and will build on the results of each previous meeting.

1, Expected Results and Timing

Oct., Nov. 1997, Jan. 1998

Schedule information requirements meetings for September,
November and January and publish Federal Register notices for the
November and January meetings at least one month in advance of those
public meetings

February 1998 Identify information requirements of all major EPA uses

February 1999 Modify SDWIS for additional public water system data needed to
address information requirements

Ongoing Participate in the Unregulated Contaminant Monitoring Rule
development

February 1999 Complete software linkage of SDWIS, ICR and STORET

February 1999 Complete software connection for public access

April 1999 Complete test of linkage and system

2. Staffing

Staff from SRMD/TAB, IAD/IMB and Regions will form the EPA nucleus of NCOD Team
along with States and Utility representatives; all development activities will be coordinated
through the Team.

SRMD/TAB will have lead on information requirements

IAD/IMB will have lead on SDWIS modification

Lead OGWDW group for software development will be decided after information
requirements are specified

3. Significant Technical Issues

How States have reported non-detection of contaminant occurrence varies from "non-detect"

to "0" (zero) to "less than detection level," each having a different meaning.

ISSUE: How should a "non-detection" of contaminant occurrence be reported for use
in the NCOD for consistent statistical analysis and interpretation?

RESPONSE: For purposes of the NCOD, a "non-detection" of contaminant occurrence
should be based on the technology used and should be reported as "Jess than
[detection level]," with the detection level of the technology specified.

Since most of the Data Base results are expected to be "non-detections" of contaminant
occurrence, the NCOD may be filled with data that indicates that the contaminants of concern
were not found within the capabilities of the testing technologies used.

ISSUE: Should the NCOD be used to store and retrieve data that will mainly show that

14


quality of data since quick improvements in how voluntary data are reported will not likely occur,
documenting the quality of the data will promote as extensive a use as possible of source water data
for the Data Base over both the near and long term.

Funding - Limits on funding provide a real constraint on designing capabilities in to the system.
Limits on Working Capital Fund expenses will drive the NCOD toward options that minimize these
expenses for both technology and use. This factor promotes the focus on known, proven technology
in the short term. Options to provide flexibility to take advantage of longer term technological
advances will be explored. Limited funds also affect the Working Capital Fund (WCF) for computer
applictions. Options will be examined in the near and long term to minimize WCF expenditures.

Technology - Near term technologies are known and can be managed into the data base design. While
long-term technologies that are technically feasible offer many possibilities, the first applications are
expensive. Focus will be on technology that is known to work for large data bases. For the long term,
flexibility will need to be designed into the system to take advantages of future advances, especially
those that will reduce cost and provide improved use and access. Evolving technologies, such as a
virtual data base that is kept current perhaps more frequently than daily, while attractive in terms of
real time update, may not be necessary for the purposes of the highest priority use, the Administrator's
determinations of which contaminants to regulate and the subsequent regulations (a long term
process), as long as the NCOD is updated regularly.

Note that if (1) SDWIS modernization cannot accomodate the NCOD, (2) software cannot be
developed to link to other data bases containing ambient (source) water quality data, and (3) existing
technology cannot be easily adapted to the needs of the NCOD, the deadlline will not be met. The
remainder of this strategy is designed to address these constraints so that they will not be an obstacle
to NCOD development.

L. Phasing of Development

Because of the limits of time and resources in the near term, the NCOD is proposed to be phased in
over time which reflect the priorities for the NCOD use. The first part of the NCOD development
will focus on information requirements for storing and retrieveing unregulated contaminant occurrence
data in the NCOD to support the Administrator’s determinations of which contaminants to regulate
in the future. The first part will also have a public information component to make information
readily accessible. The second part will focus on second priority uses, adding data sources, and
improving and expanding public access. These second priority uses include organizing data for
review of existing regulations for currently regulated contaminants and improvements in public
access.

M. Timeline

The following Timeline identifies the major activities addressed in this Strategy and may serve as a

8


Cc. Analysis of Existing Data and Data Quality
1. Approach

The analysis of existing data will provide insights to how the Data Base can be improved beyond
current data storage and retrieval methods, what to consider for data quality metadata to be in the Data
Base, and how to plan for future analysis of data from the NCOD. Data sources used in these analyses

“will include the Unregulated Contaminant Information System (URCIS) (Phase I data), unregulated
contaminant monitoring data already in SDWIS from later phases, and STORET for source waters.
Selected USGS data are already reported.to STORET for source waters. Because of its high standards
for data quality, further analysis of US Geological Survey data in its National Water Information
System (NWIS) will provide additional insights for data quality considerations that should be included
in the NCOD.

Existing data will be analyzed to provide direction to current contaminant identification and selection
activities and provide a national overview of the occurrence of contaminants of previous and current
concern. Data from URCIS and SDIWIS will be analyzed first. Initial analyses will be completed in
FY 1997 and 1998.

2. Expected Results and Timing

. Geographic Information System analyses displaying the distribution of the contaminants by
watersheds and States By December 1997
. Statistical analyses by contaminant for the US of the URCIS and SDWIS unregulated

contaminant data by March 1998

. A plan for future analyses of regulated and unregulated contaminants, including interpretation
of data from different sources collected for different purposes or from different sampling
frequencies or detection levels by April 1998

3. Staffing

. Existing staff appear to be adequate in the near-term; however, as the NCOD expands, the
volume of data will expand and may require additional staff. Staff from OST, ORD and
USGS should participate in developing the plan for future analyses, since research needs are
significant.

4. Significant Technical Issues

. Reporting formats and statistical measures used to summarize existing data vary across the
EPA. From a statistical standpoint, much of this data is of poor quality because it can not be
analyzed by the standards of current scientific practice and therefore does lend itself to
consistent reporting without challenges to interpretation.

ISSUE: What are the appropriate reporting formats and statistical methods that should

18


EXECUTIVE SUMMARY

This Working Draft Strategy for developing the National Drinking Water Contaminant Occurrence
Data Base (NCOD or "the Data Base") is a “road map” for the Environmental Protection Agency
(EPA) to complete the first phase of the Data Base by the legislated date of August 1999. The
Strategy incorporates the needs of primary users and recognize the interests of prinicpal stakeholders.
It focuses on the priority of providing contaminant occurrence data to support the EPA Administrator's
determinations of which contaminants to regulate and the resulting regulation development process.
The strategy can be used to communicate with internal and extemal stakeholders regarding their input
to the NCOD development and use.

The Strategy addresses the priorities of:

o Data Base Design and Development, incorporating primary user needs;
o Populating the Data Base;

o Analysis of Existing Data; and

o Plan for Operation, Use and Maintenance of the Data Base.

In the process of addressing these priorities, stakeholder communication will provide essential
feedback to keep NCOD development on course and input to effective use of resources, while public
access to information from the Data Base will be a key consideration in each major step.

Legislative Basis for the Data Base

By August 1999, the Environmental Protection Agency is to assemble and maintain a National
Drinking Water Contaminant Occurrence Data Base. Specific requirements for the NCOD are
identified in the SDWA Amendments, Section 126 which appear as Appendix A to this document.
To accomplish this assignment from Congress, EPA is to:

Use information on occurrence of both regulated and unregulated contaminants in PWS,
Use reliable information from other public and private sources;

Obtain input from interested parties and Science Advisory Board (SAB) on structure and
design, input parameters and requirements, and use and interpretation of the data;

. Solicit recommendations of National Academy of Sciences (NAS) and States, and any
interested parties can provide recommendations, on contaminants to be included, including
additional unregulated contaminants;

° Make data available to public in readily accessible form;

. Include detection of regulated contaminants at a quantifiable level in a PWS;

. Include unregulated contaminant data for PWS above 10,000 population and for representative
sample of PWS serving 10,000 or fewer; and

. Use data from the data base in making determinations for which contaminants to regulate in
the future.

Under the SDWA Amendments Section 125 (amending section 1445 (a)(1)(A)) as amended, the EPA
Administrator has the authority to require submission of parametric data and other information to


the contaminants of concern were not detected?
RESPONSE: For statistical purposes, the NCOD should store the data on all non-detections
in order that the reported not be’misinterpreted.

JSSUE: Concentrations at the level of detection or below constitute the majority of monitoring
data. These data are necessary in the statistical analysis of contaminant occurrence and co-
occurrence but represent a significant effort in reporting and data base storage.

RESPONSE: Explore approaches that other data bases usse in storing “non-detection” data.

4. Management and Coordination Issues

SDWIS Executive Steering Committee and its working committees need to understand the

approach and participate in the process of completing this data base on time.

ISSUE: The NCOD needs to be a regular agenda item of the SDWIS Executive
Committee and related committees.

RESPONSE: Contact all SDWIS Committee chairs to inform them of progress and request
time on their agenda in the future.

ISSUE: Undefined Working Capital Fund expenditures may lead to insufficient funds
for development and use of the NCOD.

RESPONSE: Form subteam of NCOD Team to investigate Working Capital Fund
expenditures and report to the Team

5. Funding/Contracting

OGWDwW will review internal funding for the NCOD annually for both development and
maintenance.

6. Stakeholder Involvement

NCOD National Stakeholders meeting held on May 21-22, 1997, confirmed focus on priority
for EPA use of the NCOD while making these data available to the public.

AWWA sponsored stakeholders workshop on information requirements held in mid- August,
1997, reaffirmed that EPA use of the NCOD was its first priority. The meeting specified
questions needing to be addressed by EPA to which data in the Data Base should respond.
The NCOD Development Team plans to invite States’ representatives to participate on the
Team as it moves into specifying information requirements and developing the structure of the
NCOD.

EPA plans to hold contractor-led information requirements meetings with internal EPA
stakeholders working on contaminant selection; will hold meeting with external stakeholders
to confirm information requirements

EPA will hold a second National Stakeholder’s meeting in the spring of 1998 to inform the

15


PROPOSED SOLUTION: EPA should hold a special public access meeting to discuss these
issues and conduct a feasibility study of expanded public access into the future.

5. Funding

Funds for the Guidance and User Group for travel are needed
Contractor support will be needed for the Guidance and Plan in FY 1998-1999

6. Stakeholder Involvement
The Supplier-User group will provide a mechanism for Stakeholder involvement on a
continuing basis :
A future Stakeholder meeting will provide input to future uses of the NCOD.

E. Other Part I Issues

ISSUE: The SAIC-MOSES Contract will be expiring during the timeframe of this Data Base
development requirement. How does EPA ensure that the work will be done on time?
RESPONSE: The contract transition plan will be reviewed and closely monitored when the time for
transition is near.

Ill.

Part II Activities (beyond August 1999)
A. Enhancements to Design and Structure

Add other data sources - Other data sources will be explored during Part II. These data source
may include: State ambient water quality data bases, Pesticides in Ground Water Data Base,
CERCLIS, and private data bases.

Improvements in the NCOD - As new technology improves capabilities, the NCOD is
expected to be flexible in terms of platform and other features to take advantage of these
improvements and expected cost savings.

B. Populating the Data Base -

Regional implementation of State reporting requirements through annual State
agreements/negotiations are expected to be routine. However, special studies may make
additional demands on the NCOD not originally contemplated.

The State primacy regulation should be modified to include Regulated Contaminant
Occurrence Monitoring Data reporting.

An analysis of regulated contaminant occurrence data from 5 pilot States should be conducted
to identify technical issues, including examination of issues relating to aggregation and

21


obtain an indication of Stakeholder interest. In the near term, EPA may want to consider
relaxing data quality objectives to allow currently reported to enter the NCOD.

4. Management and Coordination Issues
Same as under this heading of “Analysis of Existing Data and Data Quality” below

ISSUE: Some data bases that may be included in this and later parts of NCOD development
have data that were not expected to be applied to regulatory decisions; data contributors may
desire to withdraw their data from these data bases.

RESPONSE: Examine this issue through the Stakeholder process by contacting the data
contributors and inquiring whether problems exist with the use of their data in a regulatory
application.

The current annual workplans negotiated between EPA Regions and States do not routinely
include populating SDWIS with unregulated contaminant occurrence data or regulated
occurrence data.

ISSUE: How does EPA get States to report unregulated contaminant occurrence data as a high
priority each year in planning their work?

RESPONSE: Regional Offices can negotiate with States to include unregulated contaminant
occurrence monitoring data reporting as a high priority in future annual work plans.

5. Funding

Funds will be needed to carry out the regulation development for both the Unregulated and
Regulated Contaminant Occurrence Monitoring Regulations

To conduct the analysis of of regulated contaminant occurrence data from 5 pilot States,
including examination of issues relating to aggregation and interpretation of data based on
collection of data at different times and detection levels and under different quality asurance
and control frameworks, additional funds may be needed

Fund expert panel meeting on contaminant occurrence data analysis and interpretation

6. Stakeholder Involvement

The Association of State Drinking Water Administrators will be consulted on approaches to
obtaining occurrence data from States on an ongoing basis; also explore voluntary submission
of data, especially for regulated contaminant occurrence data.

Regions (many of which participate on the NCOD Team) will negotiate with States not having
the capability to electronically transmit the occurrence data to SDWIS on technical support
needed and completing the transmission to EPA of unregulated contaminant monitoring data
by March 1999 ‘

17


I. Part I Organization of Activities to August 1999
A. Overall Organization
1. The NCOD Development Team and other EPA Organizations

The activities of Part I will be organized and conducted by the NCOD Development Team. This
Team, which is housed in the OGWDW, includes members from across EPA: OST, OWOW, OPP,
OIRM, OSWER. These members include representatives from staff developing SDWIS, ICR and
STORET data bases in EPA's Office of Water. The Team has proposed to invite State and drinking
water industry participants, since they would be providing the data to the Data Base.

As part of the modernization of SDWIS, the EPA participates on SDWIS Executive Steering
Committee along with State members. This committee oversees’ SDWIS development and decides
which data must be reported to SDWIS. Since SDWIS is a core portion of the NCOD for public water
system data, this group will be involved in decisions affecting the NCOD.

2. Other Participants in NCOD Development
Many public and governmental levels and organizations participate in the NCOD development:

The Public: Under the SDWA Amendments, the public can provide input on the design and structure
of the Data Base. The public obviously has a wide range of interests and is most concerned about the
quality of the water it drinks. The public may be represented by a wide range of groups, such as the
consumers action organizations, the League of Women Voters and other entities.

States: States and Territories, in most cases, have the principal enforcement authority for ensuring
that Nation's drinking water supply is safe. They are responsible for reporting violations of maximum
contaminant levels and, in the SDWA Amendments, will be the source of drinking water occurrence
data reported to EPA.

Public Water Systems: Public Water Systems (PWS) are the entities responsible for taking the
samples and in some cases testing the samples to ensure that public water supplies are safe. They
provide their results to State drinking water agencies.

Testing Laboratories: Both public and private laboratories test water samples taken at PWS for the
occurrence of contaminants. They report their results to the PWS and the States.

State organizations: The Association of State Drinking Water Administrators, Association of State
and Territorial Public Health Laboratory Directors and other state groups represent State agencies that
will be aggregating data for reporting on the quality of drinking water and source waters to the public.
EPA's SDWIS currently receives data from States on compliance of public water systems with
national maximum contaminant levels. Some State agencies voluntarily report ambient surface and

12


February 1998 and then Publish Drinking Water Contaminant Candidate List
every 5 years

August 1998 Review monitoring requirements for not fewer than 12
regulated contaminants and Promulgate an any necessary
modifications

August 1999 Assemble National Drinking Water Contaminant
Occurrence Data Base for regulated and unregulated
contaminants

August 1999 Issue Regulations for Unregulated Contaminant
Monitoring

August 1999 and then every 5. | Publish Unregulated Monitoring List for not more than 30
years chemicals

August 2001 and then every 5 | Publish Determinations of whether or not to issue
years regulations for at least 5 contaminants

August 2002 and then every 6 | Review existing regulations and monitoring requirements
years and modify as appropriate

August 2003 and then every 5 | Issue Proposed Maximum Contaminant Level Goals and
years Regulations for Selected Contaminants

February 2005 and then every | Issue Final Maximum Contaminant Level Goals and
5 years Regulations for Selected Contaminants

The Data Base is specifically identified to support the Drinking Contaminant Candidate List that will
identify contaminants for future regulatory consideration and the Administrator’s determination as to
whether to regulate these contaminants. These relationships are shown in “NCOD Relation to the
Contaminant Candidate List and Administrator’s Determinations.”

Additionally, EPA already has data bases that have some of the data required in the NCOD and is
actively modernizing three of them: the Safe Drinking Water Information System (SD WIS) contains
public water system data; the STOrage and RETrieval (STORET) system contains voluntarily reported
ambient water quality data; and the CERCLIS III data base houses water quality data from Superfund
sites, many of which are near public water systems.

G. Objectives of the Strategy

The Strategy is designed to accomplish four objectives:


USGS

Data elements to
link to public
health databases

Jan. 1998 and
continuing

Individual meetings

January 1998 and
continuing -- hold
special meetings;
through NWQMC, link
to source water data

December 1997
meeting on source water
monitoring through
NWQMC, follow-up
meetings in 1998

27



AUDIENCE What do they What do we need | When is it What methods best Time frame/
need to know? to learn from necessary to get this information milestones
them? give/receive this across?
information?
OGWDW Staff: NCOD Team; Statements of Throughout IJRP sessions & review | EPA Staff JRP, Oct.
How does this fit in | CCL/Unreg. objectives, development, of NCOD data 1997, Jan 1998
with OGWDW’s Monitoring/Priority | outcomes and process, but no elements by OGWDW
other projects? Contaminants;Cost/ | technical questions | later than Jan.31, | staff.
Benefit; SDWIS; and specific 1998
Other public access | information needs
efforts, ie:
Consumer
Confidence reports
Data Sharing Priorities for data | Cost Reporting Feb. 1998 Special meeting, Hold special meeting,
Committee/SDWIS Burden of States, , conference call Feb. 1998
PWS
STORET Contaminants, Data | Possibilities to link | ASAP and Special meetings Dec. 1997, hold special
Elements to database continuing meeting with STORET
staff

Feb. 1998, special
meeting concerning
system development.

24



WORKING DRAFT
12/24/97

National Drinking Water Contaminant Occurrence Data Base
Development Strategy

I. Overall Development
A. Introduction

This Strategy for developing the National Drinking Water Contaminant Occurrence Data Base (NCOD
or "the Data Base") is a “road map” for the Environmental Protection Agency (EPA) to complete the
first part of the Data Base development by the legislated date of August 1999. The Strategy
incorporates the needs of primary users and recognize the interests of prinicpal stakeholders. It
focuses on the priority of providing contaminant occurrence data to support the EPA Administrator's
determinations of which contaminants to regulate and the resulting regulation development process.
The strategy can be used to communicate with internal and external stakeholders regarding their input
to the NCOD development and use. Public comment on the Strategy is welcome.’

The Strategy addresses the priorities of:

Data Base Design and Development, incorporating primary user needs;
Populating the Data Base;

Analysis of Existing Data; and

Plan for Operation, Use and Maintenance of the Data Base.

In the process of addressing these priorities, stakeholder communication will provide essential
feedback to keep NCOD development on course and input to effective use of resources, while public
access to information from the Data Base will be a key consideration in each major step. A
communication strategy is presented in Section IV.

B. Legislative Basis for the Data Base

By August 1999, the Environmental Protection Agency is to assemble and maintain a National
Drinking Water Contaminant Occurrence Data Base. (SDWA Amendments, Section 126; see
Appendix A) To accomplish this assignment from Congress, EPA is to:

. Use information on occurrence of both regulated and unregulated contaminants in PWS,

' Public comment on the Strategy should be sent to the National Contaminant Occurrence Data Base Team,
MC 4607, Office of Ground Water and Drinking Water, U.S. Environmental Protection Agency, 401 M St.,SW,
Washington, D C. 20460, by March 16, 1998.


establish regulations and for other purposes. Section 125 also sets out a specific process for requiring
the monitoring and reporting of unregulated contaminants. All PWSs serving more than 10,000
people and only a representative sampling of systems serving 10,000 or fewer people are required to
monitor and report unregulated contaminant monitoring data for inclusion in the NCOD.

Scope of the Data Base

The National Drinking Water Contaminant Occurrence Data Base is a collection of data of
documented quality on unregulated and regulated chemical, radiological, microbial, and physical
contaminants, and other such contaminants likely to occur, in finished, raw and source waters of
public water systems (PWS) of the United States and its territories.

Purpose of the Data Base

The purpose of the NCOD is to support the identification and selection of contaminants for future
regulation, regulation development or other appropriate actions, and review of existing regulations for
possible modification, as well as to inform the public about contaminants in drinking water.

To date, the EPA/OGWDW NCOD Development Team has:

1. Prepared a working document, "Options for the National Drinking Water Contaminant
Occurrence Data Base" (EPA-815- D-97-001), May 1997;

2. Held a Stakeholders Meeting which included participants from States, the drinking water
industry, public health organizations, environmental organizations, and the public; and

3. Had Team members participate in an American Water Works Association meeting on
information requirements for the NCOD.

4. Held two Joint Information Requirements Planning Meetings with internal EPA stakeholders
and external stakeholders

To carry out the purposes identified above and progress beyond the current status, the following
activities are planned:

° Specify information requirements by January 1998, including analytical/interpretive plan for
the data to guide information requirements

. Identify design recommendations by April 1998

. Make modifications to SDWIS by April 1999

° Initiate the regulatory process to obtain data from States for both regulated and unregulated
contaminants

. Develop an analytical/interpretive plan

. Identify other sources of data

. Develop a maintenance plan for data input, public access, new data sources, analytical process
and other key uses

: Complete the initial development of the NCOD by August, 1999, including public access

Public comment on the Strategy is welcome.


ground water quality data to STORET.

Industry organizations: The American Water Works Association, the National Association of Water
Companies, and other industry groups represent the water utilities that collect the samples and in some
cases test the samples for the occurrence of contaminants above the maximum contaminant levels.

Environmental Organizations: Environmental organizations represent a wide range of interests and
are concerned about protecting public health from drinking water contaminants that may be able to
be controlled.

3. Responsibilities

The NCOD Development Team has the responsibility to assemble and maintain the Data Base by
August 1999. To do this, it has identified a contractor to conduct detailed information requirements
meetings and design the data base. The Team has also identified a wide of range of Stakeholders
whose perspectives are important to the Data Base development and use. The Team has prepared this
Strategy to explain its proposed approach to completing Phase I of the NCOD on time.

The Stakeholders, as members of the public, have the responsibility to participate openly in public
meetings to provide input to design and structure of the data base and propose contaminants for which
information might be kept in the Data Base. Participants who attended the first Stakeholders meeting
are identified in Appendix XX.

A. Design and Structure

1. Approach
. Focus on meeting deadline to deliver data base for the highest priority use: support to the
Administrator’s decision whether to regulate contaminants and subsequent regulation
development
° Identify information requirements of all major EPA uses of the data base, but ensure that
highest priority use is met

. Focus on linking SDWIS, ICR and STORET data bases as sources of data for Part I
. Selected data base design must limit Working Capital Fund expenditures to a minimum

° Development of the NCOD will be an iterative approach within Parts as well as between Parts.
For example, information requirements meetings will be both internal and open to the public

13


Other purposes of the Data Base are to:

a. Review current regulations every 6 years;
b. Provide drinking water related data for other regulatory and nonregulatory programs;
and

c. Inform the public of the Nation's drinking water quality.

. Changes in current reporting requirements will be required for review of current
regulations.

E. Benefits of the DataBase

Several benefits may be derived from the development and use of the Data Base:

Relative to the purpose, the NCOD will allow EPA to actively investigate which contaminants
to regulate in a more consistent manner.

The NCOD will provide comprehensive and reliable data on which to base regulatory
decisions.

The NCOD will provide the basis for making decisions on which contaminants to regulate and
which regulations to modify using sound science with respect to identifying which
contaminant occurrence data to apply to regulatory changes, thereby improving future
regulations.

The NCOD will allow the public to examine in detail the contaminant occurrence data used
to support decisions concerning which contaminants to regulate and which regulations to
modify in the future, thereby improving future regulations.

The NCOD will assist in targeting which contaminants and specific regulatory requirements
are needed to protect drinking water, thereby reducing long term reporting and making
regulations more effective in their implementation. These factors are anticipated to lead to
more effective regulations.

F. Relation of the NCOD to other SDWA Activities and Requirements

The National Contaminant Occurrence Data Base supports many other activities identified in the
SDWA Amendments. These activities are described in the table below and appear in the Timeline
of “Requirements of the SDWA Amendments of 1996”:



be used to summarize the existing data, which may not be fully documented
as to its quality?

RESPONSE: OGWDW will apply the approach of its analytical plan to the existing
unregulated data and review them at the next Stakeholders Meeting.

5. Management and Coordination Issues

° ISSUE: States (except RI, ND, MO and MA) currently hold the Phase II monitoring data and
have not reported it to EPA. Approximately 85-90 percent of the States have this data in
electronic format. However, some of these States do not have the software to convert the data
into a format compatible with SDWIS.

RESPONSE: First, inform states of need to submit data, then put out call for data. Regions
will assess States’ needs for technical assistance to put the data in electronic form. For States
that do not have the data in electronic form or do not have the software to report it to SDWIS,
provide technical support, funded by Headquarters and delivered by the Regions, to help States
put data into the format for SDWIS reporting.

5. Funding

° Funding technical support to States that cannot report electronically the existing unregulated
monitoring will be necessaary in FY 1998.

° A contractor will examine data quality metadata and objectives of data sources, possible
analytical approaches, analytical plan development, and a statistical design. The US
Geological Survey will be assisting in developing a statistical approach for a “representative
sample of small and medium systems” as required in SDWA Amendments sections 125 and
126 through the development of the Unregulated Contaminant Monitoring Regulation.

6. Stakeholder Involvement

° Stakeholders will review the results of initial analyses and provide input on their utility and
identify implications for the NCOD development. This will occur in special meetings with
targeted organizations and at the Stakeholders meetings.

D. Plan for Operation, Use and Maintenance of the Data Base
1. Approach

The SDWA clearly indicates that the NCOD is to be maintained. To do so, a plan will be developed
to transition to Part II of the Data Base and keep it on course.

2. Expected Results and Timing

19


W

EPA

United States Office of Water EPA 815-D-97-005
Environment: ‘al Protecti ion (4606) December 1997

National Drinking
Water Contaminant
Occurrence

Data Base -
Development Strategy

Background Document
(Working Draft)

Revised
December 1997


I. Current Status

As of September 1997, the Office of Ground Water and Drinking Water is actively working to
identify information requirements with Stakeholders, review State and Federal data bases, and identify
statistical and analytical needs. EPA has limited occurrence data for 48 unregulated contaminants in
a separate data base set up in 1991, and will be working with States to obtain the existing unregulated
contaminant occurrence data that they store beyond the Phase I data previously reported. Currently,
States are not required to report regulated contaminant occurrence data, but only have to report
noncompliance of PWS above maximum contaminant levels (MCL). The Unregulated Contaminant
Monitoring Regulation is to be completed in the same timeframe as the NCOD. This regulation will
establish criteria for State monitoring programs for unregulated contaminants, will require fewer (up
to 30 rather than the current 48) unregulated contaminants to be monitored and reported to this Data
Base, and, for small and medium size systems (serving 10,000 or fewer people), will require that only
a representative sample of such PWSs are to be monitored. A separate regulation will be drafted to
obtain the regulated contaminant occurrence data from PWSs in the future.

To date, the ERA/OGWDW NCOD Development Team has:

1. Prepared a working document, "Options for the National Drinking Water Contaminant
Occurrence Data Base" (EPA-815- D-97-001), May 1997;

2. Held a Stakeholders Meeting which included participants from States, the drinking water
industry, public health organizations, environmental organizations, and the public; and

3. Had Team members participate in an American Water Works Association meeting on
information requirements for the NCOD.

4. Held two Joint Information Requirements Planning Meetings with internal EPA stakeholders
and external stakeholders

To carry out the purposes identified above and progress beyond the current status, the following
activities are planned:

° Specify information requirements by January 1998, including analytical/interpretive plan for
the data to guide information requirements

. Identify design recommendations by April 1998

. Make modifications to SDWIS by April 1999

. Initiate the regulatory process to obtain data from States for both regulated and unregulated
contaminants

. Develop an analytical/interpretive plan

. Identify other sources of data |

. Develop a maintenance plan for data input, public access, new data sources, analytical process
and other key uses ,

J. Factors Facilitating NCOD Development


1. Meet mandated deadlines of the Safe Drinking Water Act;

2. Identify the phases of work that will enable EPA to meet this timeline;
3. Identify specific timeframes for the work to be done;

4. Identify resources needed.

H. Principles for Developing the Data Base

Several principles will guide the development of the NCOD. These principles are:

1.

wn

10.

11.

SDWIS will be the “core” of the NCOD for public water systems data on regulated and
unregulated contaminants. The principal components of SDWIS that will-be this "core" will
include its Sampling and Inventory Business Systems. Raw water data from PWSs and
ambient water quality data from other data bases will form the "core" of the NCOD for source
water data.

Both regulated and unregulated contaminant data are to be included.

To accomplish assembling the NCOD by August 1997, the data reported by States to EPA for
regulated and unregulated contaminant occurrence must be in electronic form.

As a first priority, the NCOD must support the Administrator’s decisions concerning whether
to regulate a contaminant in the future and the subsequent regulation development, with
potential linkages to be identified to public health data bases in the future.

The NCOD must have high quality data for use in the Administrator's determinations to
regulate and set standards for a drinking water contaminant. Data of lesser quality in the Data
Base may be used for the purposes of placing a contaminant on the Contaminant Candidate
List.

Key stakeholders internal and external to EPA must be involved in the development of the
NCOD.

The NCOD must build on existing data sources, both inside and external to EPA, and
maximize the use of existing data.

Monitoring may be required under other authorities of the SDWA for other specific purposes,
and the resulting data will support the NCOD.

The NCOD must minimize demands on the EPA Working Capital Fund in its function and
operation.

Keep it simple - include only the data in the NCOD needed to satisfy the specific user
requirements and the law.

Because of the specific deadline assigned to the NCOD and the limited timeframe, EPA will
satisfy the objectives of the NCOD through application of existing technology and without
interrupting progress for early refinements once decisions have been made about structure.
Refinements may be identified and placed on hold to be addressed in later phases of the
NCOD development, as long as legislated objectives are still met in the near term.


OMB Cost impact/ Major hurdles to Dec. 1997 Special meeting with _| Special meeting
burden and benefits | keep NCOD from OMB scheduled for Dec. 1997
of NCOD moving forward to
development
OGC Requirements of Confirm legal Data elements, 9/98 | Special meetings Ongoing
law met requirements met | Design, 9/98
Use, 9/98
Public access, 4/99
Academia Contaminants, Research results August 1999 Internet access August 1999 and
Data elements and continuing thereafter
thereafter
Media Progress in Best ways to April 1998 Internet access April 1998 - Data
database inform them April 1999 In-person contact element and platform
development August 1999 decision,
Expected quality of | What is most April 1998 - SH meeting
results; applications | important to them Future SH meetings
of results .
General Public What is the NCOD | Public access issues | Jan. 1998 Federal Register Jan. 1998- Public access
& why should they | What info would Interest/Trade Groups | meeting
care about it & get | they like to know Feb. 1998 - SH meeting
| involved Future SH meetings
Public Health, Data elements to Data elements to Jan. 1998 Special meeting January 1998 - Special
physicians link to public link to puboic meeting ,
health databases health databases

26



States | Use of database User requirements | February 1998 - JRP Meetings of ASDWA,
Priority for data Electronic - Meeting with Feb. 1998
reporting format reporting technical committees | Stakeholder meeting,
capability, cost of of ASDWA Feb. 1998
reporting if - Stakeholder meetings
different from - State participation on | SH meeting
current process NCOD team
: weekly NCOD meetings
EPA Regions State reporting State electronic Feb. 1998, NCOD team members | Weekly team meetings,
requirements reporting Aug. 1999 participate in weekly Feb. Stakeholder meeting
capabilities, costs : meetings, stakeholder
to change meetings, regional
conference calls
Mechanisms to
communicate with
States/Utilities
Environmental Accessibility of User needs of Jan. 1998 Jan. JRP Special meeting, Nov.
Groups data, public Special JRP 1997
Info Exchange Environmental
Data elements Meetings on public Informational exchange
health, public access, | meeting, Jan. 1998
environmental factors | JRP - Jan 1998
Drinking Water Data elements, Reporting . Jan. 1997" Jan. JRP Jan. 1998 JRP
Industry reporting capability for
requirements expanded data
elements

25



° Use reliable information from other public and private sources;

° Obtain input from interested parties and Science Advisory Board (SAB) on structure and
design, input parameters and requirements, and use and interpretation of the data;
. Solicit recommendations of National Academy of Sciences (NAS) and States, and any

interested parties can provide recommendations, on contaminants to be included, including
additional unregulated contaminants;

° Make data available to public in readily accessible form;

. Include detection of regulated contaminants at a quantifiable level in a PWS;

. Include unregulated contaminant data for PWS above 10,000 population and for representative
sample of PWS serving 10,000 or fewer; and ‘

. Use data from the data base in making determinations for which contaminants to regulate in
the future.

Under the SDWA Amendments Section 125 (amending section 1445 (a)(1)(A)), the EPA Administrator
has the authority to require submission of parametric data and other information to establish regulations
and for other purposes. Section 125 also sets out a specific process for requiring the monitoring and
reporting of unregulated contaminants. All PWSs serving more than 10,000 people and only a
representative sampling of systems serving 10,000 or fewer people are required to monitor and report
unregulated contaminant monitoring data for inclusion in the NCOD.

C. Scope of the Data Base

The National Drinking Water Contaminant Occurrence Data Base is a collection of data of
documented quality on unregulated and regulated chemical, radiological, microbial, and physical
contaminants, and other such contaminants likely to occur, in finished, raw and source waters of
public water systems (PWS) of the United States and its territories.

D. Purpose of the Data Base

The purpose of the NCOD is to support the identification and selection of contaminants for future
Oregulation, regulation development or other appropriate actions, and review of existing regulations for
possible modification, as well as to inform the public about contaminants in drinking water.

The Safe Drinking Water Act Amendments specify the purposes of the NCOD. These purposes in
turn guide user requirements for Data Base development.

1. The primary purpose of Data Base is to support the Administrator’s determinations of which
contaminants to regulate in the future and the resulting regulation development.

° This purpose necessitates high priority for obtaining existing unregulated contaminant
monitoring data from States and completing the Unregulated Contaminant Monitoring
Rule.


States and the public of the progress in NCOD development and to obtain additional input.
° EPA will obtain input from testing laboratories in formulating which and how data is reported.
° EPA will ensure that small system considerations are taken into account through consultation
with organizations such as the National Rural Water Association and the National Association
of Towns and Townships. :
° EPA will ensure that States are fully consulted and informed on the NCOD by ensuring that
the NCOD is addressed in meetings that EPA Regional Offices hold with States drinking water
programs in the annual or biennial workplan negotiation process.

B. Populating the Data Base
1. Approach

Populating the data base will focus first on unregulated contaminants: (1) obtaining existing data for
the NCOD, and (2) completing the Unregulated Contaminant Monitoring Rule on time. Regulated
contaminant occurrence data can be obtained from-volunteer States and from agencies conducting
ambient water quality monitoring before August 1999.

1. Expected Results and Timing
March 1999 Request existing (already collected) data collected under 40 CFR

141.40(n)(11), 40 CFR 141.40(m)(12), 40 CFR 141.40 (e), and 40 CFR 141.40
Gj) from States to be reported to SDWIS

August 1999 Complete the Unregulated Contaminant Monitoring Rule and List
January 1998 Hold an expert panel on analysis and interpretation of contaminant occurrence
data
3. Staffing
. Should add an audit function for data review before and after use; this would require adding

staff for which no current position has the scope to address

4. Significant Technical Issues

. Reporting of non-detections may present a significant workload to States to quality assure the
data. From a statistical standoint, this data may be the most significant that the States can
report relative to presenting a sound scientific case that a particular contaminant should be
regulated or not based on occurrence.

ISSUE: How should non-detections be reported for use in the NCOD?
RESPONSE: The Team will raise this issue in the information requirements meetings to

16


interpretation of data based on collection of data at different times and detection levels and
under different quality asurance and control frameworks.

Cc. Analysis of Data and Data Quality

e Input to the Contaminant Selection and Unregulated Contaminant Monitoring Listing
processes = As these processes become more refined with experience, analysis of data will
point to needs of the NCOD not originally contemplated. This activity will provide areas of

possible improvement for the NCOD. Additionally, the NCOD will grow to be a very large
data base overtime. More analytical capability will need to be focused on the interpretation
of the increasingly large Data Base, As a result, OGWDW may need additional statistical
support to examine the large volume of data and the various interpretation issues.

D. Use and Maintenance of the Data Base

. Identification of specific outputs and actions to maintain the Data Base will be necessary. The
Supplier-User Group will grow in importance to ensure that the NCOD is current and useful.

TV. Communications Strategy

Complex communication issues are inherent to the NCOD’s development. The NCOD team at EPA
is incorporating user needs into every phase of database development. As the NCOD will be the
infrastructure storing data on drinking water contaminants for future regulatory decision-making, it
needs to be developed in coordination with EPA’s drinking water standards teams. EPA will provide
guidance to those required to report, and those who want to voluntarily report, data to the database.
EPA will need to design into the database information concerning the relative risk of contaminant
occurrence for the understanding of the public, once the data are publicly available.

The Overall Mission and Message of the OGWDW Program is that:

EPA, states, and their many partners will protect public health by ensuring safe drinking water and
protecting ground water.

The Principles guiding this program are:

Prevention.

Regulations and risk-based priority setting, using sound science, data and standards
Partnership and involvement

Flexibility and effectiveness in implementation

Accountability

Results

eee eee

22


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reference for the remainder of the Strategy. The Timeline is divided into six contributing components
addressed in this Strategy: Delivery Order for the NCOD development, Stakeholder Input/Access,
State/Federal Data Base inputs, Populating the data base, Communication, and Analysis of Statistics
Delivery Order. A separate Communication Strategy appears at the end of this document.


Reg Goreme a ASONAGat. Deco Teposit oy
Decsion ot 97  Machsg = FSB Fateaal to States
Ago Consult Evelyn Mecho, 4 Neches O98 Nechso

Stakeholder Input/Access Aug. 99

>
' t A | Pan for i]
RP Plan WFCINCOD
NcOD RP Eaty InteractionPubtic ‘Sept. 98 Implement
Panning Sept. 97 Nov.97 Analysis Access Sta. Planfor
Meeting & Jan 9gFeb.98 Sept 98 holder Public
dy $7 ‘Work Plan Groups & wConsum. of Aug 99
Approval Interviews Conf. Rep. pac
Aug. 97 Oct 98
. Communication Aug. 99
! | Ho ii ASDWA I |
Internet  NCOD Nat'l Mtg Stakeholder
AWWA : Work ADSWA
User Reqitg. 97 Update werage. " nidal Reqs Mtg- Obtain Oct. 98
; on OGWDW = ment pees existing public ADSWA
Aug. 87 WebPage Meeting access Feb. 99


DISCLAIMER

This “Strategy” Paper represents an effort by EPA staff to consolidate into a single
working draft Background Document a number of suggestions and ideas generated
in the course of discussions by the Office of Ground Water and Drinking Water’s
Team developing the National Drinking Water Contaminant Occurrence Data Base
(NCOD). This draft will be subject to extensive revision, development, and
qualification as the Agency proceeds through both the external public and internal
EPA deliberative processes. The information presented in this document is a
discussion of the overall approach being used by the EPA and should not be
interpreted as EPA policy.

COMMENTS ON THE STRATEGY
Public comments on the Strategy may be sent to:

National Contaminant Occurrence Data Base Team
MC 4607

Office of Ground Water and Drinking Water

U:S. Environmental Protection Agency

401 M Street, SW

Washington, D.C. 20460

by March 16, 1998.


Ongoing Maintain continuing liaison with the Contaminant Identification Team to
ensure its needs are met beyond the first phase of NCOD development

March 1999 Prepare data reporting guidance for all potential reporting entities (States,
other public agencies, and private sources) - A subteam will need to be
established.

March 1999 Hold a Stakeholders meeting to examine options for Part II of NCOD
development

August 1999 Establish an NCOD supplier-user group to provide ongoing input to the

maintenance of the Data Base and develop a Plan for the Operation, Use and
Maintenance of the NCOD; the supplier-user group may include EPA CIM,
Regulation Manaagers, States, PWS, environmental organizations and the
public.

3. Staffing

Staffing appears adequate at this time to develop this guidance and plan. This activity may require
Regional staff to ensure its implementability.

4. Significant Technical Issues

Not all data bases use the same definitions and data fields. Furthermore, as EPA adopts a performance
based laboratory quality assurance/quality control actions will be difficult and may present a problem
comparing data quality from one laboratory or State to another.

ISSUE: How will consistent data quality reporting be ensured into the future?

RESPONSE: The newly organized National Water Monitoring Council may address these issues and
make recommendations.

4. Management and Coordination Issues

° ISSUE: In Phase II of NCOD development, connections to other data bases are expected to
occur. The need to minimize Working Capital Fund expenditures should drive solutions to
this but limit the capture of other important data.

PROPOSED SOLUTION: Enter into detailed discussions with STORET to house data from
additional sources not currently putting data into that system. Other options should also be
explored before August 1999.

. ISSUE: Travel expenditures for Regions and States to participate in the NCOD Users Group
for Guidance and Plan development may need to be considered for best long term use and
maintenance of the NCOD
PROPOSED SOLUTION: Ensure Headquarters sets aside funds to cover a significant portion
of the travel costs for the participants of the NCOD Users Group.

° ISSUE: To what extent will public access be provided and will there be cautions on
interpretations of the data?

20


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The NCOD fits the test in the second “principle,” as the infrastructure for making future regulatory
decisions -based on sound science and good data.

The team used the following matrix to outline communications needs and coordinate them with phases
of Data Base development, with more targetted messages to specific audiences.

23


Many factors facilitate the development of the NCOD at this time:

SDWA Amendments - require sound science for regulatory decisions; sound data is one of the first
steps in applying sound science

Contaminant Candidate List - is part of the Administrator’s contaminant selection determination

Administrator’s determination to regulate a contaminant - is the primary use of the data base,
identified in section 126 of the SDWA Amendments

Electronic information technology - will provide flexibility up to the point of deciding how to store
and retrieve the data. Technology, already exists to put the Data Base together in several forms, the
challenge being to identify the structure that ensures ease of use in decisions and in making
information from it readily accessible to the public within the time specified by law.

Geographic information systems technology - provides the opportunity to display the data and
analyses spatially and potentially allows the public to "see" where contamination may have occurred
in their locality.

Unregulated contaminant monitoring data - already exists for an initial phase of monitoring completed
in the early 1990s. States have continued to gather unregulated contaminant monitoring data. Several
states have reported further unregulated contaminant monitoring data to SDWIS since that time.

Unregulated contaminant monitoring regulation - has the same deadline as the NCOD and will provide
the basis for the obtaining the data to support the Administrator’s determinations of which
contaminants to regulate in the future and subsequent regulation development.

Regulated contaminant occurrence data - exists for all the 83 regulated contaminants for each State's
PWSs in laboratory reports, but some states do not store them and those that do store these data do
not routinely report them to EPA since there is no current regulation requiring this reporting.

K. Factors Constraining NCOD Development

Several factors may pose constraints to NCOD development and require responses as soon as possible
to ensure that the NCOD stays on schedule. Some of these factors offer direction in the near term that
may actually be a benefit to system development and maintenance:

Time - The NCOD is the only data base in the Office of Water with a specific date set for assembly.
Managing the NCOD development toward completion by August 1999 limits options for designing
capabilities into the data system, but may be a facilitating factor since attention will be paid to existing
technologies that work for large data bases. In resonse, development will focus on known, proven
technology for the near term and rely on existing data systems, While limited time will also affect the

7