lead
service line replacement costs.
2 Acceptable forms of documentation for cost estimates include capital improvement plans, master plans,
preliminary engineering reports, facility plans, bid tabulations, and engineer's estimates. For each project with an
associated cost, the EPA needed the month and year of the cost estimate in order to allow an adjustment of the
cost to January 2020 dollars for this final LCRI EA.
3 For purposes of this analysis, "full" replacement means the system is replacing the service line from the main to
the building. "Partial" replacement means the system is only replacing the service line from the main to the curb
stop or meter, or the meter or curb stop to the building.
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determine the extent of replacement, and the EPA classified the projects as "unknown." The EPA did not
differentiate between utility-side or customer-side for partial replacement because many of the projects
did not specify if the service line was on private or public property. As such, the costs of utility-side and
customer-side replacement are assumed to be the same. The EPA also did not differentiate between
"planned" 4 and "unplanned" projects for purposes of this analysis because the projects reviewed were
presented under a variety of different scenarios and it was unclear if costs under the varied project
scenarios were different.
The final dataset for the LCRI analysis included 33 LSLR projects across 31 water systems; in 13 States;
across EPA Regions 1, 2, 3, 5, 7, and 8; and representing States in the Northeast, the Midwest, and the
West. These systems served populations ranging from 3,000 to over 2,000,000 people. Detailed
information from these projects is provided in the worksheet titled "DWINSA Project Data" in the file
"LSLR Unit Cost_Final.xlsx." The file is available in the LCRI docket EPA-HQ-OW-2022-0801 at
www.regulations.gov. The EPA converted all costs from 2021 to 2020 dollars using the Construction Cost
Index produced by Engineering News Record (ENR), which measures changes in construction costs over
time. The EPA then adjusted the data for regional differences to ensure costs were reflecting a national
estimate using the regional construction cost index produced by RSMeans5. The EPA weighted the
resulting summary statistics by the number of service lines and the final DWINSA system-sampling
weight.6,7 See Chapter 3, Section 3.2.5 for more information on the DWINSA system sampling weights.
Exhibit A-l provides summary statistics for full and partial LSLR unit costs based on utility estimates,
using data from the 33 LSLR DWINSA projects. Detailed information on the costs of LSLR and non-lead
service line replacement projects combined are provided in the worksheet titled "DWINSA Data
Analysis" in the file "LSLR Unit Cost_Final.xlsx," available in docket number EPA-HQ-OW-2022-0801 at
www.regulations.gov.
4 For purposes of this analysis, "planned" replacement means the system is replacing service lines at the same time
that it replaces a distribution main.
5 RSMeans produces a unit price guide for building construction estimators across North America. The index of
regional costs is applied to the individual project cost estimates using the zip code of the system adjusting project
costs for regional differences.
6 DWINSA's system sampling weight ensures that small and medium system costs are represented in a national
average. Large systems serving over 100,000 people receive a sample weight of one because the 7th DWINSA
surveyed all large systems serving over 100,000 people. Therefore, each large system only represents itself in the
population. Small systems serving 3,300 or fewer and medium systems serving 3,301-100,000 people receive a
sample weight that is the inverse of the selection probabilities. These weights are greater than one and are a
measure of the number of systems that each surveyed small or medium system represents. The final sampling
weights are adjusted to account for non-response.
7 To generate percentiles weighted by the number of service lines and the system sampling weight, the EPA first
converted the dataset from the project level to the service line level, creating a dataset that has a single record for
each service line replaced. Each record contained the cost per line, the type of line replaced, the sampling weight,
and whether the replacement is full or partial. The EPA then calculated the weighted mean and percentiles by
applying the system sampling weights.
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Exhibit A-l: Summary of LSLR Costs Using Data from the 7th DWINSA ($/SLR, 2020$)1,2
Statistic
SLR Unit Costs
Full
Partial
Number of Cost Estimates
23
10
Min
$1,180
$1,677
25th percentile value (used for economic analysis, low scenario)
$6,507
$1,920
Median
$7,232
$3,273
Mean
$6,930
$3,803
75th percentile value (used for economic analysis, high scenario)
$8,519
$5,400
Max
$14,966
$8,099
Acronyms: SLR = service line replacement.
Source: "LSLR Unit Cost_Final.xlsx," worksheet "DWINSA Data Analysis", available at EPA-HQ-OW-2022-0801 at
www.regulations.gov.
Notes:
1. 25th and 75th percentile values shown in bold are used in the final LCRI EA as a low and high estimate.
2. Estimated LSLR unit costs shown in this exhibit are slightly different than the range of LSLR costs reported in
Section 2.4 of the Drinking Water Infrastructure Needs Survey and Assessment: Seventh Report to Congress
(USEPA, 2023) (DWINSA Report) for several reasons. First, costs shown here are in 2020 dollars, whereas the 7th
DWINSA Report presents LSLR costs in 2021 dollars. The DWINSA Report also combines partial and full
replacement projects, as well as non-lead and LSL replacement projects. The analysis for the final LCRI EA
considered only LSL projects where it could be determined with confidence that costs applied to either full or
partial replacement. In addition, the analysis for the DWINSA Report did not exclude LSLR projects with ancillary
activities such as conducting outreach and preparing an inventory. For the purposes of this EA, the EPA excluded
projects with ancillary activities since these activities are costed separately. See the file "LSLR Unit Cost_Final.xlsx,"
worksheet "DWINSA Data Analysis", available at EPA-HQ-OW-2022-0801 at www.regulations.gov for a full list of
projects excluded for this analysis.
For the estimates in this analysis, the EPA used the 25th and 75th percentile for full and partial
replacement as the "low" and "high" values for the final LCRI cost analysis. The low and high cost
estimates for full replacement are $6,507 and $8,519, and the low and high cost estimates for partial
replacement are $1,920 and $5,400. The EPA used the same costs for replacement of lead and GRR
service lines. See Chapter 4, Section 4.3.4.3 for a summary of how the cost data are used in the
SafeWater LCR model to estimate costs for the final LCRI.
A.3 Additional Service Line Replacement Cost Data
This section provides a discussion of additional data sources and how they compare to the LSLR unit cost
estimates derived from the 7th DWINSA. Section A.3.1 provides analyses of LSLR unit cost data provided
in a 2022 report by CDM Smith (CDM Smith, 2022), referenced by AWWA in their comments on the
proposed LCRI (available in the LCRI docket EPA-HQ-OW-2022-0801 at www.regulations.gov). This
section discusses limitations in the CDM Smith dataset and provides the reasons why the EPA did not
use this dataset to model national costs.
Section A.3.2 summarizes additional data presented in a 2024 Safe Water Engineering (SWE) report on
LSLR Costs and Strategies for Reducing Them (Betanzo and Spieght, 2024), which was provided as an
attachment to the NRDC's comments on the proposed LCRI (available in the LCRI Docket EPA-HQ-2022-
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0801 at www.regulations.gov). The purpose of the SWE report was to "...assist with evaluation of LSLR
costs, for the purposes of developing Safe Drinking Water Act regulations and implementing local LSLR
programs." The authors present two new cost estimates: 1) results of a literature review to understand
current and reasonable cost ranges for LSLR unit costs, and 2) an independent construction cost
estimate using RS Means Online Construction Cost Database, Year 2024 edition (www.rsmeans.com) to
identify major cost drivers. The report also analyzes the CDM Smith Report (CDM Smith, 2022) and the
EPA's estimates based on the 7th DWINSA and compares them to the two new cost estimates. Section
A.3.2 summarizes of the authors' findings related to cost estimates for the final LCRI.
The EPA received additional SLR cost data in responses to the proposed LCRI. For example, the New
England Interstate Water Pollution Control Commission provided data that the State of New York had
found that SLR costs ranged from $5,000-10,000 per line; Aurora Water in Aurora, CO, reported paying
$11,500 for full replacement; and the Philadelphia Water Department reported they pay $12,000 to
$15,000 per SLR. For these complete comments, see the LCRI Docket EPA-HQ-2022-0801 at www.
regulations.gov. The EPA considered these new costs and found them to be in the range of costs
reported in the 7th DWINSA, the CDM Report, and the SWE Report datasets.
A.3.1 CDM Smith Report and Related AWWA Comments
This section compares the EPA's service line replacement cost estimate in Exhibit A-l to the 2022 CDM
Smith report on Considerations when Costing Lead Service Line Identification and Replacement (CDM
Smith, 2022). To estimate LSLR unit costs, CDM Smith conducted a phone interview with nine utilities
across five States in EPA Regions 2, 3, and 5 that either have previously or are currently conducting
LSLRs. The population served among these nine utilities varied from 10,000 to almost 6,000,000 people.
The study also conducted an expanded literature review to determine additional average LSLR costs;
however, the report did not indicate from which States these projects stemmed.
The initial dataset included 45 projects, with 31 projects obtained through the phone survey and 14
projects obtained through the literature review. The report dropped one full project due to "limited
scope" as well as six projects from the Massachusetts Water Resources Authority that were labeled as
both utility-side and private-side replacement. For estimates provided as a range, the study used the
midpoint. The final dataset included 38 projects, where 31 projects were obtained through the phone
survey of nine systems and seven projects obtained through the literature review of six studies. The
CDM study converted all projects to 2022 dollars using ENR's Construction Cost Index. In cases where
the month of the reported cost was not known, the study averaged the indices across the reported year
for the cost estimate.
Exhibit A-2 provides summary statistics for full, utility-side, and customer-side LSLR construction unit
costs. The EPA adjusted this dataset to 2020 dollars and compared the results against the weighted EPA
estimates calculated using 7th DWINSA data as presented in Exhibit A-l. Results for full LSLR show that
the mean value from the CDM Smith dataset is higher at $8,717 compared to the EPA's weighted mean
of $6,930. The median of the CDM Smith dataset is $8,045 and the EPA's estimate is $7,232. the CDM
Smith 25th and 75th percentile estimates for full replacement are $6,837 and $9,246, respectively. The
EPA's weighted estimates are $6,507 and $8,519, respectively. The CDM Smith estimates for customer-
side replacement are between $3,572 (25th) and $4,905 (75th). The 25th percentile for partial
replacement is higher than the EPA's estimate of $1,920 but the 75th percentile is lower than the EPA's
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estimate of $5,400. The estimates for utility-side replacement are between $4,613 and $6,997. Both
percentiles are higher than the EPA's estimate of $1,920 and $5,400, respectively.
Exhibit A-2: Summary of LSLR Costs from CDM Smith Report ($/LSLR, 2020$)
Statistic
LSLR Unit Costs
Full
Customer-Side
Utility-Side
Number of Cost Estimates
18
8
12
Min
$5,634
$2,512
$3,658
25th percentile value
$6,837
$3,572
$4,613
Median
$8,045
$4,155
$5,295
Mean
$8,717
$4,399
$6,300
75th percentile value
$9,246
$4,905
$6,997
Max
$19,835
$6,612
$15,427
Acronyms: LSLR = lead service line replacement.
Source: Considerations when Costing Lead Service Line Identification and Replacement, pp. 45-
47, available at EPA-HQ-OW-2022-0801 atwww.regulations.gov.
Note: The EPA converted all costs to 2020 dollars using ENR's Construction Cost Index. The EPA
also calculated the 25th percentile, median, and 75th percentile. For estimates provided as a
range, the EPA used the midpoint.
These summary statistics from the CDM Smith report only include "construction costs"8 associated with
LSLR. The report further estimates that, with auxiliary costs9 factored in, the average full LSLR unit cost is
approximately $11,019 in 2020 dollars, with a range falling between $6,700 and $33,322. The report did
not provide the average LSLR unit cost with auxiliary costs factored in for customer-side or utility-side
replacements. The EPA did not utilize the CDM Smith auxiliary cost data due to potential issues with
double counting because some auxiliary costs are already accounted for elsewhere in the EPA estimated
rule costs for the final LCRI. The agency estimates separate auxiliary costs for SLR-related activities that
are specifically required by the LCRI:
• service line replacement plan development and updates,
• developing and updating the inventory,
• notifications to customers and all persons served by the water system at the service connection
served by lead, GRR, and unknown service lines,
8 For purposes of this study, "Construction costs" refer to costs associated with the actual physical replacement of
the service line that would typically be included in a contractor's bid, including mobilization, excavation, pipe
installation, backfill, some restoration, or traffic control.
9 "Auxiliary costs" in this study refer to planning, design, bidding, data management, permitting, engineering
services, utility labor, construction management, customer outreach, filters, follow-up sampling and any costs or
labor associated with the replacements that is not included in the contractor's bid.
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• contacting customers, working to schedule SLRs, and doing site visits prior to replacements,
• providing filters and replacement cartridges following replacement, and
• taking a follow-up tap sample and notifying customers of results.
Other auxiliary costs discussed in the CDM Smith report are included in the 7th DWINSA estimated
replacement costs used by the agency, presented in Exhibit A-l.The 7th DWINSA costs represent
estimates used by utilities for planning and budgeting purposes and are understood to be
comprehensive and include the necessary permitting, engineering, design, and bidding costs. The 7th
DWINSA Report to Congress (USEPA, 2023) states "Cost estimates reflect comprehensive infrastructure
costs like engineering and design, purchase of raw materials and equipment, and construction labor."
There are several possible reasons why the CDM Smith report's findings are generally higher than
weighted results calculated from the 7th DWINSA data. First, the CDM Smith data were derived from
fewer systems and regions, with 31 projects from nine systems in five States and three regions, as well
as 14 projects from five American studies and one Canadian study via literature review. The 7th DWINSA
data derived their 33 projects from 31 systems in 13 States and six regions comprising more than
166,000 LSLRs, which include the States and regions observed in the CDM Smith phone survey.
Therefore, the DWINSA data represent a wider geographic range of responses and potential project
costs, whereas the CDM Smith estimates are largely the result of oversampling nine utilities.
Additionally, the survey data collected from the CDM Smith study were only from systems that served
populations over 10,000 and, therefore, may not be factoring in LSLR unit costs for smaller systems. The
utilities surveyed by CDM Smith may represent more dense, urban areas that have higher costs for
traffic coordination and pavement removal or replacement compared to more rural areas. The 7th
DWINSA captured systems serving populations ranging from 3,000 to 2,000,000. In their comments on
the proposed rule, AWWA noted that using only data from systems serving more than 10,000 people is
appropriate since the majority of lead content service lines are in CWSs serving more than 10,000
people. The EPA agrees that based on the results of the 7th DWINSA, a higher percentage of the lead
content service lines are in systems serving more than 10,000 people10. The EPA's average cost per LSLR
is weighted in the 7th DWINSA dataset by the number of service lines to be replaced. Nearly all of the
more than 138,000 individual full or partial replacements in the 7th DWINSA LSLR dataset are in systems
serving more than 10,000 people (see the derivation file, "LSLR Unit Costs_Final.xlsx," worksheet "Large
vs. Small Compare", available at EPA-HQ-OW-2022-0801 at www.regulations.gov). When the data are
weighted by the system sampling weight (i.e., when each replacement is then multiplied by the system
sample weight), the percentage of replacements in systems serving more than 10,000 people continues
to be very high at 97 percent. The EPA's 7th DWINSA cost dataset is therefore heavily weighted toward
large system replacement cost values with 97 percent of the dataset's replacement costs coming from
systems serving more than 10,000 people, compared to 88 percent of potential lead content service
10 Based on the service line data reported in Chapter 3, Exhibit 3-18, a total of 8,592,603 projected lead content
service lines (i.e., reported lead content service lines and unknowns predicted to be lead) are in systems serving
more than 10,000 people, compared to an estimated 9,791,351 total projected lead content service lines for all
system sizes (88 percent).
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lines. However, unlike the CDM Smith data, the agency's dataset includes 3 percent of replacement cost
estimates from small systems. The EPA dataset over-weights large system cost estimates compared to
small system estimates when considering the number of potential replacements occurring in the two
system size categories; however, the EPA dataset is more representative of the potential national
distribution of large versus small system service line replacement costs than the CDM Smith data.
A third factor that may account for differing costs is that CDM Smith used both a survey and a literature
review to generate their estimates, and the identified literature cases may represent larger, more
expensive projects.
Finally, the CDM Smith report did not use a weighted average, and as a result a high-cost project for
either a low or an unknown quantity of LSLRs has equal weight to a low-cost project that was averaged
over several replacements. Conversely, the 7th DWINSA is weighted by the number of service lines
replaced per project, and also applies a system sampling weight to ensure that small- and medium-
system costs are represented in a national value. In addition, it does not appear that the CDM Smith
report regionally indexed estimates to reflect a national cost, whereas the 7th DWINSA estimates
calculated under this analysis are adjusted to reflect both inflation and regional construction cost
differences among States.
Since CDM Smith's report does not describe the survey sample criteria used in its phone survey, the EPA
is unable to comment on the survey's selection process and understand how the final data points were
selected. The EPA is also unable to contextualize the cost data or compare them to other LSLR programs
because the data provided do not show the population served, and some projects do not include a
number of service lines (likely stemming from the combined data pool with some values coming from a
literature review). By comparison, the 7th DWINSA data are from a survey of a statistical sample of public
water systems that the EPA has been conducting in close cooperation with water systems and States for
over 25 years. Its methodology has been peer reviewed and is widely accepted and often cited in
literature. The DWINSA collects projects from a representative stratified random sample of water
systems, which is designed to produce unbiased and precise estimates of infrastructure need and the
number of LSLs in the United States. Rigorous water system project documentation is required to
demonstrate that a project is necessary, feasible, and has commitment. The EPA recognizes that systems
often did not provide cost data that met the documentation requirements for inclusion in the 7th
DWINSA LSLR cost dataset, so only a subset of surveyed systems are represented in the final LSLR
dataset. The EPA has no information that indicates that the lack of cost data/documentation in some
survey responses is systematically related to estimated LSLR project costs. Therefore, although the total
number of LSLR projects in the 7th DWINSA LSLR cost dataset is relatively small compared with the
number of responses for the larger 7th DWINSA, the data are representative of LSLR costs. (USEPA,
2023).
To further compare the two datasets, the EPA conducted a difference-in-mean test between the
DWINSA and CDM samples, assuming unequal variances. Because the CDM Smith dataset does not
provide sample weights and it is not possible to weight their results by number of replacements, the EPA
removed all weights from the 7th DWINSA dataset to treat the samples consistently. With weights
removed, the mean full LSLR cost for DWINSA was calculated to be $7,419, compared to a mean full
LSLR cost of $8,717 for the CDM Smith data. To formally test the difference in the mean values, the EPA
conducted a two-sample t-test with unequal variances. The test statistic is a t statistic with 36 degrees of
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freedom. The difference in the means is not statistically significant at the five percent level. For more
details of this analysis see The Cadmus Group, Inc. (2024).
In a simplified analysis to determine the potential impact to total annual incremental cost and net
benefits if the EPA were to use the CDM Smith unit cost estimates. The EPA developed SLR cost
multipliers by taking the CDM Smith full SLR cost with ancillary cost maximum value ($33,322) and
dividing by the 25th and 75th percentile DWINSA estimated costs ($6,507 and $8,519), which are used in
the low and high cost scenarios. These calculations produced multipliers of 5.12 and 3.91 for the SLR
costs in the low and high cost scenarios, respectively. The EPA used the multipliers to inflate the total
estimated annualized SLR costs for the low and high scenarios, resulting in annualized incremental SLR
costs of $6.0 and $6.4 billion, respectively. Note these values are gross overestimates of the true cost of
SLR given known double counting in ancillary costs (explained above) and the fact that the use of
multipliers to inflate total estimated SLR costs dramatically inflates the estimated cost of all line-item
cost components (e.g., the cost of a pitcher filter provided to the household post SLR will be inflated
from $64 (EPA estimate under both scenarios) to $250 under the low scenario and $330 under the high
scenario). Adding the inflated SLR cost values to the other final LCRI cost categories, results in total
annualized incremental costs that range from $6.3 to 6.7 billion across the low and high scenarios.
Despite the use of the grossly overestimated SLR costs based on the CDM Smith estimates the final LCRI
would still result in positive incremental annualized net benefits of between $7.2 billion under the low
scenario and $18.4 billion under the high scenario. Given these significant monetized annualized
incremental net benefits and considering the other quantified and non-quantified costs and benefits
discussed in Chapter 6, the EPA would reaffirm that the benefits justify the cost of the final LCRI.
A.3.2 Safe Water Engineering Report
This section summarizes LSLR cost analyses from the 2024 SWE report on LSLR Costs and Strategies for
Reducing Them (Betanzo and Spieght, 2024), which was provided as an attachment to NRDC's comments
on the proposed LCRI. The SWE report provided two different cost estimates, with one based on a
literature review (presented in Section A.3.2.1) and one based on the RS Means Online Construction
Cost Database (presented in Section A.3.2.2). Section A.3.2.3 summarizes the conclusions made by
Betanzo and Spieght (2024) with respect to the service line replacement costs used by the EPA in the
LCRI EA.
A.3.2.1 Independent Literature Review
The SWE report presents results of a literature review to explore the range of published costs for LSLR
projects and compares them to costs previously presented by AWWA and the EPA. Literature used in
this review included previous AWWA publications, CDM Smith publications, the EPA analyses, court
testimony, and media reports regarding cities with publicized LSLR programs. The final dataset yielded
56 projects. The authors converted all projects to 2020 dollars using ENR's Construction Cost Index. The
report does not identify from which utilities these costs stem or the State/region.
Exhibit A-3 provides summary statistics from the SWE report for full LSLR construction unit costs, which
the EPA compared against its calculated estimates based on the 7th DWINSA data. Using the 25th and 75th
percentiles, the SWE report estimates full replacements are between $4,495 and $9,783 in 2020 dollars,
which is a wider range than the EPA's estimates of $6,507 and $8,519, respectively. However, the
median of $6,143 and the mean of $8,247 are closer to the 7th DWINSA-based estimates of $7,232 and
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$6,930, respectively. The distribution of costs between the two datasets are slightly different in that the
mean is lower than the median for the EPA dataset, indicating that the data are slightly skewed toward
lower costs (although the mean and median differ by only approximately $200). Conversely the mean is
higher than the median for the SWE dataset, indicating that the data are skewed towards higher costs.
Exhibit A-3: Summary of Literature Review Results from Safe Water Engineering Report
($/LSLR, 2020$)
Statistic
LSLR Unit Costs (Full)
Number of Cost Estimates
56
Min
$1,173
25th percentile value
$4,495
Median
$6,143
Mean
$8,247
75th percentile value
$9,783
Max
$30,655
Acronyms: LSLR = lead service line replacement
Source: Lead Service Line Replacement Costs and Strategies for Reducing Them pp. 25-26,
available at EPA-HQ-OW-2022-0801 at www.regulations.gov.
Note: The EPA converted all costs to 2020 dollars using ENR's Construction Cost Index. The EPA
also calculated the 25th percentile, median, mean, and 75th percentile.
A.3.2.2 RS Means Construction Cost Estimates
In addition to the literature review, Betanzo and Spieght (2024) present construction cost estimates for
a range of LSLR cost scenarios which are compared against other cost estimates and used to identify
major cost drivers. Each scenario represents typical construction costs11 but differs by:
• the pipe materials (polyethylene vs. copper),
• the length of the pipe replaced, the number of replacements per day,
• the type of construction (open trench excavation which differed by depth of trench vs.
directional drilling/trenchless),
• replacement vs. restoration of the curb stop/corp stop/water meter/sod/fill material, and
• whether the sidewalks/roadways were demolished and/or restored.
The authors used RS Means Online Construction Cost Database, Year 2024 edition (www.rsmeans.com)
for all costs except for directional drilling that were not available. Instead, the authors estimated a cost
of $20 per foot for directional drilling based on literature and a web search for similar household-sized
service line or communication (cable, phone) line installation. This directional drilling estimate was
11 These estimates represent construction costs only, and do not include ancillary items such as inventories,
permits, traffic control, and program management.
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conservatively used for all trenchless options, although the authors acknowledged that other options
could be less expensive. The report provides estimated hours for field engineers and project managers
but did not provide the specific labor rate used to convert these costs to dollars.
Exhibit A-4 provides summary statistics for scenario testing of full and partial LSLR. Note that the SWE
report projected these data forward to $2024 costs, so the EPA adjusted the reports results to 2020
dollars for comparison to the 7th DWINSA analysis12. For purposes of cost comparison for full and partial
LSLRs, the EPA compared the SWE report "low scenario" costs against the 7th DWINSA's minimum and
25th percentile, the "medium scenario" costs against the 7th DWINSA's mean estimate, and the "high
scenario" costs against the 7th DWINSA's 75th percentile and maximum values.
For full LSLR, the "low cost" scenarios presented in the SWE report range in costs from $1,777 to $5,313,
which are comparable with the 7th DWINSA-based minimum cost of $1,180 and 25th percentile of
$6,507. The SWE report has a "medium cost" scenario equal to $9,073, which is higher than the 7th
DWINSA-based mean cost of $7,232. The SWE report provides only one "high cost" scenario value of
$28,320, which is much higher than the 7th DWINSA-based 75th percentile cost of $8,519 or max cost of
$14,966. The partial LSLR cost scenarios from the SWE report range in value from $1,482 to $2,471. The
lower estimate of $1,482 is comparable to the 7th DWINSA-based minimum partial cost estimate of
$1,677 and 25th percentile of $1,920. The SWE report higher partial estimate of $2,471 is notably lower
than the 7th DWINSA-based 75th percentile of $5,400 and maximum partial cost estimate of $8,099.
12 Historical ENR costs can only be to the nearest ENR historical cost index time period, which at the time this
report was published was December 2023. Since that time, ENR's historical cost index has updated the monthly
historical cost index to May 2024. The EPA therefore took an average of the past five available months' worth of
index values for 2024 to convert the data to 2020 costs.
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Exhibit A-4: Summary of LSLR Scenario Costs from Safe Water Engineering Report ($/LSLR,
2020$)
Scenario
High or Low Cost?
Partial or Full?
LSLR Unit Costs
Low Short DD PE
Low
Full
$2,046
Low Short DD Cu
Low
Full
$2,839
Low Short Open PE
Low
Full
$1,777
Low Short Open Cu
Low
Full
$2,569
Low Long DD PE
Low
Full
$2,769
Low Long DD Cu
Low
Full
$3,980
Low Long Open PE
Low
Full
$4,047
Low Long Open Cu
Low
Full
$5,313
Medium Open Cu
Medium
Full
$9,073
High Open Cu
High
Full
$28,320
DD PE
N/A
Partial
$1,831
DD Cu
N/A
Partial
$2,471
Open PE
N/A
Partial
$1,482
Open Cu
N/A
Partial
$2,122
Acronyms: Cu = copper; DD = directional drilling; LSLR = lead service line replacement; PE =
polyethylene.
Source: Lead Service Line Replacement Costs and Strategies for Reducing Them pp. 31-37,
available at EPA-HQ-OW-2022-0801 at www.regulations.gov.
Note: The EPA converted all costs to 2020 dollars using ENR's Construction Cost Index.
A.3.2.3 Safe Water Engineering Report Conclusions
The SWE report made the following conclusions (paraphrased):
• Overall, there is a large degree of consistency across the EPA estimates (based on the results of
the 7th DWINSA) and the SWE report's literature review and construction cost estimates.
• The CDM Smith cost estimates are higher but "...when the CDM Smith data are adjusted to avoid
selective inclusion of projects and more accurately reflect fixed auxiliary costs they are also
consistent with the other unit cost estimates presented here."
• Construction costs vary substantially. There is a small set of construction conditions that can
drive up costs, but based on the literature review and engineering cost estimates in the SWE
report, these conditions are not experienced in the majority of replacements.
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A.4 References
Betanzo, E. W., Safe Water Engineering, and V. Spieght. 2024. Lead Service Line Replacement Costs and
Strategies for Reducing Them. National Resources Defense Council. Submitted by NRDC as part of their
comment on the proposed LCRI.
The Cadmus Group, Inc. 2024. Memorandum from the Cadmus Group, Inc. to USEPA, OGWDW, USEPA,
regarding the Comparison of Estimate of Cost of Lead Service Line Replacements using 7th DWINSA and
CMD Smith Data. September 12, 2024.
CDM Smith. 2022. Considerations when Costing Lead Service Line Identification and Replacement.
American Water Works Association. Submitted by AWWA as part of the Small Business Advocacy Review
(SBAR) comments.
ENR. 2024. Construction Cost Index History.
https://www.enr.com/economics/historical indices/construction cost annual averageUnited States
Environmental Protection Agency (USEPA). 2023. Drinking Water Infrastructure Needs Survey and
Assessment (2021 DWINSA): Seventh Report to Congress. September 2023. Office of Water. EPA 810-R-
23-001. Available at https://www.epa.gov/system/files/documents/2023-
09/Seventh%20DWINSA September2023 Final.pdf.
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Appendix B: Modeling Costs in the SafeWater LCR Model for the Final
LCRI, 2021 LCRR, and the Pre-2021 LCR
B.l Introduction
In order to estimate the compliance costs (and benefits) of the final Lead and Copper Rule
Improvements (LCRI), the United States Environmental Protection Agency (EPA) updated the SafeWater
Lead and Copper Rule (LCR) model, which it developed for the analysis of the 2021 Lead and Copper
Rule Revisions (LCRR). SafeWater LCR is designed to estimate the costs and benefits of a treatment
technique rule and focuses on water contamination in the distribution system. Appendix B, Sections B.2
through B.4 describe in detail how the SafeWater LCR model develops a model system structure to
account for baseline and compliance characteristic variability and how these system characteristics are
used in conjunction with the 2021 LCRR and pre-2021 LCR compliance requirements to simulate model
system compliance actions and develop costs estimates over the 35-year period of analysis under both
scenarios. Because of limited data, to assess the costs (and benefits) and characterize uncertainty, the
EPA estimated 2021 LCRR and pre-2021 LCR compliance costs (and benefits) under high and low
bracketing scenarios.
Appendix B describes how the SafeWater LCR model works incorporating appropriate data. Specifically,
in this appendix, the EPA provides detail on how the SafeWater LCR model estimates the incremental
compliance costs of the final LCRI. To calculate the incremental impact of the final LCRI, each model-
public water systems' (PWSs') costs must first be estimated separately under both the final LCRI and the
baseline rule (either the 2021 LCRR or pre-2021 LCR). Then, for each model-PWS, the SafeWater LCR
model subtracts the estimated costs under the baseline rule from the model-PWS's estimated costs
under the final LCRI to determine the incremental costs of the final LCRI. The same is done for costs
borne by States.
In its primary analysis in Chapter 4, the EPA calculates the incremental costs of the final LCRI above the
costs of the 2021 LCRR. In Section B.3, the EPA provides an overview of its approach to estimate the cost
of the final LCRI. The same information for the 2021 LCRR is provided in Section B.4. In Section B.5, the
EPA provides the detailed data and algorithms used to calculate the cost of each compliance activity
PWSs will undertake to comply with the 2021 LCRR (like the information provided in Chapter 4, Section
4.2 for the final LCRI).
The EPA has also estimated the incremental costs of the LCRI above the costs of the pre-2021 LCR for
informational purposes. In Section B.6, the EPA provides an overview of its approach to estimate the
cost of the pre-2021 LCR. In Section B.7, the EPA provides the detailed data and algorithms used to
calculate the cost of each compliance activity PWSs will undertake to comply with the pre-2021 LCR. The
EPA's estimates of the incremental costs of the final LCRI above the costs of the pre-2021 LCR are
provided in Appendix C.
Before describing the detailed approach for estimating costs under the final LCRI, 2021 LCRR, and pre-
2021 LCR, in Section B.2, the EPA first describes the PWS characteristics and modeling assumptions that
are held constant to ensure consistency among the final LCRI, 2021 LCRR, and pre-2021 LCR cost
estimates.
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B.2 Baseline Conditions and Modeling Assumptions for the Final LCRI, 2021 LCRR, and Pre-
2021LCR
B.2.1 Model-PWSs
In constructing the sample of model-PWSs for the cost analysis in the SafeWater LCR model, the EPA
began with the 49,529 community water systems (CWSs) and 17,418 non-transient non-community
water systems (NTNCWS) in Safe Drinking Water Information System/Federal version (SDWIS/Fed)
fourth quarter 2020 dataset. As described in Chapter 3, from SDWIS/Fed, the EPA knows each PWS's:
• System type (CWS or NTNCWS);
• Primary water source (surface water or ground water);
• Population served;
• Corrosion control treatment (CCT) status (yes/no);
• Ownership (public or private); and
• Number of service connections.
Many additional baseline and compliance characteristics of each model-PWS are needed to estimate the
costs of the pre-2021 LCR, 2021 LCRR, and final LCRI. Therefore, the EPA draws from additional data
sources to assign the characteristics to each model-PWS. Because many model-PWS baseline
characteristics are assigned from distributional information, the EPA needed to ensure that the sample
size was large enough to generate results that were stable for each of the 36 PWS categories. In other
words, every time the EPA assigned a set of baseline characteristics and estimated the costs of the final
LCRI for a model-PWS in a PWS category, the model should have generated similar results for the PWS
category. If a PWS category had too few model-PWSs, the model would not produce stable results due
to the large number of distributional variables in the analysis.
Therefore, the EPA oversampled the SDWIS/Fed inventory to increase the number of model-PWSs in
each PWS category. For every PWS category, the EPA set the target minimum number of model-PWSs to
5,000.13 Consider the example of privately-owned CWSs serving 3,301-10,000 people with ground water
as their primary water source. This PWS category has 336 systems. To ensure the model includes at least
5,000 model-PWSs, the EPA replicated each PWS in the SDWIS/Fed inventory. So, for this example PWS
category, the sample will be replicated 15 times and there would be 5,040 model-PWSs in this category.
Continuing with this example, when the EPA estimated the costs for this PWS category, each model-PWS
would have a weight of 0.067 (336 divided by 5,040). To calculate the costs for this PWS category, the
13 Testing of the model showed that the model results remained stable (within 2 percent) between a category
sample size of 5,000 and 20,000. Once the EPA was certain that the results were sufficiently stable at the sample
size of 5,000 per category, the EPA was able to achieve complete stability (no random model variability) between
model runs by assigning a fixed random number seed for each PWS. The fixed seed ensures that each PWS
received the same data value from the distributional information each time the model was run. This allowed the
EPA to evaluate differences between options or sensitivity analyses with greater confidence.
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EPA multiplied the cost for each model-PWS by 0.067 to get the model-PWS's weighted cost, and then
sums the weighted costs for all 5,040 model-PWSs in the sample to get the total cost for the PWS
category.
Once the model-PWSs were created, the EPA assigned all baseline characteristics to each model-PWS in
the sample, so that the estimate of costs for the final LCRI and the baseline rule are based on the same
baseline characteristics. In Exhibit B-l, the EPA provides the list of baseline characteristics assigned to
each model-PWS that are critical to understanding how the model estimates costs.
Exhibit B-l: Select Baseline Characteristics Assigned from Distributional Information to
Model-PWSs
Baseline Characteristic
Data Description
Number of entry points to the distribution system
Chapter 3, Section 3.3.6; "Baseline
CCT Characteristics.xlsx"
Model-PWS has service lines with lead contents in baseline (yes/no)
Chapter 3, Section 3.3.4
Percent of connections that are lead (if any)
Chapter 3, Section 3.3.4
Type of CCT in place (if any)
Chapter 3, Section 3.3.3, and
Chapter 4, Section 4.3.2.2.1,"
Baseline CCT Characteristics.xlsx"
Current pH level
"Baseline CCT Characteristics.xlsx"
Current PO4 dose
"Baseline CCT Characteristics.xlsx"
Lead 90th percentile placement (above or below the AL) under final LCRI
Chapter 3, Exhibit 3-26
Lead 90th percentile placement under 2021 LCRR (above the AL, above the
TL but not above the AL, or below the TL)
Chapter 3, Exhibit 3-25
Lead 90th percentile placement (above or below the AL) under the pre-2021
LCR
"Initial P90 Categorization_5
bins LCR Final.xlsx"
Tap sampling frequency in baseline
Chapter 3, Section 3.3.7
Source water change (y/n) each year of analysis
Chapter 3, Exhibits 3-53 and 3-54
Treatment technology change (y/n) each year of the analysis
Chapter 3, Exhibits 3-55 and 3-56
Acronyms: AL = action level; CCT = corrosion control treatment; LCR = Lead and Copper Rule; LCRI = Lead and
Copper Rule Improvements; LCRR = Lead and Copper Rule Revisions; LSL = lead service line; PO4 = orthophosphate;
PWS = public water system; TL = trigger level.
Many other data elements are assigned to the model-PWSs to maintain consistency among the
estimation of costs for the pre-2021 LCR, the 2021 LCRR, and final LCRI (e.g., the expected likelihood
that a tap water sample will be invalidated). Chapter 4, Section 4.3, discusses how each data element is
used in the estimation of costs and provides an explanation of, or a reference to, how these data were
developed. Sections B.5 and B.7 provide the same information for the 2021 LCRR and pre-2021 LCR
respectively.
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B.2.2 Model PWS 90th Percentile Tap Sample-Range
The SafeWater LCR model first assigns a 90th percentile lead tap sample (P90)-range to each model-PWS
for the 2021 LCRR, as shown in Chapter 3, Exhibit 3-25.14 The final LCRI requires systems to take first -
and fifth-liter tap samples at service line (SL) locations with lead content (i.e., lead and galvanized
requiring replacement (GRR) service lines) and use the higher of the first- or fifth-liter samples in
calculating the PWSs 90th percentile value, which the EPA anticipates will also increase the likelihood
that a PWS would have a P90 greater than the action level (AL) when compared to the 2021 LCRR (see
Chapter 3, Exhibit 3-26 for the estimated 90th percentile values for lead tap samples under the final
LCRI). However, rather than simply assigning each model-PWS a P90-range under the final LCRI using the
percentages in Chapter 3 directly, in order to maintain consistency between the 2021 LCRR and the final
LCRI for each PWS, the SafeWater LCR model uses the model-PWS's initial P90-range under the 2021
LCRR to determine whether the model-PWS's initial P90-range under the final LCRI is as follows (see
Step 1 in Exhibit B-4):
1. If the model-PWS has no SLs with lead content, the P90-range under the final LCRI is the same as
under the 2021 LCRR.
2. If the model-PWS has lead service lines (LSLs) and the P90 is greater than the AL under LCRR,
then the P90-range under the final LCRI is the same as under the 2021 LCRR.
3. If the model-PWS has LSLs and the P90 is greater than the 2021 LCRR Trigger Level (TL) but not
greater than the AL under the LCRR, then randomly select the P90-range for the final LCRI using
the following probabilities:
a. Prob(P90 greater than the AL under final LCRI) = (Prob(P90 greater than the AL under final
LCRI) - Prob(P90 greater than the AL under LCRR)) / Prob(P90 greater than the TL but not
greater than the AL under LCRR)
b. Prob(P90 greater than the TL but not greater than the AL under final LCRI) = 1- (((Prob(P90
greater than the AL under final LCRI) - Prob(P90 greater than the AL under LCRR)) /
Prob(P90 greater than the TL but not greater than AL under LCRR))
4. If model-PWS has LSLs and P90 is at or below the TL under the 2021 LCRR, then randomly select
the P90-range for the final LCRI using the following probabilities:
a. Prob(P90 greater than the TL but not greater than the AL under LCRR) = (Prob(P90 greater
than the TL but not greater than the AL under final LCRI) - Prob(P90 greater than the TL but
not greater than the AL under LCRR)) / Prob(P90 Less than or equal to the TL under LCRR)
b. Prob(P90 Less than or equal to the TL under final LCRI) = l-((Prob(P90 greater than the TL
but not greater than the AL under final LCRI) - Prob(P90 greater than the TL but not greater
than the AL under LCRR)) / Prob(P90 Less than or equal to the TL under LCRR))
14 The SafeWater LCR model does not track PWSs' P90. Rather, it tracks the regulatory range within which the
PWS's P90 falls. A P90 can be in the following regulatory ranges: not greater than TL, greater than TL but not
greater than AL, and greater than AL. For ease of exposition, the EPA refers in this chapter to a PWS's P90-range.
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B.2.3 Very Large Systems
There are 24 very large systems serving more than one million people. Because of the small number of
systems in this size category, as well as the large costs these systems could face due to their size, the
EPA collected additional PWS-specific information on baseline characteristics from these systems and
used a modified model-PWS approach for estimating the compliance costs for this category of PWSs.
Very large systems are potentially cost drivers because they serve more than one million people.
Utilizing SafeWater to select their baseline conditions can potentially generate erroneous compliance
cost estimates. The set of such systems is relatively small (24) compared to systems in other system size
categories. Therefore, collecting system-specific information about relevant baseline characteristics is
feasible and preferable to estimating compliance costs through a modeling process. For these very large
systems, the EPA attempted to collect information on their number of SLs with lead content, entry point
(EP)-specific orthophosphate practices and chemical doses, pH measurements and pH adjustment
practices, service populations, and average annual daily and design flow (DF) rates. The EPA gathered
this information from SDWIS/Fed, and from publicly available information such as Consumer Confidence
Reports (CCRs) and water system websites. In addition, the American Water Works Association
(AWWA), in 2017 and 2018, provided data from member systems to fill data gaps.
When PWS-specific CCT data were available for very large systems, the SafeWater LCR model calculated
the CCT costs at each EP individually using the information about the EPs' baseline CCT practices and
doses. If data were not available, the EPA assigned baseline CCT characteristics using the model-PWS
approach described above. Likewise, if system-specific SL with lead content inventory data were
available, the SafeWater LCR model used the data to calculate the costs but if system-specific SL with
lead content inventory data were not available, the SafeWater LCR model assigned the number of SLs
with lead content using the same model-PWS approach for smaller system size categories. Exhibit B-2
provides a summary of the data collected for each of the very large systems. All other baseline and cost
characteristic data were assigned in the same manner as the systems serving 100,001 to 1 million size
category.
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October 2024
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Exhibit B-2: Summary of AWWA Data for PWS Systems Serving more than 1M People
PWS Name
Phosphate
Inhibitor Use for
Sequestration
pH Adjustment
Data
SL with lead
content Inventory
Flow Data
Provided
Charlotte Water System
No data provided
Chicago
No data provided
City of Austin
No data provided
City of Baltimore
No data provided
City of Houston
No
Yes, EP level
data provided
Both Public and
Private unknown
EP level data
provided
City of Phoenix
No
Yes, EP level
data provided
Public replaced,
Private unknown
EP level data
provided
City of San Diego
No data provided
Cleveland Public Water System
No data provided
Columbus Public Water System
No data provided
Dallas Water Utility
No data provided
Denver Water Board
No data provided
East Bay Mud
No
Yes, EP level
data provided
All replaced
EP level data
provided
Fairfax County Water Authority
Yes, dose
provided
Yes, EP level
data provided
None present
EP level data
provided
Las Vegas Valley Water District
No
No
None present
EP level data
provided
Los Angeles-City, Dept. Of
Water & Power
No data provided
Massachusetts Water
Resources Authority
No
Yes, EP level
data provided
Both Public and
Private present
EP level data
provided
Miami-Dade Water and Sewer
Authority - Main System
No
No
Some Public
replaced, Private
unknown
EP level data
provided
MO American St Louis Co. & St
Charles Co.
No
Yes, EP level
data provided
Public replaced,
Private present
EP level data
provided
New York City System
Yes, dose
provided
Yes, EP level
data provided
Public replaced,
Private present
EP level data
provided
Philadelphia Water
Department
Yes, dose
provided
Yes, EP level
data provided
Both Public and
Private present
EP level data
provided
San Antonio Water System
No data provided
San Jose Water System
No data provided
Suffolk County Water Authority
No
No
Specific EPs with
LSL Identified
EP level data
provided
Washington Suburban Sanitary
Commission
Yes, dose
provided
Yes, EP level
data provided
Public replaced,
Private unknown
EP level data
provided
Acronyms: AWWA = American Water Works Association; EP = entry point; LSL = lead service line; PWS = public
water system; SL = service line.
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B.2,4 Analysis Period and Discount Rates
The EPA estimated the incremental cost of the final LCRI over a 35-year period to fully capture the costs
of the rule since it may take over 30 years for many CWSs to complete their service line replacement
(SLR) program under the 2021 LCRR. In accordance with EPA policy and based on guidance from the
Office of Management and Budget (OMB), when calculating social costs and benefits, the EPA
discounted future costs (and benefits) under a social discount rate of 2 percent.
When evaluating the economic impacts on PWSs and households (not social costs and benefits), the EPA
uses the estimated PWS cost of capital to discount future costs, as this best represents the actual costs
of compliance that systems will incur over time. The EPA used data from the 2006 Community Water
System Survey (CWSS) to estimate the PWS cost of capital (USEPA, 2009a; 2009b). The survey defined
the following categories of funding sources:
• Current revenue;
• Equity or other funds from private investors;
• Government grants;
• Drinking Water State Revolving Fund (DWSRF), including loans and Principal Repayment
Forgiveness;
• Other borrowing from public sector sources; and
• Borrowing from private sectors sources.
The EPA calculated the overall weighted average cost of capital (across all funding sources and loan
periods) capital for each CWS size category and ownership type is shown in Exhibit B-3. Since similar cost
of capital information is not available for NTNCWSs, the EPA used the CWS cost of capital when
calculating the annualized cost per NTNCWS.
Exhibit B-3: Weighted Average Cost of Capital by PWS Ownership and Size Category
Size Category
Publicly Owned CWS
Privately Owned CWS
<100
3.8%
7.8%
101-500
5.5%
8.2%
501-1,000
4.0%
8.6%
1,001-3,300
4.7%
7.1%
3,301-10,000
5.8%
7.0%
10,001-50,000
6.1%
7.0%
50,001-100,000
4.9%
6.9%
100,001-500,000
4.7%
3.9%
Over 500,000
3.7%
7.8%
Acronyms: CWS = community water system; PWS = public water system.
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As mentioned above, these cost of capital estimates are derived from the 2006 CWSS. Since 2006,
Congress has established several new programs, and expanded other existing programs, that PWSs can
access to lower their cost of capital. These include the DWSRF, the Water Infrastructure Finance and
Innovation (WIFIA) Program, and the Water Infrastructure Improvements for the Nation Act of 2016
(WIIN Act).
Through the DWSRF Program, the EPA allocates annual capitalization grants to States. The funds, along
with a 20 percent State match, are placed into a dedicated loan fund to finance eligible water system
infrastructure improvement projects. States are permitted to use funding from their DWSRF to facilitate
SLR projects and are taking steps to modify their DWSRF programs to prioritize SLR. The Infrastructure
Investment and Jobs Act, also referred to as the Bipartisan Infrastructure Law (BIL), appropriated $30.7
billion in supplemental DWSRF funding and reemphasized the importance of lead service line
replacement (LSLR) under the DWSRF program by including $15 billion specifically appropriated for
"lead service line replacement projects and associated activities directly connected to the identification,
planning, design, and replacement of lead service lines." The dedicated LSLR appropriation and the
General Supplemental appropriation under the BIL as well as annual base appropriations for the DWSRF
can pay for LSLR and related activities. The BIL requires that States provide 49 percent of their LSLR and
General Supplemental capitalization grant amounts as additional subsidization in the form of principal
forgiveness and/or grants to disadvantaged communities, as defined under SDWA 1452(d)(3). The WIFIA
program provides creditworthy PWSs access to low-interest direct federal loans that can be used to
finance capital improvements including SLRs. Under the WIIN Act, three new grant programs were
established related to reducing lead in drinking water (assistance for small and disadvantaged
communities, reducing lead in drinking water, and lead testing in school and childcare program drinking
water). For additional information on other financial resources see the Federal Register Notice for this
rulemaking. Therefore, the actual cost of capital faced by some water utilities may be lower than those
used in this analysis.
B.3 Estimating Compliance Activity under the Final LCRI
Many compliance activities are required only if the PWS has a lead P90-range above the AL. Therefore,
the SafeWater LCR model must keep track of each model-PWS's lead P90-range throughout the period
of analysis. For simplicity of the modeling, the EPA assumes that many compliance activities undertaken
by PWSs will not affect a PWS's P90-range. These include, for example, developing/updating a SL
inventory, CWS sampling at schools and child-care facilities, and public education (PE). In fact, for
modeling purposes, the EPA assumes that the only compliance activities that will change a model-PWS's
P90-range are:
• Installation of CCT;
• Re-optimization of existing CCT;
• Removal of all lead content SLs; and
• A system-wide distribution system corrective action triggered by a distribution system and site
assessment (DSSA) (assumed in the cost modeling to be a system-wide increase in pH and to
occur infrequently).
Final LCRI Economic Analysis Appendices
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October 2024
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In addition to these rule compliance activities changing a PWS's P90-range, changing a water source or
treatment technology can also result in a change in P90-range.15
This section describes the modeling framework for the final LCRI employed by the SafeWater LCR model
to determine whether a model-PWS will take an action that will change its P90-range, which in turn will
change other actions the PWS will be required to take.
Rule implementation activities under the final LCRI will begin immediately after rule promulgation.
These activities will include one-time State and PWS costs for staff to read the rule, become familiar
with its provisions, and train employees on the new rule. PWSs will also comply with the inventory and
SLR initial planning requirements of the final rule in years 1 through 3 of the analysis, as well as
associated PE. The EPA expects that systems will begin complying with all other final rule requirements
three years after promulgation, or in Year 4 of the analysis.
The SafeWater LCR model works on an annual time step which the EPA calls the "year-loop." At the
beginning of the first year that the final LCRI's tap sampling requirements take effect (Year 4 of the
period of analysis), the model-PWS's initial P90y-range is set as explained above. As the SafeWater LCR
model progresses through the year-loop, it continually updates its projection of the starting P90-range
for the following year (P90y+i-range) based on:
1. The current year's starting P90-range (P90y-range);
2. Changes in source water and treatment technology in the current year;
3. Installation or re-optimization of CCT in the current year;
4. Replacement of lead content SLs in the current year; and
5. A system-wide distribution system corrective action triggered by a DSSA (assumed in the
cost modeling to be a system-wide increase in pH and to occur infrequently).
6. The EPA assumed that 100% of property owners would provide access to the water system
to conduct a full service line replacement. This is a reasonable assumption for purposes of
the economic analysis in order to develop a conservative estimate of costs. Moreover, there
are many water systems that have already completed at or near 100% LSLR (e.g., Madison,
Wl; Lansing, Ml; Green Bay, Wl; Newark, NJ; Flint, Ml; Framingham, MA), demonstrating
that achieving this level of customer participation in service line replacement programs is
possible. In addition, the final LCRI contains many requirements and incentives to facilitate
water systems gaining access for full replacement (see section IV.B.3.b of the final LCRI
Federal Register Notice (USEPA, 2024)). Further, the availability of significant funding from
the Bipartisan Infrastructure Law and other sources can reduce or eliminate direct costs to
property owners for service line replacement (where water systems do not pay for the full
service line replacement) (see section III.G of the final LCRI Federal Register notice (USEPA,
2024).
15 There can be sample variability of a PWS's P90 over time. The SafeWater LCR model assumes, however, that this
variability will not result in a change in a PWS's status with regard to being above the AL.
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7. Some systems have reported lower property owner participation rates in their service line
replacement programs in the past. The EPA does not believe these rates are comparable to
those projected under the LCRI, given the rule's requirements and incentives for systems to
gain access to complete the full replacement, as well as the significant external funding to
support full replacement. Given the rule provisions allowing the water system to avoid
replacing the service line where the property owner refuses access (when customer consent
is required), the EPA does anticipate that some property owners may refuse access for the
system to complete full replacement; however the agency does not expect these refusals to
be widespread. When property owners refuse replacement, the final LCRI's estimated
benefits are expected to decrease. The rule's costs are also expected to decrease because
the systems would not incur service line replacement costs for each replacement not
conducted.
B.3.1 Change in Source Water or Treatment Technology
As mentioned above, a change in source water or treatment technology can affect a model-PWS's
projected P90y+i-range. The first step within the year-loop is to determine whether the model-PWS has a
significant change in source water or a change in treatment technology during the year (Step 3 in Exhibit
B-4). If the model-PWS does not, then their projected P90y+i-range is not affected by a significant source
water change or treatment change (Step 7), and the model-PWS moves on to the next component of the
year-loop (Step 9).
However, if the model-PWS does have a significant change in source water or a treatment technology
change (Step 3), it is possible that this change could affect its P90y+i-range. Therefore, the SafeWater
LCR model draws a new P90-range for the model-PWS, which represents the possible P90y+i-range
associated with the new source water or treatment technology, as shown in Exhibit B-4 (Step 4).
If the model-PWS has installed or re-optimized CCT prior to the current year (Step 5), the EPA assumed
that the CCT is adequate to mitigate any increase in lead concentration associated with the significant
source water change or treatment technology changes. Therefore, if the newly drawn P90-range is
higher than the current P90y-range (Step 6), the SafeWater LCR model will keep the P90y+i-range the
same as the P90y-range, as there will be no change in lead concentrations associated with the change in
source water or treatment technology (Step 7). On the other hand, if the newly drawn P90-range is
lower than the current P90y-range (Step 6), SafeWater will set the P90y+i-range equal to the newly
drawn P90-range, in effect lowering the model-PWS's P90y+i-range (Step 8). If the model-PWS has not
installed or re-optimized CCT prior to the current year (Step 5), then the SafeWater LCR model will set
the P90y+i-range equal to the newly drawn P90-range (which may result in either an increase or
decrease of the P90y+i-range). In all three cases, the model-PWS will move on to the next component of
the year-loop (Step 9).
Final LCRI Economic Analysis Appendices
B-10
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Exhibit B-4: Simulating Change in Source Water or Treatment Technology in SafeWater LCR
A
±
Determine
Baseline
P90-Range
f
Begin Year Loop
(Year = y)
NO
Draw New P90-
Range to Reflect
Change in Source
Water or Treatment
f
No change in
P90y»i-Range due
to Source Water or
Treatment Change
Set P9
-------
B.3.2 Small CWS and NTNCWS flexibility
The final LCRI includes flexibility for CWSs that serve 3,300 or fewer people, and all NTNCWSs. If these
PWSs have a P90-range greater than the AL, they can choose to provide point-of-use (POU) devices to all
customers rather than install or re-optimize CCT.16
For modeling purposes, the EPA assigns a compliance cost to small CWSs and all NTNCWS systems that
exceed the AL in the SafeWater LCR model. The EPA uses a cost minimization assumption in the model
and assigns the least cost alternative between CCT and POU compliance alternatives.
B.3.3 Corrosion Control and Point-Of-Use Technology
After the SafeWater LCR model determines whether a model-PWS's P90y+i-range will be affected by a
change in source water or treatment technology, the model continues within the year-loop and begins
the process of determining whether the model-PWS will install CCT, re-optimize CCT, or install POU
devices (in the case of small CWSs or all NTNCWSs). The SafeWater LCR model uses the model-PWS's
P90y+i-range rather than the current year-loop's initial P90-range (P90y-range) to determine if the PWS
will install CCT, re-optimize CCT, or install POU. This is because the EPA assumes that if a PWS proposes
a significant change in water source or a change in treatment technology, the State will require the PWS
to determine the impact of the change on lead levels, and take any corrective measures (installing CCT,
re-optimizing CCT, or installing POU) before making the change in source water or treatment
technology. Therefore, the SafeWater LCR model assumes that a change of water source or treatment
technology would never lead to an action level exceedance (ALE), as the PWS would implement, if
needed, appropriate CCT or POU (if eligible) prior to the change.
The SafeWater LCR model keeps track of the model-PWS's CCT status throughout the period of analysis.
Once a model-PWS with existing CCT17 re-optimizes its CCT, or a model-PWS without CCT installs CCT,
the EPA assumes that the CCT is optimized and no further changes to CCT will be needed.1819 Therefore,
as the SafeWater LCR model continues within its year-loop (see Exhibit B-5), it determines whether the
model-PWS has already re-optimized its existing CCT, or installed new CCT, and therefore has optimized
CCT in place (Step 10). If it does, then the SafeWater LCR model makes no change to CCT in place and to
16 Small CWSs and NTNCWSs that have control over their entire plumbing system may choose to remove all lead-
bearing plumbing material. The EPA lacks the system characteristic data that would allow the agency to determine
a small system's cost for replacement of lead-bearing plumbing materials because of the significant variability
among systems and the plumbing materials in the buildings they serve. Therefore, this option was not included in
the cost estimation. The EPA assumes that systems selecting this compliance alternative would have lower costs
than if they had changed their CCT or provided POU devises.
17 The population served by PWSs with existing CCT at the beginning of the period of analysis is assumed to be
exposed to lead concentrations associated with "partial" CCT in the EPA's benefit analysis (see Chapter 5).
18 The EPA assumes, for modeling purposes, that once CCT is optimized, no further CCT changes will be required
unless the model PWS has multiple individual tap samples above the AL and is required to take corrective action
based on the DSSA. This will be covered later in this appendix in Section B.3.5.
19 When evaluating an alternative AL of 5 \xg/\, the EPA assumed that 15 percent of PWS would not be able to avoid
ALEs after installing or re-optimizing CCT.
Final LCRI Economic Analysis Appendices
B-12
October 2024
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the model-PWS's P90y+i-range due to CCT (Step 19) and the model-PWS moves on to the next stage of
the year-loop (Step 23).
Model CWSs serving more than 3,300 people with a P90y+i-range greater than the AL (Step 11) and
existing CCT in place (Step 14) will re-optimize their existing CCT (Step 15). If they do not have existing
CCT in place (Step 14), they will install CCT (Step 16). The EPA assumes that both re-optimization of and
installation of CCT due to an ALE will occur four years after the ALE (y+4) because of the time required to
conduct a pipe loop study. The same is true for small model CWSs and all NTNCWS (Step 12) if CCT is
their least costly compliance strategy (Step 13). However, if POU is their least costly compliance strategy
(Step 17), the model-PWS will install POU (y+1) (Step 18).
Once a model-PWS re-optimizes existing CCT, installs CCT, or installs POU, SafeWater will adjust its P90-
range to reflect the reduced lead levels (Steps 20, 21, and 22) before moving on to the next stage of the
year-loop (Step 23). The EPA assumes it will take two years after CCT installation or re-optimization for
the PWS's P90-range to fall (y+6 for CCT installation or re-optimization due to an ALE).
Final LCRI Economic Analysis Appendices
B-13
October 2024
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Exhibit B-5: Simulating Corrosion Control and Point-of-Use Technology under Final LCRI in
SafeWater LCR
YES
19
No Change in
P90y+i-Range Due
to CCT or POU
20
Set
P90 y+i-Range
To Reflect POU
Installation
21
Set
P90y+6-Range
To Reflect
Optimized CCT
Final LCRI Economic Analysis Appendices
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B.3.4 Replacements of Lead Content Service Lines
The SafeWater LCR model keeps track of the number of SLs with lead content a model-PWS still has in
place at the beginning of each year-loop. If a model-PWS does not have any SLs with lead content in
place (Step 24 in Exhibit B-6), then the SafeWater LCR model will make no change to the model-PWS's
P90y+i-range due to SLRs (Step 28), and the model-PWS moves on to the next stage of the year-loop
(Step 30).
If a model-PWS has SLs with lead content in place at the beginning of the year-loop (Step 24) it must
begin replacing SLs with lead content in Year 4 (Step 25). While most PWSs will be required to replace all
known and unknown SLs with lead content within 10 years beginning in Year 4, some PWSs may be
granted a deferred deadline or may be required to replace SLs on a shortened deadline determined by
the State. Systems exceeding 0.039 replacements per household per year would be eligible for deferred
deadlines beyond the 10-year replacement period. Because the EPA does not have information on the
annual variation in replacement rates which systems may experience when required to conduct
replacement, the agency has assumed an annual replacement rate. For modelling purposes, the EPA
assumes each PWS will replace the lowest of the following number of service lines each year:
• 10 percent of SLs with lead content
• 0.039 SL with lead content for each household served.
When a model-PWS replaces any SLs with lead content during the year (Step 25), the SafeWater LCR
model determines whether, at the end of the year, the model-PWS has no more SLs with lead content
remaining (Step 27). If this is the case, the SafeWater LCR model assigns a new P90y+i-range from the
distribution of P90 values for PWSs without lead content SLs (Step 29)20 and the model-PWS moves on
to the next stage of the year-loop (Step 30). If, at the end of the year, the model-PWS still has SLs with
lead content in place (Step 27), the SafeWater LCR model will make no change to the model-PWS's
P90y+i-range due to SLR (Step 28), and the model-PWS moves on to the next stage of the year-loop (Step
30).
20 Under the final LCRI, when PWSs replace an LSL at a tap water sampling location, they are required to replace
that sampling location with a new sampling location that has an LSL. Therefore, it is likely that a PWS will not see a
decrease in their P90 until most LSLs are removed. As a modeling assumption, the SafeWater LCR model changes a
PWS's P90 only after all LSLs are removed.
Final LCRI Economic Analysis Appendices
B-15
October 2024
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Exhibit B-6: Simulating Lead Service Line Replacements under Final LCRI in SafeWater LCR
YES
NO
26
Reduction in
Household
Lead
Concentration
V
28
No Change in
P90y+i-Range Due
to LSLR
_YES—
27
LSLs Remaining
at End of Year y
NO
29
Set P90y+i-Range
to Reflect Removal
of all LSLs
B.3.5 Distribution System and Site Assessments (DSSA)
In addition to requiring PWSs to take compliance actions to reduce lead concentrations when their
system-wide P90-range exceeds the AL, the final LCRI will also require PWSs to address distribution
system issues that cause a single lead tap water sample to exceed 10 |ig/L. Although the final LCRI
requires any PWS with tap water samples exceeding 10 (ig/L to identify and address localized elevated
lead concentrations, the EPA assumes, for modeling purposes, that CCT-related DSSA requirements will
Final LCRI Economic Analysis Appendices
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October 2024
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be addressed only after a PWS has optimized CCT in place. Therefore, if a model-PWS does not have
optimized CCT (Step 31 in Exhibit B-8) in place or does not have at least one lead tap sample above 10
Hg/L in the year (Step 32), then it is assumed to not make any CCT adjustments, and the SafeWater LCR
model will make no change to the model-PWS's P90y+i-range due to DSSA (Step 40). The model-PWS will
simply move to the next year-loop (Step 2, Exhibit B-4).
If a model-PWS does have optimized CCT in place, the SafeWater LCR model calculates the number of
tap samples that will be above 10 ng/L in the current year of the analysis as a binomial distribution
defined by the number of samples taken by the model-PWS during the year and the likelihood that any
given sample will be greater than 10 ng/L (Step 32). The number of tap samples a model-PWS will take
in a year depends on the model-PWS's tap sampling frequency (semi-annual, or once every one, three,
or nine years) and the system size.21 Exhibit B-7 provides the likelihood that a single lead tap sample will
be above 10 ng/L, which varies by the model-PWS's P90y-range and lead content SL status.
Exhibit B-7: Likelihood That a Single Tap Water Sample Will be in Each of the Five Bins Used
for Modelling Purposes under the Final LCRI
LSL Status
P90 >15 ng/L
12 ng/L < P90
< 15 ng/L
10 ng/L < P90
< 12 ng/L
5 ng/L < P90
< 10 ng/L
P90 < 5 ng/L
pp90above
alio 1
pp90above
alio 2
pp90above
alio 3
pp90above
alio 4
pp90above
alio 5
Has LSLs
25.2%
16.8%
13.8%
6.5%
1.8%
No LSLs
22.2%
23.1%
21.1%
6.5%
0.5%
Acronyms: LCRI = Lead and Copper Rule Improvements; LSL = lead service line; P90 = lead 90th percentile level.
Source: "Likelihood_Sample_Above_AL_LCRI_DSSA_Final.xlsx." Also see Chapter 3, Section 3.3.5.3.2 for addition
detail.
The causes of, and associated solutions to, localized elevated lead concentrations within a distribution
system are varied and location-specific. To estimate model-PWS costs, the EPA developed the following
assumptions about how model-PWSs would respond to the final LCRI DSSA requirements:
1. The first year, after CCT installation or CCT re-optimization, that a model-PWS has a tap sample
above 10 ng/L, the PWS will investigate but take no corrective action.
2. The second year, after CCT installation or CCT re-optimization, that a model-PWS has a tap
sample above 10 ng/L, it will flush the distribution system in the affected area to reduce water
age, improving CCT, and lower lead concentration levels.
3. The third year, after CCT installation or CCT re-optimization, that a model-PWS has a tap sample
above 10 ng/L, it will adjust pH at one EP to the distribution system. This is the final action a
model-PWS with only one EP will take in response to the DSSA requirement.
21 See Chapter 4, Section 4.3.2.1.1 for a discussion of sampling frequencies and monitoring schedules.
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October 2024
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4. The fourth year, after CCT installation or CCT re-optimization, if a model-PWS, with more than
one EP, has a tap sample above 10 ng/L, it will adjust pH at its remaining EPs. This is the final
action any model-PWS will take in response to the DSSA requirement.
Therefore, within the SafeWater LCR model, if a model-PWS with re-optimized CCT in place (Step 31) has
at least one lead tap sample above 10 ng/L in a given year (Step 32), its response will depend on the
DSSA activity it took in prior years:
If this is the first year the model-PWS has at least one lead tap sample above 10 ng/L (Step 33), it will
investigate the issue but take no corrective actions. The SafeWater LCR model will make no change to
the model-PWS's P90y+l-range due to DSSA (Step 41). The model-PWS will move to the next year-loop
(Step 44).
If this is the second year the model-PWS has at least one lead tap sample above 10 ng/L (Step 34), it will
flush its distribution system once to reduce lead levels (Step 37). The SafeWater LCR model will make no
change to the model-PWS's P90y+l-range due to DSSA (Step 41). The model-PWS will move to the next
year-loop (Step 44).
If this is the third year the model-PWS has at least one lead tap sample above 10 ng/L (Step 35), it will
adjust the pH at one EP (Step 38). If the model-PWS has multiple EPs, the SafeWater LCR model will
make no change to the model-PWS's P90y+l-range due to DSSA (Step 41). If, on the other hand, the
model-PWS has only one EP (Step 40), then the SafeWater LCR model will set the model-PWS's P90y+1-
range to reflect the improved system-wide corrosion control (Step 44). In both cases, the model-PWS
will move to the next year-loop (Step 44).
If this is the fourth year the model-PWS has at least one lead tap sample above 10 ng/L (Step 36), and
the model-PWS has not yet modified pH at all EPs (Step 39), then the model-PWS will adjust pH at its
remaining EPs (Step 42). The SafeWater LCR model will set its P90y+l-range to reflect the improved
corrosion control system-wide (Step 43). The model-PWS will then move to the next year-loop (Step 44).
Final LCR! Economic Analysis Appendices
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Exhibit B-8: Simulating DSSA Requirements under the final LCRI in SafeWater LCR
Final LCRI Economic Analysis Appendices B-19 October 2024
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B.4 Estimating Compliance Activity Under the 2021 LCRR
In order to maintain consistency between how the SafeWater LCR model estimates the costs for the
final LCRI and the 2021 LCRR, certain parts of the cost model remain constant across rule scenarios,
including the baseline characteristics of the model-PWSs, the analysis period and discount rates, how
very large systems are modeled, the assignment of the model-PWS's initial P90, the likelihood a single
sample is greater than the AL of (10 ng/L under the final LCRI and 15 ng/L under the 2021 LCRR), and
how changes in source water or treatment changes impact the PWS's P90y+i. Therefore, these elements
are not repeated in this section.
In addition, the EPA estimated the costs of the 2021 LCRR under the same low cost and high scenarios
used to estimate the final LCRI costs. The low scenario and high scenario differ in their assumptions
made about: 1) the number of PWS above the AL (or TL under the 2021 LCRR); 2) the cost of installing
and optimizing CCT; and 3) the cost of replacing SL with lead content.
This section describes the modeling framework for the 2021 LCRR that the SafeWater LCR model
employs to determine if a model-PWS will take an action that will change its P90-range, which in turn
will change other actions the model-PWS will be required to take.
B.4.1 Small CWS and NTNCWS Flexibility
The 2021 LCRR included flexibility for CWSs that serve 10,000 or fewer people, and all NTNCWSs. If
these PWSs have a P90-range greater than the AL, they can choose from three options to reduce the
concentration of lead in their water:22
1. Replace 7 percent of their baseline number of SLs with lead content per year until all SLs with
lead content are replaced.23
2. Optimize existing CCT or install new CCT.
3. Provide POU devices to all customers.
For modeling purposes, the EPA assigns a compliance cost to all systems that exceed the ALE in the
SafeWater LCR model. The EPA uses a cost minimization assumption in the model, and assigns the least
cost alternative between the SLR, CCT, and POU compliance alternatives.
22 The fourth option is available to CWSs serving 3,300 or fewer people and NTNCWSs that have control over their
entire plumbing system. These systems may choose to remove all lead-bearing plumbing material. The EPA did not
include this option in the cost analyses due to data constraints. The EPA lacks the system characteristic data that
would allow the agency to determine a small system's cost for replacement of lead-bearing plumbing materials
because of the significant variability among systems and the plumbing materials in the buildings they serve.
Therefore, this option is not included in the model. The EPA assumes that systems selecting this compliance
alternative would have lower costs than if they had changed their CCT or provided POU devises.
23 States may, under the LCRR, require small CWSs to remove more than 7 percent of LSLs per year. However, for
modeling purposes, the EPA assumed 7 percent per year.
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B.4.2 Corrosion Control and Point-of-Use Technology
After the SafeWater LCR model determines whether a model-PWS's P90y+i-range will be affected by a
change in source water or treatment technology, the model continues within the year-loop and begins
the process of determining whether the model-PWS will install CCT, re-optimize CCT, or install POU
devices (in the case of small CWSs or all NTNCWSs). The SafeWater LCR model uses the model-PWS's
P90y+i-range rather than the current year-loop's initial P90-range (P90y-range) to determine if the PWS
will install CCT, re-optimize CCT, or install POU. This is because the EPA assumes that if a PWS proposes
a significant change in water source or a change in treatment technology, the State will require the PWS
to determine the impact of the change on lead levels, and take any corrective measures (installing CCT,
re-optimizing CCT, or installing POU) before making the change in source water or treatment
technology. Therefore, the SafeWater LCR model assumes that a change of water source or treatment
technology would never lead to an ALE, as the PWS would implement, if needed, appropriate CCT or
POU (if eligible) prior to the change.
The SafeWater LCR model keeps track of the model-PWS's CCT status throughout the period of analysis.
Once a model-PWS with existing CCT24 re-optimizes its CCT, or a model-PWS without CCT installs CCT,
the EPA assumes that the CCT is optimized and no further changes to CCT will be needed.25 Therefore, as
the SafeWater LCR model continues within its year-loop (see Exhibit B-9), it determines whether the
model-PWS has already re-optimized its existing CCT, or installed new CCT, and therefore has optimized
CCT in place (Step 10). If it does, then the SafeWater LCR model makes no change to CCT in place and to
the model-PWS's P90y+i-range due to CCT (Step 22) and the model-PWS moves on to the next stage of
the year-loop (Step 27).
Model CWSs serving more than 10,000 people with a P90y+i-range greater than the AL (Step 11) and
existing CCT in place (Step 16) will re-optimize their existing CCT (Step 17). If they do not have existing
CCT in place (Step 16), they will install CCT (Step 19). The EPA assumes that both re-optimization of and
installation of CCT, due to an ALE, will occur four years after the ALE (y+4) because of the time required
to conduct a pipe loop study. The same is true for small model CWSs and all NTNCWS (Step 13) if CCT is
their least costly compliance strategy (Step 15). However, if POU is their least costly compliance strategy
(Step 20), the model-PWS will install POU (y+1) (Step 21). If POU and CCT are both not the model-PWS's
least costly compliance strategy, then the SafeWater LCR model makes no change to the model-PWS's
P90y+i-range due to CCT or POU (Step 22), and the model-PWS moves on to the next stage of the year-
loop (Step 27).
All model-PWSs that do not have optimized CCT (Step 10), have a P90y+i-range greater than the TL but
not greater than the AL (Steps 11 and 12), and have existing CCT in place (Step 14), will re-optimize their
CCT (Step 18). The EPA assumes re-optimization due to a trigger level exceedance (TLE) will occur three
years after the ALE (y+3) due to the time required to conduct a coupon study. If the model-PWS does
24 The population served by PWSs with existing CCT at the beginning of the period of analysis are assumed to be
exposed to lead concentrations associated with "partial" CCT in the EPA's benefit analysis (see Chapter 5).
25 EPA assumes, for modeling purposes, that once CCT is optimized, no further CCT changes will be required unless
the model PWS has multiple individual tap samples above the AL and is required to conduct DSSA the issues
leading to the exceedances, as discussed in this appendix in Section B.3.5.
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not have existing CCT (Step 14), it will take no action that results in the SafeWater LCR model changing
the PWS's P90y+i-range due to CCT (Step 22), and the model-PWS will move on to the next stage of the
year-loop (Step 27).
Once a model-PWS re-optimizes existing CCT, or installs CCT, SafeWater will adjust its P90-range to
reflect the effectiveness of the CCT in reducing lead levels (Steps 24, 25, and 26) before moving on to
the next stage of the year-loop (Step 27). The EPA assumes it will take two years after CCT installation or
re-optimization for the PWS's P90 levels to fall (y+6 for CCT installation or re-optimization due to an ALE;
y+5 for CCT re-optimization due to a TLE). The EPA further assumes that a PWS's P90 level will fall
immediately upon installation of POU (y+1).
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Exhibit B-9: Simulating Corrosion Control and Point-of-Use Technology under the 2021 LCRR
in SafeWater LCR
YES
22
No Change in
P90y+i-Range Due
to CCT or POU
25
Set
P90y+6-Range
To Reflect
Optimized CCT
18
Re-
Optimize
CCT in
Year y+3
26
Set
P90y+5-Range
To Reflect
Optimized CCT
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B.4.3 Replacements of Lead Content Service Line under the 2021 LCRR
The SafeWater LCR model keeps track of the number of lead content SLs a model-PWS still has in place
at the beginning of each year-loop. If a model-PWS does not have any SLs with lead content in place
(Step 28 in Exhibit B-10), then SafeWater will make no change to the model-PWS's P90y+i-range due to
SLRs (Step 28), and the model-PWS moves on to the next stage of the year-loop (Step 46).
If a model-PWS has SLs with lead content in place at the beginning of the year-loop (Step 28), the
requirements it faces depend on system size and type (Step 29). If the model-PWS is a CWS serving
10,000 or fewer people, or a NTNCWS (Step 29), its P90y-range is greater than the AL (Step 30), and SLR
is its least costly compliance option (Step 33), then it is required to replace 7 percent of its baseline
number of SLs with lead content each year (Step 34).26 If its P90y-range is not greater than the AL (Step
30), or SLR is not the least costly compliance option (Step 33), it will be required to replace SLs with lead
content when the system becomes aware that a household has replaced their side of the service line
(Customer Initiated SLR, see Step 40).27
If the model-PWS is not a CWS serving 10,000 or fewer people, or a NTNCWS (Step 29), its SLR
requirements depend on the model-PWS's P90y-range. If the model-PWS's P90y-range is greater than
the AL (Step 31), it is required to implement a mandatory SLR program replacing a rolling two-year
average of 3 percent of the unknown and known SLs with lead content per year. This rolling average
allows systems that experience SLR rate fluctuation to still meet a 3 percent replacement rate on
average for each two-year period while the water system is required to implement the SLR program. The
regulation also requires that a cumulative number of replacements be reached equal to 3 percent of the
sum of known lead, GRR, and lead status unknown service lines in the initial inventory, times the
number of years that elapsed between the system's first ALE and the date on which the system's lead
P90-range levels are at or below the AL for two years (four consecutive 6-month monitoring periods).
Because the EPA does not have information on the annual variation in replacement rates which systems
may experience when required to conduct mandatory replacement, the agency has assumed an annual
replacement rate of 3 percent (which equals a 3 percent rolling average value across all two-year time
periods)(Step 35).28 If its P90y-range is greater than the TL but not greater than the AL (Steps 31 and 32),
26 Under the 2021 LCRR, LSLR requirements (either mandatory or goal-based) do not allow PWSs to count test-outs
or partial LSLR. Therefore, the SafeWater LCR model assumes that model-PWSs required to conduct mandatory
SLR will replace 3 percent of their baseline LSL inventory annually (which includes only actual full physical SLRs),
and that model-PWSs subject to goal-based LSLR goals must meet these goals by replacing actual full physical LSLs.
The SafeWater LCR model does account for the cost associated with test-outs in the pre-2021 LCR cost estimation.
27 Under the 2021 LCRR, PWSs are required to replace the public side of the LSL if a homeowner replaces the
customer portion of the LSL. If a PWS has a mandatory or goal-based SLR program, this removal would count
towards their required or goal-based SLRs. If the PWS does not have an active SLR program, the PWS would still
incur the cost to replace the system side of the LSL.
28 The EPA's LSLR costs capture all estimated replacements required under the rule but because the assumed 3
percent annual rate may not capture the variation in SL replacement rate at water systems which could experience
higher rates of replacement in the first of any two-year period for the rolling average or could experience lower
rates of replacement in the first year of the two year rolling average period, the EPA's estimated discounted costs
may be under or over estimated.
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it is required to establish an annual SLR goal-based rate in consultation with the State (Step 36) and will
replace some number of SLs with lead content each year (Step 37). If the model-PWS fails to meet its
annual SLR goal-based rate (Step 38), it is required to undertake additional goal-based SLR program
outreach (Step 41). The quantity and types of additional outreach required depend on the number of
consecutive periods the model-PWS fails to meet its goal. If it meets its annual SLR goal-based rate (Step
38), it may stop the additional SLR program outreach (Step 41). If the model-PWS's P90y-range is not
greater than the TL (Step 32), it will be required to replace SLs with lead content when the system
becomes aware that a household has replaced their side of the service line (Step 40).
When a model-PWS replaces any SLs with lead content during the year (Steps 34, 35, 37, and 40), the
SafeWater LCR model determines whether, at the end of the year, the model-PWS has no more SLs with
lead content remaining (Step 42). If this is the case, the SafeWater LCR model sets the P90y+i-range to
not greater than the TL to reflect the impact of SLRs on lead concentrations (Step 45)29 and the model-
PWS moves on to the next stage of the year-loop (Step 46). If, at the end of the year, the model-PWS
still has SLs with lead content in place, the SafeWater LCR model will make no change to the model-
PWS's P90y+i-range due to SLR (Step 44), and the model-PWS moves on to the next stage of the year-
loop (Step 46).
29 Under the 2021 LCRR, when PWSs replace an LSL at a tap water sampling location, they are required to replace
that sampling location with a new sampling location that has an LSL. Therefore, it is likely that a PWS will not see a
decrease in their P90-range until most LSLs are removed. As a modeling assumption, the SafeWater LCR model
reduced a PWS's P90y+i-range only after all LSLs are removed.
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Exhibit B-10: Simulating Lead Service Line Replacements under the 2021 LCRR
44
No Change in
45
Set P90y+i-Range
P90y+i-Range Due
to Not Greater than
Tl fn Bpflpft
( mo
to LSLR
w
I L lu ncilcol
Removal of all LSLs
43
Stop Additional
LSLR Program
Outreach
B.4.4 Distribution System and Site Assessment (Find and Fix under the LCRR)
In addition to requiring PWSs to take compliance actions to reduce lead concentrations when their
system-wide P90 exceeds the TL or AL, the 2021 LCRR requires PWSs to find-and-fix distribution system
issues that cause a single lead tap water sample to exceed 15 jig/L. Although the 2021 LCRR requires any
PWS with tap water samples exceeding 15 |ig/L to identify and address localized elevated lead
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concentrations, the EPA assumes, for modeling purposes, that CCT-related find-and-fix30 requirements
will be addressed only after a PWS has optimized CCT in place. Therefore, if a model-PWS does not have
optimized CCT in place (Step 48 in Exhibit B-12) or does not have at least one lead tap sample above 15
Hg/L in the year (Step 49), then it is assumed to not make any CCT adjustments, and the SafeWater LCR
model will make no change to the model-PWS's P90y+i-range due to find-and-fix (Step 57). The model-
PWS will simply move to the next year-loop (Step 60, Exhibit B-12)
If a model-PWS does have optimized CCT in place, the SafeWater LCR model calculates the number of
tap samples that will be above 15 ng/L in the current year of the analysis as a binomial distribution
defined by the number of samples the model-PWS takes during the year and the likelihood that any
given sample will be greater than 15 ng/L (Step 49). The number of tap samples a model-PWS will take
in a year depends on the model-PWS's tap sampling frequency (semi-annual, or once every one, three,
or nine years) and the system size.31 Exhibit B-ll provides the likelihood that a single lead tap sample
will be above 15 ng/L, which varies by the model-PWS's P90y-range and lead content SL status.
Exhibit B-ll: Likelihood that a Single Tap Water Sample Will be in Each of the Five Bins Used
for Modelling Purposes under the 2021 LCRR
LSL Status
P90 >15 ng/L
12 ng/L < P90
< 15 ng/L
10 ng/L < P90
< 12 ng/L
5 ng/L < P90
< 10 ng/L
P90 < 5 ng/L
pp90above
a 115 1
pp90above
all5 2
pp90above
all5 3
pp90above
all5 4
pp90above
all5 5
Has LSLs
16.9%
9.3%
5.3%
3.1%
0.7%
No LSLs
22.2%
10.0%
7.9%
3.0%
0.4%
Acronyms: LCRR = Lead and Copper Rule Revisions; LSL = lead service line; P90 = lead 90th percentile level.
Notes:
For additional detail, see file "Likelihood_Sample_Above_AL_LCRR_Find_Fix_Final.xlsx," available in the docket at
EPA-HQ-OW-2022-0801 at www.regulations.gov. Also see Chapter 3, Section 3.3.5.3.1.
The causes of, and associated solutions to, localized elevated lead concentrations within a distribution
system are varied and location-specific. In order to estimate model-PWS costs, the EPA developed the
following assumptions about how model-PWSs would respond to the 2021 LCRR find-and-fix
requirements:
1. The first year, after CCT installation or CCT re-optimization, that a model-PWS has a tap sample
above 15 ng/L, the PWS will investigate but take no corrective action.
30 Note the 2021 LCRR rule refers to the assessment of individual locations in the distribution system with lead tap
samples exceeding the lead AL as find-and-fix. The final LCRI has updated the name of these requirements to
Distribution System and Site Assessment (DSSA) to better match the intent of the required actions.
31 See Chapter 3, Section 3.3.7 for a discussion of sampling frequencies and monitoring schedules.
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2. The second year, after CCT installation or CCT re-optimization, that a model-PWS has a tap
sample above 15 ng/L, it will flush the distribution system in the affected area to reduce water
age, improving CCT, and lower lead concentration levels.
3. The third year, after CCT installation or CCT re-optimization, that a model-PWS has a tap sample
above 15 ng/L, it will adjust pH at one EP to the distribution system. This is the final action a
model-PWS with only one EP will take in response to the find-and-fix requirement.
4. The fourth year, after CCT installation or CCT re-optimization, if a model-PWS, with more than
one EP, has a tap sample above 15 ng/L, it will adjust pH at its remaining EPs. This is the final
action any model-PWS will take in response to the find-and-fix requirement.
Therefore, within the SafeWater LCR model, if a model-PWS with re-optimized CCT in place (Step 48 in
Exhibit B-12) has at least one lead tap sample above 15 ng/L in a given year (Step 49), its response will
depend on the find-and-fix activity it took in prior years:
1. If this is the first year the model-PWS has at least one lead tap sample above 15 ng/L (Step 49),
it will investigate the issue but take no corrective actions. The SafeWater LCR model will make
no change to the model-PWS's P90y+l-range due to find-and-fix (Step 57). The model-PWS will
move to the next year-loop (Step 60).
2. If this is the second year the model-PWS has at least one lead tap sample above 15 ng/L (Step
50), it will flush its distribution system once to reduce lead levels (Step 53). The SafeWater LCR
model will make no change to the model-PWS's P90y+l-range due to find-and-fix (Step 57). The
model-PWS will move to the next year-loop (Step 60).
3. If this is the third year the model-PWS has at least one lead tap sample above 15 ng/L (Step 51),
it will adjust the pH at one EP (Step 54). If the model-PWS has multiple EPs, the SafeWater LCR
model will make no change to the model-PWS's P90y+l-range due to find-and-fix (Step 57). If,
on the other hand, the model-PWS has only one EP, then the SafeWater LCR model will set the
model-PWS's P90y+l-range to reflect the improved system-wide corrosion control (Step 59). In
both cases, the model-PWS will move to the next year-loop (Step 60).
4. If this is the fourth year the model-PWS has at least one lead tap sample above 15 ng/L (Step
52), and the model-PWS has not yet modified pH at all EPs (Step 55), then the model-PWS will
adjust pH at its remaining EPs (Step 58). The SafeWater LCR model will set its P90y+l-range to
reflect the improved corrosion control system-wide (Step 59). The model-PWS will then move to
the next year-loop (Step 60).
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Exhibit B-12: Simulating Distribution System Assessment Costs under the 2021 LCRR in
Safe Water
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B.5 Detailed Public Water System Costing Approach for the 2021 LCRR
This section details how the EPA estimated the cost of water system compliance for each major rule
component of the LCRR. To more easily compare the costing approaches between the 2021 LCRR and
final LCRI, Section B.5 is organized similarly to Section 4.3 in Chapter 4 and includes the following
sections:
• B.5.1: PWS Implementation and Administrative Costs
• B.5.2: PWS Sampling Costs
• B.5.3: PWS Corrosion Control Costs
• B.5.4: PWS Lead Service Line Inventory and Replacement Costs
• B.5.5: PWS POU-Related Costs
• B.5.6: PWS Lead Public Education, Outreach, and Notification Costs
For most activities, water systems will incur costs in the form of burden (i.e., hours). The burden is
multiplied by the labor rate ($/hr), as presented in Chapter 3, Section 3.3.11.1, to estimate labor unit
costs. Systems will also incur capital and operation and maintenance (O&M) costs for some activities.
Exhibit B-13 shows all the components, subcomponents, and activities from Exhibit 4-6 in Chapter 4 for
the final LCRI. For each major rule component, each activity has a unique letter identification (ID). The
differences in activities costed for the final LCRI and the 2021 LCRR are identified as follows: 1) gray
shading italicized text indicates new activities under the final LCRI that are not part of the 2021 LCRR
requirements; and 2) yellow shaded activities in bold are specific to the 2021 LCRR and are not included
in the final LCRI requirements.
Exhibit B-13: PWS Cost Components, Subcomponents, and Activities Organized by Section for
the 2021 LCRR1
Component
Subcomponents
Activities2
B.5.1: PWS
None.
o)
Read and understand the rule.
Implementation and
b)
Assign personnel and resources for rule implementation.
Administrative
c)
Participate in training and technical assistance provided
Costs under the
by the State during rule implementation.
2021LCRR
d)
Provide small system flexibility option recommendation
to the State.
B.5.2: PWS
B.5.2.1: PWS Lead Tap
a)
Update sampling instructions for lead tap sampling and
Sampling Costs
Sampling under the 2021
submit to the State.
under the 2021
LCRR
b)
Contact homes to establish new 100 percent LSL tap
LCRR
c)
d)
e)
f)
g)
sampling pool.
Submit tap sampling plan to the State.
Report any changes in sampling locations to the State.
Confer with the State on initial lead sampling data and
status under the rule.
Obtain households for each round of lead tap sampling.
Offer incentives to households to encourage
participation in lead tap sampling program.
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Component
Subcomponents
Activities2
h)
i)
Ship tap sampling material and instructions to
participating households.
Collect lead tap samples.
j)
Determine if a sample should be rejected and not
analyzed.
k)
Analyze lead tap samples in-house or commercially.
1)
Prepare and submit sample invalidation request to the
State.
m)
Inform consumers of tap sample results.
n)
Certify to the State that results were reported to
consumers.
o)
Submit request to renew 9-year monitoring waiver to
the State.
P)
Submit sampling results and 90th percentile calculation
to the State.
q)
Oversee the customer-initiated lead sampling program.
r)
Ship tap sampling material and instructions to
participating households for customer-initiated lead
sampling program.
s)
Collect lead tap samples for customer-initiated lead
sampling program.
t)
Analyze lead tap samples in-house or commercially for
customer-initiated lead sampling program.
u)
Inform customers of lead tap sample results for
customer-initiated lead sampling program.
B.5.2: PWS
B.5.2.2: PWS Lead Water
v)
Collect lead WQP samples from the distribution system.
Sampling Costs
Quality Parameter
w)
Analyze lead WQP samples from the distribution
(continued)
Monitoring under the
system.
2021LCRR
X)
y)
z)
Collect lead WQP samples from entry points.
Analyze lead WQP samples entry points.
Report lead WQP sampling data and compliance with
OWQPs to the State.
B.5.2.3: PWS Copper
aa)
Collect copper WQP samples from the distribution
Water Quality Parameter
system.
Monitoring under the
bb)
Analyze copper WQP samples from the distribution
2021LCRR
cc)
dd)
ee)
system.
Collect copper WQP samples from entry points.
Analyze copper WQP samples from entry points.
Report copper WQP sampling data and compliance with
OWQPs to the State.
B.5.2.4: PWS Source
ff)
Collect source water samples.
Water Monitoring under
gg)
Analyze source water samples.
the 2021LCRR
hh)
Report source water monitoring results to the State.
0: CWS School and Child
ii)
Create a list of schools and child care facilities served by
Care Lead Sampling Costs
CWS and submit to State.
under the 2021 LCRR-
jj)
Develop lead outreach materials for schools and child
First Five-Year Cycle
kk)
ID
care facilities.
Prepare and distribute initial letters explaining the
sampling program and the EPA's 3Ts Toolkit.
Contact elementary school or child care facility to
determine and finalize its sampling schedule (one-time)
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Component
Subcomponents
Activities2
or contact secondary school to offer sampling (annual).
mm) Contact school or child care facility to coordinate
sample collection logistics.
nn) Conduct walkthrough at school or child care facility
before the start of sampling.
oo) Travel to collect samples.
pp) Collect samples.
qq) Analyze samples.
rr) Provide sampling results to tested facilities.
ss) Discuss sampling results with the school or child care
facility.
tt) Conduct detailed discussion of high sampling results
with school and child care facilities.
uu) Report school and child care facility sampling results to
the State.
vv) Prepare and provide annual report on school and child
care facility sampling program to the State.
B.5.2: PWS
B.5.2.5.2: CWS School
ww) Update the list of schools and child care facilities and
Sampling Costs
and Child Care Facility
submit to the State.
under the 2021
Lead Sampling Costs
xx) Contact schools and child care facilities to offer
LCRR (continued)
under the 2021 LCRR -
sampling.
Second Five-Year Cycle
yy) Contact the school or child care facility to coordinate
On
sample collection logistics,
zz) Conduct walkthrough at school or child care facility
before the start of sampling,
aaa) Travel to collect samples,
bbb) Collect samples,
ccc) Analyze samples.
ddd) Provide sampling results to tested facilities,
eee) Discuss sampling results with the school and child care
facility.
fff) Conduct detailed discussion of high sampling results
with schools and child care facilities.
ggg) Report school and child care facility sampling results to
the State.
hhh) Prepare and provide annual report on school and child
care facility sampling program to the State.
B.5.3: PWS
B.5.3.1: CCT Installation
a) Conduct a CCT study.
Corrosion Control
b) Install CCT (PO4, PO4 with post treatment, pH
Costs under the
adjustment, or modify pH).
2021LCRR
B.5.3.2: Re-optimization
c) Revise CCT study.
of Existing Corrosion
d) Re-optimize existing CCT.
Control Treatment
B.5.3.3: Find-and-Fix
e) Contact customers and collect follow-up tap sample.
Costs
f) Analyze follow-up lead tap sample.
g) Collect distribution system WQP sample.
h) Analyze distribution system WQP sample.
i) Review incidents of systemwide event and other system
conditions.
j) Consult with the State prior to making CCT changes.
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Component
Subcomponents
Activities2
k) Report follow-up sample results and overall "find-and-
fix"3 responses to the State.
B.5.3.4: System Lead CCT
Routine Costs
1) Review CCT guidance.
m) Provide WQP data to the State and discuss during
sanitary survey,
n) Notify and consult with the State on required actions in
response to source water change,
o) Notify and consult with the State on required actions in
response to treatment change.
B.5.4: PWS Lead
Service Line
Inventory and
Replacement Costs
under the 2021
B.5.4.1: Service Line
Inventory-Related
Activities
a) Conduct records review for connector materials.
b) Compile and submit connector updated LCRR initial
inventory information (baseline inventory) to the State.
c) Identify material for unknown service lines.
d) Report annual inventory updates to the State.
LCRR
e) Conduct field investigations for inventory validation.
f) Report validation results to State.
B.5.4.2: Service Line
Replacement Plan
g) Develop initial SLR plan and submit to the State for
review.
h) Identify funding options for full SLRs.
i) Include information on deferred deadline and associated
replacement rate in the SLR plan.
j) Update SLR plan annually or certify no changes.
k) Provide an updated recommendation of the deferred
deadline and associated replacement rate.
B.5.4.3: Physical Service
Line Replacements
1) System replaces lead and GRR service lines.
B.5.4.4: Ancillary Service
Line Replacement
Activities
m) Contact customers and conduct site visits prior to service
line replacement,
n) Deliver filters and 6 months of replacement cartridges at
time of service line replacement,
o) Collect tap sample post-service line replacement,
p) Analyze post-service line replacement tap sample,
q) Inform customers of tap sample result,
r) Submit annual report on service line replacement
program to the State.
B.5.4.5: Goal-Based
Replacement Program
Activities
s) Consult with the State and develop targeted SLR
program outreach materials,
t) Distribute targeted SLR program outreach materials,
u) CWS replaces its portion of lead or GRR service line,
v) Household replaces privately-owned portion of the lead
or GRR service line,
w) Consult with State on activities to satisfy additional
goal-based SLR program outreach requirements if CWS
> 10,000 fails to meet goal,
x) Conduct activities in response to the first failure to
meet SLR goal.
y) Conduct activities in response to each additional failure
to meet SLR goal.
B.5.5: PWS POU-
Related Costs under
the 2021LCRR
B.5.5.1: POU Device
Installation and
Maintenance
a) Provide, monitor, and maintain POU devices.
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Component
Subcomponents
Activities2
B.5.5.2: POU Ancillary
Activities
b) Develop POU plan and submit to the State.
c) Develop public education materials and submit to the
State.
d) Print POU education materials.
e) Obtain households for POU monitoring.
f) Deliver POU monitoring materials and instructions to
participating households.
g) Collect tap samples after POU installation.
h) Determine if sample should be rejected and not analyzed
i) Analyze POU tap samples.
j) Prepare and submit sample invalidation request to the
State.
k) Inform customers of POU tap sample results.
1) Certify to the State that POU tap results were reported
to customers.
m) Prepare and submit annual report on POU program to
the State.
B.5.6: PWS Lead
Public Education,
Outreach, and
Notification Costs
under the 2021
LCRR
B.5.6.1: Consumer Notice
a) Develop lead consumer notice materials and submit to
the State for review.
b) Provide a copy of the consumer notice and certification
to the State.
B.5.6.2: Activities
Regardless of Lead 90th
Percentile Level
c) Update CCR language.
d) Develop new customer outreach plan.
e) Develop approach for improved public access to lead
health-related information and tap sample results.
f) Establish a process for public access to information on
known or potential lead content SL locations and tap
sample results.
g) Maintain a process for public access to lead health
information, known or potential lead content SL
locations, and tap sample results.
h) Respond to customer request for known or potential
lead content SL information.
i) Respond to requests from realtors, home inspectors, and
potential home buyers for known or potential lead
content SL information.
j) Develop a list of local and State health agencies.
k) Develop lead outreach materials for local and State
health agencies and submit to the State for review.
1) Deliver lead outreach materials for local and State health
agencies.
m) Develop public education materials for known or
potential lead content SL disturbances and submit to the
State.
n) Deliver public education for SL disturbances.
o) Deliver filters and 6 months of replacement cartridges
during disturbances of SLs.
p) Develop inventory-related outreach materials and
submit to the State for review.
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Component
Subcomponents
Activities2
q) Distribute inventory-related outreach materials.
r) Provide translation services for public education
materials.
B.5.6: PWS Lead
Public Education,
Outreach, and
Notification Costs
under the 2021
LCRR (continued)
s) Certify to the State that lead outreach was completed.4
B.5.6.3: Activities in
Response to Lead ALE
t) Update mandatory language for lead ALE public
education and submit to the State for review,
u) Deliver lead ALE public education materials to all
customers,
v) Post notice to website,
w) Prepare press release.
x) Contact public health agencies to obtain additional
organizations and update recipient list,
y) Notify public health agencies and other organizations,
z) Consult with State on other public education activities,
aa) Implement other public education activities.
Public Education
Activities in Response to
Multiple Lead ALEs
bb) Develop plan for making filters available and submit to
the State for review.
cc) Develop outreach materials for systems with multiple
lead ALEs and submit to the State for review.
dd) Conduct enhanced public education for systems with
multiple lead ALEs.
ee) Consult with State on filter program for systems with
multiple lead ALEs.
ff) Administer filter program for systems with multiple lead
ALEs.
gg) Make filters available due to multiple lead ALEs.
Acronyms: ALE = action level exceedance; CCR = Consumer Confidence Report; CCT = corrosion control treatment;
CWS = community water system; DSSA = Distribution System and Site Assessment; EPA = Environmental protection
Agency; GRR = galvanized requiring replacement; LCRR = Lead and Copper Rule Revisions; LSL = lead service line;
OCCT = optimal corrosion control treatment; OWQPs = optimal water quality parameters; POU = point-of-use; PO4
= orthophosphate; PWS = public water system; SDWIS/Fed = Safe Drinking Water Act Information System/Federal
version; SL = service line; SLR = service line replacement; WQP = water quality parameter.
Notes:
1 Systems will also incur burden for recordkeeping activities under the 2021 LCRR, such as retaining records of
decisions, supporting documentation, technical basis for decisions, and documentation submitted by the system.
The EPA has included burden for recordkeeping with each activity when applicable and opposed to providing
separate burden estimates.
2The EPA assigned a unique letter ID for each activity under a given rule component. Activities are generally
organized with upfront, one-time activities first followed by ongoing activities. The lettering follows that used for
the final LCRI, in Chapter 4, Exhibit 4-6, with the exception of activities that apply to the 2021 LCRR but not the
final LCRI.
3 Under the final LCRI, the term "find-and-fix" is replaced with Distribution System and Site Assessment.
4This certification is inclusive of outreach activities in Sections B.5.6.1 through B.5.6.3.
As was done in Chapter 4, Appendix B includes at the end of each subsection, a summary exhibit
showing the SafeWater LCR modeling approach for each water system activity (e.g., Exhibit B-15). The
exhibits follow the organization of the corresponding exhibits in Chapter 4 (e.g., Exhibit B-15 mirrors
Chapter 4, Exhibit 4-8) and are organized as follows:
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• The first and second columns show how unit burden and labor rate information is combined to
estimate a CWS and NTNCWS cost per activity, respectively.
• The third and fourth columns indicate the conditions under which the water system activity
occurs. The columns indicate if the system activity is dependent on:
o The system's 90th percentile range. See Appendix B, Section B.4 for a detailed discussion
of how the SafeWater LCR model tracks a water system's 90th percentile level and
accounts for changes in the 90th percentile level over the 35-year analysis period.
o Other characteristics of the system such as presence or absence of SLs with lead content
and/or CCT, and frequency of monitoring.
• The fifth column indicates the frequency of the activity (e.g., one-time, annually, every 3 years).
In those instances where the costing approach for a specific activity is the same under the 2021 LCRR
and final LCRI, the exhibit directs the reader to the corresponding final LCRI exhibit in Chapter 4.
The SafeWater LCR uses the information from these exhibits to calculate total annualized water system
cost for each activity. See Sections B.2 and B.4 for detail on the cost modeling methodology.
B.5.1 PWS Implementation and Administrative Costs under the 2021 LCRR
The EPA has developed costs for system implementation and administrative activities under the 2021
LCRR, as shown in Exhibit B-14. The third column provides the corresponding SafeWater LCR model data
variable in red/italic font. The last column indicates whether the activity, unit burden or cost, and
SafeWater LCR data variable are identical to those used for the final LCRI, as described in Chapter 4,
Section 4.3.1.1. The assumptions that differ for the 2021 LCRR from final LCRI are provided in notes to
the exhibit. Note that for activity d), the unit burden to provide a small system flexibility option to the
State is the same under the 2021 LCRR as the final LCRI; however, the activity occurs in Year 1 of the 35-
year analysis period under the 2021 LCRR and Year 4 under the final LCRI. Also, the requirement is for
the subset of CWSs serving 10,000 or fewer people and NTNCWSs exceeding the TL of 10 ng/L under the
LCRR. Under the final LCRI, this requirement applies to CWSs serving 3,300 or fewer people and
NTNCWSs that exceed the final lead AL of 10 ng/L.
The EPA recognizes that systems would also incur administrative burden related to specific
requirements under the 2021 LCRR. In these cases, the system burden is estimated under that rule
requirement.
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Exhibit B-14: PWS One-Time Administration Activities and Unit Burden Estimates under the
2021LCRR
Activity
Unit Burden and/or Cost
(hours/system)
SafeWater LCR Data
Variable
Same As
Final LCRI?
a) Read and understand Rule
N/A. Occurred prior to the start of the 35-year analysis
period.
b) Assign personnel and resources for
rule implementation
N/A. Occurred prior to the start of the 35-year analysis
period.
c) Participate in training and technical
assistance provided by the State
during rule implementation
N/A. Occurred prior to the start of the 35-year analysis
period.
d) Provide small system flexibility
option recommendation to the State
12 hrs/CWSs serving
<10,000 and all NTNCWSs
hrs_smJex_option_op
No.1
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule
mprovements; LCRR = Leac
and Copper
Rule Revisions; NTNCWS = non-transient non-community water system; PWS = public water system
Sources:
a)- c): The EPA assumes systems will already have incurred the burden for these activities prior to the start of the
35-year analysis period of the final LCRI. Based on implementation burden estimated for the EPA's 2012, Economic
Analysis for the Final Revised Total Coliform Rule (USEPA, 2012). Available in the docket at EPA-HQ-OW-2022-0801
at www.regulations.gov.
d): Association of State Drinking Water Administrators (ASDWA) 2024 Costs of States Transactions Study (CoSTS)
model (ASDWA, 2024).
Notes:
General: These data variables are also provided in "Administrative Burden and Costs_Final.xlsx."
1 Under the 2021 LCRR, this activity is assumed to occur in Year 1 of the 35-year analysis period and applies to
CWSs serving 10,000 or fewer people and NTNCWSs that exceed the lead TL of 10 ng/L. Under the final LCRI, the
activity is assumed to occur in Year 4 and applies to CWSs serving 3,300 or fewer people and NTNCWSs that exceed
the lead AL of 10 ng/L.
Exhibit B-15 provides the SafeWater LCR model cost estimation approach for system one-time PWS
administrative and rule implementation activities including additional cost inputs required to calculate
these costs. The gray shaded rows indicate activities that do not apply to the 2021 LCRR because they
occurred prior to the 35-year analysis period.
Exhibit B-15: PWS Administration and Rule Implementation Cost Estimation in SafeWater LCR
by Activity for the 2021 LCRR
CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply
to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other
Conditions
a) Read and understand the rule
N/A. Occurred prior to the start of the 35-year analysis period.
b) Assign personnel and resources for rule implementation
N/A. Occurred prior to the start of the 35-year analysis period.
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CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply
to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other
Conditions
c) Participate in training and technical assistance providec
implementation
by the State during rule
N/A. Occurred prior to the start of the 35-year analysis period.
d) Provide small system flexibility option recommendation to the State
The total hours per system multiplied
by the system labor rate.
(hrs_sm_flex_option_op*rate_opy
Cost applies as
written to NTNCWSs.
Above TL
CWSs serving <
10,000 people
and NTNCWSs
One time
Acronyms: CWS = community water system; LCR = Lead and Copper Rule; LCRR = Lead and Copper Rule revisions;
NTNCWS = non-transient non-community water system; PWS = public water system; TL = trigger level.
Notes:
1 See Chapter 3, Section 3.3.11.1 for a definition of PWS hourly labor rate (rate_op).
B.5.2 PWS Sampling Costs under the 2021 LCRR
This section provides system unit burden and cost for lead tap sampling, lead water quality parameter
(WQP) monitoring, copper WQP monitoring, source water monitoring, and sampling in schools and child
care facilities under the 2021 LCRR in Sections B.5.2.1 through B.5.2.5, respectively.
B.5.2.1 PWS Lead Tap Sampling under the 2021 LCRR
The discussion of lead tap sampling costs for water systems is presented in the following subsections:
• B.5.2.1.1: Lead Tap Sampling Schedules and Required Number of Samples
• B.5.2.1.2: Lead Tap Sampling Activities
Activities and costs for tap monitoring associated with the POU program are not included in this section
but are provided in Section B.5.5.
B.5.2.1.1 Lead Tap Sampling Schedules and Required Number of Samples
All CWSs and NTNCWSs are subject to lead tap sampling requirements. The frequency and required
number of samples depend on the systems' lead 90th percentile level but all systems with LSLs, GRRs, or
unknown lines are assumed to conduct one year of semi-annual monitoring at the start of the rule
(assumed to be Year 1). Systems with all non-lead service lines that are at or below the lead AL of 15
Hg/L and above the lead TL of 10 ng/L are required to begin annual monitoring starting in Year 1.
Systems with all non-lead service lines that are above the lead AL of 15 ng/L are required to begin semi-
annual monitoring starting in Year 1. For systems at or below the lead TL of 10 ng/L, the EPA assumed
systems will retain their monitoring schedule form the pre-2021 LCR from Year 1 onward.
Under the 2021 LCRR after Year 1, only systems with a 90th percentile level at or below the TL of 10 ng/L
can qualify to conduct lead tap sampling at the reduced number of sites annually, triennially, or every 9
years. The EPA estimated the percentages of systems with a 90th percentile level at or below 10 ng/L
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that would be on semi-annual monitoring,32 and on a reduced annual (p_tap_annual), triennial
(p_tap_triennial), or 9-year (p_tap_nine) monitoring schedule based on historical SDWIS/Fed data.
Those with a lead ALE must conduct lead tap sampling every six months at the standard number of
sample sites (i.e., standard semi-annual monitoring); those with a lead TLE (i.e., 90th percentile value
above 10 ng/L but at or below 15 ng/L) must sample annually at the standard number of sites. In
addition, systems must sample for a minimum of two, six-month tap sampling monitoring periods
following a change in source water or significant or long-term change in treatment. Because the number
of required sampling sites and sampling schedules can vary, costs are estimated separately for systems
on the different lead tap sampling monitoring schedules. Chapter 3, Sections 3.3.7.2 and 3.3.7.3
provides the EPA's approach for determining the initial tap monitoring requirements under the 2021
LCRR and final LCRI, respectively.
The minimum required standard number of tap samples (numb_samp_customer) or reduced number of
samples (numb_reduced_tap) is the same under the pre-2021 LCR, 2021 LCRR, and final LCRI. Refer to
Exhibit 4-9 in Chapter 4 for the minimum number of tap samples for CWSs and NTNCWSs on standard
monitoring and reduced monitoring schedules.
B.5.2.1.2 Lead Tap Sampling Activities
The EPA has developed costs for system activities associated with lead tap sampling under the 2021
LCRR, as shown in Exhibit B-16. The exhibit provides the unit burden and/or cost for each activity. The
third column provides the corresponding SafeWater LCR model data variable in red/italic font. In a few
instances, some of these activities are conducted by the State instead of the water system. These
activities are identified in the exhibit and further explained in the exhibit notes. The last column
indicates whether the activity, unit burden or cost, and SafeWater LCR data variable are identical to
those used for the final LCRI, as described in Chapter 4, Section 4.3.2.1.2. The assumptions that differ for
the 2021 LCRR from the final LCRI follow the exhibit. The gray shaded rows indicates an activity that is
not required under the 2021 LCRR. Note that this section does not pertain to CWSs serving 10,000 or
fewer and NTNCWSs that are using the POU provision and maintenance program as their lead
compliance option. These systems have some different lead tap sampling requirements that are
discussed in Section B.5.5.
Note that the conditions under which the sampling activities occur are different under the 2021 LCRR
compared to the final LCRI. The 2021 LCRR tap sampling frequency is a function of whether the 90th
percentile lead concentration is above the TL of 10 ng/L or above the AL of 15 ng/L. Under the final LCRI,
the tap sampling frequency is based on whether the 90th percentile lead concentration is above the final
lead AL of 10 ng/L, as discussed in Chapter 4, Section 4.3.2.1.2.
32 The likelihood that a system with a 90th percentile value at or below 10 ng/L being on an initial semi-annual
monitoring schedule is 1 minus (p_tap_annual + p_tap_triennial + p_tap_nine).
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Exhibit B-16: PWS Lead Tap Sampling Unit Burden and Cost Estimates under the 2021 LCRR
Activity
Unit Burden and/or
Cost1
SafeWater LCR Data
Variable
Same As Final
LCRI?
a) Update sampling instructions
for lead tap sampling and
submit to the State (one-time)
2 hrs/CWS and
NTNCWS
hrs_ devel_samp_ op2
Yes.
b) Contact homes to establish
new 100 percent LSLtap
sampling pool (one-time)
5 to 100 hrs/CWS with
LSLs
hrs_add_lsl_samp_op
Yes.
c) Update and submit tap
sampling plan (one-time)
• No LSLs: 2 to 6 hours
per PWS
• With LSLs: 8 to 20
hours per PWS
hrs_samp_plan_op
Yes.
d) Report any changes in
sampling locations to the State
3 hrs/CWS
hrs_chng_tap_op
Yes.
e) Confer with the State on initial
lead sampling data and status
under the rule (one-time)
2 hr/PWS
hrs_ in iti al_ tap_ confer_ op
Yes.
f) Obtain households for each
round of lead tap sampling
Burden per sample
(CWSs only)
No LSLs: 0.5 hrs
With LSLs: 1 hr
hrs_samp_ volun t_ op
Yes.
g) Offer incentives to households
to encourage participation in
lead tap sampling program
$10 to $100/sample per
CWS
costjncentive
Yes.
h) Ship tap sampling material and
instructions to participating
households
Burden per sample
(CWSs onlv)
0.25 hrs
Cost per sample (CWSs
onlv)
No LSLs: $8.57 to
$11.33
With LSLs: $8.96 to
$23.21
Burden
hrs_ discuss_samp_ op
Cost
cost_5_lt_samp3
Yes
i) Collect lead tap samples
Burden per sample
0.40 to 0.71 hrs per
CWS;
0.5 hrs per NTNCWS
Cost per sample
$5.75 to $10.24 per
CWS
Burden
hrs_pickup_samp_op
Cost
cost_pickup_samp
Yes.
j) Determine if a sample should
be rejected and not analyzed
0.25 hrs/rejected
sample for CWSs
hrs_samp_reject_op
Yes.
k) Analyze lead tap samples in-
house or commercially
In-house Analysis
(CWSs >100K onlv)
Burden: 0.44
hrs/sample
In-house Analysis
hrs_ an alyze_samp_ op3
cost_lab_lt_samp3
No. See
discussion that
follows this
exhibit.
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Activity
Unit Burden and/or
Cost1
SafeWater LCR Data
Variable
Same As Final
LCRI?
Cost: $3.92/sample
Commercial Analysis
(CWSs <100K and all
NTNCWSs)
$32.20/ sample
Commercial Analysis
cost_5_commercial_lab3
1) Prepare and submit sample
invalidation request to State
2 hrs per sample per
CWS and NTNCWS
hrs_samp_invalid_op
Yes.
m) Inform consumers of tap
sample results
CWS per sample
Burden: 0.05 to 0.11
hrs
Cost: $0.72
NTNCWS per sample
Burden: 1 hr
Cost: $0,079
CWS
hrs_inform_samp_op
cost_cust_lt
NTNCWS
hrs_ntncws_inform_samp_op
cost_ntncws_cust_lt
Yes.
n) Certify to the State that results
were reported to consumers
0.66 to 1 hr per CWS or
NTNCWS
hrs_cert_cust_lt_op
Yes.
o) Submit request to renew 9-
year monitoring waiver to the
State
1 hr/9 years per
qualifying CWS or
NTNCWS
hrs_renew_nine_op
Yes.
p) Submit sampling results and
90th calculation to the State
No LSLs: 2 to 3 hrs per
CWS and NTNCWS
With LSLs: 2.5 to 3.75
hrs per CWS and
NTNCWS
hrs_annual_lt_op3
Yes.
q) Oversee the customer-initiated
lead sampling program
N/A
hrs_cust_request_oversee_op
No. Not
required under
the 2021 LCRR.
r) Ship tap sampling material and
instructions to participating
households for customer-
initiated lead sampling
program
N/A
Burden
hrs_ discuss_samp_ op
Cost
cost_5_lt_samp3
No. Not
required under
the 2021 LCRR.
s) Collect lead tap samples for
customer-initiated lead
sampling program
N/A
Burden
hrs_pickup_samp_op
Cost
cost_pickup_samp
No. Not
required under
the 2021 LCRR.
t) Analyze lead tap samples in-
house or commercially for
customer-initiated lead
sampling program
N/A
In-house Analysis
hrs_ an alyze_samp_ op3
cost_lab_lt_samp3
Commercial Analysis
cost 5 commercial lab3
No. Not
required under
the 2021 LCRR.
u) Inform customers of lead tap
sample results for customer-
N/A
CWS
hrs_inform_samp_op
No. Not
required under
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Activity
Unit Burden and/or
Cost1
SafeWater LCR Data
Variable
Same As Final
LCRI?
initiated lead sampling
program
cost_cust_lt
the 2021 LCRR.
Acronyms: CWS = community water system; LCRR = Lead and Copper Rule Revisions; LCRI = Lead and Copper Rule
Improvements; LSL = lead service line; NTNCWS = non-transient non-community water system; PWS = public water
system.
Source: "Lead Analytical Burden and Costs_Final.xlsx." See Chapter 4, Section 4.3.2.1 for a summary of how the
unit burden is derived for each activity.
Notes:
1 All activities other than one-time activities are per monitoring period. In addition, many of the activities listed
above do not apply to NTNCWSs because unlike CWSs they collect their own samples from sampling locations
under their control and thus, are unlikely to change sampling sites or reject samples for analysis. They also do not
need to solicit sampling participation for customers or travel to their residences to pick up samples.
2 In Arkansas, Louisiana, Mississippi, Missouri, North Dakota, and South Carolina the State sends sampling
instructions to the water systems and thus are assumed to incur the burden to update the sampling instruction in
lieu of the system (ASDWA, 2020a).
3 In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the State pays for the cost of bottles, shipping,
analysis, and providing sample results to the system. Thus, the State will incur the burden and cost for these
activities in lieu of the system (ASDWA, 2020a).
k) Analyze lead tap samples in-house or commercially (hrs_analyze_samp_op, cost_lab_lt_samp,
cost_5_commercial_lab). Under both the 2021 LCRR and final LCRI, the EPA assumed that in-house
analyses for lead would only be conducted by CWSs serving more than 100,000 people and that all
other CWSs and all NTNCWSs would use a commercial laboratory. Under the 2021 LCRR, systems
must analyze a first-liter sample collected from non-lead service line sites and a fifth-liter sample
collected from sites served by an LSL for lead. Under the final LCRI, systems must analyze a first-liter
sample collected from non-lead service line sites but both a first- and fifth-liter sample from these
sites served by LSLs. Thus, the burden and cost for in-house analysis or commercial laboratory cost is
for one sample per LSL site under the 2021 LCRR as opposed to two under the final LCRI for LSL sites.
For the 2021 LCRR, the EPA assumed a per sample burden and cost for an in-house lead analysis of
0.44 hours (hrs_analyze_samp_op) and non-labor costs for analytical materials such as
preservatives, calibration standards, and quality assurance (QA) standards of $3.92 per sample
(cost_ lab_lt_samp). Under the final LCRI the burden and cost for a first- and fifth-liter sample is
double at 0.89 hours and $7.84.
The EPA assumed the per lead sample laboratory cost of $23.50 plus a cost of $8.70 to ship the
sample to the laboratory for a total per sample cost of $32.20 (cost_5_commercial_lab) for the
LCRR. For the final LCRI, the EPA increased this estimate for systems with LSLs to account for the
analysis and shipping of a first- and fifth-liter sample of $23.50*2 or $47.00 plus a cost to ship two
bottles to the laboratory at $10.20 for a total cost of $57.20 per sample.
Exhibit B-17 shows the SafeWater LCR model cost estimation approach for system lead tap sampling
activities under the 2021 LCRR. As shown in the exhibit, the SafeWater LCR model relies upon additional
inputs, such as number of samples for lead tap sampling and the likelihood a system is below an AL or
TL, to compute the cost per activity. It also indicates for which activities the costing approach is the
same as the final LCRI, as provided in Chapter 4, Exhibit 4-16, as well as which final LCRI activities do not
apply under the 2021 LCRR in gray shaded rows.
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Exhibit B-17: PWS Lead Tap Sampling Cost Estimation in SafeWater LCR by Activity under
2021 LCRR1,2
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
a) Update sampling instructions for lead tap sampling and submit to the State3
Same as final LCR! (see Exhibit 4-16 in Chapter 4).
b) Contact homes to establish new 100 percent LSL tap sampling pool
Same as final LCRI (see Exhibit 4-16 in Chapter 4).
c) Update and submit tap sampling plan to the State
Same as final LCRI (see Exhibit 4-16 in Chapter 4).
Final LCR! Economic Analysis Appendices
B-43
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
d) Report any changes in sampling locations to the State4
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
Twice per
year
1 - (p_tap_annual +
pjtapjtrienniai +
p_tap_nine)
Model PWS on
Total system hours per monitoring period
multiplied by the system labor rate.
(hrs_chng_tap_op*rate_op)
Cost does not
apply to
NTNCWSs.
At or
below TL
annual tap
sampling and not
doing POU
sampling
p_tap_annual
Once a
year
Model PWS on
triennial reduced
tap sampling and
not doing POU
sampling
Every 3
years
pjtapjtrienniai
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
Every 9
years
p_tap_nine
At or
below AL
and above
TL
All model PWSs
Once a
year
not doing POU
sampling
Above AL
All model PWSs
not doing POU
sampling
Twice a
year
e) Confer with the State on initial lead sampling data and status under the rule
Same as final LCRI (see Exhibit 4-16 in Chapter 4).
Final LCRI Economic Analysis Appendices
B-44
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
f) Obtain households for each round of lead tap sampling
The number of required samples per system
multiplied by the hours per sample and the
system labor rate. The number of required
samples is inflated to include those
unreturned, invalidated, and rejected to
ensure that the cost reflects the additional
burden that must occur to meet the
sampling requirement.
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
Twice per
year
(numb_samp_customer+(numb_samp_cust
omer*(1-
pp_hh_return_samp))+(numb_samp_custo
mer*pp_samp_invalid)+(numb_samp_custo
mer*pp_samp_reject))*(hrs_samp_volunt_o
p*rate_op)
Cost does not
apply to
NTNCWSs.
At or
below TL
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
Model PWS on
annual tap
sampling and not
doing POU
sampling
Once a
year
p_tap_annual
At or
below AL
and above
TL
All model PWSs
not doing POU
sampling
Once a
year
Above AL
All model PWSs
not doing POU
sampling
Twice per
year
The number of required samples per system
multiplied by the hours per sample and the
system labor rate. The number of required
samples is inflated to include those
unreturned, invalidated, and rejected to
ensure that the cost reflects the additional
burden that must occur to meet the
sampling requirement.
Model PWS on
triennial reduced
tap sampling and
not doing POU
sampling
Every 3
years
(numb_reduced_tap+(numb_reduced_tap*(1
pp_hh_return_samp))+(numb_reduced_tap*
pp_samp_invalid)+(numb_reduced_tap*pp_
samp reject))*(hrs samp volunt op*rate o
P)
Cost does not
apply to
NTNCWSs.
At or
below TL
p_tap_triennial
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
Every 9
years
p_tap_nine
Final LCRI Economic Analysis Appendices
B-45
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
g) Offer incentives to households to encourage participation in lead tap sampling program
The number of required samples per system
multiplied by the cost of the incentive. This
number is not inflated by the number of
samples deemed invalid or rejected
because it is assumed that if a sample is
invalid or rejected the system will return to
the same customer to resample. The EPA
also assumes that unreturned samples
would not be eligible for an incentive.
Numb_samp_customer*cost_incentive
Cost does not
apply to
NTNCWSs.
At or
below TL
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling that offers
an incentive
/I - (p_tap_annual
+ p_tap_triennial +
p_tap_nine)] *
pjncentive
Twice per
year
Model PWS on
annual tap
sampling and not
doing POU
sampling that offers
an incentive
Once a
year
p_tap_annual *
pjncentive
At or
below AL
and above
TL
Model PWS not
doing POU
sampling that offers
an incentive
Once a
year
Above AL
pjncentive
Twice per
year
The number of required samples per system
multiplied by the cost of the incentive. This
number is not inflated by the number of
samples deemed invalid or rejected,
because it is assumed that if a sample is
invalid or rejected the system will return to
the same customer to resample. The EPA
also assumes that unreturned samples
would not be eligible for an incentive.
Numb_reduced_tap*cost_incentive
Cost does not
apply to
NTNCWSs.
At or
below TL
Model PWS is on
triennial reduced
tap sampling and
not doing POU
sampling that offers
an incentive
p_tap_triennial *
pjncentive
Every 3
years
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling that offers
an incentive
Every 9
years
p_tap_nine *
pjncentive
Final LCRI Economic Analysis Appendices
B-46
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Lead 90th
- Range
Other Conditions2
h) Ship tap sample monitoring materials and instructions to participating households5
To calculate the
sampling
material costs
for NTNCWSs
this equation is
still used.
Number of
required
samples
multiplied by the
cost of materials
per sample. The
number of
required
samples is
inflated to
include those
invalidated to
ensure that the
cost reflects the
additional
burden that
must occur to
meet the
sampling
requirement.
Number of required samples multiplied by
the total of the hours per sample to provide
instructions times the system labor rate, plus
the cost of materials per sample. The
number of required samples is inflated to
include those unreturned, invalidated, and
rejected, to ensure that the cost reflects the
additional burden that must occur to meet
the sampling requirement.
(numb_samp_customer+(numb_samp_cust
omer*(1-
pp_hh_return_samp))+(numb_samp_custo
mer*pp_samp_invalid)+(numb_samp_custo
mer*pp_samp_reject))*((hrs_discuss_samp
_op*rate_op)+cost_5_lt_samp)
((numb_samp_c
ustomer+(numb
_samp_custom
er*pp_samp_inv
alid))*cost_5_lt_
samp)
At or
below TL
At or
below AL
and above
TL
Above AL
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
Model PWS on
annual tap
sampling and not
doing POU
sampling
p_tap_annual
All model PWSs
not doing POU
sampling
Twice per
year
Once a
year
Once a
year
Twice per
year
Final LCRI Economic Analysis Appendices
B-47
October 2024
-------
CWS Cost Per Activity
Number of required samples multiplied by
the total of the hours per sample to provide
instructions times the system labor rate, plus
the cost of materials per sample. The
number of required samples is inflated to
include those unreturned, invalidated, and
rejected, to ensure that the cost reflects the
additional burden that must occur to meet
the sampling requirement.
(numb_reduced_tap+(numb_reduced_tap*(1
pp_hh_return_samp))+(numb_reduced_tap*
pp_samp_invalid)+(numb_reduced_tap*pp_
samp_reject))*((hrs_discuss_samp_op*rate
_op)+cost_5_lt_samp)
i) Collect lead tap samples
The number of required samples per system
multiplied by the hours per sample and the
system labor rate. The number of required
samples is inflated to include those
invalidated and rejected to ensure that the
cost reflects the additional burden that must
occur to meet the sampling requirement.
(numb_samp_customer+(numb_samp_cust
omer*pp_samp_invalid)+(numb_samp_cust
omer*pp_samp_reject)+
(numb_samp_customer*(1-
NTNCWS Cost
Per Activity
To calculate the
sampling
material costs
for NTNCWSs
this equation is
still used.
Number of
required
samples
multiplied by the
cost of materials
per sample. The
number of
required
samples is
inflated to
include those
invalidated to
ensure that the
cost reflects the
additional
burden that
must occur to
meet the
sampling
requirement.
((numb_reduce
d_tapr+(numb_r
educed_tap*pp_
samp_ir>valid))*
cost_5_lt_samp
)
Conditions for Cost to
Apply to a Model PWS
Cost applies as
written to
NTNCWSs.
Lead 90th
- Range
At or
below TL
Other Conditions2
Model PWS is on
triennial reduced
tap sampling and
not doing POU
sampling
p_tap_triennial
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
p_tap_nine
Every 3
years
Every 9
years
At or
below TL
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
Final LCRI Economic Analysis Appendices
B-48
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
pp_hh_return_samp))*( (hrs_pickup_samp_o
p*rate_op)+cost_pickup_samp)
Model PWS on
annual tap
sampling and not
doing POU
sampling
Once a
year
p_tap_annual
At or
below AL
and above
TL
All model PWSs
not doing POU
sampling
Once a
year
Above AL
Twice per
year
The number of required samples multiplied
by the total of the hours per sample to
provide instructions times the system labor
rate, plus the cost of materials per sample.
The number of required samples is inflated
to include those unreturned, invalidated, and
rejected, to ensure that the cost reflects the
additional burden that must occur to meet
the sampling requirement.
Model PWS is on
triennial reduced
tap sampling and
not doing POU
sampling
Every 3
years
(numb_reduced_tap+(numb_reduced_tapr*p
p_samp_invalid)+(numb_reduced_tap*pp_s
amp_reject)+ (numb_reduced_tap*(1-
pp_hh_return_samp))*( (hrs_pickup_samp_o
p*rate_op)+cost_pickup_samp)
Cost applies as
written to
NTNCWSs.
At or
below TL
p_tap_triennial
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
Every 9
years
p_tap_nine
Final LCRI Economic Analysis Appendices
B-49
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
j) Determine if a sample should be rejected and not analyzed
The number of samples expected to be
rejected (calculated by multiplying the total
number of required samples by the
likelihood of rejection) multiplied by the
hours per sample and the system labor rate.
(numb_samp_customer*pp_samp_reject)*(h
rs_samp_reject_op*rate_op)
Cost does not
apply to
NTNCWSs.
At or
below TL
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
Twice per
year
Model PWS on
annual tap
sampling and not
doing POU
sampling
p_tap_annual
Once a
year
At or
below AL
and above
TL
All model PWSs
not doing POU
sampling
Once a
year
Above AL
Twice per
year
The number of samples expected to be
rejected (calculated by multiplying the total
number of required samples by the
likelihood of rejection) multiplied by the
hours per sample and the system labor rate.
(numb_reduced_tap*pp_samp_reject)*(hrs_
samp_reject_op*rate_op)
Cost does not
apply to
NTNCWSs.
At or
below TL
Model PWS is on
triennial reduced
tap sampling and
not doing POU
sampling
p_tap_triennial
Every 3
years
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
p_tap_nine
Every 9
years
Final LCRI Economic Analysis Appendices
B-50
October 2024
-------
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
k) Analyze lead tap samples in-house or commercially5
The number of samples multiplied by the
probabilities for a sample analyzed in house
and a sample analyzed in a commercial lab
times the different labor and material cost
burdens for each type of analysis.
The number of samples is inflated to include
those invalidated, to ensure that the cost
reflects the additional burden that must
occur to meet the sampling requirement.
(((numb_samp_customer+(numb_samp_cus
tomer*pp_samp_in valid)) *pp_lab_samp)*((h
rs_analyze_samp_op*rate_op)+cost_lab_lt_
samp))+(((numb_samp_customer+(numb_s
amp_customer*pp_samp_invalid))*pp_com
mercial_samp)*((hrs_analyze_samp_op*rat
e_op)+cost_5_commercial_lab))
Cost applies as
written to
NTNCWSs.
At or
below TL
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
Twice per
year
Model PWS is on
annual tap
sampling and not
doing POU
sampling
p_tap_annual
Once a
year
At or
below AL
and above
TL
All model PWSs
not doing POU
sampling
Once a
year
Above AL
Twice per
year
The number of samples multiplied by the
probabilities for a sample analyzed in house
and a sample analyzed in a commercial lab
times the different labor and material cost
burdens for each type of analysis.
The number of samples is inflated to include
those invalidated, to ensure that the cost
reflects the additional burden that must
occur to meet the sampling requirement.
(((numb_reduced_tap+(numb_reduced_tap*
pp_samp_invalid))*pp_lab_samp)*((hrs_ana
lyze_samp_op*rate_op)+cost_lab_lt_samp))
+(((numb_reduced_tap+(numb_reduced_tap
Cost applies as
written to
NTNCWSs.
At or
below TL
Model PWS on
triennial reduced
tap sampling and
not doing POU
sampling
p_tap_triennial
Every 3
years
Final LCRI Economic Analysis Appendices
B-51
October 2024
-------
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
*pp_samp_invalid))*pp_commercial_samp)*
((hrs_analyze_samp_op*rate_op)+cost_com
mercial_lab))
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
p_tap_nine
Every 9
years
1) Prepare and submit sample invalidation request to State
The number of samples expected to be
invalid (calculated by multiplying the total
number of required samples by the
likelihood of invalidation) multiplied by the
hours per sample and the system labor rate.
(numb_samp_customer*pp_samp_invalid)*(
hrs_samp_invalid_op*rate_op
Cost applies as
written to
NTNCWSs.
At or
below TL
Model PWS not on
reduced tap
sampling and not
doing POU
sampling
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
Twice per
year
Model PWS on
annual tap
sampling and not
doing POU
sampling
p_tap_annual
Once a
year
At or
below AL
and above
TL
All model PWSs
not doing POU
sampling
Once a
year
Above AL
Twice per
year
The number of samples expected to be
invalid (calculated by multiplying the total
number of required samples by the
likelihood of invalidation) multiplied by the
hours per sample and the system labor
rate.
Cost applies as
written to
NTNCWSs.
At or
below TL
Model PWS is on
triennial reduced
tap sampling and
not doing POU
sampling
p_tap_triennial
Every 3
years
(numb_reduced_tap*pp_samp_invalid)*(hrs
_samp_invalid_op*rate_op)
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
p_tap_nine
Every 9
years
Final LCRI Economic Analysis Appendices
B-52
October 2024
-------
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
m) Inform consumers of lead tap sample results
The number of required of samples per
system multiplied by the total of the hours
per sample times the system labor rate plus
the material cost per sample.
Hours per
sampling event
multiplied by the
system labor
rate, plus the
material cost
per sampling
event.
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
Twice per
year
Numb_samp_customer*((hrs_inform_samp_
op*rate_op)+cost_cust_lt)
((hrs_ntncws_in
form_samp_op*
rate_op)+cost_n
tncws_cust_lt)
At or
below TL
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
Model PWS is on
annual tap
sampling and not
doing POU
sampling
Once a
year
p_tap_annual
At or
below AL
and above
TL
All model PWSs
not doing POU
sampling
Once a
year
Above AL
Twice per
year
The number of required samples per system
multiplied by the total of the hours per
sample times the system labor rate plus the
material cost per sample.
Numb_reduced_tap*((hrs_inform_samp_op*
rate_op)+cost_cust_lt)
Hours per
sampling event
multiplied by the
system labor
rate, plus the
material cost
per sampling
event.
((hrs_ntncws_in
form_samp_op*
rate_op)+cost_n
tncws_cust_lt)
At or
below TL
Model PWS on
triennial reduced
tap sampling and
not doing POU
sampling
p_tap_triennial
Every 3
years
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
Every 9
years
p_tap_nine
Final LCRI Economic Analysis Appendices
B-53
October 2024
-------
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
n) Certify to the State that results were reported to consumers
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
Twice per
year
Total hours per sampling event multiplied by
the system labor rate.
(hrs_cert_cust_lt_op*rate_op)
Cost applies as
written to
NTNCWSs.
At or
below TL
Model PWS is on
annual tap
sampling and not
doing POU
sampling
p_tap_annual
Once a
year
Model PWS on
triennial reduced
tap sampling and
not doing POU
sampling
Every 3
years
p_tap_triennial
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
Every 9
years
p_tap_nine
At or
below AL
and above
TL
All model PWSs
not doing POU
sampling
Once a
year
Above AL
Twice per
year
Final LCRI Economic Analysis Appendices
B-54
October 2024
-------
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th _.. _ .... 2
„ Other Conditions2
- Range
o) Submit request to renew 9-year monitoring waiver to the State6
Same as final LCRI (see Exhibit 4-16 in Chapter 4).
p) Submit monitoring results and 90th percentile calculations to State5
Model PWS is not
on reduced tap
sampling and not
doing POU
sampling
Twice per
year
1 - (p_tap_annual +
pjtapjtrienniai +
p_tap_nine)
Total hours per sampling event multiplied by
the system labor rate.
(hrs_annual_lt_op*rate_op)
Cost applies as
written to
NTNCWSs.
At or
below TL
Model PWS is on
annual tap
sampling and not
doing POU
sampling
p_tap_annual
Once a
year
Model PWS on
triennial reduced
tap sampling and
not doing POU
sampling
Every 3
years
pjtapjtrienniai
Model PWS is on
nine-year reduced
tap sampling and
not doing POU
sampling
Every 9
years
p_tap_nine
At or
below AL
and above
TL
All model PWSs
not doing POU
sampling
Once a
year
Above AL
Twice a
year
q) Oversee the customer-initiated lead sampling program
N/A under the 2021 LCRR. New requirement under the final LCRI.
r) Ship tap sample monitoring materials and instructions to participating households for
customer-initiated lead sampling program5
N/A under the 2021 LCRR. New requirement under the final LCRI.
s) Collect lead tap samples for customer-initiated lead sampling program
N/A under the 2021 LCRR. New requirement under the final LCRI.
Final LCRI Economic Analysis Appendices
B-55
October 2024
-------
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions2
t) Analyze lead tap samples in-house or commercially for customer-initiated lead sampling
program5
N/A under the 2021 LCRR. New requirement under the final LCRI.
u) Inform customers of lead tap sample results for customer-initiated lead sampling program
N/A under the 2021 LCRR. New requirement under the final LCRI.
Acronyms: AL = action level; CWS = community water system; LCRI = Lead and Copper Rule Improvements; LSL =
lead service line; NTNCWS = non-transient non-community water system; POU = point-of-use; PWS = public water
system; TL = trigger level.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• numb_reduced_tap: the number of lead tap samples for system on reduced annual, triennial, or 9-year
monitoring (Chapter 4, Section 4.3.2.1.1).
• numb_samp_customer: the number of lead tap samples for system on standard 6-month tap monitoring
(Chapter 4, Section 4.3.2.1.1).
• p_tap_annual, p_tap_triennial, and p_tap_nine: likelihood a systems is collecting the reduced number of
lead tap samples on an annual, triennial, or 9-year frequency, respectively (Chapter 4, Section 4.3.2.1.1).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 Does not apply to CWSs serving < 10,000 people and all NTNCWSs that have selected POU as their compliance
option if they exceeded the lead AL. See Chapter 4, Section 4.3.5 and B.5.5 for additional detail. PWSs with lead
content or unknown lines are identified using the data variables and approach described in Chapter 3, Section
3.3.4.
3 In Arkansas, Louisiana, Mississippi, Missouri, North Dakota, and South Carolina the State sends sampling
instructions to the water systems and thus are assumed to incur the burden to update the sampling instruction in
lieu of the system (ASDWA, 2020a).
4 For modeling purposes, the EPA assumed that systems would report changes in sampling location during each
monitoring period.
5 The burden and costs to provide sample bottles (cost_5_lt_samp) under activity h), conduct analyses under
activity k), and provide sampling results under activity p) are incurred by the State in Arkansas, Louisiana,
Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
6 Only systems with 90th percentile values < the AL can quality for a 9-year monitoring waiver.
B.5.2.2 PWS Lead Water Quality Parameter Monitoring under the 2021 LCRR
Under the 2021 LCRR, lead WQP monitoring is required for all systems serving more than 50,000 people
with CCT (except systems that meet the criteria in 40 CFR 141.81(b)(3) or "b3" systems) and those
serving 50,000 or fewer people that exceed the lead AL of 15 ng/L.33 WQP samples are collected at
representative sites throughout the distribution system (also referred to as WQP tap samples) and at
33 Note that systems that have CCT but no OWQPs and have a TLE must monitor for two consecutive six-month
monitoring periods starting in the month following the end of the tap monitoring period with the exceedance.
These costs are not captured in the EPA cost model, thereby underestimating the impacts to systems from the
2021 LCRR WQP monitoring requirements.
Final LCRI Economic Analysis Appendices
B-56
October 2024
-------
each entry point to the distribution system. Systems must conduct WQP monitoring prior to and after
CCT installation. The State may designate optimal water quality parameters (OWQPs) after the
installation of CCT. Systems with CCT must continue to maintain WQPs at or above minimum values or
within OWQP ranges designated by the State. In addition, systems with CCT that have a single sample
above 15 ng/L must conduct WQP monitoring in the distribution system at or near the site with the high
result and determine if problems with CCT contributed to elevated lead (see Section B.5.3.3 for a
discussion of inputs related to this requirement).
The WQP monitoring requirements under the 2021 LCRR are the same as under the final LCRI, with the
exception that continued lead WQP monitoring under the final LCRI applies to all systems serving more
than 10,000 people with CCT and to those that exceed the final lead AL of 10 ng/L. In addition, WQP
monitoring is required at or near any sampling site above 10 ng/L as opposed to 15 ng/L (also see the
requirement under the 2021 LCRR that is described in footnote 33).
The remainder of this section is divided into four subsections:
• B.5.2.2.1: Baseline Corrosion Control Treatment
• B.5.2.2.2: Initial Monitoring Schedules
• B.5.2.2.3: Number of Samples
• B.5.2.2.4: Lead WQP Monitoring Activities
Exhibit B-19 at the end of Section B.5.2.2.4 is a summary exhibit that explains how the cost inputs are
modeled by the SafeWater LCR model.
B.5.2.2.1 Baseline Corrosion Control Treatment
WQP monitoring requirements vary for systems with and without CCT and by type of CCT. The EPA used
the same approach for the pre-2021 LCR, 2021 LCRR, and final LCRI to identify systems with and without
CCT (see Chapter 3, Section 3.3.3). For those with CCT, the EPA estimated the percentage of systems
that currently have one of the three types of CCT used in the cost model:
• Modify pH (pbaseph),
• Add P04 without pH post-treatment (pbasepo4), and
• Add P04 and modify pH (pbasephpo4).
Chapter 4, Section 4.3.2.2.1 provides the EPA's approach for developing these percentages. The
percentages were used for the pre-2021 LCR, 2021 LCRR, and final LCRI.
B.5.2.2.2 Initial MonitorinRSchedules
As described in Section 3.3.8.1 in Chapter 3, systems with CCT can qualify for reduced WQP monitoring
in the distribution system under the 2021 LCRR if they are in compliance with State-set OWQP ranges
and do not exceed the TL of 10 ng/L. The number of consecutive monitoring periods in which a system
meets these criteria determines if a system will collect two samples at a reduced number of sites in the
Final LCRI Economic Analysis Appendices
B-57
October 2024
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distribution system on a semi-annual or annually. Under the 2021 LCRR, systems can no longer qualify
for triennial WQP tap monitoring.
The EPA assumed only systems serving more than 50,000 people with CCT could qualify for reduced
distribution system monitoring because these systems are required to continue WQP monitoring to
demonstrate compliance with their OWQPs unlike smaller systems with CCT or systems without CCT.
Section 3.3.8.1 in Chapter 3 provides the EPA's approach for determining the estimated percentage of
systems with CCT that would be on one of three WQP distribution monitoring schedules at the start of
rule implementation based on historical SDWIS/Fed data.
The final LCRI modifies the WQP monitoring requirements for systems serving 10,001 to 50,000 people
with CCT. These systems must conduct WQP monitoring irrespective of their lead or copper 90th
percentile levels. Those serving 50,000 people or fewer without CCT are only required to monitor for
WQPs in those monitoring periods in which they have a lead or copper ALE and to continue such
monitoring until they no longer exceed the AL for two consecutive 6-month monitoring periods.
However, with the lowering of the lead ALto 10 ng/L, more systems in this size category are expected to
exceed the lead AL and would be subject to WQP monitoring requirements. Refer to Chapter 3, Section
3.3.8.2 for additional detail.
B.5.2.2.3 Number of Samples
The minimum number of WQP distribution system samples for CWSs and NTNCWSs on standard
(numb_enhance_wqp) and reduced monitoring (numb_reduced_wqp) are the same under the pre-2021
LCR, 2021 LCRR, and final LCRI and are discussed in Chapter 4, Section 4.3.2.2.3. Under the 2021 LCRR
and retained in the final LCRI, systems with a lead tap sample result above the lead AL (15 ng/L under
the 2021 LCRR and 10 ng/L under the final LCRI) must conduct WQP monitoring in the distribution
system at or near the site with the high lead result. If an existing WQP site does not meet these criteria,
the system must identify a new WQP monitoring site and those with CCT must use it for future sampling
in addition to the existing number of WQP sites. Refer to Section B.5.3.3 for a more detailed discussion.
Under the 2021 LCRR and retained under the final LCRI, systems must also collect WQP samples at each
entry point to the distribution system. The number of entry points samples corresponds to the
SafeWater LCR model data input numb_ep_wqp. Modeling assumptions for WQP entry point sampling
under the 2021 LCRR are as follows:
• Systems without CCT serving 50,000 or fewer people must collect two samples from each entry
point to the distribution system during each 6-month monitoring periods in which they have a
lead or copper ALE. Under the 2021 LCRR, they must continue this monitoring until they no
longer have an ALE during two consecutive 6-month monitoring periods.
• Systems with CCT must collect one sample per entry point every two weeks. This applies to all
systems serving more than 50,000 except "b3" systems and those serving 50,000 or fewer
people during each 6-month monitoring periods in which they have a lead or copper ALE and
subsequent monitoring periods until they no longer have an ALE for two consecutive monitoring
periods.
Final LCRI Economic Analysis Appendices
B-58
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There are no reduced monitoring provisions for WQPs collected at entry points under the 2021 LCRR, as
was true under the pre-2021 LCR and remains unchanged under the final LCRI.
The estimated number of entry points per system, which corresponds to the SafeWater LCR model input
numb_ep, is provided in Chapter 3, Section 3.3.6.1.
B.5.2.2.4 Lead WQP MonitorinR Activities
The EPA has developed water system costs for five lead WQP monitoring activities under the 2021 LCRR,
as shown in Exhibit B-18. The exhibit provides the unit burden and/or cost for each activity. The third
column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the activities, unit burden or cost, and SafeWater LCR data variables are identical
for the 2021 LCRR to those used for the final LCRI, as described in Chapter 4, Section 4.3.2.2.
Note that the conditions under which the WQP monitoring activity costs apply are different under the
2021 LCRR compared to the final LCRI. Under the LCRR, lead WQP monitoring is required for all systems
serving more than 50,000 people with CCT except "b3" systems and those serving 50,000 or fewer
people that exceed the lead AL of 15 ng/L. Under the final LCRI, system serving 10,001 to 50,000 people
with CCT also must conduct WQP monitoring regardless of their lead 90th percentile level and systems
serving 50,000 or fewer people without CCT must conduct monitoring if they exceed the final lead AL of
10 ng/L.
Exhibit B-18: PWS Lead WQP Monitoring Unit Burden and Cost Estimates under the 2021
LCRR
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As
Final
LCRI?2
v) Collect lead WQP
samples from the
distribution system
Burden per sample per PWS
0.5 hrs (distribution)
Cost per sample
No CCT: $2.66 (CWS & NTNCWS)
pH adjustment:
• $1.70 to $2.66 (CWS);
• $2.66 (NTNCWS)
Orthophosphate:
• $2.66 to $2.82 (CWS)
• $2.66 (NTNCWS)
Burden
hrs_wqp_op
Cost
No CCT: cost_wqp_material
pH: cost_wqp_material_ph
Orthophosphate:
cost_ wqp_material_ortho
Yes.
w) Analyze lead WQP
samples from the
distribution system
In-House Burden per sample
No CCT: 0.15 hrs (CWS & NTNCWS)
pH adjustment:
• 0.15 to 0.46 hrs (CWS)
• 0.15 hrs (NTNCWS)
Orthophosphate:
• 0.15 to 1.34 hrs (CWS)
• 0.15 hrs (NTNCWS)
In-House Cost per sample
In-House Burden
No CCT:
hrs_ wqp_ an alyze_ dist_ op
pH: hrs_wqp_analyze_ph_op
Orthophosphate:
hrs_ wqp_ an alyze_ ortho_op
Yes.
Final LCRI Economic Analysis Appendices
B-59
October 2024
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Same As
Activity
Unit Burden and/or Cost
SafeWaterLCR Data Variable
Final
LCRI?2
No CCT: $0.63 (CWS & NTNCWS)
In-House Cost
pH adjustment:
No CCT: cost_wqp_analyze
• $0.63 to $0.98 (CWS)
pH: cost_wqp_ph_analyze
• $0.63 (NTNCWS)
Orthophosphate:
• $0.63 to $1.07 (CWS)
Orthophosphate:
• $0.63 (NTNCWS)
cost_wqp_ortho_analyze
Commercial Cost per sample
No CCT: $27.24 to 30.55 (CWS &
Commercial Cost
NTNCWS)
No CCT: cost_lab_wqp
pH adjustment: $27.24 to 30.55
pH: cost_lab_ph_wqp
(CWS & NTNCWS)
Orthophosphate:
Orthophosphate: $60.34 to $61.89
cost_lab_ortho_wqp
(CWS & NTNCWS)
x) Collect lead WQP
Burden per sample
Burden
Yes.
samples from entry
0.4 hrs for 80 percent of ground
hrs_ep_wqp_op
points
water PWSs1
Cost
Cost per sample
cost_ep_wqp_material
No CCT: $2.66 (CWS & NTNCWS)
cost_ ep_ wqp_ph_material
pH adjustment:
• $1.70 to $2.66 (CWS);
• $2.66 (NTNCWS)
cost_ ep_ wqp_ orth o_materi al
Orthophosphate:
• $2.66 to $2.82 (CWS)
• $2.66 (NTNCWS)
y) Analyze lead WQP
In-House Burden per sample
In-House Burden
Yes.
samples from entry
No CCT: 0.15 hrs (CWS & NTNCWS)
hrs_ wqp_ an alyze_ ep_ op
points
pH adjustment:
hrs_ wqp_ an alyze_ph_ ep_op
• 0.15 to 0.46 hrs (CWS)
• 0.15 hrs (NTNCWS)
Orthophosphate:
hrs_ wqp_ an alyze_ ortho_ ep_ op
• 0.15 to 1.34 hrs (CWS)
• 0.15 hrs (NTNCWS)
In-House Cost per sample
In-House Cost
No CCT: $0.63 (CWS & NTNCWS)
cost_ wqp_ an alyze_ep
pH adjustment:
cost_ wqp_ an alyze_ph_ ep
• $0.63 to $0.98 (CWS)
• $0.63 (NTNCWS)
Orthophosphate:
cost_ wqp_ an alyze_ ortho_ep
• $0.63 to $1.07 (CWS)
• $0.63 (NTNCWS)
Commercial Cost per sample
Commercial Cost
No CCT:
cost_lab_wqp_ep
• $29.28 to $30.21 (CWS)
cost_lab_ wqp_ph_ ep
Final LCRI Economic Analysis Appendices
B-60
October 2024
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Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As
Final
LCRI?2
• No CCT: $30.55 (NTNCWS)
pH adjustment:
• $30.58 to $33.30 (CWS)
• $33.93 (NTNCWS)
Orthophosphate:
• $61.90 to $63.49 (CWS)
• $63.84 (NTNCWS)
cost_lab_wqp_ortho_ep
z) Report lead WQP
sampling data and
compliance with
OWQPs to the State
No CCT: 4 hrs/PWS
With CCT: 5 hrs/PWS
Burden
hrs_report_ wqp_op
Yes.
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; LCRR = Lead and Copper Rule revisions; NTNCWS = non-transient non-community water system;
OWQP = optimal water quality parameters; PWS = public water system; WQP = water qualify parameter.
Source: "WQP Analytical Burden and Costs_Final.xlsx."
Notes:
1 The EPA assumed the burden to collect WQP samples to be 0.4 hours for all surface water systems and 20
percent of ground water systems based on the 2022 Disinfectants/Disinfection Byproducts, Chemical, and
Radionuclides Rules ICR (Renewal), Exhibit 9 (WQP Monitoring - Monitoring, Burden, and Cost Assumptions)
(USEPA, 2022).
2 The SafeWater input variables are the same under the 2021 LCRR and final LCRI; however, the systems to which
these requirements apply vary between the two rules. Under the LCRR, lead WQP monitoring is required for all
systems serving more than 50,000 people with CCT except "b3" systems and those serving 50,000 or fewer people
that exceed the lead AL of 15 ng/L. Under the final LCRI, system serving 10,001 to 50,000 people with CCT also
must conduct WQP monitoring regardless of their lead 90th percentile level and systems serving 50,000 or fewer
people must conduct monitoring if they exceed the final lead ALof 10 ng/L.
Exhibit B-19 shows the SafeWater LCR model cost estimation approach for water system lead WQP
monitoring activities under the 2021 LCRR including additional cost inputs that are required to calculate
these costs.
Final LCRI Economic Analysis Appendices
B-61
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Exhibit B-19: PWS Lead WQP Monitoring Cost Estimation in SafeWater LCR by Activity under the 2021 LCRR1
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range
Other Conditions
v) Collect lead WQP samples from the distribution system
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mat
erial))
Model PWSs serving <50,000 without
CCT
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mat
erial ph))
Cost applies
as written to
NTNCWSs.
Above AL
Model PWSs serving <50,000 with pH
adjustment
pbaseph
Twice per
year
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
Model PWSs serving <50,000 with
PCM or both PCM and pH adjustment
(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mat
erial ortho))
pbasepo4, pbasephpo4
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mat
erial_ph))
Cost applies
as written to
NTNCWSs.
All
Model PWSs serving >50,000 with
pH adjustment that do not qualify for
reduced WQP monitoring
Twice per
year
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mat
erial_ortho))
Model PWSs serving >50,000 with
PO4 or both PO4 and pH adjustment
that do not qualify for reduced WQP
monitoring
pbasepo4, pbasephpo4,
1 - (p wqp annual + p wqp six red)
Twice per
year
Final LCR! Economic Analysis Appendices
B-62
October 2024
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CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
(r>umb_reduced_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mate
rial_ph))
Cost applies
as written to
NTNCWSs.
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
(r>umb_reduced_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mate
rial_ortho))
Cost applies
as written to
NTNCWSs.
w) Analyze lead WQP samples from the distribution system
There are different labor (burden) and material costs for a
sample analyzed in house and a sample analyzed using a
commercial lab. The in-house analysis costs are calculated
using the number of required samples per system multiplied
by the percentage of samples analyzed in house times the
system labor rate, plus the material cost of the in-house
analysis per sample. The commercial lab analysis costs are
calculated using the number of required samples per system
multiplied by the percentage of samples analyzed in a
commercial lab times the system labor rate, plus the material
cost of the commercial lab analysis per sample.
Final LCRI Economic Analysis Appendices
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range Other Conditions
Model PWSs with pH adjustment on
six-month reduced WQP monitoring
pbaseph, p_wqp_six_red
Twice a
year
All
Model PWSs with pH adjustment on
annual WQP monitoring
pbaseph, p_wqp_annual
Once a
year
Model PWSs with PO4 or both PO4
and pH adjustment on six-month
reduced sample WQP monitoring
pbasepo4, pbasephpo4,
p_wqp_six_red
Twice a
year
All
Model PWSs with PO4 or both PO4
and pH adjustment on annual WQP
monitoring
pbasepo4, pbasephpo4,
p_wqp_annual
Once a
year
Model PWSs serving <50,000 without
CCT
1-63
October 2024
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CWS Cost Per Activity
NTNCWS
Cost Per
Activity
(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_dis
t_op*rate_op)+cost_wqp_analyze))+((numb_enhance_wqp*pp
_commercial_samp)*cost_lab_wqp))
There are different labor (burden) and material costs for a
sample analyzed in house and a sample analyzed using a
commercial lab. The in-house analysis costs are calculated
using the number of required samples per system multiplied
by the percentage of samples analyzed in house times the
system labor rate, plus the material cost of the in-house
analysis per sample. The commercial lab analysis costs are
calculated using the number of required samples per system
multiplied by the percentage of samples analyzed in a
commercial lab times the system labor rate, plus the material
cost of the commercial lab analysis per sample.
Cost applies
as written to
NTNCWSs.
(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ph
_op*rate_op)+cost_wqp_ph_analyze))+((numb_enhance_wqp
*pp commercial samp)*cost lab ph wqp))
There are different labor (burden) and material costs for a
sample analyzed in house and a sample analyzed using a
commercial lab. The in-house analysis costs are calculated
using the number of required samples per system multiplied
by the percentage of samples analyzed in house times the
system labor rate, plus the material cost of the in-house
analysis per sample. The commercial lab analysis costs are
calculated using the number of required samples per system
multiplied by the percentage of samples analyzed in a
commercial lab times the system labor rate, plus the material
cost of the commercial lab analysis per sample.
(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ort
ho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_enhance
wqp*pp commercial samp)*cost lab ortho wqp))
Final LCRI Economic Analysis Appendices
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range
Other Conditions
Above AL
Model PWSs serving <50,000 with pH
adjustment
pbaseph
Twice a
year
Model PWSs serving <50,000 with
PCM or both PCM and pH adjustment
pbasepo4, pbasephpo4
1-64
October 2024
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CWS Cost Per Activity
NTNCWS
Cost Per
Activity
There are different labor (burden) and material costs for a
sample analyzed in house and a sample analyzed using a
commercial lab. The in-house analysis costs are calculated
using the number of required samples per system multiplied
by the percentage of samples analyzed in house times the
system labor rate, plus the material cost of the in-house
analysis per sample. The commercial lab analysis costs are
calculated using the number of required samples per system
multiplied by the percentage of samples analyzed in a
commercial lab times the system labor rate, plus the material
cost of the commercial lab analysis per sample.
(((numb_enhance_wqp*pp_tab_samp)*((hrs_wqp_anatyze_ph Cost applies
_op*rate_op)+cost_wqp_ph_analyze))+((numb_enhance_wqp as written to
*pp commercial samp)*cost lab ph wqp)) NTNCWSs.
There are different labor (burden) and material costs for a
sample analyzed in house and a sample analyzed using a
commercial lab. The in-house analysis costs are calculated
using the number of required samples per system multiplied
by the percentage of samples analyzed in house times the
system labor rate, plus the material cost of the in-house
analysis per sample. The commercial lab analysis costs are
calculated using the number of required samples per system
multiplied by the percentage of samples analyzed in a
commercial lab times the system labor rate, plus the material
cost of the commercial lab analysis per sample.
(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ort
ho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_enhance
wqp*pp commercial samp)*cost lab ortho wqp))
Final LCRI Economic Analysis Appendices
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range Other Conditions
Model PWSs serving >50,000 with
pH adjustment that do not qualify for
reduced WQP monitoring
Twice a
year
pbaseph;
1- (p_wqp_annual + p_wqp_six_red)
Model PWSs serving >50,000 with
PCM or both PCM and pH adjustment
that do not qualify for reduced WQP
monitoring
Twice a
year
pbasepo4; pbasephpo4;
1 - (p_wqp_annual +
p_wqp_six_red)
1-65
October 2024
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CWS Cost Per Activity
NTNCWS
Cost Per
Activity
There are different labor (burden) and material costs for a
sample analyzed in house and a sample analyzed using a
commercial lab. The in-house analysis costs are calculated
using the number of required samples per system multiplied
by the percentage of samples analyzed in house times the
system labor rate, plus the material cost of the in-house
analysis per sample. The commercial lab analysis costs are
calculated using the number of required samples per system
multiplied by the percentage of samples analyzed in a
commercial lab times the system labor rate, plus the material
cost of the commercial lab analysis per sample.
(((numb_reduced_wqp*pp_lab_samp)*((hrs_wqp_analyze_ph
_op*rate_op)+cost_wqp_ph_analyze))+((numb_reduced_wqp*
pp_commercial_samp)*cost_lab_ph_wqp))
Cost applies
as written to
NTNCWSs.
There are different labor (burden) and material costs for a
sample analyzed in house and a sample analyzed using a
commercial lab. The in-house analysis costs are calculated
using the number of required samples per system multiplied
by the percentage of samples analyzed in house times the
system labor rate, plus the material cost of the in-house
analysis per sample. The commercial lab analysis costs are
calculated using the number of required samples per system
multiplied by the percentage of samples analyzed in a
commercial lab times the system labor rate, plus the material
cost of the commercial lab analysis per sample.
(((numb_reduced_wqp*pp_lab_samp)*((hrs_wqp_analyze_ort
ho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_reduced_
wqp*pp_commercial_samp)*cost_lab_ortho_wqp))
Cost applies
as written to
NTNCWSs.
Final LCRI Economic Analysis Appendices
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range Other Conditions
Model PWSs with pH adjustment on
six-month reduced sample WQP
monitoring
Twice a
year
pbaseph, p_wqp_six_red
All
Model PWSs with pH adjustment on
annual WQP monitoring
pbaseph, p_wqp_annual
Once a
year
Model PWSs serving > 50,000 with
PCM or both PCM and pH adjustment
on six-month reduced WQP
monitoring
Twice a
year
pbasepo4, pbasephpo4,
p_wqp_six_red
All
Model PWSs serving > 50,000 with
PO4 or both PO4 and pH adjustment
on annual WQP monitoring
Once a
year
1-66
October 2024
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CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range
Other Conditions
pbasepo4, pbasephpo4,
p wqp annual
x) Collect lead WQP samples from entry points
The number of entry points per system multiplied by the
number of samples, then multiplied by the total of the labor
hours per sample times the system labor rate, plus the cost
per sample.
((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_
ep_wqp_material))
Model PWSs serving <50,000 without
CCT
Twice a
year
The number of entry points per system multiplied by the
number of samples, then multiplied by the total of the labor
hours per sample times the system labor rate, plus the cost
per sample.
((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_
ep wqp ph material))
Cost applies
as written to
NTNCWSs.
Above AL
Model PWSs serving <50,000 with pH
adjustment
pbaseph
Every 2
weeks
The number of entry points per system multiplied by the
number of samples, then multiplied by the total of the labor
hours per sample times the system labor rate, plus the cost
per sample.
((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_
ep wqp ortho material))
Model PWSs serving <50,000 with
PCM or both PCM and pH adjustment
pbasepo4, pbasephpo4
The number of entry points per system multiplied by the
number of samples, then multiplied by the total of the labor
hours per sample times the system labor rate, plus the cost
per sample.
((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_
ep wqp ph material))
Cost applies
as written to
NTNCWSs.
All
Model PWSs serving > 50,000 with
pH adjustment
pbaseph
Every 2
weeks
The number of entry points per system multiplied by the
number of samples, then multiplied by the total of the labor
hours per sample times the system labor rate, plus the cost
per sample.
Model PWSs serving > 50,000 with
PCM or both PCM and pH adjustment
pbasepo4, pbasephpo4
Final LCRI Economic Analysis Appendices
B-67
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CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range
Other Conditions
((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_
ep_wqp_ortho_material))
y) Analyze lead WQP samples from entry points
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analy
ze_ep_op*rate_op)+cost_wqp_analyze_ep))+(((numb_ep*num
b ep wqp)*pp commercial samp)* cost lab wqp ep))
Cost applies
as written to
NTNCWSs.
Above AL
Model PWSs serving <50,000 without
CCT
Twice a
year
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
Above AL
Model PWSs serving <50,000 with pH
adjustment
((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analy
ze_ph_ep_op*rate_op)+cost_wqp_analyze_ph_ep))+(((numb_
ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ph_
ep))
Cost applies
as written to
NTNCWSs.
pbaseph
Every two
weeks
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
Above AL
Model PWSs serving <50,000 with
PCM or both PCM and pH adjustment
((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analy
ze_ortho_ep_op*rate_op)+cost_wqp_analyze_ortho_ep))+(((n
umb_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wq
p ortho ep))
pbasepo4, pbasephpo4
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analy
ze ph ep op*rate op)+cost wqp analyze ph ep))+(((numb
Cost applies
as written to
NTNCWSs.
All
Model PWSs serving >50,000 with
pH adjustment
pbaseph
Every two
weeks
Final LCRI Economic Analysis Appendices
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October 2024
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CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range Other Conditions
ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ph_
ep))
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analy
ze_ortho_op*rate_op)+cost_wqp_analyze_ortho_ep))+(((numb
_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ort
ho_ep))
Model PWSs serving >50,000 with
PO4 or both PO4 and pH adjustment
pbasepo4, pbasephpo4
z) Report lead WQP sampling data and compliance with OWQPs to the State
The labor hours for reporting per system multiplied by the
labor rate.
(hrs_report_wqp_op*rate_op)
Cost applies
as written to
NTNCWSs.
Above AL
Model PWSs serving <50,000 without
CCT
Twice a
year
Model PWSs serving <50,000 with pH
adjustment
pbaseph
Model PWSs serving <50,000 with
PO4 or both PO4 and pH adjustment
pbasepo4, pbasephpo4
All
Model PWSs serving >50,000 with pH
adjustment
pbaseph
Model PWSs serving >50,000 with
PO4 or both PO4 and pH adjustment
pbasepo4, pbasephpo4
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-community water system;
OWQP = optimal water quality parameter; PO4 = orthophosphate; PWS = public water system; WQP = water quality parameter.
Note:
Final LCRI Economic Analysis Appendices
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1The data variables in the exhibit are defined previously in this section with the exception of:
• numb_enhance_wqp: number of distribution system samples for systems on standard WQP monitoring (Chapter 4, Section B.5.2.2.3).
• numb_ep\ number of entry points per systems (Chapter 4, Section B.5.2.2.3).
• numb_ep_wqp\ number of entry point samples per systems (Chapter 4, Section B.5.2.2.3).
• numb_reduced_wqp\ number of distribution system samples for systems on reduced WQP monitoring (Chapter 4, Section B.5.2.2.3).
• pbaseph'. likelihood a system has an existing CCT of modify pH (S Chapter 4, Section B.5.2.2.1).
• pbasepo4: likelihood a system has existing CCT of adding PO4 without pH post treatment (Chapter 4, Section B.5.2.2.1).
• pbasephpo4\ likelihood a system has existing CCT of adding PO4 with modify pH (Chapter 4, Section B.5.2.2.1).
• P-wqP-six-red, p_wqp_annual\ likelihood a system is on reduced distribution system monitoring schedule at a semi-annual or annual schedule,
respectively (Chapter 4, Section 0).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
Final LCRI Economic Analysis Appendices
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B.5.2.3 PWS Copper Water Quality Parameter Monitoring under the 2021 LCRR
This discussion of copper WQP monitoring costs for water systems under the 2021 LCRR is presented in
the following subsections:
• B.5.2.3.1: Applicability and Likelihood of a Copper ALE
• B.5.2.3.2: Copper WQP Monitoring Activities
B.5.2.3.1 Applicability and Likelihood of a Copper ALE
As was done for the final LCRI, the SafeWater LCR models Copper WQP Monitoring separately from the
Lead WQP Monitoring for the 2021 LCRR. The frequency of Lead WQP Monitoring depends on the lead
90th percentile, with all systems above the AL and all systems serving more than 50,000 people34
conducting Lead WQP Monitoring under the LCRR.35 Copper WQP Monitoring is required when a system
exceeds the copper AL. To not double count the cost of WQP monitoring for systems experiencing both
a copper ALE and a lead ALE simultaneously, the SafeWater LCR models the costs of Copper and Lead
WQP Monitoring separately and restricts Copper WQP Monitoring to systems with a copper ALE only
and lead 90th percentile not greater than the lead AL of 15 ng/L.
The cost inputs used to estimate WQP costs in response to a copper ALE are identical to those incurred
in response to a lead ALE with the following exceptions:
• The likelihood of a system's exceeding the copper ALE, which corresponds to p_copper_ale, is
used in lieu of system's lead 90th percentile level.
• Systems are not assumed to be on reduced WQP distribution system monitoring in response to
a copper ALE, and all systems are assumed to be on a 6-month standard monitoring schedule.
Thus, the data inputs associated with reduced monitoring are not applicable. These include the
reduced number of WQP monitoring samples per distribution sample site (numb_reduced_wqp),
and the likelihood that a system will be on a 6-month (p_wqp_six_red) or annual
(p_wqp_annual) WQP sampling schedule.
This approach is also used for the final LCRI and is detailed in Chapter 4, Section 4.3.2.3.1.
34 All systems serving more than 50,000 people are required to have CCT and to conduct WQP monitoring with the
exception of systems that have naturally non-corrosive water, i.e., "b3" systems. Refer to Chapter 3, Section 3.3.3
for the EPA's approach for deriving the number of "b3" systems (assumed to be 16 CWSs).
35 As previously discussed in B.5.2.2, under the final LCRI, system serving 10,001 to 50,000 people with CCT also
must conduct WQP monitoring regardless of their 90th percentile levels.
Final LCRI Economic Analysis Appendices
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B.5.2.3.2 Copper WQP MonitorinR Activities
The activities, unit burden and costs, and data variables used to estimate copper WQP monitoring costs
under the 2021 LCRR are identical to those for lead, as shown in Exhibit B-20, with the exception that
they are triggered in response to a copper ALE.
Exhibit B-20: PWS Copper WQP Monitoring Unit Burden and Cost Estimates under the 2021
LCRR
Activity
Unit Burden SafeWater LCR Data
and/or Cost Variable
Same As Final
LCRI?1
aa) Collect copper WQP samples from the
distribution system
Same as Exhibit B-18, activity v).
Yes.
bb) Analyze copper WQP samples from the
distribution system
Same as Exhibit B-18, activity w).
Yes.
cc) Collect copper WQP samples from
entry points
Same as Exhibit B-18, activity x).
Yes.
dd) Analyze copper WQP samples from
entry points
Same as Exhibit B-18, activity y).
Yes.
ee) Report copper WQP sampling data and
compliance with OWQPs to the State
Same as Exhibit B-18, activity z).
Yes.
Acronyms: LCRI = Lead and Copper Rule Improvements; LCRR = Lead and Copper Rule Revisions; OWQP = optimal
water qualify parameter; PWS = public water system; WQP = water qualify parameter.
Source: "WQP Analytica Burden and Costs_Final.xlsx."
Notes:
1 Under the final LCRI, system serving 10,001 to 50,000 people with CCT also must conduct WQP monitoring
regardless of their 90th percentile levels.
Exhibit B-21 shows the SafeWater LCR model cost estimation approach for system WQP monitoring
activities in response to a copper ALE including additional cost inputs that are required to calculate
these costs under the 2021 LCRR.
Final LCRI Economic Analysis Appendices
B-72
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Exhibit B-21: PWS Copper WQP Monitoring Cost Estimation in SafeWater LCR by Activity under the 2021 LCRR1
CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
aa) Collect copper WQP samples from the distribution system
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
Model PWSs serving <50,000
without CCT and have a copper ALE
(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mat
erial))
p_copper_ale
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mat
erial_ph))
Cost applies as
written to
NTNCWSs.
At or below AL
Model PWSs serving <50,000 that
have pH adjustment and a copper
ALE
p_copper_ale, pbaseph
Twice per
event
Number of samples multiplied by the total of the hours per
sample times the system labor rate, plus the cost of materials
per sample.
(numb_enhance_wqp*((hrs_wqp_op*rate_op)+cost_wqp_mat
erial_ortho))
Model PWSs serving <50,000 that
have PCM or both PCM and pH
adjustment and a copper ALE
p_copper_ale, pbasepo4,
pbasephpo4
Final LCR! Economic Analysis Appendices
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CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
bb) Analyze copper WQP samples from the distribution system
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_di
st_op*rate_op)+cost_wqp_analyze))+((numb_enhance_wqp*p
p commercial samp)*cost lab wqp))
Model PWSs serving <50,000
without CCT and have a copper ALE
p_copper_ale
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ph
_op*rate_op)+cost_wqp_ph_analyze))+((numb_enhance_wqp
*pp commercial samp)*cost lab ph wqp))
Cost applies as
written to
NTNCWSs.
At or below AL
Model PWSs serving <50,000 that
have pH adjustment and a copper
ALE
p_copper_ale, pbaseph
Twice per
event
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
Model PWSs serving <50,000 that
have PCM or both PCM and pH
adjustment and have a copper ALE
(((numb_enhance_wqp*pp_lab_samp)*((hrs_wqp_analyze_ort
ho_op*rate_op)+cost_wqp_ortho_analyze))+((numb_enhance
wqp*pp commercial samp)*cost lab ortho wqp))
p_copper_ale, pbasepo4,
pbasephpo4
Final LCRI Economic Analysis Appendices
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CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
cc) Collect copper WQP samples from entry points
The number of entry points per system multiplied by the
number of samples, then multiplied by the total of the labor
hours per sample times the system labor rate, plus the cost
per sample.
((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_
eP_ wqp_material))
Cost applies as
written to
NTNCWSs.
At or below AL
Model PWSs serving <50,000
without CCT and have a copper ALE
p_copper_ale
Every 2
weeks per
event
The number of entry points per system multiplied by the
number of samples, then multiplied by the total of the labor
hours per sample times the system labor rate, plus the cost
per sample.
((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_
ep wqp ph material))
Model PWSs serving <50,000 that
have pH adjustment and a copper
ALE
p_copper_ale, pbaseph
The number of entry points per system multiplied by the
number of samples, then multiplied by the total of the labor
hours per sample times the system labor rate, plus the cost
per sample.
((numb_ep*numb_ep_wqp)*((hrs_ep_wqp_op*rate_op)+cost_
ep wqp ortho material))
Model PWSs serving <50,000 that
have PCM or both PCM and pH
adjustment and have a copper ALE
p_copper_ale, pbasepo4,
pbasephpo4
Final LCRI Economic Analysis Appendices
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October 2024
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CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
dd) Analyze copper WQP samples from entry points
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
Model PWSs serving <50,000
without CCT and have a copper ALE
p_copper_ale
((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analy
ze_ep_op*rate_op)+cost_wqp_analyze_ep))+(((numb_ep*nu
mb_ep_wqp)*pp_commercial_samp)* cost_lab_wqp_ep))
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analy
ze_ph_ep_op*rate_op)+cost_wqp_analyze_ph_ep))+(((numb_
ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wqp_ph_
ep))
Cost applies as
written to
NTNCWSs.
Above AL
Model PWSs serving <50,000 that
have pH adjustment and a copper
ALE
p_copper_ale, pbaseph
Every two
weeks per
event
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
Model PWSs serving <50,000 that
have PCM or both PCM and pH
adjustment and have a copper ALE
((((numb_ep*numb_ep_wqp)*pp_lab_samp)*((hrs_wqp_analy
ze_ortho_ep_op*rate_op)+cost_wqp_analyze_ortho_ep))+(((n
umb_ep*numb_ep_wqp)*pp_commercial_samp)*cost_lab_wq
p ortho ep))
p_copper_ale, pbasepo4,
pbasephpo4
Final LCRI Economic Analysis Appendices
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CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
ee) Report copper WQP sampling data and compliance with OWQPs to the State
Model PWSs serving <50,000
without CCT and have a copper ALE
p_copper_ale
The labor hours for reporting per system multiplied by the
labor rate.
(hrs_report_wqp_op*rate_op)
Cost applies
as written to
NTNCWSs.
At or below
AL
Model PWSs serving <50,000 that
have pH adjustment and a copper
ALE
p copper ale, pbaseph
Twice per
event
Model PWSs serving <50,000 that
have PO4 or both PCM and pH
adjustment and have a copper ALE
p_copper_ale, pbasepo4,
pbasephpo4
Acronyms: AL = action level; ALE = action level exceedance; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-
community water system; PO4 = orthophosphate; OWQP = optimal water quality parameter; PWS = public water system; WQP = water quality parameter.
Note:
1The data variables in the exhibit are defined previously in this section with the exception of:
• numb_enhance_wqp: number of distribution system samples for systems on standard WQP monitoring (Chapter 4, Section 4.3.2.2.3).
• numb_ep: number of entry points per systems (Chapter 4, Section 4.3.2.2.3).
• pbaseplr. likelihood a system has an existing CCT of modify pH (Chapter 4, Section 4.3.2.2.1).
• pbasepo4: likelihood a system has existing CCT of adding PO4 without pH post treatment (Chapter 4, Section 4.3.2.2.1).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
Final LCRI Economic Analysis Appendices
B-77
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B.5.2.4 PWS Source Water Monitoring under the 2021 LCRR
This discussion of source water monitoring costs for water systems is presented in the following
subsections:
• B.5.2.4.1: Applicability and Required Number of Samples
• B.5.2.4.2: Source Water Monitoring Activities
B.5.2.4.1 Applicability and Required Number of Samples
Under the 2021 LCRR, CWSs and NTNCWSs must sample at each entry point if they experience a
significant source water change and/or have not already conducted source water monitoring for a
previous lead or copper AL. The EPA retained this requirement in the final LCRI. The likelihood of a
significant source change as well as the required number of source water samples is the same under the
2021 LCRR and final LCRI and are described in Chapter 4, Section 4.3.2.4.1. The likelihood that a system
will exceed the lead and/or copper AL is lower under the 2021 LCRR than the final LCRI because:
• The lead AL under the 2021 LCRR is 15 ng/L and the final LCRI is 10 ng/L.
• LSL systems under the 2021 LCRR use the fifth-liter sample in their 90th percentile calculation
but under the final LCRI they would use the higher of the first- and fifth-liter sample.
A discussion of the EPA's approach for estimating the likelihood a system will initially have a lead ALE
under the 2021 LCRR is provided in Chapter 3, Section 3.3.5.1.1, with the estimated percentages
provided in Exhibit 3-25. The likelihood a system will have a copper ALE is provided in Chapter 4, Section
4.3.2.3.1. Note that this approach may result in an overestimation of cost because the 2021 LCRR allows
systems to forego source water monitoring if they previously sampled source water in response to an
ALE, the State has not required source water treatment, and they have not added any new water
sources that change their primacy source type. For modeling purposes no system is assumed to have
source water treatment.
B.5.2.4.2 Source Water MonitorinR Activities
The EPA has developed system costs for three source water monitoring activities under the 2021 LCRR,
as shown in Exhibit B-22. The exhibit provides the unit burden and/or cost for each activity. The third
column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the activity, unit burden or cost, and SafeWater LCR data variable for the 2021 LCR
are identical to those used for the final LCRI, as described in Chapter 4, Section 4.3.2.4.2.
In a few instances, some of these activities are conducted by the State instead of the water system.
These activities are identified in the exhibit and further explained in the exhibit notes.
Final LCRI Economic Analysis Appendices B-78
October 2024
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Exhibit B-22: PWS Source Monitoring Burden and Cost Estimates under the 2021 LCRR
Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same As Final
LCRI?
ff) Collect source water
samples
Burden
0.5 hrs/sample
Cost
$1.12/sample for CWSs serving
> 100K
Burden
hrs_source_op
Cost
cost_source_moter/o/2
Yes.
gg) Analyze source water
samples
In-House Burden
0.44 hrs/sample for CWSs
serving > 100K
In-House Cost
$3.92/sample for CWSs serving
> 100K
Commercial Cost
$31.00/sample for CWSs serving
< lOOKand NTNCWSs
In-House Burden
hrs_analyze_samp_op1
In-House Cost
cost_source_analyze1
Commercial Cost
cos^source1
Yes.
hh) Report source water
monitoring results to the
State
1 hour/report
hrs_report_source_op1
Yes.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; LCRR = Lead and Copper
Rule Revisions; NTNCWS = non-transient non-community water system; PWS = public water system.
Sources:
ff), hh): 2022 Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 15
(USEPA, 2022); "Lead Analytical Burden and Costs_Final.xlsx," worksheets "Source_Collect_Analyze_CWS" and
"Source_Collect_Analyze_NTNCWS."
gg): See file "Lead Analytical Burden and Costs_Final.xlsx," worksheets "Source_Collect_Analyze_CWS" and
"Source_Collect_Analyze_NTNCWS."
Note:
1The burden and costs for these activities are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri,
and South Carolina.
Exhibit B-23 provides the SafeWater LCR model cost estimation approach for system source water
monitoring activities and indicates that the approach under the 2021 LCRR is the same as that used for
the final LCRI, as provided in Chapter 4, Exhibit 4-43.
Final LCRI Economic Analysis Appendices B-79
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Exhibit B-23: PWS Source Water Monitoring Cost Estimation in SafeWater LCR by Activity
under the 2021LCRR1
CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other
Conditions2
ff) Collect source water samples1
Same as final LCRI (see Exhibit 4-43 in Chapter 4).
gg) Analyze source water samples1
Same as final LCRI (see Exhibit 4-43 in Chapter 4).
hh) Report source water monitoring results to the State1
Same as final LCRI (see Exhibit 4-43 in Chapter 4).
Acronyms: CWS = community water system; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
1The burden and cost to provide sample bottles (cost_source_material) under activity ff), conduct analyses under
activity gg), and report source water sample results to the system under activity hh) are incurred by the State in
Arkansas, Louisiana, Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
B.5.2.5 CWS School and Child Care Lead Sampling Costs under the 2021 LCRR
As detailed in Chapter 3, Section 3.3.10, the 2021 LCRR established requirements for CWSs to conduct
PE and lead testing in drinking water in K - 12 public and private schools and licensed child care facilities
in their service area. CWSs must collect five samples per tested school (numb_samp_five) and two
samples at each tested child care facility (numb_samp_two). The rule splits this testing program into two
phases. The first testing phase occurs at elementary schools and child care facilities during the first 5
years of rule implementation, which is assumed to occur in Years 1 through 5 of the 35-year period of
analysis. During the first five-year cycle, systems must schedule and conduct testing at 20 percent of
elementary schools and 20 percent of child care facilities (pp_mand_twenty_partic) per year such that
each would be tested once in the five-year period. The EPA assumed all elementary schools and child
facilities would accept sampling. CWSs are also required to annually provide secondary schools with
information on how to request sampling and must sample if requested by the school. In Years 6 onward,
CWSs are only required to test elementary schools, secondary schools, and child care facilities that
request testing. The EPA assumed 5 percent of elementary schools and child care facilities would
request testing each year, starting in Year 6 and 5 percent of secondary schools would request testing
each year, starting in Year 1 (pp_voluntary_partic).
The final LCRI retains the testing and PE requirements of the 2021 LCRR and the costing inputs and
approach for estimating costs are the same under both rules with two exceptions. First, the final LCRI
adds a new requirement for systems to provide school and child care facility testing results to their State
within 30 days of receiving the analytical results. Secondly, the allowance for States to waive testing at a
school and/or licensed child care facility is broader under the final LCRI. Under the 2021 LCRR, States
cannot waive testing requirements for CWSs based on sampling conducted prior to the 2021 LCRR
compliance date of October 16, 2024. Under the final LCRI, States can waive requirements for the first
five-year sampling cycle after the final LCRI compliance date in schools and licensed child care facilities
Final LCRI Economic Analysis Appendices B-80
October 2024
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that were sampled between January 1, 2021 and the final LCRI compliance date. See Chapter 3, Section
3.3.10.2 for the EPA's approach for estimating the percentage of schools and child care facilities for
which CWSs will receive a waiver under the 2021 LCRR and final LCRI.
B.5.2.5.1 First Five-Year TestinR Cycle
The EPA has developed system burden and costs to implement a lead in drinking water testing program
at elementary schools and child care facilities for the first five-year testing cycle under the 2021 LCRR, as
shown in Exhibit B-24. The exhibit provides the unit burden and/or cost for each activity. The third
column provides the corresponding SafeWater LCR model data variable in red/italic font. In a few
instances, some of these activities are conducted by the State instead of the CWS. These activities are
identified in the exhibit and further explained in the exhibit notes. The last column indicates if the
activities, unit burden or cost, and SafeWater LCR data variables for the 2021 LCRR are identical to those
used for the final LCRI, as described in Chapter 4, Section 4.3.2.5.1. The gray shaded row indicates an
activity that is not required under the 2021 LCRR.
Exhibit B-24: CWS School and Child Care Facility Sampling Unit Burden and Cost Estimates for
the First Five-Year Testing Cycle Phase under the 2021 LCRR
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As
Final LCRI?
ii) Create a list of
schools and child
care facilities served
by the CWS and
submit to the State
(one-time)
0.08 hrs/school or child
care facility
hrs_school_identify_op
Yes.
jj) Develop lead
outreach materials
for schools and child
care facilities (one-
time)
7 hrs/CWS
hrs_ de vel_pe_sch ool_op
Yes.
kk) Prepare and
distribute initial
letters explaining
the sampling
program and the
EPA's 3Ts Toolkit
(one-time)
Burden
0.05 to 0.11 hrs/school or
child care facility
Cost
$0.47 to $0.72/ school or
child care facility
Burden
hrs_school_letter_op
Cost
cost_school_letter
Yes.
II) Contact elementary
school or child care
facility to determine
and finalize its
sampling schedule
(one-time) or
contact secondary
school to offer
sampling (annual)
School
0.5 hrs/elementary school
(one-time)
0.05 to 0.11/secondary
school (annual)
School Cost
$0.47 to $0.72/secondary
school
School
hrs_school_call_op (elementary)
hrs_school_annual_contact_op
(secondary)
School Cost
cost_school_annual_contact
(secondary)
Yes.
Final LCRI Economic Analysis Appendices B-81
October 2024
-------
Activity
Unit Burden and/or Cost
SafeWaterLCR Data Variable
Same As
Final LCRI?
Child Care Facility
1 hr/child care facility
Child Care Facility
hrs childcare call op
mm) Contact school or
child care facility to
coordinate sample
collection logistics
0.25 hrs/school or child
care facility
hrs_school_coor_sample_op
Yes.
nn) Conduct
walkthrough at
school or child care
facility before the
start of sampling
Burden
1.40 to 1.71 hrs/school or
child care facility
Cost
$5.75 to $10.24/school or
child care facility
Burden
hrs_ walkthrough_school_op
Cost
cost_walkthrough_school
Yes.
oo) Travel to collect
samples
Burden
0.40 to 0.71 hrs/school or
child care facility
Cost
$5.75 to $10.24/school or
child care facility
Burden
hrs_travel_samp_school_op
Cost
cost_travel_samp_school
Yes.
pp) Collect samples
Burden
0.17 hrs/sample
Cost
$1.12/sample for CWSs
serving > 100,000 people
Burden
hrs_collect_samp_school_op
Cost
cost_collect_samp_school1
Yes.
qq) Analyze samples
In-House Analysis (CWSs >
lOOKonlv)
Burden: 0.44 hrs/sample
Cost: $3.92/sample
Commercial Analysis
$31.00/sample
In-House Analysis
hrs_ an alyze_samp_ op1
costjabj^samp1
Commercial Analysis
cost commercial lab1
Yes.
rr) Provide sampling
results to tested
facilities
Burden
0.05 to 0.11 hrs/tested
facility
Cost
$0.72/ tested facility
Burden
hrs_inform_samp_pe_school_op
Cost
cost_inform_samp_pe_school
Yes.
ss) Discuss sampling
results with the
school and child
care facility
1 hr/school or child care
facility
hrs_ result_ discuss_ op
Yes.
tt) Conduct detailed
discussion of high
sampling results
with schools and
child care facilities
5 hr/sample
Burden
hrs_school_help_op
Yes.
uu) Report school and
child care facility
N/A
Burden
hrs_report_sch_cc_results_op
No. Not
required
Final LCRI Economic Analysis Appendices B-82
October 2024
-------
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As
Final LCRI?
sampling results to
the State
under the
2021 LCRR.2
vv) Prepare and provide
annual report on
school and child
care facility
sampling program to
the State
Burden
1 to 8 hrs/CWS
Cost
$0.72/CWS
Burden
hrs_annual_report_school_prepare_op
Cost
cost_ann ual_report_school_dist
Yes.
Acronyms: AL = action level; 3Ts Toolkit = "3Ts for Reducing Lead in Drinking Water Toolkit"; CWS = community
water system; LCRI = Lead and Copper Rule Improvements; LCRR = Lead and Copper Rule Revisions; PWS = public
water system.
Source: "School_Child Care lnputs_Final.xlsx." Other data sources are provided following this exhibit for each
activity, as applicable.
Note:
1The burden and costs for these activities are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri,
and South Carolina (ASDWA, 2020a).
2 Under the LCRR, the sampling results are included as part of the annual report (activity vv)). Under the final LCRI,
systems would be required to report sampling results within 30 days of receiving the results.
Exhibit B-25 provides the SafeWater LCR model cost estimation approach for each activity under the first
five-year cycle including additional cost inputs required to calculate these costs under the 2021 LCRR.
The exhibit also indicates if the costing approach for a specific activity is the same as that under the final
LCRI, as documented in Chapter 4, Exhibit 4-45. The gray shaded row indicates an activity that is new
under the final LCRI and does not apply to the 2021 LCRR.
The main difference between the costing estimation approach for the 2021 LCRR and final LCRI is the
likelihood that a CWS will receive a waiver for testing a school or child care facility. Refer to Exhibit 3-72
and Exhibit 3-73 in Chapter 3 for these likelihoods under the 2021 LCRR and final LCRI, respectively.
Final LCRI Economic Analysis Appendices B-83
October 2024
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Exhibit B-25: CWS School and Child Care Facility First Five-Year Testing Cycle Cost Estimation in SafeWater LCR by Activity under
the 2021 LCRR1
Same as final LCR! (see Exhibit 4-45 in Chapter 4).
Final LCR! Economic Analysis Appendices
B-84
October 2024
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CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th - Range
Other Conditions
ss) Discuss sampling results with school and child care facilities
Same as final LCRI (see Exhibit 4-45 in Chapter 4).
tt) Conduct detailed discussion of high sampling results with school and child care facilities
Same as final LCRI (see Exhibit 4-45 in Chapter 4).
uu) Report school and child care facility sampling results to the State
N/A under the 2021 LCRR. New requirement under the final LCRI.
vv) Prepare and provide annual report on school and child care facility sampling to State
Same as final LCRI (see Exhibit 4-45 in Chapter 4).
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient non-community water system; PWS =
public water system.
Notes:
1 The first testing cycle is assumed to occur in Years 4 through 8 at elementary schools and child care facilities.
2 The burden and costs to provide sample bottles (cost_collect_samp_school) under activity pp) and conduct analyses under activity qq) are incurred by the
State in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
Final LCRI Economic Analysis Appendices
B-85
October 2024
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B.5.2.5.2 Second Five-Year TestinR Cycle On
Under the 2021 LCRR and final LCRI, after CWSs complete one five-year cycle of testing at elementary
schools and child care facilities, testing at these facilities is on request only. In addition, CWSs are only
required to test those secondary schools that request testing. The EPA assumed that five percent of
elementary and secondary schools, and licensed child care facilities per year would elect to participate
in the sampling program (pp_voluntary_partic). This estimate is based on the EPA's discussions with
Greater Cincinnati Water Works about their school testing program (available in the docket at EPA-HQ-
OW-2022-0801).
The EPA has developed system burden and costs for 12 activities the agency has identified as necessary
to implement the on request program for drinking water testing at schools and child care facilities as
shown in Exhibit B-26. The exhibit provides the unit burden and/or cost for each activity. The
assumptions used in the estimation of each activity follows the exhibit. The third column provides the
corresponding SafeWater LCR model data variable in red/italic font. In a few instances, some of these
activities are conducted by the State instead of the CWS. These activities are identified in the exhibit and
further explained in the exhibit notes. The last column indicates if the activities, unit burden or cost, and
SafeWater LCR data variables for the 2021 LCRR are identical to those used for the final LCRI, as
described in Chapter 4, Section 4.3.2.5.2. The gray shaded row indicates an activity that is not required
under the 2021 LCRR.
Exhibit B-26: CWS School and Child Care Facility Sampling Unit Burden and Cost Estimates
under the Second and Subsequent Five-Year Testing Cycles under the 2021 LCRR
Activity
Unit Burden
and/or Cost
SafeWater LCR Data Variable
Same As
Final LCRI?
ww) Update the list of
schools and child care
facilities and submit to
the State (every five
years)
0.08 hrs/school or
child care facility
hrs_school_identify_op
Yes.
xx) Contact schools and
child care facilities to
offer sampling
Burden
0.05 to 0.11
hrs/school or child
care facility
Cost
$0.47 to $0.72
Burden
hrs_school_annual_contact_op
Cost
cost_school_annual_contact
Yes.
yy) Contact the school or
child care facility to
coordinate sample
collection logistics
0.25 hrs/school or
child care facility
hrs_school_coor_sample_op
Yes.
Final LCRI Economic Analysis Appendices B-86
October 2024
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Activity
Unit Burden
and/or Cost
SafeWaterLCR Data Variable
Same As
Final LCRI?
zz) Conduct walkthrough
at school or child care
facility before the start
of sampling
Burden
1.40 to 1.71
hrs/school or child
care facility
Cost
$5.75 to
$10.24/school or
child care facility
Burden
hrs_ walkthrough_school_op
Cost
cost_walkthrough_school
Yes.
aaa) Travel to collect
samples
Burden
0.40 to 0.71
hrs/school or child
care facility
Cost
$5.75 to
$10.24/school or
child care facility
Burden
hrs_travel_samp_school_op
Cost
cost_travel_samp_school
Yes.
bbb) Collect samples
Burden
0.17 hrs/sample
Cost
$1.12/sample for
CWSs serving >
100K
Burden
hrs_ collect_samp_school_ op
Cost
cost_collect_samp_school1
Yes.
ccc) Analyze samples
In-house Analysis
(CWSs > 100K onlv)
Burden: 0.44
hrs/sample
Cost: $3.92/sample
Commercial
Analysis
$31.00/sample
In-House Analysis
hrs_ an alyze_samp_ op1
costjabj^samp1
Commercial Analysis
cos^commercialjab1
Yes.
ddd) Provide sampling
results to tested
facilities
Burden
0.05 to 0.11
hrs/tested facility
Cost
$0.72/ tested
facility
Burden
hrs_inform_samp_pe_school_op
Cost
cost_inform_samp_pe_school
Yes.
eee) Discuss sampling
results with the school
and child care facility
1 hr/school or child
care facility
hrs_ result_ discuss_ op
Yes.
fff) Conduct detailed
discussion of high
sampling results with
schools and child care
facilities
5 hr/sample
Burden
hrs_school_help_op
Yes.
Final LCRI Economic Analysis Appendices B-87
October 2024
-------
Activity
Unit Burden
and/or Cost
SafeWater LCR Data Variable
Same As
Final LCRI?
ggg) Report school and
child care facility
sampling results to the
State
N/A
Burden
hrs_report_sch_cc_results_op
No. Not
required
under the
2021
LCRR.2
hhh) Prepare and provide
annual report on
school and child care
facility sampling
program to the State
Burden
1 to 8 hrs/CWS
Cost
$0.72/CWS
Burden
hrs_annual_report_school_prepare_op
Cost
cost_ann ual_report_school_dist
Yes.
Acronyms: AL = action level; CWS = community water system; LCRI = Lead and Copper Rule Improvements; LCRR =
Lead and Copper Rule Revisions; PWS = public water system.
Source: "School_Child Care lnputs_Final.xlsx." Other data sources are provided following this exhibit for each
activity, as applicable.
Note:
1The burden and costs for these activities are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri,
and South Carolina (ASDWA, 2020a).
2 Under the LCRR, the sampling results are included as part of the annual report (activity hhh). Under the final LCRI,
systems would be required to report sampling results within 30 days of receiving the results.
Exhibit B-27 provides the SafeWater LCR model cost estimation approach for each activity under the
second and subsequent five-year cycles of the 2021 LCRR including additional cost inputs required to
calculate these costs. The exhibit also indicates if the costing approach for a specific activity is the same
as that under the final LCRI, as documented in Chapter 4, Exhibit 4-47. The gray shaded row indicates an
activity that is new under the final LCRI and does not apply to the 2021 LCRR.
Final LCRI Economic Analysis Appendices B-88
October 2024
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Exhibit B-27: PWS Second Five-Year Testing Cycle On School and Child Care Facility Sampling Phase Cost Estimation in SafeWater
LCR by Activity under the 2021 LCRR1
Final LCR! Economic Analysis Appendices
B-89
October 2024
-------
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency of
Activity
Lead 90th - Range
Other Conditions
N/A under the 2021 LCRR. New requirement under the final LCRI.
hhh) Prepare and provide annual report on school and child care facility sampling to State
Same as final LCRI (see Exhibit 4-47 in Chapter 4).
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; LCRR = Lead and Copper Rule Revisions; NTNCWS = non-transient
non-community water system; PWS = public water system.
Notes:
1 The second five-year testing cycle on is assumed to start in Year 9.
2 The burden and costs to provide sample bottles (cost_collect_samp_school) under activity bbb) and conduct analyses under activity ccc) are incurred by the
State in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
Final LCRI Economic Analysis Appendices
B-90
October 2024
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B.5.3 PWS Corrosion Control Costs under the 2021 LCRR
Under the LCRR, PWSs may be required to install CCT, re-optimize their existing CCT, or perform a "find-
and-fix"36 adjustment to their CCT. CCT installation and re-optimization are triggered based on the
system's lead 90th percentile range. The "find-and-fix" requirements are triggered under the 2021 LCRR
when an individual lead tap sample is greater than 15 ng/L. Any changes to the status of a system's CCT
may result in technology-related costs (capital and/or O&M), as well as ancillary costs for data
submission, consultation, and CCT studies.
The unit cost inputs and assumptions for CCT are the same under the 2021 LCRR and final LCRI;
however, the conditions under which they apply are different. Both rules require CCT installation for
systems without CCT that exceed the lead AL; however, the final LCRI lowers the lead AL from 15 to 10
Hg/L and removes CCT requirements associated with the TL under the LCRR. The final LCRI also lowers
the eligibility threshold for CWSs seeking a compliance option other than CCT from those serving 10,000
or fewer people to 3,300 or fewer people. Lastly, the final LCRI allows water systems to defer the
installation or re-optimization of CCT if they can remove all their LSLs and GRR service lines within five
years of initially exceeding the lead AL. This option was not available under the LCRR.
This section presents the following CCT-related costs:
• B.5.3.1: CCT Installation
• B.5.3.2: Re-optimization of Existing Corrosion Control Treatment
• B.5.3.3: Find-and-Fix Costs
• B.5.3.4: System Lead CCT Routine Costs
The derivation and values for baseline pH (baselineph_wocct, baselineph_woph, baselineph_wpo4ph,
baselineph_wph) and baseline P04 dose (baselinepo4dose) are the same as those used to calculate the
CCT costs for the final LCRI and can be found in Chapter 4, Section 4.3.3.
B.5.3.1 CCT Installation
Under the 2021 LCRR, PWSs without CCT may be required to install CCT if they exceed the lead AL of 15
Hg/L. The approach for estimating capital and O&M costs for CCT installation is the same under the 2021
LCRR as under the final LCRI, as described in Chapter 4, Section 4.3.3.1.1.
The EPA has developed system costs for an ancillary activity associated with CCT installation as shown in
Exhibit B-28. The exhibit provides the unit burden and/or cost for the activity. The third column provides
the corresponding SafeWater LCR model data variable in red/italic font. The last column indicates
whether the activity, unit burden or cost, and the SafeWater LCR data variable for the 2021 LCRR are
identical to those used for the final LCRI, as described in Chapter 4, Section 4.3.3.1.2.
36 In the final LCRI, the EPA is replacing the term "find-and-fix" with "Distribution System and Site Assessment" to
recognize that the fix to address the exceedance may be outside the control of the water system.
Final LCRI Economic Analysis Appendices
B-91
October 2024
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Exhibit B-28: PWS CCT Installation-Related Unit Burden and Cost Estimates under the 2021
LCRR
Activity1
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same As Final
LCRI?
a) Conduct a CCT
study
Study
• No LSLs (coupon testing): $30,372
• With LSLs (harvested pipe loop testing):
$307,744 for < 50,000 people; $376,685
for > 50,000 people
cost_cct_study_dem
No. See
discussion that
follows this
exhibit.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; LSL = lead service line;
PWS = public water system.
Notes:
1 Activity b), "Install CCT Treatment (PO4, PO4 with post treatment, pH adjustment, or modify pH)" was previously
discussed in Chapter 4, Section 4.3.3.1.1.
a) Conduct a study (cost_cct_study_dem). The EPA assumed States will require all systems to conduct
either harvested pipe loop testing or a coupon study prior to CCT installation under the 2021 LCRR.
The SafeWater LCR model uses the following set of assumptions:
• Systems required to conduct a CCT study will use a contractor.
• Systems without LSLs will use a coupon study at an estimated cost of $30,372 for
systems of all sizes.
• Systems with LSLs will conduct harvested pipe loop testing and will incur a cost of
$307,744 for those serving 50,000 or fewer people and $376,685 for those serving more
than 50,000 people.
Note that these assumptions for the 2021 LCRR differ from the final LCRI in which systems serving
10,000 or fewer people with LSLs will also use a coupon study in lieu of a harvested pipe loop study.
The development of harvested pipe loop and coupon test study costs are detailed in Technologies
and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2023).
Exhibit B-29 indicates that the costing approach for ancillary CCT installation is the same under the 2021
LCRR as under the final LCRI, as documented in Chapter 4, Exhibit 4-55.
Exhibit B-29: PWS Ancillary CCT Installation Cost Estimation in SafeWater LCR by Activity
under the 2021LCRR1
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th _ ....
„ Other Conditions
- Range
a) Conduct a CCT study
Same as final LCRI (see Exhibit 4-55 in Chapter 4).
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; PWS = public water system; NTNCWS = non-transient non-community water system.
Final LCRI Economic Analysis Appendices
B-92
October 2024
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B. 5.3.2 Re-optimization of Existing Corrosion Control Treatment
PWSs that have previously installed CCT may be required to re-optimize their treatment if they exceed
the lead TL or ALE under the LCRR. The EPA uses the same approach to estimate the costs for re-
optimizing existing CCT under the 2021 LCRR as under the final LCRI, as described in Chapter 4, Section
4.3.3.2.1.
The EPA has developed system ancillary costs for an ancillary activity associated with CCT re-
optimization as shown in Exhibit B-30. The exhibit provides the unit burden and/or cost for the activity.
The assumptions used in the estimation of the unit burden follow the exhibit. The third column provides
the corresponding SafeWater LCR model data variable in red/italic font. The last column indicates if the
activities, unit burden or cost, and SafeWater LCR data variables are identical for the 2021 LCR to those
used for the final LCRI, as described in Chapter 4, Section 4.3.3.2. For this activity, the estimated unit
cost for revising the CCT study is different for systems exceeding the TL than those exceeding the AL
under the 2021 LCRR. However, the unit costs for systems exceeding the AL is the same for both the
2021 LCRR and final LCRI.
Exhibit B-30: PWS CCT Ancillary Re-optimization Unit Burden and Cost Estimates under the
2021LCRR
Activity1
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same As Final LCRI?
c) Revise CCT
study
Svstems with TLE but no ALE
$6,148 to $ll,831/system
Svstems with ALE2
No LSLs: $30,372
with LSLs: $307,744 to $376,685
cost_revise_cct
cost_cct_study_dem
No. See explanation
following the exhibit.
Acronyms: ALE = action level exceedance, CCT = corrosion control treatment; LCRI = Lead and Copper Rule
Improvements; LSL = lead service line; TLE = trigger level exceedance.
Source: "CCT Study and Review Costs_Final.xlsx;" Technologies and Costs for Corrosion Control to Reduce Lead in
Drinking Water (USEPA, 2023).
Notes:
1 Activity d), "Re-optimize existing CCT" was previously discussed in Chapter 4, Section 4.3.3.2.1.
2 The unit cost is the same for systems that exceed the lead AL under the 2021 LCRR and final LCRI.
c) Revise CCT study (cost_revise_cct). The EPA assumes the following for systems that exceed the TL
but not the AL under the 2021 LCRR:
• States will require all systems to conduct a study prior to CCT re-optimization.
• Systems will use a contractor to conduct a study.
• Systems will revise their existing CCT (cost_revise_cct) that is estimated at $6,148 for
systems serving 3,300 or fewer people, $8,756 for systems serving 3,301 to 50,000 people,
and $11,831 for systems serving more than 50,000 people. Note that this may overestimate
costs because the 2021 LCRR gives States discretion to allow these systems to re-optimize
without first conducting a study.
Final LCRI Economic Analysis Appendices
B-93
October 2024
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For systems that exceed the AL under the 2021 LCRR, the EPA assumes that systems will conduct a
demonstration study with the same unit costs as presented in Chapter 4, Section 4.3.3.2.2 for the final
LCRI.
Exhibit B-31 shows the SafeWater LCR model cost estimation approach for system ancillary CCT re-
optimization study activities including additional cost inputs required to calculate these costs under the
2021 LCRR.
Exhibit B-31: PWS CCT Ancillary Re-optimization Cost Estimation in SafeWater LCR by Activity
under the 2021LCRR
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply
to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions
c) Revise CCT study
Material cost per system for the marginal
contractor cost for revision of CCT study.
cost_revise_cct
Cost applies as
written to
NTNCWSs.
At or
below AL
and above
TL
Model PWS re-
optimizing CCT
One time
Material cost per system for the marginal
contractor cost, with the difference
between coupon testing and harvested
pipe loop testing reflected in the
stratification of the data by system LSL
status.
Cost applies as
written to
NTNCWSs.
Above AL1
Model PWS re-
optimizing CCT
One time
cost_cct_study_dem
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; LSL = lead service
line; NTNCWS = non-transient non-community water system; PWS = public water system; TL = trigger level.
Notes:
1 The cost estimation approach is the same for systems that exceed the lead AL under the 2021 LCRR and final
LCRI.
B.5.3.3 Find-and-Fix Costs
Under the 2021 LCRR, water systems must undertake the same actions required under the final LCRI but
must do so if a single sample exceeds 15 ng/L, as opposed to if a single sample exceeds 10 ng/L under
the final LCRI. As noted previously in footnote 36, the EPA is replacing the term "find-and-fix" with
"Distribution System and Site Assessment" in the final LCRI. The final LCRI also clarifies the allowable
distance from the site with the lead result above 10 ng/L for the WQP monitoring location, but this does
not affect the unit cost inputs for find-and-fix activities.
The estimated likelihood that an individual lead sample is above 15 ng/L is presented in Chapter 3,
Section 3.3.5.3.1. Similar to the final LCRI, the EPA assumed in the SafeWater LCR model that in
response to individual lead tap water samples above 15 ng/L, model-PWSs will take progressively more
stringent corrective actions. These assumed actions are:
1. First sampling period with one or more individual tap water samples above 15 ng/L - model-
PWS will investigate the cause but not take any corrective action.
Final LCRI Economic Analysis Appendices
B-94
October 2024
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2. Second sampling period with one or more individual tap water samples above 15 ng/L - model-
PWS will perform spot flushing once in the distribution system.
3. Third sampling period with one or more individual tap water samples above 15 ng/L - model-
PWS will increase the pH level at one entry point.
4. Fourth sampling period with one or more individual tap water samples above 15 ng/L - model-
PWS will increase the pH at all other entry points (if more than one).
These corrective actions are not meant to encompass the entire suite of find-and-fix compliance options
but rather provide a representation of typical actions a PWS might take to correct reoccurring individual
lead tap samples over 15 ng/L.
The EPA used the same SafeWater LCR inputs and values under the 2021 LCRR and final LCRI, except as
noted for activities g) and h) below in Exhibit B-32.
• Burden hrs_flush_wqp_op and costs for systems to conduct flushing cost_flush_wqp as provided
in Chapter 4, Section 4.3.3.3.1.
• Cost to increase pH described in Chapter 4, Section 4.3.3.3.2.
• Ancillary costs, such as follow-up sampling, WQP sampling, reviewing incidents of system-wide
events and other system conditions, consulting with States prior to any CCT adjustments, and
reporting to the State. These activities are detailed in Chapter 4, Section 4.3.3.3.3 and shown in
Exhibit B-32.
Exhibit B-32: PWS Ancillary Find-and-Fix Unit Burden and Cost Estimates under the 2021
LCRR1
Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same As
Final LCRI?
e) Contact customers and
collect follow-up tap
sample
Burden per sample
CWSs: 3.4 to 3.7 hrs
NTNCWSs: 0.5 hrs
Costs per sample
CWSs: $5.75 to $13.09
NTNCWSs: $0
Burden
hrs_samp_ above_ al_ op
Cost
cost_samp_ above_ al
Yes.
f) Analyze follow-up lead
tap sample
In-house Analysis (CWSs > 100K
only)
Burden: 0.44 hrs/sample
Cost: $3.92
Commercial Analysis
$32.20
In-house Analysis
hrs_ an alyze_samp_ op2
cost_lab_lt_samp2
Commercial Analysis
cost commercial lab2
Yes.
g) Collect distribution
system WQP sample
Burden per sample per PWS
0.5 hrs
Cost for per sample
No CCT: $2.66 (CWS & NTNCWS)
pH adjustment:
Burden
hrs_ wqp_dssa_op
Cost
No CCT: cost_wqp_material
pH: cost_wqp_material_ph
No.3
Final LCRI Economic Analysis Appendices
B-95
October 2024
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Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same As
Final LCRI?
• $1.70 to $2.66 (CWS);
• $2.66 (NTNCWS)
Orthophosphate:
Orthophosphate:
• $0.63 to $1.07 (CWS)
cost_wqp_material_ortho
$2.66 (NTNCWS)
h) Analyze distribution
In-House Burden per sample
In-House Burden
No.3
system WQP sample
No CCT: 0.15 hrs (CWS & NTNCWS)
pH adjustment:
• 0.15 to 0.46 hrs (CWS)
• 0.15 hrs (NTNCWS)
Orthophosphate:
• 0.15 to 1.34 hrs (CWS)
• 0.15 hrs (NTNCWS)
In-House cost per sample
No CCT: $0.63 (CWS & NTNCWS)
pH adjustment:
• $0.63 to $0.98 (CWS)
• $0.63 (NTNCWS)
Orthophosphate:
• $0.63 to $1.07 (CWS)
• $0.63 (NTNCWS)
Commercial cost per sample
No CCT: $27.24 to $30.55 (CWS &
NTNCWS)
pH adjustment: $27.24 to 30.55
(CWS & NTNCWS)
Orthophosphate: $60.34 to
$61.89 (CWS & NTNCWS)
No CCT:
hrs_ wqp_analyze_dist_op
pH adjustment:
hrs_wqp_analyze_ph_op
Orthophosphate:
hrs_wqp_an alyze_ orth o_ op
In-House Cost
No CCT: cost_wqp_analyze
pH adjustment:
cost_ wqp_ph_an alyze
Orthophosphate:
cost_ wqp_ orth o_ an alyze
Commercial Cost
No CCT: cost_lab_wqp
pH: cost_lab_ph_wqp
Orthophosphate:
cost_lab_ortho_wqp
i) Review incidents of
CWSs: 4 to 30 hrs/system
hrs_deter_dssa_op
Yes.
systemwide event and
NTNCWSs: lto 14 hrs/system
other system conditions
j) Consult with the State
2 hrs per system with CCT
hrs_consult_dssa_op
Yes.
prior to making CCT
changes
k) Report follow-up
2 hrs/PWS serving < 50,000 people;
hrs_report_ dssa_ op
Yes.
sample results and
4 hrs/PWS serving > 50,000
overall find-and-fix
people
responses to the State
Acronyms: CCT = corrosion control treatment; CWS = community water system; DSSA = Distribution System and
Site Assessment; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient non-community water
system; PWS = public water system; WQP = water quality parameter.
Sources: See Chapter 4, Section 4.3.3.3.3.
Note:
1 Under the LCRR, the requirements triggered by a single sample above the AL are referred to as "find-and-fix."
Under the final LCRI, this term has been replaced by Distribution System and Site Assessment.
2 In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina, the State pays for the cost of bottles, shipping,
analysis, and providing sample results to the system. Thus, the State will incur the burden and cost for these
activities in lieu of the system (ASDWA, 2020a).
Final LCRI Economic Analysis Appendices
B-96
October 2024
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3 Under the final LCRI, systems without CCT are not required to conduct WQP monitoring, which corresponds to
activities g) and h) in the exhibit above.
Exhibit B-33 provides the SafeWater LCR model cost estimation approach for system ancillary find-and-
fix activities including additional cost inputs that are required to calculate the total costs under the 2021
LCRR.
Final LCRI Economic Analysis Appendices
B-97
October 2024
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Exhibit B-33: PWS Ancillary Find-and-Fix Cost Estimation in SafeWater LCR by Activity under the 2021 LCRR12
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
e) Contact customers and collect follow-up tap samples3
The number of required samples per system >15 |jg/L multiplied by the total of
the hours per sample times the system labor rate, plus the cost of materials per
sample.
PWSs not on reduced tap
sampling and not doing POU
sampling
Twice a year
(pp_above_al_bin_three*numb_samp_customer)*((hrs_samp_above_al_op*rat
e_op)+cost_samp_above_al)
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Cost applies as
written to
NTNCWSs.
At or below
TL
PWSs on annual tap
sampling and not doing POU
sampling
p_tap_annual
Once a year
The number of required samples per system >15 |jg/L multiplied by the total of
the hours per sample times the system labor rate, plus the cost of materials per
sample.
(pp_above_al_bin_three*numb_reduced_tap)*((hrs_samp_above_al_op*rate_o
p)+cost_samp_above_al)
PWSs on triennial reduced
tap sampling and not doing
POU sampling
p_tap_triennial
Every 3
years
The number of required samples per system >15 |jg/L multiplied by the total of
the hours per sample times the system labor rate, plus the cost of materials per
sample.
(pp_above_al_bin_two*numb_samp_customer)*((hrs_samp_above_al_op*rate
op)+cost samp above al)
Cost applies as
written to
NTNCWSs.
At or below
AL and
above TL
All PWSs with at least one
sample > 15 |jg/L
Once a year
The number of required samples per system >15 |jg/L multiplied by the total of
the hours per sample times the system labor rate, plus the cost of materials per
sample.
(pp_above_al_bin_one*numb_samp_customer)*((hrs_samp_above_al_op*rate
op)+cost samp above al)
Above AL
All PWSs with at least one
sample > 15 |jg/L
Twice a year
Final LCR! Economic Analysis Appendices
B-98
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
f) Analyze follow-up lead tap sample3
The number of samples multiplied by the likelihoods for a sample analyzed in
house and a sample analyzed in a commercial lab times the different labor and
material cost burdens for each type of analysis.
(((pp_above_al_bin_three*numb_samp_customer) *pp_lab_samp)*( (hrs_analyz
e_samp_op*rate_op)+cost_lab_lt_samp))+(((pp_above_al_bin_three*numb_sa
mp_customer)*pp_commercial_samp)*cost_commercial_lab)
PWSs is not on reduced tap
sampling and not doing POU
sampling
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Twice a year
Cost applies as
written to
NTNCWSs.
At or below
TL
PWSs on annual tap
sampling and not doing POU
sampling
p_tap_annual
Once a year
The number of samples multiplied by the likelihoods for a sample analyzed in
house and a sample analyzed in a commercial lab times the different labor and
material cost burdens for each type of analysis.
(((pp_above_al_bin_three*numb_reduced_tap)*pp_lab_samp)*( (hrs_analyze_s
amp_op*rate_op)+cost_lab_lt_samp))+(((pp_above_al_bin_three*numb_reduc
ed tap)*pp commercial samp)*cost commercial lab)
PWSs on triennial reduced
tap sampling and not doing
POU sampling
p_tap_triennial
Every 3
years
The number of samples multiplied by the likelihoods for a sample analyzed in
house and a sample analyzed in a commercial lab times the different labor and
material cost burdens for each type of analysis.
(((pp_above_al_bin_two*numb_samp_customer)*pp_lab_samp)*((hrs_analyze
_samp_op*rate_op)+cost_lab_lt_samp))+(((pp_above_al_bin_two*numb_samp
_customer)*pp_commercial_samp)*cost_commercial_lab)
Cost applies as
written to
NTNCWSs.
At or below
AL and
above TL
All PWSs with at least one
sample > 15 |jg/L
Once a year
Final LCRI Economic Analysis Appendices
B-99
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to a
Model PWS
Lead 90th- „ ....
„ Other Conditions
Range
Frequency
of Activity
The number of samples multiplied by the likelihoods for a sample analyzed in
house and a sample analyzed in a commercial lab times the different labor and
material cost burdens for each type of analysis.
(((pp_above_al_bin_one*numb_samp_customer)*pp_lab_samp)*((hrs_analyze
_samp_op*rate_op)+cost_lab_lt_samp))+(((pp_above_al_bin_one*numb_samp
_customer)*pp_commercial_samp)*cost_commercial_lab)
Cost applies as
written to
NTNCWSs.
Above AL
All PWSs with at least one
sample > 15 |jg/L
Twice a year
g) Collect distribution system WQP sample
The number of required samples per system >15 |jg/L multiplied by the total of
hours per sample times the system labor rate, plus the material cost per
sample. A system only needs to collect an additional WQP monitoring sample if
there is not existing WQP monitoring done near the site of the >15 |jg/L tap
sample.
numb_wqp_sites_added
*((hrs_ wqp_ dssa_op *rate_op)+cost_ wqp_material_ph)
Cost does not
apply to
NTNCWSs.
All
PWSs with existing CCT of
pH and not doing POU
sampling
pbaseph
Once per
event
The number of required samples per system >15 |jg/L multiplied by the total of
hours per sample times the system labor rate, plus the material cost per
sample. A system only needs to collect an additional WQP monitoring sample if
there is not existing WQP monitoring done at or near the site of the >15 |jg/L
tap sample.
numb_wqp_sites_added*((hrs_wqp_dssa_op*rate_op)+cost_wqp_material_ort
ho)
Cost does not
apply to
NTNCWSs.
All
PWSs with existing CCT of
PO4 or both PO4 and pH
adjustment and not doing
POU sampling
pbasepo4, pbasephpo4
Once per
event
The number of required samples per system >15 |jg/L multiplied by the total of
hours per sample times the system labor rate, plus the material cost per
sample. A system only needs to collect an additional WQP monitoring sample if
there is not existing WQP monitoring done at or near the site of the >15 |jg/L
tap sample.
numb wqp sites added*((hrs wqp dssa op*rate op)+cost wqp materia)
Cost does not
apply to
NTNCWSs.
All
PWSs without CCT
1 - pws_cct
Once per
event
Final LCRI Economic Analysis Appendices
B-100
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
h) Analyze distribution system WQP sample
The number of samples multiplied by the likelihoods for a sample analyzed in
house and a sample analyzed in a commercial lab times the different labor and
material cost burdens for each type of analysis.
A system only needs to collect an additional WQP monitoring sample if there is
not existing WQP monitoring done near the site of the >15 |jg/L tap sample.
((numb_wqp_sites_added*pp_lab_samp)*((hrs_wqp_analyze_ph_op*rate_op)+
cost_wqp_ph_analyze))+((numb_wqp_sites_added*pp_commercial_samp)*cos
t_lab_ph_wqp)
Cost does not
apply to
NTNCWS
All
PWS with existing CCT of pH
and not doing POU sampling
pbaseph
Once per
event
The number of samples multiplied by the likelihoods for a sample analyzed in
house and a sample analyzed in a commercial lab times the different labor and
material cost burdens for each type of analysis.
A system only needs to collect an additional WQP monitoring sample if there is
not existing WQP monitoring done near the site of the >15 |jg/L tap sample.
((numb_wqp_sites_added*pp_lab_samp)*((hrs_wqp_analyze_ortho_op*rate_o
p)+cost_wqp_ortho_analyze))+((numb_wqp_sites_added*pp_commercial_sam
p)*cost_lab_ortho_wqp)
Cost does not
apply to
NTNCWS
All
PWSs with existing CCT of
PO4 or both PO4 and pH
adjustment and not doing
POU sampling
pbasepo4, pbasephpo4
Once per
event
The number of samples multiplied by the likelihoods for a sample analyzed in
house and a sample analyzed in a commercial lab times the different labor and
material cost burdens for each type of analysis.
A system only needs to collect an additional WQP monitoring sample if there is
not existing WQP monitoring done near the site of the >15 |jg/L tap sample.
((numb_wqp_sites_added*pp_lab_samp)*((hrs_wqp_analyze_dist_op*rate_op)
+cost_wqp_analyze))+((numb_wqp_sites_added*pp_commercial_samp)*cost_l
ab_wqp)
Cost does not
apply to
NTNCWSs.
All
PWSs without CCT
1 - pws_cct
Once per
event
i) Review incidents of systemwide event and other system conditions
The labor hours for review per system multiplied by the system labor rate.
(hrs_deter_dssa_op*rate_op)
Cost applies as
written to
NTNCWSs.
All
All PWSs with at least one
sample > 15 |jg/L
Once per
event
Final LCRI Economic Analysis Appendices
B-101
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
j) Consult with State prior to making CCT changes
The labor hours per system multiplied by the system labor
(hrs_consult_dssa_op*rate_op)
Cost applies as
written to
NTNCWSs.
All
All PWSs where a second
sampling period has at least
one sample > 15 |jg/L
Once per
event
k) Report follow-up sample results and overall "find-and-fix" responses
Hours for reporting multiplied by the system labor rate.
(hrs_report_dssa_op*rate_op)
Cost applies as
written to
NTNCWSs.
All
All PWSs with at least one
sample > 15 |jg/L
Once per
event
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-community water system; PO4
= orthophosphate; POU = point-of-use; PO4 = orthophosphate; PWS = public water system; TL = trigger level; WQP = water quality parameter.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• pbaseph, pbasepo4, and pbasephpo4: Likelihood system has pH adjustment, orthophosphate, or pH adjustment and orthophosphate for their CCT
(Chapter 4, Section 4.3.2.2.1).
• pp_lab_samp and pp_commercial_samp\ Likelihood that system will use in-house laboratory or commercial laboratory, respectively (Chapter 4,
Section 4.3.2.1.2).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2Systems on 9-year monitoring schedules cannot have any lead or copper in their entire distribution system including all buildings they serve and thus, none
should have any samples above 15 ng/L and be subject to find-and-fix requirements.
3 The burden and costs to provide sample bottles (cost_samp_above_al) under activity e) and conduct analyses under activity f) are incurred by the State in
Arkansas, Louisiana, Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
Final LCRI Economic Analysis Appendices
B-102
October 2024
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B.5.3.4 System Lead CCTRoutine Costs
The EPA developed routine costs associated with CCT under the 2021 LCRR as shown in Exhibit B-34. The
exhibit provides the unit burden each activity. The assumptions used in the estimation of each activity
follows the exhibit. The third column provides the corresponding SafeWater LCR model data variable in
red/italic font. The last column indicates that the activity, unit burden or cost, and SafeWater LCR data
variable for the 2021 LCRR are identical to those used for the final LCRI, as described in Chapter 4,
Section 4.3.3.4.
Exhibit B-34: PWS CCT Routine Unit Burden and Cost Estimates under the 2021 LCRR
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As
Final LCRI?
1) Review CCT guidance
1 hr/system with CCT
serving > SOK/update1
hrs_rev_cct_op
Yes.
m) Provide WQP data to the
State and discuss during
sanitary survey
1.5 to 3 hrs/system with
CCT per sanitary survey2
hrs_sanit_surv_op
Yes.
n) Notify and consult with the
State if CCT actions are
required in response to
source water change
• 10 to 22 hrs/system on
reduced tap monitoring
• 6 to 12 hrs/system on
standard tap monitoring
hrs_coop_source_chng_red_op
hrs_coop_source_chng_rout_op
Yes.
o) Notify and consult with the
State if CCT actions are
required in response to
treatment change
46 to 84 hrs/system
hrs_coop_treat_chng_op
Yes.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; WQP = water quality
parameter.
Sources:
frequency of CCT guidance updates is assumed to be every five years.
2Sanitary surveys are conducted at least every five years for NTNCWSs and every three years for CWSs except
where ground water CWSs meet special performance criteria and are permitted to conduct sanitary surveys every
five years (p_spec_req).
I) & m): "CCT Study and Review Costs_Final.xlsx."
n): "Likelihood_SourceChange_Final.xlsx."
o): "Likelihood_TreatmentChange_Final.xlsx;" ASDWA, 2024.
Note: For the proposed LCRI EA, the EPA assumed a different burden for systems on standard and reduced
monitoring. For the final LCRI EA, the EPA used estimates provided by ASDWA in its 2024 CoSTS model (ASDWA,
2024) and assumed systems and States would incur the same burden to provide a report and conduct a review,
respectively, regardless of the system's monitoring schedule.
Exhibit B-35 provides the SafeWater LCR model cost estimation approach for routine system activities
related to CCT including additional cost inputs required to calculate these costs under the 2021 LCRR. It
also indicates if the costing approach is the same for the 2021 LCRR as that under the final LCRI, as
documented in Chapter 4, Exhibit 4-71.
Final LCRI Economic Analysis Appendices B-103
October 2024
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Exhibit B-35: PWS Lead CCT Routine Cost Estimation in SafeWater LCR by Activity under the
2021LCRR1
CWS Cost Per Activity
I) Review CCT guidance
Same as final LCRI (see Exhibit 4-71 in Chapter 4).
m) Provide WQP data to State and discuss during sanitary survey2
Same as final LCRI (see Exhibit 4-71 in Chapter 4).
n) Notify and consult with State on response to a change in source water
The total hours per system
multiplied by the system labor
rate.
At or
below
Model PWS that is not on
reduced tap sampling with a
change in source water
(hrs_coop_source_chng_rout_o
p*rate_op)
TL
1 - (p_tap_annual +
pjtapjtrienniai + p_tap_nine) *
p source chng
Cost
applies as
written to
NTNCWSs
Above
TL
Model PWSs with a change in
source water
p_source_chng
Once per event
The total hours per system
multiplied by the system labor
rate.
At or
below
Model PWS that is on reduced
tap sampling with a change in
source water
(hrs_coop_source_chng_red_o
p*rate_op)
TL
(p_tap_annual + p_tap_triennial
+ p_tap_nine) *
p_source_chng
o) Notify and consult with State on response to a change in water treatment
Same as final LCRI (see Exhibit 4-71 in Chapter 4).
Conditions for Cost to Apply
to a Model PWS
Frequency of Activity
Lead
90th -
Range
Other Conditions
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; PWS = public water system; TL = trigger
level; WQP = water quality parameter
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• p_tap_annual, p_tap_triennial, and p_tap_nine: Likelihood a system will qualify to collect lead tap
samples at an annual, triennial, and nine-year frequency, respectively (Chapter 3, Section 3.3.7.2).
• p_source_chng\ Likelihood that a system will change sources in a given year (Chapter 3, Section 3.3.9.1).
• p_treat_chng: Likelihood that a system will change treatment in a given year (Chapter 3, Section 3.3.9.3).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
B.5.4 PWS Lead Service Line Inventory and Replacement Costs under the 2021 LCRR
The cost analysis for inventory and SLR activities under the 2021 LCRR are in the following subsections:
• B.5.4.1: Service Line Inventory-Related Activities
Final LCRI Economic Analysis Appendices B-104
October 2024
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• B.5.4.2: Service Line Replacement Plan
• B.5.4.3: Physical Service Line Replacements
• B.5.4.4: Ancillary Service Line Replacement Activities
• B.5.4.5: Goal-Based Replacement Program Activities
Note that the last section, goal-based program replacement activities, are not included in the final LCRI
analysis because the final LCRI requires full replacement of all lead and GRR service lines by a specific
time frame and thus, does not include a provision for a goal-based SLR.
A key input to service line inventory and replacement-related costs is the baseline percentage of
systems with lead content service lines and the percent of service lines in those systems that are lead
content. The economic analysis for the 2021 LCRR (USEPA, 2020) used two datasets to characterize LSLs
in CWSs based on surveys done by the AWWA. Since the 2021 LCRR was finalized, LSL survey data from
the 7th Drinking Water Infrastructure Survey Assessment (DWINSA), collected primarily from February
2021 - December 2021, have become available. Due to the extensiveness and representativeness of the
dataset and the detailed information gathered on service line material, the EPA uses the 7th DWINSA
results to characterize service line material for this LCRI economic analysis in place of the two previous
AWWA surveys. For additional discussion of the 7th DWINSA dataset and the EPA's decision to use it to
characterize service line material for the final LCRI economic analysis, See Chapter 3, Sections 3.2.5 and
3.3.4.
Unlike the datasets used for the 2021 LCRR economic analysis, the 7th DWINSA dataset includes
information on GRR and unknown service lines. The EPA used a combined estimate of lead, GRR, and
unknowns service lines to estimate the total service lines with known and potential lead content. The
EPA used this baseline estimate of known and potential LSLs consistently for the pre-2021 LCR, 2021
LCRR, and final LCRI analyses. For more information, see Chapter 3, Section 3.3.4.1.2.
Where available, the EPA used system-specific information on number of LSLs for PWSs serving greater
than 1 million people. For NTNCWSs, the EPA used the same approach for estimating the number of lead
content service lines as was used for the 2021 LCRR economic analysis (See Chapter 3, Section 3.3.4.2
for detailed information).
Under all 2021 LCRR replacement programs, a service line is counted toward a system's replacement
rate if the entire line is replaced. This includes replacement of both the system- and customer-side of
the service line or removing the remaining portion of the service line (assumed to be the customer's
portion).
B.5.4.1 Service Line Inventory-Related Activities
As noted in Chapter 4, Section 4.3.4.1, the 2021 LCRR required systems to prepare an initial inventory by
October 16, 2024, which is prior to the final LCRI analysis period. Therefore, the cost for preparing the
initial inventory is not included in the final LCRI or 2021 LCRR cost analysis. The 2021 LCRR requires
systems with lead, GRR, and unknown service lines to prepare and submit inventory updates on the
same schedule as a system's tap sampling monitoring, but no more frequently than annually. The final
LCRI requires annual inventory updates (see Chapter 4, Section 4.3.4.1.2 for unit costs for these
Final LCRI Economic Analysis Appendices B-105
October 2024
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activities). The EPA made a simplifying assumption that systems would also submit annual inventory
updates under the 2021 LCRR as they replace service lines and identify unknowns. This assumption
could lead to an overestimate of inventory-related 2021 LCRR costs, although the EPA expects the
overestimate to be minor because the unit cost for the activity is small at 1 hour per water system.
The final LCRI has additional requirements for water systems to update their inventories with
information on connectors (see Chapter 4, Section 4.3.4.1.2) and to validate the accuracy of the material
categorization of a proportion of non-lead service lines (see Chapter 4, Section 4.3.4.1.3), which are not
included in the 2021 LCRR cost analysis.
The EPA has developed costs for relevant inventory-related activities under the 2021 LCRR, as shown in
Exhibit B-36. The exhibit provides the unit burden and/or cost for each activity and the SafeWater LCR
data variable in red/italic font. The last column indicates if the activity, unit burden and/or cost, and
SafeWater LCR data variable are identical to those used for the final LCRI, as described in Chapter 4,
Section 4.3.4.1.2. Gray shaded rows indicate activities that are not required under the 2021 LCRR.
Exhibit B-36: PWS LSL Inventory-Related Unit Burden and Cost Estimates under the 2021 LCRR
Activity
Unit Burden and/or
Cost
SafeWater LCR Data Variable
Same As Final LCRI?
a) Conduct records
review for connector
materials
N/A
hrs_updated_initial_inv_op
No. Not required
under the 2021
LCRR.
b) Compile and submit
connector updated
LCRR initial inventory
information (baseline
inventory) to the
State
N/A
hrs_report_updated_initial_inv_op
No. Not required
under the 2021
LCRR.
c) Identify material for
unknown service lines
$35.94 to $52.55 per
unknown service line
investigated each
year
cost_update
Yes.
d) Report annual
inventory updates to
the State
lhr per CWS and 1
hr per NTNCWS per
year for systems with
lead, GRR, or
unknown service
lines.1
hrs_ report_ in v_ op
Yes
e) Conduct field
investigations for
inventory validation
N/A
cost_valid
No. Not required
under the 2021
LCRR.
f) Report validation
results to the State
N/A
hrs_ valid_ report_ op
No. Not required
Under the 2021
LCRR.
Acronyms: CWS = community water system; GRR = galvanized requiring replacement; LSL = lead service line;
NTNCWS = non-transient non-community water system; LCRI = Lead and Copper Rule Improvements; LCRR = Lead
and Copper Rule Revisions.
Note: The 2021 LCRR requires systems with lead, GRR, and unknown service lines to prepare and submit inventory
updates on the same schedule as a system's tap sampling monitoring, but no more frequently than annually. The
Final LCRI Economic Analysis Appendices B-106
October 2024
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EPA assumed systems would submit annual inventory updates under the 2021 LCRR as they replace service lines
and identify unknowns.
Exhibit B-37 provides the SafeWater LCR model costing approach for these inventory-related activities
and indicates if the activity applies to the 2021 LCRR or is the same as the final LCRI that presented in
Exhibit 4-83 in Chapter 4. The gray shaded rows indicate activities that do not apply to the 2021 LCRR.
Exhibit B-37: Lead Service Line Inventory Cost Estimation in SafeWater LCR by Activity under
the 2021 LCRR
Acronyms: CWS = community water system; LCRR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; PWS = public water system.
B.5.4.2 Service Line Replacement Plan
All CWSs and NTNCWSs with known or potential lead content service lines are required to prepare a SLR
plan under the 2021 LCRR and the final LCRI. The required contents of the plan, however, are different
between the two regulations, as explained later in this section. In addition, the LCRI includes new
requirements for systems with lead, GRR, or unknown services lines to update their plan annually or to
certify no change (see Exhibit B-38, activity j)), as well as additional reviews and consultations for
systems seeking or on a deferred replacement schedule (see activities i) and k)). Exhibit B-38 provides
the unit burden and/or cost for the service line replacement plan activities under the 2021 LCRR and the
SafeWater LCR data variable name in red italics font. The last column indicates if the activity, unit
burden and/or cost, and SafeWater LCR data variable name are identical to those used for the final LCRI,
as described in Chapter 4, Section 4.3.4.1.2. The gray shaded rows indicates activities that are not
required under the 2021 LCRR.
Final LCRI Economic Analysis Appendices B-107
October 2024
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Exhibit B-38: PWS Service Line Replacement Plan Unit Burden and Cost Estimates under the
2021LCRR
Activity
Unit Burden and/or
Cost
SafeWater LCR Data
Variable
Same as Final
LCRI?
g) Develop initial SLR plan
and submit to the State
for review (one-time)
12 to 52 hrs/CWS;
12 hrs/NTNCWS
hrs_slr_plan_op
No. See discussion
following this
exhibit.
h) Identify funding options
for full SLRs (one-time)
68to 170 hrs/CWS
hrs_fin_op_op
Yes.
i) Include information on
deferred deadline and
associated replacement
rate in the SLR plan1
N/A
hrs_slr_plan_defer_op
No. Not required
under the 2021
LCRR.
j) Update SLR plan annually
or certify no changes
N/A
hrs_slr_plan_ update_ op
No. Not required
under the 2021
LCRR.
k) Provide a
recommendation of the
deferred deadline and
associated replacement
rate2
N/A
hrs_defer_update_op
No. Not required
under the 2021
LCRR.
Acronyms: CWS = community water system;; LCRI = Lead and Copper Rule Improvements; LCRR = Lead and
Copper Rule Revisions. NTNCWS = non-transient non-community water system; SLR = service line replacement.
g) Develop initial SLR plan and submit to the State for review (hrs_slr_plan_op). Under the 2021
LCRR, all systems with lead, GRR, and/or unknown service lines are required to develop a plan for
their SLR program that includes the following elements:
• A strategy for determining the composition of lead status unknown service lines in its inventory.
• A strategy for informing customers before a full or partial SLR.
• Procedures for coordinating the full SLR.
• A funding strategy for conducting SLR that includes ways to accommodate customers that are
unable to pay to replace the portion they own.
• A procedure for customers to flush service lines and premise plumbing of particulate lead post-
replacement.
• The EPA retained this requirement for the final LCRI but with some modifications, as detailed in
Chapter 4, Section 4.3.4.2, activity g) and activity i) for systems eligible for a deferred deadline.
Specific only to the 2021 LCRR for those CWSs serving more than 10,000 people, the plan also must
include a recommended goal should the system be triggered into the goal-based program upon
having a TLE. This requirement for developing a replacement goal was not retained under the LCRI as
the EPA is eliminating the trigger level.
Final LCRI Economic Analysis Appendices B-108
October 2024
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For the 2021 LCRR Economic analysis (USEPA, 2020), the EPA based the PWS burden estimate for
preparing the plan on the estimate from the Association of State Drinking Water Administrators
(ASDWA) 2020 CoSTS model for States to review it. Specifically, the EPA assumed systems would
require twice the burden to prepare the plan as for the State to review it. The burden
(hrs_slr_plan_js) assumes 6 hrs for States to review the plan for small CWSs and NTNCWSs, 10 for
medium CWSs, and 18 for large CWSs (ASDWA, 2020b; 2024). The EPA assumed that the additional
elements to be included in the replacement plan compared to the 2021 LCRR requirements would be
minimal compared to the other elements of the plan and assumed the same burden for preparing the
plan except for the burden to prepare the replacement goal under the LCRR. The EPA assumed that
CWSs serving > 10,000 people would spend an additional 16 hours to develop the goal replacement
rate and provide justification on why they recommended a certain goal rate. See Exhibit B-39 for the
total estimated PWS burden to prepare the plan under the 2021 LCRR that includes developing and
justifying the goal rate.
Exhibit B-39: Estimated Burden for Systems to Develop a SLR Plan under the 2021 LCRR
System Size
(Population Served)
hrs_slr_plan_op
CWSs
NTNCWSs
<3,300
12
12
3,301-10,000
20
12
10,001-50,000
36
12
>50,000
52
12
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system.
Source: "LSLR Ancillary Costs_Final.xlsx."
Exhibit B-40 provides the SafeWater LCR model costing approach for these activities and indicates that
the approach is the same under the 2021 LCRR as that used for the final LCRI, as provided in Chapter 4,
Exhibit 4-89.
Exhibit B-40: SLR Plan Cost Estimation in SafeWater LCR by Activity under the 2021 LCRR
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
g) Develop initial SLR plan and submit to State for review
Same as final LCRI (see Exhibit 4-89 in Chapter 4).
h) Identify funding options for full SLRs
Same as final LCRI (see Exhibit 4-89 in Chapter 4).
i) Include information on deferred deadline and associated replacement rate in the SLR
plan
N/A. New requirement under the final LCRI.
Final LCRI Economic Analysis Appendices B-109
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
j) Update SLR plan annually or certify no changes
N/A. New requirement under the final LCRI.
k) Provide a recommendation of the deferred deadline and associated replacement rate
N/A. New requirement under the final LCRI.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; SLR = service line
replacement; NTNCWS = non-transient non-community water system; PWS = public water system.
B.5.4.3 Physical Service Line Replacements
Physical replacement of lead and GRR service lines are required under both the 2021 LCRR and the final
LCRI. The unit costs for service line replacement are the same under both regulations. As discussed in
Chapter 3, Section 3.3.4.3, several States already require PWSs to replace service lines with lead
content. Since these requirements already exist, these State-required replacements37 are not included in
the cost or benefits of the 2021 LCRR. For each PWS in a State with an existing SLR requirement,
SafeWater LCR first calculates the number of SLs that would need to be replaced each year under the
2021 LCRR absent any State requirement. These are known as the PWS's Federal SLRs. Next, SafeWater
LCR calculates the number of SLs that would need to be replaced each year under the State
requirements, absent any federal requirement. These are known as the PWS's State SLRs. SafeWater
LCR then determines the PWS's Total SLR as the maximum of the Federal or State Replacements. Finally,
SafeWater LCR calculates the PWS's SLRs due to the 2021 LCRR as the difference between the PWS's
Total SL replacements and the PWS's State SL replacements. Only the SL replacements due to the 2021
LCRR are included in the cost and benefit estimates of the 2021 LCRR. However, the PWS's Total SL
replacements are tracked as they count towards the PWS's SL replacement requirement and total lines
replaced in the system. Exhibit B-41 provides the unit burden and/or cost for the activities and the
SafeWater LCR data variable name in red italics font. The last column indicates that the activity, unit
burden or cost, and SafeWater LCR data variable are identical to those used for the final LCRI, as
described in Chapter 4, Section 4.3.4.3. (Also see Appendix A for additional details on the unit costs for
SLR). Note that both approaches also use the same baseline estimate of service lines with lead content,
and the same estimated proportion of those service lines that are full LSLs, partial LSLs, and GRR service
lines as presented in Chapter 3, Section 3.3.4.1.2.
Exhibit B-41: Unit Costs for Service Line Replacement under the 2021 LCRR
Activity
Cost Estimate Range
(2020$)
SafeWater LCR Data Variable
Same as Final LCRI?
1) System replaces lead
and GRR service lines
Full: $6,507 - $8,519;
Partial: $1,920-$5,400;
cost_lslr_lsl_reg_mand_pws;
cost_lslr_partial_reg_pws;
Yes.
37 The States of Illinois, Michigan, New Jersey, and Rhode Island have passed State laws and regulations requiring
mandatory service line replacement independent of their tap monitoring results.
Final LCRI Economic Analysis Appendices B-110
October 2024
-------
Activity
Cost Estimate Range
(2020$)
SafeWater LCR Data Variable
Same as Final LCRI?
GRR: $1,920-$5,400
cost Islr gal prev Isl reg pws
Acronyms: GRR = galvanized requiring replacement; LCRI = Lead and Copper Rule Improvements.
Source: "LSLR Unit Cost.xlsx."
The conditions under which SLR is required are different under the 2021 LCRR compared to the final
LCRI. Under the LCRR, SLR requirements are tied to the system's 90th percentile lead concentration or
can be a result of customer-initiated activities. Replacement requirements under the 2021 LCRR for
systems that exceed the lead AL of 15 ng/L (referred to as "mandatory replacement) are as follows:
• CWSs serving more than 10,000 that exceed the lead AL must fully replace lead and GRR service
lines on a rolling two-year average of 3 percent per year using a baseline number of lead, GRR,
and unknown service lines at the time the system first exceeds the lead AL.
• CWSs serving 10,000 or fewer people and NTNCWSs can choose among four compliance
options: 1) Replace all lead and GRR service lines, 2) install POU treatment, 3) install/re-optimize
CCT, or 4) replace all lead-bearing plumbing material.38 Systems choosing SLR as their approved
compliance option must replace lead and GRR service lines at a schedule set by the State not to
exceed 15 years and must replace all lead and GRR service lines regardless of their subsequent
lead 90th percentile value.
The 2021 LCRR also requires systems to initiate goal-based replacement if they are below the AL but
exceed the TL of 10 ng/L. See Section B.5.4.5 for all activities and unit burden and costs related to goal-
based replacement.
In addition to requirements for systems that exceed the lead AL or TL, the 2021 LCRR requires all water
systems to replace their portion of a lead or GRR service line if a customer notifies them or, through the
normal course of business, the system becomes aware that the customer is replacing their side (referred
to as "customer-initiated" replacement). The 2021 LCRR cost analysis includes an estimated rate for
customer-initiated replacement for those systems not conducting mandatory replacement upon
exceeding the lead TL or AL. For the final LCRI, all systems would be required to implement a SLR
program, so customer-initiated replacement does not apply.
38 The EPA uses a cost minimization assumption in the SafeWater LCR cost model and assigns the least cost
alternative between the SLR, CCT, and POU compliance alternatives. The EPA lacks the system characteristic data
that would allow the agency to determine a small system's cost for replacement of lead-bearing plumbing
materials because of the significant variability among systems and the plumbing materials in the buildings they
serve. The EPA assumed a system would only select the replacement of lead-bearing plumbing materials
compliance option if it cost less than the three other alternative compliance options. By selecting the least cost of
the three other options the EPA has accounted for the costs that small water systems would incur but may be
overestimating the costs for those systems that find the cost of lead-bearing plumbing replacement to be less than
the other three options.
Final LCRI Economic Analysis Appendices B-lll
October 2024
-------
The EPA estimated the likelihood of customer-initiated replacements to be 0.05 percent of lead and GRR
service lines per year (p_cust_init_lslr) based on a 2020 report titled Lead Pipes and Environmental
Justice: A Study of Lead Pipe Replacement in Washington, DC (Environmental Defense Fund and
American University School of Public Affairs, 2020). The report includes a graph (Figure 7) showing the
number of customer-initiated LSLRs each year from 2009 to 2018. The rate was approximately 25 LSLs
per year (out of approximately 48,000 LSLs in DC Water's system39) from 2009 through 2013. The rate
jumped in 2014 to nearly 200 replacements per year, likely because of a new incentive for home
renovators to participate in the program before applying for a permit. The number jumped again in 2017
to more than 300 replacements after the highly publicized elevated lead issues in Flint, Michigan and DC
Water launched a new online interactive online map which made it easier for customers to see which
properties had LSLs. The EPA used the customer-initiated replacement rate from 2009 to 2013 (25 /
48,000 = 0.05 percent) to represent a typical system, although the EPA recognizes that this value may be
high for some systems because of the highly publicized case of elevated lead in Washington, D.C.'s water
in 2004.
Exhibit B-42 provides the SafeWater LCR model costing approach for these activities including additional
cost inputs that are required to calculate the total costs under the 2021 LCRR.
Exhibit B-42: Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity
under the 2021LCRR
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply
to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
1) Systems replace lead and GRR service lines
Mandatory SLR: The sum of the number of
lines replaced for each category of possible
types of replacement multiplied by the
costs per type of replacement.
((num_lslr_replace*cost_lslr_lsl_reg_mand
_pws)+(num_lslr_partial_replace*cost_lslr_
partial_reg_pws)+(num_lslr_gal_prev_lsl_r
eplace*cost_lslr_gal_prev_lsl_reg_pws))
Cost applies
as written to
NTNCWSs
which conduct
LSLRs under
the small
system
flexibility
program.
Above AL
Model PWS
participating in the
mandatory LSLR
program
Once a year
Customer-Initiated SLR: The number of
customer-initiated partial line replacements
multiplied but the cost of a partial utility
side replacement.
(num_lsl_requested*
cost_lslr_partial_reg_pws)
Cost does not
apply to
NTNCWSs.
At or below
theTL
Model PWS not
participating in the
goal-based or
mandatory LSLR
programs
Once a year
39 The 48,000 LSL estimate is from a September 26, 2018 memorandum from Jeffrey S. DeWitt, Government of the
District of Columbia Chief Financial Officer to the Phil Mendelson, Chairman of the Council of the District of
Columbia. http://lims.dccouncil.us/Download/38916/B22-0507-Fiscal-lmpact-Statementl.pdf.
Final LCR! Economic Analysis Appendices B-112
October 2024
-------
Acronyms: AL = action level; CWS = community water system; GRR = galvanized requiring replacement; LSLR = lead
service line replacement; NTNCWS = non-transient non-community water system; PWS = public water system; SLR
= service line replacement; TL = trigger level.
B.5.4.4 Ancillary Service Line Replacement Activities
Exhibit B-43 presents estimated burden and costs for ancillary activities associated with SLR that is
triggered under the 2021 LCRR when systems exceed the AL or TL. The exhibit provides the unit burden
and/or cost for each activity. The third column provides the corresponding SafeWater LCR model data
variable in red/italic font. The last column indicates that the activity, unit burden and cost, and
SafeWater LCR data variable are identical for the 2021 LCRR to those used for the final LCRI, as described
in Chapter 4, Section 4.3.4.4. Note that the activities related to consulting with the State and developing
and distributing outreach materials in the event of a TLE are in Section B.5.4.5.
Exhibit B-43: PWS Unit Burden and Cost Estimates
Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same as Final LCRI?
m) Contact customers and
conduct site visits
prior to SLR
Burden per replaced
service line
1.70 to 2.07 hrs
Cost per replaced service
line
$11.64 to $16.13/replaced
service line
Burden
hrs_replaced_lsl_contact_op
Cost
cost_replaced_lsl_contact
Yes.
n) Deliver filters and 6
month of replacement
cartridges at time of
SLR
$64/replaced service line
cost_filter_hh
Yes.
o) Collect tap sample
post-SLR
Burden per sample
CWSs: 0.9 to 1.2 hrs
NTNCWSs: 0.5 hrs
Cost per sample per CWS
Travel: $5.75 to $10.24
Bottle: $0 to $2.85
Burden
hrs_collect_lsl_lslr_op
Cost
cost_pickup_samp
cos^otherj^samp1
Yes.
p) Analyze post-SLR tap
sample
In-house Analysis (CWSs >
lOOKonlv)
Burden: 0.44 hrs/sample
Cost: $3.92
Commercial Analyses
$32.20/sample
In-house Analvs/s
hrs_an alyze_ lsl_ lslr_ op1
costjabjsljslr1
Commercial Analysis
cos^commercialjsljslr1
Yes.
q) Inform customers of
tap sample result
Burden
CWSs: 0.05 -0.11
hrs/sample
NTNCWSs: 1 hr/system
Cost
Burden
hrs_inform_samp_ op
hrs_ntncws_cust_lslr_op
Cost
cost_cust_lslr
Yes.
Final LCRI Economic Analysis Appendices B-113
October 2024
-------
Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same as Final LCRI?
CWSs: $0.72/sample
NTNCWSs: $0.079/system
cost_ntncws_cust_lslr
r) Submit annual report
on SLR program to the
State
1 to 8 hrs/CWS
1 hr/NTNCWS
hrs_report_lcr_op
Yes.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system; SLR = service line replacement.
Sources: Data sources for each activity are provided following this exhibit.
Note:
1The burden and costs for these activities are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri,
and South Carolina (ASDWA, 2020a).
Exhibit B-44 provides the SafeWater LCR model cost estimation approach for PWS ancillary SLR activities
including additional cost inputs that are required to calculate these costs under the 2021 LCRR.
Exhibit B-44: Lead Service Line Inventory Ancillary Cost Estimation in SafeWater LCR by
Activity under the 2021 LCRR1
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
m) Contact customers and conduct site visits prior to SLR
The number of lines replaced multiplied
by the total of the hours per lead line
replacement times the system labor
rates, plus the material cost.
num_lsl_replace *
(hrs_replaced_lsl_contact_op * rate_op +
cost_replaced_lsl_contact)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS
participating in the
goal-based LSLR
program
Once a
year
Above AL
Model PWS
participating in the
mandatory LSLR
program
n) Deliver filters and 6 months of replacement cartridges at time of SLR
The number of lines replaced multiplied
by the material cost.
num_lsl_replace*cost_filter_hh
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS
participating in the
goal-based LSLR
program
Once a
year
Cost applies as
written to
NTNCWSs.
Above AL
Model PWS
participating in the
mandatory LSLR
program
Final LCRI Economic Analysis Appendices
B-114
October 2024
-------
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
o) Collect tap sample post-SLR3
The number of samples per replaced
lead line multiplied by the number of
lines replaced, multiplied by the total of
the hours per lead line replacement
times the system labor rates, plus the
material cost.
(numb_samp_lslr*num_lsl_replace)*((hrs
_collect_lsl_lslr_op*rate_op)+cost_other
_lt_samp+cost_pickup_samp)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS
participating in the
goal-based LSLR
program
Once a
year
Cost applies as
written to
NTNCWSs.
Above AL
Model PWS
participating in the
mandatory LSLR
program
p) Analyze post-SLR tap sample3
The number of samples multiplied by the
probabilities for a sample analyzed in
house and a sample analyzed in a
commercial lab times the different labor
and material cost burdens for each type
of analysis.
(((numb_samp_lslr*numjsl_replace) *pp
_lab_samp)*((hrs_analyze_lsl_lslr_op*rat
e_op)+cost_lab_lsl_lslr))+(((numb_samp
_lslr*num_lsl_replace)*pp_commercial_s
amp)*cost_commercial_lsl_lslr)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS
participating in the
goal-based LSLR
program
Once a
year
Cost applies as
written to
NTNCWSs.
Above AL
Model PWS
participating in the
mandatory LSLR
program
Final LCRI Economic Analysis Appendices B-115
October 2024
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
q) Inform customers of the tap sample result
The number of lines replaced multiplied
by the total of the hours per lead line
replacement times the system labor
rates, plus the material cost.
num_lsl_replace*((hrs_inform_samp_op*
rate_op)+cost_cust_lslr)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS
participating in the
goal-based LSLR
program
Once a
year
The total hours
per system
times the
system labor
rates, plus the
material cost.
(hrs_ntncws_cu
st_lslr_op*rate_
op)+cost_ntncw
s_cust_lslr)
Above AL
Model PWS
participating in the
mandatory LSLR
program
r) Submit annual report on SLR program to the State
The total hours for reporting per system
multiplied by the system labor rate.
. (hrs_report_lcr_op*rate_op)
Cost applies as
written to
NTNCWSs.
Above TL
Model PWS
participating in either
the goal-based or
mandatory LSLR
program
Once a
year
Acronyms: AL = action level; CWS = community water system; LSL = lead service line; LSLR = lead service line
replacement; NTNCWS = non-transient non-community water system; PWS = public water system; SLR = service
line replacement; TL = trigger level.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• pp_lab_samp and pp_commercial_samp\ Likelihood that system will use in-house laboratory or
commercial laboratory, respectively (Chapter 4, Section 4.3.2.1.2).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 PWSs with lead content or unknown lines are identified using the data variables and approach described in
Chapter 3, Section 3.3.4.
3 The burden and costs to provide sample bottles (cost_other_lt_samp) under activity i) and conduct analyses
under activity m) are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina
(ASDWA, 2020a).
B.5.4.5 Goal-Based Replacement Program Activities
Under the 2021 LCRR, CWSs serving more than 10,000 people with known or potential lead content
service lines that exceed the TL but not the lead AL must begin implementing a goal-based SLR program
with a goal replacement rate that has been approved by the State. Similar to the mandatory SLR
program as described in Section B.5.4.3, only full SLR count towards the system's annual replacement
goal. If CWSs serving more than 10,000 people fail to meet their SLR goal, they must conduct additional
outreach activities to promote SLR and encourage consumers to participate in the replacement
Final LCRI Economic Analysis Appendices B-116
October 2024
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program. CWSs must continue the outreach activities until one of the following is met: 1) the goal is
met, 2) the system is at or below the TL for two consecutive one-year monitoring periods, or 3) the
system has made at least two good faith efforts to contact all customers served by a lead or GRR service
line about the SLR program. The requirement for a goal-based replacement program and the associated
goal-based outreach was not retained under the final LCRI.
Exhibit B-45 shows the EPA's estimated burden and/or costs for all activities related to a goal-based
replacement program. The assumptions used in the estimation of the unit burden and costs follow the
exhibit. The third column provides the corresponding SafeWater LCR model data variable in red/italic
font. The last column indicates that these requirements are unique to the 2021 LCRR. Additional detail
describing each activity is provided following the exhibit.
Exhibit B-45: Unit Burden and Cost Estimates for Goal-Based Replacement Program Activities
under the 2021LCRR
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same as Final
LCRI?
s) Consult with the
State and develop
targeted SLR
program outreach
materials (one-time)
9 hrs/CWS with TLE serving
> 10,000 people
hrs_lslr_out_op
No. Unique to
the 2021 LCRR.
t) Distribute targeted
SLR program
outreach materials
CWSs serving >10,000 with TLE
0.0026 to 0.0111 hrs/HH;
$0.35/HH
hrs_dist_lslr_out_op;
cost_lslr_out
No. Unique to
the 2021 LCRR.
u) CWS replaces its
portion of lead or
GRR service line
Partial SLR: $1,920 - $5,400;
GRR replacement: $1,920 -
$5,400
cost_lslr_partial_reg_pws;
cost Islr gal prev Isl reg pws
No. Unique to
the 2021 LCRR.
v) Household replaces
privately-owned
portion of the lead
or GRR service line
Partial SLR: $1,920 - $5,400
GRR replacement: $1,920 -
$5,400
cost_lslr_partial_reg_pws;
cost Islr gal prev Isl reg pws
No. Unique to
the 2021 LCRR.
w) Consult with State
on activities to
satisfy additional
goal-based SLR
program outreach
requirements if CWS
> 10,000 fails to
meet goal
2 hrs/CWS serving > 10,000
people
hrs_consult_fail_op
No. Unique to
the 2021 LCRR.
x) Conduct activities in
response to the first
failure to meet SLR
goal
Burden per HH per CWS
serving > 10,000 people: 0.06
hrs
Cost per HH per CWS serving >
10,000 people: $3.00 to $3.01
Burden
hrs_fail_hh_op
Cost
cost_fail_hh
No. Unique to
the 2021 LCRR.
y) Conduct activities in
response to each
Burden per CWS serving >
10,000 people:54 to 96 hrs
Burden
hrs_fail_sys_op
No. Unique to
the 2021 LCRR.
Final LCRI Economic Analysis Appendices B-117
October 2024
-------
Activity
Unit Burden and/or Cost
SafeWaterLCR Data Variable
Same as Final
LCRI?
additional failure to
meet SLR goal
Cost per CWS serving > 10,000
people:$l,259 to $3,085
Cost
cost_fail_sys
Acronyms: CWS = community water system; GRR = galvanized requiring replacement; HH = household; LCRI = Lead
and Copper Rule Improvements; LCRR = Lead and Copper Rule Revisions; SLR = service line replacement; TLE =
trigger level exceedance.
Sources:
s) & t): "Public Education lnputs_CWS_Final.xlsx."
u) & v): "LSLR Unit Cost.xlsx."
w): "LSLR Ancillary Costs_Final.xlsx."
x) & y): "Failure to Meet LSLR Goal_Final.xlsx."
Note: The system cannot discontinue the activities in this exhibit until they meet one of the following conditions:
1) the goal is met, 2) the system is at or below the TL for two consecutive one-year monitoring periods, or 3) the
system has made at least two good faith efforts to contact all customers served by an LSL or GRR service line about
the SLR program.
s) Consult with the State and develop targeted SLR program outreach materials (hrs_lslr_out_op).
CWSs with known or potential lead content service lines serving more than 10,000 people with a TLE
will incur burden to consult with their States and develop outreach materials on their SLR program
that invite customers to participate in their goal-based program. The EPA assumed that all CWSs will
use an EPA-developed template. The EPA assumed that systems will require 7 hours to develop
these materials based on the hours to prepare additional brochure language from the 2022
Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 33a
(USEPA, 2022). The EPA also assumed that systems will require an additional 2 hours to consult with
the State for a total of 9 hours.
t) Distribute targeted SLR program outreach materials (hrs_dist_lslr_out_op, cost_lslr_out). CWSs
with known or potential lead content service lines serving more than 10,000 people with a TLE will
incur burden to distribute targeted SLR program outreach materials to households with lead, GRR,
and unknown service lines. The estimated burden and costing assumptions are provided in Exhibit
B-46. The rule allows CWSs to discontinue distribution of this outreach material after two
consecutive monitoring periods at or below the TL.
Final LCRI Economic Analysis Appendices B-118
October 2024
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Exhibit B-46: Estimated Annual Burden (per household) to Distribute Targeted Outreach
Materials about SLR Program for CWSs with Known or Potential Lead Content Serving >
10,000 people with a TLE (hrs_dist_lslr_out_op)
System Size
(Population
Served)
Separate
mailing
(hrs per
CWS)
Bill Stuffer
(hrs per
CWS)
Average
(hrs per
CWS)
Average
HH per
CWS
Separate/
Bill Stuffer
(hrs per HH)
Productio
n (hrs per
HH)
Total
(hrs/HH)
A
B
C =
(A+B)/2
D
E = C/D
F
G = D + F
10,001-50,000
120
30
75
8,688
0.0086
0.0025
0.0111
50,001-
100,000
120
30
75
27,432
0.0027
0.0025
0.0052
100,001-
1,000,000
120
30
75
93,284
0.0008
0.0025
0.0033
>1,000,000
120
30
75
768,098
0.0001
0.0025
0.0026
Acronyms: CWS = community water system; HH = household; SLR = service line replacement; TLE = trigger level
exceedance.
Source: "Public Education lnputs_CWS_Final.xlsx."
Notes:
A: The EPA assumption regarding the burden per system to prepare separate mailings.
B: The EPA assumption regarding the burden per system to mail materials with the water bill.
C: The EPA assumed that half of systems will conduct separate mailings and the other half will include targeted
outreach materials with the water bill.
D: Based on estimated 2.53 people per household (numb_hh) times the average population per system. See
Chapter 4, Section 4.3.6.2, activity i) for the derivation of households per CWS.
F: The EPA assumed 0.25 hours per 100 brochures for production. Estimate is based on assumptions for production
labor used in the Economic and Supporting Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule
(Exhibit 17) (USEPA, 2007).
These systems will also incur costs to distribute these materials. The EPA assumed:
• Systems providing the materials in the water bill will incur a cost for a cover letter (paper cost of
$0,019 and ink of $0.06) and brochure (paper cost of $0,019 and ink of $0.06) for a total cost of
$0.16 per household. See "General Cost Model lnputs_Final.xlsx" for additional information
about costs for paper and ink. The EPA assumed that the weight of the cover letter and
brochure would not result in additional postage being needed to mail the water bill.
• Systems distributing the materials in a separate mailing will incur the costs for a cover letter and
brochure of $0.16 and also the cost of an envelope ($0,092), and bulk rate postage ($0,299)
since systems will be sending out more than 200 mailings for a total per household cost of
$0.55 for a separate mailing. See "General Cost Model lnputs_Final.xlsx" for additional
information about costs for paper, envelopes, and postage.
The EPA assumed half of these systems will include the materials in the water bill and the other half will
mail them separately. Thus, the estimated cost is the average of $0,016 and $0.55 or $0.35 per
household for data variable cost Islr out.
Final LCRI Economic Analysis Appendices B-119
October 2024
-------
u) CWS replaces its portion of lead or GRR service line (cost_lslr_partial_reg_pws). CWSs serving
more than 10,000 people that have a TLE must implement a goal-based SLR program in which they
replace lead and GRR service lines at a rate approved by the State. Systems must continue replacing
lead and GRR service lines until they no longer exceed the TL for two consecutive annual periods of
tap sampling. The EPA assumed that CWSs will only incur costs for the utility side of the LSLR, and
that customers will pay for their portion to achieve full replacements. Thus, the unit cost for CWSs
for goal-based replacement is the partial SLR cost (cost_lslr_partial_reg_pws).
The EPA assumed for modeling purposes that States would set an average replacement rate goal of
2 percent per year (pp_lsl_replaced_vol_goal). To recognize that this is a goal and not a
requirement, the EPA modeled a range of actual replacement rates of 1 to 5 percent with a most
likely value of 2.5 percent (pp_lsl_replaced_vol_pct).
v) Household replaces privately-owned portion of the lead or GRR service line
(cost_lslr_partial_reg_pws; cost_lslr_gal_prev_lsl_reg_pws). The EPA assumed for the goal-based
program, customers will incur the cost of replacing their portion of the service line. The unit cost for
households replacing their portion of the service is the same as the partial SLR unit cost for systems
(cost_lslr_partial_reg_pws). For more information on the unit costs for service line replacement, see
Section B.5.4.3 and Appendix A.
w) Consult with States on activities to satisfy additional goal-based SLR program outreach
requirements if CWS > 10,000 fails to meet goal (hrs_consult_fail_op). The EPA estimates that a
certain percent of CWSs serving > 10,000 people would fail to meet their replacement goal and be
required to conduct outreach under the 2021 LCRR. To model this scenario, the SafeWater LCR
assumes a range of replacement rates from 1 to 5 percent with a most with a most likely value of 2.5
percent (pp_lsl_replaced_vol_pct). For each model run, the SafeWater LCR model randomly selects a
replacement rate from this distribution. When the rate is less than 2 percent, the system incurs
burden and costs for additional outreach activities described in this activity and activities x) and y)
below.
The EPA estimates that CWSs will incur an annual burden of 2 hours to consult with their State on
needed outreach activities to consumers40 to promote SLR and encourage consumers to participate
in the replacement program. This estimate is based on the burden for systems to consult with their
State on PE activities from pg. 60 of the Economic and Supporting Analyses: Short-Term Regulatory
Changes to the Lead and Copper Rule (USEPA, 2007).
x) Conduct activities in response to the first failure to meet LSLR goal (hrs_fail_hh_op, cost_fail_hh).
CWSs that fail to meet their replacement goal must select one outreach activity in the first year in
which they miss their goal. The possible outreach activities identified in the 2021 LCRR are: 1) send
certified mail to customers with lead or GRR service lines, 2) conduct town hall meeting, 3) conduct
community event and provide lead outreach materials and information on LSLR program, 4) contact
40 Systems must provide materials to consumers in which the water system and/or customer's portion of the
service line is lead, GRR, or lead status unknown. See Chapter Error! Reference source not found., Section 3.3.4
for a more detailed discussion of these types of service lines.
Final LCR! Economic Analysis Appendices B-120
October 2024
-------
customers via phone, text message, email, or door hanger, or 5) conduct other State-approved
methods. To estimate the burden and cost for the initial failure, the EPA assumed that systems
would select lower cost methods of contacting customer by mail or by phone, with equal likelihood
of each method being selected. The EPA assumed that CWSs would not contact customers via door
hanger method due to the higher burden and cost associated with door hanger delivery as
compared to a letter or phone call. Similarly, the EPA assumed that systems would not select one of
the higher options of community event or town hall meeting for their first activity after not meeting
the goal. As shown in Column E of Exhibit B-47, the EPA estimated the average burden per
household for hrs_fail_hh_op. The burden is applied to hh_remain_lsl, which is the number of
households served by lead, GRR, or unknown service lines in the specific year of the 35-year analysis
period.
Exhibit B-47: Unit Burden and Cost to Conduct Outreach in Response to First Failure to Meet
SLR Goal (hrs/household/year)
System Size
(population Served)
Using Certified Mail
to Contact Customers
Contacting Customers
by Phone
Average for Conducting
Outreach for First Failure to
Meet Goal
Burden
(hrs/HH)
Cost
($/HH)
Burden
(hrs/HH)
Cost
($/HH)
Burden (hrs/HH)
hrs_fail_hh_op
Cost ($/HH)
cost_fail_hh
A
B
C
D
E = Avg(A,C)
F=Avg(B,D)
10,001-50,000
0.11
$5.97
0
$0,053
0.06
$3.01
50,001-100,000
0.11
$5.97
0
$0,045
0.06
$3.01
100,001-1,000,000
0.11
$5.97
0
$0,042
0.06
$3.01
>1,000,000
0.11
$5.97
0
$0,037
0.06
$3.00
Acronyms: HH = household; SLR = service line replacement.
Source: "Failure to Meet LSLR Goal_Final.xlsx."
Notes:
A: Assumed a burden of 1 hour per 9 letters, based on the 2022 Disinfectants/Disinfection Byproducts, Chemical,
and Radionuclides Rules ICR (Renewal), Exhibit 29 - Notification of Sampling Results for Customers Whose Taps Are
Sampled (Note G) (USEPA, 2022).
B: The costs include a certified letter, paper, ink, and envelopes (See Derivation file "Failure to Meet LSLR
Goal_Final.xlsx", worksheet, "Support Tables", Table S-2.)
C: Assumed systems would use a robocalling service and would incur a minimal burden to coordinate with the
company who is providing the service. For the proposed LCRI, the EPA incorrectly used an estimate of 1 hour per
household instead of 1 hour per system. The estimate of 1 hour per system is assumed to be a minimal per
household burden in the final LCRI EA.
D: The cost per household is based on the average cost from three companies (see file," Robocall Pricing
Estimates.xlsx").
E: For the proposed LCRI EA, the average burden was estimated as 0.56 hours per household. The EPA revised its
estimate to 0.06 hours correct a formula error in the source file listed above
y) Conduct activities in response to each additional failure to meet LSLR goal (hrs_fail_sys_op,
cost_sys_hh). Systems that continue to fail to meet their goal in any subsequent concurrent year
must conduct one of the initial outreach activities listed in activity x) and two additional activities
Final LCRI Economic Analysis Appendices B-121
October 2024
-------
from the following list: 1) social media campaign, 2) distribute information via mail to organizations
representing plumbers and contractors, and 3) outreach to newspaper, television, or radio, and 4)
visit targeted customers to discuss the SLR program. The EPA estimated that systems would
continue the initial outreach activity of contacting customers by phone or by mail using the burden
and costs from Exhibit B-47 and select two additional activities with equal probability of selecting a
social media campaign; coordination with organizations representing plumbers and contractors, and
outreach to newspapers or radios.
Exhibit B-48 shows how the EPA derived the annual burden for each subsequent failure to meet the
annual goal. The annual burden per system, hrs_fail_sys_op, is provided in Column D.
Exhibit B-48: Burden to Conduct Additional Outreach in Response to Subsequent Failure(s) to
Meet LSLR Goal (hrs/system per year)
System Size
(Population
Served)
Social
Media
Campaign
Coordinate with
organizations
representing
plumbers and
contractors
Outreach to
newspaper,
television, or
radio
Average Burden per
System for Second
and Additional Failure
to Meet Goal
hrs_fail_sys_op
A
B
C
D = 2* Avg (A:C)
10,001-50,000
76
4.0
0.5
54
50,001-100,000
136
7.0
0.5
96
100,001-1,000,000
136
7.0
0.5
96
>1,000,000
136
7.0
0.5
96
Source: "Failure to Meet LSLR Goal_Final.xlsx." and "Public Education lnputs_CWS_Final.xlsx."
Notes:
A: Activities include planning, content, community management, and evaluation. See file, "Failure to Meet LSLR
Goals_Final.xlsx," worksheet, "Social Media Campaign" for detailed assumptions.
B: The EPA assumed systems reach out to four groups. Assumes systems serving 10,001 to 50,000 people reach out
via email (0.5 hrs) and phone (0.5 hrs), and large system reach out via email (0.5 hrs) and webinar (0.25 to post
material and 1 hours to schedule webinar).
C: Assumed systems will pay for an ad in the newspaper. The burden is assumed to be the same as that used to
estimate the cost of a paid ad as part of other outreach activities that are required for CWSs that exceed the lead
AL. See "Public Education lnputs_CWS_Final.xlsx", Table 4 (Column B) in worksheet "Pb ALE_Other Activity Detail."
E: For the proposed LCRI EA, the EPA estimated a burden of 124 to 226 hours. The EPA revised this estimate
because 1) it double counted the burden from the first goal failure that is modeled in SafeWater to continue
through each subsequent goal failure; and 2) to exclude a townhall meeting as a possible outreach response
because it is not listed as one of the activities when a water system has a subsequent goal failure.
Exhibit B-49 shows how the EPA derived the annual cost for the required outreach for each subsequent
failure to meet the goal-based replacement rate. The annual cost per system, cost_fail_sys, is provided
in Column D.
Final LCRI Economic Analysis Appendices B-122
October 2024
-------
Exhibit B-49: Cost to Conduct Additional Outreach in Response to Subsequent Failure(s) to
Meet LSLR Goal ($/system per year)
System Size
(Population
Served)
Social
Media
Campaign
Coordinate with
organizations
representing
plumbers and
contractors
Outreach to
newspaper,
television, or
radio
Average Cost per
System for Second
and Additional Failure
to Meet Goal
cost_fail_sys
A
B
C
D = 2* Avg (A:C)
10,001-50,000
$0
$0
$1,888
$1,259
50,001-100,000
$300
$0
$4,328
$3,085
100,001-1,000,000
$300
$0
$4,328
$3,085
>1,000,000
$300
$0
$4,328
$3,085
Source: "Failure to Meet LSLR Goal_Final.xlsx." and "Public Education lnputs_CWS_Final.xlsx."
Notes:
A: Activities include planning, content, community management, and evaluation. See file, "Failure to Meet LSLR
Goals_Final.xlsx," worksheet, "Social Media Campaign" for detailed assumptions.
B: The EPA assumed that outreach is in the form of email, phone calls, and webinars; therefore, there are no costs
associated with this activity.
C: Assumed systems will pay for an ad in the newspaper. The cost is assumed to be the same as that used to
estimate the cost of a paid ad as part of other outreach activities that are required for CWSs that exceed the lead
AL. See "Public Education lnputs_CWS_Final.xlsx," Table 5 (Column B) in worksheet "Pb ALE_Other Activity Detail."
E: For the proposed LCRI EA, the EPA estimated a costs of $1,716 to $43,639. The EPA revised this estimate
because 1) it double counted the burden from the first goal failure that is modeled in SafeWater to continue
through each subsequent goal failure; and 2) to exclude a townhall meeting as a possible outreach response
because it is not listed as one of the activities when a water system has a subsequent goal failure.
Exhibit B-50 provides the SafeWater LCR model costing approach for LSL activities associated with goal-
based SLR including additional cost inputs that are required to calculate these costs.
Exhibit B-50: Goal-based Replacement Activities Cost Estimation in SafeWater LCR by Activity
under the 2021 LCRR 12
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
s) Consult with State and develop targeted SLR program outreach material
The total consulting hours per system
multiplied by the system labor rate.
(hrs_lslr_out_op*rate_op)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS
participating in goal-
based SLR program
One time
Final LCRI Economic Analysis Appendices B-123
October 2024
-------
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions
t) Distribute targeted SLR program outreach materials
The number of households with
remaining LSLs multiplied by the total of
the hours per household times the
system labor rate, plus the materials
cost.
hh_remain_lsl * (hrs_dist_lslr_out_op *
rate_op + cost_lslr_out)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS
participating in the
goal-based SLR
program
Once a
year
u) CWS replace system-owned portion of lead or GRR service line
The sum of the number of lines replaced
for each category of possible types of
replacement multiplied by the costs per
type of replacement.
((num_lslr_replace*cost_lslr_lsl_reg_ma
nd_pws)+(num_lslr_partial_replace*cost
_lslr_lsl_reg_mand_pws)+(num_lslr_gal_
prev Isl replace*cost Islr gal prev Isl r
eg pws))
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS
participating in the
goal-based SLR
program
Once a
year
v) Household replaces privately-owned portion of the lead or GRR service line
The number of customer-side LSLs and
GRR replaced as part of goal-based
program each year times the unit cost.
(num_lslr_lsl_replace*
cost_lslr_partial_reg_pws)+(num_lslr_gal
_prev_lsl_replace*cost_lslr_gal_prev_lsl
reg pws)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Households served by
systems participating
in the goal-based SLR
program
Once a
year
w) Consult with State on activities to satisfy additional goal-based SLR program if CWS >
10,000 fails to meet goal
The total consulting hours per system
multiplied by the system labor rate.
(hrs_consult_fail_op*rate_op)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS serving >
10,000 that does not
meet its goal-based
SLR rate
Once a
year
x) Conduct activities in response to the first failure to meet SLR goal
The number of households with
remaining LSLs multiplied by the total of
the hours per household times the
system labor rate, plus the material cost
per household.
hh_remain_lsr((hrs_fail_hh_op*rate_op)
+cost_fail_hh)
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS serving >
10,000 that does not
meet its goal-based
SLR rate at least once
Once a
year
y) Conduct activities in response to each additional failure to meet SLR goal
The hours per system multiplied by the
system labor rate, plus the material cost
per system.
((hrs fail sys op*rate op)+cost fail sys
;
Cost does not
apply to
NTNCWSs.
At or below
AL and
above TL
Model PWS serving >
10,000 that does not
meet its goal-based
SLR rate for two or
more times
Once a
year
Final LCRI Economic Analysis Appendices B-124
October 2024
-------
Acronyms: AL = action level; CWS = community water system; GRR = galvanized requiring replacement; LSL = lead
service line; NTNCWS = non-transient non-community water system; PWS = public water system; SLR = service line
replacement; TL = trigger level.
Notes:
1 The data variables in this exhibit are defined previously in this section with the exception of:
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 The system can discontinue the activities in this exhibit if: 1) the goal is met, 2) the system no longer exceeds the
TL for two consecutive one-year tap sampling monitoring periods, or 3) the system has made at least two good
faith efforts to contact all customers served by an LSL or GRR about the LSLR program.
B.5.5 PWS POU-Related Costs under the 2021 LCRR
The 2021 LCRR introduced the small system flexibility option for CWSs serving 10,000 or fewer people
and all NTNCWSs. If these systems exceed the lead TL of 10 ng/L but not the lead AL of 15 ng/L, they
must select one of four options for approval by the State and implement that option if they
subsequently exceeds the lead AL: 1) Install and maintain optimal corrosion control treatment (OCCT),
replace all LSLs within 15 years, 3) install and maintain POU treatment devices at all service connections,
or 4) replace all lead plumbing materials on a schedule specified by the State but not to exceed one
year. For modeling purposes, the EPA assumed that systems would choose the least costly option from
among the first three alternatives.41 The SafeWater LCR model calculates the annualized cost the system
will face under each of these three options and selects the least costly alternative.
For the final LCRI, the approach is similar but for CWSs, the small system flexibility option is limited to
those serving 3,300 or fewer people. In addition, under the final LCRI, the EPA removed service line
replacement as a small system compliance option because it is a mandatory requirement for all systems
with lead and/or GRR service lines, eliminated the TL, and lowered the AL to 10 ng/L. CWSs serving
3,300 or fewer people and NTNCWSs that exceed the lead AL must evaluate and recommend to their
State which compliance option they will implement from among CCT installation/re-optimization, or the
compliance alternatives POU device installation and maintenance or replacement of lead-bearing
materials. Systems must then implement the State-approved compliance option.
Under the 2021 LCRR and final LCRI, systems implementing the POU option have costs to develop an
upfront plan, provide and maintain POU devices, educate customers on them, and conduct sampling.
Note that once the POU option is started, the system must continue to implement this program
regardless of their subsequent lead 90th percentile levels.
POU-related costs are grouped into two subsections:
• B.5.5.1: POU Device Installation and Maintenance
• B.5.5.2: POU Ancillary Activities
41 See footnote 38 for the EPA's rationale for excluding replacement of lead plumbing materials from the
SafeWater LCR cost model.
Final LCRI Economic Analysis Appendices B-125
October 2024
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B.5.5.1 POU Device Installation and Maintenance
The EPA has developed costs to provide, monitor, and maintain POU devices under the 2021 LCRR, as
shown in Exhibit B-51. The exhibit provides the unit burden and/or cost for each activity. The third
column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the activity, unit burden or cost, and SafeWater LCR data variable are identical for
the 2021 LCRR to those used for the final LCRI, as described in Chapter 4, Section 4.3.5.1.
Exhibit B-51: PWS POU Device Installation and Maintenance Unit Burden and Cost Estimates
under the 2021LCRR
Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same as Final LCRI?
a) Provide, monitor, and
maintain POU devices
$104 per household per
year
ann ual_pou_cost_hh
Yes.
Acronyms: LCRI = Lead and Copper Rule Improvements; POU = point-of-use.
Sources: Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2023).
Exhibit B-52 provides the SafeWater LCR model costing approach for installation and maintenance of
POU devices and indicates that the approach is the same under the 2021 LCRR as that used for the final
LCRI, as provided in Chapter 4, Exhibit 4-101.
Exhibit B-52: Point-of-Use Device Installation and Maintenance Cost Estimation in SafeWater
LCR under the 2021 LCRR by Activity
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th- „ ....
„ . Other Conditions
Range1
a) Provide, monitor, and maintain POU devices
Same as final LCRI (see Exhibit 4-101 in Chapter 4).
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system; POU = point-of-use; PWS = public water system.
B.5.5.2 POU Ancillary Activities
The EPA has developed costs for one-time ancillary PWS activities related to POU program development
and on-going ancillary activities as shown in Exhibit B-53. The exhibit provides the unit burden and/or
cost for each activity. The third column provides the corresponding SafeWater LCR model data variable
in red/italic font. The last column indicates that the activity, unit burden, and SafeWater LCR data
variable are identical to those used for the final LCRI, as described in Chapter 4, Section 4.3.5.2. As
stated above, the differences between the two rules is that under the 2021 LCRR, CWSs serving up to
10,000 people can implement this option with State approval. The other difference is that some of these
activities are required when the system exceeds the lead TL under the 2021 LCRR.
Final LCRI Economic Analysis Appendices B-126
October 2024
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Exhibit B-53: PWS Ancillary POU-Related Burden and Cost Estimates under the 2021 LCRR1
Activity
Unit Burden and/or Cost
SafeWaterLCR Data Variable
Same As
Final LCRI?
b) Develop POU plan and
submit to the State
(one-time)2
178 to 328 hrs for CWSs;
148 to 388 hrs for NTNCWSs
hrs_pou_plan_dev_op
Yes.
c) Develop public
education materials and
submit to the State
(one-time)
7 hrs per CWS and NTNCWS
hrs_pe_pou_op
Yes.
d) Print POU education
materials
Burden
0.0025 hrs/sample per CWS
1 hr/NTNCWS
Cost
$0,079 sample per CWS and
NTNCWS
Burden
hrs_print_pe_pou_op
hrs_ntncws_distr_pe_pou_op
Cost
cost_print_pe_pou
cost_ntncws_distr_pe_pou
Yes.
e) Obtain households for
POU monitoring
0.5 hrs per sample for CWSs
only
hrs_samp_volunt_pou_op
Yes.
f) Deliver POU monitoring
materials and
instructions to
participating
households
Burden
0.25 hrs/sample per CWS
Cost
$8.57 to 8.77 sample per CWS
$0 per NTNCWS
Burden
hrs_discuss_samp_op
Cost
cost_pou_samp3
No4
g) Collect tap samples
after POU installation
CWS
Burden: 0.40 hrs/sample
Cost: $5.75
NTNCWS
0.5 hrs/sample
CWS
hrs_pickup_samp_ op
cost_pickup_ samp
NTNCWS
hrs_source_op
Yes.
h) Determine if sample
should be rejected and
not analyzed
0.25 hrs/rejected sample for
CWSs only
hrs_samp_reject_op
Yes.
i) Analyze POU tap
samples
In-House Burden
N/A
In-House Cost
N/A
Commercial Analysis
$32.30/ sample per CWS and
NTNCWSs
In-House Burden
hrs_analyze_samp_op3
In-House Cost
cost_lab_lt_samp3
Commercial Analysis
cost_commerical_lab3
Yes.
j) Prepare and submit
sample invalidation
request to the State
2 hrs per sample per CWS and
NTNCWS
hrs_samp_in valid_ op
Yes.
Final LCRI Economic Analysis Appendices B-127
October 2024
-------
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As
Final LCRI?
k) Inform customers of
POU tap sample results
CWS
Burden: 0.05 hrs/sample
Cost: $0.72/sample
NTNCWS
Burden: 1 hr/sample
Cost: $0.079/sample
CWS
hrs_inform_samp_ op
cost_cust_lt
NTNCWS
hrs_n tncws_inform_samp_ op
cost ntncws cust It
Yes.
1) Certify to the State that
POU tap results were
reported to customers
0.66 hrs/year per CWS;
0.66 to 1 hr/year for NTNCWS
hrs_cert_cust_lt_op
Yes.
m) Prepare and submit
annual report on POU
program to the State
1 hr per CWS;
1 to 8 hrs per NTNCWS
hrs_pou_report_ann_prep_op
Yes.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system; POU = point-of-use.
Sources:
b) & m) "POU lnputs_Final.xlsx", worksheets "CWS_Cost Model Inputs" and "NTNCWS_Cost Model Inputs",
worksheet, "POU Outreach."
c) & d) Public Education lnputs_CWS_Final.xlsx; Public Education lnputs_NTNCWS_Update.xlsx.
e) -1): Lead Analytical Burden and Costs_Final.xlsx, worksheets "POU_Collect_Analyze_LCRR_LCRI" and
"POU_Sample_Report_LCRR_LCRI."
1 Requirements apply only to CWSs serving 10,000 or fewer people and NTNCWS that exceed the AL and have POU
provision and maintenance as their approved compliance option.
2 The rule does not explicitly include a POU plan. However, the EPA assumed most systems would prepare this plan
prior to implementing a POU program. This assumption may overestimate costs during the first year the program is
implemented.
3 In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina, the State pays for the cost of bottles, shipping,
analysis, and providing sample results to the system (ASDWA, 2020a). Thus, the State will incur the burden and
cost for these activities in lieu of the system.
4 The EPA used the same burden and cost inputs as under the final LCRI; however, the subset of CWSs to which
these inputs apply are those serving 10,000 or fewer people (as opposed to 3,300 or fewer under the LCRI). Also,
see Note 1 for additional applicability information.
The EPA used the same data variables and inputs for CWSs to discuss proper sampling procedures with
customers of 0.25 hours per sample (hrs_discuss_samp_op) as under the lead tap program. Exhibit B-54
provides the SafeWater LCR model cost estimation approach for system ancillary POU system cost
inputs including additional cost inputs that are required to calculate these costs and those activities in
which the costing approach for the 2021 LCRR is the same as the final LCRI, as documented in Chapter 4,
Exhibit 4-106.
Final LCRI Economic Analysis Appendices B-128
October 2024
-------
Exhibit B-54: PWS Point-of-Use Ancillary Costing Estimation in SafeWater LCR by Activity
under the 2021LCRR1'2
CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th -
Range2
Other Conditions
b) Develop POU plan and submit to the State
The total hours per system
multiplied by the system labor rate.
(hrs_pou_plan_dev_op*rate_op)
Cost applies as written
to NTNCWSs.
Above TL
Model PWS
selecting POU
installation and
maintenance as
their compliance
option
One time
c) Develop public education materials and submit to the State for review
Same as final LCRI (see Exhibit 4-106 in Chapter 4).
d) Print POU education material
The hours per household multiplied
by the system labor rate and the
material cost.
(pws_pop/numb_hh) *
((hrs_print_pe_pou_op*rate_op)+
cost_print_pe_pou)
The hours per system
multiplied by the
system labor rate and
the material cost.
((hrs_ntncws_distr_pe
_pou_op*rate_op)+cos
t_ntncws_distr_pe_pou
)
Above TL
Model PWS
installing POU
device
Once a
year
e) Obtain households for POU Monitoring
k) Inform customers of POU tap sample results
I) Certify to State that POU tap sample results were reported to customers
m) Prepare and submit annual POU program report to the State
Same as final LCRI (see Exhibit 4-106 in Chapter 4).
Final LCR! Economic Analysis Appendices B-129
October 2024
-------
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system; POU = point-of-use; PWS = public water system; TL = trigger level.
Notes:
1 The data variables in this exhibit are defined previously in this section with the exception of:
• numb_pou\ Number of POU devices per PWSs that elects POU option (Chapter 4, Section 4.3.5.1).
• pp_lab_samp and pp_commercial_samp\ Likelihood that system will use in-house laboratory or
commercial laboratory, respectively (Chapter 4, Section 4.3.2.1.2).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 Once the POU program is started in response to a lead ALE, systems must continue to implement this program
regardless of their subsequent lead 90th percentile levels.
B.5.6 PWS Lead Public Education, Outreach, and Notification Costs under the 2021 LCRR
Under the 2021 LCRR, systems will incur labor and non-labor costs to provide consumer notice in
response to a single lead sample above 15 ng/L, to conduct additional education and outreach
regardless of their lead 90th percentile level, and to conduct PE requirements in response to a lead 90th
percentile level. These activities and associated costs are detailed in Sections B.5.6.1 through B.5.6.3,
respectively.
Note that PE requirements that is provided to customers when a CWS serving more than 10,000 people
exceeds the TL or fails to meet their replacement goal were previously discussed in Section B.5.4.5. PE
requirements for systems implementing a POU program were previously discussed in Section B.5.5.2.
Enhanced public outreach for systems with a minimum of three lead ALEs in a five-year period (i.e.,
multiple lead ALEs) is a new requirement under the final LCRI and is not discussed in this appendix (see
Chapter 4, Section 4.3.6.4 for these requirements and costing assumptions).
B.5.6.1 Consumer Notice
The EPA has developed costs for water systems to provide consumer notice of an individual's lead tap
sampling result within three calendar days if it exceeds 15 ng/L under the 2021 LCR, as shown in Exhibit
B-55. This exhibit provides the unit burden and/or cost for this activity. The third column provides the
corresponding SafeWater LCR model data variable in red/italic font. The last column indicates that the
activity, unit burden or cost, and SafeWater LCR data variable for the 2021 LCRR are identical to those
used for the final LCRI, as described in Chapter 4, Section 4.3.6.1. Note that under the final LCRI, water
systems would be required to provide consumer notice of an individual's lead and copper results,
regardless of the level, within three calendar days.
Exhibit B-55: PWS Burden for Consumer Notification of Lead and Copper Tap Sampling Results
under the 2021LCRR
Activity
Unit Burden and/or
Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
a) Develop lead consumer
notice materials and
submit to the State for
review (one time)
7 hours/PWS
hrs_consumer_noti ce_ de vel_op
Yes
Final LCRI Economic Analysis Appendices B-130
October 2024
-------
Activity
Unit Burden and/or
Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
b) Provide a copy of the
consumer notice and
certification to the State
0.08 hrs/customer
contact
hrs_samp_notice_op
No1
Acronyms: LCRI = Lead and Copper Rule Improvement; PWS = pubic water system.
Source: "Public Education lnputs_CWS_Final.xlsx," "Public Education lnputs_NTNCWS_Final.xlsx."
Note:
1 The burden and cost estimates are the same under the 2021 LCRR and final LCRI; however, under the 2021 LCRR
this notification applies only to lead samples that exceed 15 ng/L. Under the final LCRI, the EPA is requiring water
systems to provide lead and copper results to consumers at tested taps within three business days.
B.5.6.2 Activities Regardless of Lead 90th Percentile Level
The EPA has developed CWS costs for activities associated with PE requirements under the 2021 LCRR
that are independent of a system's lead 90th percentile level, as provided in Exhibit B-56. The exhibit
provides the unit burden and/or cost for each activity. The third column provides the corresponding
SafeWater LCR model data variable in red/italic font. The last column indicates whether or not the
activity, unit burden or cost, and SafeWater LCR data variable are identical under the 2021 LCRR to
those used for the final LCRI, as described in Chapter 4, Section 4.3.6.2. The assumptions that differ for
the 2021 LCRR from final LCRI follow the exhibit. The gray shaded row indicates an activity that is not
required under the 2021 LCRR.
Exhibit B-56: PWS Burden and Cost for Public Education Activities that Are Independent of
Lead 90th Percentile Levels under the 2021 LCRR
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
c) Update CCR language
(one-time)
0.5 hrs/CWS serving <3,300
people;
1 hr/CWS serving > 3,300
people
hrs_ update_ccr_ op
Yes.
d) Develop new
customer outreach
plan (one-time)
4 hrs/CWS with LSLs serving
<50,000 people;
8 hr/CWS with LSLs serving >
50,000 people
hrs_cust_plan_op
Yes.
e) Develop approach for
improved public
access to lead health-
related information
and tap sample results
(one-time)
10 to 40 hours/CWS
hrs_p ub_ access_ op
Yes.
f) Establish a process for
public access to
information on known
or potential lead
content SL locations
and tap sample results
(one-time)
5 hrs/CWS with LSLs serving
<3,300 people;
10 hrs/CWS with LSLs serving
> 3,300 people
hrs_access_lsl_op
Yes.
Final LCRI Economic Analysis Appendices B-131
October 2024
-------
Activity
Unit Burden and/or Cost
SafeWaterLCR Data Variable
Same As Final
LCRI?
g) Maintain a process for
public access to lead
health information,
known or potential
lead content SL
locations, and tap
sample results
No LSLs
2 hrs/CWS serving
< 3,300 people
4 hrs/CWS serving
> 3,300 people
With LSLs
6 hrs/CWS serving
< 3,300 people
12 hrs/CWS serving
> 3,300 people
hrs_maint_lsl_op
Yes.
h) Respond to customer
request for known or
potential lead content
SL information
0.05 hrs/request;
$0/request
hrs_hh_request_op;
cost_hh_request
Yes.
i) Respond to requests
from realtors, home
inspectors, and
potential home buyers
for known or potential
lead content SL
information
0.05 hrs/request;
$0/request
hrs_other_request_op;
cost_other_request
Yes.
j) Develop a list of local
and State health
agencies
CWSs
0.08 hrs/ local and State
health
hrs_hc_list_op
Yes.
k) Develop lead outreach
materials for local and
State health agencies
and submit to the
State for review (one
time)
7 hrs/CWS
hrs_pub_devel_hc_op
Yes.
1) Deliver lead outreach
materials for local and
State health agencies
CWSs
2 to 36 hrs/local and State
health agency;
$5.97/ local and State health
hrs_hc_op;
cost_hc
No. See
explanation
following this
exhibit.
m) Develop public
education for lead
content SL
disturbances and
submit to the State
(one-time)
7 hrs/CWS with LSLs
hrs_p ub_ de vel_ wtr_ op
Yes.
n) Deliver public
education for SL
disturbances
0.083 hours/delivery;
$0.21/delivery
hrs_p ub_ deli v_ wtr_ op;
cost_pub_deliv_wtr_ed
No. See
discussion
following the
exhibit
o) Deliver filters and 6
months of
replacement
cartridges during SL
disturbances
$64/household
cost_filter_hh
No. See
discussion
following this
exhibit.
Final LCRI Economic Analysis Appendices B-132
October 2024
-------
Activity
Unit Burden and/or Cost
SafeWaterLCR Data Variable
Same As Final
LCRI?
p) Develop inventory-
related outreach
materials and submit
to the State for review
(one time)
7 hours per system
hrs_pe_lsl_ gen_ develop_ op
Yes.
q) Distribute inventory-
related outreach
materials
CWS
0.4426 to 0.0026/household
per year
$0.35 to $ 0.48/household
per year
NTNCWS
1 hr per system per year
$0.79 per system per year
CWS
hrs_pe_lsl_ gen_ dist_ op;
cost_pe_lsl_gen
NTNCWS
hrs_ntncws_pe_lsl_gen_dist_op;
ntncws_pe_lsl_op
Yes.
r) Provide translation
services for public
education materials
N/A
hrs_translate_phon e_ op;
cost_ t ran slat e_ cws
N/A. Not
required
under the
2021 LCRR.
s) Certify to the State
that lead outreach
was completed
CWSs
2 hrs/CWS serving <50,000
people;
3 hrs/CWS serving
> 50,000 people
NTNCWSs
0.66 hrs/NTNCWS serving
<50,000 people;
1 hr/NTNCWS serving
> 50,000 people
CWSs
hrs_pe_ certify_quarterly_ op
NTNCWSs
hrs_cert_outreach_annual_op
Yes.
Acronyms: CCR = consumer confidence report; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; LSL = lead service lines; NTNCWS = non-transient non-community water system; SL = service line.
Sources:
c) - n): "Public Education lnputs_CWS_Final.xlsx."
0): Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water (USEPA, 2023).
p), q), s): "Public Education lnputs_CWS_Final.xlsx;" "Public Education lnputs_NTNCWS_Final.xlsx."
1) Deliver lead outreach to local and State health agencies (hrs_hc_op, cost_hc). Under the 2021
LCRR, CWSs must report the results of school testing to local and State health care agencies
annually. This differs from the final LCRI in which the testing results must be reported within 30 days
of receiving the results. For both the 2021 LCRR and final LCRI, CWSs are required to report other
information to the health department annually, including outreach materials, as well as the results
of any activities in response to a sample above the AL (as previously discussed in Section B.5.3.3).
The EPA also assumed under the 2021 LCRR and final LCRI that systems will also incur annual burden
to make any necessary updates to the list of organizations. The resulting annual burden estimates
for conducting outreach to health care agencies are provided in Exhibit B-57.
Final LCRI Economic Analysis Appendices B-133
October 2024
-------
n) Deliver public education for SL disturbances (hrs_pub_deliv_wtr_op; cost_pub_deliv_wtr_ed).
Under the 2021 LCRR, CWSs must provide PE materials if a disturbance to a lead, GRR, or unknown
service line results from replacement of an inline water meter, a water meter setter, or a connector.
The EPA assumed the same unit burden and cost to provide the PE materials as was assumed for the
final LCRI (0.083 hours and $0.21 per delivery). However, the estimated percent of lead, GRR, and
unknowns service lines per year that would be disturbed and require delivery of PE material
(perc_hh_water_wrk) is different because the 2021 LCRR does not require PE if the disturbance
results from a water main replacement (this was added to the final LCRI). For the 2021 LCRR, the
EPA assumes that 6.5percentn of lead, GRR, and unknowns service lines would be disturbed each
year and require PE materials based on 6 percent for meter replacements (assuming on an average
meter lifespan of approximately 15-20 years based on information from the city of Pasadena, Texas
(Pasadena, no date)) plus 0.5 percent based on the estimated percent of service lines that are
exposed during water meter reading, service line repair or replacement, backflow prevention
inspections, and other street repair or capital projects with open cut excavations. The 0.5 percent
may be an overestimate because some activities such as backflow prevention inspection and meter
reading may not result in a disturbance.
o) Deliver filters and 6 months of replacement cartridges during SL disturbances (cost_filter_hh).
Under the 2021 LCRR, CWSs must provide filters and six months of replacement cartridges if a
disturbance to a lead, GRR, or unknown service lines results from replacement of an inline water
meter, a water meter setter, or a connector. The EPA assumed the same unit cost for filters and
replacement cartridges as was assumed for the final LCRI ($64/household). However, the estimated
percent of service lines per year that would be disturbed (perc_hh_water_wrk) is different because
the 2021 LCRR does not require PE if the disturbance results from a water main replacement (this
was added to the final LCRI). For the LCRR, the EPA assumes that 6.5 percent of lead, GRR, and
unknown service lines would be disturbed each year and require filters and replacement cartridges,
as discussed in activity n) above.
Exhibit B-57: Annual CWS Burden (per system) to Conduct Outreach to Local and State Health
Agencies
System Size
(Population served)
# of Organizations
per system
Production
Time per
organization
Distribute
Letters per
month
Update List
of
Organizations
(annual)
Total (Annual
Burden)
A
B
C = A*B
D
E = C+D
numb_ha +1
hrs_hc_op
<3,300
2
1
2
0
2
3,301-100,000
2
1
2
1
3
42 For the proposed LCRI EA, the EPA assumed that 5.9 percent of households will be impacted annually by water-
related work disturbances and would receive PE based on the estimated life of a water main, meter, and other
service line replacements provided by Massachusetts Water Resources Authority. Utilizing these data, EPA
assumed an average 17-year life of a meter, CWSs would replace a meter at an annual rate of 5.9 percent.
Final LCRI Economic Analysis Appendices B-134
October 2024
-------
System Size
(Population served)
# of Organizations
per system
Production
Time per
organization
Distribute
Letters per
month
Update List
of
Organizations
(annual)
Total (Annual
Burden)
A
B
C = A*B
D
E = C+D
numb_ha +1
hrs_hc_op
100,001-1,000,000
3
1
3
2
5
>1,000,000
17
2
34
2
36
Notes
A: Chapter 4, Exhibit 4-113.
B: The EPA assumed systems would require 1 hour and 2 hours each month to prepare a cover letter and assemble
the results of lead in drinking water testing at schools and child care facilities for systems serving 1 million people
or fewer and more than 1 million people, respectively. In addition, once per year, the information to local and
State health departments will also include actions taken in response to a single sample above 15 ng/L (i.e., find-
and-fix activities).
D: The EPA assumed zero burden for systems serving 3,300 or fewer people. For CWSs serving 3,301 to 100,000
people, the EPA assumed an annual burden of 1 hour per system to update the list of organizations. For systems
serving more than 100,000 people, the EPA assumed an annual burden of 2 hours per system.
Under the 2021 LCRR, the EPA assumed systems will deliver the information to local and State health
departments via certified mail annually at an estimated cost of $5.97 per organization (cost_hc) per year
that includes paper ($0,019), envelope ($0,092), ink ($0.06), and certified mail ($5.80). Under the final
LCRI, these costs are assumed to occur monthly for an annual cost of $71.65.
Exhibit B-58 provides the SafeWater LCR model costing approach for system PE activities and indicates
that in general they are the same for the 2021 LCRR as those used for final LCRI, as shown in Chapter 4,
Exhibit 4-119.
Exhibit B-58: PWS Lead Public Education Unit Costing Approach in SafeWater LCR by Activity
under the 2021LCRR1
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other
Conditions2
a) Develop lead consumer notice materials and submit to the State for review
The total hours per system multiplied by the system
labor rate.
(hrs_consumer_notice_devel_op*rate_op)
Cost applies
as written to
NTNCWS
All
All model All
model PWSs
with at least one
lead sample >
15 ug/L
One time
Final LCRI Economic Analysis Appendices B-135
October 2024
-------
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other
Conditions2
b) Provide a copy of the consumer notice and certification to the State
The total hours per system multiplied by the system
labor rate.
(hrs_samp_notice_op*rate_op)
Cost applies
as written to
NTNCWS
All
All model PWSs
with at least one
lead sample >
15 pg/L
Once per
event
c) Update CCR language
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
d) Develop new customer outreach plan
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
e) Develop approach for improved public access to lead health-related information and tap
sample results
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
f) Establish a process for public access to information on known or potential lead content SL
locations and tap sample results
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
g) Maintain a process for public access on lead health information, known or potential lead
content SL locations, and tap sample results
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
i) Respond to requests from realtors, home inspectors, and potential home buyers for known
or potential lead content SL information
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
j) Develop list of local and State health agencies
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
k) Develop lead outreach materials for local and State health agencies and submit to the State
for review
The number of State and local health agencies per
system times the total hours per health agency
multiplied by the system labor rate.
Cost applies
as written to
NTNCWSs.
All
All model PWSs
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
n) Deliver public education for SL disturbances
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
o) Deliver filters and 6 months of replacement cartridges during SL disturbances
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
(numb_ha+1)*((hrs_hc_op*rate_op)+cost_hc)
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
m) Develop public education material for known or potential SL disturbances and submit to the
State
Once a
year3
Final LCRI Economic Analysis Appendices B-136
October 2024
-------
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other
Conditions2
p) Develop inventory-related outreach materials and submit to the State for review
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
q) Distribute inventory-related outreach materials
Same as final LCRI (see Exhibit 4-119 in Chapter 4).
r) Provide translation services for public education materials
N/A. New requirement under the final LCRI.
s) Certify to State that lead outreach was completed
| Same as final LCRI (see Exhibit 4-119 in Chapter 4).
Acronyms: CCR = consumer confidence report; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; PWS = public water system; SL = service
line.
Notes:
1 The data variables in the exhibit are defined previously in Section B.5.6.2 with the exception of:
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 PWSs with lead content or unknown lines are identified using the data variables and approach described in
Chapter 3, Section 3.3.4.
3 For the LCRR, the burden and costs occur one a year. For the final LCRI, the monthly burden and costs are
multiplied by 12 to provide an annual burden and costs. Thus, the costing approach, as shown in Chapter 4, Exhibit
4-119 are the same for the two rules.
B.5.6.3 Activities in Response to Lead ALE
The 2021 LCRR and final LCRI retain the PE requirements of the pre-2021 LCR for systems that exceed
the lead AL but add a requirement for systems to update their mandatory PE language. The EPA has
developed system costs for PE activities in response to a lead ALE under the 2021 LCRR, as provided in
Exhibit B-59. The exhibit provides the unit burden and/or cost for each activity. The third column
provides the corresponding SafeWater LCR model data variable in red/italic font. The last column
indicates that the unit burden or cost and SafeWater LCR data variable are identical for the 2021 LCRR to
those used for the final LCRI, as described in Chapter 4, Section 4.3.6.3.
Exhibit B-59: PWS PE Burden in Response to Lead ALE under the 2021 LCRR
Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same As Final
LCRI?
t) Update mandatory
language for lead ALE
public education and
submit to the State for
review (one-time)
7 hrs per CWS and NTNCWS
hrs_pe_ al_ de vel_ op
Yes.
u) Deliver lead ALE public
education materials to
all customers
CWSs
0.0025 hours/household;
$0.27 to $0.40/CWS
CWSs
hrs_ distr_edu_ op;
cost_pe_lcr_delivery
Yes.
Final LCRI Economic Analysis Appendices B-137
October 2024
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Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same As Final
LCRI?
NTNCWSs
1 hr/NTNCWS
$0.079/NTNCWS
NTNCWSs
hrs_ n tn cws_ distr_edu_ op;
cost_ntncws_pe_lcr_delivery
v) Post notice to website
0.5 hrs/CWSs serving > 50,000
people
hrs_web_op
Yes.
w) Prepare press release
10 hrs/press release per CWS
serving > 3,300 people;
$0/press release
hrs_pr_op;
cost_pr
Yes.
x) Contact public health
agencies to obtain
additional organizations
and update recipient list
0.5 hrs/CWSs serving <3,300
people;
1.5 hrs/CWSs serving 3,301 to
100,000 people;
2.5 hrs/CWS serving > 100,000
people
hrs_ha_op
Yes.
y) Notify public health
agencies and other
organizations
0.0025
hours/organization/CWS;
$5.97/organization/CWS
hrs_distr_agencies_pe_op;
cost_pe_lead_ale
Yes.
z) Consult with the State
on other public
education activities
2 hrs/CWS
hrs_ ale_ consult_ op
Yes.
aa) Implement other public
education activities
2.7 to 1,039.2 hrs/CWS;
$38.82 to $297,956/CWS
hrs_ ale_ other_ op;
cost_ale_other
Yes.
Acronyms: ALE = action level exceedance; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; PWS = public water system.
Sources:
t), u): "Public Education lnputs_CWS_Final.xlsx"; "Public Education lnputs_NTNCWS_Final.xlsx."
v)-aa): "Public Education lnputs_CWS_Final.xlsx."
Exhibit B-60 provides the SafeWater LCR model cost estimation approach for system PE requirements in
response to a lead ALE and indicates that the approach is the same for the 2021 LCRR as that used for
the final LCRI, as provided in Chapter 4, Exhibit 4-126.
Final LCRI Economic Analysis Appendices B-138
October 2024
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Exhibit B-60: PWS Lead ALE Public Education Unit Costing Approach in SafeWater LCR by
Activity under the 2021 LCRR1
Acronyms: ALE = action level exceedance; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; PWS = public water system.
B.6 Detailed State Costing Approach for the 2021 LCRR
This section details how the EPA estimated the cost of compliance for the 56 primacy agencies (States)43
for each major rule component of the LCRR, including:
• B.6.1: State Implementation and Administrative Costs under the 2021 LCRR
• B.6.2: State Sampling Related Costs under the 2021 LCRR
43 The 56 primacy agencies include 49 states (excluding Wyoming), Puerto Rico, Guam, United States Virgin Islands,
American Samoa, North Mariana Islands, and Navajo Nation. For cost modeling purposes, the EPA also included
the District of Columbia (D.C.) as a primacy agency when assigning burden and costs of the rule although some of
these costs are incurred by the actual primacy agency, EPA Region 3. Note that the EPA uses the "State" to denote
"primacy agency" in this economic analysis.
Final LCRI Economic Analysis Appendices B-139
October 2024
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• B.6.3: State CCT Related Costs under the 2021 LCRR
• B.6.4: State Service Line Inventory and Replacement Related Costs under the 2021 LCRR
• B.6.5: State POU Related Costs under the 2021 LCRR
• B.6.6: State Lead Public Education, Outreach, and Notification Costs under the 2021 LCRR
For the activities described in Section B.5, State will incur costs in the form of burden (i.e., hours) to
provide oversight and review. The State burden is multiplied by the labor rate ($/hr), as presented in
Chapter 3, Section 3.3.11.2 to estimate labor unit costs. Exhibit B-61 shows all the components,
subcomponents, and activities from Chapter 4, Exhibit 4-141 for the final LCRI. For each major rule
component, each activity has a unique letter ID. The differences in activities costed for the final LCRI and
the 2021 LCRR are identified as follows: 1) gray shading italicized text indicates new activities under the
final LCRI and were not part of the 2021 LCRR requirements; and 2) yellow shaded activities in bold are
specific to the 2021 LCRR and are not included in the final LCRI requirements.
Exhibit B-61: State Cost Components, Subcomponents, and Activities Organized by Section for
the 2021 LCRR1
Component
Subcomponents
Activities2
B.6.1: State
Implementation and
Administrative Costs under
the 2021LCRR
B.6.1.1: State Start-up
Implementation and
Administrative Activities
a) Adopt rule and develop program.
b) Modify data management systems.
c) Provide system training and technical
assistance.
d) Provide staff training.
e) Review and approve small system
flexibility option.
B.6.1.2: State Annual
Implementation and
Administrative Activities
f) Coordinate with the EPA.
g) Provide ongoing technical assistance.
h) Report to SDWIS/Fed.
i) Train staff for annual administration.
B.6.2: State Sampling
Related Costs under the
2021LCRR
B.6.2.1: State Lead Tap Sampling
Costs
a) Provide templates for revised sampling
instructions and conduct review.
b) Review updated sampling plan.
c) Review initial lead monitoring data and
prepare systems for status under the
rule.
d) Review change in tap sample locations.
e) Review 9-year monitoring waiver
renewal.
f) Review sample invalidation requests.
g) Review consumer notification
certifications.
h) Review monitoring results and 90th
percentile calculations.
B.6.2.2: State Lead WQP Sampling
Costs under the 2021 LCRR
i) Review lead WQP sampling data and
compliance with OWQPs.
B.6.2.3: State Copper WQP
Monitoring Costs
j) Review copper WQP sampling data and
compliance with OWQPs.
Final LCRI Economic Analysis Appendices B-140
October 2024
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Component
Subcomponents
Activities2
B.6.2.4: State Source Water
Monitoring Costs under the 2021
LCRR
k) Review source water monitoring results.
B.6.2.5: State School Sampling
Costs
1) Review list of schools and child care
facilities.
m) Provide templates on school and child
care facility testing program,
n) Review school and child care facility
testing program materials.
o) Review school and child care facility
sampling results after individual
sampling events.
p) Review annual reports on school and
child care facility lead in drinking water
testing program.
B.6.3: State CCT Related
Costs under the 2021 LCRR
B.6.3.1: State CCT Installation
Costs under the 2021 LCRR
a) Review CCT study and determine type of
CCT to be installed.
b) Set OWQPs after CCT installation.
B.6.3.2: State CCT Re-optimization
Costs under the 2021 LCRR
c) Review CCT study and determine
needed OCCT adjustment.
d) Reset OWQPs after CCT re-optimization.
B.6.3.3: State Find-and-Fix Costs
e) Consult with system prior to any find-
and-fix CCT adjustments.
f) Review report on find-and-fix3
responses.
B.6.3.4: State Lead CCT Routine
Costs under the 2021 LCRR
g) Review CCT guidance and applicability
to individual PWSs.
h) Review water quality data with PWSs
during sanitary survey.
i) Consult on required actions in response
to source water change.
j) Consult on required actions in response
to treatment change.
Final LCRI Economic Analysis Appendices B-141
October 2024
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Component
Subcomponents
Activities2
B.6.4: State Service Line
B.6.4.1: SL Inventory Costs
a)
Review connector updated LCRR initial
Inventory and
inventory (baseline inventory).
Replacement Related
b)
Review service line inventory updates
Costs
c)
Review inventory validation report
B.6.4.2: SLR Plan Review Costs
d)
Review initial SLR plan
e)
Review information on deferred
deadline and associated replacement
rate in the SLR plan and determine
fastest feasible rate
f)
Review annually updated SLR plan or
certification of no change
g)
Conduct triennial review of water
system updated recommended deferred
deadline and associated replacement
rate and determine fastest feasible rate
B.6.4.3: SLR Report Review Costs
h)
Review annual SLR program report
B.6.4.4: Goal-Based Replacement
i)
Provide targeted LSLR program
Program Activities
j)
k)
outreach templates and consults with
PWS
Review targeted outreach materials
Determine additional activities for
CWSs not meeting their goal-based
rate.
B.6.5: State POU Related
B.6.5.1: One-Time POU Program
a)
Review POU plan.
Costs under the 2021 LCRR
Costs
b)
c)
Provide templates for POU outreach
materials.
Review POU public education materials.
B.6.5.2: Ongoing POU Program
d)
Review sample invalidation request for
Costs
e)
f)
POU monitoring.
Review customer notification
certifications.
Review annual POU program report.
B.6.6.1: Consumer Notice
a)
Provide templates for consumer notice
B.6.6: State Lead Public
materials.
Education, Outreach, and
b)
Review lead consumer notice materials.
Notification Costs
c)
Review copy of the consumer notice and
certification.
B.6.6.2: Activities Regardless of
d)
Provide templates for updated CCR
the Lead 90th Percentile Level
e)
f)
g)
h)
i)
j)
language.
Provide templates for local and State
health department lead outreach.
Review lead outreach materials for local
and State health departments.
Participate in joint communication
efforts with local and State health
departments.
Provide templates for service line
disturbance outreach materials.
Review public education materials for
service line disturbances.
Provide templates for inventory-related
Final LCRI Economic Analysis Appendices B-142
October 2024
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Component
Subcomponents
Activities2
outreach materials,
k) Review inventory-related outreach
materials.
1) Provide technical assistance to PWSsfor
public education materials.
m) Review public education certifications.
B.6.6.3: Public Education Activities
in Response to Lead ALE
n) Provide templates for updated public
education materials for systems with a
lead ALE.
o) Review revised lead language,
p) Consult with CWS on other public
education activities in response to lead
ALE.
Public Education Activities in
Response to Multiple Lead ALEs
q) Review plan for making filters available,
r) Provide templates for systems with
multiple lead ALEs.
s) Review outreach materials provided by
systems with multiple lead ALEs.
t) Consult on filter program for systems
with multiple lead ALEs.
Acronyms: ALE = action level exceedance; CCR = Consumer Confidence Report; CCT = corrosion control treatment;
CWS = community water system; DSSA = Distribution System and Site Assessment; EPA = Environmental Protection
Agency; LCRR = Lead and Copper Rule Revisions; LSLR = lead service line replacement; OWQPs = optimal water
quality parameters; POU = point-of-use; PWS = public water system; SDWIS/Fed = Safe Drinking Water Act
Information System/Federal version; SL = service line; SLR = service line replacement; WQP = water quality
parameter.
Notes:
1 States will also incur burden for recordkeeping activities under the LCRR, such as retaining records of decisions,
supporting documentation, technical basis for decisions, and documentation submitted by the system. The EPA
has included burden for recordkeeping with each activity when applicable as opposed to providing separate
burden estimates.
2The EPA assigned a unique letter of identification (ID) for each activity under a given rule component. Activities
are generally organized with upfront, one-time activities first followed by ongoing activities. The lettering follows
that used for the final LCRI, with the exception of activities that apply to the 2021 LCRR but not the final LCRI.
3 Under the final LCRI, the term "find-and-fix" is replaced with distribution system and site assessment (DSSA).
B.6.1 State Implementation and Administrative Costs under the 2021 LCRR
States will incur both one-time and annual burden to implement and administer the requirements under
the 2021 LCRR. These one-time activities and associated SafeWater LCR model cost inputs are described
in Sections B.6.1.1. Ongoing activities and associated cost inputs are provided in Section B.6.1.2.
Note that State burden estimates for responding to specific requirements of the 2021 LCRR (e.g., review
changes in a system's treatment, consult with systems, etc.) are presented in the sections for those
particular rule requirements.
B.6.1.1 State Start-up Implementation and Administrative Activities
The EPA has developed costs for State activities associated with start-up implementation and
administrative activities under the 2021 LCRR, as shown in Exhibit B-62. The third column provides the
Final LCRI Economic Analysis Appendices B-143
October 2024
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corresponding SafeWater LCR model data variable in red/italic font. The last column indicates whether
or not the activity, unit burden, and SafeWater LCR data variable are identical under the 2021 LCRR to
those used for the final LCRI, as described in Chapter 4, Section 4.4.1.1. The assumptions that differ for
the 2021 LCRR from final LCRI are provided in notes to the exhibit and a more detailed explanation also
follows the exhibit.
The EPA recognizes that States would also incur administrative burden related to specific requirements
under the 2021 LCRR. In these cases, the system burden is estimated under that particular rule
requirement.
Exhibit B-62: State Administration Activities and Unit Burden Estimates (Occur during Years 1
and 2) under the 2021 LCRR1,2
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
a) Adopt rule and develop
640 hrs/State
hrs_adopt_ruleJs
Yes.
program
b) Modify data management
740 hrs/State
hrs_modify_dsJs
Yes.
systems1
c) Provide system training and
800 hrs/State
hrsjnitial_taJs
Yes.
technical assistance
d) Provide staff training
196 hrs/State
hrs_trainjmpJs
Yes.
e) Review and approve small
6 per CWSs serving
hrs_smJ:lex_opJs
No. See discussion
system flexibility option
<10,000 and all NTNCWSs
following this
exhibit.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system.
Sources: ASDWA 2020 and 2024 CoSTS models (ASDWA, 2020b; 2024). Also see, Administrative Burden and
Costs.xlsx for more detailed information on deriving the estimated burden based on ASDWA's 2020 and 2024
CoSTS models.
Notes:
1 The SafeWater LCR Data Variable input is the same under the 2021 LCRR and final LCRI; however, under the LCRR,
the small system flexibility option for CWSs is available to those serving 10,000 or fewer people as opposed to
those serving 3,300 or fewer people under the final LCRI.
2 The EPA assumed that activities a) through d) occur each year over a five-year period (ASDWA, 2020b). However,
for the LCRR, three of those years will have occurred prior to the 35-year analysis period; thus, the EPA assumed
these activities will occur in Years 1 and 2 of the 35-year analysis period. The EPA assumed activity e) will occur in
Year 1 of the 35-year analysis period of the economic analysis.
e) Review and approve small system flexibility option (hrs_sm_flex_option Js). States will incur
burden to review and approve the compliance option recommended by CWSs serving 10,000 or
fewer and all NTNCWSs that exceed the lead TL of 10 ng/L under the 2021 LCRR. The EPA assumed a
burden of 6 hours based on the burden for States to review and track a system's selected
compliance option from the ASDWA 2024 CoSTS model, section "Small System Flexibility" (ASDWA,
2024).
Final LCRI Economic Analysis Appendices B-144
October 2024
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Under the final LCRI, the same costing input and value are used; however, the systems to which this
requirement applies and the timing of this requirement varies from the LCRR. Under the final LCRI,
the small system flexibility option for CWSs is limited to those serving 3,300 or fewer people. In
addition, the requirement to provide a recommended small system flexibility option applies when
the system exceed the lead TL of 10 ng/L. Further, under the final LCRI, the EPA assumes States will
incur this cost in Year 4 of the analysis period.
B.6.1.2 State Annual Implementation and Administrative Activities
In addition to one-time, upfront activities, States will incur burden to conduct annual activities to
administer the 2021 LCRR. The EPA has identified and developed costs for four annual administration
activities as shown in Exhibit B-63. The exhibit provides the unit burden estimate for each activity and
additional burden for new SDWIS/Fed reporting requirements under the 2021 LCRR. The third column
provides the corresponding SafeWater LCR model data variable in red/italic font. The last column
indicates that the unit burden or cost, and SafeWater LCR data variable are identical for the 2021 LCRR
to those used for the final LCRI, as described in Chapter 4, Section 4.4.1.2.
Exhibit B-63: State Annual Administration Activities and Unit Burden Estimates under the
2021LCRR
Activity
Unit Burden
(hours/State)
SafeWater LCR Data
Variable
Same As Final LCRI?
f) Coordinate with the EPA
1,040
hrs_coord_epaJs
Yes.
g) Provide ongoing technical assistance
2,367
hrs_taJs
Yes.
h) Report to SDWIS/Fed
1,560
hrs_sdwisJs
Yes.
i) Train staff for annual administration
104
hrs_train_annJs
Yes.
Per State Total
5,051
Acronyms: EPA = Environmental Protection Agency; LCRI = Lead and Copper Rule Improvements; SDWIS/Fed = Safe
Drinking Water Information System/Federal version.
Sources:
f), h), and i): "Administrative Burden and Costs.xlsx." Unit burdens are based on implementation burden estimated
for the EPA's 2012, Economic Analysis for the Final Revised Total Coliform Rule, Exhibit 7.4, available in the docket.
g): ASDWA 2020 and 2024 CoSTS models (ASDWA, 2020b; 2024) and "Administrative Burden and Costs Final.xlsx."
Exhibit B-64 provides details on how costs are calculated for State administrative and rule
implementation activities a) through i) including additional cost inputs that are required to calculate
these costs under the 2021 LCRR. It also indicates for which of the activities the costing approach is the
same as the final LCRI, as documented in Chapter 4, Exhibit 4-145.
Final LCRI Economic Analysis Appendices B-145
October 2024
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Exhibit B-64: State Administration and Rule Implementation Cost Estimation in SafeWater
LCR by Activity under the 2021 LCRR1
State Agency Cost Per Activity for
CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to
Apply to a State
Frequency
of Activity
Lead 90th
- Range
Other
Conditions
a) Adopt rule and develop program
The hours per State multiplied by the State
labor rate.
(hrs_adopt_ruleJs*rateJs)
Cost applies as
written to States for
NTNCWSs.
All
All States
Annually for
first 2 years
b) Modify data management systems
The hours per State multiplied by the State
labor rate.
(hrs_modify_dsJs*rateJs)
Cost applies as
written to States for
NTNCWSs.
All
All States
Annually for
first 2 years
c) Provide system training and technical assistance
The hours per State multiplied by the State
labor rate.
(hrsjnitialjaJs*rateJs)
Cost applies as
written to States for
NTNCWSs.
All
All States
Annually for
first 2 years
d) Provide staff training
The hours per State multiplied by the State
labor rate.
(hrsjrainjmpJs*rateJs)
Cost applies as
written to States for
NTNCWSs.
All
All States
Annually for
first 2 years
e) Review and approve small system flexibility option 2
The hours per system multiplied by the
State labor rate.
(hrs_smJlex_optionJs*rateJs)
Cost applies as
written to States for
NTNCWSs.
Above TL
CWSs without
CCT serving <
10,000 and
NTNCWSs
One time
f) Coordinate with the EPA
Same as final LCRI (see Exhibit 4-145 in Chapter 4).
g) Provide ongoing technical assistance
Same as final LCRI (see Exhibit 4-145 in Chapter 4).
i) Train staff for annual administration
Same as final LCRI (see Exhibit 4-145 in Chapter 4).
Acronyms: CCT = corrosion control treatment; CWS = community water system; EPA = Environmental Protection
Agency; NTNCWS = non-transient non-community water system; SDWIS/Fed = Safe Drinking Water Information
System/Federal version; TL = trigger level.
Notes:
1 Costs are applied per State as opposed per system. The data variables in the exhibit are defined previously in
Section B.6.1 B.6.1 with the exception of:
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
Final LCRI Economic Analysis Appendices B-146
October 2024
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B.6.2 State Sampling Related Costs under the 2021 LCRR
This section provides State unit burden related to lead tap sampling, lead WQP monitoring, copper WQP
monitoring, source water monitoring, and school testing in Sections B.6.2.1 through B.6.2.5,
respectively, under the 2021 LCRR. As noted in Subsections B.6.2.1, B.6.2.2, B.6.2.4, and B.6.2.5, as well
as Section B.6.5 that pertains to the POU program and Section B.5.4.4 that pertain to SLR, five States
incur the cost of bottles, analysis, and providing lead sample results to the system (ASDWA, 2020a). In
addition, six States also incur the burden and cost to update lead tap sampling instructions (see Sections
B.5.2.1.2 and B.6.2.1). Note that there may be additional State laboratories that incur some analytical
and reporting burden and costs in lieu of the system that would result in an underestimation of State
costs.
B.6.2.1 State Lead Tap Sampling Costs under the 2021 LCRR
The EPA has identified and developed costs for eight State oversight and review activities associated
with lead tap sampling conducted by water systems under the 2021 LCRR, as shown in Exhibit B-65. The
exhibit provides the unit burden and/or cost for each activity. The third column provides the
corresponding SafeWater LCR model data variable in red/italic font. The last column indicates that the
unit burden or cost, and SafeWater LCR data variable are identical for the 2021 LCRR to those used for
the final LCRI, as described in Chapter 4, Section 4.4.2.1.
Exhibit B-65: State Lead Tap Sampling Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
a) Provide templates for
revised sampling
instructions and conduct
review (one-time)
0.75 to 1 hr/PWS
hrs_rev_sampJs1
Yes.
b) Review updated sampling
plan
PWSs without LSLs
2 to 4 hrs/PWS
PWSs with LSLs
4 to 10 hrs/PWS
hrs_rev_samp_planJs
Yes.
c) Review initial lead
monitoring data and
prepare systems for status
under the rule
2 to 4 hrs/PWS
hrs_initial_tap_revJs
Yes.
d) Review change in tap
sample locations2
2 hrs/CWS
hrs_chng_tapJs
Yes.
e) Review 9-year monitoring
waiver renewal
0.5 hrs/PWS for those with 9-
year monitoring waiver
hrs_renew_nineJs
Yes.
f) Review sample invalidation
requests
2 hrs/invalidation request
hrs_sampjnvalidJs
Yes.
g) Review consumer
notification certifications
0.33 to 0.5 hrs/certification
hrs_cert_custjtJs
Yes.
Final LCRI Economic Analysis Appendices B-147
October 2024
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Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
h) Review monitoring results
and 90th percentile
calculations3
PWSs without LSLs
0.5 to 2 hrs/PWS
PWSs with LSLs
0.63 to 2.5 hrs/PWS
hrs_annual_ltJs
Yes.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvement; LSL = lead service line;
PWS = public water system.
Source: "Lead Analytical Burden and Costs_Final.xlsx."
Notes:
1 As previously discussed in Section B.5.2.1.2, in Arkansas, Louisiana, Mississippi, Missouri, North Dakota, and
South Carolina the State sends sampling instructions to the water systems and thus are assumed to incur the
burden to update the sampling instruction in lieu of the system (ASDWA, 2020a).
2 Applies to CWSs only. The EPA assumed 0 hours for NTNCWSs because they collect their own samples from
sampling locations under their control and thus, are unlikely to change sampling sites and submit documentation
to the State for review.
3 As previously discussed in Section B.5.2.1.2, in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the
State pays for the cost of bottles, analysis, and providing sample results to the system (ASDWA, 2020a). Thus, the
State will incur the burden and cost for these activities in lieu of the system. In this instance, the system burden to
provide monitoring results and 90th percentile calculations is applied to these States and hrs_annual_ltJs would be
0. Instead, they will incur the system burden of hrs_annual_lt_op (see B.5.2.1.2, activity p).
Exhibit B-66 shows the SafeWater LCR model costing approach for these State lead tap sampling
activities including additional cost inputs required to calculate these costs under the 2021 LCRR. It also
indicates for which of the activities the costing approach is the same as the final LCRI, as documented in
Chapter 4, Exhibit 4-148.
Final LCRI Economic Analysis Appendices B-148
October 2024
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Exhibit B-66: State Lead Tap Sampling Unit Cost Estimation in SafeWater LCR by Activity under the 2021 LCRR1
State Cost Per Activity for CWSs
State Cost Per Activity
for NTNCWSs
Conditions for Cost to Apply to a State
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
a) Provide templates for revised sampling instructions and conduct review
Same as final LCR1 (see Exhibit 4-148 in Chapter 4).
b) Review updated sampling plan for LSL systems
Same as final LCRI (see Exhibit 4-148 in Chapter 4).
c) Review initial lead monitoring data and prepare systems for status under the rule
Same as final LCRI (see Exhibit 4-148 in Chapter 4).
d) Review change in tap sample locations
The hours per system multiplied by the State labor
rate.
(hrs_chng_tapJs*rateJs)
States with any model PWSs not on reduced
tap sampling and not doing POU sampling
1 - (p_tap_annual + pjtapjtrienniai +
p_tap_nine)
Twice a year
Cost does not apply to
States for NTNCWSs.
At or below
TL
States with any model PWSs on annual tap
sampling and not doing POU sampling
p_tap_annual
Once a year
States with any model PWSs on reduced
triennial tap sampling and not doing POU
sampling
Every 3
years
pjtapjtrienniai
The hours per system multiplied by the State labor
rate.
(hrs_chng_tapJs*rateJs)
Cost does not apply to
States for NTNCWSs.
At or below
TL
States with any model PWSs on reduced nine
year sampling and not doing POU sampling
pjap_nine
Every 9
years
At or below
AL and
above TL
States with any model PWSs not doing POU
sampling
Once a year
Final LCRI Economic Analysis Appendices
B-149
October 2024
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State Cost Per Activity for CWSs
State Cost Per Activity
for NTNCWSs
Conditions for Cost to Apply to a State
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
Above AL
States with any model PWSs not doing POU
sampling
Twice a year
e) Review 9-year monitoring waiver renewal3
The hours per system multiplied by the State labor
rate.
(hrs_renew_nineJs*rateJs)
Cost applies as written to
States for NTNCWSs.
At or below
TL3
States with any model PWSs on reduced nine-
year sampling and not doing POU sampling
pjap_nine
Every 9
years
f) Review sample invalidation requests
The number of samples determined to be invalid
multiplied by the hours per sample per system and
the State labor rate.
(numb_samp_customer*pp_samp_invalid)*(hrs_sa
mp invalidJs*rateJs)
Cost applies as written to
States for NTNCWSs.
At or below
TL
States with any model PWSs not on reduced
tap sampling and not doing POU sampling
1 - (pjap_annual + pjapjriennial +
pjap_nine)
Twice a year
States with any model PWSs on annual tap
sampling and not doing POU sampling
pjap_annual
Once a year
The number of samples determined to be invalid
multiplied by the hours per sample per system and
the State labor rate.
(numb_reduced_tap*pp_samp_invalid)*(hrs_samp
JnvalidJs*rateJs)
Cost applies as written to
States for NTNCWSs.
At or below
TL
States with any model PWSs on reduced
triennial tap sampling and not doing POU
sampling
pjapjriennial
Every 3
years
States with any model PWSs on reduced nine
year sampling and not doing POU sampling
pjap_nine
Every 9
years
The number of samples determined to be invalid
multiplied by the hours per sample per system and
the State labor rate.
(numb_samp_customer*pp_sampJnvalid)*(hrs_sa
mp invalid js*rate js)
Cost applies as written to
States for NTNCWSs.
At or below
AL and
above TL
States with any model PWSs not doing POU
sampling
Once a year
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State Cost Per Activity for CWSs
State Cost Per Activity
for NTNCWSs
Conditions for Cost to Apply to a State
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
Above AL
Twice a year
g) Review consumer notification certifications
The hours per system multiplied by the State labor
rate.
(hrs_cert_cust_ltJs*rateJs)
States with any model PWSs not on reduced
tap sampling and not doing POU sampling
1 - (p_tap_annual + p_tap_triennial +
p_tap_nine)
Twice a year
States with any model PWSs on reduced
annual tap sampling and not doing POU
sampling
Once a year
At or below
TL
p_tap_annual
Cost applies as written to
States for NTNCWSs.
States with any model PWSs on reduced
triennial tap sampling and not doing POU
sampling
p_tap_triennial
Every 3
years
States with any model PWSs on reduced nine
year sampling and not doing POU sampling
p_tap_nine
Every 9
years
At or below
AL and
above TL
States with any model PWSs not doing POU
sampling
Once a year
Above AL
Twice a year
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State Cost Per Activity for CWSs
State Cost Per Activity
for NTNCWSs
Conditions for Cost to Apply to a State
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
h) Review monitoring results and 90th percentile calculations4
The hours per system multiplied by the State labor
rate.
States with any model PWSs not on reduced
tap sampling and not doing POU sampling
Twice a year
(hrs_annual_ltJs*rateJs)
1 - (p_tap_annual + p_tap_triennial +
p_tap_nine)
At or below
TL
States with any model PWSs on reduced
annual tap sampling and not doing POU
sampling
p_tap_annual
Once a year
Cost applies as written to
States for NTNCWSs.
States with any model PWSs on reduced
triennial tap sampling and not doing POU
sampling
p_tap_triennial
Every 3
years
States with any model PWSs on reduced nine
year sampling and not doing POU sampling
p_tap_nine
Every 9
years
At or below
AL and
above TL
States with any model PWSs not doing POU
sampling
Once a year
Above AL
States with any model PWSs not doing POU
sampling
Twice a year
Acronyms: AL = action level; CWS = community water system; LCRI = Lead and Copper Rule Improvements; LCRR = Lead and Copper Rule Revisions; LSL = lead
service line; NTNCWS = non-transient non-community water system; POU = point-of-use; PWS = public water system; TL = trigger level.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of the following:
• numb_reduced tap: the number of lead tap samples for system on reduced annual, triennial, or 9-year monitoring (Chapter 4, Section 4.3.2.1.1).
• numb_samp_customer: the number of lead tap samples for system on standard 6-month tap monitoring (Chapter 4, Section 4.3.2.1.1).
• p_tap_annual, p_tap_triennial, and p_tap_nine: likelihood a systems is collecting the reduced number of lead tap samples on an annual, triennial, or
9-year frequency, respectively (Chapter 4, Section 4.3.2.1.1).
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• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
2 Does not apply to CWSs serving < 10,000 people and all NTNCWSs that have selected POU provision and maintenance as their compliance option if they
exceeded the lead AL. PWSs with lead content or unknown lines are identified using the data variables and approach described in Chapter 3, Section 3.3.4.
3 Only systems with 90th percentile values < the AL of 10 ng/L can quality for a 9-year monitoring waiver.
4 As previously discussed in Section B.5.2.1.2, in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the State pays for the cost of bottles, shipping,
analysis, and providing sample results to the system (ASDWA, 2020a). Thus, the State will incur the burden and cost for these activities in lieu of the system. In
this instance, the system burden to provide monitoring results and 90th percentile calculations is applied to these States and hrs_annual_ltJs would be 0.
Instead, they will incur the system burden of hrs_annual_lt_op (see Section B.5.2.1.2B.5.2.1.2, activity p).
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B.6.2.2 State Lead WQP Sampling Costs under the 2021 LCRR
The EPA has developed State costs for the review of lead WQP monitoring data submitted by systems
serving 50,000 or fewer people with a lead ALE and all systems serving more than 50,000 people with
CCT44 under the 2021 LCRR, as shown in Exhibit B-67. The exhibit provides the unit burden. The third
column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the unit burden or cost, and SafeWater LCR data variable are identical for the
2021 LCRR to that used for the final LCRI, as described in Chapter 4, Section 4.4.2.2.
Note that States will review fewer submissions under the 2021 LCRR than the final LCRI. This is because
under the final LCRI: 1) more systems are expected to exceed the lead AL under the final LCRI due to
more stringent tap sampling and 90th percentile protocol requirements for systems with LSLs; and 2)
Systems serving 10,001 to 50,000 people with CCT will be required to continue WQP monitoring
irrespective of their lead 90th percentile level.
Exhibit B-67: State Lead WQP Monitoring Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
i) Review lead WQP
sampling data and
compliance with OWQPs
No CCT: 5 hrs/system/6-month
monitoring period;
With CCT: 8.5 hrs/system/6-month
monitoring period
hrs_wqpJs
Yes.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; OWQP = optimal water
quality parameter; WQP = water quality parameter.
Source: "WQP Analytical Burden and Costs_Final.xlsx."
Exhibit B-68 provides the SafeWater LCR model costing approach for this State lead WQP monitoring
activity under the 2021 LCRR. As shown in the exhibit, the SafeWater LCR model relies upon additional
inputs, such the likelihood a system has a certain type of CCT in place, to estimate total costs. A
description of the data variables and section where they are described in more detail are provided in the
footnote to the exhibit.
44 All systems serving more than 50,000 people except those with naturally non-corrosive water (i.e., "b3"
systems") are required to have CCT.
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Exhibit B-68: State Lead WQP Monitoring Cost Estimation in SafeWater LCR by Activity under
the 2021 LCRR1
State Cost Per Activity
for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a State
Frequency
of Activity
Lead 90th -
Range
Other Conditions
i) Review lead WQP sampling data and compliance with OWQPs
The hours per system
multiplied by the State
labor rate.
(hrs_wqpJs*rateJs)
Cost applies as written
to States for
NTNCWSs.
Above AL
States with any PWSs serving
<50,000 and without CCT
States with any PWSs serving
<50,000 and having pH
adjustment in place
pbaseph
States with any PWSs serving
<50,000 and having PO4 or
both PO4 and pH adjustment in
place
pbasepo4, pbasephpo4
Twice a
year
All
States with any PWSs serving
>50,000 and having pH
adjustment in place
pbaseph
States with any PWSs serving
>50,000 and having PO4 or
both PO4 and pH adjustment in
place
pbasepo4, pbasephpo4
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-
transient non-community water system; OWQP = optimal water quality parameter; PO4 = orthophosphate; PWS =
public water system; WQP = water quality parameter.
Notes:
The data variables in the exhibit are defined previously in this section with the exception of:
• pbaseph, pbasepo4, and pbasephpo4: Likelihood system has pH adjustment, orthophosphate, or pH
adjustment and orthophosphate for their CCT (Chapter 4, Section B.5.2.2.1).
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
B.6.2.3 State Copper WQP Monitoring Costs under the 2021 LCRR
The EPA has developed State costs for the review of copper WQP monitoring data per 6-month
monitoring period under the 2021 LCRR as shown in Exhibit B-69. The exhibit provides the unit burden.
The third column provides the corresponding SafeWater LCR model data variable in red/italic font. Note
that the data variable is the same as for reviewing lead WQP data for the 2021 LCRR, as indicated in the
last column to that used for the final LCRI, as described in Chapter 4, Section 4.4.2.3.
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As stated in Section B.5.2.3, the SafeWater LCR models copper WQP monitoring separately from lead
WQP monitoring to avoid double counting the cost of WQP monitoring for systems experiencing a
copper ALE and a lead ALE simultaneously. The SafeWater LCR model restricts copper WQP monitoring
to systems serving 50,000 or fewer people without CCT that do not exceed the lead AL but exceed the
copper AL of 1.3 mg/L. See Exhibit 4-38 and Exhibit 4-39 in Chapter 4, Section 4.3.2.3.1 for the likelihood
a system has a copper only ALE (p_copper_ale) 45 for CWSs and NTNCWSs, respectively.
Exhibit B-69: State Copper WQP Monitoring Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
j) Review copper WQP
sampling data and
compliance with OWQPs
No CCT: 5 hrs/system/6
month monitoring period;
With CCT: 8.5 hrs/system/6
month monitoring period
hrs_wqpJs
Yes.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; OWQP = optimal water
quality parameter; WQP = water quality parameter.
Source: "WQP Analytical Burden and Costs_Final.xlsx."
Exhibit B-70 shows the SafeWater LCR model costing approach for this State copper WQP monitoring
activity under the 2021 LCRR. As shown in the exhibit, the SafeWater LCR model relies upon additional
inputs that include the likelihood a system has a certain type of CCT in place and, as discussed above,
the likelihood a system has a copper ALE. A description of the data variables and section where they are
described in more detail are provided in footnote 1 to the exhibit.
Exhibit B-70: State Copper WQP Monitoring Cost Estimation in SafeWater LCR by Activity
under the 2021LCRR1
State Cost Per Activity for
CWSs
State Cost Per Activity
for NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th -
Range
Other Conditions
j) Review copper WQP sampling data and compliance with OWQPs
The hours per system
multiplied by the State labor
rate.
(hrs_wqpJs*rateJs)
Cost applies as written to
States for NTNCWSs.
At or below
AL
States with any model
PWSs serving <50,000,
without CCT, and having a
copper ALE
p_copper_ale
Twice a year
45 As described in Chapter 4, Section 4.3.2.3.1, the EPA assumed all systems with CCT would have sufficient CCT
such that none would have a copper ALE. Because all systems serving 50,000 or more people have CCT (except for
16 "b3" systems), SafeWater LCR does not assign any copper WQP costs to systems serving more than 50,000
people.
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State Cost Per Activity for
CWSs
State Cost Per Activity
for NTNCWSs
Conditions for Cost to Apply to a
State
Lead 90th - _ ....
„ Other Conditions
Range
The hours per system
multiplied by the State labor
rate.
(hrs_wqpJs*rateJs)
Cost applies as written to
States for NTNCWSs.
At or below
AL
States with any model
PWSs serving >50,000,
having pH adjustment in
place, and having a
copper ALE
p_copper_ale, pbaseph
States with any model
PWSs serving >50,000,
having PCM or both PCM
and pH adjustment in
place, and having a
copper ALE
p_copper_ale, pbasepo4,
pbasephpo4
Frequency
of Activity
Twice a year
Acronyms: AL = action level; ALE = action level exceedance; CCT = corrosion control treatment; CWS = community
water system; NTNCWS = non-transient non-community water system; OWQP = optimal water quality parameter;
PO4 = orthophosphate; PWS = public water system; WQP = water quality parameter.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• p_copper_ale: Likelihood that a system exceeds the copper AL (Chapter 4, Section B.5.2.3.1).
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
B.6.2.4 State Source Water Monitoring Costs under the 2021 LCRR
The EPA has developed State costs to review source water monitoring data as shown in Exhibit B-71. The
exhibit provides the unit burden. The third column provides the corresponding SafeWater LCR model
data variable in red/italic font. The last column indicates that the unit burden, and SafeWater LCR data
variable are identical for the 2021 LCRR to that used for the final LCRI, as described in Chapter 4, Section
4.4.2.4.
Exhibit B-71: State Source Monitoring Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
k) Review source water
monitoring results
0.5 hrs/system/monitoring
period in which source water
samples are collected
hrs_sourceJs
Yes.
Source: " Lead Analytical Burden and Costs_Final.xlsx," worksheet, "Source_Reporting_Review."
Notes: In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the State pays for the cost of bottles,
analysis, and providing sample results to the system. Thus, the State will incur the burden and cost for these
activities in lieu of the system (ASDWA, 2020a). In these States, because the State is reporting the results, the
burden to review the results (hrs_sourceJs) is 0. Instead, the system burden to report the results
(hrs_report_source_op) is applied to these States (see Section B.5.2.4.2, activity hh).
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Exhibit B-72 details how the data variables are used to estimate State source water monitoring unit
costs for the 2021 LCRR and indicates that the approach is the same as that used for the final LCRI, as
provided in Chapter 4, Exhibit 4-154.
Exhibit B-72: State Source Water Monitoring Cost Estimation in SafeWater LCR by Activity
under the 2021LCRR
State Cost Per Activity for
CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th „ ....
„ Other Conditions
- Range
k) Review source water monitoring results
Same as final LCRI (see Exhibit 4-154 in Chapter 4).
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system.
B.6.2.5 State School Sampling Costs under the 2021 LCRR
The 2021 LCRR establishes requirements for CWSs to conduct PE and lead in drinking water testing in K -
12 public and private schools and licensed child care facilities in their service area. A high-level
discussion of these requirements and the differences between the 2021 LCRR and final LCRI are
provided in Section B.5.2.5.
The EPA has developed burden for one-time State activities for oversight of CWSs' lead in drinking water
testing programs at schools and child care facilities under the 2021 LCRR, as shown in Exhibit B-73. The
exhibit provides the unit burden for each activity. The third column provides the corresponding
SafeWater LCR model data variable in red/italic font. The last column indicates whether or not the unit
burden or cost, and SafeWater LCR data variable are identical for the 2021 LCRR to that used for the
final LCRI, as described in Chapter 4, Section 4.4.2.5. The gray shaded row indicates an activity that is not
required under the 2021 LCRR.
For both the 2021 LCRR and final LCRI, the one-time activities are assumed to occur in Year 4 and the on-
going activities to occur under the first and second five-year testing cycles starting in Year 4 onward.
Exhibit B-73: State School Sampling Burden Estimates under the 2021 LCRR1
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
I) Review list of schools and child
3 hrs/CWS
hrs_rev_school_listJs
Yes.
care facilities (every 5 years
starting in Year 4)
m) Provide templates on school and
0.25 to 0.5 hrs/CWS
hrs_temp_schoolJs
Yes.
child care facility testing program
(one time)
n) Review school and child care
1 hrs/CWS serving <
hrs_rev_school_infoJs
Yes.
facility testing program materials
50,000;
(one time)
3 hrs/CWS serving
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Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
> 50,000
o) Review school and child care
facility sampling results after
individual sampling events
N/A
hrs_sch_cc_results_reviewJs
No. Unique to
the final LCRI.2
p) Review annual reports on school
and child care facility lead in
drinking water testing program
1 hr/CWS/year
hrs_annual_report_schoolJs
Yes.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements.
Source: "School_Child Care lnputs_Final.xlsx."
Note:
1 As previously discussed in Section B.5.2.5 in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the
State pays for the cost of bottles, shipping, and analyses associated with lead testing (ASDWA, 2020a). Thus, the
State will incur the burden and costs for these activities under the testing program at schools and child cares.
2 Under the LCRR, the sampling results are included as part of the annual report (activity p)). Under the final LCRI,
systems would be required to report sampling results within 30 days of receiving the results.
Exhibit B-74 provides details on how costs are calculated for State school and child care facility
sampling-related costs and indicates that in general, they are the same as that used for the final LCRI, as
documented in Chapter 4, Exhibit 4-156.
Exhibit B-74: State School and Child Care Facility Sampling Cost Estimation in SafeWater LCR
by Activity under the 2021 LCRR
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to
Apply to a State
Frequency
of Activity
Lead 90th - Other
Range Conditions
1) Review list of schools and child care facilities
Same as final LCRI (see Exhibit 4-156 in Chapter 4).
m) Provide templates on school and child care facility testing program
Same as final LCRI (see Exhibit 4-156 in Chapter 4).
n) Review school and child care facility testing program materials
Same as final LCRI (see Exhibit 4-156 in Chapter 4).
o) Review school and child care facility sampling results after individual sampling events
N/A under the LCRR. New requirement under the final LCRI.
p) Review annual reports on school and child care facility lead in drinking water testing
program
Same as final LCRI (see Exhibit 4-156 in Chapter 4).
Acronyms: CWS = community water system; LCRI = Lead and Copper rule Improvements; LCRR = Lead and Copper
Rule Revisions; NTNCWS = non-transient non-community water system.
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B.6.3 State CCT Related Costs under the 2021 LCRR
State oversight and review activities related to CCT are grouped into four major subcomponents:
• CCT Installation
• Re-optimization
• Find-and-Fix
• Routine
The unit burden and costs for CCT-related activities are generally the same for the 2021 LCRR as for the
final LCRI; however, the conditions under which the costs apply are different due to the requirements in
response to a TLE under the 2021 LCRR. Unit costs and modeling assumptions for each activity related to
these four subcomponents are presented in Sections B.6.3.1 through B.6.3.4, respectively.
B.6.3.1 State CCT Installation Costs under the 2021 LCRR
The EPA has developed State cost for two one-time activities associated with CCT installation under the
LCRR, as shown in Exhibit B-75. The exhibit provides the unit burden for each activity. The third column
provides the corresponding SafeWater LCR model data variables in red/italic font. The last column
indicates that the unit burden for the 2021 LCRR is the same as for the final LCRI, as presented in
Chapter 4, Section 4.4.3.1.
Exhibit B-75: State CCT Installation Related Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
a) Review CCT study and
determine type of CCT to
be installed
27 to 52 hrs/system
hrs_review_cct_study_leadJs
Yes.
b) Set OWQPs after CCT
installation
2 to 12 hrs/system serving
< 50,000 people
hrs_set_owqpJs
Yes.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule improvements; OWQP = optimal water
quality parameter.
Source: a), b): "CCT Study and Review Costs_Final.xlsx."
Exhibit B-76 provides the SafeWater LCR model costing approach for the two State activities related to
CCT Installation and indicates that the approach is the same for the 2021 LCRR as that used for the final
LCRI, as described in Chapter 4, Exhibit 4-160.
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Exhibit B-76: State CCT Installation Cost Estimation in SafeWater LCR by Activity under the
2021LCRR
State Cost Per Activity for
CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th _ ....
_ Other Conditions
- Range
a) Review CCT study and determine type of CCT to be installed
Same as final LCRI (see Exhibit 4-160 in Chapter 4).
b) Set OWQPs after CCT installation
| Same as final LCRI (see Exhibit 4-160 in Chapter 4).
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; OWQPs = optimal water quality
parameters.
B. 6.3.2 State CCT Re-optimization Costs under the 2021 LCRR
The EPA has identified and developed State cost for two oversight and review activities associated with
a system's re-optimization of existing CCT under the 2021 LCRR, as shown in Exhibit B-77. The exhibit
provides the unit burden for each activity. The third column provides the corresponding SafeWater LCR
model data variable in red/italic font. The last column indicates that the activities, unit burden or cost,
and SafeWater LCR data variables are identical for the 2021 LCRR to those used for the final LCRI, as
described in Chapter 4, Section 4.4.3.2.
Exhibit B-77: State CCT Re-Optimization-Related Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
c) Review CCT study and
determine needed CCT
adjustment
28 to 50 hrs/system
hrs_review_cct_study_leadJs
Yes.
d) Reset OWQPs after CCT
re-optimization
2 to 20 hrs/system
hrs_reset_owqpJs
Yes.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; OWQP = optimal water
quality parameter.
Source: "CCT Study and Review Costs_Final.xlsx."
Exhibit B-78 details how the data variables are used to estimate State activities related to CCT re-
optimization including additional cost inputs that are required to calculate the total costs under the
2021 LCRR.
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Exhibit B-78: State CCT Re-optimization Cost Estimation in SafeWater LCR by Activity under
the 2021 LCRR1
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply
to a State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
c) Review CCT study and determine needed CCT adjustment
The hours per system multiplied by the
State labor rate.
(hrs_review_cct_study_leadJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
Above TL
States with model
PWS conducting a
study prior to re-
optimizing CCT
One time
d) Reset OWQPs after CCT re-optimization
The hours per system multiplied by the
State labor rate.
(hrs_reset_owqpJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
Above TL
States with model
PWS re-optimizing
CCT
One time
Acronyms: CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-
community water system; OWQP = optimal water quality parameters PWS = public water system; TL = trigger level.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
B.6.3.3 State Find-and-Fix Costs under the 2021 LCRR
The EPA developed State costs to related to find-and-fix activities 46 under the 2021 LCRR, as shown in
Exhibit B-79. The unit burden is the same, although the frequency is different because the 2021 LCRR
requires find-and-fix activities for single samples above 15 ng/L, whereas the final LCRI requires an
assessment for single samples above 10 ng/L. The exhibit provides the unit burden for each activity. The
third column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the activities, unit burden or cost, and SafeWater LCR data variables are identical
for the 2021 LCRR to those used for the final LCRI, as described in Chapter 4, Section 4.4.3.3.
Exhibit B-79: State Find-and-Fix Burden under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
e) Consult with system prior
to any find-and-fix CCT
adjustments
2 hrs per PWS
hrs_consult_dssaJs
Yes.
f) Review report on find-and-
fix responses
1 hr/PWS serving < 50,000
people;
2 hrs/PWS serving > 50,000
people
hrs_report_dssaJs
Yes.
46 Refer to footnote.
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Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; PWS = public water
system.
Source: "Likelihood_Sample_Above_AL_LCRR_Find_Fix.xlsx."
Exhibit B-80 provides details on how total costs for the 2021 LCRR are calculated for this activity
including additional cost inputs that are required to calculate the total costs under the 2021 LCRR.
Exhibit B-80: State CCT Find-and-Fix Cost Estimation in SafeWater LCR by Activity for the 2021
LCRR1'2
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
e) Consult with system prior to any find-and-fix CCT adjustments
The hours per system multiplied by the
State labor rate.
(hrs_consult_dssaJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
All
All States with model
PWS with at least one
sample > 15 |jg/L
Once a
year
f) Review report regarding all find-and-fix activities
The hours per system multiplied by the
State labor rate.
(hrs_report_dssaJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
All
All States with model
PWS with at least one
sample > 15 |jg/L
Once a
year
Acronyms: CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-transient non-
community water system; PWS = public water system.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
2 As previously discussed in Section 4.3.3.2.2 in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the
State pays for the cost of bottles, shipping, and analyses (ASDWA, 2020a). Thus, the State will incur the burden and
cost for these activities.
B.6.3.4 State Lead CCT Routine Costs under the 2021 LCRR
The EPA developed State costs to review and consult on system's activities related to review of CCT
guidance, submitted water quality data during the sanitary survey, and the notification of a source or
treatment change under the 2021 LCRR, as shown in Exhibit B-81. The exhibit provides the unit burden
for each activity. The third column provides the corresponding SafeWater LCR model data variable in
red/italic font. The last column indicates that the activities, unit burden or cost, and SafeWater LCR data
variables are identical to those used for the final LCRI, as described in Chapter 4, Section 4.4.3.4. Note
that while the unit burden for activities i) and j) are the same, the conditions under which they apply are
different under the 2021 LCRR compared to the final LCRI because of the requirements specific to
systems that exceed the TL and not the AL.
Final LCRI Economic Analysis Appendices
B-163
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Exhibit B-81: State CCT Installation Related Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As
Final LCRI?
g) Review CCT guidance and
• 40 hrs/State/update
hrs_cct_reviewJs
Yes.
applicability to individual
PWSs
h) Review water quality data
• 2 to 5
hrs_sanit_survJs
Yes.
with PWSs during sanitary
hrs/system/sanitary
survey
survey
i) Consult on required
• 6 to 12 hrs/system on
hrs_coop_source_chng_redJs
Yes.
actions in response to
reduced tap monitoring
source water change
• 4 to 7 hrs/system on
standard tap monitoring
hrs_coop_source_chng_routJs
j) Consult on required
46 to 84 hrs/system
hrs_coop_ treat_ chn gjs
Yes.
actions in response to
treatment change
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; PWS = public water
system.
Exhibit B-82 details how the data variables are used to estimate State activities related to CCT re-
optimization including additional cost inputs that are required to calculate the total costs and indicates
for which activities the costing approach for the 2021 LCRR is the same as the final LCRI, as provided in
Chapter 4, Exhibit 4-170.
Exhibit B-82: State CCT Re-optimization Cost Estimation in SafeWater LCR by Activity under
the 2021 LCRR1
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply
to a State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
g) Review CCT guidance and to which PWSs it applies
Same as final LCRI (see Exhibit 4-170 in Chapter 4).
h) Review water quality data with PWSs during sanitary survey
Same as final LCRI (see Exhibit 4-170 in Chapter 4).
i) Consult on required actions in response to source water change
The hours per system multiplied by the
State labor rate.
(hrs_coop_source_chng_routJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
At or
below TL
States with any model
PWSs not on reduced
tap sampling that have
a change in source
water
1 - (p_tap_annual +
pjtapjtrienniai +
p_tap_nine);
p_source_chng
Once per
event
Final LCRI Economic Analysis Appendices
B-164
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State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply
to a State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
Above TL
States with any model
PWSs with a change in
source water
p_source_chng
The hours per system multiplied by the
State labor rate.
(hrs_coop_source_chng_redJs*rateJs)
At or
below TL
States with any model
PWSs on reduced tap
sampling that have a
change in source
water
p_tap_annual,
p_tap_triennial,
p_tap_nine,
p_source_chng
j) Consult on required actions in response to treatment change
Same as final LCRI (see Exhibit 4-170 in Chapter 4).
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; PWS = public water system; TL = trigger
level.
Note:
1The data variables in the exhibit are defined previously in this section with the exception of:
• p_tap_annual, p_tap_triennial, and p_tap_nine: Likelihood a system will qualify to collect the reduced
number of lead tap samples at an annual, triennial, and nine-year frequency, respectively (Chapter 3,
Section 3.3.7.2).
• p_source_chng\ Likelihood that a system will change sources in a given year (Chapter 3, Section 3.3.9.1).
• p_spec_req\ Likelihood a ground water CWS will meet special conditions to conduct a sanitary survey
every 3 years vs. every 5 years (Chapter 4, Section 4.3.3.4 activity m)).
• p_treat_change: Likelihood that a system will change treatment in a given year (Chapter 3, Section
3.3.9.3).
• rateJs\ State hourly labor rate (Chapter 3, Section 3.3.11.2).
B.6.4 State Service Line Inventory and Replacement Related Costs under the 2021 LCRR
States will incur burden to conduct oversight activities related to systems' service line inventory and
replacement programs. Section B.6.4.1 describes oversight activities associated with the service line
inventory. Section B.6.4.2 includes activities to review the SLR plan, Section B.6.4.3 includes the review
of the annual SLR report, and Section B.6.4.4 includes oversight activities related to systems' goal-based
replacement activities. Exhibit B-88 at the end of Section B.6.4.4 provides the SafeWater LCR model
approach including additional cost inputs that are required to calculate the total costs.
B.6.4.1 SL Inventory Costs
The EPA has identified and developed State costs for one-time activities associated with LSL inventory
development under the 2021 LCRR, as shown in Exhibit B-83. The exhibit provides the unit burden for
Final LCRI Economic Analysis Appendices
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each activity. The third column provides the corresponding SafeWater LCR model data variable in
red/italic font. The last column indicates whether the activity, unit burden, and SafeWater LCR data
variable are identical for the 2021 LCRR to those used for the final LCRI, as described in Chapter 4,
Section 4.4.4.1. The gray shaded rows indicate activities that are not required under the 2021 LCRR.
Exhibit B-83: State LSL Inventory Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
a) Review connector updated
N/A
hrs_updated_initial_inv_revJs
No. Not
LCRR initial inventory (baseline
required under
inventory) (one-time)
the 2021 LCRR.
b) Review service line inventory
0.5 hrs/CWS or
hrs_inv_update_revJs
Yes.
updates
NTNCWS
c) Review validation report (one-
N/A
hrs_inv_valid_revJs
No. Not
time)
required under
the 2021 LCRR.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; LCRR = Lead and Copper
Rule Revisions; NTNCWS = non-transient non-community water system;
Sources:
a): "LCRI Updated Initial Inventory with Connectors_Final.xlsx."
b) & c): "Inventory Updates and Validation_Final.xlsx."
B. 6.4.2 SLR Plan Review Costs
The EPA has identified and developed State costs for activities associated with the review of the SLR
plan under the 2021 LCRR, as shown in Exhibit B-84. The exhibit provides the unit burden for each
activity. The assumptions used in the estimation of the unit burden follow the exhibit. The third column
provides the corresponding SafeWater LCR model data variable in red/italic font. The last column
indicates whether the activity, unit burden, and SafeWater LCR data variable for the 2020 LCRR are
identical to those used for the final LCRI, as described in Chapter 4, Section 4.4.4.2. The gray shaded
rows indicate activities that are not required under the 2021 LCRR.
Exhibit B-84: State LSL Plan and Annual Report Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
d) Review initial SLR plan (one-
time)1
6 to 26 hours/CWS
6 hours/NTNCWS
hrs_slr_planJs
No. See discussion
following this
exhibit.
e) Review information on
deferred deadline and
associated replacement rate
in the SLR plan and
determine fastest feasible
rate
N/A
hrs_slr_plan_deferJs
No. Not required
under the 2021
LCRR.
Final LCRI Economic Analysis Appendices
B-166
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Activity
Unit Burden
SafeWaterLCR Data Variable
Same As Final
LCRI?
f) Review annually updated SLR
plan or certification of no
change
N/A
hrs_slr_plan_updateJs
No. Not required
under the 2021
LCRR.
g) Conduct triennial review of
water system updated
recommended deferred
deadline and associated
replacement rate and
determine fastest feasible
rate
N/A
hrs_defer_updateJs
No. Not required
under the 2021
LCRR.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; LCRR = Lead and Copper
Rule Revisions; NTNCWS = non-transient non-community water system; SLR = service line replacement.
Source: "LSLR Ancillary Costs_Final.xlsx."
Notes
1 Under the 2021 LCRR, this includes burden to negotiate a goal-based replacement rate for CWSs serving more
than 10,000 people if they are triggered into the goal-based service line replacement program due to a lead TLE.
d) Review initial SLR plan (hrs_slr_plan_js). States will incur burden to review the SLR plan that water
systems with lead, GRR, and/or unknown service lines must prepare. This estimate also includes
burden for the State to negotiate a replacement goal with CWSs serving more than 10,000 people,
should the systems be triggered into the goal-based replacement program due to a TLE. The State
burden (hrs_slr_planJs) is based on the ASDWA 2020 CoSTS model as provided in Exhibit B-85
(ASDWA, 2020b).
Exhibit B-85: One-Time Burden to Review SLR Plan and Negotiate Replacement Goal under
the 2021 LCRR (hrs/system)
System size
(Population Served)
CWSs
NTNCWSs
hrs_slr_planJs
<3,300
6
6
3,301-10,000
10
6
10,001-50,000
18
6
> 50,000
26
6
Acronyms: CWS = community water system; NTNCWS = non-transient non-community water system.
Source: ASDWA's "Final CoSTS 2-6-20," worksheet "LSL Inv. and Repl." includes the burden to review the LSLR plan
in row 71 of 6,10,18 hours for NTNCWS/small CWS, medium CWS, and large CWS, respectively. The EPA assumed
large, medium, and small systems corresponded to those size categories defined in the pre-2021 LCR as systems
serving more than 50,000 people, 3,301 to 50,000 people, and 3,300 or fewer people, respectively. For CWSs
serving more than 10,000 people, the burden also includes hours to negotiate a goal of 8 hours from row 73
(ASDWA, 2020b).
Final LCRI Economic Analysis Appendices
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B. 6.4.3 SLR Report Review Costs
The EPA has identified and developed State costs for an activity associated with the review of the annual
SLR report under the 2021 LCRR, as shown in Exhibit B-86. The exhibit provides the unit burden for this
activity. The assumptions used in the estimation of the unit burden follow the exhibit. The third column
provides the Exhibit B-86 corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the unit burden, and SafeWater LCR data variable are identical for the 2021 LCRR
to that used for the final LCRI, as described in Chapter 4, Section 4.4.4.3.
Exhibit B-86: State LSL Plan and Annual Report Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
h) Review annual SLR program
report1
1 to 4 hours/CWS;
1 hour/NTNCWS
hrs_report_lcrJs
Yes.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system;; SLR = service line replacement.
Source: "LSLR Ancillary Costs_Final.xlsx."
Notes
1 The EPA assumes that this burden includes review of the system's progress on goal-based replacement when
applicable. See Section B.6.4.4 for goal-based activities.
B. 6.4.4 Goal-Based Replacement Program Activities
Exhibit B-87 shows the EPA's estimated burden and/or costs for all activities related to a goal-based
replacement program for CWSs serving > 10,000 people with known or potential lead content that
experience a TLE but not an ALE under the 2021 LCRR. The assumptions used in the estimation of the
unit burden and costs follow the exhibit. The third column provides the corresponding SafeWater LCR
model data variable in red/italic font. The last column indicates that these requirements are unique to
the 2021 LCRR. Additional detail describing each activity is provided following the exhibit.
Exhibit B-87: State Goal-Based Replacement Program Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
i) Provide targeted SLR program
outreach templates and
consults with PWS
2.25 to 2.5 hrs/CWSs
serving > 10,000
hrs_temp_lslr_outJs
No. Unique to
the 2021 LCRR.
j) Review targeted outreach
materials
0.5 hours/CWS serving
10,001 - 50,000 people;
2 hours/CWS serving
> 50,000 people
hrs_review_targeted_peJs
No. Unique to
the 2021 LCRR.
k) Determine additional
activities for CWSs not
meeting their goal-based rate
2 hours/CWS serving
> 10,000 with TLE that
fails to meet SLR goal
hrs_consultJ:ailJs
No. Unique to
the 2021 LCRR.
Acronyms: CWS = community water system; LCRI = Lead and Coper Rule Improvements; LCRR = Lead and Copper
Rule Revisions; PWS = public water system; SLR = service line replacement; TLE = trigger level exceedance.
Sources:
Final LCRI Economic Analysis Appendices
B-168
October 2024
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i) & j): "Public Education lnput_CWS_Final.xlsx."
k): "LSLR Ancillary Costs_Final.xlsx."
i) Provide targeted LSLR program outreach templates and consult with PWS (hrs_temp_lslr_out Js).
CWSs serving more than 10,000 people with a TLE must provide additional outreach to customers
served by lead, GRR, or unknown service lines regarding the system's SLR program. The EPA
assumed that the State will incur a one-time burden to provide a template for these outreach
materials and consult with the system of 2.25 to 2.5 hours. The estimates are based on responses
from Indiana and North Carolina to an ASDWA survey regarding the burden to provide a template
for revised sampling instructions. The EPA assumed that the burden to provide the outreach
template would be the same as the burden to provide the sampling template (hrs_rev_samp_js),
which is based on the North Carolina estimate of 0.25 hours per sampling instructions template and
the Indiana estimate of 0.5 hours per template. It includes an additional 2 hours for consultation
with the CWS. The questionnaire and each State's responses are available in the docket at EPA-HQ-
OW-2022-0801 at www.regulations.gov.
j) Review targeted outreach materials (hrs_review_targeted_peJs). The EPA assumed that States
will incur a one-time burden to review the SLR program outreach materials described in activity i)
above. The EPA assumed that CWSs serving 10,001 to 50,000 people will use a template and States
will require 0.5 hours to review the outreach materials. The EPA assumed that systems serving more
than 50,000 people will adapt the template and the States will require more time to review these
materials of 2 hours. This estimate is consistent with that assumed for the review of other types of
consumer outreach and PE materials.
k) Determine additional activities for CWSs not meeting their goal-based rate (hrs_consult_fail Js).
States will also incur burden to determine needed activities for CWSs serving more than 10,000
people with a TLE that fail to meet their goal-based replacement requirements, the EPA assumed
States will incur a burden of 2 hours per system (hrs_consult_failJs). The EPA assumed this
consultation burden is similar to that used for other activities and is based on the estimated burden
for systems to consult with their State on PE activities from pg. 60 of the Economic and Supporting
Analyses: Short-Term Regulatory Changes to the Lead and Copper Rule (USEPA, 2007).
To estimate total costs for this activity, the EPA multiplied the burden by the estimated number of
systems that fail to meet their SLR goal. For modeling purposes, the EPA assumed that States would
set an average replacement rate goal of 2 percent per year (pp_lsl_replaced_vol_goal). To recognize
that this is a goal and not a requirement, the EPA modeled a range of actual replacement rates of 1
to 5 percent with a most likely value of 2.5 percent (pp_lsl_replaced_vol_pct). For each system in the
goal-based program, the SafeWater LCR model randomly selects a replacement rate from this
distribution and when the rate is less than 2 percent, the State will incur burden to determine
additional activities for PWSs.
Exhibit B-88 provides the SafeWater LCR model costing approach including additional cost inputs that
are required to calculate the total costs under the 2021 LCRR. It also indicates for which activities the
costing approach is the same for the 2021 LCRR as the final LCRI, as provided in Chapter 4, Exhibit 4-177,
as well as which final LCRI activities do not apply under the 2021 LCRR in gray shaded rows.
Final LCRI Economic Analysis Appendices
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Exhibit B-88: State Lead Service Line Replacement Cost Estimation in SafeWater LCR by
Activity under the 2021 LCRR1,2
i) Provide targeted SLR program outreach templates and consult with PWS
The hours per system multiplied by
the State labor rate.
(hrs_temp_lslr_outJs*rateJs)
Cost does not
apply to States for
NTNCWSs.
At or
below AL
and above
TL
States with any model
PWSs with service lines
of lead or unknown
content
One Time
j) Review targeted outreach materials
The hours per system multiplied by
the State labor rate.
(hrs_review_targeted_peJs*rateJs)
Cost does not
apply to States for
NTNCWSs.
At or
below AL
and above
TL
States with any model
PWSs with service lines
of lead or unknown
content
One Time
k) Determine additional activities for CWSs not meeting their goal-based rate
The hours per system multiplied by
the State labor rate.
(hrs_consult_failJs*rateJs)
Cost does not
apply to States for
NTNCWSs.
At or
below AL
and above
TL
States with any model
PWSs that do not meet
their goal-based
replacement rate
Once a
year
Acronyms: AL = action level; CWS = community water system; LCRI = Lead and Copper Rule Improvements; LCRR =
Lead and Copper Rule Revisions; NTNCWS = non-transient non-community water system; PWS = public water
system; SLR = service line replacement; TL = trigger level.
Notes:
Final LCRI Economic Analysis Appendices
B-170
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1 The data variables in the exhibit are defined previously in this section with the exception of the following:
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
2As previously discussed in Section B.5.4.4, in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the
State pays for the cost of bottles and shipping and conducting the analysis for samples following LSLR. Thus, the
State will incur the burden and cost for these activities (ASDWA, 2020a).
3 PWSs with lead content or unknown lines are identified using the data variables and approach described in
Chapter 3, Section 3.3.4.
4The costing approach is the same for this activity under the 2021 LCRR and final LCRI but as explained in Section
B.6.4.2, activity d) the input values are different.
B.6.5 State POU Related Costs under the 2021 LCRR
States will incur both one-time and ongoing burden to conduct oversight activities related to systems'
POU programs under the 2021 LCRR. CWSs serving 10,000 or fewer people above the TL and NTNCWSs
with a lead 90th percentile above the TL must evaluate and recommend to their State which compliance
alternative they would implement if they have a future lead ALE that can include POU device installation
and maintenance. State activities and associated SafeWater LCR model cost inputs for one-time and
ongoing activities are described in Sections B.6.5.1 and B.6.5.2, respectively.
B.6.5.1 One-Time POU Program Costs
The EPA has developed costs for three one-time State activities related to POU program oversight as
under the 2021 LCRR, shown in Exhibit B-89. The exhibit provides the unit burden for each activity. The
third column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the activity, unit burden, and SafeWater LCR data variable under the 2021 LCRR
are identical to those used for the final LCRI, as described in Chapter 4, Section 4.4.5.1. As previously
stated, the main difference between the two rule is that under the 2021 LCRR, CWSs serving up to
10,000 people can implement this option with State approval as opposed to 3,300 or fewer people
under the final LCRI. The other difference is that some of these activities are required when the system
exceeds the lead TL under the 2021 LCRR.
Exhibit B-89: State One-Time POU-Related Burden Estimates
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
a) Review POU plan
37 to 67 hrs/CWS serving < 10,000;
29.5 to 67 hrs/NTNCWSs
hrs_pou_plan_revJs
Yes
b) Provide templates
0.25 to 0.5 hrs/PWS serving < 10,000
hrs_temp_pouJs
Yes
for POU outreach
materials
c) Review POU PE
0.5 hrs/CWS serving < 10,000;
hrs_review_pe_pouJs
Yes
materials
0.5 to 2 hrs/NTNCWSs
Acronyms: CWS = community water system; LCRI = Lead and Copper rule Improvements; NTNCWS = non-transient
non-community water system; PE = public education; POU = point-of-use; PWS = public water system.
Source:
a): "POU lnputs_Final.xlsx."
b) & c): "Public Education lnputs_CWS_Final.xlsx"; "Public Education lnputs_NTNCWS_Final.xlsx."
Notes:
Final LCRI Economic Analysis Appendices
B-171
October 2024
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a) - c): States will only conduct these activities for the subset of CWS serving <10,000 people and NTNCWSs that
have a TLE or lead ALE without a prior TLE and for which POU provision and maintenance is their approved lead
compliance option. This differs from the final LCRI in which these oversight activities apply to CWS serving <3,300
people and NTNCWSs that have a lead ALE and for which POU provision and maintenance is their approved lead
compliance option.
c) The rule does not explicitly include a POU plan. However, the EPA assumed most systems would prepare this
plan prior to implementing a POU program. This assumption may overestimate costs during the first year the
program is implemented.
Exhibit B-91 in Section B.6.5.2 provides the SafeWater LCR model approach including additional cost
inputs that are required to calculate the total costs under the 2021 LCRR.
B.6.5.2 Ongoing POU Program Costs
The EPA has developed costs for three ongoing State activities related to POU program oversight under
the 2021 LCRR, as shown in Exhibit B-90. The exhibit provides the unit burden for each activity. The third
column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the activity, unit burden, and SafeWater LCR data variable for the 2021 LCRR are
identical to those used for the final LCRI, as described in Chapter 4, Section 4.4.5.2.
Exhibit B-90: State Ongoing POU-Related Burden Estimates under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
d) Review sample
2 hrs/request
hrs_samp_invalidJs
Yes
invalidation request for
POU monitoring
e) Review customer
0.33 to 0.5/certification
hrs_cert_cust_ltJs
Yes
notification certifications
f) Review annual POU
0.5 hrs/CWS serving
hrs_pou_report_ann_revJs
Yes
program report
< 10,000 people;
0.5 to 4 hr/NTNCWS
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system; POU = point-of-use.
Sources:
d) & e): "Lead Analytical Burden and Costs_Final.xlsx."
f): "POU lnputs_Final.xlsx."
Notes:
d) - f): States will only conduct these activities for the subset of CWS serving <10,000 people and NTNCWSs that
have a TLE or lead ALE without a prior TLE and for which POU provision and maintenance is their approved lead
compliance option. This differs from the final LCRI in which these oversight activities apply to CWS serving <3,300
people and NTNCWSs that have a lead ALE and for which POU provision and maintenance is their approved lead
compliance option.
Exhibit B-91 provides the SafeWater LCR model costing approach for POU-related activities a) through f)
including additional cost inputs that are required to calculate the total costs under the 2021 LCRR. It also
indicates for which activities the costing approach under the 2021 LCRR is the same as the final LCRI, as
provided in Chapter 4, Exhibit 4-182.
Final LCRI Economic Analysis Appendices
B-172
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Exhibit B-91: State POU Cost Estimation in SafeWater LCR (by Activity)1,2
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to
Apply to a State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
a) Review POU plan
The hours per system multiplied by the
State labor rate.
(hrs_pou_plan_revJs*rateJs)
Cost applies as
written to States for
NTNCWSs.
Above TL
States with model
PWSs installing
POU devices or
conducting a POU
plan
One time
b) Provide templates for POU outreach materials
The hours per system multiplied by the
State labor rate.
(hrs_temp_pouJs*rateJs)
Cost applies as
written to States for
NTNCWSs.
Above TL
States with model
PWSs installing
POU devices or
conducting a POU
devices
One time
c) Review POU PE materials
Same as final LCRI (see Exhibit 4-182 in Chapter 4).
d) Review sample invalidation request for POU monitoring
Same as final LCRI (see Exhibit 4-182 in Chapter 4).
e) Review customer notification certifications
Same as final LCRI (see Exhibit 4-182 in Chapter 4).
f) Review annual POU program report
Same as final LCRI (see Exhibit 4-182 in Chapter 4).
Acronyms: AL = action level; CWS = community water system; LCRI = Lead and Copper Rule Improvements;
NTNCWS = non-transient non-community water system; PE = public education; POU = point-of-use; PWS = public
water system; TL = trigger level.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
2As previously discussed in Section B.5.5.2, in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the
State pays for the cost of bottles and shipping and conducting the analysis for samples following LSLR (ASDWA,
2020a). Thus, the State will incur the burden and cost for these activities.
B.6.6 State Lead Public Education, Outreach, and Notification Costs under the 2021 LCRR
Under the 2021 LCRR, States will incur burden to conduct oversight and review activities related to
consumer notice in response to a single lead sample above 15 ng/L, additional education and outreach
regardless of a system's lead 90th percentile level, and PE requirements in response to a system's lead
90th percentile level. These activities and associated costs are detailed in Sections B.6.6.1 through
B.6.6.3, respectively. Exhibit B-95 at the end of Section B.6.6.3 provides details on how costs are
calculated for PWS PE activities a) through p) including additional cost inputs that are required to
calculate these costs.
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Note that State PE activities associated with outreach that is provided to customers when a CWS serving
more than 10,000 people exceeds the TL or fails to meet their replacement goal were previously
discussed in B.6.4. State PE activities associated with the POU program were previously discussion in
Section B.6.5. State activities associated with enhanced public outreach for systems with a minimum of
three lead ALEs in a five-year period (i.e., multiple lead ALEs) is a new requirement under the final LCRI
and is not discussed in this appendix (see Chapter 4, Section 4.4.6.4 for these State requirements and
costing assumptions).
B.6.6.1 Consumer Notice
The EPA has developed State costs related to a system's three-day calendar consumer notice in
response to a lead sample above 15 ng/L under the 2021 LCRR, as shown in Exhibit B-92. The exhibit
provides the unit burden. The third column provides the corresponding SafeWater LCR model data
variable in red/italic font. The last column indicates that the activity, unit burden, and SafeWater LCR
data variable are identical under the 2021 LCRR to those used for the final LCRI, as described in Chapter
4, Section 4.4.6.1. However, under the 2021 LCRR this three-day notification applies only to lead
samples that exceed 15 ng/L; whereas, under the final it would apply all lead and copper results and
must be completed within three business days.
Exhibit B-92: State Burden for Consumer Notification When Sample is > 15 |ig/L under the
2021LCRR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
a) Provide templates for
consumer notice materials
0.25 to 0.5 hrs per PWS
hrs_consumer_notice_tempJs
Yes.
b) Review lead consumer
notice materials
0.5 to 2 hours per PWS
hrs_consumer_notice_revJs
Yes.
c) Review copy of the
consumer notice and
certification
0.5 hrs/customer
contact
hrs_samp_noticeJs
Yes.1
Acronyms: LCRI = Lead and Copper Rule Improvements; PWS = public water system.
Source: "Public Education lnputs_CWS_Final.xlsx," "Public Education lnputs_NTNCWS_Final.xlsx."
Note:
1 The burden and cost estimates are the same under the 2021 LCRR and final LCRI; however, under the 2021 LCRR
this notification applies only to lead samples that exceed 15 ng/L. Under the final LCRI, the EPA is requiring all lead
and copper results be provided to consumers at tested taps within three business days.
B. 6.6.2 Activities Regardless of the Lead 90th Percentile Level
The EPA has developed State costs for activities associated with PE requirements under the 2021 LCRR
that are independent of a system's lead 90th percentile status, as provided in Exhibit B-93. The exhibit
provides the unit burden. The third column provides the corresponding SafeWater LCR model data
variable in red/italic font. The last column indicates whether the activity, unit burden, and SafeWater
LCR data variable for the 2021 LCRR are identical to those used for the final LCRI, as described in Chapter
4, Section 4.4.6.2. The gray shaded row indicates an activity that is not required under the 2021 LCRR.
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Exhibit B-93: State Burden for Public Education Activities that Are Independent of Lead 90th
Percentile Levels under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
d) Provide templates for updated
CCR language (one-time)
0.25 to 0.5 hrs/CWS
hrs_temp_ccrJs
Yes
e) Provide templates for local and
State health departments lead
outreach
0.25 to 0.5 hrs/CWS
hrs_pub_temp_hcJs
Yes
f) Review lead outreach materials
for local and State health
departments
0.5 to 2 hrs/CWS
hrs_pub_rev_hcJs
Yes
g) Participate in joint
communication efforts with
local and State health
departments
1 hr/CWS
hrs_hcJs
Yes
h) Provide templates for service
line disturbance outreach
materials
0.25 to 0.5/CWS
hrs_wtr_tempJs
Yes
i) Review public education
materials for service line
disturbances
0.5 to 2 hrs/CWS with
LSLs
hrs_review_wtr_peJs
Yes
j) Provide templates for
inventory-related outreach
materials (one-time)
0.25 to 0.5/CWS or
NTNCWS
hrs_pejsl_gen_tempJs
Yes
k) Review inventory-related
outreach materials (one-time)
0.5 to 2 hours/CWS or
NTNCWS
hrs_pejsl_revJs
Yes
1) Provide technical assistance to
PWSs for public education
materials
N/A
hrs_translate_phoneJs
cost_translate_state
No. Not
required
under the
2021 LCRR.
m) Review public education
certifications1
CWSs
1 to 1.5 hrs/CWS
NTNCWSs
0.33 to 0.5 hrs/NTNCWS
CWSs
hrs_pe_certify_quarterlyJs
NTNCWSs
hrs_cert_outreach_annualJs
Yes
Acronyms: CCR = consumer confidence report; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; LCRR = Lead and Copper Rule Revisions; LSL = lead service lines; PE = public education.
Sources:
d) - i): "Public Education lnputs_CWS_Final.xlsx."
j)-k, m): "Public Education lnputs_CWS_Final.xlsx" "Public Education lnputs_NTNCWS_Final.xlsx."
Notes:
1 The EPA assumed that a system's certification would not only include any outreach conducted in response to a
lead ALE but also include lead consumer notice that is conducted in response to a sample exceeding 15 ng/L and
other outreach activities that are independent of a system's lead 90th percentile level.
B.6.6.3 Public Education Activities in Response to Lead ALE under the 2021 LCRR
The EPA has developed State costs for activities associated with PE requirements in response to a lead
ALE under the 2021 LCRR, as provided in Exhibit B-94. The exhibit provides the unit burden. The third
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column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates that the activity, unit burden, and SafeWater LCR data variable are identical for the
2021 LCRR to those used for the final LCRI, as described in Chapter 4, Section 4.4.6.3.
Exhibit B-94: State PE Burden in Response to Lead ALE under the 2021 LCRR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
n) Provide templates for updated
0.25 to 0.5/CWS or
hrs_ale_lang_tempJs
Yes.
public education materials for
NTNCWS
systems with a lead ALE
o) Review revised lead language (one-
0.5 to 2 hrs/CWS or
hrs_ale_langjs
Yes.
time)
NTNCWS
p) Consult with CWS on other PE
2 hrs/CWS
hrs_ale_consultJs
Yes.
activities in response to a lead ALE
Acronyms: ALE = action level exceedance; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; PE = public education; NTNCWS = non-transient non-community water system.
Sources:
n) & o): "Public Education lnputs_CWS_Final.xlsx;" "Public Education lnputs_NTNCWS_Final.xlsx."
p): "Public Education lnputs_CWS_Final.xlsx."
Exhibit B-95 provides details on how total costs for the State PE requirements under the 2021 LCRR are
calculated for activities a) through p) including additional cost inputs that are required to calculate the
total costs. It also indicates that in general they are the same as those used for final LCRI, as shown in
Chapter 4, Exhibit 4-189. The gray shaded row indicates an activity that is new under the final LCRI and
does not apply to the 2021 LCRR. As previously stated, this exhibit does not include State oversight
activities that are related to water systems that have multiple lead ALEs, which is a new requirement
under the final LCRI (see Chapter 4, Section 4.4.6.4 for information).
Exhibit B-95: State Lead Public Education Cost Estimation in SafeWater LCR by Activity under
the 2021 LCRR1'2
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to
a State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
a) Provide templates for consumer notice materials
The hours per system multiplied by
the State labor rate.
(hrs_consumer_notice_tempJs
*rate js)
Cost applies as
written to States for
NTNCWSs.
All
All States with model
PWSs with at least one
sample > 15 |jg/L
Once per
event
b) Review lead consumer notice materials
The hours per system multiplied by
the State labor rate.
(hrs_consumer_notice_revJs
*rate js)
Cost applies as
written to States for
NTNCWSs.
All
All States with model
PWSs with at least one
sample > 15 |jg/L
Once per
event
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State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to
a State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
c) Review copy of the consumer notice and certification
The hours per system multiplied by
the State labor rate.
Cost applies as
written to States for
All
All States with model
PWSs with at least one
Once per
event
(hrs_samp_noticeJs*rateJs)
NTNCWSs.
sample > 15 |jg/L
d) Provide templates for updated CCR language
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
e) Provide templates for local and State health departments lead outreach
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
f) Review lead outreach materials for local and State health departments
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
g) Participate in joint communication efforts with local and State health departments
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
h) Provide templates for service line disturbance outreach materials
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
i) Review public education materials for service line disturbances
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
j) Provide templates for inventory-related outreach materials
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
k) Review inventory-related outreach materials
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
I) Provide technical assistance to PWSs for public education materials
N/A under the 2021 LCRR. New requirement under the final LCRI.
m) Review public education certifications
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
n) Provide templates for updated public education materials for systems with a lead ALE
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
o) Review revised lead language
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
p) Consult with CWS on other public education activities in response to lead ALE
Same as final LCRI (see Exhibit 4-189 in Chapter 4).
Acronyms: ALE = action level exceedance; CCR = consumer confidence report; CWS = community water system;
LCRI = Lead and Copper Rule Improvements; LCRR = Lead and Copper Rule Revisions; NTNCWS = non-transient
non-community water system; PWS = public water system.
Notes:
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1 State oversight burden and costs for systems with LSLs with the exception of those associated with service line
disturbances and implementing the POU program are included in Sections B.6.6.2B.6.4 and B.6.5B.6.5.1,
respectively.
2 The data variables in the exhibit are defined previously in this section with the exception of:
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
B.7 Estimating Compliance Activity Under the Pre-2021 LCR
In the primary economic analysis (EA), the EPA used the final Lead and Copper Rule Revisions (2021
LCRR) regulatory framework as the baseline for the estimated incremental costs and benefits of the final
Lead and Copper Rule Improvements (LCRI) (see Chapters 4, 5, and 6). This choice of baseline in the
primary EA is consistent with Office of Management and Budget (OMB) guidance in Circular A4 (OMB,
2023). Circular A4 states that the proposed regulations "are generally measured against a no-action
baseline: an analytically reasonable forecast of the way the world would look absent the regulatory
action being assessed." Absent in the final regulatory changes in this final LCRI rulemaking, the 2021
LCRR would remain in effect and best represents the future regulatory framework and costs faced by
public water systems (PWSs) and the resultant social benefits that would accrue to the public free of
additional regulatory action.
Because most of the regulatory requirements of the 2021 LCRR have not been implemented as of the
date of this final rule the EPA for informational purposes, in this appendix, estimated the incremental
costs and benefits of the final LCRI using the pre-2021 Lead and Copper Rule (LCR) as the baseline
regulatory framework. The results shown are the incremental costs and benefits of the final LCRI if the
requirements of the 2021 LCRR to be implemented after October 24, 2024, had not been promulgated.
These results will assist stakeholders that are more familiar with the current, or pre-2021 LCR, state of
the world with understanding the potential estimated impacts of the final LCRI.
In order to maintain consistency between how the SafeWater LCR model estimates the costs for the
final LCRI and the pre-2021 LCR baseline, certain parts of the cost model remain constant across rule
scenarios, including the baseline characteristics of the model-PWSs, the analysis period and discount
rates, how very large systems are modeled, the assignment of the model-PWS's initial P90-range and
the likelihood that a single sample is greater than the ALE (both of which differ from the final LCRI and
2021 LCRR due to different sampling requirements under each rule), and how changes in source water
or treatment changes impact the PWS's P90y+i-range.
In addition, the EPA estimated the costs of the pre-2021 LCR under the same low and high scenarios
used to estimate the final LCRI costs. The low scenario and high scenario differ in their assumptions
made about: 1) the number of PWS above the AL under the pre-2021 LCR; 2) the cost of installing and
optimizing CCT; and 3) the cost of SL replacement.
This section describes the modeling framework for the pre-2021 LCR that the SafeWater LCR model
employs to determine if a model-PWS will take an action that will change its P90-range, which in turn
will change other actions the model-PWS will be required to take.
B.7.1 Corrosion Control Technology
After the SafeWater LCR model determines if a model-PWS's P90y+i-range will be impacted by a change
in source water or treatment technology (see Section B.3.1), it continues within the year-loop and
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begins the process of determining if the model-PWS will install or optimize CCT. The EPA assumes that
when a system installs CCT or optimizing existing CCT they will achieve the same standard of efficacy, or
lead reduction, as under the final LCRI.
The SafeWater LCR model keeps track of the model-PWS's CCT status throughout the period of analysis.
Once a model-PWS with existing CCT re-optimizes its CCT, or a model-PWS without CCT installs CCT, the
EPA assumes that the CCT is optimized and no further changes to CCT will be needed. Therefore, as the
SafeWater LCR model continues within its year-loop (see Exhibit B-96, which continues the steps
presented in Exhibit B-4), it determines whether the model-PWS has already re-optimized its existing
CCT, or installed new CCT, and therefore has optimized CCT in place (Step 10). If it does, then SafeWater
makes no change to CCT in place and to the model-PWS's P90y+i-range due to CCT (Step 16) and the
model-PWS moves on to the next stage of the year-loop (Step 18).
Model-PWSs with a P90y+i-range greater than the AL (Step 11) and existing CCT in place (Step 13) will re-
optimize their existing CCT (Step 12). If they do not have existing CCT in place (Step 16), they will install
CCT (Step 14). Once a model-PWS optimizes existing CCT, or installs CCT, SafeWater will adjust its P90y+n-
range to reflect the effectiveness of the CCT in reducing lead levels (Step 15) before moving on to the
next stage of the year-loop (Step 18). In the case of re-optimizing existing CCT, the model-PWS will first
make a recommendation to their State regarding CCT optimization and the State will review the
recommendation and either require the model-PWS to perform a CCT study or inform the model-PWS of
what changes to their CCT treatment are required. Depending on if a CCT study is required or not, this
process can take two or three years. The EPA assumes that it will require another year for the model-
PWS to optimize their CCT and an additional two years for the model-PWS's P90-range to fall below the
AL. In the case of new CCT installation, if the model-PWS has not already conducted a CCT study, the
EPA assumes it will take the model-PWS two years to complete the CCT study and an additional two
years to install the CCT technology. The EPA assumes that the model-PWS's P90-range will fall below the
AL two years after CCT is installed.
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Exhibit B-96: Simulating Corrosion Control Under the Pre-2021 LCR in SafeWater LCR Model
YES
16
No change in
P90y+i-Range due
toCCT
15
Set
P90 y+n-Range
To Reflect
Optimized OCT
17
Reduction in PWS-
wide Lead
Concentration
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B.7.2 Replacement of Lead Content Service Lines
Under the pre-2021 LCR, if a PWS's P90y-range is above the AL, PWSs are required to install CCT. If they
already have CCT installed, and their P90y-range is above the AL, they are required to replace 7 percent
of their baseline number of LSLs each year until their P90-range falls at or below the AL.47,48 EPA assumes
that it will take three years for PWSs to identify and correct any issues in order to get below the AL for
two consecutive six-month monitoring periods, which would allow them to discontinue the SL
replacement program under the pre-2021 LCR. Therefore, for modeling purposes, the SafeWater LCR
model will require three years of SL replacements. Furthermore, the EPA assumes a PWS will only
conduct one three-year period of SL replacements during the period of analysis.
Therefore, the SafeWater LCR model first checks to see if the model-PWS has already conducted three
years of SL replacements (Step 19 in Exhibit B-97) and if it has, then the SafeWater LCR model makes no
change to the model-PWS's P90y+i-range due to SL replacements (Step 26) and the model-PWS returns
to the beginning of the year-loop (Step 2 in Exhibit B-4) to determine its compliance actions and costs
for the next year of the analysis.
If the model-PWS has not already completed three years of SL replacements (Step 19), but it did conduct
SL replacement in the prior year (Step 20), it must already be in a three-year SL replacement period. In
this case, the model-PWS will remove 7 percent of its baseline LSLs this year (Step 24). If this is the third
year of the model-PWS's SL replacement program, then at the end of the year (Step 27) the SafeWater
LCR model will adjust the model-PWS's P90y+i-range to reflect the impact of SL replacement and any
other corrective actions the model-PWS took on the model-PWS's lead concentrations (Step 28). The
EPA assumes that the model-PWS's P90y+i-range will be below the AL. The model-PWS will then return
to the beginning of the year-loop (Step 2 in Exhibit B-4) to determine its compliance actions and costs
for the next year of the analysis.
47 Under the pre-2021 LCR, test-outs count towards the 7 percent annual replacement requirement. The cost of
replacing actual physical LSLs and the cost of test-outs are both captured by the SafeWater LCR model as described
in Section Error! Reference source not found.. In addition, because test-outs do not provide any actual reduction
in lead exposure, when a test-out is completed, the SafeWater LCR model does not adjust the population with LSLs
in the benefits analysis (see Chapter 6). Likewise, under the pre-2021 LCR, completion of partial LSLRs count
towards the 7 percent annual replacement requirement. Since partial LSLRs provide less reduction in lead
exposure than a full LSLR, when a partial LSLR is completed, the SafeWater LCR model accounts for this in the
benefits analysis (see Chapter 5).
48 In the case of a PWS with existing CCT in place, that has an ALE, the PWS may need to make minor adjustments
to its existing CCT to return to compliance. At the same time, the PWS would have to conduct LSLRs at a rate of 7
percent every year until their P90 is not greater than the AL for two consecutive 6-month monitoring periods.
Since both the changes to the existing CCT that would be required, and the exact time it would take for a PWS to
return to compliance, is not known, the EPA modeled the cost of this scenario assuming no incremental CCT costs
and a standard 3-year period of LSLRs. The three-year period used for the estimated average number of years of
replacements is based on 85 CWSs. For additional details, see the file "LSLR_Time_Span_Analysis_CWS_Final.xlsx,"
available in the docket at EPA-HQ-OW-2022-0801.
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If the model-PWS has not removed any LSLs in prior years (Steps 19 and 20), does not have CCT installed
(Step 21), has LSLs in the system inventory (Step 22), and has a P90y-range above the AL (Step 23) it will
begin its three-year SL replacement program by removing 7 percent of its baseline LSLs (Step 24). Since
the model-PWS has not completed its three year SL replacement program (Step 26), the SafeWater LCR
model will not make any adjustment to the model-PWS's P90y+i-range (Step 27) and the model-PWS will
return to the beginning of the year-loop (Step 2 in Exhibit B-4) to determine its compliance actions and
costs for the next year of the analysis.
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Exhibit B-97: Simulating SL replacement Under the Pre-2021 LCR in SafeWater LCR Model
YE
26
No Change in
P90y+i-Range
JT
YES
28
Reduce P90y+i-to
Below AL
Return to Beginning of Year Loop
Year = y+l
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B.8 Detailed Public Water System Costing Approach for the Pre-2021 LCR
This section details how the EPA estimated the cost of compliance with each major component of the
pre-2021 LCR, including:
• B.8.1: PWS Sampling Costs
• B.8.2: PWS CCT-Related Costs
• B.8.3: PWS Lead Service Line Replacement-Related Costs
• B.8.4: PWS Public Education-Related Costs
The final LCRI requirements associated with one-time activities to implement and administer the rule
changes, lead in drinking water testing at schools and child cares, DSSA requirements, public outreach
requirements other than those required when a system exceeds the lead AL, and the POU program are
not applicable to the pre-2021 LCR and thus are not included in this section. However, Exhibit B-98
shows all the components, subcomponents, and activities from Exhibit 4-6 in Chapter 4 for the final LCRI
to facilitate comparison between the pre-2021 LCR and final LCRI. For each major rule component, each
activity has a unique letter ID. The differences in activities costed for the final LCRI and the 2021 LCRR
are identified as follows: 1) gray shading italicized text indicates activities under the final LCRI that were
not part of the pre-2021 LCR requirements; and 2) yellow shaded activities in bold are specific to the
pre-2021 LCR and are not included in the final LCRI requirements.
Exhibit B-98: PWS Cost Components, Subcomponents, and Activities Organized by Section for
the Pre-2021 LCR1
Component
Subcomponents
Activities2
PWS
Implementation and
Administrative
Costs
PWS One-Time
Implementation and
Administrative Costs
a) Read and understand the rule.
b) Assign personnel and resources for rule
implementation.
c) Participate in training and technical assistance
provided by the State during rule implementation.
d) Provide small system flexibility option recommendation
to the State.
B.8.1.1: PWS Lead Tap
Sampling
a) Update sampling instructions for lead tap sampling
and submit to the State.
b) Contact homes to establish new 100 percent LSL tap
sampling pool.
c) Update and submit tap sampling plan to the State.
d) Report any changes in sampling locations to the State.
B.8.1: PWS
Sampling Costs
e) Confer with the State on initial lead sampling data and
status under the LCRI.
f) Obtain households for each round of lead tap
sampling.
g) Offer incentives to households to encourage
participation in lead tap sampling program.
h) Ship tap sampling material and instructions to
participating households.
i) Collect lead tap samples.
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Component
Subcomponents
Activities2
j) Determine if a sample should be rejected and not
analyzed.
k) Analyze lead tap samples in-house or commercially.
1) Prepare and submit sample invalidation request to the
State.
m) Inform consumers of tap sample results.
n) Certify to the State that results were reported to
consumers.
o) Submit request to renew 9-year monitoring waiver to
the State.
p) Submit sampling results and 90th percentile calculation
to the State.
B.8.1: PWS Sampling
Costs (Continued)
q) Oversee the customer-initiated lead sampling
program.
r) Ship tap sampling material and instructions to
participating households for customer-initiated lead
sampling program.
s) Collect lead tap samples for customer-initiated lead
sampling program.
t) Analyze lead tap samples in-house or commercially for
customer-initiated lead sampling program.
u) Inform customers of lead tap sample results for
customer-initiated lead sampling program.
B.8.1.2: PWS Lead Water
Quality Parameter
Monitoring
v) Collect lead WQP samples from the distribution
system.
w) Analyze lead WQP samples from the distribution
system.
x) Collect lead WQP samples from entry points,
y) Analyze lead WQP samples from entry points,
z) Report lead WQP sampling data and compliance with
OWQPs to the State.
B.8.1.3: PWS Copper
Water Quality Parameter
Monitoring
aa) Collect copper WQP samples from the distribution
systems.
bb) Analyze copper WQP samples from the distribution
system.
cc) Collect copper WQP samples from entry points,
dd) Analyze copper WQP samples from entry points,
ee) Report copper WQP sampling data and compliance
with OWQPs to the State.
B.8.1.4: PWS Source
Water Monitoring
ff) Collect source water samples.
gg) Analyze source water samples.
hh) Report source water monitoring results to the State.
CWS School and Child
Care Facility Lead
Sampling Costs - First
Five-Year Cycle
ii) Create a list of schools and child care facilities served
by CWS and submit to State.
jj) Develop lead outreach materials for schools and child
care facilities.
kk) Prepare and distribute initial letters explaining the
sampling program and the EPA's 3Ts Toolkit.
II) Contact elementary school or child care facility to
determine and finalize its sampling schedule (one-time)
or contact secondary school to offer sampling (annual).
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Component
Subcomponents
Activities2
mm) Contact school or child care facility to coordinate
sample collection logistics.
n n) Conduct walkthrough at school or child care facility
before the start of sampling.
oo) Travel to collect samples.
pp) Collect samples.
qq) Analyze samples.
rr) Provide sampling results to tested facilities.
ss) Discuss sampling results with the school or child care
facility.
tt) Conduct detailed discussion of high sampling results
with schools and child care facilities.
uu) Report school and child care facility sampling results to
the State.
vv) Prepare and provide annual report on school and child
care facility sampling program to the State.
CWS School and Child
Care Facility Lead
Sampling Costs - Second
Five-Year Cycle On
ww) Update the list of schools and child care facilities and
submit to the State.
xx) Contact schools and child care facilities to offer
sampling.
yy) Contact the school or child care facility to coordinate
sample collection logistics.
zz) Conduct walkthrough at school or child care facility
before the start of sampling.
aaa) Travel to collect samples,
bbb) Collect samples.
ccc) Analyze samples.
ddd) Provide sampling results to tested facilities.
eee) Discuss sampling results with the school and child care
facility.
fff) Conduct detailed discussion of high sampling results
with schools and child care facilities.
ggg) Report school and child care facility sampling results to
the State.
hhh) Prepare and provide annual report on school and child
care facility sampling program to the State.
B.8.2: PWS
Corrosion Control
Costs
B.8.2.1: CCT Installation
a) Conduct a CCT study.
b) Install CCT (PO4, PO4 with post treatment, pH
adjustment, or modify pH).
B.8.2.2: Re-optimization
of Existing Corrosion
Control Treatment
c) Revise CCT study
d) Re-optimize existing CCT.
DSSA Costs
e) Contact customers and collect follow-up tap sample.
f) Analyze follow-up lead tap sample.
g) Collect distribution system WQP sample.
h) Analyze distribution system WQP sample.
i) Review incidents of systemwide event and other
system conditions.
j) Consult with the State prior to making CCT changes.
k) Report follow-up sample results and overall DSSA
responses to the State.
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Component
Subcomponents
Activities2
B.8.2.3: Lead CCT Routine
Costs
1) Review CCT guidance.
m) Provide WQP data to the State and discuss during
sanitary survey.
n) Notify and consult with the State on required actions
in response to source water change,
o) Notify and consult with the State on required actions
in response to treatment change.
B.8.2.4 CCT Activities
Unique to the pre-2021
LCR
p) Submit water quality data to determine if CCT study
is needed.
Service Line Inventory
a) Conduct records review for connector material.
b) Compile and submit connector updated LCRR initial
inventory information (baseline inventory) to the State.
c) Identify material for unknown service lines.
d) Report annual inventory updates to the State.
e) Conduct field investigations for inventory invalidation.
f) Report validation results to State.
Service Line Replacement
Plan
g) Develop initial SLR plan and submit to the State for
review.
h) Identify funding options for full SLRs.
i) Include information on deferred deadline and
associated replacement rate in the SLR plan.
j) Update SLR plan annually or certify no changes.
k) Provide a recommendation of the deferred deadline and
associated replacement rate.
1) System replaces lead and GRR service lines
B.8.3: PWS Lead
Service Line
B.8.3.1: Lead Service Line
Replacements
m) Systems replace their portion of the LSL
n) Households replace privately-owned portion of the
LSL
o) Contact customers and conduct site visits prior to
service line replacement.
Replacement-
Related Costs
B.8.3.2: Ancillary Lead
Service Line Replacement
Activities
p) Deliver filters and 6 months of replacement cartridges
at time of service line replacement.
q) Collect tap sample post-service line replacement,
r) Analyze post-service line replacement tap sample,
s) Inform customers of tap sample result,
t) Submit annual report on service line replacement
program to the State.
B.8.3.3: Ancillary Service
Line Replacement
Activities Unique to the
Pre-2021 LCR
u) Develop information that asks if customers want
their LSL replaced,
v) Deliver information that asks if customers want their
LSL replaced.
w) Develop information that goes to customers prior to
partial LSLR.
x) Deliver prior notification for partial LSLRs.
y) Submit documentation that partial LSLR were fulfilled
z) Collect samples for test out provision,
aa) Analyze lead tap samples for test out provision.
POU Device Installation
and Maintenance
a) Provide, monitor, and maintain POU devices.
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Component
Subcomponents
Activities2
PWS POU-Related
Costs (Small System
Compliance Option)
POU Ancillary Activities
b) Develop POU plan and submit to the State.
c) Develop public education materials and submit to the
State.
d) Print POU education materials.
e) Obtain households for POU monitoring.
f) Deliver POU monitoring materials and instructions to
participating households.
g) Collect tap samples after POU installation.
h) Determine if sample should be rejected and not
analyzed.
i) Analyze POU tap samples.
j) Prepare and submit sample invalidation request to the
State.
k) Inform customers of POU tap sample results.
1) Certify to the State that POU tap results were reported
to customers.
m) Prepare and submit annual report on POU program to
the State.
B.8.4: PWS Lead
Public Education,
Outreach, and
Notification Costs
Consumer Notice
a) Develop lead consumer notice materials and submit to
the State for review.
b) Provide a copy of the consumer notice and certification
to the State.
Activities Regardless of
Lead 90th Percentile
Level
c) Update CCR language.
d) Develop new customer outreach plan.
e) Develop approach for improved public access to lead
health-related information and tap sample results.
f) Establish a process for public access to information on
known or potential lead content SL locations and tap
sample results.
g) Maintain a process for public access to lead health
information, known or potential lead content SL
locations, and tap sample results.
h) Respond to customer request for known or potential
lead content SL information.
i) Respond to requests from realtors, home inspectors,
and potential home buyers for known or potential SL
information.
j) Develop a list of local and State health agencies.
k) Develop lead outreach materials for local and State
health agencies and submit to the State for review.
1) Deliver lead outreach materials for local and State
health agencies.
m) Develop public education materials for known or
potential SL disturbances and submit to the State.
n) Deliver public education for SL disturbances.
o) Deliver filters and 6 months of replacement cartridges
during disturbances ofSLs
p) Develop inventory-related outreach materials and
submit to the State for review
q) Distribute inventory-related outreach materials
r) Provide translation services for public education
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Component
Subcomponents
Activities2
materials
Public Education
Activities in Response to
s) Update mandatory language for lead ALE public
education and submit to the State for review
Lead ALE
t) Deliver lead ALE public education materials to all
customers
u) Post notice to website
v) Prepare press release
w) Contact public health agencies to obtain additional
organizations and update recipient list
x) Notify public health agencies and other organizations
y) Consult with State on other public education activities
z) Implement other public education activities
aa) Certify to the State that lead outreach was completed3
Public Education
Activities in Response to
Multiple Lead ALEs
bb) Provide filters due to multiple lead ALEs
cc) Develop outreach materials for systems with multiple
lead ALEs and submit to the State for review
dd) Conduct enhanced public education for systems with
multiple lead ALEs
ee) Consult with States on filter program for systems with
multiple lead ALEs
ff) Develop plan for making filters available and submit to
the State for review
gg) Make filters available due to multiple lead ALEs
Acronyms: ALE = action level exceedance; CCR = consumer confidence report; CCT = corrosion control treatment;
CWS = community water system; DSSA = Distribution System and Site Assessment; GRR = galvanized requiring
replacement; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule Improvements; LSL = lead service line;
LSLR = lead service line replacement; OCCT = optimal corrosion control treatment; OWQPs = optimal water quality
parameters; PO4 = orthophosphate; POU = point-of-use; PWS = public water system; SL = service line; SLR = service
line replacement; WQP = water quality parameter.
Notes:
1 Systems will also incur burden for recordkeeping activities under the pre-2021 LCR, such as retaining records of
decisions, supporting documentation, technical basis for decisions, and documentation submitted by the system.
The EPA has included burden for recordkeeping with each activity when applicable and opposed to providing
separate burden estimates.
2The EPA assigned a unique letter ID for each activity under a given rule component. Activities are generally
organized with upfront, one-time activities first followed by ongoing activities. The lettering follows that used for
the final LCRI, in Chapter 4, Exhibit 4-6, with the exception of activities that apply to the pre-2021 LCR but not the
final LCRI.
3 For the pre-2021 LCRI discussion in Section B.8.4, the certification is re-lettered as activity aa) and is included as
part of the public education requirements when a systems exceeds the lead AL. For the final LCRI activity s) is
included in Chapter 4, Section 4.3.6.2 - Activities Regardless of Lead 90th Percentile Levels because the certification
includes all public education, outreach, and notification requirements.
As was done in Chapter 4, and Sections B.5 and B.6, the end of each subsection provides a summary
exhibit showing the SafeWater LCR modeling approach for each water system activity (e.g., Exhibit
B-99). The exhibits follow the organization of the corresponding exhibits in Chapter 4 (e.g., Exhibit B-99
mirrors Chapter 4, Exhibit 4-10).
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• The first and second columns show how unit burden and labor rate information is combined to
estimate a CWS and NTNCWS cost per activity, respectively.
• The third and fourth columns indicate the conditions under which the water system activity
occurs. The columns indicate if the system activity is dependent on:
o The system's 90th percentile range. See Section B.7 for a detailed discussion of how the
SafeWater LCR model tracks a water system's 90th percentile level and accounts for
changes in the 90th percentile level over the 35-year analysis period.
o Other characteristics of the system such as presence or absence of SLs with lead content
and/or CCT, and frequency of monitoring.
• The fifth column indicates the frequency of the activity (e.g., one-time, annually, every 3 years).
In those instances where the costing approach for a specific activity is the same under the pre-2021 LCR
and final LCRI, the exhibit directs the reader to the corresponding final LCRI exhibit in Chapter 4.
The SafeWater LCR uses the information from these exhibits to calculate total annualized water system
cost for each activity. See Sections B.3 and B.7 for detail on the cost modeling methodology for the pre-
2021 LCR.
B.8.1 PWS Sampling Costs
This section provides system unit burden and cost for lead tap sampling, lead WQP monitoring, copper
WQP monitoring, and source water monitoring in Sections B.8.1.1 through B.8.1.4, respectively.
B.8.1.1 PWS Lead Tap Sampling
The discussion of lead tap sampling costs for water systems is presented in two subsections as follows:
• B.8.1.1.1: Lead Tap Sampling Schedules and Required Number of Samples
• B.8.1.1.2: Lead Tap Sampling Activities
Exhibit B-101 at the end of Section B.8.1.1.2 is a summary exhibit that indicates how the cost inputs are
modeled by the SafeWater LCR model. Note that the SafeWater LCR model does not include the costs of
copper tap sampling, because the final LCRI does not change the program that is relevant for estimating
the costs using the SafeWater LCR model.
B.8.1.1.1 Lead Tap Sampling Schedules and Required Number of Samples
All CWSs and NTNCWSs are subject to lead tap sampling requirements. The frequency and required
number of samples depend on the systems' lead 90th percentile level and/or compliance with OWQPs as
detailed in Chapter 3, Section 3.3.7.1. Systems that qualify for reduced monitoring can collect tap
samples from a reduced number of sites on an annual, triennial, or 9-year monitoring schedule. Those
on standard monitoring must conduct lead tap monitoring every six months at the standard number of
sample sites.
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Because the number of required sampling sites and sampling schedules can vary, costs are estimated
separately for systems on the different lead tap monitoring schedules. The EPA estimated the
percentages of systems that would be on semi-annual monitoring,49 and on a reduced annual
(p_tap_annual), triennial (p_tap_triennial), or 9-year monitoring (p_tap_nine) schedule at the start of
the LCRI implementation period (assumed to be Year 4) based on historical SDWIS/Fed data. Chapter 3,
Section 4.3.7.1 provides a detailed discussion of how these percentages were derived.
The minimum required number of tap samples for CWSs and NTNCWSs on standard monitoring
(numb_samp_customer) and reduced monitoring (numb_reduced_tap) under the pre-2021 LCR, 2021
LCRR, and final LCRI are the same. Refer to Exhibit 4-9 in Chapter 4 for the minimum number of tap
samples for CWSs and NTNCWSs on standard monitoring and reduced monitoring schedules.
B.8.1.1.2 Lead Tap SamplinR Activities
The EPA has developed costs for system activities associated with lead tap monitoring as shown in
Exhibit B-99. The exhibit provides the unit burden and/or cost for each activity. The third column
provides the corresponding SafeWater LCR model data variable in red/italic font. Activities that are
conducted by some States in lieu of the water system are identified in the exhibit and further noted
below the exhibit. The last column indicates whether the activity, unit burden or cost, and SafeWater
LCR data variable are identical for the pre-2021 LCR to those used for the final LCRI, as described in
Chapter 4, Section 4.3.2.1.2. The assumptions that differ from the LCRI follow the exhibit. Gray shaded
rows indicate new requirements that apply only to the final LCRI. They are included to more fully
characterize the differences between the pre-2021 LCR and final LCRI.
Note that the conditions under which the sampling activities occur are different under the pre-2021 LCR
compared to the final LCRI. Under both rules the tap sampling frequency is a function of whether the
90th percentile lead concentration is above the lead AL but under the final LCRI the AL has been lowered
from 15 ng/Lto 10 ng/L, as discussed in Chapter 4, Section 4.3.2.1.2. In addition, under the pre-2021
LCR, systems monitoring annually collect the reduced number of tap samples for lead and copper;
whereas, under the final LCRI, systems monitoring annually collect the standard number of tap samples
for lead and reduced number for copper.
Exhibit B-99: PWS Lead Tap Sampling Unit Burden and Cost Estimates under the Pre-2021
LCR1
Activity
Unit Burden and/or
Cost1
SafeWater LCR Data
Variable
Same As Final
LCRI?
a) Update sampling instruction for
lead tap sampling and submit to
the State (one-time)
N/A
hrs_devel_samp_op
N/A under the
pre-2021 LCR.
b) Contact homes to establish new
N/A
hrs_add_lsl_samp_op
N/A under the
49 The likelihood that a system with a lead 90th percentile value at or below 15 ng/L being on an initial semi-annual
monitoring schedule is 1 minus (p_tap_annual + p_tap_triennial + p_tap_nine).
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Activity
Unit Burden and/or
Cost1
SafeWater LCR Data
Variable
Same As Final
LCRI?
100 percent LSLtap sampling
pool (one-time)
pre-2021 LCR.
c) Update and submit tap sampling
plan to the State
N/A
hrs_samp_plan_ op
N/A under the
pre-2021 LCR.
d) Report any changes in sampling
locations to the State
3 hrs/CWS
hrs_chng_tap_op
Yes.
e) Confer with the State on initial
lead sampling data and status
under the LCRI
N/A
hrs_initial_tap_confer_op
N/A under the
pre-2021 LCR.
f) Obtain households for each
round of lead tap sampling
Burden per sample
(CWSs only)
No LSLs: 0.5 hrs
With LSLs: 1 hrs
hrs_samp_ volun t_ op
No. See
discussion
following the
exhibit.
g) Offer incentives to households to
encourage participation in lead
tap sampling program
$10 to $100/sample
per CWS
costjncentive
Yes.
h) Ship lead tap sampling material
and instructions to participating
households
Burden per sample
(CWSs onlv)
0.25 hrs
Burden
hrs_discuss_samp_op
Yes.
Cost per sample (CWSs
onlv)
$8.57 to $11.33
Cost
cost_lt_samp2
No. See
discussion
following the
exhibit.
i) Collect lead tap samples
Burden per sample
0.40 to 0.71 hrs per
CWS;
0.5 hrs per NTNCWS
Cost per sample
$5.75 to $10.24 per
CWS
Burden
hrs_pickup_samp_ op
Cost
cost_pickup_samp
Yes.
j) Determine if sample should be
rejected and not analyzed
0.25 hrs/rejected
sample for CWSs
hrs_samp_reject_op
Yes.
k) Analyze lead tap samples in-
house or commercially
In-house Analysis
(CWSs >100K onlv)
Burden: 0.44
hrs/sample
Cost: $3.92/sample
In-house Analysis
hrs_analyze_samp_op2
cost_lab_lt_samp2
No. See
discussion
following the
exhibit.
Commercial Analysis
(CWSs <100K and all
NTNCWSs)
$32.20/ sample
Commercial Analysis
cost_commercial_lab2
No. See
discussion
following the
exhibit.
1) Prepare and submit sample
invalidation request to the State
2 hrs per sample per
CWS and NTNCWS
hrs_samp_in valid_ op
Yes.
m) Inform consumers of lead tap
sample results
CWS per sample
CWS
hrs_inform_samp_ op
Yes.
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Activity
Unit Burden and/or
Cost1
SafeWater LCR Data
Variable
Same As Final
LCRI?
Burden: 0.05 to 0.11
hrs
Cost: $0.72
NTNCWS per sample
Burden: 1 hr
Cost: $0,079
cost_cust_lt
NTNCWS
hrs_n tncws_inform_samp_ op
cost_ntncws_cust_lt
n) Certify to the State that results
were reported to consumers
0.66 to 1
hr/monitoring period
per CWS or NTNCWS
hrs_cert_cust_lt_op
Yes.
o) Submit request to renew 9-year
monitoring waiver to the State
1 hr/9 years per
qualifying CWS or
NTNCWS
hrs_renew_nine_op
Yes.
p) Submit sampling results and lead
90th calculation to State
No LSLs: 2 to 3 hrs per
CWS and NTNCWS
With LSLs: 2.5 to 3.75
hrs per CWS and
NTNCWS
hrs_annual_lt_op2
No. See
discussion
following the
exhibit.
q) Oversee the customer-initiated
lead sampling program
N/A
hrs_cust_request_oversee_op
N/A under the
pre-2021 LCR.
r) Ship tap sampling material and
instructions to participating
households for customer-
initiated lead sampling program
N/A
Burden
hrs_discuss_samp_op
Cost
cost_5_lt_samp3
N/A under the
pre-2021 LCR.
s) Collect lead tap samples for
customer-initiated lead sampling
program
N/A
Burden
hrs_pickup_samp_ op
Cost
cost_pickup_samp
N/A under the
pre-2021 LCR.
t) Analyze lead tap samples in-
house or commercially for
customer-initiated lead sampling
program
N/A
In-house Analysis
hrs_analyze_samp_op3
cost_lab_lt_samp3
Commercial Analysis
cost 5 commercial lab3
N/A under the
pre-2021 LCR.
u) Inform customers of lead tap
sample results for customer-
initiated lead sampling program
N/A
CWS
hrs_inform_samp_ op
cost_cust_lt
N/A under the
pre-2021 LCR.
Acronyms: CWS = community water system; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; LSL = lead service line; NTNCWS = non-transient non-community water system; PWS = public water
system.
Source: "Lead Analytical Burden and Costs_Final.xlsx."
Notes:
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1 Many of the activities listed above do not apply to NTNCWSs because, unlike CWSs, they collect their own
samples from sampling locations under their control and thus, are unlikely to change sampling sites or reject
samples for analysis. They also do not need to solicit sampling participation for customers or travel to their
residences to pick up samples.
2 In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina, the State pays for the cost of bottles, shipping,
analysis, and providing sample results to the system. Thus, the State will incur the burden and cost for these
activities in lieu of the system (ASDWA, 2020a). In addition, the SafeWater variable cost_!t_samp and
cost_commercial_lab are used for the pre-2021 LCR in lieu of the final LCRI SafeWater variables cost_5Jt_samp
and cost_5_commercial_lab, respectively.
f) Obtain households for each round of lead tap sampling (hrs_samp_volunt_op). For each
monitoring period under the pre-2021 LCR, CWSs will contact customers to obtain volunteers to
participate in the lead tap sampling program. The EPA assumed CWSs will spend 0.5 hours per
customer based on the following assumptions:
• CWSs will contact customers by phone.
• CWSs will spend 20 minutes with those that agree to participate to explain the program, or 50
percent of customers, and 5 minutes with those that do not, for an average of 15 minutes per
sample.
• Because systems will need to contact 2 customers for every one sample, the 15-minute burden
is doubled, resulting in an average burden of 0.5 hours per sample.
The assumptions used to estimate this burden are the same as those for the final LCRI with the
exception that under that rule, systems must collect all samples from available sites served by LSLs. The
EPA assumed CWSs with LSLs will require additional efforts to obtain customers to participate in the
sampling pool due to a more aggressive LSLR program and require 1 hour per sample. The EPA applies
the same inflation factors to account for customers that do not collect their sample (1-
pp_hh_return_samp), sample rejection (pp_samp_reject), and sample invalidation (pp_samp_invalid) as
the LCRI. See Chapter 4, Section 4.3.2.1.2, activity f) for additional detail.
h) Ship lead tap sampling materials and instructions to participating households
(hrs_discuss_samp_op, cost_lt_samp). The EPA assumed CWSs will ship sampling materials to
customers. Thus, CWSs will incur non-labor costs for a CWS to ship a test kit to participating
customers that includes the cost of a one-liter bottle, bottle label, resealable plastic bag, directions,
chain of custody form, and shipping container (cost_lt_samp). The inputs and assumptions for this
activity are provided in Exhibit B-100 and use the same inputs values as those used for systems
without LSLs under the final LCRI but have a different variable name for the final LCRI
(cost_5_lt_samp). Under the final LCRI the costs are higher for systems at sites with LSLs because
they must have both a first- and fifth-liter sample. Thus the system will provide five sample bottles
in lieu of one bottle in the sample kit. See Chapter 4, Section 4.3.2.1.2, activity h) for additional
detail.
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Exhibit B-100: Non-Labor Costs for CWS to Provide Test Kits (per Sample)
System Size (Population
Served)
Test Kit
Shipping bottles to
customers
Total Non-Labor Costs
to Provide Test Kits
cost_lt_samp
A
B
C = A+B
<3,300
$1.27
$7.50
$8.77
3,301 -100,000
$1.07
$7.50
$8.57
> 100,000
$3.83
$7.50
$11.33
Notes:
A: Bottles are provided as part of the commercial laboratory fee and all CWSs serving 100,000 or fewer people are
assumed to use commercial labs. Bottle costs for CWSs serving > 100,000 people are based on three vendor
quotes. See file, "Lead Analytical Burden and Costs_Final.xlsx," worksheet "Sample Kit_Bottle."
B: The EPA estimated the sample kit to weigh 0.23 pounds ("Sample Kit and Shipping Costs_Final.xlsx," worksheet
"Shipping to Customer Cost" for detail). The shipping cost is the 2020 United States Postal Service (USPS) retail
ground shipping costs for Zones 1 or 2 for package of 1 pound or less. Postage costs are available at
https://pe.usps.eom/Archive/NHTML/DMMArchive20201018/Noticel23.htm#_c037%20 (Accessed 6.27.2022).
They are also provided in "General Cost Model lnputs_Final," worksheet, "Postage", Table 2.
k) Analyze lead tap samples in-house or commercially (hrs_analyze_samp_op, cost_lab_lt_samp,
cost_5_commercial_lab). Under both the pre-2021 LCR and final LCRI, the EPA assumed that in-
house analyses for lead would only be conducted by CWSs serving more than 100,000 people
(pp_lab_samp) and that all other CWSs and all NTNCWSs would use a commercial laboratory
(pp_commercial_samp). Under the pre-2021 LCR, systems must analyze a first-liter sample collected
at any site (i.e., non-lead service line or LSL site). Under the final LCRI, systems must collect a first-
liter sample from non-lead service line sites and both a first- and fifth-liter sample from sites served
by LSLs. Thus, the burden and cost for in-house analysis or commercial laboratory cost is for one
sample per LSL site under the pre-2021 LCR as opposed to two under the final LCRI per LSL site. For
the pre-2021 LCR, the EPA assumed a per sample burden and cost for an in-house lead analysis of
0.44 hours (hrs_analyze_samp_op) and non-labor costs for analytical materials such as
preservatives, calibration standards, and QA standards of $3.92 per sample (cost_lab_lt_samp).
Under the final LCRI the burden and cost for a first- and fifth-liter sample is double at 0.89 hours and
$7.84.
The EPA assumed the per lead sample laboratory cost of $23.50 plus a cost of $8.70 to ship the
sample to the laboratory for a total per sample cost of $32.20 (cost_commercial_lab) under the pre-
2021 LCR. For the final LCRI, the EPA increased this estimate for systems with LSLs to account for the
analysis and shipping of a first- and fifth-liter sample of $23.50*2 or $47.00 plus a cost to ship two
bottles to the laboratory at $10.20 for a total cost of $57.20 for both samples (cost_5_
comm ercial_lab).
p) Submit sampling results and lead 90th percentile calculation to the State (hrs_annual_lt_op). The
EPA estimated the burden for CWSs and NTNCWSs to submit tap monitoring results and their 90th
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percentile calculation of 2 hours for systems serving 10,000 or fewer, 2.5 hours for systems serving
10,001 to 50,000, and 3 hours for systems serving more than 100,000 people. These estimates are
based on the 2022 Disinfectants/Disinfection Byproducts, Chemicaland Radionuclides Rules ICR
(Renewal), Exhibit 48 (Tap Sample Calcs) (USEPA, 2022) and were doubled from the proposed rule to
mirror changes to State burden (hrs_annual_ltJs) based on ASDWA's 2024 CoSTS model, section
"Tap Sampling" (ASDWA, 2024). Under the final LCRI, the EPA assumed systems with LSLs will incur a
25 percent higher burden because they must provide documentation if they are unable to meet
their minimum sampling requirements with sites served by LSLs. See Section 4.3.2.1.2, activity p) for
additional detail.
Exhibit B-101 provides the SafeWater LCR model cost estimation approach for system lead tap sampling
activities including additional cost inputs required to calculate these costs under the pre-2021 LCR. As
shown in the exhibit, the SafeWater LCR model relies upon additional inputs, such the system's
monitoring schedule, to compute the cost per activity. The exhibit also indicates for which activities the
costing approach is the same as the final LCRI, as provided in Chapter 4, Exhibit 4-16, as well as which
final LCRI activities do not apply under the pre-2021 LCR in gray shaded rows.
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Exhibit B-101: PWS Lead Tap Sampling Cost Estimation in SafeWater LCR by Activity under the Pre-2021 LCR1
N/A under the pre-2021 LCR.
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CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
f) Obtain households for each round of lead tap sampling
Number of required samples per system multiplied by the hours
per sample and the system labor rate. The number of required
samples is inflated to include those unreturned, invalidated, and
rejected to ensure that the cost reflects the additional burden
that must occur to meet the sampling requirement.
(numb_samp_customer+(numb_samp_customer*(1-
pp_hh_return_samp))+(numb_samp_customer*pp_samp_invali
d)+(numb_samp_customer*pp_samp_reject))*(hrs_samp_volun
t op*rate op)
All
Model PWS not on reduced
tap monitoring
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Twice per
year
Number of required samples per system multiplied by the hours
per sample and the system labor rate. The number of required
samples is inflated to include those unreturned, invalidated, and
rejected to ensure that the cost reflects the additional burden
that must occur to meet the sampling requirement.
(numb_reduced_tap+(numb_reduced_tap*(1-
pp_hh_return_samp))+(numb_reduced_tap*pp_samp_invalid)+
(numb_reduced_tap*pp_samp_reject))*(hrs_samp_volunt_op*r
ate_op)
Cost does not apply to
NTNCWSs.
Model PWS on annual
reduced tap monitoring
p_tap_annual
Once a
year
All
Model PWS on triennial
reduced tap monitoring
p_tap_triennial
Every 3
years
Model PWS is on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
g) Offer incentives to households to encourage participation in lead tap sampling program
Number of required samples per system multiplied by the cost
of the incentive. This number is not inflated by the number of
samples deemed invalid or rejected because it is assumed that
if a sample is invalid or rejected the system will return to the
same customer to resample. The EPA also assumes that
unreturned samples would not be eligible for an incentive.
Cost does not apply to
NTNCWSs.
All
Model PWS not on reduced
tap monitoring that offers an
incentive
/I - (p_tap_annual +
Twice per
year
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CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
(numb samp customer*cost incentive)
p_tap_triennial + p_tap_nine)]
* pjncentive
Number of required samples per system multiplied by the cost
of the incentive. This number is not inflated by the number of
samples deemed invalid or rejected, because it is assumed that
if a sample is invalid or rejected the system will return to the
same customer to resample. The EPA also assumes that
unreturned samples would not be eligible for an incentive.
Model PWS on annual
reduced tap monitoring that
offers an incentive
p_tap_annual * pjncentive
Once a
year
(numb reduced tap*cost incentive)
Cost does not apply to
NTNCWSs.
All
Model PWS on triennial
reduced tap monitoring that
offers an incentive
pjtapjtrienniai * pjncentive
Every 3
years
Model PWS on nine-year
reduced tap monitoring that
offers an incentive
Every 9
years
p_tap_nine * pjncentive
h) Ship lead tap sampling materials and instructions to participating households3
Number of required samples multiplied by the total of the hours
per sample to provide instructions times the system labor rate,
plus the cost of materials per sample. The number of required
samples is inflated to include those unreturned, invalidated, and
rejected, to ensure that the cost reflects the additional burden
that must occur to meet the sampling requirement.
(numb_samp_customer+(numb_samp_customer*(1-
pp_hh_return_samp))+(numb_samp_customer*pp_samp_invali
d)+(numb _samp_customer*pp_samp_reject))*((hrs_discuss_s
amp_op*rate_op)+cost_lt_samp)
Number of required samples
multiplied by the cost of
materials per sample. The
number of required samples
is inflated to include those
invalidated to ensure that
the cost reflects the
additional burden that must
occur to meet the sampling
requirement.
(numb_samp_customer+(nu
mb_samp_customer*pp_sa
mp invalid))* cost It samp)
All
Model PWS not on reduced
tap sampling monitoring
1 - (p_tap_annual +
pjtapjtrienniai + p_tap_nine)
Twice per
year
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CWS Cost Per Activity
Number of required samples multiplied by the total of the hours
per sample to provide instructions times the system labor rate,
plus the cost of materials per sample. The number of required
samples is inflated to include those unreturned, invalidated, and
rejected, to ensure that the cost reflects the additional burden
that must occur to meet the sampling requirement.
(numb_reduced_tap+(numb_reduced_tap*(1-
pp_hh_return_samp))+(numb_reduced_tap*pp_samp_invalid)+
(numb_reduced_tap*pp_samp_reject))*((hrs_discuss_samp_op
*rate_op)+cost_lt_samp)
NTNCWS Cost Per Activity
Number of required samples
multiplied by the cost of
materials per sample. The
number of required samples
is inflated to include those
invalidated to ensure that
the cost reflects the
additional burden that must
occur to meet the sampling
requirement.
(numb_reduced_tap+(numb
_reduced
tap *pp_samp_invalid)) *
cost_lt_samp)
Conditions for Cost to Apply to a
Model PWS
i) Collect lead tap samples
Number of required samples per system multiplied by the hours
per sample and the system labor rate, plus the cost of materials
per sample. The number of required samples is inflated to
include those invalidated, unreturned, and rejected to ensure
that the cost reflects the additional burden that must occur to
meet the sampling requirement.
(numb_samp_customer+(numb_samp_customer*pp_samp_inv
alid)+ +(numb_customer_samp*(1-
pp_hh_return_samp))+(numb_samp_customer*pp_samp_reject
))*((hrs_pickup_samp_op*rate_op)+cost_pickup_samp)
Number of required samples
per system multiplied by the
cost of materials per sample.
The number of required
samples is inflated to include
those invalidated to ensure
that the cost reflects the
additional burden that must
occur to meet the sampling
requirement.
(numb_samp_customer+(nu
mb samp customer*pp sa
Lead 90th -
Range
Frequency
of Activity
All
All
Other Conditions2
Model PWS on annual
reduced tap monitoring
Once a
year
p_tap_annual
Model PWS is on triennial
reduced tap monitoring
Every 3
years
p_tap_triennial
Model PWS on nine-year
reduced tap monitoring
Every 9
years
p_tap_nine
Model PWS not on reduced
tap monitoring
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Twice per
year
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CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
mp_in valid)) *cost_pickup_sa
mp
Number of required samples multiplied by the total of the hours
per sample times the system labor rate, plus the cost of
materials per sample. The number of required samples is
inflated to include those unreturned, invalidated, and rejected,
to ensure that the cost reflects the additional burden that must
occur to meet the sampling requirement.
(numb_reduced_tap+(numb_reduced_tap *(1-
pp_hh_return_samp))+(numb_reduced_tap)
*pp_samp_invalid)+(numb_reduced_tap*pp_samp_reject))*
*((hrs_pickup_samp_op*rate_op)+cost_pickup_samp)
Number of required samples
per systems multiplied by
the cost of materials per
sample. The number of
required samples is inflated
to include those invalidated
to ensure that the cost
reflects the additional
burden that must occur to
meet the sampling
requirement.
(numb_reduced_tap+(numb
_reduced_tap)
*pp_samp_invalid))*
*cost pickup samp
Model PWS on annual
reduced tap monitoring
p_tap_annual
Once a
year
All
Model PWS on triennial
reduced tap monitoring
p_tap_triennial
Every 3
years
Model PWS on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
j) Determine if sample should be rejected and not analyzed
The number of samples expected to be rejected (calculated by
multiplying the total number of required samples by the
likelihood of rejection) multiplied by the hours per sample and
the system labor rate.
(numb_samp_customer*pp_samp_reject)*(hrs_samp_reject_op
*rate op)
Cost does not apply to
NTNCWSs.
All
Model PWS not on reduced
tap sampling monitoring
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Twice per
year
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CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a
Model PWS
Lead 90th - _.. _ .... 2
„ Other Conditions2
Range
Frequency
of Activity
The number of samples expected to be rejected (calculated by
multiplying the total number of required samples by the
likelihood of rejection) multiplied by the hours per sample and
the system labor rate.
(numb_reduced_tap*pp_samp_reject)*(hrs_samp_reject_op*rat
e_op)
Cost does not apply to
NTNCWSs.
All
Model PWS on annual
reduced tap monitoring
p_tap_annual
Once a
year
Model PWS on triennial
reduced tap monitoring
p_tap_triennial
Every 3
years
Model PWS on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
k) Analyze lead tap samples in-house or commercially3
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
The number of samples is inflated to include those invalidated,
to ensure that the cost reflects the additional burden that must
occur to meet the sampling requirement.
(((numb_samp_customer+(numb_samp_customer*pp_samp_in
valid))*pp_lab_samp)*((hrs_analyze_samp_op*rate_op)+cost_l
ab_lt_samp))+(((numb_samp_customer+(numb_samp_custom
er*pp_samp_invalid))*pp_commercial_samp)*((hrs_analyze_sa
mp op*rate op)+cost commercial lab))
Cost applies as written to
NTNCWSs.
All
Model PWS not on reduced
tap sampling monitoring
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Twice per
year
The number of samples multiplied by the probabilities for a
sample analyzed in house and a sample analyzed in a
commercial lab times the different labor and material cost
burdens for each type of analysis.
Model PWS on annual
reduced tap monitoring
p_tap_annual
Once a
year
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October 2024
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CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
The number of samples is inflated to include those invalidated,
to ensure that the cost reflects the additional burden that must
occur to meet the sampling requirement.
(((numb_reduced_tap+(numb_reduced_tap*pp_samp_invalid))*
pp_lab_samp)*((hrs_analyze_samp_op*rate_op)+cost_lab_lt_s
amp))+(((numb_reduced_tap+(numb_reduced_tap*pp_samp_in
valid))*pp_commercial_samp)*((hrs_analyze_samp_op*rate_op
)+cost commercial lab))
Cost applies as written to
NTNCWSs.
All
Model PWS on triennial
reduced tap monitoring
p_tap_triennial
Every 3
years
Model PWS is on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
1) Prepare and submit sample invalidation request to the State
The number of samples expected to be invalid (calculated by
multiplying the total number of required samples by the
likelihood of invalidation) multiplied by the hours per sample
and the system labor rate.
(numb_samp_customer*pp_samp_invalid)*(hrs_samp_invalid_
op*rate op
Cost applies as written to
NTNCWSs.
All
Model PWS not on reduced
tap monitoring
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Twice per
year
The number of samples expected to be invalid (calculated by
multiplying the total number of required samples by the
likelihood of invalidation) multiplied by the hours per sample
and the system labor rate.
Cost applies as written to
NTNCWSs.
All
Model PWS on annual
reduced tap monitoring
p_tap_annual
Once a
year
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CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a
Model PWS
Lead 90th - _.. _ .... 2
„ Other Conditions2
Range
Frequency
of Activity
(numb_reduced_tap*pp_samp_invalid)*(hrs_samp_invalid_op*r
ate_op)
Model PWS on triennial
reduced tap monitoring
p_tap_triennial
Every 3
years
Model PWS on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
m) Inform consumers of lead tap sample results
The number of required of samples per system multiplied by the
total of the hours per sample times the system labor rate plus
the material cost per sample.
(numb_samp_customer)*((hrs_inform_samp_op*rate_op)+cost
_cust_lt)
Hours per sampling event
multiplied by the system
labor rate, plus the material
cost per sampling event.
C (hrs_ntncws_inform_samp_
op*rate_op)+cost_ntncws_c
ust_lt)
All
Model PWS not on reduced
tap sampling monitoring
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Twice per
year
The number of required samples per system multiplied by the
total of the hours per sample times the system labor rate plus
the material cost per sample.
(numb reduced tap)*((hrs inform samp op*rate op)+cost cu
stjt)
Hours per sampling event
multiplied by the system
labor rate, plus the material
cost per sampling event.
C (hrs_ntncws_inform_samp_
op*rate_op)+cost_ntncws_c
ust_lt)
All
Model PWS on annual
reduced tap monitoring
p_tap_annual
Once a
year
Model PWS on triennial
reduced tap monitoring
p_tap_triennial
Every 3
years
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CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
Model PWS on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
n) Certify to the State that results were reported to consumers
Total hours per sampling event multiplied by the system labor
rate.
(hrs_cert_cust_lt_op*rate_op)
Model PWS not on reduced
tap monitoring
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
Twice per
year
Cost applies as written to
NTNCWSs.
All
Model PWS on annual
reduced tap monitoring
p_tap_annual
Once a
year
Model PWS on triennial
reduced tap monitoring
p_tap_triennial
Every 3
years
Model PWS on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
o) Submit request to renew 9-year monitoring waiver to the State4
Total hours per sampling event multiplied by the system labor
rate.
(hrs_renew_nine_op*rate_op)
Cost applies as written to
NTNCWSs.
All
Model PWS on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
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CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to a
Model PWS
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
p) Submit sampling results and lead 90th percentile calculation to the State3
Total hours per sampling event multiplied by the system labor
rate.
Model PWS not on reduced
tap monitoring
Twice per
(hrs_annual_lt_op*rate_op)
1 - (p_tap_annual +
p_tap_triennial + p_tap_nine)
year
Cost applies as written to
NTNCWSs.
All
Model PWS on annual
reduced tap monitoring
p_tap_annual
Once a
year
Model PWS on triennial
reduced tap monitoring
p_tap_triennial
Every 3
years
Model PWS is on nine-year
reduced tap monitoring
p_tap_nine
Every 9
years
q) Oversee the customer-initiated lead sampling program
N/A under the pre-2021 LCR.
r) Ship tap sample monitoring materials and instructions to participating households for customer-initiated lead sampling program
N/A under the pre-2021 LCR.
s) Collect lead tap samples for customer-initiated lead sampling program
N/A under the pre-2021 LCR.
t) Analyze lead tap samples in-house or commercially for customer-initiated lead sampling program
N/A under the pre-2021 LCR.
u) Inform customers of lead tap sample results for customer-initiated lead sampling program
N/A under the pre-2021 LCR.
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Acronyms: AL = action level; CWS = community water system; EPA = Environmental Protection Agency; LCR = Lead and Copper Rule; LCRI = Lead and Copper
Rule Improvements; LSL = lead service line; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• numb_reduced-tap: the number of lead tap samples for system on reduced annual, triennial, or 9-year monitoring (Chapter 4, Section 4.3.2.1.1).
• numb_samp_customer: the number of lead tap samples for system on standard 6-month tap monitoring (Chapter 4, Section 4.3.2.1.1).
• p_tap_annual, p_tap_triennial, and p_tap_nine: likelihood a systems is collecting the reduced number of lead tap samples on an annual, triennial, or
9-year frequency, respectively (Chapter 4, Section 4.3.2.1.1).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 For modeling purposes, the EPA assumed that systems would report changes in sampling location during each monitoring period.
3The burden and costs to provide sample bottles (cost_lt_samp) under activity h), conduct analyses under activity k), and report sample results to the system
under activity p) are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
4 Only a subset of systems with lead 90th percentile values < 5 ng/Lcan quality for a 9-year monitoring waiver. See Chapter 3, Section 3.3.7.1 for additional
detail.
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B.8.1.2 PWS Lead Water Quality Parameter Monitoring
Under the pre-2021 LCR, lead WQP monitoring is required for all systems serving more than 50,000
people with CCT (except systems with naturally non-corrosive water that meet the criteria in 40 CFR
141.81(b)(3) or "b3" systems)50 and those serving 50,000 or fewer people that exceed the lead AL of 15
Hg/L. WQP samples are collected at representative sites throughout the distribution system (also
referred to as tap WQP samples) and at each entry point to the distribution system. Systems must
conduct WQP monitoring prior to the installation of CCT and after CCT installation. The State may
designate OWQPs after the installation of CCT. Systems with CCT must continue to maintain WQPs at or
above minimum values or within OWQP ranges designated by the State.
The remainder of this section is divided into four subsections:
• B.8.1.2.1: Baseline Corrosion Control Treatment
• B.8.1.2.2: Initial Monitoring Schedules
• B.8.1.2.3: Number of Samples
• B.8.1.2.4: Lead WQP Monitoring Activities
B.8.1.2.1 Baseline Corrosion Control Treatment
WQP monitoring requirements vary for systems with and without CCT and by type of CCT. To estimate
costs associated with WQP monitoring, the EPA identified systems with and without CCT, as described in
Chapter 3, Section 3.3.3. For those with CCT, the EPA estimated the percentage of systems that
currently have one of the three types of CCT used in the cost model:
• Modify pH (pbaseph),
• Add P04 without pH post-treatment (pbasepo4), and
• Add P04 and modify pH (pbasephpo4)
See Exhibit 4-18 in Chapter 4, Section 4.3.2.2.1 for the baseline percent of systems with each of these
types of CCT.
B.8.1.2.2 Initial Monitoring Schedules
As described in Chapter 3, Section 3.3.8.1, systems with CCT could qualify for reduced WQP monitoring
in the distribution system under the pre-2021 LCR if they were in compliance with State-set OWQP
ranges or minimums. The number of consecutive monitoring periods in which a system meets its
OWQPs determines if a system qualifies for reduced semi-annual, annual, or triennial WQP tap
monitoring. Note that the criteria for systems to qualify for reduced distribution system monitoring
50 All systems serving more than 50,000 people are required to have CCT and to conduct WQP monitoring with the
exception of systems that have naturally non-corrosive water, i.e., "b3" systems. Refer to Chapter 3, Section 3.3.3
for the EPA's approach for deriving the number of "b3" systems (assumed to be 16 CWSs).
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under the 2021 LCRR and final LCRI is more stringent than the pre-2021 LCR and includes a requirement
that systems' 90th percentile levels not exceed 10 ng/L. Further, under the LCRI and 2021 LCRR systems
are no longer allowed to conduct WQP tap monitoring on a triennial frequency (see Chapter 3, Section
3.3.8.2 for additional detail). For modeling purposes, the EPA applied the same approach for the pre-
2021 LCR as was used for the 2021 LCRR and final LCRI, as previously described in Chapter 3, Section
3.3.8.1.
Exhibit B-102 and Exhibit B-103 provide the percentage of CWSs serving more than 50,000 people with
CCT and no lead or copper ALE on each of the four possible WQP tap monitoring schedules under the
LCR by source water type based on analysis of SDWIS/Fed data for 2012 through 2020. For NTNCWSs,
this information is provided in Exhibit B-104 for surface water systems. Note that no ground water
NTNCWS serves more than 50,000 people. Also, these exhibits exclude systems without CCT because
WQP monitoring to comply with OWQPs is not required for these systems. The exhibits show that:
• The majority of CWS ground water systems (98.6 to 100%) and CWSs surface water systems
(98.5 to 100%) serving more than 50,000 people met the criteria triennial reduced WQP tap
monitoring.
• Of the two surface water NTNCWSs that serve more than 50,000 people, one met the criteria for
annual reduced WQP tap monitoring and the other is on six-month standard monitoring.
Exhibit B-102: Percent of Ground Water CWSs Serving > 50,000 People with CCT and No Lead
or Copper ALE on Various WQP Distribution System Monitoring Schedules (pre-2021 LCR)
System Size
(Population Served)
6 Month (Standard)
6 Month (Reduced)
Annual(Reduced)
Triennial
(Reduced)
A = 1- (B+C+D)
p_wqp_six_red
p_wqp_annual
p_wqp_triennial
B
C
D
50,001-100,000
0.0%
0.0%
0.0%
100.0%
100,001-1,000,000
1.4%
0.0%
0.0%
98.6%
>1 M
0.0%
0.0%
0.0%
100.0%
Source: For additional information, see "WQP Schedules_CWS_LCR_Final.xlsx," available in the docket at EPA-HQ-
OW-2022-0801 at www.regulations.gov.
Note: Percentages are based on OWQP violation and compliance data reported to SDWIS/Fed for 2012 - 2020 in
the fourth quarter frozen 2020 dataset, current through December 31, 2020.
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Exhibit B-103: Percent of Surface Water CWSs Serving > 50,000 People with CCT and No Lead
or Copper ALE on Various WQP Distribution System Monitoring Schedules (pre-2021 LCR)
System Size
(Population Served)
6 Month (Standard)
6 Month (Reduced)
Annual(Reduced)
Triennial
(Reduced)
A = 1- (B+C+D)
p_wqp_six_red
p_wqp_annual
p_wqp_triennial
B
C
D
50,001-100,000
1.0%
1.0%
0.0%
97.9%
100,001-1,000,000
1.5%
0.0%
0.0%
98.5%
>1 M
0.0%
0.0%
0.0%
100.0%
Source: For additional information, see "WQP Schedules_CWS_LCR_Final.xlsx," available in the docket at EPA-HQ-
OW-2022-0801 at www.regulations.gov.
Note: Percentages are based on OWQP violation and compliance data reported to SDWIS/Fed for 2012 - 2020 in
the fourth quarter frozen 2020 dataset, current through December 31, 2020.
Exhibit B-104: Percent of Surface Water NTNCWSs Serving > 50,000 People with CCT and No
Lead or Copper ALE on Various WQP Distribution System Monitoring Schedules (pre-2021
LCR)
System Size
(Population Served)
6 Month (Standard)
6 Month (Reduced)
Annual(Reduced)
Triennial
(Reduced)
A =1-(B+C+D)
p_wqp_six_red
p_wqp_annual
p_wqp_triennial
B
C
D
50,001-100,000
100.0%
0.0%
0.0%
0.0%
100,001-1,000,000
0.0%
0.0%
0.0%
100.0%
>1 M
Source: For additional information, see "WQP Schedules_NTNCWS_LCR_Final.xlsx," available in the docket at EPA-
HQ-OW-2022-0801 at www.regulations.gov.
Notes:
1. Percentages are based on OWQP violation and compliance data reported to SDWIS/Fed for 2012 - 2020 in the
fourth quarter frozen 2020 dataset, current through December 31, 2020.
2. The gray shaded cells denote that no surface water NTNCWS serves more than 1M people.
B.8.1.2.3 Number of Samples
The minimum number of WQP distribution system samples for CWSs and NTNCWSs on standard
(numb_enhance_wqp) and reduced (numb_reduced_wqp) monitoring and minimum number of entry
points (numb_ep_wqp) are the same under the pre-2021 LCR and final LCRI and are discussed in Chapter
4, Section 4.3.2.2.3. Under the final LCRI, the monitoring requirements are more stringent. Specifically,
systems serving 10,001 to 50,000 people with CCT must conduct WQP monitoring irrespective of their
lead or copper 90th percentile level. In addition systems with a lead tap sample result above the final
lead AL of 10 ng/L must conduct WQP monitoring in the distribution system at or near the site with the
high lead result. If an existing WQP site does not meet these criteria, the system must identify a new
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WQP monitoring site and those with CCT must use it for future sampling in addition to the existing
number of WQP sites. Refer to Chapter 4, Section 4.3.3.3 for a more detailed discussion.
B.8.1.2.4 Lead WQP Monitoring Activities
The EPA has developed water system costs for five lead WQP monitoring activities as shown in Exhibit
B-105. The exhibit provides the unit burden and costs for each activity. The third column provides the
corresponding SafeWater LCR model data variable in red/italic font. The last column indicates whether
the activity, unit burden or cost, and the SafeWater LCR model data variable for the pre-2021 LCR are
identical to those used for the final LCRI, as described in Chapter 4, Section 4.3.2.2.4. The assumptions
that differ from the final LCRI follow the exhibit.
Exhibit B-105: PWS Lead WQP Monitoring Unit Burden and Cost Estimates under the Pre-2021
LCR
Unit Burden and/or Cost
Same As Final
Activity
SafeWater LCR Data Variable
LCRI?
v) Collect lead WQP
Burden per sample per PWS
Burden
Yes
samples from the
0.5 hrs (distribution)
hrs_wqp_op
distribution
system
Cost per sample
Cost
No CCT: $2.66 (CWS &
No CCT: cost_wqp_material
NTNCWS)
pH adjustment:
pH: cost_wqp_material_ph
• $1.70 to $2.66 (CWS);
• $2.66 (NTNCWS)
Orthophosphate:
Orthophosphate:
• $2.66 to $2.82 (CWS)
cost_ wqp_material_ortho
• $2.66 (NTNCWS)
w) Analyze lead
In-House Burden per sample
In-House Burden
Yes (for in-house
WQP samples
No CCT: 0.15 hrs (CWS &
No CCT: hrs_wqp_analyze_dist_op
burden and
from the
NTNCWS)
cost).
distribution
pH adjustment:
pH: hrs_wqp_analyze_ph_op
system
• 0.15 to 0.46 hrs (CWS)
• 0.15 hrs (NTNCWS)
Orthophosphate:
Orthophosphate:
• 0.15 to 1.34 hrs (CWS)
hrs_wqp_analyze_ortho_op
• 0.15 hrs (NTNCWS)
In-House Cost per sample
In-House Cost
No CCT: $0.63 (CWS &
No CCT: cost_wqp_analyze
NTNCWS)
pH: cost_wqp_ph_analyze
pH adjustment:
• $0.63 to $0.98 (CWS)
• $0.63 (NTNCWS)
Orthophosphate:
Orthophosphate:
cost_wqp_ortho_analyze
• $0.63 to $1.07 (CWS)
• $0.63 (NTNCWS)
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Unit Burden and/or Cost
Same As Final
Activity
SafeWater LCR Data Variable
LCRI?
Commercial Cost per sample
Cost for Commercial Analysis
No. See
No CCT: $49.41 to 50.96 (CWS
No CCT: cost_lab_wqp1
discussion
& NTNCWS)
pH: cost_lab_ph_wqp
following this
pH adjustment: $27.24 to
Orthophosphate:
exhibit.
$30.55 (CWS & NTNCWS)
cost_lab_ ortho_ wqp
Orthophosphate: $60.34 to
$61.89 (CWS & NTNCWS)
x) Collect lead WQP
Burden per sample
Burden
Yes.
samples from
0.4 hrs for 80 percent of
hrs_ep_wqp_op
entry points
ground water PWSs1
Cost per sample
Cost
No CCT: $2.66 (CWS &
cost_ ep_ wqp_material
NTNCWS)
pH adjustment:
cost_ep_wqp_ph_material
• $1.70 to $2.66 (CWS);
• $2.66 (NTNCWS)
Orthophosphate:
cost_ ep_ wqp_ orth o_materi al
• $2.66 to $2.82 (CWS)
• $2.66 (NTNCWS)
y) Analyze lead
In-House Burden per sample
In-House Burden
Yes.
WQP samples
No CCT: 0.15 hrs (CWS &
hrs_ wqp_ analyze_ ep_ op
from entry points
NTNCWS)
pH adjustment:
hrs_ wqp_ analyze_ph_ ep_ op
• 0.15 to 0.46 hrs (CWS)
• 0.15 hrs (NTNCWS)
Orthophosphate:
hrs_ wqp_ analyze_ ortho_ep_ op
• 0.15 to 1.34 hrs (CWS)
• 0.15 hrs (NTNCWS)
In-House Cost per sample
In-House Cost
No CCT: $0.63 (CWS &
cost_ wqp_ analyze_ ep
NTNCWS)
pH adjustment:
cost_wqp_analyze_ph_ep
• $0.63 to $0.98 (CWS)
• $0.63 (NTNCWS)
Orthophosphate:
cost_wqp_analyze_ortho_ep
• $0.63 to $1.07 (CWS)
• $0.63 (NTNCWS)
Commercial Cost per sample
Commercial Cost
No. See
No CCT:
cost_lab_ wqp_ ep1
discussion
• $50.35 to $50.78 (CWS)
following the
• No CCT: $50.96 (NTNCWS)
exhibit.
pH adjustment:
cost_lab_ wqp_ph_ ep
• $30.58 to $33.30 (CWS)
• $33.93 (NTNCWS)
Orthophosphate:
cost_lab_wqp_ortho_ep
• $61.90 to $63.49 (CWS)
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Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
• $63.84 (NTNCWS)
z) Report lead WQP
sampling data
and compliance
with OWQPs
No CCT: 4 hrs/PWS
With CCT: 5 hrs/PWS
hrs_report_ wqp_op
Yes.
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRI = Lead and Copper
Improvements; NTNCWS = non-transient non-community water system; OWQP = optimal water quality
parameters; PWS = public water system; WQP = water quality parameter.
Source: "WQP Analytical Burden and Costs_Final.xlsx."
Note:
1 As explained in more detail in the text following this exhibit, the commercial WQP laboratory costs differ between
the pre-2021 LCR and final LCRI for systems without CCT.
w) Analyze lead WQP samples from the distribution system (cost_lab_wqp). The commercial
laboratory cost for systems without CCT differ under the pre-2021 LCR and final LCRI. In addition to
monitoring for pH and alkalinity, which are required under both rule, systems without CCT under the
pre-2021 LCR must also monitor calcium. The final LCRI does not include calcium as a regulated WQP
because it is used to evaluate the effectiveness of calcium stabilization that is not a CCT option
under the final LCRI. For modeling purposes, the EPA assumed the following for both rules:
• All systems serving more than 50,000 people would already have CCT in place or are b3 systems
and would not be required to install CCT.
• All systems would conduct pH in-house but only CWSs serving more than 100,000 people would
conduct all their WQP analyses in-house. All other systems would use a commercial laboratory.
Under the pre-2021 LCR, the EPA assumed that CWSs and NTNCWSs serving 50,000 or fewer people
without CCT would incur a per sample commercial cost to analyze alkalinity ($26.43) and calcium
($22.36) based on the quotes provided by seven laboratories and shipping costs ranging from 0.63 to
$1.28, as shown in Exhibit B-106.
Exhibit B-106: CWS and NTNCWS Lead Distribution Laboratory Costs without CCT under the
Pre-2021 LCR
System Size
(Population Served)
Commercial Analysis including Shipping Sample to Lab ($/Sample)
Alkalinity
Calcium
Shipping
Total
cost_lab_wqp
A
B
C
D = A:C
<100
$26.43
$22.36
$2.18
$50.96
101-500
$26.43
$22.36
$2.18
$50.96
501-1,000
$26.43
$22.36
$1.28
$50.06
1,001-3,300
$26.43
$22.36
$1.28
$50.06
3,301-10,000
$26.43
$22.36
$1.03
$49.81
10,001-50,000
$26.43
$22.36
$0.63
$49.41
> 50,000
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Source: "WQP Analytical Burden and Costs_Final.xlsx," worksheet "Non-Labor Cost_CWS_LCR" and Non-Labor
Cost_NTNCWS_LCR."
Notes:
General: The EPA assumed no costs for 16 CWSs serving > 50,000 people without CCT because they are b3 systems
and not subject to WQP requirements
A & B: Based on quotes from seven laboratories.
C: Shipping costs are 2020 USPS postage rates. The EPA assumes systems are shipping 4 to 40 samples based on
systems size to a laboratory that is in Zone 1 or 2. See WQP Analytical Burden and Costs_Final.xlsx," Table A-2 for
CWSs and Table A-4 for NTNCWSs in worksheet " Shipping to Lab_$_l_CR" for additional detail.
Under the final LCRI, the commercial laboratory cost includes only the alkalinity cost of $26.43 and
shipping costs ranging from $0.81 to $4.13 based on the number of samples shipped to the laboratory.
Also refer to Chapter 4, Section 4.3.2.2.4, activity v) for a discussion of WQP analytical distribution
system requirements under the final LCRI.
y) Analyze lead WQP samples from entry points (cost_lab_wqp_ep). Similar to activity v), the only
difference in unit burden and cost for lead WQP entry point monitoring for the pre-2021 LCR
compared to the final LCRI is that systems without CCT under the pre-2021 LCR must have samples
analyzed for copper (cost_lab_wqp_ep). Exhibit B-107 and Exhibit B-108 provide the estimated
commercial laboratory costs per entry point for CWSs and NTNCWSs, respectively.
Exhibit B-107: CWS Lead Entry Point Laboratory Costs without CCT under the Pre-2021 LCR
System Size
(Population Served)
Commercial Analysis including Shipping Sample to Lab ($/Sample)
Alkalinity
Calcium
Shipping
Total
cost_lab_wqp_ep
A
B
C
D = A:C
<100
$26.43
$22.36
$1.99
$50.78
101-500
$26.43
$22.36
$1.85
$50.64
501-1,000
$26.43
$22.36
$1.56
$50.35
1,001-3,300
$26.43
$22.36
$1.62
$50.41
3,301-10,000
$26.43
$22.36
$1.63
$50.42
10,001-50,000
$26.43
$22.36
$1.67
$50.46
> 50,000
Source: "WQP Analytical Burden and Costs_Final.xlsx," worksheet " Non-Labor Cost_CWS_LCR" and Non-Labor
Cost_NTNCWS_LCR."
Notes:
General: The EPA assumed no costs for 16 CWSs serving > 50,000 people without CCT because they are b3 systems
and not subject to WQP requirements
A & B: Based on quotes from seven laboratories.
C: Shipping costs are 2020 USPS postage rates. The EPA assumes systems are shipping 4.4 to 6.1 samples based on
systems size to a laboratory that is in Zone 1 or 2. See WQP Analytical Burden and Costs_Final.xlsx," Table A-l in
worksheet " Shipping to Lab_$_l_CR" for additional detail.
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Exhibit B-108: NTNCWS Lead Entry Point Laboratory Costs without CCT under the Pre-2021
LCR
System Size
(Population Served)
Commercial Analysis including Shipping Sample to Lab ($/Sample)
Alkalinity
Calcium
Shipping
Total
cost_lab_wqp_ep
A
B
C
D = A:C
<100
$26.43
$22.36
$2.18
$50.96
101-500
$26.43
$22.36
$2.18
$50.96
501-1,000
$26.43
$22.36
$2.18
$50.96
1,001-3,300
$26.43
$22.36
$2.18
$50.96
3,301-10,000
$26.43
$22.36
$2.18
$50.96
10,001-50,000
$26.43
$22.36
$2.18
$50.96
> 50,000
Source: "WQP Analytical Burden and Costs_Final.xlsx," worksheet "Non-Labor Cost_CWS_LCR" and Non-Labor
Cost_NTNCWS_LCR."
Notes:
General: The EPA assumed no costs for 16 CWSs serving > 50,000 people without CCT because they are b3 systems
and not subject to WQP requirements
A & B: Based on quotes from seven laboratories.
C: Shipping costs are 2020 USPS postage rates. The EPA assumes systems are shipping 4 samples to a laboratory
that is in Zone 1 or 2. See WQP Analytical Burden and Costs_Final.xlsx," Table A-3 in worksheet " Shipping to
Lab_$_LCR" for additional detail.
The SafeWater LCR model cost estimation approach for estimating the cost of lead WQP monitoring
including additional cost inputs required to calculate these costs are identical to those for the LCRR. For
additional detail, refer to Exhibit B-19 in Section B.5.2.2.4.
B.8.1.3 PWS Copper Water Quality Parameter Monitoring
As was done for the final LCRI, the SafeWater LCR models Copper WQP Monitoring separately from the
Lead WQP Monitoring for the pre-2021 LCR. The frequency of Lead WQP Monitoring depends on the
lead 90th percentile, with all systems above the AL and all systems serving more than 50,000 people
except b3 systems conducting Lead WQP Monitoring. Copper WQP Monitoring is required when a
system exceeds the copper AL. To not double count the cost of WQP monitoring for systems
experiencing both a copper ALE and a lead ALE simultaneously, the SafeWater LCR models the costs of
Copper and Lead WQP Monitoring separately and restricts Copper WQP Monitoring to systems with a
copper ALE only and lead 90th percentile not greater than the lead AL of 15 ng/L.
The cost inputs used to estimate WQP costs in response to a copper ALE are identical to those incurred
in response to a lead ALE, as shown in Exhibit B-109, with the following exceptions:
• The likelihood of a system's exceeding the copper ALE, which corresponds to p_copper_ale, is
used in lieu of system's lead 90th percentile level.
• Systems are not assumed to be on reduced WQP distribution system monitoring in response to
a copper ALE, and all systems are assumed to be on a six-month standard monitoring schedule.
Thus, the data inputs associated with reduced monitoring are not applicable. These include the
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reduced number of WQP monitoring samples per distribution sample site (numb_reduced_wqp),
and the likelihood that a system will be on a six-month (p_wqp_six_red), annual
(p_wqp_annual), or triennial schedule (p_wqp_triennial) WQP sampling schedule.
This approach is also used for the final LCRI and is detailed in Chapter 4, Section 4.3.2.3.1.
Exhibit B-109: PWS Copper WQP Monitoring Unit Burden and Cost Estimates
Activity
Unit Burden SafeWater LCR _ „
„ J ... .. Same As Final LCRI?
and/or Cost Data Variable
aa) Collect copper WQP samples from
the distribution system
Same as Exhibit B-105, activity v).
bb) Analyze copper WQP samples from
the distribution system
Same as Exhibit B-105, activity w).
cc) Collect copper WQP samples from
entry points
Same as Exhibit B-105, activity x).
dd) Analyze WQP samples from entry
point copper
Same as Exhibit B-105, activity y).
ee) Report copper WQP sampling data
and compliance with OWQPs
Same as Exhibit B-105, activity z).
Acronyms: LCRI = Lead and Copper Rule Improvements; OWQP = optimal water quality parameter; WQP = water
qualify parameter.
Source: "WQP Analytical Burden and Costs_Final.xlsx."
The SafeWater LCR model cost estimation approach for estimating the cost of copper WQP monitoring
including additional cost inputs required to calculate these costs are identical to those for the LCRR. For
additional detail, refer to Appendix B, Exhibit B-21 in Section B.5.2.3.2.
B.8.1.4 PWS Source Water Monitoring
Under the pre-2021 LCR, water systems were required to conduct source water monitoring when they
exceeded the lead or copper AL. Under the final LCRI, systems can forego source water monitoring if
they previously sampled source water in response to an ALE, the State has not required source water
treatment, and they have not added any new water sources that changes their primacy source type. For
modeling purposes, no system is assumed to have source water treatment.
The EPA has developed system costs for three source water monitoring activities as shown in Exhibit
B-110. The exhibit provides the unit burden and/or cost for each activity. The third column provides the
corresponding SafeWater LCR model data variable in red/italic font. Activities that are conducted by
some States in lieu of the water system are identified in a footnote below the exhibit. The last column
indicates that the unit burden or cost, and the SafeWater LCR model data variable for the pre-2021 LCR
are identical to those used for the final LCRI, as described in Chapter 4, Section 4.3.2.4.2.
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Exhibit B-110: PWS Source Monitoring Burden and Cost Estimates under the Pre-2021 LCR
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
ff) Collect source water
samples
Burden
0.5 hrs/sample
Cost
$1.12/sample for CWSs serving
> 100K
Burden
hrs_source_op
Cost
cost_source_ material1
Yes.
gg) Analyze source water
samples
In-House Burden
0.44 hrs/sample for CWSs
serving > 100K
In-House Cost
$3.92/sample for CWSs serving
> 100K
Commercial Cost
$31.00/sample for CWSs
serving < 100K and NTNCWSs
In-House Burden
hrs_ an alyze_samp_ op1
In-House Cost
cost_source_ an alyze1
Commercial Cost
cost_source
Yes.
hh) Report source water
monitoring results to
the State
1 hour/report
hrs_report_source_op1
Yes.
Acronyms: CWS = community water system; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient
non-community water system.
Sources:
ff), hh): 2022 Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit 15
(USEPA, 2022); "Lead Analytical Burden and Costs_Final.xlsx," worksheets "Source_Collect_Analyze_CWS" and
"Source_Collect_Analyze_NTNCWS."
gg): See file "Lead Analytical Burden and Costs_Final.xlsx," worksheets "Source_Collect_Analyze_CWS" and
"Source_Collect_Analyze_NTNCWS."
Note:
1The burden and costs for these activities are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri,
and South Carolina (ASDWA, 2020a).
Exhibit B-lll shows the SafeWater LCR model cost estimation approach for system source water
monitoring activities including additional cost inputs required to calculate these costs under the pre-201
LCR.
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Exhibit B-lll: PWS Source Water Monitoring Cost Estimation in SafeWater LCR by Activity under the Pre-2021 LCR1
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions
ff) Collect source water samples
The number of EPs per system multiplied by the number of
samples, then multiplied by the total of the labor hours per sample
times the system labor rate, plus the cost per sample.
((numb_ep*numb_st_sample)*((hrs_source_op*rate_op)+cost_so
urce material))
At or
below AL
Model PWSs with surface water sources
and a copper ALE
p_copper_ale
Once per
event
Cost applies
as written to
NTNCWSs.
Model PWSs with ground water sources
and a copper ALE
p_copper_ale
Every three
years per
event
Above AL
Model PWSs with surface water sources
Once a
year
Model PWSs with ground water sources
Every three
years
gg) Analyze source water samples2
There are different labor (burden) and material costs for a sample
analyzed in house and a sample analyzed using a commercial
lab. The in-house analysis costs are calculated using the number
of required samples per EP multiplied by the number of EPs per
system times the percentage of samples analyzed in house and
the system labor rate, plus the material cost of the in-house
analysis per sample. The commercial lab analysis costs are
calculated using the number of required samples per EP
multiplied by the number of EPs per system times the percentage
of samples analyzed commercially times the material cost of the
commercial lab analysis per sample.
Cost applies
as written to
NTNCWSs.
Model PWS with surface water sources
and a copper ALE
p_copper_ale
Once per
event
((pp_lab_samp*(numb_ep*numb_st_sample))*((hrs_analyze_sam
p_op*rate_op)+cost_source_analyze))+((pp_commercial_samp*(
numb ep*numb st sample))*cost source)
At or
below AL
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CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions
Model-PWS with ground water sources and
a copper ALE
p_copper_ale
Every three
years per
event
Above AL
Model PWS with surface water sources
Once a
year
Model PWS with ground water sources
Every three
years
hh) Report source water monitoring results
The total reporting hours per system multiplied by the labor rate.
Model PWS with surface water sources
and a copper ALE
Once per
(hrs_report_source_op*rate_op)
At or
below AL
p_copper_ale
event
Cost applies
as written to
NTNCWSs.
Model PWS with ground water sources and
a copper ALE
p_copper_ale
Every three
years per
event
Above AL
Model PWS with surface water sources
Once a
year
Model PWS with ground water sources
Every three
years
Acronyms: AL = action level; ALE = action level exceedance; CWS = community water system; EP = entry points; NTNCWS = non-transient non-community
water system; PWS = public water system.
Notes:
1The data variables in the exhibit are defined previously in this section with the exception of:
• numb_ep: number of entry points per systems (Chapter 4, Section 4.3.2.2.3).
• numb_st_sample: number of samples per entry point for source water monitoring (Chapter 4, Section 4.3.2.4.1).
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• p_copper_ale: likelihood a system with exceed the copper AL (Chapter 4, Section 4.3.2.3.1).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 The burden and costs to provide sample bottles (cost_source_material) under activity ff), conduct analyses under activity gg), and report results to the system
under activity hh) are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
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B.8.2 PWS Corrosion Control Costs
This section discusses water system activities related to CCT installation (Section B.8.2.1), re-
optimization (Section B.8.2.2), and lead CCT routine activities (Section B.8.2.3) under the pre-2021 LCR
and associated burden and costs. CCT activities that are unique to the pre-2021 LCR are presented in
Section B.8.2.4.
Systems serving 50,000 or fewer people without CCT were not required to conduct CCT steps under the
pre-2021 LCR unless they exceeded the lead and/or copper AL. Systems serving 50,000 or fewer people
that exceeded the lead/copper AL were required to install CCT after making OCCT recommendation to
the State and, if required, to conduct a CCT study.
Systems with CCT under the pre-2021 LCR were required to continue to operate and maintain OCCT,
including maintaining WQPs at or above minimum values or within OWQP ranges designated by the
State. States could modify their determination of OCCT and OWQPs on their own initiative or in
response to a request by a water system or other interested party. Although the pre-2021 LCR did not
explicitly require systems adjust their CCT (i.e., re-optimize CCT), the EPA assumed that systems would
revise their study and re-optimize in response to a subsequent lead ALE. Also, the pre-2021 LCR does not
require responses to individual samples over the action level as under the 2021 LCRR and final LCRI.
Unique to the pre-2021 LCR, a State can allow systems to forgo a study prior to installing or re-
optimizing CCT. The EPA assumes that in these cases, States would require water systems to submit
water quality data.
The derivation and values for baseline pH (baselineph_wocct, baselineph_woph, baselineph_wpo4ph,
baselineph_wph) and baseline P04 dose (baselinepo4dose) are the same as those used to calculate the
CCT costs for the 2021 LCRR and can be found in Chapter 4, Section 4.3.3.
B.8.2.1 CCT Installation
Under the pre-2021 LCR, PWSs without CCT may be required to install CCT if they exceed the lead AL of
15 ng/L. The approach for estimating capital and O&M costs for CCT installation is the same under the
pre-2021 LCR as under the final LCRI, as described in Chapter 4, Section 4.3.3.1.1. The frequency at
which systems exceeded the lead AL is different, however, under the pre-2021 LCR compared to the
final LCRI due to revised sampling requirements for LSL systems and lower lead AL.
The EPA has developed system costs for ancillary activities associated with CCT installation as shown in
Exhibit B-112. The exhibit provides the unit burden and/or cost for the activity. The third column
provides the corresponding SafeWater LCR model data variable in red/italic font. The last column
indicates that the activities, unit burden or cost, and SafeWater LCR data variables are different for the
pre-2021 LCR from those used for the final LCRI. An explanation of the unit burden and cost estimates
for the activities follow the exhibit.
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Exhibit B-112: PWS CCT Installation-Related Unit Burden and Cost Estimates for the Pre-2021
LCR
Activity
Unit Burden and/or
Cost
SafeWaterLCR Data Variable
Same As Final
LCRI?
a) Conduct a CCT study
$7,985 to
$12,256/desktop study;
$58,393/demonstration
study
cost_cct_study_desk;
cost_cct_study_dem
No. See discussion
following the
exhibit.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements.
Source: a): "CCT Study and Review Costs_Final.xlsx."
Note: Activity b), "Install CCT Treatment (PO4, PO4 with post treatment, pH adjustment, or modify pH)" is the same
as the final LCRI as discussed in Chapter 4, Section 4.3.3.1.
a) Conduct a CCT study (cost_cct_study_desk, cost_cct_study_dem). The EPA assumed States will
require a subset of systems to conduct a CCT study prior to CCT installation using the data variable
p_cct_study, as shown in Exhibit B-113. The EPA's assumptions are provided in the notes below the
exhibit.
Exhibit B-113: Likelihood of CCT Study (p_cct_study)
System Size (Population
Served)
Systems with LSLs
Systems without LSLs
A
B
< 1,000
0%
0%
1,001 - 50,000
90%
33%
> 50,000
N/A
N/A
Acronyms: LSL = lead service line.
Source: "CCT Study and Review Costs_Final.xlsx." Based on recommendations in the OCCT Recommendations
Document (USEPA, 2019).
Notes:
A: For systems with LSLs, the EPA's Optimal Corrosion Control Treatment Evaluation Technical
Recommendations for Primacy Agencies and Public Water Systems (i.e., OCCT Recommendations Document)
(USEPA, 2019) recommends that all systems serving 50,000 people or fewer do a study. The EPA recognizes,
however, that very small systems serving 1,000 people or fewer may lack the resources to do a study, even if
they have LSLs. In these cases, the State can designate OCCT without a study. For systems serving 1,001 -
50,000 with LSLs, the EPA assumed that for a small portion (10 percent), treatment is straightforward and
does not require a CCT study. The EPA assumed that large systems serving > 50,000 people conducted CCT
studies already except for CWSs with naturally non-corrosive water that meet the criteria in § 141.81(b)(3),
i.e., b3 systems, and are assumed to never have a lead or copper ALE and thus, will not be required to conduct
a study or install CCT.
B: For systems without LSLs, the EPA assumed that very small systems serving 1,000 people or fewer may lack
the resources to do a study. In these cases, the State can designate OCCT without a study. The OCCT
Recommendations Document recommends that the State use the checklist in Exhibit 4.2 of that document to
determine whether to require a study. The EPA assumed that based on this checklist, State will require 33
percent of systems serving 1,001 - 50,000 without LSLs to conduct a CCT study.
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Systems can perform a "desktop study" based on documented analogous treatments with other
systems of similar size, water chemistry, and distribution system configuration. Alternatively, they
can perform a "demonstration study" using at least one of the following study tools: pipe rig/loop
tests, metal coupon tests, or partial system tests. The EPA assumed that systems required to
conduct a CCT study will use a contractor. Exhibit B-114 provides the data variable, inputs values,
and general approach use to estimate the costs per system to conduct a desktop or demonstration
study.
Exhibit B-114: CCT Study Costs ($2020)
System Size
(Population Served)
Cost per system for contractor to
conduct desktop study
Cost per system for contractor to
conduct demonstration study
cost_cct_study_desk
cost_cct_study_dem
A
B
< 3,300
$7,985
N/A
3,301-50,000
$12,256
$58,393
> 50,000
N/A
N/A
Source: "CCT Study and Review Costs_Final.xlsx."
Notes:
A,B: The EPA used American Society of Civil Engineers (ASCE) and Bureau of Labor Statistics (BLS) as sources for
contractor labor rates, identification of major tasks for each study type, and estimated burden (hours) and costs
for each task to develop cost estimate for systems serving <3,300 people and those serving 3,301 to 50,000
people. The EPA assumed that large systems serving > 50,000 people conducted CCT studies already except for
CWSs with naturally non-corrosive water that meet the criteria in § 141.81(b)(3), i.e., b3 systems, and are assumed
to never have a lead or copper ALE and thus, will not be required to conduct a study or install CCT.
B: The EPA did not develop unit cost estimates for demonstration studies for systems serving < 3,300 people
because demonstration studies are likely cost prohibitive for these systems.
Exhibit B-115 shows the EPA's estimated likelihood of a system doing a demonstration study vs. a
desktop study (p_demo_study) by LSL status and size category with detailed assumptions in the notes.
Note that systems may have conducted a study previously if they exceeded the TL in the past. The EPA
assumed the same probabilities of a demonstration study vs. a desktop study for systems without CCT
that exceed the TL and are required to conduct a CCT study.
Exhibit B-115: Likelihood of Demonstration Study vs. a Desktop Study (p_demo_study)
System Size
(Population Served)
Systems with LSLs
Systems without LSLs
A
B
< 3,300
0%
0%
3,301 - 10,000
50%
10%
10,001 - 50,000
90%
90%
> 50,000
N/A
N/A
Acronyms: LSL = lead service line.
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Source: "CCT Study and Review_Final.xlsx." Based on recommendations in the EPA's Optimal Corrosion Control
Treatment Evaluation Technical Recommendations for Primacy Agencies and Public Water Systems (i.e., OCCT
Recommendations Document) (USEPA, 2019).
A, B. The EPA assumed that no systems serving 3,300 people or fewer will conduct a demonstration study,
regardless of LSL status, due to resource constraints. For systems serving 3,301 to 50,000 people, the EPA used the
checklist in Exhibit 4.4 of the OCCT Recommendations Document to estimate the likelihood that systems would
conduct a demonstration. Based on the checklist, the EPA assumed that 50 percent of systems with LSLs serving
3,301 to 10,000 people would conduct a demonstration study while only 10 percent of these systems without LSLs
would perform the demonstration study. For systems serving 10,001 to 50,000 people, the EPA assumed that most
would do a demonstration study except for a small number (10 percent) that could meet the criteria with a
desktop study. The EPA assumed that large systems serving > 50,000 people conducted CCT studies already except
for CWSs with naturally non-corrosive water that meet the criteria in § 141.81(b)(3), i.e., b3 systems, and are
assumed to never have a lead or copper ALE and thus, will not be required to conduct a study or install CCT.
Exhibit B-116 shows the SafeWater LCR model cost estimation approach for the cost of ancillary system
activities association with CCT installation under the pre-2021 LCR including additional cost inputs
required to calculate these costs.
Exhibit B-116: PWS Ancillary CCT Cost Estimation in SafeWater LCR by Activity under the Pre-
2021 LCR1
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions
a) Conduct a CCT study
Systems will use a contractor for the CCT
study, and the study will either be a
demonstration study or a desktop study.
The cost per study is determined by
multiplying the cost for a demonstration
study by the likelihood that a system will opt
for a demonstration study, plus the cost of a
desktop study multiplied by the likelihood
that a system will not opt instead for a
demonstration study.
Cost applies
as written to
NTNCWSs.
Above AL
Model PWSs without
CCT that conducts a
study on CCT
installation
p_cct_study
One time
((p_demo_study*cost_cct_study_dem)+((1-
p_demo_study)*cost_cct_study_desk))
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-
transient non-community water system; PWS = public water system.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
B.8.2.2 Re-optimization of Existing Corrosion Control Treatment
PWSs may re-optimize CCT in response to an ALE. The re-optimization of CCT at a system requires both
technology-related capital and annual O&M costs as well as a number of ancillary associated costs. The
EPA uses the same approach to estimate the costs for re-optimizing existing CCT under the pre-2021 LCR
Final LCR! Economic Analysis Appendices
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as under the final LCRI, as described in Chapter 4, Section 4.3.3.2.1. The frequency at which systems
exceeded the lead AL is different, however, under the pre-2021 LCR compared to the final LCRI due to
revised sampling requirements for LSL systems.
The EPA has developed system ancillary costs for activities associated with CCT re-optimization as shown
in Exhibit B-117. The exhibit provides the unit burden and costs for each activity. The third column
provides the corresponding SafeWater LCR model data variable in red/italic font. The last column
indicates whether the activity, unit burden or cost, and the SafeWater LCR model data variable are
identical for the pre-2021 LCR to those used for the final LCRI. The assumptions that differ from the
2021 LCRR follow the exhibit.
Exhibit B-117: PWS CCT Ancillary Re-optimization Unit Burden and Cost Estimates under the
Pre-2021 LCR
Activity
Unit Burden and/or Costs
SafeWater LCR Data Variable
Same As Final LCRI?
c) Revise CCT study
$6,148 to $ll,831/system
cost_revise_cct
No. See discussion
following exhibit.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements.
Sources: "CCT Study and Review Costs_Final.xlsx."
Note: Activity d), "Re-optimize existing CCT" was previously discussed in this Section.
c) Revise CCT study (cost_revise_cct). The EPA estimated the following costs for a revised study:
• Systems serving 3,300 or fewer people: $6,148.
• Systems serving 3,301 to 50,000 people: $8,756.
• Systems serving more than 50,000 people: $11,831.
See the derivation file, "CCT Study and Review Costs_Final.xlsx" for additional detail. For some systems
serving 50,000 or fewer people with CCT, the EPA assumes that the State will designate re-optimized
CCT without requiring them to revise their study. The EPA used recommendations in the OCCT
Recommendations Document (USEPA, 2019) to estimate the likelihood of a CCT study (p_cct_study)
from Section B.8.2.1.
Exhibit B-118 provides the SafeWater LCR model costing approach for estimating the cost for re-
optimization of CCT including additional cost inputs that are required to calculate these costs under the
pre-2021 LCR.
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Exhibit B-118: PWS CCT Ancillary Re-optimization Cost Estimation in SafeWater LCR by
Activity under the Pre-2021 LCR1
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply
to a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions
c) Revise CCT study
Material cost per system for the marginal
contractor cost, with the difference
between desk-top and demonstration
study reflected in the stratification of the
data by system size.
cost_revise_cct
Cost applies as
written to
NTNCWSs.
Above AL
Model PWS re-
optimizing CCT
p_cct_study
One time
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-
transient non-community water system; PWS = public water system.
Note:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• p_cct_study: Likelihood a State will require a CCT study (Section B.8.2.1).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
B.8.2.3 Lead CCT Routine Costs
The EPA has developed system costs for routine activities associated with CCT under the pre-2021 LCR,
as shown in Exhibit B-119. The exhibit provides the unit burden and costs for each activity. The third
column provides the corresponding SafeWater LCR model data variable in red/italic font. The last
column indicates whether the activity, unit burden or cost, and the SafeWater LCR model data variable
for the pre-2021 LCR are identical to those used for the LCRI, as described in Chapter 4, Section 4.3.3.4.
Gray shaded rows indicate new requirements that apply only to the final LCRI.
Exhibit B-119: PWS Lead CCT Routine Unit Burden and Cost Estimates under the Pre-2021 LCR
Activity
Unit Burden and/or
Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
1) Review CCT guidance
N/A
hrs_rev_cct_op
N/A under the pre-
2021 LCR.
m) Provide WQP data to
N/A
hrs_sanit_surv_op
N/A under the pre-
State and discuss during
2021 LCR.
sanitary survey
n) Notify and consult with
N/A for systems on
hrs_coop_source_chng_rout_op
N/A under the pre-
State on required actions
standard tap
2021 LCR.
in response to source
monitoring
water change
6 to 12 hrs/system on
reduced tap monitoring
hrs_coop_source_chng_red_op
Yes.
o) Notify and consult with
46 to 84 hrs/system on
hrs_coop_ treat_ chn g_ op
Yes.
State on required actions
reduced tap monitoring
in response to treatment
change
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Acronyms: CCT = corrosion control treatment; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; WQP = water quality parameter.
Sources:
I), m): "CCT Study and Review Costs_Final.xlsx."
n): "Likelihood_SourceChange_Final.xlsx."
0): "Likelihood_TreatmentChange_Final.xlsx."
Notes:
1), m): Under the pre-2021 LCR, consultation with the State prior to making a source or treatment change applied
only to those systems on a reduced monitoring schedule, i.e., monitoring less frequently than semi-annually. The
final LCRI adds a requirement for this consultation to also apply to system monitoring semi-annually (see Chapter
4, Section 4.3.3.4, activities n) and o) for additional detail.
Exhibit B-120 shows the SafeWater LCR model cost estimation approach for the cost of ancillary system
activities association with CCT installation including additional cost inputs required to calculate these
costs. The exhibit also indicates in gray shaded rows which final LCRI activities from Chapter 4, Exhibit 4-
71 do not apply under the pre-2021 LCR.
Exhibit B-120: PWS Lead CCT Routine Cost Estimation in SafeWater LCR by Activity1
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions
1) Review CCT guidance
N/A under the pre-2021 LCR.
m) Provide WQP data to the State and discuss during sanitary survey
N/A under the pre-2021 LCR.
n) Notify and consult with State in response to a change in source water2
The total hours per system multiplied by the
system labor rate.
(hrs_coop_source_chng_red_op*rate_op)
Cost applies
as written to
NTNCWSs.
All
Model PWS that is on
reduced tap sampling
with a change in source
water
(p_tap_annual +
p_tap_triennial +
p_tap_nine) *
p source chng
Once a
year
o) Notify and consult with State in response to a change in water treatment
The total hours per system multiplied by the
system labor rate.
(hrs_coop_treat_chng_op*rate_op)
Cost applies
as written to
NTNCWSs.
All
Model PWS that is on
reduced tap sampling
with a change in source
water
(p_tap_annual +
p_tap_triennial +
p_tap_nine) *
p source chng
Once per
event
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCR = Lead and Copper Rule; LCRR
= Lead and Copper Rule revisions; NTNCWS = non-transient non-community water system; PWS = public water
system; WQP = water quality parameter.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
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• p_tap_annual, p_tap_triennial, and p_tap_nine: Likelihood a system will qualify to collect lead tap
samples at an annual, triennial, and nine-year frequency, respectively (Chapter 3, Section 3.3.7.1).
• p_source_chng\ Likelihood that a system will change sources in a given year (Chapter 3, Section 3.3.9.1).
• p_treat_chng: Likelihood that a system will change treatment in a given year (Chapter 3, Section 3.3.9.3).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
B.8.2.4 CCTActivities Unique to the Pre-2021 LCR
Unique to the pre-2021 LCR, a State can allow systems to forgo a study prior to installing or re-
optimizing CCT. The EPA assumes that in these cases, States would require water systems to submit
water quality data. Exhibit B-121 shows this activity and the unit burden. The third column provides the
corresponding SafeWater LCR model data variable in red/italic font. The last column indicates that the
activity and unit burden are unique to the pre-2021 LCR. The assumptions for estimating the burden
follow the exhibit.
Exhibit B-121: PWS CCT Costs Unique to the Pre-2021 LCR
Activity
Unit Burden and/or
Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
p) Submit water quality
data to determine if CCT
study is needed
4 to 8 hrs/system
hrs_submit_ wq_data_op
No. See discussion
following the
exhibit.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements.
Source: "CCT Study and Review Costs_Final.xlsx."
p) Submit water quality data to determine if CCT study is needed (hrs_submit_ wq_data_op). States
can allow systems serving 50,000 or fewer people without CCT to forego a study prior to installing or
re-optimizing CCT. The EPA assumed for those systems that are not required to conduct a study, the
State would require systems to submit water quality data to allow the State to determine the type
of CCT to be installed. The EPA assumed systems would use the electronic templates provided with
the Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primacy
Agencies and Public Water Systems (hereafter referred to as the "OCCT Recommendations
Document") (USEPA, 2019) and require 4 hours for systems serving 3,300 or fewer people and 8
hours for those serving 3,301 to 50,000 people to provide these data. Note that under the final LCRI,
the EPA assumed this activity would not apply because all systems would conduct a study prior to
installing CCT as opposed to submitting water quality data. The EPA multiplied
hrs_submit_wq_data_op by 1 minus p_cct_study to determine the burden for systems to submit
water quality data in lieu of a CCT study.
For systems with CCT, States can also allow systems serving 50,000 or fewer people to forego
conducting a revised CCT study prior to re-optimizing CCT. The EPA assumed for those systems that
are not required to conduct a study, the State would require systems to submit water quality data to
allow the State to determine needed CCT modifications that constitute re-optimized CCT. The same
assumptions are used as for those systems without CCT.
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Exhibit B-122 shows the SafeWater LCR model cost estimation approach for the cost of CCT activities
unique to the pre-2021 LCR including additional cost inputs required to calculate these costs.
Exhibit B-122: PWS CCT Cost Estimation for Activities Unique to the Pre-2021 LCR in
SafeWater LCR1
CWS Cost Per Activity
NTNCWS
Cost Per
Activity
Conditions for Cost to Apply to
a Model PWS
Frequency
of Activity
Lead 90th
- Range
Other Conditions
p) Submit water quality data to determine if CCT study revision is needed
The hours per system multiplied by the
system labor rate.
(hrs_submit_wq_data_op*rate_op)
Cost applies
as written to
NTNCWSs.
Above AL
Model PWS installing
CCT
Model PWS re-
optimizing CCT serving
< 50,000 people
One time
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; LCRR = Lead and
Copper Rule revisions; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of: rate_op: PWS hourly
labor rate (Chapter 3, Section 3.3.11.1).
B.8.3 PWS Lead Service Line Replacement-Related Costs
Under the pre-2021 LCR, water systems with LSLs that continued to exceed the lead AL were required to
annually replace at least seven percent of the initial number of LSLs in their distribution system. Systems
could stop LSLR when the system no longer exceeded the lead AL for two consecutive six-month
monitoring periods.
This section is divided into three subsections:
• B.8.3.1: Lead Service Line Replacements
• B.8.3.2: Ancillary Lead Service Line Replacements
• B.8.3.3: Ancillary Service Line Replacement Activities Unique to the Pre-2021 LCR
Note that the final LCRI greatly expands the requirements associated with SLR, including developing an
SL inventory and plan, additional customer outreach, and customer-initiated SL replacements that
correspond to activities a) through I). These activities do not apply to the pre-2021 LCR and, thus, are
not discussed in the section. For additional detail, see Chapter 4, Section 4.3.4.
B.8.3.1 Lead Service Line Replacements
This section summarizes the EPA's cost estimates for replacement of LSLs under the pre-2021 LCR.
Under that rule, systems were required to replace LSLs when they continue to exceed the lead AL after
installing CCT or source water treatment, whichever occurred later. Systems can discontinue LSLR after
they no longer exceed the lead AL for two consecutive, six-month monitoring periods. Under the final
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LCRI, water systems would be required to fully replace all lead and GRR service lines within 10 years
unless the State has set a shorter schedule or approved a deferred rate.
The estimated percent of systems that exceed the lead AL of 15 ng/L is presented in Exhibit B-123. The
exhibit presents separate estimates for systems with and without LSLs and a low and high estimate to
represent uncertainty in the estimate.
Exhibit B-123: Number and Percent of CWSs by Lead 90th Percentile Classification under the
Pre-2021 LCR
Category
No LSLs
Has LSLs
Low Estimate
P90 < 5 ng/L
88.5%
74.6%
5 ng/L < P90 < 10 ng/L
7.1%
18.0%
10 ng/L < P90 < 12 ng/L
1.0%
2.8%
12 ng/L < P90 < 15 ng/L
1.0%
2.2%
P90 >15 ng/L
2.3%
2.4%
High Estimate
P90 < 5 ng/L
79.6%
60.0%
5 ng/L < P90 < 10 ng/L
11.7%
23.2%
10 ng/L < P90 < 12 ng/L
2.0%
4.9%
12 ng/L < P90 < 15 ng/L
1.9%
4.0%
P90 >15 ng/L
4.8%
7.9%
Acronyms: LSL = lead service line; P90 = lead 90th percentile level.
Source: Initial P90 Categorization_LCR_Final.xlsx.
Note: The percentages have changed slightly from those presented in the proposed LCRI EA because in this final
LCRI EA, they are based on additional systems with known LSL status from the DWINSA supplement.
Under the pre-2021 LCR, the following types of replacements can count toward the annual 7 percent
replacement rate:
• Utility-side LSLR [i.e., Partial LSLR): The pre-2021 LCR only required systems to replace the
portion of the LSL that they owned. Often, the system's ownership stops at the homeowner's
property line, and the homeowner's portion is not required to be replaced.
• Full LSLR: Full LSLR is when the entire LSL is replaced (i.e., the utility-side portion and the
customer-owned portion, if applicable).
• "Test out" LSLs: An LSL can "test out" (i.e., be considered replaced) if all samples from the LSL
are at or below the lead AL. "Test out" LSLs do not have to be physically replaced.
Exhibit B-124 provides the estimated likelihood of these three types of replacements.
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Exhibit B-124: Likelihood of Type of Replacement
System Size
(Population
Served)
Estimated
Percent of
Systems that
Select Test Out
Option
Estimated
Percent of LSLs
that Meets
Criteria for Test
Out
Estimated
Percent of
LSLs Replaced
through the
Testing
Estimated
Percent of LSLR
that are Utility-
Side Only
Estimated
Percent of LSLR
that are Full
(pp_lcr_test)
(pp_lcr_test_yes)
(pp_lslr_partial)
(pp_lcr_full)
A
B
C=A*B
D = 72% -
(72%*C)
E = 28%-
(28%*C)
<10,000
0%
0%
0%
72%
28%
>10,000
25%
80%
20%
58%
22%
Acronyms: LSL = lead service line; LSLR = lead service line replacement.
Notes:
A: The EPA assumes that 25 percent of CWSs serving more than 10,000 people with CCT that are triggered into
LSLR would test their LSLs before replacing them to determine if any meet the test out criteria. The EPA only has
documentation indicating that larger systems conduct a mix of test outs and replacements when required to
replace LSLs. Thus, the EPA assumed that zero percent of CWSs serving < 10,000 will elect to use the test out
criteria.
B: The EPA assumed that the percent of LSLs that meet the test out criteria under the pre-2021 LCR is 80 percent
for systems serving > 10,000 people based on success rate from DC Water (76 percent) and Fort Wayne (89.2
percent). The Economic and Supporting Analysis: Short-Term Regulatory Changes to the Lead and Copper Rule
indicated a test out success rate for DC Water of 76 percent but did not indicate the number of LSL test-out
samples collected (USEPA, 2007). Fort Wayne took 1,975 sample and 213 or 10.8 percent were above 15 ng/L, with
the remaining 89.2 percent <15 ng/L.
D & E: A survey by Black & Veatch, which targeted 300 water systems and had a response rate of 41 systems,
indicated 72 percent of replacements involved removal of the utility side only. The remaining 28 percent involved
removal of both the public and private side. Results were presented at EPA's LSLR workshop in 2004. For more
information on the survey, see Strategies to Obtain Customer Acceptance of Complete Lead Service Line
Replacement (AWWA, 2005).
Under the pre-2021 LCR, the EPA assumed for modeling purposes that CWSs will incur costs to replace
only their portion of the line (i.e., partial replacements). The cost for the customer side is assigned as a
household cost. The SafeWater LCR model tracks the percent of LSLR that are full and adjusts the
inventory for each year in the 35-year analysis period. NTNCWSs are assumed to own the entire service
line and to conduct full replacements.
Exhibit B-125 shows the unit costs for partial and full replacements. Additional detail is also provided in
Appendix A. The third column provides the corresponding SafeWater LCR model data variable in
red/italic font. The last column indicates whether the activity, unit burden or cost, and the SafeWater
LCR model data variable are identical to those used for the pre-2021 LCR as for the final LCRI, as
described in Chapter 4, Section 4.3.4.3. The assumptions that differ from the 2021 LCRR follow the
exhibit. The gray shaded row indicates an activity that does not apply under the pre-2021 LCR.
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Exhibit B-125: PWS LSLR Cost Estimates under the Pre-2021 LCR
Activity
Cost Estimate Range
SafeWaterLCR Data Variable
Same As Final
LCRI?
1) System replaces
lead or GRR service
lines
N/A
cost_lslr_lsl_reg_mand_pws;
cost_lslr_partial_reg_pws;
cost Islr gal prev Isl reg pws
N/A under the
pre-2021 LCR.
m) Systems replace
their portion of the
LSL
CWS
Partial: $1,920-$5,400
NTNCWS
Full: $6,507 - $8,519
CWS
cost_lslr_partial_reg_pws
NTNCWS
cost_lslr_lsl_reg_mand_pws
No. See
explanation
following this
exhibit.
n) Households replace
privately-owned
portion of the LSL
CWS
Partial: $1,920-$5,400
cost_lslr_partial_reg_pws
No. See
explanation
following this
exhibit.
Source: "LSLR Unit Cost_Final.xlsx."
Acronyms: CWS = community water system; GRR = galvanized requiring replacement; LCR = Lead and Copper Rule;
LCRI = Lead and Copper Rule Improvements; LSL= lead service lines; NTNCWS = non-transient non-community
water system.
Notes:
m): Reflects the cost of physical replacement only. As previously discussed in this section, under the pre-2021 LCR,
systems can also replace their LSL through a non-physical means using the "test out" provision. Under the pre-
2021 LCR and final LCRI, NTNCWSs were assumed to own and replace the entire LSLs. The same data variable and
cost input are used for NTNCWSs under both rules.
n): Under the pre-2021 LCR, households were assumed to incur the cost for the customer-owned portion to
achieve full LSLR.
m) Systems replace their portion of the LSL (cost_lslr_partial_reg_pws). The EPA has developed low
and high unit cost estimates based on reported project data in the 7th DWINSA for full replacements,
partial replacements, and replacements of GRR service lines. Low and high unit cost estimates are
based on the 25th and 75th percentile data from 33 DWINSA reported projects. The detailed
methodology for estimating the SLR unit costs is provided in Appendix A, Section A.2. For the pre-
2021 LCR, water systems are not required to replace GRR.
The EPA applied the low and high cost estimates for partial replacement of $1,920 - $5,400 to CWSs
(cost_lslr_partial_reg_pws) and the low and high cost estimates for full replacements of $6,507 -
$8,519 for NTNCWSs (cost_lslr_lsl_reg_mand_pws) because in general NTNCWSs own their entire
service line. In addition to the unit cost and likelihood of the type of LSLR under each program, the
EPA needs the total number of LSLs replaced each year (num_lsl_replace) to estimate LSLR costs
under the pre-2021 LCR. The number of LSLs replaced is calculated as the number of LSLs for a
system multiplied by the replacement rate per year. The EPA assumed a 7 percent replacement rate
as required by the pre-2021 LCR. The EPA assumed that LSLR under the pre-2021 LCR will last an
average of three years based on an analysis of SDWIS/Fed data for 103 CWSs (see
LSLR_Time_Span_Analysis_CWS_Final.xlsx").
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n) Households replaces their portion of the LSL (cost_lslr_partial_reg_pws). Under the pre-2021 LCR,
the EPA assumed households would pay for the replacement of their portion of the LSL and would
incur a low or high-end cost of $1,920 - $5,400.
Exhibit B-126 provides the SafeWater LCR model cost estimation approach for systems and households
to replace LSLs including additional cost inputs required to calculate these costs.
Exhibit B-126: Lead Service Line Replacement Cost Estimation in SafeWater LCR by Activity1,2
System Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to
Apply to a Model PWS
Frequency
of Activity
Lead 90th -
Range
Other
Conditions
1) System replaces lead or GRR service lines
N/A under the pre-2021 LCR.
m) Systems replace their portion of the LSL
The sum of the number of lines replaced
via the different replacement options
multiplied by the costs per type of
replacement. Replacement options
include full LSLR and partial replacements
on the system owned side of the LSL.
The sum of the
number of lines
replaced via the
different
replacement
options multiplied
by the costs per
type of
replacement.
Above AL
Model PWS
subject to the
LSLR program
Once a year
(num_lslr_lsl_replace+num_lslr_partial_re
place)*cost_lslr_partial_reg_pws)
num_lslr_lsl_replac
e *cost_lslr_lsl_reg_
mand pws
n) Households replace privately-owned portion of the LSL
The number of full lead line replacements
multiplied by the per line cost to
households. The conditional likelihoods in
this equation account for the removal of
tested out lines from the inventory. The
EPA assumes that customers always pay
for the part of the LSL belonging to them
when an LSL is fully or partially replaced.
Customers do not pay for
pigtail/gooseneck replacements in the
model.
Cost does not
apply to
NTNCWSs.
Above AL
Households
within Model
PWSs subject
to the LSLR
Program
Once a year
(num_lslr_lsl_replace*
cost Islr partial req pws)
Acronyms: AL = action level; CWS = community water system; GRR = galvanized requiring replacement; LCR = Lead
and Copper Rule; LSL = lead service line; LSLR = lead service line replacement; NTNCWS = non-transient non-
community water system; PWS = public water system;.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• num_lslr_lsl_replace\ Number of LSLs replaced per year that is calculated in the SafeWater LCR model.
2 Systems can discontinue these activities if they no longer exceed the lead ALfor two consecutive, six-month
monitoring periods.
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B.8.3.2 Ancillary Lead Service Line Replacement Activities
The EPA developed system costs for ancillary activities associated with LSLR under the pre-2021 LCR, as
shown in Exhibit B-127. The exhibit provides the unit burden and cost for each activity. The third column
provides the corresponding SafeWater LCR model data variable in red/italic font. Activities that are
conducted by some States in lieu of the water system are identified in the exhibit and further noted
below the exhibit. The last column indicates if the activity, unit burden or cost, and the SafeWater LCR
model data variable for the pre-2021 LCR are identical to those used for the final LCRI, as described in
Chapter 4, Section 4.3.4.4. The assumptions that differ from the LCRI follow the exhibit. Gray shaded
rows indicate requirements that apply to the final LCRI. Those activities that are unique to the pre-2021
LCR are discussed in Section B.8.3.3.
Exhibit B-127: PWS LSL Replacement Ancillary Unit Burden and Cost Estimates under the Pre-
2021 LCR
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same as Final
LCRI?
o) Contact customers
and conduct site
visits prior to service
line replacement
Burden per replaced
service line
1.70 to 2.07 hrs
Cost per replaced service
line
$11.64 to $16.13
Burden
hrs_replaced_ lsl_ con tact_ op
Cost
cost_replaced_lsl_contact
Yes.1
p) Deliver filters and 6
months of
replacement
cartridges at time of
SLR
N/A
cost_filter_hh
N/A under the
pre-2021 LCR.
q) Collect tap sample
post-service line
replacement
Burden per sample
CWSs: 0.9 to 1.2 hrs
Cost per sample per CWS
Travel: $5.75 to $10.24
Bottle: $0 to $2.85
Burden
hrs_ collect_lsl_plslr_ op
Cost
cost_pickup_samp
cost_lsl_samp2
No. See
explanation
following the
exhibit.
r) Analyze post-service
line replacement tap
sample
In-house Analysis (CWSs >
lOOKonlv)
Burden: 0.44 hrs/sample
Cost: $3.92
Commercial Analyses
$32.20/sample
In-house Analvs/s
hrs_ an alyze_lsl_plslr_op2
cost_lab_lsl_plslr2
Commercial Analysis
cost_commercial_lsl_plslr2
No. See
explanation
following the
exhibit.
s) Inform customers of
tap sample result
Burden
CWSs: 0.05 -0.11
hrs/sample
Cost
CWSs: $0.72/sample
Burden
hrs_inform_samp_op
Cost
cost_cust_plslr
No. See
explanation
following the
exhibit.
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Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same as Final
LCRI?
t) Submit annual report
on service line
replacement program
to State
1 to 8 hrs/CWS
1 hr/NTNCWS
hrs_ report_ lcr_op
Yes4
Acronyms: CWS = community water system; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; SLR = service line replacement.
Sources:
p), q) & u): "LSLR Ancillary Costs_Final.xlsx."
r)-t):" Lead Analytical Burden and Costs_Final.xlsx."
Notes:
1 This input corresponds to activity m) in Chapter 4, Section 4.3.4.4 for the final LCRI.
2 NTNCWSs are assumed to own and control their entire LSL and will fully replace the LSL. In addition, they are not
expected to contact customers prior to replacement to coordinate any efforts. In addition, under the pre-2021
LCR, monitoring after a service line replacement only is required after partial LSLR. Therefore, the only activity that
applies to NTNCWSs in this exhibit under the pre-2021 LCR is submitting an annual report (hrs_report_lcr_op).
3The burden and costs for these activities are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri,
and South Carolina (ASDWA, 2020a).
4 Although the report content under the annual LSLR reports differs between the pre-2021 LCR and final LCRI, the
EPA assumed systems would incur a similar burden to prepare this report and thus, used the same data variable
name and input for both rules. For the final LCRI, this input corresponds to activity r) in Chapter 4, Section 4.3.4.4.
q) Collect tap samples after post-service line replacement (hrs_collect_lsl_plslr_op,
cost_pickup_samp, cost_lsl_samp). Under the pre-2021 LCR, systems must offer to collect a lead
tap sample at each home for which a partial replacement (i.e., utility-side only) was conducted. The
EPA assumed all residents would agree to this testing. The EPA also assumed no NTNCWS would
conduct a partial LSLR because all NTNCWSs would own and replace the entire service line. Thus,
this sampling requirement would not apply to NTNCWSs. The burden and costs for this activity are
different from the tap sampling requirements discussed in Section B.8.1.1.2 because the system
collects the sample after replacement as opposed to the tap sampling program in which the
customer collects the sample. Exhibit B-128 and Exhibit B-129 provide the estimated CWS burden
and cost to collect these samples.
Exhibit B-128: CWS Unit Burden for LSLR-Related Sample Collection
System Size
(Population Served)
Burden (hrs/Sample)
Round-trip travel to
customer's home
Sample Collection
Burden
Total Sample
Collection Burden
hrs_collect_lsl_plslr_op
A
B
C = A + B
<100,000
0.40
0.5
0.9
100,001-1,000,000
0.51
0.5
1.0
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System Size
(Population Served)
Burden (hrs/Sample)
Round-trip travel to
customer's home
Sample Collection
Burden
Total Sample
Collection Burden
hrs_collect_lsl_plslr_op
A
B
C = A + B
>1,000,000
0.71
0.5
1.2
Source: "Lead Analytical Burden and Costs_Final.xlsx," worksheet, "LSLR_CollectAnaly_CWS_LCRR_LCRI."
Notes:
A: Based on census data and zip codes from the 2006 Community Water System Survey, the EPA assumed the
following one-way driving distances for CWSs: 5.0 miles serving < 100,000 people, 6.4 miles serving 100,001 -
1M, and 8.9 miles for > 1M. These distances were doubled to estimate roundtrip mileage. See file, "Estimated
Driving Distance_Final.xlsx for additional detail on how these estimates were derived. The EPA assumed an
average speed of 25 miles per hour.
B: The EPA assumed the same collection burden following LSLR as for source water sample collection, which is
based on the 2022 Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal),
Exhibit 15, Average Labor Hrs. for Collection (Per Sample) (USEPA, 2022).
C: Under the final LCRI, the variable name hrs_collect_lsl_lslr_op is used.
Exhibit B-129: CWS Non-labor Unit Cost to Collect Post-SLR Tap Sample
System Size
(Population Served)
Cost (hrs/Sample)
Round-trip travel to customer's
home
Bottle Cost
cost_pickup_samp
cost_other_lt_samp
A
B
<100,000
$5.75
$0.00
100,001-1,000,000
$7.36
$2.85
>1,000,000
$10.24
$2.85
Source: "Lead Analytical Burden and Costs_Final.xlsx," worksheet, "LSLR_CollectAnaly_CWS_LCRR_LCRI."
Notes:
A: Based on census data and zip codes from the 2006 Community Water System Survey, assumed the
following one-way driving distances for CWSs: 5.0 miles serving < 100,000 people, 6.4 miles serving 100,001 -
1M, and 8.9 miles for > 1M. These distances were doubled to estimate roundtrip mileage. See file, "Estimated
Driving Distance_Final.xlsx for additional detail on how these estimates were derived. The EPA assumed an
average speed of 25 miles per hour and used the Federal reimbursement rate of $0,575 (2020 mileage rate).
B: Bottles are included as part of the commercial laboratory fee. Only CWSs serving more than 100,000 people
are assumed to conduct analyses in-house for lead. For a detailed discussion of the assumptions used to
estimate bottle costs, see file "Lead Analytical Burden and Costs_Final.xlsx," worksheet, "Sample
Kit_Bottle_$-"
Under the pre-2021 LCR, systems will incur the same burden and cost to collect one sample
following replacement of each partial or full LSL. In addition, the requirement applies to both CWSs
and NTNCWSs.
r) Analyze post-service line replacement tap samples (hrs_analyze_lsl_plslr_op, cost_lab_lsl_plslr,
cost_commercial_lsl_plslr). The EPA assumed CWSs serving more than 100,000 people will conduct
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B-236
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lead analyses in-house and require 0.44 hours per sample based on estimates provided by three
laboratories (hrs_analyze_lsl_plslr_op). These systems will also incur consumable costs of $3.92 per
sample based on information from three vendors (cost_lab_lsl_plslr). The remaining CWSs and all
NTNCWSs are assumed to use commercial laboratories and incur a cost of $23.50 per lead sample
based on quotes from seven laboratories plus a per sample shipping cost of $8.70 for a total per
sample cost of $32.20 (cost_commercial_lsl_plslr). Note that these cost are the same as those
incurred by CWSs under the final LCRI for systems analyzing samples following service line
replacement but the variable names are different, as shown in Exhibit B-119. In addition, under the
final LCRI, systems must collect a lead tap sample following all service line replacements. Thus, these
costs also apply to NTNCWSs. See Chapter 4, Section 4.3.4.4, activity p) for additional detail.
s) Inform customers of tap sample results (hrs_inform_samp_op, cost_cust_plslr). CWSs must notify
their customers of their lead analytical results in samples collected in response to a partial LSLR. The
EPA assumed CWSs would incur the same burden and cost to provide this notification as estimated
under the final LCRI replacement program. Note that under the final LCRI, the variable names are
different and the notifications also apply to NTNCWSs. See Chapter 4, Section 4.3.4.4, activity q) for
additional detail.
Exhibit B-130 provides the SafeWater LCR model cost estimation approach for PWS ancillary LSLR
activities including additional cost inputs that are required to calculate these costs. The gray shaded row
indicates an activity that does not apply to the pre-2021 LCR.
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Exhibit B-130: Lead Service Line Replacement Ancillary Cost Estimation in SafeWater LCR by Activity under the Pre-2021 LCR1,2
CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply
to a Model PWS
Frequency of
Activity
Lead 90th -
Range
Other Conditions
o) Contact customers and conduct site visits prior to service line replacement
The number of full lines replaced multiplied by the total of the hours per line
times the system labor rate, plus the material cost.
The pre-2021 LCR allowed systems to "test out" an LSL instead of physically
replacing it. The test out lines count towards the replacement target but
because they do not result in the same benefits as the removal of an LSL
they are not included in the calculation of lead lines replaced
(num_lsl_replace). The equation is adjusted to reflect this using pp_lcr_test
and pp_lcr_test_yes.
Cost does not apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
(num_lsl_replace*((hrs_replaced_lsl_contact_op*rate_op)+cost_replaced_LS
L contact))
p) Deliver filters and 6 months of replacement cartridges at time of SLR
N/A under the pre-2021 LCR.
q) Collect lead tap samples post-service line replacement23
The samples for a system's partial LSL replacements multiplied by the total of
the material cost per sample, plus the hours per sample times the system
labor rate.
(num_lslr_partial_replace*numb_samp_plslr)*(cost_lsl_samp+cost_pickup_s
amp+(hrs collect Isl plslr op*rate op))
Cost does not apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
r) Analyze post-service line replacement2
There are different labor (burden) and material costs for a sample analyzed
in house and a sample analyzed using a commercial lab. The in-house
analysis costs are calculated using the number of required samples per
replaced lead line multiplied by the number of replaced lead lines and the
percentage of samples analyzed in house times the system labor rate, plus
the material cost of the in-house analysis per sample. The commercial lab
analysis costs are calculated using the number of required samples per
system multiplied by the percentage of samples analyzed in a commercial lab
times the material cost of the commercial lab analysis per sample.
Cost does not apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
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CWS Cost Per Activity
NTNCWS Cost Per
Activity
Conditions for Cost to Apply
to a Model PWS
Frequency of
Activity
Lead 90th -
Range
Other Conditions
(((num_lslr_partial_replace*numb_samp_plslr)*pp_lab_samp)*((hrs_analyze_
lsl_plslr_op*rate_op)+cost_lab_lsl_plslr))+(((num_lslr_partial_replace*numb_
samp plslr)*pp commercial samp)*cost commercial Isl plslr)
s) Inform customers of results tap sample results2
The samples for a system's partial LSLRs multiplied by the material cost, the
hours per sample, and the system labor rate.
(num_lslr_partial_replace*numb_samp_plslr)*((hrs_inform_samp_op*rate_op
)+cost cust plslr)
Cost does not apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
t) Submit annual report on service line replacement program to State
The estimated total reporting hours per system multiplied by the system labor
rate.
(hrs_report_lcr_op*rate_op)
Cost applies as written
to NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
Acronyms: AL = action level; CWS = community water system; LCR = Lead and Copper Rule; LSL = lead service line; LSLR = lead service line replacement;
NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
1 The data variables in this exhibit are defined previously in Section B.5.4.4 with the exception of:
• num_lslr_partial_replace: Number of partial LSLs replaced per year that is calculated in the SafeWater LCR model.
• numb_samp_plslr\ Number of samples collected following partial LSLR. Assumed to be one per replacement.
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 These activities apply after systems (assumed to be CWSs only) conduct a partial LSLR. The system can discontinue these activities after it no longer exceeds
the lead AL of 15 ng/L for two consecutive, six-month monitoring periods.
3The burden and costs to provide sample bottles (cost_lsl_samp) under activity q) and conduct analyses under activity r) are incurred by the State in Arkansas,
Louisiana, Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
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B.8.3.3 Ancillary Service Line Replacement Activities Unique to the Pre-2021 LCR
Under the pre-2021 LCR systems will incur ancillary activities associated with LSLR that do not apply to
the final LCRI, as shown in Exhibit B-131. The activities in this exhibit apply only to CWSs because,
NTNCWSs are assumed to fully replace their LSLs and are not expected to contact customers prior to
replacement to coordinate any efforts.
Exhibit B-131: PWS LSL Replacement Ancillary Unit Burden and Cost Estimates under the Pre-
2021 LCR1
Activity
Unit Burden and/or Cost
SafeWater LCR Data
Variable
Same as Final
LCRI?
u) Develop information that
asks if customers want their
LSL replaced (one-time)
7 hrs/CWS subject to
mandatory LSLR
hrs_lcr_lslr_ out_op
No. Unique to
the pre-2021
LCR.
v) Deliver information that
asks if customers want their
LSL replaced (one-time)
Burden
0.0025 hrs per delivery
Cost
$0,703 per delivery
Burden
hrs Icr Islr out deliv op
Cost
cost Icr Islr out
No. Unique to
the pre-2021
LCR.
w) Develop information that
goes to customers prior to
partial LSLR (one-time)
7 hrs/CWS subject to
mandatory LSLR
hrs_lcr_lslr_prior_op
No. Unique to
the pre-2021
LCR.
x) Deliver prior notification for
partial LSLRs
Burden
0.5 hrs per delivery
Cost
$0,703 per delivery
Burden
hrs_prior_notif_op
Cost
cost_prior_notif
No. Unique to
the pre-2021
LCR.
y) Submit documentation that
partial LSLR requirements
were fulfilled
0.5 hrs
hrs_report_plslr_op
No. Unique to
the pre-2021
LCR.
z) Collect samples for test out
provision
Burden per sample for
CWSs
0.9 to 1.2 hrs
Cost per sample for
CWSs
Travel: $5.75 to $10.24
Bottle: $0 to $2.85
Burden
hrs_collect_lsl_plslr_op
Cost
cost_pickup_samp
cost_lsl_samp2
No. Unique to
the pre-2021
LCR.
aa) Analyze lead tap samples for
test out provision
In-house Analysis (CWSs
> lOOKonlv)
Burden: 0.44 hrs/sample
Cost: $3.92/sample
Commercial Analysis
$32.30/ sample
In-house Analysis
hrs_an alyze_ lsl_plslr_ op2
cost_lab_lsl_plslr2
Commercial Analysis
cost_commercial_lsl_plslr2
No. Unique to
the pre-2021
LCR.
Acronyms: CWS = community water system; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; LSL= lead service lines; LSLR = lead service line replacement; NTNCWS = non-transient non-
community water system.
Sources:
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u) -y): "LSL Ancillary Costs_Final.xlsx."
z) & aa):" Lead Analytical Burden and Costs_Final.xlsx."
Notes:
1The activities in this exhibit apply only to CWSs because, NTNCWSs are assumed to fully replace their LSLs and are
not expected to contact customers prior to replacement to coordinate any efforts.
2The burden and costs for these activities are incurred by the State in Arkansas, Louisiana, Mississippi, Missouri,
and South Carolina (ASDWA, 2020a).
u) Develop information that asks if customers want their LSL replaced (hrs_lcr_lslr_out_op). CWSs
subject to mandatory LSLR will incur burden to ask their customers if they want their portion of the
LSL replaced prior to initiating replacement of the system-side. The EPA estimated systems will incur
a burden of 7 hours based on the 2022 Disinfectants/Disinfection Byproducts, Chemicaland
Radionuclides Rules ICR (Renewal), Exhibit 33a (USEPA, 2022).
v) Deliver information that asks if customer wants their LSL replaced (hrs_lcr_lslr_out_deliv_op,
cost_lcr_lslr_out). The EPA assumed systems will incur a burden of 0.0025 hours per letter or 15
minutes per 100 copies to prepare the materials described in activity v) for delivery based on the
Economic and Supporting Analysis: Short-Term Regulatory Changes to the Lead and Copper Rule, p.
54 (USEPA, 2007). The EPA estimates systems will incur a cost of $0,703 to send the materials
($0,017 for pamphlet, $0.06 for ink, $0,076 for envelope, and $0.55 for postage). See file "General
Cost Model lnputs_Final.xlsx" for assumptions for paper, envelope, and postage. Bulk rate does not
apply because notice is being sent to fewer than 200 households. The EPA assumed this information
is sent to 7 percent of households with LSLs to meet the minimum requirement of the rule. Note
that the number of households with LSLs changes during the 35-year rule analysis period, decreasing
over time as the system fully replaces LSLs (households with LSLs each year is expressed in the
SafeWater LCR model as hh_remain_lsl).
w) Develop information that goes to customers prior to partial LSLR (hrs_lcr_lslr_prior_op). Under the
pre-2021 LCR, systems must notify customers prior to partial replacement of an LSL explaining that
they may experience a temporary increase in lead levels and measures they can take to minimize
their exposure. The materials must also include an offer to replace the customer-side at the owner's
expense. The EPA assumes systems will incur a burden of 7 hours based on the 2022
Disinfectants/Disinfection Byproducts, Chemicaland Radionuclides Rules ICR (Renewal), Exhibit 33a
(USEPA, 2022). See Exhibit B-124 for the percent of LSLs that are partial replacements
(p_lslr_partial)) of the 7 percent of LSLs replaced per year under mandatory replacement. See
activity s) for explanation of how the EPA tracks the number of households with LSLs remaining for
each system over the 35-year analysis period.
x) Deliver information prior to partial LSLR (hrs_prior_notif_op, cost_prior_notif). The EPA assumed
systems will incur a burden of 0.5 hours for all system sizes to provide a letter with the materials
described in activity t) based on the 2022 Disinfectants/Disinfection Byproducts, Chemicaland
Radionuclides Rules ICR (Renewal) in Exhibit 35 (Partial LSL Letter) (USEPA, 2022). The EPA assumed
systems will incur the same mailing cost of $0,703 described in activity s). This information goes to
the same percent of households with LSLs as activity s).
y) Submit documentation that partial LSLR was fulfilled (hrs_report_plslr_op). The EPA assumed
systems will incur a burden of 0.5 hours to provide documentation to the State that they fulfilled
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their partial LSLRs requirements that include activities q) - s) in Section B.8.3.2, and activities u)
through y) that are described above. The estimate of 0.5 hours is based on the 2022 Disinfectants
and Disinfection Byproducts, Chemical, and Radionuclides Rules ICR, Exhibit 35 (Partial LSL Letter).
z) Collect samples for test out provision (hrs_collect_lsl_plslr_op, cost_pickup_samp, cost_lsl_samp).
Systems electing to use the test out provision are assumed to collect one sample per tested LSLs
(numb_samp_test). As shown in Exhibit B-124, the EPA assumed 25 percent of CWSs serving more
than 10,000 people would test all LSLs before replacing them to determine if any meet the test out
criteria (pp_lcr_test). The EPA assumed systems test 7 percent of LSLs per year, with the number of
LSLs per system based on the estimated percentage of LSLs (perc_lsl) adjusted each year to account
for full LSLR (i.e., households with LSLs each year is expressed in the SafeWater LCR model as
hh_remain_lsl). Systems will incur the same burden and cost with this sample collection as
described in activity q) in Section B.8.3.2.
aa) Analyze lead tap samples for test out provision (hrs_analyze_lsl_plslr_op, cost_lab_lsl_plslr,
cost_commercial_lsl_plslr). The EPA assumed systems would incur the same costs and burden to
analyze a lead tap sample in-house or commercially as described in activity r) in Section B.8.3.2.
Exhibit B-132 provides the SafeWater LCR model cost estimation approach for PWS ancillary LSLR that
are unique to the pre-2021 LCR including additional cost inputs that are required to calculate these
costs.
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Exhibit B-132: Lead Service Line Replacement Ancillary Cost Estimation in SafeWater LCR by Activity under the Pre-2021 LCR1,2
CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply
to a Model PWS
Frequency of
Activity
Lead 90th -
Range
Other Conditions
u) Develop information that asks if customers want their LSL replaced
The total hours per system multiplied by the system labor rate.
(hrs_lcr_lslr_out_op*rate_op)
Cost does not
apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
One time
v) Deliver information that asks customer if their want their LSL replaced
Seven percent of the number of remaining LSL households multiplied by the total of
the hours per household times the system labor rate, plus the material cost.
(.07*hh_remain_lsl)*((hrs_lcr_lslr_out_deliv_op*rate_op)+cost_lcr_lslr_out)
Cost does not
apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
w) Develop information that goes to customers prior to partial LSLR
The total hours per system multiplied by the system labor rate.
(hrs_lcr_lslr_prior_op*rate_op)
Cost does not
apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
One time
x) Deliver prior notification for partial LSLRs
The number of lines partially replaced multiplied by the total of the hours per line
times the system labor rate, plus the material cost.
num_lslr_partial_replace*((hrs_prior_notif_op*rate_op)+cost_prior_notif)
Cost does not
apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
y) Submit documentation that partial LSLR requirements were fulfilled
The estimated total hours per system multiplied by the system labor rate.
(hrs_report_plslr_op*rate_op)
Cost does not
apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
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CWS Cost Per Activity
NTNCWS Cost
Per Activity
Conditions for Cost to Apply
to a Model PWS
Frequency of
Activity
Lead 90th -
Range
Other Conditions
z) Collect lead tap samples for test out provision3
The number of samples required for each service line that is "test out" multiplied by
the hours per sample times the system labor rate, plus the total of the material cost
per sample.
((num_lsl_testout)*(numb_samp_test))*(cost_lsl_samp+cost_pickup_samp+(hrs_coll
ect_lsl_plslr_op*rate_op))
Cost does not
apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
aa) Analyze lead tap samples for test out provision3
There are different labor (burden) and material costs for a sample analyzed in house
and a sample analyzed using a commercial lab. The in-house analysis costs are
calculated using the number of required samples per tested lead line multiplied by
the number of test lead lines and the percentage of samples analyzed in house times
the system labor rate, plus the material cost of the in-house analysis per sample. The
commercial lab analysis costs are calculated using the number of required samples
per system multiplied by the percentage of samples analyzed in a commercial lab
times the commercial lab analysis per sample.
Cost does not
apply to
NTNCWS.
Above AL
Model PWSs
complying with the
mandatory LSLR
program
Once a year
((((num_lsl_testout)*(numb_samp_test))*pp_lab_samp)*((hrs_analyze_lsl_plslr_op*ra
te_op)+cost_lab_lsl_plslr))+((((num_lsl_testout)*(numb_samp_test))*pp_commercial_
samp)*cost commercial Isl plslr)
Acronyms: AL = action level; CWS = community water system; LSL = lead service line; LSLR = lead service line replacement; NTNCWS = non-transient non-
community water system; PWS = public water system.
Notes:
1 The data variables in this exhibit are defined previously in Section B.8.3.1 through B.8.3.3 with the exception of:
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 The system can discontinue the activities in this exhibit after it no longer exceeds the lead AL for two consecutive, six-month monitoring periods.
3The burden and costs to provide sample bottles (cost_lsl_samp) under activity z) and conduct analyses under activity aa) are incurred by the State in Arkansas,
Louisiana, Mississippi, Missouri, and South Carolina (ASDWA, 2020a).
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B.8.4 PWS Lead Public Education, Outreach, and Notification Costs under the Pre-2021 LCR
Under the pre-2021 LCR, systems will incur labor and non-labor costs to lead PE in response to lead ALE
of 15 ng/L. The EPA has developed system costs for these activities, as provided in Exhibit B-133. The
exhibit provides the unit burden and/or cost for each activity. The third column provides the
corresponding SafeWater LCR model data variable in red/italic font. The last column indicates whether
the activity, unit burden or cost, and SafeWater LCR data variable are identical for the pre-2021 LCR to
those used for the final LCRI, as described in Chapter 4, Section 4.3.6.3. The gray shaded row indicates
an activity that is not required under the pre-2021 LCR.
Note that the final LCRI, includes additional PE, outreach, and notification activities that require
expedited consumer notice of individual tap results, are independent of a systems lead 90th percentile
level, those that are triggered when a system has at least three lead ALEs in a five-year period (i.e., has
multiple lead ALEs). Those requirements are not included in B.8.4 but are detailed in Chapter 4, Sections
4.4.6.1, 4.3.6.2, and 4.3.6.4, respectively, as activities a) through s) and bb) through gg).
Exhibit B-133: PWS Public Education Burden in Response to Lead ALE under the Pre-2021 LCR
Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
s) Update mandatory
language for lead ALE
public education and
submit to the State for
review (one-time)
N/A
hrs_pe_ al_ de vel_ op
N/A under the
pre-2021 LCR.
t) Deliver lead ALE public
education materials to
all customers
CWSs
0.0025 hours/household;
$0.27 to $0.40/CWS
NTNCWSs
1 hr/NTNCWS
$0.079/NTNCWS
CWSs
hrs_distr_edu_op;
cost_pe_lcr_delivery
NTNCWSs
hrs_ n tn cws_ distr_ edu_ op;
cost_ntncws_pe_lcr_delivery
Yes.
u) Post notice to website
0.5 hrs/CWSs serving >
50,000 people
hrs_web_op
Yes.
v) Prepare press release
10 hrs/press release per
CWS serving > 3,300
people;
$0/press release
hrs_pr_op;
cost_pr
Yes.
w) Contact public health
agencies to obtain
additional organizations
and update recipient list
0.5 hrs/CWSs serving
<3,300 people;
1.5 hrs/CWSs serving 3,301
to 100,000 people;
2.5 hrs/CWS serving >
100,000 people
hrs_ha_op
Yes.
x) Notify public health
agencies and other
organizations
0.0025
hours/organization/CWS;
$5.97/organization/CWS
hrs_distr_agencies_pe_op;
cost_pe_lead_ale
Yes.
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Activity
Unit Burden and/or Cost
SafeWater LCR Data Variable
Same As Final
LCRI?
y) Consult with the State
on other public
education activities
2 hrs/CWS
hrs_ ale_ consult_ op
Yes.
z) Implement other public
education activities
2.7 to 1,039.2 hrs/CWS;
$38.82 to $297,956/CWS
hrs_ ale_ other_ op;
cost ale other
Yes.
aa) Certify to the State that
lead outreach was
completed1
CWSs
2 hrs/CWS serving <50,000
people;
3 hrs/CWS serving > 50,000
people
NTNCWSs
0.66 hrs/NTNCWS serving
<50,000 people;
1 hr/NTNCWS serving >
50,000 people
CWSs
hrs_pe_ certify_ quarterly_op
NTNCWSs
hrs_cert_outreach_annual_op
Yes
Acronyms: ALE = action level exceedance; CWS = community water system; LCR = Lead and Copper Rule; LCRI =
Lead and Copper Rule Improvements; NTNCWS = non-transient non-community water system.
Sources:
v) - aa): "Public Education lnputs_CWS_Final.xlsx"; "Public Education lnputs_NTNCWS_Final.xlsx."
u), bb): "Public Education lnputs_CWS_Final.xlsx."
Notes
1 For the final LCRI, this corresponds to activity s), which is included in Chapter 4, Section 4.3.6.2 - Activities
Regardless of lead 90th Percentile Levels. For the final LCRI, the certification includes all public education, outreach,
and notification requirements.
Exhibit B-134 shows the SafeWater LCR model cost estimation approach for system lead PE activities
and indicates if the approach is the same as that used for the final LCRI, as provided in Chapter 4, Exhibit
4-126, as well as a final LCRI activity that does not apply under the pre-2021 LCR in a gray shaded row.
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Exhibit B-134: PWS Lead ALE Public Education Unit Cost Estimation in SafeWater LCR by Activity under the Pre-2021 LCR1
CWS Cost Per Activity
NTNCWS Cost Per Activity
Conditions for Cost to Apply to
a Model PWS
Frequency of Activity
Lead 90th -
Range
Other Conditions
s) Update mandatory language for lead ALE PE and submit to the State for review
N/A under the pre-2021 LCR. Assumed to have already occurred for all model PWSs with a lead ALE.
t) Deliver lead ALE public education materials to all customers
Same as final LCRI (see activity u) in Exhibit 4-126 in Chapter 4).
u) Post lead notice on website
Same as final LCRI (see activity v) in Exhibit 4-126 in Chapter 4).
v) Prepare a press release
Same as final LCRI (see activity w) in Exhibit 4-126 in Chapter 4).
w) Contact public health agencies to obtain additional organizations and update recipient list
Same as final LCRI (see activity x) in Exhibit 4-126 in Chapter 4).
x) Notify public health agencies and other organizations
Same as final LCRI (see activity y) in Exhibit 4-126 in Chapter 4).
y) Consult with the State on other public education activities
Same as final LCRI (see activity z) in Exhibit 4-126 in Chapter 4).
z) Implement other PE activities
Same as final LCRI (see activity aa) in Exhibit 4-126 in Chapter 4).
aa) Certify to State that lead outreach was completed3
The total hours per system multiplied by the
system labor rate.
(hrs_pe_certify_quarterly_op*rate_op)
The total hours per system
multiplied by the system labor
rate.
(hrs_cert_outreach_annual_o
p*rate_op)
Above AL
All model PWSs
Once a year2
Acronyms: AL = action level; ALE = action level exceedance; CWS = community water system; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; PE = public education; PWS = public water system.
Notes:
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1 The data variables in the exhibit are defined previously in this section with the exception of:
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2System can discontinue PE activities after they no longer exceeds the lead AL
3 CWSs submit their certifications quarterly but for modeling purposes, the burden is estimated on an annual basis. Under the final LCRI this cost is aggregated
under the public education activities regardless of lead 90th percentile level and is provided in Chapter 4, Exhibit 4-119 as activity s).
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B.9 Detailed State Costing Approach for the Pre-2021 LCR
For many of the water system activities described in Section 0, the 56 primacy agencies (States)51 will
incur costs in the form of burden (i.e., hours) to provide oversight and review. The State burden is
multiplied by the labor rate ($/hr), as presented in Chapter 3, Section 3.3.11.2 to estimate labor unit
costs. The remainder of this section is organized as follows:
• B.9.1: State Administrative Costs under the Pre-2021 LCR
• B.9.2: State Sampling Related Costs under the Pre-2021 LCR
• B.9.3: State CCT-Related Costs under the Pre-2021 LCR
• B.9.4: State Lead Service Line Testing and Replacement under the Pre-2021 LCR
• B.9.5: State Lead Public Education and Outreach under the Pre-2021 LCR
The final LCRI requirements associated with one-time activities to implement and administer the rule
changes, lead in drinking water testing at schools and child cares, DSSA requirements, public outreach
requirements other than those required when a system exceeds the lead AL, and the POU program are
not applicable to the pre-2021 LCR and thus are not included B.9. However, Exhibit B-135 shows all the
components, subcomponents, and activities from Exhibit 4-141 in Chapter 4 for the final LCRI to
facilitate comparison between the two rules. For each major rule component, each activity has a unique
letter ID. The differences in activities costed for the final LCRI and the pre-2021 LCR are identified as
follows: 1) gray shading italicized text indicates activities under the final LCRI that were not part of the
pre-2021 LCR requirements; and 2) yellow shaded activities in bold are specific to the LCR and are not
included in the final LCRI requirements.
At the end of each subsection, the EPA provides a summary exhibit showing the SafeWater LCR
modeling approach for each State activity, as was done in Section B.5 for PWSs. The SafeWater LCR
model uses the information from these exhibits to calculate total annualized State cost for each activity.
See Section B.6 for detail on the cost modeling methodology.
Exhibit B-135: State Cost Components, Subcomponents, and Activities Organized by Section1
Component
Subcomponents
Activities2
B.9.1: State Administrative
Costs under the Pre-2021
LCR
a) Adopt rule and develop program.
b) Modify data management systems.
c) Provide system training and technical assistance.
d) Provide staff training.
e) Review and approve small system flexibility option.
B.9.1: State Administrative
Costs under the Pre-2021
None
f) Coordinate with the EPA.
g) Provide ongoing technical assistance.
51 The 56 primacy agencies include 49 states (excluding Wyoming), District of Columbia, Puerto Rico, Guam, United
States Virgin Islands, American Samoa, North Mariana Islands, and Navajo Nation. Note that some burden and
costs pertaining D.C. are incurred by the EPA but for modeling purposes are assigned to the D.C.
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Component
Subcomponents
Activities2
LCR (continued)
h)
i)
Report to SDWIS/Fed.
Train staff for annual administration.
B.9.2: State Sampling
B.9.2.1: State Lead
a)
Provide templates for revised sampling instructions
Related Costs under the
Tap Sampling Costs
and conduct review.
Pre-2021 LCR
b)
c)
Review updated sampling plan.
Review initial lead monitoring data and prepare
systems for status under the rule.
d)
Review change in tap sample locations.
e)
Review 9-year monitoring waiver renewal.
f)
Review sample invalidation requests.
g)
Review consumer notification certifications.
h)
Review monitoring results and 90th percentile
calculations.
B.9.2.2: State Lead
i)
Review lead WQP sampling data and compliance
WQP Sampling Costs
with OWQPs.
B.9.2.3: State Copper
j)
Review copper WQP sampling data and compliance
WQP Monitoring
with OWQPs.
Costs
B.9.2.4: State Source
k)
Review source water monitoring results.
Water Monitoring
Costs
State School Sampling
1)
Review list of schools and child care facilities.
Costs
m)
n)
o)
P)
Provide templates on school and child care facility
testing program.
Review school and child care facility testing program
materials.
Review school and child care facility sampling results
after individual sampling events.
Review annual reports on school and child care
facility lead in drinking water testing program.
B.9.3: State CCT-Related
B.9.3.1: State CCT
a)
Review CCT study and determine type of CCT to be
Costs under the Pre-2021
Installation Costs
installed
LCR
b)
Set OWQPs after CCT installation
B.9.3.2: State CCT Re-
c)
Review CCT study and determine needed OCCT
optimization Costs
d)
adjustment
Reset OWQPs after CCT re-optimization
State DSSA Costs
e)
f)
Consult with system prior to any DSSA CCT
adjustments
Review report on DSSA responses
B.9.3.3: State Lead
g)
Review CCT guidance and applicability to individual
CCT Routine Costs
h)
PWSs
Review water quality data with PWSs during
sanitary survey
i)
Consult on required actions in response to source
water change
j)
Consult on required actions in response to
treatment change
B.9.3.4 State CCT
k)
Determine need for a CCT study
Costs Unique to the
1)
Determine type of CCT or systems without a study
Pre-2021 LCR
m)
n)
Determine the need for a revised CCT study
Determine the CCT adjustment for systems without
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Component
Subcomponents
Activities2
a revised study
B.9.4: State Lead Service
Line Testing and
Replacement under the
Pre-2021 LCR
SL Inventory Costs
a) Review connector updated LCRR initial inventory
(baseline inventory)
b) Review annual service line inventory updates
c) Review inventory validation report
SLR Plan Review Costs
d) Review initial SLR plan
e) Review information on deferred deadline and
associated replacement rate in the SLR plan and
determine fastest feasible rate.
f) Review annually updated SLR plan or certification of
no change.
g) Conduct triennial review of water system updated
recommended deferred deadline and associated
replacement rate and determine fastest feasible
rate.
SLR Report Review
Costs
h) Review annual SLR program report3
None
i) Review report on lead tap samples following
partial LSLR
State Lead Public
Education and Outreach
under the Pre-2021 LCR
Related Costs
One-Time POU
Program Costs
a) Review POU plan.
b) Provide templates for POU outreach materials.
c) Review POU public education materials.
Ongoing POU Program
Costs
d) Review sample invalidation request for POU
monitoring.
e) Review customer notification certifications.
f) Review annual POU program report.
Consumer Notice
a) Provide templates for consumer notice materials.
b) Review lead consumer notice materials.
c) Review copy of the consumer notice and
certification.
Activities Regardless
of the Lead 90th
Percentile Level
d) Provide templates for updated CCR language.
e) Provide templates for local and State health
department lead outreach.
f) Review lead outreach materials for local and State
health departments.
g) Participate in joint communication efforts with local
and State health departments.
h) Provide templates for service line disturbance
outreach materials.
i) Review public education materials for service line
disturbances.
j) Provide templates for inventory-related outreach
materials.
k) Review inventory-related outreach materials.
1) Provide technical assistance to PWSsfor public
education materials.
m) Review public education certifications.
B.9.5: State Lead Public
Education and Outreach
under the Pre-2021 LCR
n) Provide templates for updated public education
materials for systems with a lead ALE
o) Review revised lead language for systems with a
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Component
Subcomponents
Activities2
lead ALE
p) Consult with CWS on other public education
activities in response to lead ALE
q) Review public education certifications4
Public Education
Activities in Response
to Multiple Lead ALEs
p) Review plan for making filters available.
q) Provide templates for systems with multiple lead
ALEs.
r) Review outreach materials provided by systems with
multiple lead ALEs.
s) Consult on filter program for systems with multiple
lead ALEs.
Acronyms: ALE = action level exceedance; CCR = Consumer Confidence Report; CCT = corrosion control treatment;
CWS = community water system; DSSA = Distribution System and Site Assessment; EPA = Environmental Protection
Agency; LCR = Lead and Copper Rule; LSLR = lead service line replacement; OCCT = optimal corrosion control
treatment; OWQPs = optimal water quality parameters; POU = point-of-use; PWS = public water system;
SDWIS/Fed = Safe Drinking Water Act Information System/Federal version; SL = service line; SLR = service line
replacement; WQP = water quality parameter.
Notes:
1 States will also incur burden for recordkeeping activities under the pre-2021 LCR, such as retaining records of
decisions, supporting documentation, technical basis for decisions, and documentation submitted by the system.
The EPA has included burden for recordkeeping with each activity when applicable as opposed to providing
separate burden estimates.
2The EPA assigned a unique letter of identification (ID) for each activity under a given rule component. Activities
are generally organized with upfront, one-time activities first followed by ongoing activities. Note that these
activities are different than the activities identified for PWSs in Exhibit B-13. Activities shaded in gray indicate new
requirements that apply only to the LCRR. They are included to more fully characterize the differences between
the pre-2021 LCR and final LCRI.
3The review of the annual SLR report applies to the pre-2021 LCR and final LCRI. This report is discussed in Section
B.9.4.
4 For the final LCRI, the review of certifications corresponds to activity s) that is included in Chapter 4, Section
4.4.6.2 - Activities Regardless of Lead 90th Percentile Levels.
B.9.1 State Administrative Costs under the Pre-2021 LCR
Because the pre-2021 LCR is already in effect, States will not incur one-time rule implementation burden
that are included for the final LCRI as activities a) through e) in Chapter 4, Section 4.4.1.1. However,
States will incur burden for four annual administration activities, as shown in Exhibit B-136. This exhibit
provides the unit burden estimate for each activity. The third column provides the corresponding
SafeWater LCR model data variable. The last column indicates whether the activity, unit burden, and the
SafeWater LCR model data variable are identical to those used for the final LCRI, as described in Chapter
4, Section 4.4.1.2. The assumptions that differ from the final LCRI follow the exhibit.
Note that State burden estimates for responding to specific requirements of the pre-2021 LCR (e.g.,
review changes in a system's treatment, consult with systems) are presented in the sections for those
particular rule requirements.
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Exhibit B-136: State Annual Administration Activities and Unit Burden Estimates under the
Pre-2021 LCR
Activity
Unit Burden
(hours/State)
SafeWater LCR Data
Variable
Same As Final LCRI?
f) Coordinate with the EPA
1,040
hrs_coord_epaJs
Yes.
g) Provide ongoing technical
assistance
774
hrs_taJs
No. See discussion
following the exhibit.
h) Report to SDWIS/Fed
1,040
hrs_sdwisJs
No. See discussion
following the exhibit.
i) Train staff for annual
administration
104
hrs_train_annJs
Yes.
Per State Total
2,958
Acronyms: EPA = Environmental Protection Agency; LCRI = Lead and Copper Rule Improvements; SDWIS/Fed = Safe
Drinking Water Information System/Federal version.
Sources:
f), g), and i): "Administrative Burden and Costs_Final.xlsx." All unit burdens are based on the administrative burden
estimated for the EPA's 2012, Economic Analysis for the Final Revised Total Coliform Rule, Exhibit 7.4 (USEPA,
2012).
g): ASDWA 2020 and 2024 CoSTS models (ASDWA, 2020b; ASDWA, 2024). Also see " Administrative Burden and
Costs_Final.xlsx."
Notes:
f): States must coordinate with their EPA Regional office to be certain that their program is consistent with Federal
requirements.
g): Includes ongoing tracking and follow-up activities for review of monitoring data and public notice and
education for systems with lead ALEs. See "Administrative Burden and Costs_Final.xlsx worksheet,"
"Deriv_Ongoing TA_LCR" for additional detail on how this burden estimate was derived.
h): Includes the burden for States to report 90th percentile data, milestone, and violation and compliance
information to SDWIS/Fed. Under the LCRR, the EPA assumed additional administrative burden (+560 hours or 0.25
full time equivalents) for States to report the following to SDWIS/Fed: OCCT status of all water systems, including
the parameters that define the optimization; all lead 90th percentile values for systems serving 3,300 or fewer in
lieu of only those levels above 15 ng/L; and the current number of LSLs and service lines of unknown material for
all water systems.
i): Assumed States will have annual burden to continue to train staff.
g) Provide ongoing technical assistance (hrs_taJs). The EPA determined the on-going tracking and
follow-up per system estimates provided in ASDWA 2020 and 2024 CoSTS models (ASDWA, 2020b;
ASDWA, 2024) for the review of monitoring data and public notice and education as follows:
1. Determined the per system burden estimates separately for 12 categories that included
small, medium, and large CWSs with and without LSLs and NTNCWSs with and without LSLs
because the estimates and rule applicability vary by system size, system type, and LSL
status.
2. Multiplied the per system estimate by the number of systems in each of the 12 categories
based on the system inventory information provided in Chapter 3, Section 3.3.1.
3. Summed the burden for the four system type and LSL status categories to derive a total
burden by size category.
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4. Divided each burden by the 49 States used in the ASDWA CoSTs model to derive a total
burden by size category.
5. Determined the weighted average across the size categories.
6. Divided the burden is step 5 by five because the estimates are provided for a five-year
period.
In determining the per system burden estimates, the EPA reviewed both ASDWA 2020 and
2024 CoSTS models. In the instances where the burdens differed between the ASDWA 2020
CoSTS and ASDWA 2024 CoSTS models, the EPA used the higher of the two to provide a
more conservative estimate. There were no changes in burden estimates applicable to the
LCR, so the burden remained the same in the proposed and final rules. Note that the EPA
did not include ASDWA's estimates for reporting or re-evaluation activities in the ongoing
technical assistance burden because they are included in other data variables nor violations
or compliance estimates because the EPA assumed full compliance for cost modeling
purposes. Also, the ongoing technical assistance burden does not include estimates from
"CCT" worksheets because they are one-time activities and the EPA has accounted for their
burden in other activities.
h) Report to SDWIS/Fed (hrs_sdwisJs). The EPA estimated the Includes the annual burden for States
to report 90th percentile data, milestone, and violation and compliance information to SDWIS/Fed of
1,040 hours. Under the final LCRI, the EPA assumed additional administrative burden (+560 hours or
0.25 full time equivalents) for States to report to additional SDWIS/Fed reporting requirements that
include OCCT status of all water systems, including the parameters that define the optimization; all
lead 90th percentile values for systems serving 3,300 or fewer in lieu of only those levels above the
lead AL; and the existing number of lead, GRR, and service lines of unknown material for all water
systems.
Exhibit B-137 shows the SafeWater LCR model cost estimation approach for State administrative
activities and indicates that the costing approach is the same as that used for the final LCRI, as provided
in Chapter 4, Exhibit 4-145.
Exhibit B-137: State Administration and Rule Implementation Costing Approach in SafeWater
LCR by Activity under the pre-2021 LCR1
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to
Apply to a State
Frequency
of Activity
Lead 90th - Other
Range Conditions
f) Coordinate with the EPA
Same as final LCRI (see Exhibit 4-145 in Chapter 4).
g) Provide ongoing technical assistance
Same as final LCRI (see Exhibit 4-145 in Chapter 4).
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State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to
Apply to a State
Frequency
of Activity
Lead 90th - Other
Range Conditions
h) Report to SDWIS/Fed
Same as final LCRI (see Exhibit 4-145 in Chapter 4).
i) Train staff for annual administration
Same as final LCRI (see Exhibit 4-145 in Chapter 4).
Acronyms: CWS = community water system; EPA = Environmental Protection Agency; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; SDWIS/Fed = Safe Drinking Water
Information System/Federal version.
B.9.2 State Sampling Related Costs under the Pre-2021 LCR
This section provides State unit burden related to lead tap sampling, lead WQP monitoring, copper WQP
monitoring, and source water monitoring in Sections B.9.2.1 through B.9.2.4, respectively. As noted in
Subsections B.9.2.1 and B.9.2.4, as well as Section B.9.4 that pertains to LSLR, Arkansas, Louisiana,
Mississippi, Missouri, and South Carolina pay for the cost of bottles, analysis, and providing sample
results to the system as part of their State's oversight and implementation responsibilities. Thus, these
States will incur the cost of bottles, analysis, and providing lead sample results to the system (ASDWA,
2020a). Note that there may be additional State laboratories that incur some analytical and reporting
burden and costs in lieu of the system that would result in an underestimation of State costs.
School testing under the final LCRI does not apply to the pre-2021 LCR and thus is not covered in this
section. For additional detail, refer to Chapter 4, Section 4.4.2.5.
B.9.2.1 State Lead Tap Sampling Costs
The EPA has identified and developed costs for State oversight and review activities associated with lead
tap sampling conducted by water systems under the pre-2021 LCR, as shown in Exhibit B-138. The
exhibit provides the unit burden for each activity. The third column provides the corresponding
SafeWater LCR model data variable in red/italic font. Activities that are conducted by some States in lieu
of the water system are identified in a footnote below the exhibit. The last column indicates whether
the activity, unit burden, and the SafeWater LCR model data variable for the pre-2021 LCR are identical
to those used for the final LCRI, as described in Chapter 4, Section 4.4.2.1. The assumptions that differ
from the final LCRI follow the exhibit. Gray shaded rows indicate new requirements that do not apply to
the pre-2021 LCR.
Exhibit B-138: State Lead Tap Sampling Burden Estimates under the Pre-2021 LCR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
a) Provide templates for
revised sampling
instructions and conduct
review (one-time)
N/A
hrs_rev_sampJs
N/A under the pre-
2021 LCR.
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Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
b) Review updated
sampling plan (one-time)
N/A
hrs_rev_samp_planJs
N/A under the pre-
2021 LCR.
c) Review initial lead tap
sampling data and
prepare systems for
status under the rule
N/A
hrsjnitial_tap_revJs
N/A under the pre-
2021 LCR.
d) Review change in tap
sample locations1
2 hrs/CWS
hrs_chng_tapJs
Yes.
e) Review 9-year
monitoring waiver
renewal
0.5 hrs/PWS for those with 9-
year monitoring waiver
hrs_renew_nineJs
Yes.
f) Review sample
invalidation requests
2 hrs/invalidation request
hrs_sampjnvalidJs
Yes.
g) Review consumer
notification certifications
0.33 to 0.5 hrs/certification
hrs_cert_custjtJs
Yes.
h) Review monitoring
results and 90th
percentile calculations
0.5 to 2 hrs/PWS
hrs_annualjtJs2
No. See discussion
following the
exhibit.
Acronyms: CWS = community water system; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; PWS = public water system.
Source: "Lead Analytical Burden and Costs_Final.xlsx."
Notes:
1 Applies to CWSs only. The EPA assumed 0 hours for NTNCWSs because they collect their own samples from
sampling locations under their control and thus, are unlikely to change sampling sites and submit documentation
to the State for review.
2 As previously discussed in Section B.8.1.1.2 in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the
State pays for the cost of bottles, shipping, analysis, and providing sample results to the system (ASDWA, 2020a).
Thus, the State will incur the burden and cost for these activities in lieu of the system. In this instance, the system
burden to provide monitoring results and 90th percentile calculations is applied to these States and
hrs_annual_ltJs would be 0. Instead, they will incur the system burden of hrs_annual_lt_op (see B.8.1.1.2, activity
P)).
h) Review monitoring results and 90th percentile calculations (hrs_annual_ltJs). The EPA estimated
the burden for States to review monitoring results and lead 90th percentile calculations is 0.5 hours
for systems serving 3,300 or fewer, 1 hour for systems serving 3,301 to 10,000, 1.5 hours for
systems serving 10,001 to 100,000, and 2 hours for systems serving greater than 100,000. These
estimates are based on the 2022 Disinfectants/Disinfection Byproducts, Chemicaland Radionuclides
Rules ICR (Renewal), Exhibit 48 (Tap Sample Calcs) (USEPA, 2022) and were doubled from the
proposed rule based on ASDWA's 2024 CoSTS model, section "Tap Sampling" (ASDWA, 2024). For
the final LCRI, the burden for LSL systems is 1.25 times higher because LSL systems must provide a
justification if they are unable to collect their required number of samples from only sites served by
LSLs.
Exhibit B-139 shows the SafeWater LCR model cost estimation approach for State lead tap monitoring
activities including additional cost inputs required to calculate these costs, as well as final LCRI activities
from Chapter 4, Exhibit 4-148 that do not apply under the pre-2021 LCR in gray shaded rows.
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Exhibit B-139: State Lead Tap Sampling Unit Cost Estimation in SafeWater LCR by Activity
under the Pre-2021 LCR1
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
a) Provide templates for revised sampling instructions and conduct review
N/A under the pre-2021 LCR.
b) Review updated sampling plan for LSL systems
N/A under the pre-2021 LCR.
c) Review initial lead monitoring data and prepare systems for status under the rule
N/A under the pre-2021 LCR.
d) Review change in tap sample locations
The hours per system multiplied by
the State labor rate
All
States with systems not on
reduced tap monitoring
Twice a
(hrs_chng_tapJs*rateJs)
1 - (p_tap_annual +
p_tap_triennial +
p_tap_nine)
year
Cost does not
apply to States
for NTNCWSs.
States with systems on
reduced annual tap
sampling
p tap annual
Once a
year
States with systems on
reduced triennial tap
sampling
Every 3
years
p tap triennial
States with systems on
reduced nine year sampling
Every 9
p_tap_nine
years
e) Review 9-year monitoring waiver renewal
The hours per system multiplied by
the State labor rate
(hrs_renew_nineJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
All
States with systems on
reduced nine-year sampling
p_tap_nine
Every 9
years
f) Review sample invalidation requests
The number of samples determined
to be invalid multiplied by the hours
per sample per system and the State
labor rate
(numb_samp_customer*pp_samp_in
valid)*(hrs samp invalid js*rate js)
States with systems not on
reduced tap sampling
1 - (p_tap_annual +
pjtapjtrienniai +
p_tap_nine)
Twice a
year
The number of samples determined
to be invalid multiplied by the hours
per sample per system and the State
labor rate.
(numb_reduced_tap*pp_samp_invali
d)*(hrs_samp_invalidJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
All
States with systems on
reduced annual tap
sampling
p_tap_annual
Once a
year
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State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th -
Range
Other Conditions2
States with systems on
reduced triennial tap
sampling
p_tap_triennial
Every 3
years
States with systems on
reduced nine year sampling
p_tap_nine
Every 9
years
g) Review consumer notification certifications
The hours per system multiplied by
the State labor rate.
(hrs_cert_cust_ltJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
All
States with systems not on
reduced tap sampling
1 - (p_tap_annual +
p_tap_triennial +
p tap nine)
Twice a
year
States with systems on
reduced annual tap
sampling
p tap annual
Once a
year
States with systems on
reduced triennial tap
sampling
p tap triennial
Every 3
years
States with systems on
reduced nine year sampling
p_tap_nine
Every 9
years
h) Review monitoring results and 90th percentile calculations2
The hours per system multiplied by
the State labor rate.
States with systems not on
reduced tap sampling
Twice a
(hrs_annual_ltjs*ratejs)
1 - (p_tap_annual +
pjtapjtrienniai +
p tap nine)
year
Cost applies as
written to States
States with systems on
reduced annual tap
sampling
Once a
year
for NTNCWSs.
All
p tap annual
States with systems on
reduced triennial tap
sampling
Every 3
years
p tap triennial
States with systems on
reduced nine year sampling
Every 9
p_tap_nine
years
Acronyms: CWS = community water system; LCR = Lead and Copper Rule; LCRR = Lead and Copper Rule Revisions;
LSL = lead service line; NTNCWS = non-transient non-community water system.
Notes:
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1 The data variables in the exhibit are defined previously in this section with the exception of the following:
• numb_reduced_tap\ the number of lead tap samples for system on reduced annual, triennial, or 9-year
monitoring (Chapter 4, Section 4.3.2.1.1).
• numb_samp_customer: the number of lead tap samples for system on standard 6-month tap monitoring
(Chapter 4, Section 4.3.2.1.1).
• pp_sampjnvalid: Likelihood that a lead sample will be deemed invalid (Chapter 4, Section 4.3.2.1.2,
activity f)).
• p_tap_annual, p_tap_triennial, and p_tap_nine: Likelihood a system will qualify to collect lead tap
samples at an annual, triennial, and nine-year frequency, respectively (Chapter 3, Section 3.3.7.1).
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
2 In Arkansas, Louisiana, Mississippi, Missouri, and South Carolina, the State conducts this activity in lieu of the
system (ASDWA, 2020a). In these States, the burden for hrs_annual_ltJs is 0. Instead, they will incur the system
burden of hrs_annual_lt_op (see B.8.1.1.2, activity p)).
B.9.2.2 State Lead WQP Sampling Costs
The EPA has developed State costs for the review of lead WQP monitoring data submitted by systems
serving 50,000 or fewer people that exceed the lead AL of 15 ng/L and all systems serving more than
50,000 people with CCT52 under the pre-2021 LCR, as shown in Exhibit B-140. The exhibit provides the
unit burden for this review. The third column provides the corresponding SafeWater LCR model data
variable in red/italic font. The last column indicates that the activity, unit burden, and the SafeWater
LCR model data variable are identical to those used for the final LCRI, as described in Chapter 4, Section
4.4.2.2.
The conditions under which the inputs apply differ under the pre-2021 LCR and final LCRI. Under the
final LCRI, systems are not allowed to conduct distribution WQP monitoring on a triennial frequency as
was allowed under the pre-2021 LCR. Further, more systems will be required to conduct WQP
monitoring under the final LCRI because: 1) more systems are expected to exceed the lead AL due to
more stringent tap sampling and 90th percentile protocol requirements for systems with LSLs; and 2)
systems serving 10,001 to 50,000 people with CCT will be required to continue WQP monitoring
irrespective of their lead 90th percentile level.
Exhibit B-140: State Lead WQP Monitoring Burden Estimates under the Pre-2021 LCR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
i) Review lead WQP sampling
data and compliance with
OWQPs
No CCT: 5 hrs/system/6-month
monitoring period;
With CCT: 8.5 hrs/system/6-month
monitoring period
hrs_wqpJs
Yes.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; OWQP = optimal water
quality parameter; WQP = water quality parameter.
52 All systems serving more than 50,000 people except those with naturally non-corrosive water (i.e., "b3"
systems") are required to have CCT.
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Source:" WQP Analytical Burden and Costs_Final.xlsx."
The SafeWater LCR model costing approach for estimating the cost of lead WQP monitoring including
additional cost inputs that are required to calculate these costs under the pre-2021 LCR are identical to
those for the LCRR. For additional detail, refer to Exhibit B-68 in Section B.6.2.2.
B.9.2.3 State Copper WQP Monitoring Costs
The EPA has developed State costs for the review of copper WQP monitoring data per six-month
monitoring period under the pre-2021 LCR, as shown in Exhibit B-141. The exhibit provides the unit
burden for this review. The third column provides the corresponding SafeWater LCR model data variable
in red/italic font. The last column indicates that the activity, unit burden, and the SafeWater LCR model
data variable are identical to those used for the final LCRI, as described in Chapter 4, Section 4.4.2.3.
Exhibit B-141: State Copper WQP Monitoring Burden Estimates under the Pre-2021 LCR
Activity
Unit Burden
SafeWater LCR
Data Variable
Same As Final
LCRI?
j) Review copper WQP
sampling data and
compliance with
OWQPs
No CCT: 5 hrs/system/6 month
monitoring period;
With CCT: 8.5 hrs/system/6 month
monitoring period
hrs_wqpJs
Yes.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; OWQP = optimal water
quality parameter; WQP = water quality parameter.
Source:" WQP Analytical Burden and Costs_Final.xlsx."
The SafeWater LCR model costing approach for estimating the cost of lead WQP monitoring including
additional cost inputs that are required to calculate these costs are identical to those for the final LCRI.
For additional detail, refer to Exhibit B-70 in Section B.6.2.3.
B.9.2.4 State Source Water Monitoring Costs
Under the pre-2021 LCR, source water monitoring was required if a water system had a significant
source water change. PWSs also were required to conduct source water monitoring when they
exceeded the lead or copper AL. The likelihood of a significant source change or ALE, as well as the
required number of source water samples, are described in Chapter 4, Section 4.3.2.4.1. Under the final
LCRI, systems can forego source water monitoring if they previously sampled source water in response
to an ALE, the State has not required source water treatment, and they have not added any new water
sources that changes their primacy source type. For modeling purposes, no system is assumed to have
source water treatment.
The EPA has developed State costs to review source water monitoring data as shown in Exhibit B-142.
The exhibit provides the unit burden for this review. The third column provides the corresponding
SafeWater LCR model data variable in red/italic font. The last column indicates that the activity, unit
burden, and the SafeWater LCR model data variable are identical to those used for the final LCRI, as
described in Chapter 4, Section 4.4.2.4.
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Exhibit B-142: State Source Monitoring Burden Estimates
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As LCRR?
k) Review source water
monitoring results
0.5 hrs/system/monitoring
period in which source water
samples are collected
hrs_sourceJs1
Yes.
Acronyms: LCRR = Lead and Copper Rule Revisions.
Source: "Lead Analytical Burden and Costs_Final.xlsx."
Notes:
1As previously discussed in Section B.8.1.4 in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the
State pays for the cost of bottles, shipping, analysis, and providing sample results to the system (ASDWA, 2020a).
Thus, the State will incur the burden and cost for these activities. In these States, because the State is reporting the
results, the burden to review the results (hrs_sourceJs) is 0. Instead, the system burden to report the results
(hrs_report_source_op) is applied to these States (see Section B.8.1.4, activity hh)).
2The unit burden and data variable names are the same between the pre-2021 LCR and final LCRI. However, their
applicability differs. Under the pre-2021 LCR, systems were required to continue to conduct source water
monitoring whenever they had a lead or copper ALE. Under the final LCRI, systems forego source water monitoring
if they previously sampled source water in response to an ALE, the State has not required source water treatment,
and they have not added any new water sources that changes their primacy source type. For modeling purposes,
no system is assumed to have source water treatment.
Exhibit B-143 shows the SafeWater LCR model cost estimation approach for State source water
monitoring activities including additional cost inputs required to calculate these costs under the pre-
2021 LCR.
Exhibit B-143: State Source Water Monitoring Cost Estimation in SafeWater LCR by Activity
under the pre-2021 LCR1
State Cost Per Activity
for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency of
Event
Lead 90th
- Range
Other Conditions
k) Review source water monitoring results2
The hours per system
multiplied by the State
labor rate.
(hrs_sourceJs*rateJs)
Cost applies as
written to States for
NTNCWSs.
At or
below AL
States with systems with
surface water sources and a
copper ALE
p_copper_ale
Once per
event
Above AL
States with systems with
surface water sources
Once per year
At or
below AL
States with systems with
groundwater sources and a
copper ALE
p_copper_ale
Every three
years per
event
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State Cost Per Activity
for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency of
Event
Lead 90th
- Range
Other Conditions
Above AL
States with systems with
groundwater sources
Every three
years
Acronyms: AL = action level; ALE = action level exceedance; CWS = community water system; NTNCWS = non-
transient non-community water system.
Notes:
1The data variables in the exhibit are defined previously in this section with the exception of:
• p_tap_annual, p_tap_triennial, and p_tap_nine: Likelihood a system will qualify to collect lead tap
samples at an annual, triennial, and nine-year frequency, respectively (Chapter 3, Section 3.3.7.1).
• numb_st_sample: number of samples per entry point for source water monitoring (Chapter 4, Section
4.3.2.4.1).
• p_copper_ale: likelihood a system with exceed the copper AL (Chapter 4, Section 4.3.2.3.1).
• rate_op: PWS hourly labor rate (Chapter 3, Section 3.3.11.1).
2 As previously discussed in Section B.8.1.4 in Arkansas, Louisiana, Mississippi, Missouri, and South Carolina the
State pays for the cost of bottles, shipping, analysis, and providing sample results to the system (ASDWA, 2020a).
Thus, the State will incur the burden and cost for these activities in lieu of the system. In these States, because the
State is reporting the results, the burden to review the results (hrs_sourceJs) is 0. Instead, the system burden to
report the results (hrs_report_source_op) is applied to these States (see Section B.8.1.4, activity hh)).
B.9.3 State CCT-Related Costs under the Pre-2021 LCR
State oversight and review activities related to CCT are grouped into four major subcomponents:
• B.9.3.1: State CCT Installation Costs
• B.9.3.2: State CCT Re-optimization Costs
• B.9.3.3: State Lead CCT Routine Costs
• B.9.3.4: State CCT Activities Unique to the Pre-2021 LCR
State oversight activities related to find-and-fix when a single sample exceeds 15 ng/L is a new
requirement under the final LCRI and does not apply to the pre-2021 LCR and thus are not discussed in
Appendix B.
B.9.3.1 State CCT Installation Costs
The EPA developed State cost for one-time activities associated with CCT installation under the pre-2021
LCR, as shown in Exhibit B-144. The exhibit provides the unit burden for each activity. The third column
provides the corresponding SafeWater LCR model data variables in red/italic font. The last column
indicates whether the activity, unit burden or cost, the SafeWater LCR model data variable, and/or
applicability are identical for the pre-2021 LCR to those used for the final LCRI, as described in Chapter 4,
Section 4.4.3.1.
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Exhibit B-144: State CCT Installation-Related Burden Estimates
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
a) Review CCT study and
determine type of
CCT to be installed
27 to 52 hrs/system
hrs_review_cct_leadJs
Yes.
b) Set OWQPs after CCT
installation
2 to 12 hrs/system serving <
50,000 people
hrs_set_owqpJs
Yes.
Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; LSL = lead service line;
OWQP = optimal water quality parameter.
Exhibit B-145 provides the SafeWater LCR model cost estimation approach for State activities related to
CCT Installation and indicates that the costing approach is the same as the final LCRI, as provided in
Chapter 4, Exhibit 4-160.
Exhibit B-145: State CCT Installation Cost Estimation in SafeWater LCR by Activity1
State Cost Per Activity for
CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th _ ....
_ Other Conditions
- Range
a) Review CCT study and determine type of CCT to be installed
Same as final LCRI (see Exhibit 4-160 in Chapter 4).
b) Set OWQPs after CCT installation
| Same as final LCRI (see Exhibit 4-160 in Chapter 4).
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; OWQP = optimal water quality parameter.
B.9.3.2 State CCT Re-optimization Costs
The EPA identified and developed State cost for oversight and review activities associated with a
system's re-optimization of existing CCT under the pre-2021 LCR, as shown in Exhibit B-146. This exhibit
provides the unit burden for each activity. The third column provides the corresponding SafeWater LCR
model data variables in red/italic font. The last column indicates whether the activity, unit burden, and
the SafeWater LCR model data variable for the pre-2021 LCR are identical to those used for the final
LCRI, as described in Chapter 4, Section 4.4.3.2.
Exhibit B-146: State CCT Re-Optimization-Related Burden Estimates under the Pre-2021 LCR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
c) Review study and
determine needed
OCCT adjustment
28 to 50 hrs/system
hrs_review_cct_leadJs
Yes.
d) Reset OWQPs after CCT
re-optimization
2 to 20 hrs/system
hrs_reset_owqpJs
Yes.
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Acronyms: CCT = corrosion control treatment; LCRI = Lead and Copper Rule Improvements; LSL = lead service line;
OCCT = optimal corrosion control treatment; OWQP = optimal water quality parameter.
Exhibit B-147 shows the SafeWater LCR model cost estimation approach for State activities related to
CCT re-optimization and indicates that the approach for the final pre-2021 LCR is the same as that used
for the final LCRI, as provided in Chapter 4, Exhibit 4-163.
Exhibit B-147: State CCT Re-optimization Cost Estimation in SafeWater LCR by Activity under
the Pre-2021 LCR1
State Cost Per ^ ....
..... . Conditio
Activity for
State Cost Per Activity for CWSs NTNCWSs
Lead 90th
- Range
c) Review CCT study and determine needed OCCT adjustment
Conditions for Cost to Apply
to a State
Other Conditions
Frequency
of Activity
Acronyms: CCT = corrosion control treatment; CWS = community water system; LCRI = Lead and Copper Rule
Improvements; NTNCWS = non-transient non-community water system; OCCT = optimal water quality parameters;
OWQP = optimal water quality parameters.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• p_cct_study: Likelihood a State will require a CCT study (Section B.8.2.1).
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
B.9.3.3 State Lead CCT Routine Costs
The EPA developed State cost associated with routine CCT activities under the pre-2021 LCR, as shown in
Exhibit B-148. The exhibit provides the unit burden for each activity. The third column provides the
corresponding SafeWater LCR model data variables in red/italic font. The last column indicates whether
the activity, unit burden or cost, the SafeWater LCR model data variable, and/or applicability for the pre-
2021 LCR are identical to those used for the LCRR, as described in Chapter 4, Section 4.4.3.4. Gray
shaded rows indicate requirements that do not apply to the pre-2021 LCR.
Exhibit B-148: State Lead CCT Routine Burden Estimates under the Pre-2021 LCR
Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
g) Review CCT
guidance and
applicability to
individual PWSs
N/A
hrs_cct_reviewJs
N/A. Does not
apply to the pre-
2021 LCR.
h) Review water
quality data with
N/A
hrs_sanit_survJs
N/A. Does not
apply to the pre-
2021 LCR.
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Activity
Unit Burden
SafeWater LCR Data Variable
Same As Final
LCRI?
PWSs during
sanitary survey
i) Consult on
6 to 12 hrs/system on reduced
hrs_coop_source_chng_redJs
Yes.
required actions in
tap monitoring
response to source
water change
N/A for systems on standard
hrs_coop_source_chng_routJs
N/A. Does not
monitoring.
apply to the pre-
2021 LCR.
j) Consult on
46 to 84 hrs/system on
hrs_coop_treat_chng_ js
Yes.
required actions in
reduced tap monitoring
response to
treatment change
Acronyms: CCT = corrosion control treatment; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; PWS = public water system.
Sources:
i): "Likelihood_SourceChange_Final.xlsx."
j): "Likelihood_TreatmentChange_Final.xlsx."
Notes:
i) & j): Under the pre-2021 LCR, consultation with the State prior to making a source or treatment change applied
only to those systems on a reduced monitoring schedule, i.e., monitoring less frequently than semi-annually.
Under the final LCRI this consultation to also apply to system monitoring semi-annually (see Chapter 4, Section
4.4.3.4 activities i) and j) for additional detail.
Exhibit B-149 provides the SafeWater LCR model cost estimation approach for State activities related to
consultation on a change in source or treatment including additional cost inputs that are required to
calculate total costs under the pre-2021 LCR.
Exhibit B-149: State Lead CCT Routine Cost Estimation in SafeWater LCR by Activity under the
pre-2021 LCR1
State Cost Per Activity for
CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
g) Review CCT guidance and applicability to individual PWSs
N/A under the pre-2021 LCR.
h) Review water quality data with PWSs during sanitary survey
N/A under the pre-2021 LCR.
i) Consult on required actions in response to source water change2
The hours per system multiplied
by the State labor rate.
(hrs_coop_source_chng_
redJs*rateJs)
Cost applies as
written for primacy
agencies to
NTNCWSs.
Below AL
States with any model
PWSs on reduced tap
sampling that have a change
in source water
1 - [pjap_annual +
p tap triennial +
Once per
event
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State Cost Per Activity for
CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
p_tap_nine] and
p_source_chng
j) Consult on required actions in response to treatment change
The hours per system multiplied
by the State labor rate.
(hrs_coop_treat_chng_
js*rateJs)
Cost applies as
written for primacy
agencies to
NTNCWSs.
Below AL
States with any model
PWSs on reduced tap
sampling that have a change
in treatment
1 - [p_tap_annual +
p_tap_triennial +
p_tap_nine] and
p treat change
Once per
event
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; LCR = Lead and
Copper Rule; NTNCWS = non-transient non-community water system; PWS = public water system.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• p_tap_annual, p_tap_triennial, and p_tap_nine: Likelihood a system will qualify to collect lead tap
samples at. an annual, triennial, and nine-year frequency, respectively (Chapter 3, Section 3.3.7.1).
• p_treat_chng: Likelihood that a system will change treatment in a given year (Chapter 3, Section 3.3.9.3).
• p_source_chng: Likelihood a system will have a source change (Chapter 3, Section 3.3.9.1).
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
B.9.3.4 State CCT Activities Unique to the Pre-2021 LCR
The EPA developed State cost for CCT activities unique to the pre-2021 LCR as shown in Exhibit B-150.
The exhibit provides the unit burden for each activity. The third column provides the corresponding
SafeWater LCR model data variables in red/italic font. The last column indicates that the activity is
unique to the pre-2021 LCR. A description of these activities follows the exhibit.
Exhibit B-150: State CCT Activities Unique to the Pre-2021 LCR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
k) Determine need for a CCT
study
4 to 16 hrs/system serving
<50K
hrs_lcr_studyJs
No. Unique to the
pre-2021 LCR.
I) Determine type of CCT for
systems without a study
20 to 80 hrs/system serving
<50K
hrsjcr_cctJs
No. Unique to the
pre-2021 LCR.
m) Determine need for a
revised CCT study
4 to 16 hrs/system serving
<50K
hrsjcr_studyJs
No. Unique to the
pre-2021 LCR.
n) Determine type of CCT
adjustment for systems
without a study
20 to 80 hrs/system serving
<50K
hrsjcr_cctJs
No. Unique to the
pre-2021 LCR.
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Acronyms: CCT = corrosion control treatment; LCR =
Improvements.
Source: "CCT Study and Review Costs_Final.xlsx."
Lead and Copper Rule; LCRI = Lead and Copper Rule
k) Determine need for a CCT study (hrs_lcr_study_js). The EPA estimated that States would require 4
hours, 8 hours, and 16 hours to determine if systems serving 3,300 or fewer people, 3,301 to 10,000
people, and 10,001 to 50,000 people, respectively, would need to conduct a study prior to installing
CCT. The EPA based the burden for this decision on responses provided by North Carolina to an
ASDWA 2016 questionnaire (available in the docket at EPA-HQ-OW-HQ-2017-0300 at
www.regulations.gov) for systems serving 3,300 or fewer people and systems serving 10,001 to
50,000 people. North Carolina did not provide an estimate for systems serving 3,301 to 10,000
people and the EPA assumed 50 percent of the burden needed for those serving 10,001 to 50,000
people. All assumed 0 burden for those serving more than 50,000 people because these systems
should already have CCT in place.
I) Determine type of CCT for systems without a study (hrs_lcr_cctJs). Exhibit B-151 provides the data
variable and inputs values associated with the States determination of the type of required CCT for
systems that do not conduct a CCT study. The estimates are based on North Carolina and Indiana's
responses to a 2016 ASDWA questionnaire. North Carolina reported that determining CCT without a
study would take 24 hours for systems serving < 100 people to 80 hours for those serving 10,001 to
50,000 people. Indiana responded that this would take 16 hours for systems serving < 100 people to
80 hours for those serving 10,001 to 50,000 people. The EPA assumed 20 hours (averaging 16 and 24
hours from North Carolina and Indiana) for systems serving < 100 people and 80 hours for systems
serving 10,001 to 50,000 people, which was the estimate reported by both States. For the size
categories in between, the EPA assumed 40 hours for those systems serving 101 to 1,000 people
and 60 hours for those serving 3,301 -10,000 people.
Exhibit B-151: Estimated Burden to Determine CCT for Systems with No Study
System Size
(Population Served)
Determine CCT when study is NOT required
(hrs/system)
(hrs_lcr_cctJs)
<100
20
101-1,000
40
1,001-10,000
60
10,001-50,000
80
> 50,000
N/A
Acronyms: CCT = corrosion control treatment.
Source: "CCT Study and Review Costs_Final.xlsx."
Note: The shaded row indicates size categories that are not subject to these requirements because with very
few exceptions, systems serving > 50,000 were already required to conduct a CCT study and install CCT under
the pre-2021 LCR.
An important input in estimating total State costs for this activity is the likelihood that the State will
require a study. The EPA estimated the likelihood of a CCT study (p_cct_study) for LSL and non-lead
service line systems based on the recommendations in the OCCT Recommendations Document
(USEPA, 2019). For detailed approach and values, see Section B.8.2.1.
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m) Determine need for a revised CCT study (hrs_lcr_study_js). States have discretion to determine if a
system serving 50,000 or fewer people must revise their CCT study. The EPA assumed this activity
will require the same burden as determining the need for a CCT study and used the same data
variable of hrs_lcr_study_js. See activity k) for data inputs and assumptions.
n) Determine CCT adjustment for systems without a revised study (hrs_icr_cctJs). For systems serving
50,000 or fewer people that do not revise their CCT study, States will determine the needed CCT
adjustment. The EPA assumed this activity will require the same burden as determining CCT when
no study is done and used the same data variable for hrs_lcr_cct_js. See activity I) for data inputs
and assumptions.
To estimate the likelihood that the State will determine the needed CCT adjustment without a
revised study, the EPA used the likelihood that State will require a new CCT study (p_cct_study) as
described in Section B.8.2.1. The EPA assumed that all systems serving more than 50,000 people will
revise their study.
Exhibit B-152 provides the SafeWater LCR model cost estimation approach for State activities that are
unique to the pre-2021 LCR including additional cost inputs that are required to calculate total costs.
Exhibit B-152: State Activities Unique to the Pre-2021 LCR Cost Estimation in SafeWater LCR
by Activity1
State Cost Per Activity for
CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
k) Determine need for a CCT study
The hours per system multiplied
by the State labor rate.
(hrsjcr_studyjs*rateJs)
Cost applies as
written to States
for NTNCWSs.
Above AL
States with any model
PWSs installing CCT
One time
1) Determine type of CCT for systems without a study
The hours per system multiplied
by the State labor rate.
(hrs_lcr_cctJs *rateJs)
Cost applies as
written to States
for NTNCWSs.
Above AL
States with any model
PWSs installing CCT without
conducting a study on the
installation of CCT
1 - p_cct_study
One time
m) Determine need for a revised CCT study
The hours per system multiplied
by the State labor rate.
(hrsjcr_studyjs*rateJs)
Cost applies as
written to States
for NTNCWSs.
Above AL
States with model PWSs re-
optimizing CCT
One time
n) Determine CCT adjustment for systems without a revised study
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State Cost Per Activity for
CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
The hours per system multiplied
by the State labor rate.
(hrs_lcr_cctJs*rateJs)
Cost applies as
written to States
for NTNCWSs.
Above AL
States with-model PWSs re-
optimizing CCT that are not
required to first conduct a
CCT study
1 - p_cct_study
One time
Acronyms: AL = action level; CCT = corrosion control treatment; CWS = community water system; NTNCWS = non-
transient non-community water system; PWS = public water system.
Notes:
1 The data variables in the exhibit are defined previously in this section with the exception of:
• p_cct_study: Likelihood a State will require a CCT study (Section B.8.2.1).
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
B.9.4 State Lead Service Line Testing and Replacement under the Pre-2021 LCR
Under the pre-2021 LCRI, States did not incur the one-time burden associated with the new SLR
program oversight responsibilities described in Chapter 4, Sections 4.4.4.1 through 4.4.4.3, activities a)
through g) that pertain to inventory, plan development and revision, and reassessment of deferred SLR
rates. Thus, these activities are not discussed in this section.
For the pre-2021 LCR, the EPA developed State costs for two ongoing activities associated with the
review of water systems' LSL testing and LSLR program activities as shown in Exhibit B-153. The third
column provides the corresponding SafeWater LCR model data variables in red/italic font. The last
column indicates whether the activity, unit burden, the SafeWater LCR model data variable, and/or
applicability are identical to those used for the final LCRI, as described in Chapter 4, Section 4.4.4.2. The
assumptions that differ from the 2021 LCRR follow the exhibit.
Exhibit B-153: State Ongoing LSL Testing and Replacement-Related Costs Burden Estimates1
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final LCRI?
h) Review annual SLR program
report
1 to 4 hrs/CWS;
1 hr/NTNCWS
hrs_report_lcrJs
Yes.2
i) Review report on lead tap
samples following partial LSLR
0.5 hrs/CWS
hrs_report_plslrJs
No. Unique to the
pre-2021 LCR.
Acronyms: CWS = community water system; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule
Improvements; LSLR = lead service line replacement; NTNCWS = non-transient non-community water system; SLR
= service line replacement.
Source: "LSLR Ancillary Costs_Final.xlsx."
Notes:
1 As previously discussed in Sections B.8.3.2 and B.8.3.3, Arkansas, Louisiana, Mississippi, Missouri, and South
Carolina pay for the cost of bottles, analysis, and providing sample results to the system as part of their State's LCR
oversight and implementation responsibilities (ASDWA, 2020a). Thus, these States will incur the burden and cost
to provide sample bottles and conduct lead sample analyses.
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2 Although the report content under the annual LSLR reports differ between the pre-2021 LCR and final LCRI, the
EPA assumed the State would incur a similar burden to review this report and thus, used the same data variable
name and input for both rules. Refer to Chapter 4, Section 4.4.4.3, activity h) for additional detail.
i) Review report on lead tap samples following partial LSLR (hrs_report_plslrJs). States will incur
annual burden to review CWS's submittal of LSL sample results following partial LSLR. As previously
stated, NTNCWSs are assumed to conduct full replacements and such would not be providing these
sample results. The EPA assumed States will require 0.5 hours to review these results based on the
2022 Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal), Exhibit
35 (Partial LSL Letter) (USEPA, 2022).
Exhibit B-154 provides the SafeWater LCR model cost estimation approach for State LSLR activities and
indicates if the approach is the same for the pre-2021 LCR as that used for the final LCRI, as provided in
Chapter 4, Exhibit 4-177. It also includes additional cost inputs that are required to calculate these costs.
Exhibit B-154: State Lead Service Line Replacement Cost Estimation in SafeWater LCR by
Activity1,2
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity3
Lead 90th
- Range
Other Conditions
h) Review annual SLR program report
Same as final LCRI (see Exhibit 4-177 in Chapter 4).
i) Review report on lead tap sampling following partial LSLR
The hours per system multiplied by
the State labor rate.
(hrs_report_plslrJs*rateJs)
Cost does not
apply to State for
NTNCWSs.
Above AL
States with systems
complying with the
mandatory LSLR
program
Once a
year
Acronyms: AL = action level; CWS = community water system; LCRI = Lead and Copper Rule Improvements; LSLR =
lead service line replacement; NTNCWS = non-transient non-community water system; SLR = service line
replacement.
Notes:
1 Under the pre-2021 LCR, these activities could stop after the system no longer has a lead ALE for two
consecutive, six-month monitoring periods.
2 The data variables in the exhibit are defined previously in this section with the exception of:
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
3 As previously discussed in Sections B.8.3.2 and B.8.3.3, in Arkansas, Louisiana, Mississippi, Missouri, and South
Carolina the State pays for the cost of bottles and shipping and conducting the analysis for samples following LSLR
(ASDWA, 2020a). Thus, the State will incur the burden and cost for these activities.
B.9.5 State Lead Public Education and Outreach under the Pre-2021 LCR
Under the pre-2021 LCR, States incurred oversight burden associated with PE that is required for water
systems that exceed the lead AL of 15 ng/L. These oversight activities are provided in Exhibit B-155. The
exhibit provides the unit burden for each activity. The third column provides the corresponding
SafeWater LCR model data variable in red/italic font. The last column indicates whether the activity, unit
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burden, and the SafeWater LCR model data variable are identical for the pre-2021 LCR to those used for
the final LCRI, as described in Chapter 4, Section 4.4.6.3. The gray shaded row indicates an activity that is
not required under the pre-2021 LCR.
Note that the final LCRI, includes additional PE, outreach, and notification State oversight activities
associated with expedited consumer notice of individual sample tap sample results, requirements that
are independent of a systems lead 90th percentile level, and those that are triggered when a system has
more than one lead ALE in a five-year period. Those requirements are not included in this section but
are detailed in Chapter 4, Sections 4.4.6.1, 4.4.6.2, and 4.4.6.4, respectively, as activities a) through m)
and q) through t).
Exhibit B-155: State PE Burden in Response to Lead ALE under the Pre-2021 LCR
Activity
Unit Burden
SafeWater LCR Data
Variable
Same As Final
LCRI?
n) Provide templates for
updated public education
materials for systems with a
lead ALE (one-time)
N/A
hrs_ale_lang_tempJs
N/A under the
pre-2021 LCR.
o) Review revised lead
language (one-time)
N/A
hrs_ale_langjs
N/A under the
pre-2021 LCR.
p) Consult with CWS on other
public education activities
in response to lead ALE
2 hrs/CWS
hrs_ale_consultJs
Yes.
q) Review public education
certifications
CWSs
1 to 1.5 hrs/CWS
NTNCWSs
0.33 to 0.5 hr/NTNCWS
CWSs
hrs_pe_certify_quarterlyJs
NTNCWSs
hrs_cert_outreach_annualJs
Yes.
Acronyms: ALE = action level exceedance; CWS = community water system; LCR = Lead and Copper Rule; LCRI =
Lead and Copper Rule Improvements; NTNCWS = non-transient non-community water system.
Sources:
p): "Public Education lnputs_CWS_Final xlsx.
q): "Public Education lnputs_CWS_Final.xlsx; "Public Education lnputs_NTNCWS_Final.xlsx."
Exhibit B-156 shows the SafeWater LCR model cost estimation approach for State PE activities including
additional cost inputs that are required to calculate these costs under the pre-2021 LCR. The exhibit also
indicates if the approach is the same as that used for the final LCRI, as provided in Chapter 4, Exhibit 4-
189, as well an activity that does not apply under the pre-2021 LCR in a gray shaded row.
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Exhibit B-156: State Lead ALE Public Education Costing Approach in SafeWater LCR by Activity
under the Pre-2021 LCR1,2
State Cost Per Activity for CWSs
State Cost Per
Activity for
NTNCWSs
Conditions for Cost to Apply to a
State
Frequency
of Activity
Lead 90th
- Range
Other Conditions
n) Provide templates for updating public education materials for systems with a lead ALE
N/A under the pre-2021 LCR. Assumed to have already occurred for all model PWSs with a lead ALE.
o) Review revised lead language for systems with a lead ALE
N/A under the pre-2021 LCR. Assumed to have already occurred for all model PWSs with a lead ALE.
p) Consult with CWS on other PE activities in response to lead ALE
Same as final LCRI (see activity p) in Exhibit 4-189 in Chapter 4).
q) Review public education certifications
The hours per system multiplied by
the State labor rate.
(hrs_pe_certify_quarterlyJs*rateJs)
The hours per
system multiplied
by the State labor
rate.
(hrs_cert_outreach
annual js*rate js)
Above AL
All States
Once a
year3
Acronyms: AL = action level; ALE = action level exceedance; CWS = community water system; LCR = Lead and
Copper Rule; LCRI = Lead and Copper Rule Improvements; NTNCWS = non-transient non-community water system;
PE = public education.
Notes:
1 States can discontinue these activities when the system no longer has a lead ALE for one monitoring period.
2 The data variables in the exhibit are defined previously in this section with the exception of:
• rateJs: State hourly labor rate (Chapter 3, Section 3.3.11.2).
3 The State will review certifications quarterly for CWSs. For modeling purposes, the State burden is estimated on
an annual basis. Under the final LCRI this cost is aggregated under the public education activities regardless of lead
90th percentile level and corresponds to activity m) that is included in Chapter 4, Section 4.4.6.2.
B.10 References
Association of State Drinking Water Administrators (ASDWA). 2020a. States LCRR Compliance
Monitoring Costs 03172020. May 17, 2020.
ASDWA. 2020b. Costs of States Transactions Study (CoSTS) for EPA's Proposed LCRR. February 6, 2020.
ASDWA. 2024. Costs of States Transactions Study (CoSTS). February 5, 2024. Submitted by ASDWA as
part of their comments on the proposed Lead and Copper Rule Improvements.
American Water Works Association (AWWA). 2005. Strategies to Obtain Customer Acceptance of
Complete Lead Service Line Replacement. Denver, CO. Available at
https://www.awwa.Org/Portals/0/AWW A/Government/StrategiesforLSLs.pdf?ver=2013-03-29-132027-
193.
Environmental Defense Fund and American University School of Public Affairs. 2020. Lead Pipes and
Environmental Justice: A Study of Lead Pipe Replacement in Washington, DC. March 2020. Available at
Final LCRI Economic Analysis Appendices
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https://www.edf.org/sites/default/files/u4296/LeadPipe EnvironJustice AU%20and%20EDF%20Report.
pdf?utm source=presentation&utm campaign=edf-
health none upd hlth&utm medium=referral&utm id=1597699006.
Office of Management and Budget (OMB). (2003). Circular A-4. Obama White House Archives.
https://obamawhitehouse.archives.gov/omb/circulars a004 a-4/.
Pasadena, Texas. Frequently Asked Questions - Water Meters. Frequentlv-Asked-Questions—Water-
Meters-PDF (pasadenatx.gov). No date.
United States Environmental Protection Agency (USEPA). 2007. Economic and Supporting Analyses:
Short-Term Regulatory Changes to the Lead and Copper Rule. September 2007. Office of Water. EPA-
815-R0-7022. Available at https://nepis.epa.gov/Exe/ZvPDF.cgi?Dockev=P100150Y.txt.
USEPA. 2009a. 2006 Community Water System Survey Volume I: Overview. February 2009. Office of
Water. EPA 815-R-09-001. Available at https://www.epa.gov/dwreginfo/communitv-water-system-
survev.
USEPA. 2009b. 2006 Community Water System Survey Volume II: Detailed Tables and Survey
Methodology. May 2009. Office of Water. EPA 815-R-09-002. Available at
https://nepis.epa.gov/Exe/ZyPDF.cgi/P1009USA.PDF?Dockev=P1009USA.PDF.
USEPA. 2012. Economic Analysis for the Final Revised Total Coliform Rule. September 2012. Office of
Water. EPA 815-R-12-004. Available at
https://nepis.epa.gov/Exe/ZvPDF.cgi/P100PIVQ. PDF?Dockev=P100PIVQ. PDF.
USEPA. 2019. Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primacy
Agencies and Public Water Systems. March 2016 (Updated 2019). Office of Water. EPA 816-B-16-003.
https://www.epa.gov/dwreginfo/optimal-corrosion-control-treatment-evaluation-technical-
recommendations.
USEPA. 2020. Economic Analysis for the Final Lead and Copper Rule Revisions. December 2020. Office of
Water. EPA 816-R-20-008.
USEPA. 2022. Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (Renewal).
Submitted to OMB for review and approval on March 24, 2023. (EPA ICR Number 1896.12, OMB Control
Number 2040-0204).
USEPA. 2023. Technologies and Costs for Corrosion Control to Reduce Lead in Drinking Water. August
2023. Office of Water.
USEPA. 2024. National Primary Drinking Water Regulations Lead and Copper Rule: Improvements (LCRI).
Final Rule.
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Appendix C: Costs and Benefits of the Final LCRI as Compared to the
pre-2021 LCR
C.l Introduction
In the primary economic analysis (EA), the EPA used the final Lead and Copper Rule Revisions (2021
LCRR) regulatory framework as the baseline for the estimated incremental costs and benefits of the final
Lead and Copper Rule Improvements (LCRI) (see Chapters 4, 5, and 6). This choice of baseline in the
primary EA is consistent with Office of Management and Budget (OMB) guidance in Circular A4 (OMB,
2023). Circular A4 states that the proposed regulations "are generally measured against a no-action
baseline: an analytically reasonable forecast of the way the world would look absent the regulatory
action being assessed." Absent in the final regulatory changes in this final LCRI rulemaking, the 2021
LCRR would remain in effect and best represents the future regulatory framework and costs faced by
public water systems (PWSs) and the resultant social benefits that would accrue to the public free of
additional regulatory action.
Because most of the regulatory requirements of the 2021 LCRR have not been implemented as of the
date of this final rule the EPA for informational purposes, in this appendix, estimated the incremental
costs and benefits of the final LCRI using the pre-2021 Lead and Copper Rule (LCR) as the baseline
regulatory framework. The results shown are the incremental costs and benefits of the final LCRI if the
requirements of the 2021 LCRR to be implemented after October 24, 2024, had not been promulgated.
These results will assist stakeholders that are more familiar with the current, or pre-2021 LCR, state of
the world with understanding the potential estimated impacts of the final LCRI.
C.2 National Costs and Benefits with pre-2021 LCR Baseline
At a discount rate of 2 percent, the annual monetized incremental costs of the final LCRI, when
compared to the pre-2021 LCR baseline, ranges from $1.8 billion to $2.4 billion (Exhibit C-l).
As seen in Exhibit C-2, the annual monetized incremental benefits of the final LCRI, when compared to
the pre-2021 LCR baseline, ranges from $16.2 billion to $34.6 billion at a 2 percent discount rate.
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Exhibit C-l: Estimated National Annualized Monetized Incremental Costs of the Final LCRI at 2 Percent Discount Rate (pre-2021
LCR Baseline, millions of 2022 dollars)
Low Estimate
High Estimate
Baseline
LCRI
Incremental
Baseline
LCRI
Incremental
PWS Annual Costs
Sampling
$75.8
$166.0
$90.2
$76.7
$176.2
$99.5
PWS SLR*
$1.3
$1,259.0
$1,257.7
$12.2
$1,763.9
$1,751.7
Corrosion Control Technology
$429.1
$591.1
$162.0
$476.7
$692.9
$216.2
Point-of Use Installation and
Maintenance
$0.0
$5.1
$5.1
$0.0
$9.6
$9.6
Public Education and Outreach
$0.3
$267.3
$267.0
$0.8
$302.2
$301.4
Rule Implementation and
Administration
$0.0
$3.4
$3.4
$0.0
$3.4
$3.4
Total Annual PWS Costs
$506.5
$2,291.9
$1,785.4
$566.4
$2,948.2
$2,381.8
Household SLR Costs**
$0.9
$0.0
-$0.9
$9.5
$0.0
-$9.5
State Rule Implementation and
Administration
$10.6
$66.1
$55.5
$11.0
$67.6
$56.6
Wastewater Treatment Plant Costs***
$0.5
$3.0
$2.5
$1.3
$5.1
$3.8
Total Annual Rule Costs
$518.5
$2,361.0
$1,842.5
$588.2
$3,020.9
$2,432.7
Acronyms: LCRI = Lead and Copper Rule Improvements; SLR = lead service line replacement; PWS = public water system.
Notes: Previous Baseline costs are projected over the 35-year period of analysis and are affected by the EPA's assumptions on three uncertain variables which
vary between the low and high cost scenarios.
*Service line replacement includes full and partial lead service lines and galvanized requiring replacement service lines.
** The EPA in the Economic Analysis for the Final Lead and Copper Rule Revisions (hereafter referred to as the "Final 2021 LCRR EA") (USEPA, 2020b) assumed
that the cost of customer-side service line replacements made under the pre-2021 LCR service line replacement requirements (baseline for the 2021 LCRR EA)
would be paid for by households. The agency also assumed that system-side service line replacements under the pre-2021 LCR requirements would be paid by
the PWS. The EPA made these modeling assumptions based on information the agency had about previous pre-2021 LCR replacement projects. Also, as part of
the 2021 LCRR EA, the EPA assumed that service line replacement conducted under the 2021 LCRR final rule 3 percent mandatory replacement requirement
would be paid for by PWSs. This assumption followed from the fact that failure to meet the 2021 LCRR mandatory LSLR requirement would be a violation and
could motivate more systems to meet the replacement target even if they had to adopt customer incentive programs that would shift the cost of replacing
customer-side service lines from customers to the system. To be consistent with these 2021 LCRR modeling assumptions, for purposes of the EA of the final
LCRI, the EPA assumed that mandatory replacement costs would fall only on systems. Therefore, the negative incremental values reported for the "Household
Final LCRI Economic Analysis Appendices
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SLR Costs" category do not represent a net cost savings to households. They represent an assumed shift of the estimated service line replacement costs from
households to systems. The EPA made this assumption for the final LCRI because it has insufficient information to estimate the actual service line replacement
cost sharing relationship between customers and systems at the national level of analysis and therefore defaults to the most conservative assumption by
placing all replacement costs on the system. Moreover, as explained in section V.B.5, subsection Assessment of Service Line Replacement Cost-Sharing
Prohibition in the Federal Register Notice for this rulemaking, the EPA has not used its section 1412 authority under the Safe Drinking Water Act (SDWA) to
direct how a water system covers the costs of compliance with a national primary drinking water rule, which is, at its core, a matter of State and local law.
***Due to many water systems operating both the wastewater and drinking water systems, the EPA is evaluating the costs of additional phosphate usage for
informational purposes. These costs are not "likely to occur solely as a result of compliance" with the final LCRI, and therefore are not costs considered as part
of the Health Risk Reduction and Cost Analysis (HRRCA) under SDWA, Section 1412(b)(3)(C)(i)(lll).
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Exhibit C-2: Estimated National Annualized Monetized Incremental Benefits of the Final LCRI
at 2 Percent Discount Rate (pre-2021 LCR Baseline, millions of 2022 dollars3)
Low Estimate
High Estimate
Baseline
LCRI
Incremental
Baseline
LCRI
Incremental
Annual IQ Benefits
$124.5
$6,831.3
$6,706.8
$611.4
$10,963.0
$10,351.6
Annual Low-Birth
Weight Benefits
$0.1
$5.4
$5.3
$0.4
$5.7
$5.3
Annual ADHD Benefits
$3.4
$196.3
$192.9
$33.1
$599.5
$566.4
Annual Adult CVD
Premature Mortality
Benefits
$179.9
$9,454.3
$9,274.4
$1,531.3
$25,210.0
$23,678.7
Total Annual Benefits
$307.9
$16,487.3
$16,179.4
$2,176.2
$36,778.2
$34,602.0
Acronyms: ADHD = attention-deficit/hyperactivity disorder; CVD = cardiovascular disease; IQ = intelligence
quotient; LCR = Lead and Copper Rule; LCRI = Lead and Copper Rule Improvements.
Notes: aThe economic value of each avoided health effect is described in Chapter 5, Section 5.5.
C.3 References
Office of Management and Budget (OMB). (2023). Circular A-4. November 9, 2023. Retrieved from
https://www.whitehouse.gov/wp-content/uploads/2023/ll/CircularA-4.pdf.
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Appendix D: Adverse Health Effects Associated with Lead Exposures
This appendix provides a qualitative discussion of the adult and child health effects associated with lead
exposure, which are anticipated to be reduced by the rule. The health effects discussed in this chapter
were identified using two comprehensive U.S. Government documents summarizing the literature on
lead exposure and its health impacts: EPA's Integrated Science Assessment for Lead (USEPA, 2024)
(hereafter referred to as the EPA ISA) and the U.S. Department of Health and Human Services' National
Toxicology Program Monograph on Health Effects of Low-Level Lead (National Toxicology Program,
2012) (hereafter referred to as the NTP Monograph). Both sources present comprehensive reviews of
the literature on adverse human health effects associated with lead exposures. Specifically, the EPA ISA
reviewed the literature published since its 2006 review of health outcomes associated with all levels of
lead exposure. The NTP Monograph reviewed available literature on lead exposures resulting in blood
lead levels <10 micrograms per deciliter (ng/dL), as these are representative of current U.S. lead
exposure levels, and at the time the review was conducted, health effects above 10 ng/dL were well
documented (NTP, 2012 p. XV).53
The EPA ISA and the NTP Monograph both provide conclusions on the association between lead
exposure and adverse human health outcomes. The EPA (2024) ISA uses a five-level hierarchy to classify
the weight of evidence for causation based on epidemiological and toxicological studies. This section
primarily discusses health endpoints assigned causal determinations in the top two levels of the
hierarchy. These top two categories are:
• Causal relationship: Pollutant (Contaminant) has been shown to result in health effects in
studies in which chance, bias, and confounding could be ruled out with reasonable confidence.
• Likely to be a causal relationship: Pollutant (Contaminant) has been shown to result in health
effects in studies in which chance and bias can be ruled out with reasonable confidence, but
potential issues remain.
Similarly, the NTP Monograph conducted a review of the epidemiological literature for the association
between low-level lead exposure (defined by blood lead levels <10 ng/dL) and select health endpoints,
and categorized their conclusions using a four-level hierarchy. This section primarily discusses health
endpoints assigned conclusions in the top two levels of the NTP Monograph hierarchy. These top two
categories are:
• Sufficient evidence of association: Chance, bias, and confounding could be ruled out with
reasonable confidence.
• Limited evidence of association: Chance, bias, and confounding could not be ruled out with
reasonable confidence.
Among the causal and likely to be causal health endpoints in the EPA (2024) ISA, and the sufficient and
limited evidence of association health endpoints in the NTP Monograph, eight categories of health
53 At the time the NTP monograph was being written, blood lead levels in both children and adults were
considered elevated if they were above 10 ng/dL (ABLES, 2009; CDC, 2007).
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effects were identified and are therefore discussed in this appendix: cardiovascular effects (Section D.l),
renal effects (Section D.2), reproductive and developmental effects (Section D.3), immune effects
(Section D.4), hypersensitivity and allergy response (Section D.5), resistance to bacterial infection
(Section D.6), neurological effects (Section D.7), and cancer (Section D.8). It is anticipated that a
reduction in lead exposures to adults and children due to the rule will subsequently result in a reduction
in the health effects associated with lead exposures described in this appendix. If expected changes in
exposure as a result of the rule are quantified, it would be possible to develop quantitative estimates of
changes in several of these health endpoints (see Chapter 5). Additionally, other health effects of lead
exposure not discussed in this appendix may also be reduced because of the final LCRI requirements.
D.l Cardiovascular Effects
Recent evidence suggests that exposure to lead may result in cardiovascular disease (CVD); specifically,
increases in hypertension, coronary heart disease (CHD), and CVD-related premature mortality (NTP,
2012; USEPA, 2024). Lead is thought to impact the cardiovascular system in several ways. According to
the EPA (2024) ISA, the mechanistic evidence from toxicological studies is strongest for the role of lead-
induced oxidative stress in hypertension. Evidence in the 2024 ISA further expands and supports the
multiple studies cited in the EPA (2013) ISA that show lead changes enzymatic activity, leading to an
increase in formation of reactive oxygen species, which results in increased risk of oxidative damage to
the cardiovascular system. Additionally, these reactive oxygen species interfere with nitrogen dioxide (a
vasodilator), resulting in the constriction of blood vessels and therefore an increase in blood pressure.
High blood pressure is a well-recognized risk factor for CVD and CVD-related premature mortality (Ezzati
et al., 2006).
Another potential mechanism through which lead may adversely affect the cardiovascular system is by
altering the normal function of vascular cells, including endothelial and vascular smooth muscle cells
(USEPA, 2024). For example, lead induces inflammatory damage to endothelial cells, which line the
interior of blood vessels and help to regulate blood pressure (Cines et al., 1998; USEPA, 2024). There is
also evidence that lead exposure stimulates migration and proliferation of vascular smooth muscle cells,
which are both significant events in the pathogenesis of atherosclerosis (USEPA, 2024). Atherosclerosis
is a key component of the pathological process of peripheral arterial disease, stroke, and coronary heart
disease, all of which can cause CVD premature mortality (CDC, 2004).
Lead may also exert cardiovascular toxicity through disruption of calcium homeostasis. Evidence
suggests that dysregulated calcium levels alter heart rate, which is associated with cardiovascular
morbidity and CVD premature mortality in older adults (USEPA, 2013). Calcium-induced pro-coagulant
activity may contribute to thrombosis, a risk factor for stroke and heart attack (USEPA, 2013). While the
EPA (2024) ISA did not assign causality determinations for specific cardiovascular endpoints, the
available evidence supported a causal relationship between lead exposure, cardiovascular effects, and
cardiovascular-related mortality as a category.
The remainder of Section D.l discusses specific evidence regarding potential effects of lead exposure on
cardiovascular health. Apart from blood pressure and hypertension (Section D.l.l) and
electrocardiogram (EKG) abnormalities (Section D.l.2), cardiovascular health outcomes are discussed for
adults only. This is because several of the longer-term cardiovascular morbidity and CVD premature
mortality endpoints typically do not manifest until later in life.
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D.l.l Blood Pressure and Hypertension
The association between lead and blood pressure or hypertension is the most widely studied of the
cardiovascular endpoints. Blood pressure is the force exerted by the heart against the walls of the
arteries and is measured in units of millimeters of mercury (mmHg). Systolic blood pressure is the
maximum pressure exerted during the pumping phase of the heartbeat. Diastolic blood pressure is the
minimum pressure in the arteries when the heart muscle relaxes between beats (National Toxicology
Program, 2012). Hypertension is the medical term for high blood pressure (currently, systolic blood
pressure >140 mmHg or diastolic blood pressure >90 mmHg) compared to an optimal blood pressure of
<120/80 mmHg. Blood pressures of 120-139/80-89 mmHg are considered prehypertension (National
Toxicology Program, 2012).
D. 1.1.1 Adults
The NTP Monograph assigned the highest categorization to the relationship between lead exposure and
hypertension. While the EPA (2024) ISA did not assign causality determinations for specific
cardiovascular endpoints, the available evidence supported a causal relationship between lead
exposure, cardiovascular effects, and cardiovascular-related mortality. Similar to findings from the 2013
ISA, the strong evidence for this conclusion comes from studies that consistently demonstrate the
effects of lead exposure on increased blood pressure and hypertension, including evidence from several
prospective epidemiologic studies that identified an association between higher blood and bone lead
levels and higher incidence of hypertension plus increased blood pressure in adults. The link between
lead levels and higher blood pressure is further supported by findings from studies using other study
designs including cross-sectional studies, meta-analyses, and animal studies. However, uncertainties
remain regarding the timing, frequency, duration, and level of lead exposure contributing to the blood
pressure effects observed in epidemiology studies (USEPA, 2024). The NTP Monograph states that there
is sufficient evidence of association between blood lead levels <10 ng/dL and increased blood pressure
and risk of hypertension (National Toxicology Program, 2012, p. 63). The NTP Monograph notes that two
meta-analyses (Navas-Acien et al., 2008; Nawrot, Thijs, Den Hond, Roels, & Staessen, 2002) concluded
that there is an association between lead exposure and hypertension.
Sensitive subpopulations may have unique lead related risks for increased blood pressure and
hypertension. In particular, pregnant women and post-menopausal women may experience the
mobilization of bone lead due to the body's effort to increase the amount of calcium in the blood stream
from bone stores (Gulson et al., 1997; S. J. Rothenberg, Khan, et al., 2000). The NTP Monograph states
that there is sufficient evidence of association between blood lead levels <10 ng/dL and increased blood
pressure and risk of hypertension during pregnancy (National Toxicology Program, 2012, p. 64).
However, it reports that the evidence is mixed for post-menopausal women.
D. 1.1.2 Children
Compared to adults, children have a much lower prevalence of CVD, which makes it difficult to
determine the relationship between lead exposure and cardiovascular endpoints. The 2024 ISA
reiterates the small amount of evidence suggesting a relationship between Pb exposure and BP and
hypertensive effects in children and notes that recent evidence supports the previous findings. Only a
handful of studies have been published examining cardiovascular endpoints in children. The NTP
Monograph found inadequate evidence of association to evaluate the potential association between
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blood lead and effects on blood pressure and hypertension in children (National Toxicology Program,
2012, p. 64). Since neither document reports strong evidence regarding lead exposure effects on blood
pressure and hypertension in children, this endpoint is not further discussed in this section.
D.1.2 Electrocardiogram Abnormalities
D. 1.2.1 Adults
The NTP Monograph concluded that there is limited evidence of association between blood lead <10
Hg/dL and EKG abnormalities (National Toxicology Program, 2012, p. 70). EKG abnormalities are changes
in the typical pattern of electrical activity of the heart, including the P wave (atrial activity), QRS wave
(ventricle activity), and T wave (return to resting state). The NTP Monograph concluded that
polymorphisms in iron metabolism genes may modify the relationship between lead and EKG
abnormalities. The NTP Monograph also concluded that there is inadequate evidence of an association
between lead exposure and heart rate variability due to inconsistent results among four publications on
lead and heart rate variability with mean blood lead levels <10 ng/dL (Gump et al., 2011; Jhun et al.,
2005; National Toxicology Program, 2012; S. K. Park et al., 2008; S. K. Park et al., 2006). Heart rate
variability is defined as changes in the interval between heartbeats (American Heart Association, 2011).
Heart rate variability "reflects sympathetic (low frequency) and parasympathetic (high and low
frequency) autonomic nervous system function, with decreases in variability indicating abnormal
autonomic function" (National Toxicology Program, 2012, p. 87). Several studies have examined the
relationship between lead exposures, as determined by blood or bone lead levels, and EKG
abnormalities using the Normative Aging Study54 population. In a study of 775 cohort men, bone lead (in
both the tibia and patella) was significantly associated with EKG abnormalities, but blood lead was not
(Cheng et al., 1998). A prospective study using 496 men from the Normative Aging Study also found tibia
lead to be significantly associated with changes in the heart's electrical activity over an 8-year follow-up
(Eum, 2011). Findings from a 2009 study reported bone lead to be significantly associated with specific
changes in the electrical activity of the heart (S. K. Park et al., 2009). These, however, were the only lead
exposure studies focusing on EKG abnormalities in the NTP Monograph. The EPA (2024) ISA mentions
that there was additional "epidemiologic and toxicological evidence for effects such as changes in
cardiac electrophysiology (e.g., electrocardiography measures of cardiac depolarization, repolarization,
and HRV), arrythmia, and markers of atherosclerosis"; however, the ISA did not assign a determination
for this endpoint (USEPA, 2024, pp. IS-43).
D. 1.2.2 Children
The NTP Monograph concluded that there is limited evidence of association between blood lead <5
Hg/dL and EKG abnormalities (National Toxicology Program, 2012, p. 75). The NTP Monograph
conclusion is based on findings from the Oswego Children's Study that revealed an association between
decreased stroke volume and increased total peripheral resistance in response to acute stress tasks and
54 The Normative Aging Study is a longitudinal study of U.S. men consisting mostly of veterans from World War II
and the Korean War.
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concurrent blood lead among 9.5-year-olds (Gump et al., 2011; Gump et al., 2007; Gump et al., 2005).
EKG abnormalities among children are not discussed in the EPA (2024) ISA.
D.1.3 Clinical Cardiovascular Conditions
Evidence from the EPA (2024) ISA supports a causal relationship between lead exposure, cardiovascular
effects, and cardiovascular-related mortality. This newer evidence further supports the evidence from
the 2013 ISA. The EPA (2024) ISA acknowledges that there is some uncertainty in the effects of timing,
frequency, duration, and level of lead exposures on cardiovascular outcomes. The NTP Monograph
found limited evidence of association between blood lead <5 ng/dL and general clinical CVD (National
Toxicology Program, 2012, p. 70). A recent meta-analysis supports these findings. Chowdhury et al.,
(2018) looked at 37 studies examining the relationship between metals and CVD in a systematic review.
In order to standardize the analysis, they compared top versus bottom thirds of baseline levels, pooled
relative risks and found a relative risk (confidence interval) for lead was 1.43 (1.16 to 1.76) for CVD, 1.85
(1.27 to 2.69) for coronary heart disease, and 1.63 (1.14 to 2.34) for stroke.
Atherosclerosis is the process where lipids, cholesterol, cellular waste products, calcium, and fibrin (a
clotting material in the blood) deposit or accumulate in the inner lining of an artery (American Heart
Association, 2014). The buildup that results is called plaque. Atherosclerosis is measured using various
indicators such as intima-media thickness, arterial stiffness, stenosis, and aortic media thickness. Several
studies have found associations between lead exposure and these indicators (Lee et al., 2009; Por^ba et
al., 2011a; Zelleretal., 2010).
Peripheral arterial disease is caused by atherosclerosis, which narrows the arteries and reduces the
amount of blood reaching tissues in a person's arms or legs. The NTP Monograph noted that for
conditions that are exacerbated by increases in blood pressure, such as peripheral arterial disease, there
has been a demonstrated increased risk from lead exposure. Studies have indicated that increased blood
lead levels are associated with a higher risk of peripheral arterial disease (Guallar et al., 2006; Muntner
et al., 2005; Navas-Acien et al., 2004).
As with peripheral arterial disease, coronary heart disease is also exacerbated by increases in blood
pressure. Evidence using a variety of lead measures (blood lead, bone lead and environmental levels,
e.g. airborne dust, has shown that higher lead levels are associated with increased risk of coronary heart
disease (Jain et al., 2007; Kim et al., 2008) and myocardial infarction (Afridi et al., 2010; Gustavsson et
al., 2001). Elevated blood lead is associated with left ventricular hypertrophy in the heart, an outcome
associated with coronary heart disease (Schwartz, 1991).
D.1.4 Cardiovascular Mortality
Lead-induced cardiovascular morbidity has implications for CVD premature mortality. CVD premature
mortality is defined as death attributed to heart or circulatory causes (National Toxicology Program,
2012, p. 62). The EPA (2024) ISA concluded that there is sufficient evidence that there is a causal
relationship between lead exposure, cardiovascular effects, and cardiovascular-related mortality.
Specifically, the EPA stated, "a large number of prospective cohort studies reported consistent
associations between body Pb concentrations and cardiovascular outcomes such as increased BP,
hypertension, and cardiovascular mortality." (USEPA, 2024, p.lS-42). The NTP concluded that there is
limited evidence of association between blood lead levels <10 ng/dLand increased mortality from
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cardiovascular causes and that the "association between increased CVD mortality and increased blood
Pb was supported by three prospective studies but not supported by two prospective studies, one of
which reported a significant association with bone Pb" (National Toxicology Program, 2012, p. 90).
However, several studies published after the NTP Monograph have found significant associations
between CVD premature mortality and lead exposure (Aoki et al., 2016; Lanphear et al., 2018; Ruiz-
Hernandez et al., 2017). However, differences in exposure metrics, timing of exposure, and extent of
exposure yield differences in estimates of risk. For further information on these studies, the reader is
referred to Chapter 5. An additional study, Duan et al., (2020) was published after the literature search
in the Abt Associates report which described the concentration-response functions used to support this
economic analysis (EA), was described in the 2024 Lead ISA. Duan et al., (2020) examined more recent
NHANES data (1999-2014), finding a relative risk ratio of 1.39 (95% CI: 1.28, 1.51) and is reported in the
2024 Lead ISA as finding "associations of similar magnitude" of the other studies used in the benefits
analysis described in Chapter 5.
Investigations of the association between lead exposure and CVD premature mortality have been
conducted using nationally representative cross-sectional data from the National Center for Health
Statistics' National Health and Nutrition Examination Survey (NHANES). Menke et al. (2006) evaluated
participants in NHANES with blood lead data collected between 1988 to 1994 and found a significant
relationship between blood lead levels and increased mortality after 12 years of follow-up. After
controlling for a large number of confounding factors including hypertension and kidney function, the
authors observed an association between lead exposure and cardiovascular mortality at a low mean
blood lead concentration (2.58 ng/dL). Analyses of smaller studies also find a positive relationship
between lead exposure and CVD-related premature mortality. A study of American 65- to 87-year-old
females, found a higher risk of combined CVD premature mortality and coronary heart disease mortality
among women with blood lead levels >8 ng/dL (Khalil et al., 2009).
The two studies cited in the NTP Monograph as the reason for the limited, rather than sufficient
evidence, of an association between lead exposure and CVD premature mortality are Moller &
Kristensen (1992) and Weisskopf et al. (2009). Moller & Kristensen (1992) examined the risk of
developing coronary heart disease and CVD using both fatal and non-fatal cases. The authors found a
significant univariate association between blood lead and total mortality, coronary heart disease, and
CVD. The statistically significant association was attenuated when the models included potential
confounders, although the association remained positive (i.e., an increase in blood lead was related to
an increase in mortality). The authors did not examine the risk of CVD premature mortality after
eliminating the non-fatal cases included in the analysis. Weisskopf et al. (2009) evaluated the
relationship between bone and blood lead and several health endpoints including all-cause, CVD-
related, and cancer-related deaths. The authors found bone lead, specifically patella lead, to be
associated with a slight increase in CVD premature mortality; however, this association was not
statistically significant.55 Weisskopf et al. (2009) did not find an association between blood lead and any
55 In a 2015 reanalysis, Weisskopf et al. found that, after further adjustment and application of methods to
decrease potential bias, the association between patella lead and CVD premature mortality reached statistical
significance. No associations between tibia or blood lead were found in the reanalysis.
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other mortality category.
Since the NTP Monograph was published, three new analyses of the NHANES data have found significant
associations between lead exposures and CVD premature mortality. Aoki et al. (2016) examined over
18,600 adults in NHANES 1999-2010 and found that hematocrit-corrected56 blood lead levels were
significantly associated with CVD premature mortality. Ruiz-Hernandez et al. (2017) examined changes
in uncorrected blood lead levels and CVD premature mortality between participants in NHANES 1988-
1994 and NHANES 1999-2004. The study found that declines in lead exposure were associated with
reductions in CVD premature mortalities. Lanphear et al. (2018) examined the same cohort as the
(Menke et al., 2006) study described above, but used a longer period of follow-up for CVD premature
mortality, allowing for additional deaths to be included in the analysis. The Lanphear et al. (2018)
analyses found significant associations between blood lead levels and CVD premature mortality, with
greater increases in CVD premature mortality for a given increase in blood lead observed in individuals
with blood lead levels below 5 ng/dL.
D.2 Renal Effects
The primary functions of the kidney include regulating water levels and balancing the levels of water and
essential chemicals in the body (USEPA, 2024). The key measurement that reflects kidney function is the
glomerular filtration rate (GFR), which estimates how much blood passes through the tiny filters in the
kidneys, called glomeruli, each minute (National Library of Medicine, 2015). The best method for
measuring GFR is very invasive and time consuming because it involves the measurement of
exogenously delivered radionuclide or radiocontrast markers in timed, sequential blood samples or
kidney imaging (USEPA, 2013). Therefore, alternative methods to measure kidney function have been
developed and used in health effect studies such as measuring serum creatinine, blood urea nitrogen,
cystatin C, and creatinine clearance.
D.2.1 Adults
The NTP Monograph concluded that there is sufficient evidence of an association between lead
exposure and decreased kidney function. Specifically, the NTP Monograph found sufficient evidence of
an association between blood lead levels <5 ng/dL and decreased GFR (National Toxicology Program,
2012, p. 80). The 2013 EPA ISA stated that the evidence of renal effects from lead exposure is suggestive
of a causal relationship based on multiple high-quality epidemiologic studies; however, the 2024 ISA has
updated the conclusion to be a causal relationship between Pb exposure and renal effects. "Notably,
prospective studies with baseline measures of renal function reduce uncertainty regarding potential
reverse causality, providing additional evidence of Pb-associated decrements in renal function in adult
populations with mean BLLs <5 ug/dL" (USEPA, 2024).
56 Aoki et al. (2016) corrected blood lead for hematocrit (i.e., the proportion of whole blood composed of red
blood cells) in order to take into account red blood cell counts. This is because the majority of lead in blood is
found in red blood cells but lead itself may cause red blood cell numbers to decrease. If lead decreases red blood
cell counts, then measuring uncorrected blood lead may result in an underestimation of the association between
blood lead and CVD premature mortality.
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Lead exposure was found to contribute to kidney effects in the general population. Several high-quality
epidemiology studies found an association between increased blood lead and increased serum
creatinine (C de Burbure et al., 2003; Kim et al., 1996; Lai et al., 2008; Muntner et al., 2003; Navas-Acien
et al., 2009; Staessen et al., 1990; Tsaih et al., 2004). Serum creatinine levels >30 mg/g indicate
albuminuria, or the presence of excess protein in urine; if persistent, albuminuria can indicate kidney
damage. The relationship between blood lead and serum creatinine was also identified as it pertains to
specific subpopulations. Specifically, Muntner et al. (2003) found an increased risk for elevated serum
creatinine in hypertensives but not normotensives. Additionally, Tsaih et al. (2004) found a relationship
between changes in serum creatinine and baseline blood and bone lead in diabetics but not
nondiabetics. Further, Staessen (1990) found a correlation between blood lead and serum creatinine
only in males, but not in females. Thus, the large outcomes from large population studies may be
impacted by comingling individuals with specific sensitivities with the general population.
Epidemiology studies using other markers of kidney dysfunction found similar associations between lead
levels and kidney dysfunction. Studies have observed an association between blood lead and decreased
creatinine clearance, which is another marker of kidney dysfunction (Akesson et al., 2005; Muntner et
al., 2005; Payton et al., 1994; Staessen et al., 1992). Similarly, studies measuring adverse renal effects by
measuring cystatin C as an indicator of kidney dysfunction have found a relationship between decreased
kidney function and blood lead (C. de Burbure et al., 2006; Fadrowski et al., 2010). Studies measuring
GFR57 as an indicator of kidney function have found an increased risk of decreased GFR with increasing
lead levels (Akesson et al., 2005; Muntner et al., 2005). Muntner et al. (2005) specifically found an
increased risk for chronic kidney disease in individuals with higher blood lead (1.63-2.47 ng/dL) when
compared to people with blood lead less than 1.06 ng/dL. In addition, the patterns between lead
exposure and decreased kidney function have been identified in adolescents (C. de Burbure et al., 2006;
Fadrowski et al., 2010). However, some research has found no association between blood lead and
adverse renal effects in the general population (Coria et al., 2009; Mortada, 2004) and in adolescents (C.
de Burbure et al., 2006; Fadrowski et al., 2010).
D.2.2 Children
The NTP Monograph concluded that there is limited evidence of association between blood lead levels
<5 ng/dL and decreased kidney function among 12- to 20-year-olds (National Toxicology Program, 2012,
p. 84). The limited evidence of association conclusion is based primarily on a study by Fadrowski et al.
(2010) using 1988-1994 NHANES III data that observed a relationship between blood lead levels and
decreased estimated GFR (eGFR, based on cystatin C) among 12- to 20-year-olds. The NTP Monograph
notes that the weight of this evidence is bolstered by the findings at similar lead levels in adults
((Needleman et al., 1990), p. 84). The EPA ISA does not assign a conclusion category for renal effects in
children but does note that recent studies of elevated lead exposure in children did not consistently
indicate reduced kidney function (Coria et al., 2009; Khan et al., 2010).
57 GFR is the ideal measurement for kidney function.
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D.3 Reproductive and Developmental Effects
Lead exposure has been linked to adverse reproductive and developmental effects including delayed
puberty, decreased postnatal growth, changes to sperm, decreased fertility, increased time to
conception, fetal development effects, and reduced gestational age.
D.3.1 Delayed Puberty
Measures of sexual maturation and puberty include age at menarche and Tanner developmental
staging58 of breasts, testicular volume, and pubic hair. The EPA (2024) ISA found a causal relationship
between lead exposure and developmental effects, which includes delayed puberty, based on the
epidemiology and toxicology literature. The NTP Monograph stated that there is sufficient evidence of
association between concurrent blood lead <10 ng/dL and delays in sexual maturation or puberty onset
in 8-to 17-year-olds, and limited evidence that blood lead <5 ng/dL is associated with delayed puberty
(Needleman et al., 1990, p. 94).The NTP Monograph's sufficient evidence conclusion is based on the
agreement of reported inverse associations between blood lead level and measures of sexual
maturation in eight cross-sectional studies and one prospective study (Denham et al., 2005; Gollenberg
et al., 2010; Hauser et al., 2008; Naicker et al., 2010; Selevan et al., 2003; Staessen et al., 2001; Tomoum
et al., 2010; Williams et al., 2010; Wu et al., 2003). The limited evidence conclusion was made based on
the availability of only four cross-sectional studies reporting associations between blood lead levels <5
Hg/dL and delayed markers of puberty (Denham et al., 2005; Selevan et al., 2003; Staessen et al., 2001;
Wu et al., 2003), coupled with a study reporting a lack of association in a cross-sectional study of girls
(Wolff et al., 2008). Several large, cross-sectional analyses using 1988-1994 NHANES III data have
reported delayed development in girls as determined by Tanner pubic hair and breast stages and age at
menarche with low levels of blood lead (Gollenberg et al., 2010; Selevan et al., 2003; Wu et al., 2003).
While fewer studies of delayed puberty have been conducted in boys, the limited evidence suggests
lead-related associations with decreased testicular volume, lower Tanner genital stages, and lower
Tanner stages of pubic hair development (Hauser et al., 2008; J. A. Staessen et al., 2001; Tomoum et al.,
2010; Williams et al., 2010). Similar associations have been found in studies conducted internationally
(Naicker et al., 2010; Tomoum et al., 2010). Associations between lead exposure and significant delays in
sexual maturation reported in these studies remained when adjusting for factors such as race, body
mass index, and socioeconomic status.
D.3.2 Postnatal Growth
The NTP Monograph found sufficient evidence of association between concurrent blood lead <10 ng/dL
in children and decreased postnatal growth (National Toxicology Program, 2012, p. 94), p. 94. Findings
from several cross-sectional studies and three prospective studies support the significant association
between concurrent blood lead levels and indicators of decreased postnatal growth in 1- to 16-year-
olds. For example, this association between blood lead and height has been observed through the
analysis of the 1988-1994 NHANES III data in 1-to 7-year-olds (Ballew et al., 1999), as well as in 8-to 16-
58 Tanner staging is a system frequently used for evaluating pubertal maturation. Tanner staging is based on five
stages of development and can be used to evaluate pubertal disorders.
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year-old girls (Selevan et al.,1984). Other effects of blood lead on postnatal growth reported in cross-
sectional studies include height, leg and arm length, head and chest circumference, and body weight
(Hauser et al., 2008; Ignasiak et al., 2006; Kafourou et al., 1997; Kordas et al., 2004; Little et al., 2009).
The NTP Monograph found limited evidence of an association between maternal blood lead levels and
postnatal growth. Specifically, the NTP Monograph noted limited evidence that maternal blood lead <10
Hg/dL is associated with decreased head circumference in children up to 4 years old based on three
prospective studies (National Toxicology Program, 2012, p. 98 ; Rothenberg et al., 1993; Rothenberg et
al., 1999; Schell et al., 2009). Lead exposure has also been shown to affect child height and body weight
later in life. A study of Mexican children found that increases in maternal bone lead during pregnancy
were associated with decreased body weight in 5-year-old girls (Afeiche et al., 2011).
Although the EPA ISA found a causal relationship between lead exposure and developmental effects, the
report notes that this causal determination is based on the findings of delayed pubertal onset among
males and females rather than postnatal growth. The EPA (2024) ISA stated that recent studies
examining the association between lead exposure and postnatal growth are inconsistent, "though
epidemiologic studies that examined BLLs, as opposed to other biomarkers, provide more consistent
patterns of inverse associations between Pb exposure and height and weight in children (8 mo to 11 yr)"
(USEPA, 2024, pp. IS-54).
D.3.3 Sperm Parameters
Sperm parameters include characteristics such as sperm count or concentration, sperm motility, and
sperm morphology. The EPA (2024) ISA concluded that there is sufficient evidence that there is a causal
relationship between lead exposure and male reproductive function, which includes sperm quality based
on animal toxicological studies showing detrimental effects on semen quality, sperm, and
fecundity/fertility with supporting evidence in epidemiology studies of associations between lead
exposure and detrimental effects on sperm. The NTP Monograph states that there is sufficient evidence
of association between blood lead levels >15 ng/dL and adverse changes in sperm parameters
predominantly based on occupational studies of men reporting effects at blood lead levels ranging from
15 to 50 ng/dL (National Toxicology Program, 2012, p. 98). Several studies found that higher blood or
semen lead was associated with lower sperm count or concentration (Alexander et al., 1998; Alexander
et al., 1996; Assennato et al., 1986; Bonde et al., 2002; Chowdhury et al., 1986; Fisher-Fischbein et al.,
1987; Lancranjan et al., 1975; Lerda, 1992; Mahmoud et al., 2005; Naha et al., 2005; Naha & Chowdhury,
2006; Naha & Manna, 2007; Robins et al., 1997; Telisman et al., 2000).
Higher blood or semen lead levels have also been found to be associated with decreased sperm motility
(Chowdhury et al., 1986; Kasperczyk et al., 2008; Lancranjan et al., 1975; Lerda, 1992; Naha &
Chowdhury, 2006; Naha & Manna, 2007). One study found that sperm motility improved in male battery
workers undergoing treatment to lower blood lead (Viskum et al., 1999). Abnormal sperm morphology is
also associated with lead exposure in the epidemiology literature (Chowdhury et al., 1986; Fisher-
Fischbein et al., 1987; Hsu et al., 2009; Lancranjan et al., 1975; Lerda, 1992; Naha et al., 2005; Naha &
Chowdhury, 2006; Naha & Manna, 2007; Robins et al., 1997; Telisman et al., 2000). The effect of lead on
sperm parameters at lower lead exposure levels is unclear based on the available literature. A threshold
below which blood lead levels will not exert an effect has not been clearly established. Recent
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toxicological data in the 2024 ISA support the findings in the 2013 ISA, specifically potential impact on
sperm or semen quality (e.g., sperm density, motility, morphology, etc.) (USEPA, 2024, p. IS-36).
D.3.4 Fertility and Time to Conception
Evidence indicates that lead exposure increases the risk of reduced fertility and increased time to
conception (reduced fecundity) in men. The EPA (2024) ISA determined that there is sufficient evidence
to conclude there is a causal relationship between male reproductive function and lead exposure based
primarily on toxicological studies. The NTP Monograph concluded that "there is sufficient evidence that
paternal blood levels > 20 ng/dL are associated with delayed conception time and limited evidence that
blood Pb levels > 10 ng/dL in men are associated with other measures of reduced fertility" (National
Toxicology Program, 2012, p. 104). The NTP Monograph states that their sufficient evidence of delayed
conception time conclusion is based on four studies reporting increased time to pregnancy with blood
lead levels of 20-40 ng/dL in men, and that the limited evidence of reduced fertility conclusion is also
based on these four studies plus a single large retrospective occupational study that reported increased
odds of infertility among men with blood lead levels >10 ng/dL. The inverse association between male
fertility and lead exposure appears to be present for males with above-average blood lead levels.
Several studies reported an increased time to pregnancy or decreased fecundability in men with blood
lead levels between 20 and 40 ng/dL (Apostoli et al., 2000; De Rosa, 2003; Sallmen et al., 2000; Shiau et
al., 2004). In addition, a study of male workers at a lead battery plant found decreased odds for a live
birth in the wives of lead workers with mean blood lead of 46 ng/dL compared to workers with mean
blood lead of 10 ng/dL or relative to pre-exposure (Gennart et al., 1992). Large occupational cohorts
have also demonstrated that blood lead > 10 ng/dL can lead to higher odds of male infertility (Sallmen et
al., 2000).
D.3.5 Spontaneous Abortions
The association between lead exposure and likelihood of spontaneous abortion has been investigated in
both men and women. The NTP Monograph states that there is limited evidence that maternal blood
lead <10 ng/dL is associated with spontaneous abortion (National Toxicology Program, 2012, p. 107).
This conclusion is based on a prospective nested case-control study by Borja-Aburto et al. (1999). NTP
also states that there is limited evidence that paternal blood lead >31 ng/dL is associated with
spontaneous abortions based on a retrospective nested case-control study by Lindbohm et al. (1991)
(National Toxicology Program, 2012, p. 107). Borja-Aburto et al. (1999) suggests increased odds of
spontaneous abortion for maternal blood lead <10 ng/dL. Borja-Aburto et al. (1999) found evidence for
a concentration-response relationship and significant odds ratios for spontaneous abortions (odds ratios
of 2.3, 5.4, and 12) with maternal blood lead during the first trimester of pregnancy of 5-9, 10-14, and
>15 ng/dL as compared to pregnant women with maternal blood lead of <5 ng/dL. Results from a
Chinese study of anembryonic pregnancy, as well as several occupational exposure studies, support
these findings (Faikoglu et al., 2006; Gundacker et al., 2010; Lamadrid-Figueroa et al., 2007; Yin et al.,
2008). Among women with a history of previous spontaneous abortions, evidence exists that the rate of
spontaneous abortion may be higher in women with higher plasma/blood lead ratios compared to
women with lower plasma/blood lead ratios (Lamadrid-Figueroa et al., 2007). Evidence also suggests
that women with higher placental lead levels were more likely to have had a previous miscarriage
compared to women with lower placental lead levels (Gundacker et al., 2010).
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As for paternal lead levels being associated with spontaneous abortions, several occupational studies
indicate that elevated blood lead is associated with increased odds of spontaneous abortion. A Finnish
study of men with occupational exposure to lead and with wives aged 18-40 found that paternal blood
lead >31 ng/dL was associated with higher odds of spontaneous abortion (odds ratio = 3.8 (95 percent
confidence interval: 1.2, 12)) compared to men with blood lead <21 ng/dL (Lindbohm et al., 1991).
Similar findings have been reported in other occupational epidemiology studies (Al-Hakkak et al., 1986;
Beckman & Nordstrom, 1982).
D.3.6 Reduced Fetal Growth/Low Birth Weight
When examining the reduced fetal growth/low birth weight outcome, there are several measures of
reduced growth or intrauterine growth restrictions: small for gestational age (babies with birth weight
below the 10th percentile for a given gestational age), lower birth weight (evaluated as a continuous
variable), and low birth weight (<2,500 grams after at least 37 weeks of gestation). Several indicators of
lead exposure can be used to examine the relationship between lead exposure and reduced fetal growth
including blood lead, bone (patella and tibia) lead, umbilical cord lead, placental lead, air lead, and
breast milk lead (2 months postpartum). The NTP Monograph states that there is sufficient evidence of
association between maternal blood lead <5 ng/dL and reduced fetal growth or lower birth weight
based on several prospective studies, a large retrospective cohort study of over 43,000 mother-infant
pairs by Zhu et al. (2010), and a number of cross-sectional studies with maternal or umbilical cord blood
lead at delivery (National Toxicology Program, 2012, p. 109). The EPA (2013) ISA combined all adverse
birth outcomes (i.e., neural tube defects, which are birth defects of the brain or spinal cord, preterm
birth, low birth weight) into one category, whereas the NTP Monograph reviewed measures of an
infant's birth weight (e.g., small for gestation age or lower birth weight) as a stand-alone category. The
EPA (2024) ISA concluded the evidence was likely to be a causal relationship between lead exposure and
adverse birth outcomes (i.e., neural tube defects, preterm birth, and low birth weight/fetal growth)
based on a "recent quasi-experimental study that reported Pb-related changes in birth weight and
probability of low birth weight, preterm birth, and small for gestational age, in addition to other studies
demonstrating effects between Pb exposure and preterm birth (Table 8.1)" (Appendix 8, UESPA, 2024).
The relationship between lead exposure and low birth weight (<2,500 grams after at least 37 weeks of
gestation) was investigated heavily using both maternal blood lead and cord blood lead levels. Many of
the studies looking at the effect of maternal blood lead on birth weight have found an inverse
relationship between this exposure metric and response (Bornschein et al., 1989; Cantonwine et al.,
2010; Dietrich et al., 1987; Ernhart et al., 1986; Gundacker et al., 2010; Kordas et al., 2009; Osman et al.,
2000; Srivastavaet al., 2001; Zhu et al., 2010). In the largest cohort study of the association to date, Zhu
et al. (2010) found that the slope of the association between birth weight and lead exposure was
steeper at lower blood lead levels. For example, a 2 ng/dL increase in blood lead would be expected to
decrease birth weight by approximately 40 grams given an initial blood lead level of 0 ng/dL and by 10
grams given an initial blood lead of 8 ng/dL. However, the magnitude of observed decreases in birth
weight varies by study. Several analyses found the relationship between blood lead and birth weight to
be linear. A handful of studies referenced in the EPA (2013) ISA and NTP Monograph did not find any
relationship between maternal blood lead and birth weight (Gonzalez-Cossio et al., 1997; Iranpour et al.,
2007; Loiacono et al., 1992; Rahman & Hakeem, 2003; Sowers et al., 2002). Since the documents were
published, several additional cohort studies have also found significant associations between lead
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exposure and decreased birth weight (Rabito et al., 2014; Taylor et al., 2014; Taylor et al., 2016). A few
have found evidence of an association only in certain segments of the population (e.g., women with low
calcium intake as in Hong et al., 2014) or only in male infants (Nishioka et al., 2014; Perkins et al., 2014).
Elevated cord blood lead was also shown to adversely affect infant birth weight (Atabeket al., 2007;
Bellinger et al., 1991; Cantonwine et al., 2010; Ernhart et al., 1986; Gundacker et al., 2010; Neuspiel et
al., 1994; Osman et al., 2000; Srivastava et al., 2001; Zentner et al., 2006). However, some studies have
not found the same association (Gonzalez-Cossio et al., 1997; Iranpour et al., 2007; Janjua et al., 2009;
Loiacono et al., 1992; Wells et al., 2011).
Placental lead has also been used to study the effects of lead exposure on low birth weight. Although
some studies have found that higher placental lead levels are associated with lower birth weight (Llanos
& Ronco, 2009; Ward et al., 1990), several have either not found an association or found a positive
association between placental lead level and birth weight (Gundacker et al., 2010; Odland, 2004;
Wibberly, 1977). Elevated bone lead levels were associated with lower birth weight in several studies
(Cantonwine et al., 2010; Gonzalez-Cossio et al., 1997; Kordas et al., 2009).
D.3.7 Preterm Birth and Gestational Age
The NTP Monograph states that there is limited evidence of an association between maternal blood lead
or umbilical blood lead <10 ng/dL and preterm birth or reduced gestational age (National Toxicology
Program, 2012, p. 112). Increases in maternal blood lead levels during pregnancy have been associated
with increased incidence of preterm birth in several prospective and cross-sectional studies
(Cantonwineet al., 2010; Dietrich et al., 1987; Fagheret al., 1993; Fahim et al., 1976; Jelliffe-Pawlowski et
al., 2006; McMichael et al., 1986; Vigeh et al., 2011). However, there is inconsistency among the results
using each of these metrics (National Toxicology Program, 2012, p. 114). In addition, a large
retrospective cohort (43,288 mother-infant pairs) from the New York State Heavy Metals Registry did
not find an association between maternal blood lead (mean, 2.1 ng/dL) and preterm birth (Zhu et al.,
2010). Associations between lead exposure and risk of preterm birth have also been observed when
examining umbilical cord blood lead (Cantonwine et al., 2010; Fagher et al., 1993; Fahim et al., 1976;
McMichael et al., 1986; Patel & Prabhu, 2009; Torres-Sanchez et al., 1999) and placental lead levels
(Falcon et al., 2003; Ward et al., 1990; Ward et al., 1987). Therefore, NTP assigned this endpoint a
conclusion of limited, rather than sufficient, evidence.
D.4 Immune Effects
The immune system is responsible for protecting organisms from foreign agents, such as microbes or
chemicals (Schultz & Grieder, 1987). The immune system is dependent on its ability to distinguish
between "self" and "non-self" initiators of response. White blood cells, antibodies, and other proteins
and chemical substances along with a complex signaling system are components of an immune
response. Immune function can be measured in several ways including by the level and function of
different immune cells (e.g., T-cells, B-cells, monocytes, macrophages, neutrophils, lymphocytes, or cells
involved in delayed-type hypersensitivity (DTH)); and immune cell secretions (e.g., cytokines). Immune
function can also be measured through the presence of antibodies (e.g., immunoglobulins such as IgE,
IgG, IgA); clinical indicators of allergy (e.g., positive skin prick tests); and the presence of immune-based
disease (e.g., asthma, autoimmunity).
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Health outcomes related to the immune system associated with lead exposure include increased
hypersensitivity and allergy response in children exposed prenatally (see Section D.5), and decreased
resistance to bacterial infections (see Section D.6).
D.5 Increased Hypersensitivity and Allergy Response
D.5.1 Adults
The EPA (2024) ISA found that the evidence is suggestive of but not sufficient to infer, a causal
relationship between Pb exposure and sensitization and allergic responses. "In contrast to evidence
presented in the 2013 Pb ISA (U.S. EPA, 2013), the recent studies provide little evidence of an
association between exposure to Pb and atopic disease, and inconsistent evidence for immunological
biomarkers involved in sensitization and allergic response" (USEPA, 2024). The NTP Monograph found
inadequate evidence in adults to address the potential association between blood lead <10 ng/dL and
IgE, allergy, eczema, or asthma in adults due to a general lack of studies at lower doses and
inconsistency in the available data ((National Toxicology Program, 2012, p. 45), p. 45). In adults, lead
exposure has been linked to changes in a spectrum of cellular and humoral immune responses including
changes in T lymphocyte and macrophage function, suppression of the DTH response, increased IgE
production, changes in cytokine production, and inflammation.
D.5.2 Children
The EPA (2024 ISA found that the evidence is suggestive of but not sufficient to infer, a causal
relationship between Pb exposure and sensitization and allergic responses.. "A considerable uncertainty
in the evidence base is the limited number of children with asthma in the cohort studies evaluated, both
in recent studies and in the 2013 Pb ISA. This decreases the statistical power to detect an association"
(USEPA, 2024). The NTP Monograph states that there is limited evidence of an association between lead
exposure and increased IgE in children. This conclusion is based on evidence for lead-related increases in
IgE from several cross-sectional studies (K.L. Hon, 2011; Hon et al., 2009; K.L. Hon et al., 2010; Karmaus
et al., 2005; Lutz et al., 1999; Sun et al., 2009). The NTP Monograph additionally concluded that there is
limited evidence of a link between lead exposures and increased allergic sensitization, based on the
aforementioned studies of lead and IgE together with a prospective study on allergic sensitization by
Jedrychowski et al. (2011) (National Toxicology Program, 2012, p. 49). Jedrychowski et al. (2011)
collected data on both concurrent and prenatal exposure in 5-year-olds and examined the allergic
sensitization or atopy (determined by a skin prick test) to common allergens administered when the
children were 5-year-olds. Maternal blood lead and umbilical cord blood lead were significantly
associated with frequency of sensitization in the children, but current blood lead levels were not. Data
from the Jedrychowski et al. (2011) study also showed a lead-associated increase in serum IgE. There is
also evidence that low levels of prenatal lead exposure (<10 ng/dL in blood) in adults is associated with
increased hypersensitivity and allergy in their offspring.
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D.6 Resistance to Bacterial Infection
D.6.1 Adults
The EPA (2024) ISA states that there is likely to be a causal relationship between lead exposure and
decreased host resistance in adults based on epidemiological studies examining the relationship
between Pb exposure and immunosuppression , expanding on the evidence in the 2013 ISA, . This
endpoint was not considered in the NTP Monograph. Evidence from human studies indicates an
association between lead exposure and weakened resistance to bacterial infection. In fact, as described
in the EPA (2013) ISA, the ability of lead to cause reduced bacterial resistance in animals has been
known for several decades. Animal studies suggest that a potential mode of action for this outcome is
the suppression of Thl cytokine production and reduction of macrophage function. "The strongest
evidence supporting a 'likely to be causal' relationship between Pb exposure and immunosuppression
comes from toxicological studies consistently demonstrating that Pb exposures suppress the DTH
response and increase susceptibility to bacterial infection in animals with BLLs < 30 ug/dL" (USEPA,
2024).The epidemiology studies demonstrated that increased susceptibility to bacterial infections and
suppressed DTH reactions are associated with blood lead levels (7-25 ug/dL) in adults as a consequence
of dietary lead exposure (USEPA, 2013, p. 1-34).
D.6.2 Children
Epidemiology studies found a higher prevalence of respiratory infections among children with higher
concurrent blood lead levels. A study of children in Boston found a relationship between an increase in
infections and cord blood lead > 10 ug/dL at the time of birth (Rabinowitz et al., 1990). Higher blood
lead levels were also associated with an increase in infections in a study of German children with a mean
blood lead level of 3.34 ug/dL (Karmaus et al., 2005). While the EPA (2013) ISA states that there is likely
to be a causal relationship between lead exposure and decreased host resistance to infection,
inadequate statistical analysis and consideration of confounders in the identified studies are not
sufficient to support a causal conclusion for children (USEPA, 2013, p. 4-552).
D.7 Neurological Effects
The nervous system is responsible for controlling the body's sensory, integrative, and motor functions
by transmitting signals that initiate a response throughout the body (National Institute of Child Health
and Human Development, 2013). The nervous system is divided into two parts: the central nervous
system (brain and spinal cord) and the peripheral nervous system, which consists of the somatic nerves
and ganglia. Neurological function can be measured in several ways depending on the outcome of
interest. In this section, the following health outcomes will be discussed: cognitive function, behavior,
conduct disorders, internalizing behaviors, psychological effects, neurodegeneration, and sensory
function.
D.7.1 Cognitive Function
Cognitive function is typically measured through Intelligence Quotient (IQ) tests (Srivastava et al., 2001).
Other measures of cognitive function include pattern comparison speed, vocabulary, and word list
memory (National Toxicology Program, 2012). Strong associations have been found between decreased
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IQ and early childhood lead exposures, including in utero exposures. The effects of childhood lead
exposure on cognitive function can persist through adulthood.
D.7.1.1 Adults
Based on prospective studies indicating associations of higher bone lead levels with declines in cognitive
function in adults, the EPA (2024) ISA determined a causal relationship between lead exposure and
cognitive function decrements. Recent prospective cohort studies with longer follow-up periods,
multiple and repeatedly measured cognitive outcomes, and adjustment for multiple risk factors and
confounders reduce uncertainties and strengthen the overall evidence related to the association of Pb
exposure with cognitive function in adulthood. Specifically, recent cohort studies indicate that higher
adult bone Pb levels (tibia mean range: 10.5 to 21.6 ng/g, patella mean range: 12.6 to 30.6 ng/g) were
associated with poor cognitive function/performance during young-, mid- or older-adulthood periods.
The NTP Monograph found limited evidence of association between decreased cognitive function in
adults at exposure levels <10 ng/dL due to mixed results for an association with blood lead and a more
consistent association with bone lead (National Toxicology Program, 2012, p. 27).
A study of 141 older men from the Normative Aging Study reported that concurrent blood lead levels
(mean, 5.5 ng/dL) were associated with decreases in specific measures of cognitive function, including
pattern comparison speed, vocabulary, word list memory, the Boston Naming Test (Payton, Riggs, Spiro,
Weiss, & Hu, 1998). The study authors found that tibia lead (but not patella lead) level was associated
with decreased performance in a test of spatial ability. Wright et al. (2003) studied 736 older men from
the Normative Aging Study and reported and associations between blood lead (mean, 4.5 ng/dL), patella
lead, and tibia lead and decreased performance on the Mini-Mental State Examination (MMSE).
Muldoon et al. (1996) also examined cognitive performance, with the MMSE and Wechsler Adult
Intelligence Scale-Revised, for 530 older women and found that blood lead level (mean, 4.8 ng/dL) was
associated with decreased performance on the Trail Making Test and the Digit Symbol Substitution Test.
However, this result was found among rural participants but not urban subjects.
Other studies reported an association between bone lead and decreased performance but did not find
an association with blood lead levels. Shih et al. (2006) reported a lack of an association between
current blood lead level (mean, 3.5 ng/dL) and cognitive function, however, they found tibia lead levels
to be significantly associated with lower scores in all seven domains of the cognitive test battery. Weuve
et al. (2009) reported that tibia lead levels were associated with reduced cognitive function measured by
the Telephone Interview for Cognitive Status in a study of 587 older women from the Nurses' Health
Study. However, blood lead and patella lead levels were not significantly related to the test score.
Two additional studies did not find associations with blood lead levels. Nordberg et al. (2000) did not
find an association between blood lead level (mean, 3.7 ng/dL) and performance on the MMSE in a
study of 762 older adults in Sweden. Gao et al. (2008) reported that concurrent blood lead (mean, 3.9
Hg/dL) was not significantly related to cognitive function in a study of 188 people from rural China.
D.7.1.2 Children: IQ
The EPA (2024) ISA and NTP Monograph found that the strongest evidence for an association between
lead and neurological effects is captured in studies that examine intellectual function among children.
Intellectual function is typically assessed using IQ scores, which are evaluated by administering a test
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such as the Wechsler Intelligence Scale for Children (WISC) or the Stanford-Binet Intelligence Scale
(National Toxicology Program, 2012, p. 20). Since IQ is a measure of general intelligence, these scales
include tests of vocabulary, comprehension, reasoning, memory, speed, and arithmetic. Raw IQ scores
are standardized at the population level to obtain a mean of 100 and standard deviation of 15 for each
age group (Beres et al., 2000). Cognitive function in children can also be assessed using alternative tests
that do not measure IQ, including the Mental Development Index (MDI) and the General Cognitive Index
(GCI).
The EPA (2024) ISA stated that recent studies support the 2013 ISA conclusion that "Pb-associated
cognitive effects in children occur in populations with mean BLLs between 2 and 8 ug/dL (Appendix
3.5.1.6.1) (USEPA, 2024, p. IS-27). The NTP Monograph concluded that there is sufficient evidence of
association between blood lead levels <5 ug/dL and decreases in various general and specific measures
of cognitive function in children from 3 months to 16 years of age. This conclusion is based on
prospective and cross-sectional studies using a wide range of tests to assess cognitive function (National
Toxicology Program, 2012, p. 27).
Recent longitudinal epidemiologic studies with group or population means <5 ug/dL add to the
evidence, generally supporting conclusions from the 2013 Pb ISA (USEPA, 2024, p. IS-28). Canfield et al.
(2003) studied 6- to 60-month-olds and 3- to 5-year-olds in Rochester, NY and found that each 10 ug/dL
increase in average lifetime blood lead level was associated with a 4.6-point decrease in IQ. In a study of
the same cohort, Jusko et al. (2008) found that children with blood lead levels <5 ug/dL scored 4.9
points higher on IQtests than children with blood lead levels between 5 and 9.9 ug/dL. A pooled
analysis of seven international cohort studies by Lanphear et al. (2005) estimated IQ decreases of 3.9,
1.9, and 1.1 points when blood lead increases from 2.4 to 10 ug/dL, 10 to 20 ug/dL, and 20 to 30 ug/dL,
respectively. Thus, the effects of incremental changes in lead on IQ appear to be larger in magnitude at
lower levels of lead exposure than at higher levels (e.g., nonlinear).
In 2013, Crump et al. published a statistical reevaluation of the data used in the Lanphear et al. (2005)
pooled analysis that related low levels of blood lead to intellectual deficits in children. In this work
Crump et al. had two main goals: (1) to reproduce the results of Lanphear et al. (2005) and correct any
errors, and (2) perform an independent analysis of the Lanphear et al. (2005) database. In 2019,
Lanphear published a correction to the original 2005 paper. Budtz-J0rgensen et al. (2013) reanalyzed the
Lanphear et al. (2005) data using additional statistical methods and a benchmark dose approach. All
three papers are summarized in more detail in Appendix J of the Final 2021 LCRR EA and Budtz-
J0rgensen et al. (2013), Crump et al., (2013) and Lanphear et al (2019) reinforce the findings in the
original Lanphear et al. (2005) paper. Jusko et al (2008) and Min et al (2009), which use more recent
blood lead levels than those used in the Crump and Lanphear analyses, both identified deficits in IQ at a
lower blood lead level than Crump et al. (2013), who used the data published by Lanphear et al. in 2005.
Min et al. (2009) only examines concurrent exposure, and the authors identify that at age 4 there is a
decrease of 0.77 IQ points for every 1 ug/dL increase in blood lead level. In Min et al. (2009), the dose-
response relationship between concurrent blood lead level and Performance IQ at 4 years showed a
steep slope at lower levels (up to 7 ug/dL) but did not reach significance. Jusko et al. (2008)
demonstrated that the slope of the blood-lead IQ relationship was steeper at lower levels of lead
exposure where IQ decreased by 1.2, 0.32, and 0.15 points per 1-pig/dL increase in peak blood lead over
the range of 2.1-10 ug/dL, 10-20 ug/dL, and 20-30 ug/dL, respectively. In both the Min and Jusko
studies, the steeper slopes at lower blood lead levels without log transformation showed increased
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deficits; this reinforces the fact that reducing lead levels in lower ranges of average blood lead level has
a significant impact on preventing IQ loss.
The NTP Monograph also found limited evidence of decreased cognitive function in children with
prenatal exposure levels <5 ng/dL. This conclusion is based on strong, consistent support for an
association between increased umbilical cord blood lead and decreased MDI scores, plus the mixed
evidence for maternal blood lead and MDI or other measures of cognitive function in children (National
Toxicology Program, 2012, p. 31). Several prospective studies indicated a negative association between
prenatal lead exposures <5 ng/dL and both general and specific cognitive function. General cognitive
function is measured using general non-IQ assessment tools (e.g., the MDI and GCI tests). Specific
cognitive functions may be measured using individual subsets of the WISC (e.g., Block Design or Digit
Span) tool. There is strong epidemiological evidence of the effects of lead exposure on cognitive
function from MDI scores in children aged 6 months to 3 years, and scores on specific cognitive function
tests in children aged 6 months to 16 years (National Toxicology Program, 2012, p. 27). A study of a
Mexican cohort found an association between increased maternal patella lead and decreased MDI
scores among 2-year-olds, suggesting that maternal cumulative lead exposure also plays a role in
decreased cognitive function in children (Gomaa etal., 2002).
D.7.1.3 Children: Academic Achievement
The relationship between lead exposure and decrements in Full Scale Intelligence Quotient (FSIQ) has
been reviewed by several researchers and government agencies. There also is agreement that lower
FSIQ and learning are linked with poorer academic performance and achievement. FSIQ is a combination
of 10 subtest scores most commonly evaluated using the WISC and is considered the most
representative measure of full cognitive function. The EPA (2024) ISA determined a causal relationship
between lead exposure and decrements in children's cognitive functioning, which includes academic
performance and achievement. This conclusion is based on several lines of evidence including findings
from prospective studies in diverse populations, coherence with evidence in animals, and evidence
describing modes of action. The NTP Monograph found sufficient evidence of decreases in measures of
academic achievement in 6- to 18-year-olds with blood lead <5 ng/dL based on the consistency of
effects on several measures of academic achievement in multiple studies (National Toxicology Program,
2012, p. 23). Both prospective and cross-sectional studies conducted on children with blood lead <10
Hg/dL in North America, Europe, and Africa have documented an inverse relationship between blood
lead and class rank, end-of-grade testing, and scores on academic performance tests. Associations
between decreased academic achievement and lead exposure have been noted in prospective studies
for early-childhood lead exposure in blood (9-36 months of age) and tooth dentin (6- to 8-year-olds) and
later in life achievement (Chandramouli et al.,2009; Miranda et al., 2009; Needleman et al., 1990).
However, these findings are complicated by the fact that blood lead measurements change over time.
Cross-sectional study results support the negative association between concurrent blood lead and
academic achievement for children (Al-Salea et al., 2001; Lanphear et al., 2000; Rabinowitz et al., 1992;
Wang et al., 2002).
The studies reviewed in the EPA (2024) ISA revealed lower performance on tests of math, reading, and
spelling skills, as well as lower probability of completing high school, lower class rank, and lower teacher
ratings of academic function. The confidence in the association between blood lead in children and
decreased academic performance is bolstered by the fact that it is consistent regardless of the academic
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achievement measure used. Miranda et al. (2009) found that an increase in blood lead from 1 to 10
Hg/dL was associated with a 2.3-point decrease in end-of-grade score in children in the 5th percentile of
end-of-grade compared to a 0.8-point decrease in children in the 95th percentile of end-of-grade score.
This impact was shown to be independently associated with end-of-grade score even after accounting
for socioeconomic factors.
Several studies found the association between blood lead and math or reading test scores to remain
significant after the consideration of confounders such as socioeconomic status, maternal education,
material intelligence, and parental caregiving. For example, a study of 488 children in the United
Kingdom found that Standard Assessment Test grades decreased 0.3 points (95 percent confidence
interval: -0.5, -0.1) when blood lead at 30 months old was doubled. The study adjusted for maternal
education, maternal smoking, home ownership, parental socioeconomic status, and parental caregiving
quality (Chandramouli et al., 2009). The same study revealed that Standard Assessment Test scores did
not differ between children with blood lead 0-2 ng/dL compared to those with 2-5 ng/dL (Chandramouli
et al., 2009). Similarly, Needleman et al. (1990) found an increased probability of dropping out of high
school in 18-year-olds with tooth lead levels >20 ppm compared to those with tooth lead levels <10
ppm. Although Needleman et al. (1990) adjusted for several confounders including maternal education,
IQ, and age, socioeconomic status, and subject alcohol use, controlling for these variables could have
contributed to the imprecision of the effect estimate. The small sample size (132 subjects) could also
have impacted the results.
Cross-sectional studies referenced in the EPA (2013 and 2024) ISA also reported relationships between
lower scores in math and reading test results and higher concurrent blood lead. The association
between lead exposure and lower math and reading scores was identified in more than one analysis of
NHANES data. For example, Lanphear et al. (2000) found a supra-linear relationship between blood lead
and math scores among nearly 5,000 6- to- 16-year-olds. This was similar to the relationship between
FSIQ and lead levels. The analysis of the 1988-1994 NHANES III data revealed that a 1 ng/dL increase in
concurrent blood lead was associated with a 0.70-point decrease in math score among all subjects and a
1.1-point decrease among 6- to 16-year-olds with blood lead <5 ng/dL (Lanphear et al., 2000). In
addition to its large sample size, the examination of multiple chemical exposures included in this
analysis of NHANES III data provides increased confidence in the results.
Of the studies reviewed in the NTP Monograph and conducted in the 15 years prior to the NTP
Monograph, many revealed decrements in academic achievement in relation to blood lead <10 ng/dL
and as low as 2 ng/dL. This relationship remains stable after controlling for several confounders such as
socioeconomic factors, sex, race/ethnicity, and age of subject during blood lead measurement, parental
education, and tobacco exposure. An analysis of 4,853 6- to 16-year-olds in the 1988-1994 NHANES III
dataset revealed an association between decreased achievement measured via the Wide Range
Achievement Test-Revised and concurrent blood lead <5 ng/dL (Lanphear et al., 2000). Some studies
have reported differential effects of blood lead on test scores: in a study of fourth graders in North
Carolina, children with lower test scores experienced greater decreases in scores given the same
increase in blood lead than children with higher test scores (Miranda et al., 2009). Lower parental
education and lower socioeconomic status were also shown to affect children with lower test scores in
the studies reviewed, implying that lead with other confounders can increase the impact from lead
alone among children with low baseline achievement levels.
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The EPA also reviewed the Kordas et al. (2005) and Evens et al. (2015) cross-sectional studies. Kordas et
al. used a battery of 14 cognitive tests that examined different aspects of executive functions, which
showed steeper slopes for tests on math, memory, and a picture vocabulary test. The second study,
Evens et al. (2015), utilized a standardized test that focused on examining critical and quantitative
reasoning abilities, which were shown to be influenced by lead levels even below 5 ng/dL.
D.7.2 Attention-Related Behavior
The NTP Monograph noted limited evidence of association between maternal blood lead levels
<10 ng/dL and incidence of attention-related behaviors via in utero lead exposures based on the mixed
results of studies with prenatal exposure data (National Toxicology Program, 2012, p. 37). A study of
1,923 15- and 17-year-olds in the Boston area found cord blood lead and tooth dentin lead to be
associated with inflexible behavior but not hyperactivity in 8-year-olds (Leviton et al., 1993). Another
study of 195 children in the Cincinnati area reported that scores on the Continuous Performance Test
was inversely associated with average childhood blood lead at <5 years of age, blood lead at 6.5 years of
age, and maternal blood lead level during the first and second trimester of pregnancy (Ris et al., 2004).
This indicates that children with higher blood lead levels had poorer test performance. Some
participants in the Ris et al. (2004) study also had early childhood blood lead levels above 10 ng/dL,
indicating that in addition to prenatal exposures to lead, they were exposed to high levels of lead in
early childhood.
The NTP Monograph found sufficient evidence of attention-related behavioral problems in 3- to 18-year-
olds with blood lead <5 ng/dL based on the consistency of effects in the studies reviewed and the
support for effects down to and below 2 ng/dL blood lead (National Toxicology Program, 2012, p. 34).
Rather than basing this determination solely on the outcome of attention-deficit/hyperactivity disorder
(ADHD), the broader category of attention-related behaviors is used in the NTP Monograph for two
reasons. First, NTP states in the Monograph that using "attention-related behaviors" more accurately
reflects the diversity of the behavioral effects data presented in the literature. The diagnostic criteria for
attention-related behaviors can include several types of behavioral deficits in addition to hyperactivity,
inattention, and the overall diagnosis of ADHD. Secondly, the diagnosis of ADHD in the studies reviewed
lacks the strength of a diagnosis given by trained clinicians using Diagnostic and Statistical Manual of
Mental Disorders (DSM) criteria.59 For example, several of the studies examined diagnosed ADHD based
on untrained teacher evaluations, parental reporting of a physician's diagnosis, or whether a child was
taking ADHD medication.
Most of the studies reviewed in the NTP Monograph identified significant associations between blood
lead <5 ng/dL in children and attention-related behaviors, with several reporting the association at
blood lead <2 ng/dL. As described in the NTP Monograph, over 10 studies suggest an association
between current average blood lead of 1-11 ng/dL and attention-related behavioral issues, ADHD, or
other indicators of decreased attention or increased hypersensitivity in 3- to 18-year-olds. For example,
Wang et al. (2008) reported a significant association between ADHD determined from a structured
59 The DSM is the standard classification of mental disorders used by mental health professionals in the United
States. The DSM contains a list of diagnostic criteria for each disorder and indicates which symptoms and for how
long these symptoms must be present in order to report a diagnosis.
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diagnostic interview and concurrent blood lead >5 ng/dL in a case-control study of 1,260 Chinese 4- to
12-year-olds. A study of Romanian children also found an increase in attention-related behavioral
problems based on parent and teacher ratings using German diagnostic surveys in a study of 83 8- to 12-
year-olds with concurrent mean blood lead of 3-5 ng/dL (Nicolescu et al., 2010). Two studies conducted
in the United States with 7- to 9-year-old inner-city black children found that blood lead was positively
related to several attention-related behaviors including higher ADHD and inattention scores (Chiodo et
al., 2007; Chiodo et al., 2004).
NHANES data were used to support the relationship between blood lead and attention-related
behaviors. Braun et al. (2006) found the odds of ADHD to be more than four times greater among 4- to
15-year-olds in the 1999-2002 NHANES with blood lead >2 ng/dL compared to children with blood lead
<0.8 ng/dL. Similarly, Froehlich et al. (2009) found that children in the 2001-2004 NHANES with
concurrent blood lead >1.3 ng/dL and concurrent blood lead of >0.9 to 1.3 ng/dL had 2.3-greater and
1.7-greater odds, respectively, of ADHD compared to children with blood lead <0.8 ng/dL. While
Froehlich et al. (2009) used the Diagnostic Interview Schedule for Children to determine ADHD in
subjects, Braun et al. (2006) relied on parental report of stimulant medication or previous diagnosis of
ADHD.
The NTP Monograph found limited evidence of attention-related behavioral problems in children with
prenatal lead exposure at blood lead <10 ng/dL based on the review of several studies (National
Toxicology Program, 2012, p. 34). The limited conclusion was chosen because the children in the studies
were also exposed to lead in early childhood, therefore the timing of exposure that is most important in
causing the adverse effect could not be determined. A prospective study of prenatal and early childhood
lead exposure up to 6 years old found that performance on the Continuous Performance Test - Conners'
Version at ages 15-17 years old was inversely related to maternal blood lead during the first or second
trimester of pregnancy (mean=8.9 ng/dL), mean blood lead under 5 years old, and concurrent blood
lead at age 6.5 years old (Ris et al., 2004). This indicates that children with higher lead exposures did not
score as well as children with lower lead exposures on these tests. However, blood lead levels of
participants during early childhood were above 10 ng/dL. Studies of cord lead levels (mean=6.8 ng/dL)
and tooth dentin lead levels in 1,923 8-year-olds in Boston were associated with inflexible behavior but
not with hyperactivity (Leviton et al., 1993). The NTP Monograph conclusion is also based on bone lead
studies that found an association between lead exposure and attention-related behaviors such as
hyperactivity and inattention. Lead levels in primary teeth and tibiae have been reported to be
significantly associated with measures of inattention in 19- to 20-year-olds (Bellinger 1994).
The EPA (2024) ISA strengthened the conclusions of the 2013 ISA which concluded that there was a
causal relationship between lead exposure and inattention, impulsivity, and hyperactivity in children
based on recent studies of children with group mean BLLs < 5 |J.g/dL supporting the 2013 ISA
conclusions and "prospective studies of ADHD, including a study of clinical ADHD that controlled for
parental education and SES, although not quality of parental caregiving reported positive associations"
(USEPA, 2024). The 2024 ISA addresses the uncertainties presented in the 2013 ISA by stating that "The
largest uncertainty addressed by the recent evidence base is the previous lack of prospective studies
examining ADHD (Appendix 3.5.2.4-3.5.2.5). The bulk of the recent evidence comprises prospective
studies that establish the temporality of the association between Pb exposure and parent or teacher
ratings of ADHD symptoms and clinical ADHD. Across studies, associations were observed with tooth Pb
concentrations, childhood BLLs (<6 ng/dL), and with maternal or cord BLLs (2-5 ng/dL)."
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The causal relationship for inattention, impulsivity and hyperactivity cited in the EPA (2024, Appendix 3,
Table 3-3) ISA relies on data from both cross-sectional studies and prospective cohort studies. The
studies characterized as strongest were the prospective studies that investigated attention and found
associations with blood or tooth lead level. Several of the studies cited in the EPA (2013) ISA were also
cited in the NTP Monograph including Ris et al. (2004) and Bellinger et al. (1994). The prospective
studies demonstrated the temporality of the association between lead exposure and onset of attention-
related effects. The research collectively looked at lead exposures at various points in time including
prenatal blood lead, blood lead measured 9-11 years before attention was measured, lifetime average
blood lead, and tooth lead. Several confounders were controlled for in most prospective studies
including parental education; IQ; caregiving quality; socioeconomic status; birth outcomes; and
exposure to alcohol, drugs, or smoking. The newer studies reviewed in the EPA (2013) ISA found
evidence of an association between measures of decreased attention and concurrent blood lead level
between 2 and 5 ng/dL. However, there are several limitations that should be considered when
interpreting these results. For example, the studies did not consider the effects of potential confounders
such as parental caregiving quality and examined adolescents who may have been influenced by higher
lead exposures during early childhood. Further supporting the relationship between BLLs and ADHD, the
EPA's 2024 ISA identified a cross-sectional study by Geier et al. (2018) that also found a relationship
after adjusting for covariates "such as" gender, race and socioeconomic status odds ratio (95% CI) 1.29
(1.03-1.55). This study examined 2,109 people aged 10-19 using 2003-2004 NHANES data (Geier et al.,
2018).
D.7.3 Conduct Disorders
The EPA (2024) ISA determined a likely causal relationship between lead exposure and conduct
disorders in children primarily based on consistent results from recent prospective cohort studies (see
Appendix 3.5.3.1 of the 2024 Pb ISA). The determination was influenced by the uncertainty introduced
by inconsistent animal evidence with relevant exposures and the small number of epidemiological
studies identified. Several prospective studies indicate a positive association between conduct issues
and prenatal maternal blood lead measurements, concurrent (age 6 years), and lifetime average (4-5
years or 11-13 years) blood lead (mean=6.8-14.3 ng/dL) (Burns et al., 1999; Dietrich et al., 2001).
Dietrich et al. (2001) reported an association between lead exposure and self and parent-reported
delinquent and antisocial acts. The study used prenatal maternal first trimester blood lead
measurements, average childhood lead exposure, and a late body burden of lead levels for 15- to 17-
year-olds. Several cross-sectional studies reported associations between conduct problems and lead
exposure at blood lead lower than those reported in the prospective studies (1-5 ng/dL). Although the
cross-sectional studies reported relationships between lead exposure and outcome, the EPA (2013) ISA
notes that confidence in these results is limited due to inadequate adjustment for confounding
variables.
The NTP Monograph found sufficient evidence of increased incidence of problem behaviors in children
with blood lead <5 ng/dL based on the consistency of effects in multiple prospective and cross-sectional
studies (National Toxicology Program, 2012, p. 46). The NTP Monograph included delinquent, criminal,
or antisocial behavior in its review of problem behaviors. The conclusion was based on data from several
prospective and cross-sectional studies illustrating increased criminal behavior in 6- to 15-year-olds with
concurrent blood lead <1-15 ng/dL. Adjustments for confounders were made in several of the studies
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for socioeconomic variables including sex, race/ethnicity, age of blood lead measurement, parental
education, and tobacco exposure. One of the key studies reviewed in the NTP Monograph is a cross-
sectional study of the 2001-2004 NHANES data that found a relationship between conduct disorders and
blood lead >0.8 ng/dL in 8- to 15-year-olds compared to 8- to 15-year-olds with blood lead <0.7 ng/dL
conducted by Braun et al. (2008).
Several studies found associations between elevated blood lead levels in young adults and criminal
behavior. Wright et al. (2008) analyzed 250 young adults aged 19-24 enrolled in the Cincinnati Lead
Study. The study reported a relationship between higher rates of total criminal arrests and blood lead at
6 years old. The association between crime and increased lead exposure is supported by studies
measuring tooth dentin lead. In a New Zealand study of 1,265 21-year-olds, Fergusson et al. (2008)
found an association between reported crimes and tooth dentin lead from primary teeth shed at 6 to 8
years old. Bellinger et al. (1994) also reported a significant relationship between tooth dentin lead levels
and problem behaviors in 8-year-olds in Boston. The NTP Monograph found limited evidence of
increased incidence of problem behaviors in children with prenatal exposure to lead levels <10 ng/dL.
The analysis by Wright et al. (2008) suggested a relationship between higher maternal blood lead during
the first or early second trimester of pregnancy and higher rates of total criminal arrests among 19- to
24-year-olds enrolled in the Cincinnati Lead Study. Several studies supported the association between
lead exposure and delinquent behavior or criminal arrests. However, the blood lead levels in some of
the participants were above 10 ng/dL, thus making the generalizability of these studies' findings to
blood lead <10 ng/dL limited.
D.7.4 Internalizing Behaviors
In contrast to studies that investigated externalizing behaviors in children such as inattention,
impulsivity, and conduct disorders, there are also studies that investigated internalized behaviors.
Internalizing behaviors include withdrawn behaviors, symptoms of depression, fearfulness, and anxiety.
Internalized behaviors are most often assessed through parent or teacher reports using the Child
Behavior Checklist.60
The EPA (2024) ISA determined a likely causal relationship between lead exposure and internalized
behaviors in children (USEPA, 2024, p. IS-33). Multiple prospective studies of various populations
provide key evidence for an association between increased lead exposure and higher ratings of
internalized behaviors. These studies reported cord blood, concurrent blood (age 3), lifetime average
blood, and tooth lead levels to be associated with higher ratings of internalized behaviors in children 3-
to 13-year-old children. Results from cross-sectional studies also support the EPA ISA's causal
determination of a relationship between lead exposure and internalized behaviors in children for
concurrent blood (Liu et al., 2011; Roy et al., 2009) and hair lead levels (Bao et al., 2009).
60 The Child Behavior Checklist is a widely used questionnaire to assess behavioral and emotional problems in
children.
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D.7.5 Psychological Effects
The EPA (2024) ISA states that there is a likely causal relationship between lead exposure and
psychopathological effects based on "recent prospective analyses provide additional support for a
positive association between bone and BLLs and psychopathological effects in older adults, although
results from cross-sectional studies are inconsistent. Recent toxicological studies in rodents with
developmental exposure continue to provide evidence of anxiety-like behaviors. Multiple studies
demonstrate the persistence of these effects into adulthood. Additionally, a few recent studies in
rodents demonstrated effects of adult-only Pb exposures on anxiety-like behavior after 42-126 d of
exposure (BLLs: 7.1 to 28.4 ug/dL), but not following a 30-d exposure (BLLs: 6.8 to 8.8 ug/dL)" (USEPA,
2024, p. IS-40). In some cases, the epidemiology results are supported by evidence from studies of
toxicology. The NTP Monograph concluded that there is limited evidence for an association between
lead levels and psychiatric symptoms based on the small number of studies supporting such effects. Two
of these studies were from a single cohort61 (National Toxicology Program, 2012, p. 38). The NTP
Monograph points out that in adults, the studies "do not include cohorts where that blood Pb levels
were consistently below 10 ug/dL from birth to the time of the behavioral assessment". Thus, the
evidence for effects below 10 ug/dL is not strong.
Self-reported symptoms of depression and anxiety in adults are linked to higher concurrent blood lead
or tibia lead levels in cross-sectional studies. Three studies on the association between lead levels and
psychological effects were referenced by both reports (Bouchard et al., 2009; Rajan et al., 2007; Rhodes,
et al., 2003). The studies indicated an association between lead levels and panic disorder, somatization,
and the global severity index62. One study, Bouchard et al. (2009), determined that what they described
as a generalized anxiety disorder was not associated with lead levels, but Rhodes et al. (2003) found that
elevated anxiety and phobic anxiety were significantly associated with blood, tibia and patella lead
levels.
D.7.6 Neurodegeneration
Some studies described in the NTP Monograph, and the EPA (2024) ISA looked at measures of the
progressive loss of neurological functions as manifest in amyotrophic lateral sclerosis (ALS) and essential
tremor disorders.
The EPA 2024 ISA found that there is a suggestive, but not sufficient to infer, a causal relationship
between lead and neurodegenerative diseases The NTP Monograph concluded that there is limited
evidence of an association between increased occurrence of ALS and blood lead levels <10 ug/dL
(National Toxicology Program, 2012, p. 38). Both the NTP Monograph and the EPA ISA discuss the
potential of reverse causation. That is, the observed associations between blood lead and ALS may not
necessarily mean that lead exposure contributes to the development of ALS. Instead, it could be that the
decreases in activity associated with ALS increase bone turnover, which releases lead from bone and
thereby increases blood lead levels. Five studies on the association between lead and ALS were
61 i.e., the Normative Aging Study
62 An indicator quantifying a respondent's psychological distress status.
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reviewed in both reports; while three studies observed effects, only two of these studies had significant
results (Fang et al., 2010; Kamel et al., 2005). Fang et al. (2010) conducted a case-control study of U.S.
military veterans and found that associations between blood lead and ALS remained significant after
adjustment for indicators of bone turnover. Although this study suggests that reverse causation is not
likely, the EPA (2013) ISA points out that the study lacked actual measurements of bone lead, and that
directionality still cannot be established. In addition, studies in ALS patients have generally produced
inconsistent results. The EPA ISA specifically points to the mixed findings of the Kamel studies (Kamel et
al., 2002; Kamel et al., 2003; Kamel et al., 2005) of a New England cohort of ALS cases recruited from the
Neuromuscular Research Unit at the New England Medical Center and the Neurophysiology Laboratory
at Brigham and Women's Hospital (p. 4-223).
The NTP Monograph determined that there is evidence of a sufficient association between essential
tremor incidence in adults and blood lead levels <10 ng/dL, but evidence of a limited association in
adults with blood lead levels <5 ng/dL (National Toxicology Program, 2012, p. 39). The four studies on
this endpoint identified in the NTP Monograph examined more than 300 cases of essential tremor, and
all indicated consistent associations between diagnosis and blood lead levels. However, the NTP
Monograph found limited evidence at <5 ng/dL because the two identified studies examining
participants with blood lead <5 ng/dL are representative of only a small group of patients. NTP
concluded that there is sufficient evidence of a relationship at blood lead levels of <10 ng/dL because
the same pattern of effects was observed in two "widely separated" groups in terms of geography
(National Toxicology Program, 2012, p. 51).
D.7.7 Auditory Function
Auditory function can be evaluated through measurements of hearing thresholds, auditory processing,
and changes to brainstem auditory evoked potential.
D. 7.7.1 Adults
The EPA ISA states that the evidence on lead exposure and auditory function is suggestive of a causal
relationship based on limited epidemiological evidence with relevant bone or blood lead levels, and a
lack of animal evidence at relevant exposures (USEPA,2024). The NTP Monograph found limited
evidence for associations between decreased auditory function and both prenatal and adult blood lead
levels of <10 ng/dL based on a supportive but small body of studies on the subject (National Toxicology
Program, 2012, p. 40).
Four studies in adults are highlighted in the NTP Monograph. These address individuals with lower blood
lead levels. Forst et al. (1997) reported that blood lead level (mean, 5 ng/dL; range, 1-18 ng/dL) was
associated with an elevated hearing threshold at 4,000 Hz, but not at other frequencies. Hwang et al.
(2009) found at blood lead levels >7 ng/dL that hearing thresholds were significantly increased in a study
of 259 steel plant workers in Taiwan. In a case-control study of 121 adult cases (mean lead level, 10.7
Hg/dL) referred for hearing testing, elevated blood lead was significantly associated with higher hearing
thresholds compared to controls (Chuang et al., 2007). In a cross-sectional analysis of 448 men in the
Normative Aging Study, tibia lead (mean, 23 ng/g) and patella lead (mean, 33 ng/g) were significantly
associated with hearing loss indicated by higher hearing thresholds (Park et al., 2010).
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D.7.7.2 Children
The NTP Monograph found sufficient evidence of decreased hearing in children with blood lead <10
Hg/dL (National Toxicology Program, 2012, p. 40). The conclusion set in the NTP Monograph is based on
several cross-sectional studies that reported increased hearing thresholds and an increase in brainstem
auditory evoked potential in 4-to 19-year-olds. The NTP Monograph references two studies conducted
by Schwartz and Otto on blood lead and hearing loss, which are also reviewed in the EPA ISA. In their
analysis of NHANES II (1976-1980) data, Schwartz and Otto (Schwartz & Otto, 1987) found a significant
relationship between blood lead and increased hearing thresholds for pure-tone frequencies in 4,519 4-
to 19-year-olds. The researchers also found an association between hearing loss and blood lead >8
Hg/dL, as well as a 2-decibel decrease in hearing at all frequencies with an increase in blood lead from 6
to 18 ng/dL in an analysis of the Hispanic Health and Nutrition Examination Survey data for 3,545 six- to
19-year-olds (Schwartz & Otto, 1991).
The NTP Monograph found limited evidence of decreased hearing in children with prenatal lead
exposure at blood lead <10 ng/dL (National Toxicology Program, 2012, p. 40). A limited conclusion was
assigned rather than a sufficient conclusion because few of the studies identified addressed low-level
lead exposures. The limited conclusion is based on three studies that demonstrated an association
between prenatal exposure to blood lead <10 ng/dL and auditory effects. Two studies reported changes
in the latency and interpeak interval of brainstem auditory evoked potential in infants born to mothers
with blood lead <10 ng/dL and 5- to 6-year-olds born to mothers with mean blood lead of 8 ng/dL
(Rothenberget al., 1994; Rothenberg et al., 2000). In an analysis of 259 children enrolled in the
Cincinnati Lead Study, Dietrich et al. (1992) found associations between auditory processing disorders at
age 5 and both prenatal lead exposure (mean prenatal blood lead=8 ng/dL) and early childhood lead
exposure (mean infant blood lead=5 ng/dL). However, the applicability of Dietrich et al.'s, (1992)
findings to blood lead <10 ng/dL is limited given that mean blood lead of subjects aged 1-5 was 10-17
Hg/dL.
The EPA (2024) ISA determined a suggestive of but not sufficient to infer, a causal relationship between
lead exposure and decreased auditory function in children based on cross-sectional and case-control
studies generally supporting an association between Pb exposure and hearing loss "but are not entirely
consistent." The uncertainty in this determination is due to a lack of animal evidence in juveniles and at
relevant exposures. Both prospective and cross-sectional studies demonstrated a relationship between
higher blood lead and decreased auditory function in children. Most studies reviewed adjusted for
socioeconomic factors, and several studies controlled for child health and nutrition. The association
between higher lead exposure and decreased auditory function was found for several time periods of
exposure including prenatal maternal, neonatal, lifetime average (to age 5), and concurrent (age 4-19)
blood lead (Dietrich et al., 1992; Rothenberg et al., 2000; Schwartz & Otto, 1987, 1991). This association
is also supported by animal studies, but at levels higher than relevant to the scope of the EPA ISA.
D.7.8 Motor Function
Motor function includes both fine and gross motor function. Fine motor function includes skills such as
response speed and dexterity, while gross motor function includes postural balance, action tremor, and
agility. Since there is little evidence on this endpoint available in adults, the EPA (2024) ISA did not
provide a conclusion on the association between lead exposure and motor function during adulthood. In
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children aged 4.5 to 17 years old, the EPA (2024) ISA determined a likely causal relationship between
lead exposure and decreased motor function (USEPA, 2024).63 This relationship was demonstrated for
both fine and gross motor function. A few studies provided the EPA with key evidence to determine a
likely causal relationship between lead exposure and motor function decrements. Ris et al. (2004) found
that higher early childhood blood lead (mean age=78 months; mean blood lead=11.7 ng/dL) was
associated with poorer fine motor function in adolescents aged 12-17 from the Cincinnati Lead Study.
Bhattacharya et al. (2006) found a significant relationship between decrements in gross motor skills and
higher early childhood blood lead among participants in the Cincinnati Lead Study. Additional analyses
of this cohort suggest that decreased upper limb dexterity, fine motor composite score, and poorer
postural balance are associated with higher concurrent, lifetime average, and neonatal (but not prenatal
maternal blood lead measurements) blood lead (Bhattacharya et al., 1995; Dietrich et al., 1993). The
EPA ISA reports that the studies reviewed adjusted for confounders such as child health, parental
caregiving quality, and socioeconomic factors. On the other hand, cross-sectional studies and
toxicological data reviewed in the EPA ISA provided mixed evidence of an association between motor
function decrements and higher blood lead.
D.8 Cancer
Animal studies provided the EPA with evidence to determine a likely causal relationship between lead
exposure and cancer (USEPA,2024). Additionally, the International Agency for Research on Cancer (IARC)
lists inorganic lead compounds as probable human carcinogens, and organic lead compounds as not
classifiable (International Agency for Research on Cancer, 2006). The NTP Monograph did not review
cancer because it reviewed the carcinogenic effects of lead in its Report on Carcinogens. In the 2004
Report on Carcinogens, NTP found that lead and lead compounds are reasonably anticipated to be
human carcinogens based on sufficient evidence from toxicological studies and limited evidence from
human studies. Lead exposure is associated most strongly with lung and stomach cancer, but has also
been associated with increased risk for urinary-bladder cancer (National Toxicology Program, 2004).
Inconsistent results have been reported in the epidemiological literature on the relationship between
lead exposure and cancer mortality. One epidemiological study using NHANES III (1988-1994) data
demonstrated an association between increased blood lead and increased cancer mortality (Schober et
al., 2006). However, other studies have reported weak or no associations (Khalil et al., 2009; Menke et
al., 2006; Weisskopf et al., 2009).
Despite the inconclusiveness of epidemiology evidence, toxicological studies demonstrate associations
between lead exposure and cancer. Although no new relevant animal studies were identified, the ISA
states, "animal studies available in previous reviews continue to provide strong support for the
carcinogenic potential of high Pb exposures (chronic 10,000 ppm Pb acetate diet or 2,600 ppm drinking
water Pb acetate)" (USEPA, 2024, Appendix 10, p. 10-23). There is strong evidence of lead-induced
tumor development in animal studies with long-term exposures (18-24 months) to high lead
concentrations (> 2,600 ppm) (Azar et al., 1973; Kasprzaket al., 1985; Koller, et al., 1985; Van Esch &
63 Effects on motor function in children were not reviewed as an endpoint in the NTP Monograph.
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Kroes, 1969). Additionally, the Lead ISA identified the potential that early life exposures could induce
cancer in adulthood (Waalkes et al., (1995); Tokar et al. (2010)).
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Appendix E: Adverse Health Effects Associated with Copper Exposures
Although copper is an essential trace element required for several metabolic processes, excess copper
intake is toxic and linked to various adverse health effects. Copper is common in human diets: the
average adult ingests approximately 1 mg/day, and absorbs approximately half of that amount (National
Research Council, 2000). Copper is necessary for many physiological functions including aerobic
metabolism, immune and cardiac function, glucose metabolism regulation, and essential for adequate
human growth. Additionally, copper deficiency has been linked to altered cholesterol metabolism, and
anemia and bone-marrow abnormalities among children (Bost et al., 2016; National Research Council,
2000). The National Academy of Science has set a Recommended Daily Allowance for copper in healthy
adults of 0.9 mg/day, and Recommended Daily Allowances ranging from 0.34 mg/day to 0.7 mg/day for
children 1 years up to 13 years old (Institute of Medicine, 2001). Recommended Daily Allowances
represent the necessary daily amount of copper needed for normal metabolic functions. The National
Academy of Science also developed Tolerable Upper Intake Levels for copper, which range from 1
mg/day for children 1-3 years of age to 10 mg/day for adults, including pregnant mothers. These
Tolerable Upper Intake Levels values are contentious, as varying concentrations of excess copper intake
have been found to cause excess retention in the body, leading to adverse health effects (Turnlund et
al., 2005).
Studies show that adverse gastrointestinal and hepatic effects are associated with high copper ingestion.
Acute gastrointestinal symptoms are the most common adverse effect observed among adults and
children. Chronic hepatic effects are also a concern, particularly for those with Wilson's disease and
children pre-disposed to genetic cirrhosis syndromes. These diseases disrupt copper homeostasis,
leading to excess accumulation that can be worsened by excess copper ingestion (National Research
Council, 2000).
This appendix provides a qualitative discussion of the adult and child health effects associated with
ingested copper exposure, which are anticipated to be reduced by the rule. The monetary value
associated with the benefits of the final LCRI are not quantified in this appendix because quantitative
changes in exposure were not estimated.
The health effects discussed in this Appendix were identified using various sources. The United States
Department of Health and Human Services' Toxicological Profile for Copper (ATSDR, 2004) provides a
comprehensive review of all effects associated with copper exposure in literature before 2004. The
National Research Council's Copper in Drinking Water provides a comprehensive review of effects
associated with ingesting copper via drinking water in literature before 2000. An additional search was
conducted to identify studies published after 2004. However, these health effects are not expected to
occur at the concentrations currently found in public drinking water systems that are in compliance with
the Lead and Copper Rule. A recent study as part of the American Healthy Homes Survey II tested 678
US homes where children may be living and found 1.5% exceeded the action level for copper of 1.3
mg/L. The mean copper concentration was found to be 125 ng/L (Bradham et al., 2023).
E.l Acute Gastrointestinal Distress
Copper exposure via drinking water has been linked to gastrointestinal distress, most often nausea and
vomiting, and less often, diarrhea and abdominal pain (ATSDR, 2004), however, as described below
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these levels were higher than are found in most U.S. water in compliance with the Lead and Copper
Rule. The gastrointestinal system absorbs 12-60% of ingested copper and is suggested as an explanation
for gastrointestinal effects (de Romanaet al., 2011; Wapnir, 1998). Copper absorption primarily occurs in
the duodenum, but also the stomach and distal part of the small intestine. Copper is then transported to
the liver via the portal vein (Bost et al., 2016; Kodama and Bhadhprasit, 2012). Since the literature on
this endpoint primarily examines adults, gastrointestinal effects discussed in this appendix pertain to
healthy adults unless otherwise specified.
Many studies have found nausea to be the primary acute health effect of a single exposure to copper in
drinking water among healthy adults. The maximum contaminant level goal (MCLG) the EPA established
in the Lead and Copper Rule for copper is 1.3 mg/L. The MCLG is the maximum level of a contaminant in
drinking water at which no known or anticipated adverse effect on the health of persons would occur,
allowing an adequate margin of safety. The World Health Organization's Guidelines for Drinking Water
Quality summarized various case studies of copper contamination in beverages and public water
supplies. It found nausea, vomiting and diarrhea to be acute onset symptoms of copper exposure at
concentrations as low as 4 mg/L, typically occurring within 15 to 60 minutes of initial exposure (World
Health Organization, 2004).
Nausea and vomiting resulting from acute exposures are thought to be caused by a reflex response from
the stimulation of the vagal nerve, which originates in the stomach (de Romana et al., 2011). Larger
ingested copper doses directly stimulate the hypothalamic vomit center in addition to the vagal nerve
causing vomiting. The physiological changes that result in diarrhea are not well understood (de Romana
et al., 2011). Copper ingestion reduces the mucosal barrier capacity and gastric permeability to sucrose
and delays the first phase of gastric emptying by decreasing antral area. However, these effects have
been found to be independent of gastrointestinal symptoms (Araya et al., 2003; Gottelandet al., 2001).
Generally, the ionic form of copper is considered an irritant of the gastrointestinal tract and has been
suggested as an explanation for gastrointestinal symptoms caused by copper in drinking water (National
Research Council, 2000).
E.2 Chronic Liver Toxicity
Copper exposure has been linked to hepatic effects in susceptible individuals, such as those with
Wilson's disease or infants and children who have genetic susceptibilities. For these populations, chronic
liver disease is a primary concern. Liver effects are not considered a major concern for healthy adults, as
long-term daily exposure to copper in a regular diet of up to 12 mg/day has shown no adverse liver
effects (Institute of Medicine, 2001). This level is higher than the expected copper levels in water
systems in compliance with the previous LCR. A recent study assessed the association between copper
and non-alcoholic fatty liver disease.
E.2.1 Wilson's Disease
Wilson's disease is an autosomal recessive genetic disorder of copper metabolism, characterized by
defective ATP7B function leading to impaired biliary excretion of copper, affecting 1 in 30,000
individuals (Ala et al., 2007). High copper deposition in the liver, brain, cornea and low levels of
ceruloplasmin are markers of the disease that typically do not present before age 7, and often manifest
into chronic liver cirrhosis (de Romana et al., 2011). Other clinical manifestations of the disease include
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neurological, psychiatric, and ophthalmic symptoms. It is generally agreed that the disease does not
manifest as a result of excess copper exposure, but excess dietary copper intake can worsen the disease
once present (Ala et al., 2007; ATSDR, 2004).
Currently, individuals with Wilson's disease are advised to avoid foods high in copper and to test
drinking water levels, in addition to undergoing medicinal treatment. High hepatic copper levels have
been observed in individuals with Wilson's disease who consume average copper intakes, therefore
excess copper from foods and water are of concern in this population (ATSDR, 2004). Due to the rarity of
Wilson's disease, there are currently no controlled trials examining effects of ingested copper. Despite
this, current literature still suggests that individuals with Wilson's disease should avoid high copper
intake, even if they are stable and adhering to medical therapy (Russell et al., 2018).
E.2.2 Infants and Children with Genetic Susceptibilities
Effects on the liver are primarily a concern among infants and children who have genetic susceptibilities
affecting copper homeostasis. Infants have a higher absorption and reduced capacity to excrete copper
at high doses compared to other age groups, and the same is assumed for children (National Research
Council, 2000). However, the literature does not support an association between elevated copper
exposure and hepatic effects in non-susceptible infants and children.
There are several disorders associated with liver toxicosis and copper exposures in children. Indian
Childhood Cirrhosis (ICC) is characterized by swelling and degeneration of liver cells and the presence of
excess copper deposits (Prasad et al., 1996). It was thought to be found exclusively among Indian
children, and incidence has rapidly declined in the last three decades (Yadav et al., 2015). Idiopathic
Copper Toxicosis (ICT) refers to cases that have similar presentation to ICC but occur outside of India
(Nayak and Chitale, 2013).
The exact etiology of these diseases is unknown but has been hypothesized to involve both genetic
susceptibilities and high copper exposure. Childhood cirrhosis in India has been attributed to the use of
copper containers and consumption of high-copper animal milk during infancy, as incidence of ICC
significantly decreased with promotion of preventative activities (de Romana et al., 2011). However, a
review of 103 case studies of childhood cirrhosis in Germany found that less than 10 percent were
attributable to copper exposures (World Health Organization, 2004). In a recent review of the literature
on ICC and ICC-like diseases, Nayak and Chitale (2013) concluded that excessive copper ingestion
through water and food are not a primary cause of the development of the disease nor further liver
injury. Furthermore, genealogic studies of families suggest that genetic inheritance is necessary for the
manifestation of ICC and ICT (Nayak and Chitale, 2013). Therefore, while these disorders involve genetic
predisposition and accumulation of copper, the significance of copper ingestion to the development of
ICC and ICT remains unclear.
In the general population of infants and children, epidemiological and human controlled exposure
studies have failed to find any associations between copper exposure and adverse effects on the liver. In
a study by Scheinberg and Sternlieb (1996), death from cirrhosis or any liver disease among children
under 6 years of age in towns exposed to drinking water containing approximately 9 mg/L of copper
were compared to children in towns with lower copper concentrations. No difference in incidence of
hepatic mortality was observed (Scheinberg and Sternlieb, 1996). A 2011 review of studies on liver
diseases in infants concluded that genetic susceptibility is important because infant populations with
Final LCRI Economic Analysis Appendices
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similarly high levels of exposure in the same geographical areas did not develop liver abnormalities (de
Romana et al., 2011). In a study by Olivares et al. (1998), no alterations in liver function were found in
healthy infants exposed to 0.315 mg/kg/day of copper in drinking water for 9 months. In addition, no
differences in serum concentrations of copper were observed, which suggests that infants and children
can adapt to different levels of copper intake by varying absorption of copper.
E.3 References
Agency for Toxic Substances and Disease Registry (ATSDR). 2004. Toxicological profile for copper 314.
Ala, A., A. P. Walker, K. Ashkan, J. S. Dooley, and M.L. Schilsky. 2007. Wilson's disease. The Lancet
369(9559): 397-408. doi:https://doi.org/10.1016/S0140-6736(07)60196-2
Araya, M., M. Olivares, F. Pizarro, M. Gonzalez, H. Speisky, and R. Uauy. 2003. Gastrointestinal
symptoms and blood indicators of copper load in apparently healthy adults undergoing controlled
copper exposure. American Journal Clinical Nutrition 77(3): 646-650. doi:DOI: 10.1093/ajcn/77.3.646
Bost, M., S. Houdart, M. Oberli, E. Kalonji, J.-F. Huneau, and I. Margaritis. 2016. Dietary copper and
human health: Current evidence and unresolved issues. Journal of Trace Elements in Medicine and
Biology 35: 107-115. doi:https://doi.org/10.1016/j.jtemb.2016.02.006
Bradham, K.D., C.M. Nelson, T.D. Sowers, D.A. Lytle, J. Tully, M.R. Schock, K. Li, M.D. Blackmon, K.
Kovalcik, D. Cox, G. Dewalt, W. Friedman, E.A. Pinzer, and P.J. Ashley. 2023. A national survey of lead
and other metal(loids) in residential drinking water in the United States. J Expo Sci Environ Epidemiol 33:
160-167. https://doi.org/10.1038/s41370-022-00461-6
Chen, C., Q. Zhou, R. Yang, Z. Wu, H. Yuan, N. Zhang, M. Zhi, Y. Zhang, X. Ni, Z. Wang, D. Gao, X. Zhu, J.
Cai, Z. Yang, and L. Sun. 2021. Copper exposure association with prevalence of non-alcoholic fatty liver
disease and insulin resistance among US adults (NHANES 2011-2014). Ecotoxicology and environmental
safety 218: 112295. Advance online publication.
https://doi.Org/10.1016/j.ecoenv.2021.112295https://doi.org/10.1016/j.scitotenv.2022.155441
de Romana, D. L., M. Olivares, R. Uauy, and M. Araya. 2011. Risks and benefits of copper in light of new
insights of copper homeostasis. Journal of Trace Elements in Medicine and Biology 25(1): 3-13.
doi:https://doi.org/10.1016/j.jtemb. 2010.11.004
Gotteland, M., M. Araya, F. Pizarro, and M. Olivares. 2001. Effect of acute copper exposure on
gastrointestinal permeability in healthy volunteers. Dig DisSci. 46(9): 1909-1914.
Institute of Medicine. 2001. Dietary Reference Intakes for Vitamin A, Vitamin K, Arsenic, Boron,
Chromium, Copper, Iodine, Iron, Manganese, Molybdenum, Nickel, Silicon, Vanadium, and Zinc.
Washington, D.C.: National Academies Press.
Kodama, H., C. Fujisawa, and W. Bhadhprasit. 2012. Inherited Copper Transport Disorders: Biochemical
Mechanisms, Diagnosis, and Treatment. Current Drug Metabolism 13: 237-250. doi:doi:
10.2174/138920012799320455
National Research Council. 2000. Copper in Drinking Water. Washington, D.C. : National Academies
Press.
Final LCRI Economic Analysis Appendices
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Nayak, N. C., and A.R. Chitale. 2013. Indian childhood cirrhosis (ICC) & ICC-like diseases: The changing
scenario of facts versus notions. Indian J Med Res 137(6): 1029-1042.
Prasad, R., G. Kaur, R. Nath, and B.N. Walia. 1996. Molecular basis of pathophysiology of Indian
childhood cirrhosis: role of nuclear copper accumulation in liver. Mol Cell Biochem 156(1): 25-30. heal
Russell, K., L.K. Gillanders, D.W. Orr, and L.D. Plank. 2018. Dietary copper restriction in Wilson's disease.
Eur J Clin Nutr 72(3): 326-331. doi:doi: 10.1038/s41430-017-0002-0
Scheinberg, I. H., and I. Sternlieb,. 1996. Wilson disease and idiopathic copper toxicosis. American
Journal Clinical Nutrition 63(5): 842-845. doi:https://doi.org/10.1093/ajcn/63.5.842
Turnlund, J. R., W.R. Keyes, S.K. Kim, and J.M. Domek. 2005. Long-term high copper intake: effects on
copper absorption, retention, and homeostasis in men. American Journal Clinical Nutrition 81: 822-828.
Wapnir, R. A. 1998. Copper absorption and bioavailability. American Journal Clinical Nutrition 67: 1054-
1060. doi:doi: 10.1093/ajcn/67.5.1054S.
World Health Organization. 2004. Copper in Drinking-water 23.
Yadav, J., D. Sharma, S. Yadav, and S. Shastri. 2015. Indian Childhood Cirrhosis: Case Report and Pediatric
Diagnostic Challenges. International Journal of Pediatrics, 3(5-1): 865-869.
Final LCRI Economic Analysis Appendices
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Appendix F: Sensitivity Analysis for IQ Valuation in Children and
Costs and Benefits of the Final Rule at a 3 Percent and 7 Percent
Discount Rate
This appendix contains a sensitivity analysis based on an alternate value of an IQ point, described in
Section F.l. This appendix also contains the costs and the benefits at the 3 and 7 percent discount rates.
The values for an IQ point and case of ADHD at the 3 and 7 percent discount rates, which are used in the
estimation of benefits when using the 3 and 7 percent discount rates (shown in Section F.4) are shown
in Section 064. The rule costs at a 3 percent and 7 percent discount rate are presented in Section F.3. The
rule benefits at a 3% and 7% discount rate are presented in Section F.4. A comparison of the costs and
benefits at a 3% and 7% discount rate are presented in Section F.5.
F.l Sensitivity Analysis for the Value of an IQ point
As a sensitivity analysis for scenario IQ benefits of the final LCRI, the EPA used an alternative estimate
for the value of an IQ point based on Lin et al.'s (2018). This section first briefly describes the Lin et al.
(2018) analysis, then presents the alternate estimate for the value of an IQ point from Lin et al. (2018).
Lin et al. (2018) uses the Bureau of Labor Statistics' National Longitudinal Survey for the year 1979
(NLSY79) to examine how the effect of IQ on earnings varies over the lifecycle to age 50. Lin et al. (2018)
generated estimates that are comparable to Salkever (1995) because they included participants with
zero earnings in the analysis to capture effects related to labor participation. But in contrast to Salkever
(1995), Lin et al. (2018) modeled a reduced form relationship by including IQ in the earnings equation
without controlling for education due its endogeneity. Therefore, the coefficient on IQ captures both the
direct effect on earnings and the indirect effect resulting from increased educational attainment. Lin et
al. (2018) included a similar but not identical set of socioeconomic background variables as Salkever
(1995). In addition, Lin et al. (2018) included three non-cognitive personality traits—sociability, self-
esteem, and perceived level of control over one's life. Lin et al. (2018) also compared the results to
estimates using a more recent survey—the NLSY 1997 cohort (NLSY97), a survey of roughly 9,000
Americans born from 1980 to 1984 (BLS, 2015). They found that the effect of IQ on earnings at age 30
was not significantly different across the two cohorts. Lin et al. (2018) noted that, after adjusting for
years worked, reference age, and IQ scale, their central estimate of the effect of IQ on lifetime earnings
is within two percent of the USEPA (2008) range of estimates. Because Lin et al. (2018) estimates of the
IQ-earnings effect increase with age, their estimate of the IQ-earnings effect at age 30 is smaller than
Salkever (1995) found. According to Lin et al. (2018), their estimates are generally applicable to policies
aimed at improving cognitive performance including reduced exposure to neurotoxins. Further
discussion can be found in Appendix K of the 2021 Final LCRR EA and in USEPA (2019).
The results presented in Exhibit F-l use Lin et al.'s preferred estimates, after performing the conversion
to a per IQ point estimate (see Lin et al. (2018, footnote 42)). Unlike the estimates based on the EPA
64 For low birth weight and cardiovascular mortality, the discounting is done in SafeWater, as described in Chapter
5.
Final LCRI Economic Analysis Appendices
F-l
October 2024
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reanalysis of Salkever (1995), lost earnings while in school are implicitly accounted for in the Lin et al.
(2018) IQ effect percentage.
The overall estimate for males and females combined is computed assuming a population that is 52
percent male based on the male: female ratio of births (CDC, 2017). For the reasons described above,
the estimated values of an IQ point for males and females based on the Lin et al. estimates are lower
than the EPA Salkever reanalysis estimates, and therefore inform our low scenario benefits estimates.
As was the case with the main IQ analysis presented in Chapter 5, the IQ point values need to be
discounted to age 7 for use in the benefits analysis. The Lin et al. value of an IQ point discounted to age
7 is $22,908 using a 2 percent discount rate, in 2022 dollars. Like the main estimate, a declining interest
rate was used after the year 2079 for the 2 percent discount rate.
Exhibit F-l. Estimated National Annual Children's IQ Benefits, All PWSs - 2 Percent Discount
Rate (millions of 2022 USD)
Main Analysis
Lin et al. (2018)
Baseline
LCRI
ncremental
Baseline
LCRI Incremental
Annual IQ Point
Decrement Avoided
59,586
45,371
-14,215
59,586
45,371
-14,215
due to CCT
Annual Value of IQ
Impacts Avoided due to
CCT (millions of 2022
$2,306.1
$1,707.5
-$598.6
$1,251.1
$926.3
-$324.8
USD)
Annual IQ Point
Decrement Avoided
24,476
233,404
208,929
24,476
233,404
208,929
due to SLR
Annual Value of IQ
Impacts Avoided due to
SLR (millions of 2022
$963.6
$8,988.7
$8,025.1
$522.7
$4,876.5
$4,353.8
USD)
Annual IQ Point
Decrement Avoided
226
52
-173
226
52
-173
due to POU
Annual Value of IQ
Impacts Avoided due to
POU (millions of 2022
$9.3
$2.0
-$7.3
$5.0
$1.1
-$3.9
USD)
Final LCRI Economic Analysis Appendices
F-2
October 2024
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Main Analysis Lin et al. (2018)
Baseline LCRI Incremental
Annual IQ Point
Decrement Avoided 0 5,234 5,234
due to Filters
Annual Value of IQ
Impacts Avoided due to .
H , $0.0 $264.8 $264.8
Filters (millions of 2022
USD)
Baseline LCRI Incremental
0 5,234 5,234
$0.0 $143.6 $143.6
Total Annual Child
Cognitive $3,279.0 $10,963.0 $7,684.0
Development Benefits
(millions of 2022 USD)
$1,778.8 $5,947.5 $4,168.7
Acronyms: CCT = corrosion control treatment; IQ = Intelligence quotient; LCRI = Lead and Copper Rule
Improvements; SLR = lead service line replacement; POU = point-of-use; PWSs = public water systems; USD =
United States dollar.
F.2 Valuation of Avoided IQ Loss and Avoided Case of ADHD at 3 Percent and 7 Percent
Discount Rates
The main IQ estimate (used for both the high and low scenarios) based on Salkever at a 3% discount rate
is $28,520 and $7,180 at the 7% discount rate in 2022 dollars. The high and low estimates for ADHD at a
3 percent and 7 percent are summarized in Exhibit F-2. These IQ and ADHD values are using when
estimating benefits under the 3 and 7 percent discount rate scenarios presented in Section F.4 below.
Exhibit F-2: ADHD Valuation at a 3 Percent and 7 Percent Discount Rate
Assumed Persistence of ADHD Into Adulthood
Aae at ADHD
Diaanosis
3%
Discount
Rate
(2022
USD)
7%
Discount
Rate
(2022
USD)
90%
11 (High- Froelich)
$159,928
$104,756
29.3%
7 (Low- Ji)
$111,927
$70,775
Acronyms: ADHD = attention deficit hyperactivity disorder; USD = United States Dollar.
F.3 Final Rule Costs at a 3 Percent and 7 Percent Discount Rate
Exhibit F-3 and Exhibit F-4 present the costs of the final LCRI at a 3 and 7 percent discount rate.
Final LCRI Economic Analysis Appendices
F-3
October 2024
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Exhibit F-3: Estimated National Annualized Rule Costs - 3 Percent Discount Rate (millions of
2022 USD)
Low Estimate
High Estimate
Baseline
LCRI
Incremental
Baseline
LCRI
Incremental
PWS Annual Costs
Sampling
$137.7
$166.7
$29.0
$148.5
$177.4
$28.9
PWS SLR*
$92.8
$1,366.4
$1,273.6
$136.1
$1,913.7
$1,777.6
Corrosion Control
Technology
$558.1
$595.1
$37.0
$656.2
$697.2
$41.0
Point-of Use Installation
and Maintenance
$2.4
$5.0
$2.6
$5.9
$9.4
$3.5
Public Education and
Outreach
$71.2
$281.1
$209.9
$74.2
$320.0
$245.8
Rule Implementation and
Administration
$0.1
$3.9
$3.8
$0.2
$4.0
$3.8
Total Annual PWS
Costs
$862.3
$2,418.2
$1,555.9
$1,021.1
$3,121.7
$2,100.6
Household SLR Costs**
$8.7
$0.0
-$8.7
$28.4
$0.0
-$28.4
State Rule
Implementation and
$39.5
$66.5
$27.0
$43.1
$68.1
$25.0
Administration
Wastewater T reatment
Plant Costs***
$2.9
$2.9
$0.0
$4.7
$4.9
$0.2
Total Annual Rule
Costs
$913.4
$2,487.6
$1,574.2
$1,097.3
$3,194.7
$2,097.4
Acronyms: LCRI = Lead and Copper Rule Improvements; SLR = service line replacement; PWS = public water
system; USD = United States Dollar.
Notes: Previous Baseline costs are projected over the 35-year period of analysis and are affected by the EPA's
assumptions on three uncertain variables which vary between the low and high cost scenarios.
*Service line replacement includes full and partial lead service lines and galvanized requiring replacement service
lines.
**The EPA in the Final 2021 LCRR EA (USEPA, 2020) assumed that the cost of customer-side service line
replacements made under the goal-based replacement requirement would be paid for by households. The agency
also assumed that system-side service line replacements under the goal-based replacement requirement and all
service line replacements (both customer-side and systems-side) would be paid by the PWS under the 3 percent
mandatory replacement requirement. The EPA made these modeling assumptions based on the different levels of
regulatory responsibility systems faced operating under a goal-based replacement requirement versus a
mandatory replacement requirement. While systems would not be subject to a potential violation for not meeting
the replacement target under the goal-based replacement requirement, under the 3 percent mandatory
replacement requirement the possibility of a violation could motivate more systems to meet the replacement
target even if they had to adopt customer incentive programs that would shift the cost of replacing customer-side
service lines from customers to the system. To be consistent with these 2021 LCRR modeling assumptions, under
Final LCRI Economic Analysis Appendices
F-4
October 2024
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the final LCRI, the EPA assumed that mandatory replacement costs would fall only on systems. Therefore, the
negative incremental values reported for the "Household SLR Costs" category do not represent a net cost savings
to households. They represent an assumed shift of the estimated service line replacement costs from households
to systems. The EPA has insufficient information to estimate the actual service line replacement cost sharing
relationship between customers and systems at the national level of analysis.
***Due to many water systems operating both the wastewater and drinking water systems, the EPA is evaluating
the costs of additional phosphate usage for informational purposes. These costs are not "likely to occur solely as a
result of compliance" with the final LCRI, and therefore are not costs considered as part of the HRRCA under
SDWA, Section 1412(b)(3)(C)(i)(lll).
Exhibit F-4: Estimated National Annualized Rule Costs - 7 Percent Discount Rate (millions of
2022 USD)
Low Estimate
High Estimate
Baseline
LCRI
Incremental
Baseline
LCRI
Incremental
PWS Annual Costs
Sampling
$153.7
$167.8
$14.1
$169.0
$180.6
$11.6
PWS SLR*
$126.0
$1,743.6
$1,617.6
$183.2
$2,436.5
$2,253.3
Corrosion Control
Technology
$583.2
$610.1
$26.9
$689.3
$711.6
$22.3
Point-of Use Installation
and Maintenance
$2.4
$4.4
$2.0
$5.7
$8.2
$2.5
Public Education and
Outreach
$77.7
$330.7
$253.0
$82.9
$385.2
$302.3
Rule Implementation and
Administration
$0.2
$6.5
$6.3
$0.3
$6.6
$6.3
Total Annual PWS
Costs
$943.2
$2,863.1
$1,919.9
$1,130.4
$3,728.7
$2,598.3
Household SLR Costs**
$11.3
$0.0
-$11.3
$37.0
$0.0
-$37.0
State Rule
Implementation and
$44.1
$67.3
$23.2
$48.7
$69.5
$20.8
Administration
Wastewater T reatment
Plant Costs***
$2.7
$2.4
-$0.3
$4.2
$4.1
-$0.1
Total Annual Rule
Costs
$1,001.3
$2,932.8
$1,931.5
$1,220.3
$3,802.3
$2,582.0
Acronyms: LCRI = Lead and Copper Rule Improvements; SLR = service line replacement; PWS = public water
system; USD = United States dollar.
Notes: Previous Baseline costs are projected over the 35-year period of analysis and are affected by the EPA's
assumptions on three uncertain variables which vary between the low and high cost scenarios.
*Service line replacement includes full and partial lead service lines and galvanized requiring replacement service
lines.
Final LCRI Economic Analysis Appendices
F-5
October 2024
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**The EPA in the Final 2021 LCRR EA (USEPA, 2020) assumed that the cost of customer-side service line
replacements made under the goal-based replacement requirement would be paid for by households. The agency
also assumed that system-side service line replacements under the goal-based replacement requirement and all
service line replacements (both customer-side and systems-side) would be paid by the PWS under the 3 percent
mandatory replacement requirement. The EPA made these modeling assumptions based on the different levels of
regulatory responsibility systems faced operating under a goal-based replacement requirement versus a
mandatory replacement requirement. While systems would not be subject to a potential violation for not meeting
the replacement target under the goal-based replacement requirement, under the 3 percent mandatory
replacement requirement the possibility of a violation could motivate more systems to meet the replacement
target even if they had to adopt customer incentive programs that would shift the cost of replacing customer-side
service lines from customers to the system. To be consistent with these 2021 LCRR modeling assumptions, under
the final LCRI, the EPA assumed that mandatory replacement costs would fall only on systems. Therefore, the
negative incremental values reported for the "Household SLR Costs" category do not represent a net cost savings
to households. They represent an assumed shift of the estimated service line replacement costs from households
to systems. The EPA has insufficient information to estimate the actual service line replacement cost sharing
relationship between customers and systems at the national level of analysis.
***Due to many water systems operating both the wastewater and drinking water systems, the EPA is evaluating
the costs of additional phosphate usage for informational purposes. These costs are not "likely to occur solely as a
result of compliance" with the final LCRI, and therefore are not costs considered as part of the HRRCA under
SDWA, Section 1412(b)(3)(C)(i)(lll).
F.4 Final Rule Benefits at a 3 Percent and 7 Percent Discount Rate
Exhibit F-5 and Exhibit F-6 present the benefits of the final LCRI at the 3 and 7 percent discount rates
under both the high and low scenarios. These benefits follow the methodology described in Chapter 5,
using the inputs at 3 and 7 percent for IQ and ADHD described in Section. Discounting at 3 and 7 percent
for LBW and CVD Mortality is done in Safewater.
Exhibit F-5: Estimated National Annual Benefits - 3 Percent Discount Rate (millions of 2022
USD)
Low Estimate
High Estimate
Baseline
LCRI
Incremental
Baseline
LCRI
Incremental
Annual Child
Cognitive
Development
Benefits
$778.3
$4,381.0
$3,602.7
$2,114.2
$7,034.7
$4,920.5
Annual Low-Birth
Weight Benefits
$1.0
$5.2
$4.2
$1.8
$5.4
$3.6
Annual ADHD
Benefits
$27.8
$161.7
$133.9
$147.1
$487.5
$340.4
Annual Adult CVD
Premature
$1,657.5
$8,905.6
$7,248.1
$7,750.2
$23,784.8
$16,034.6
Mortality Benefits
Total Annual
Benefits
$2,464.6
$13,453.5
$10,988.9
$10,013.3
$31,312.4
$21,299.1
Final LCRI Economic Analysis Appendices
F-6
October 2024
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Acronyms: ADHD = Attention-Deficit/Hyperactivity Disorder; CVD = cardiovascular disease; LCRI = Lead and Copper
Rule Improvements; USD = United States dollar.
Exhibit F-6: Estimated National Annual Benefits - 7 Percent Discount Rate (millions of 2022
USD)
Low Estimate
High Estimate
Baseline
LCRI
Incremental
Baseline
LCRI
Incremental
Annual Child
Cognitive
Development
Benefits
$158.9
$873.7
$714.8
$433.0
$1,406.8
$973.8
Annual Low-Birth
Weight Benefits
$0.9
$4.4
$3.5
$1.5
$4.6
$3.1
Annual ADHD
Benefits
$14.0
$79.6
$65.6
$73.5
$237.1
$163.6
Annual Adult CVD
Premature
Mortality Benefits
$1,298.8
$6,801.6
$5,502.8
$6,101.8
$18,297.8
$12,196.0
Total Annual
Benefits
$1,472.6
$7,759.3
$6,286.7
$6,609.8
$19,946.3
$13,336.5
Acronyms: ADHD = Attention-Deficit/Hyperactivity Disorder; CVD = cardiovascular disease; LCRI = Lead and Copper
Rule Improvements; USD = United States dollar.
F.5 Comparison of Costs to Benefits and a 3 Percent and 7 Percent Discount Rate
Exhibit F-7 and Exhibit F-8 display a comparison of the costs and benefits of the final LCRI at the 3 and 7
percent discount rates.
Exhibit F-7: Comparison of Estimated Monetized National Annualized Incremental Costs to
Benefits of the LCRI - 3 Percent Discount Rate (millions 2022 USD)
Low Scenario
High Scenario
Annualized Incremental Costs
$1,574.2
$2,097.4
Annualized Incremental Benefits
$10,988.9
$21,299.1
Annual Net Benefits
$9,414.7
$19,201.7
Final LCRI Economic Analysis Appendices
F-7
October 2024
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Exhibit F-8: Comparison of Estimated Monetized National Annualized Incremental Costs to
Benefits of the LCRI - 7 Percent Discount Rate (millions 2022 USD)
Low Scenario
High Scenario
Annualized Incremental Costs
$1,931.5
$2,582.0
Annualized Incremental Benefits
$6,286.7
$13,336.5
Annual Net Benefits
$4,355.2
$10,754.5
F.6 Sensitivity Analysis of Costs and Benefits Assuming Some CWS Customers Refuse Service
Line Replacement
For the final LCRI's economic analysis, the EPA assumed that 100% of property owners would provide
access to the water system to conduct a full service line replacement. This is a reasonable assumption
for purposes of the economic analysis in order to develop a conservative estimate of costs. Moreover,
there are many water systems that have already completed at or near 100% LSLR (e.g., Madison, Wl;
Lansing, Ml; Green Bay, Wl; Newark, NJ; Flint, Ml; Framingham, MA), demonstrating that achieving this
level of customer participation in service line replacement programs is possible. In addition, the final
LCRI contains many requirements and incentives to facilitate water systems gaining access for full
replacement (see section IV.B.3.b of the final LCRI Federal Register notice). Further, the availability of
significant funding from the Bipartisan Infrastructure Law and other sources can reduce or eliminate
direct costs to property owners for service line replacement (where water systems do not pay for the
full service line replacement) (see section III.G of the final LCRI Federal Register notice).
Some systems' have reported lower property owner participation rates in their service line replacement
programs in the past. The EPA does not believe these rates are comparable to those projected under the
LCRI, given the rule's requirements and incentives for systems to gain access to complete the full
replacement of lead and GRR service lines, as well as the significant external funding to support full
replacement of lead and GRR service lines. Given the rule provisions allowing the water system to avoid
replacing the service line where the property owner refuses access (when customer consent is
required), the EPA does anticipate that some property owners may refuse access for the system to
complete full replacement; however, the agency does not expect these refusals to be widespread.
Because the EPA received comments that some customers may refuse to allow CWS assess to replace
lead or GRR service line on their property and that the analysis of the cost and benefits of the proposed
rule did not account for this eventuality, the EPA has conducted a sensitivity analysis of the costs and
benefits of the final LCRI under the assumption that customer agreement is needed to obtain access to
replace customer side lead and GRR service lines (this may not be the case in some systems (e.g.,
Newark, NJ) and that only 85 percent of CWS customers with lead and GRR service lines would provide
access to replace their lines. This 85 percent participation rate for the sensitivity analysis was derived by
approximating the average the replacement rates of two cities' recent service line replacement
program: Denver Water (95%) (Denver Water, 2024 and DC Water (65-75%) (D.C. Lead Line Task Force,
2024). Note that all other final LCRI rule requirements are held constant.
Final LCRI Economic Analysis Appendices
F-8
October 2024
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As shown in Exhibit F-9, which compares the costs of the final LCRI rule to the costs associated with the
sensitivity analysis, under the high scenario, the annualized incremental costs of the sensitivity scenario,
which assumes 85 percent of lead and GRR service lines are replaced, are lower than those of the final
LCRI, $1,919 million versus $1,954 million. This reduction in annualized cost is driven by a reduction in
SLR costs. However, this cost savings is somewhat offset by higher annualized incremental sampling,
CCT, POU, and public education costs in the model. This is because, the EPA made a simplifying
assumption, under the sensitivity scenario, that all systems with lead and GRR service lines could not
replace 15 percent of these lines due to the inability to obtain customer consent, therefore all CWSs
with lead and GRR service lines would never remove all LSLs and would continue to conduct outreach to
lead and GRR service line customers and have higher probabilities of ALEs, which trigger additional LCRI
requirements associated with sampling, CCT, POU, and public education activities. This assumption likely
results in an overestimate of costs associated with the sensitivity scenario, but the EPA has insufficient
information to allow the agency to develop a compliance scenario that reliably estimates the number of
systems that replace all lead and GRR service lines versus those systems that do not.
Exhibit F-9: Estimated National Annualized Rule Cost Comparison Between the Final LCRI and
the LCRI Assuming 85 Percent of Lead and GRR Service Lines are Replaced (High Scenario) - 2
Percent Discount Rate (millions of 2022 USD)
Final Rule
LCRI Assuming 85 Percent of Lead and
GRR Service Lines are Replaced
Baseline
LCRI
Incremental
Baseline
LCRI
Incremental
PWS Annual Costs
Sampling
$143.6
$176.2
$32.6
$143.6
$198.0
$54.4
PWS SLR*
$124.5
$1,763.9
$1,639.4
$124.5
$1,533.1
$1,408.6
Corrosion Control
Technology
$647.8
$692.9
$45.1
$647.8
$704.4
$56.6
Point-of Use Installation and
Maintenance
$5.9
$9.6
$3.7
$5.9
$10.3
$4.4
Public Education and
Outreach
$72.1
$302.2
$230.1
$72.1
$457.9
$385.8
Rule Implementation and
Administration
$0.2
$3.4
$3.2
$0.2
$3.4
$3.2
Total Annual PWS Costs
$994.1
$2,948.2
$1,954.1
$994.1
$2,907.1
$1,913.0
Household SLR Costs**
$26.4
$0.0
-$26.4
$26.4
$0.0
-$26.4
State Rule Implementation
and Administration
$41.8
$67.6
$25.8
$41.8
$73.6
$31.8
Wastewater Treatment Plant
Costs***
$4.8
$5.1
$0.3
$4.8
$5.2
$0.4
Total Annual Rule Costs
$1,067.1
$3,020.9
$1,953.8
$1,067.1
$2,985.9
$1,918.8
Final LCRI Economic Analysis Appendices
F-9
October 2024
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Acronyms: LCRI = Lead and Copper Rule Improvements; SLR = service line replacement; PWS = public water system;
USD = United States dollar.
Notes: Previous Baseline costs are projected over the 35-year period of analysis and are affected by EPA's
assumptions on three uncertain variables which vary between the low and high cost scenarios.
*Service line replacement includes full and partial lead service lines and galvanized requiring replacement service
lines.
**The EPA in the LCRR economic analysis (USEPA, 2020) assumed that the cost of customer-side service line
replacements made under the goal-based replacement requirement would be paid for by households. The agency
also assumed that system-side service line replacements under the goal-based replacement requirement and all
service line replacements (both customer-side and systems-side) would be paid by the PWS under the 3 percent
mandatory replacement requirement. The EPA made these modeling assumptions based on the different levels of
regulatory responsibility systems faced operating under a goal-based replacement requirement versus a mandatory
replacement requirement. While systems would not be subject to a potential violation for not meeting the
replacement target under the goal-based replacement requirement, under the 3 percent mandatory replacement
requirement the possibility of a violation could motivate more systems to meet the replacement target even if they
had to adopt customer incentive programs that would shift the cost of replacing customer-side service lines from
customers to the system. To be consistent with these LCRR modeling assumptions, under the final LCRI, the EPA
assumed that mandatory replacement costs would fall only on systems. Therefore, the negative incremental values
reported for the "Household SLR Costs" category do not represent a net cost savings to households. They represent
an assumed shift of the estimated service line replacement costs from households to systems. EPA has insufficient
information to estimate the actual service line replacement cost sharing relationship between customers and
systems at the national level of analysis.
***Due to many water systems operating both the wastewater and drinking water systems, the EPA is evaluating
the costs of additional phosphate usage for informational purposes. These costs are not "likely to occur solely as a
result of compliance" with the final LCRI, and therefore are not costs considered as part of the HRRCA under SDWA,
Section 1412(b)(3)(C)(i)(lll).
As shown in Exhibit F-10, the estimated annualized incremental benefits under the sensitivity analysis
scenario are lower than under the final LCRI rule ($22.1 billion versus $25.1 billion). This is driven by the
decrease in the number of lead and GRR service line replacements and the associated reduction in lead
exposure related illness. Note some of the reduction in benefits is offset by increased use of CCT and
POU devices given higher rates of ALEs.
Exhibit F-100: Estimated National Annual Benefit Comparison Between the Final LCRI and the
LCRI Assuming 85 Percent of Lead and GRR Service Lines are Replaced (High Scenario) - 2
Percent Discount Rate (millions of 2022 USD)
Final Rule
LCRI Assuming 85 Percent of Lead and
GRR Service Lines are Replaced
Baseline
LCRI Incremental Baseline
LCRI
Incremental
Annual IQ Benefits
$3,279.0 $10,963.0 $7,684.0 $3,279.0 $10,022.7 $6,743.7
Final LCRI Economic Analysis Appendices
F-10
October 2024
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Annual Low-Birth Weight
Benefits
$1.8
$5.7
$3.9
$1.8
$5.2
$3.4
Annual ADHD Benefits
$179.9
$599.5
$419.6
$179.9
$550.2
$370.3
Annual Adult CVD
Premature Mortality
Benefits
$8,174.9
$25,210.0
$17,035.1
$8,174.9
$23,146.3
$14,971.4
Total Annual Benefits
$11,635.6
$36,778.2
$25,142.6
$11,635.6
$33,724.4
$22,088.8
Acronyms: ADHD = attention-deficit/hyperactivity disorder; CVD = cardiovascular disease; IQ = intelligence
quotient; LCRI = Lead and Copper Rule Improvements; USD = United States dollar.
Exhibit F-ll compares the annualized incremental net benefits of the final LCRI and the sensitivity
scenario. The incremental annualized net benefits of the sensitivity scenario (85 percent of lead and GRR
service lines being replaced because of customers refusing water systems access to replace lines) would
be roughly $3 billion lower ($20.2 billion versus $23.2 billion) than the final LCRI.
Exhibit F-ll: Comparison of Estimated Monetized National Annualized Incremental Costs,
Benefits, and Net Benefits Between the Final LCRI and the LCRI Assuming 85 Percent of Lead
and GRR Service Lines are Replaced - (High Scenario) - 2 Percent Discount Rate (millions 2022
USD)
Annualized Incremental Costs
Annualized Incremental
Benefits
Final Rule
$1,953.8
$25,142.6
LCRI Assuming 85 Percent of Lead and GRR
Service Lines are Replaced
$1,918.8
$22,088.8
Annual Net Benefits
$23,188.8
$20,170.0
F.7 References
Bureau of Labor Statistics (BLS). 1979. National Longitudinal Survey of Youth (NLSY) 1979 cohort.
BLS. 2015. National Longitudinal Survey of Youth (NLSY) 1997 cohort.
Centers for Disease Control and Prevention (CDC). 2017. National Vital Statistics Reports. Volume 66,
Number 1; Births: Final Data for 2015. Retrieved from:
https://www.cdc.gov/nchs/data/nvsr/nvsr66/nvsr66 Ol.pdf.
Final LCRI Economic Analysis Appendices
F-ll
October 2024
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D.C. Lead Line Task Force. 2024. DRAFT D.C. Lead Line Task Force Council Report. Available at:
https://doee.dc.gov/sites/default/files/dc/sites/ddoe/service_content/attachments/20220714%20Lead
%20Task%20Force%20Report%20draft_clean.pdf
Denver Water. 2024. Comments on the Notice of Proposed Rulemaking: "National Primary Drinking
Water Regulations for Lead and Copper: Improvements (LCRI)." Available at:
https://www.regulations.gov/comment/EPA-HQ-OW-2022-0801-0849
U.S. EPA. 2008. Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air
Quality Standards for Lead. Benefits Analysis Approach and Results, Chapter 5.
Final LCRI Economic Analysis Appendices
F-12
October 2024
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