## Information Collection Request for
Contaminant Occurrence Data in Support of EPA's Third Six-Year Review of National Primary Drinking Water Regulations

November 2009

Prepared by: The Cadmus Group, Inc.
57 Water Street Watertown, MA 02472

Prepared for: Nancy Parrotta, Project Officer Shari Bauman, Work Assignment Manager Karen Wirth, Alternate Wo rk Assignment Manager U.S. Environmental Protection Agency
Office of Ground Water and Drinking Water

Standards and Risk Management Division 1201 Constitution Ave, N.W.

Washington, D.C. 20004Six-Year 3 ICR November 2009

Page i of iii 

### TABLE OF CONTENTS

1 IDENTIFICATION OF THE IN FORMATION COLLECTION ....................................... 1 1(a) Title and Number of the Information Collection .................................................. 1 1(b) Short Characterization ........................................................................................... 1

2 NEED FOR AND USE OF THE COLLECTION .............................................................. 3 2(a) Need/Authority for the Collection ......................................................................... 3 2(b) Practical Utility/Users of the Data ........................................................................ 3

3 NON-DUPLICATION, CONSULTATIONS A ND OTHER COLLECTION CRITERIA 5 3(a) Non-duplication ..................................................................................................... 5 3(b) Public Notice Required Prior to ICR Submission to OMB ................................... 5 3(c) Consultations ......................................................................................................... 5 3(d) Effects of Less Frequent Collection ...................................................................... 6 3(e) General Guidelines ................................................................................................ 6 3(f) Confidentiality ....................................................................................................... 6 3(g) Sensitive Questions ............................................................................................... 6

4 RESPONDENTS AND THE INFORMATION ................................................................. 7 4(a) Respondents and NAICS/SIC Codes .................................................................... 7 4(b) Information Requested .......................................................................................... 7 4(b)(i) Data Items ...................................................................................................... 7 4(b)(ii) Respondent Activities .................................................................................. 11
5 INFORMATION COLLECTED–AGENC Y ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT ...................................... 13 5(a) Agency Activities ................................................................................................ 13 5(b) Collection Methodology and Management ......................................................... 15 5(c) Small Entity Flexibility ....................................................................................... 17 5(d) Collection Schedule ............................................................................................. 18

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION .......................... 19 6(a) Estimating Respondent Burden ........................................................................... 20 6(b) Estimating Respondent Costs .............................................................................. 21 6(c) Estimating Agency Burden and Costs ................................................................. 21 6(c)(i) Agency Burden ............................................................................................. 22 6(c)(ii) Agency Cost ................................................................................................. 23 6(d) Estimating the Respondent Universe and Total Burden and Costs ..................... 24 6(e) Bottom Line Burden Hours and Cost Tables ...................................................... 24 6(f) Reasons for Change in Burden ............................................................................ 25 6(g) Burden Statement ................................................................................................ 25

APPENDICES .................................................................................................................... .......... 27 Appendix A: Detailed Burden and Cost for States .......................................................... 28 Appendix B: Detailed Burden and Cost for EPA ............................................................ 32Six-Year 3 ICR November 2009

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### LIST OF EXHIBITS

Exhibit 4-1: Occurrence Da ta to Be Requested ............................................................................. 8 Exhibit 4-2: Requested Data Categories ....................................................................................... . 9 Exhibit 6-1: Average Annual State Burden and Costs................................................................. 21
Exhibit 6-2: Annual EPA Burden and Costs................................................................................ 23
Exhibit 6-3: Bottom Line Burden and Costs................................................................................ 24
Exhibit A-1: Estimated State Burden for Occurrence Data Submission ..................................... 28
Exhibit A-2: Estimated 2012 Salaries and Overhead Costs from ASDWA State Resource Model

............................................................................................................................... ............ 31
Exhibit B-1: Estimated Burden and Labor Co sts to EPA for Occurrenc e Data Collection and Analysis....................................................................................................................... ...... 32Six-Year 3 ICR November 2009

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ACRONYMS

AMWA Association of Metropolitan Water Agencies
AWWA American Water Works Association
ASDWA Association of State Dr inking Water Administrators CFR Code of Federal Regulations DQO Data Quality Objective
DBPR Disinfectants and Di sinfection Byproducts Rule EPA Environmental Protection Agency FBRR Filter Backwash Recycling Rule FR Federal Register
FTP File Transfer Protocol
GWR Ground Water Rule ICR Information Collection Request
IESWTR Interim Enhanced Surface Water Treatment Rule
MCL Maximum Contaminant Level mg/L Milligrams per Liter
NAICS North American Indus try Classification System
NCOD National Contaminant Occurrence Database NPDWR National Primary Drinking Water Regulation O&M Operation and Maintenance OMB Office of Management and Budget PRA Paperwork Reduction Act PWS Public Water System PWSID Public Water System Identification Number PWSS Public Water System Supervision QA/QC Quality Assurance/Quality Control RFA Regulatory Flexibility Act
SBA Small Business Administration SBREFA Small Business Regulatory Enforcement Fairness Act SDWA Safe Drinking Water Act SDWIS Safe Drinking Water Information System
SWTR Surface Water Treatment Rule
TCR Total Coliform RuleSix-Year 3 ICR November 2009

Page 1 of 34 

### 1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title: Information Collection Request for Contaminant Occurrence Data in Support of
EPA's Third Six-Year Review of Nati onal Primary Drinking Water Regulations

OMB Control Number: 2040-0275

EPA Tracking Number: 2231.02

1(b) Short Characterization

The Safe Drinking Water Act (SDWA), as amended in 1996, requires that the U.S. Environmental Protection Agency (EPA) revi ew existing National Pr imary Drinking Water Regulations (NPDWRs) no less often than every six years and, if appropriate, revise them. EPA is currently completing its second Six-Year Re view cycle (2003-2009) du ring which the Agency is performing a detailed review of 71 chemical NPDWRs which were promulgated prior to 2003.
The occurrence assessments conducted for the second Six-Year Review were based on compliance monitoring data collected from 1998 to 2005 and voluntarily submitted by States 1
and other primacy agencies under the current Information Collection Request (ICR No. 2231.01, 71 FR 32340). EPA expects to publish the review results by the end of 2009.

EPA is issuing this Information Collection Re quest (ICR) as a one-time request for States to voluntarily submit historical regulated mon itoring data in 2012. To comply with the 1995 Amendments to the Paperwork Reduction Act (PRA), this ICR estimates the potential cost to
States for data submission acro ss the 3-year ICR period of 2010-2012. This is the renewal of the current ICR No. 2231.01 (71 FR 32340).

With this ICR, EPA's Office of Water is requesting that States submit compliance monitoring data (occurrence data and treatment technique data) fo r public water systems (PWSs) to support the Agency’s third Six-Year Review . Monitoring data from 2006 to 2011 will be requested for all regulated chemical and radiological contaminants, microbiological contaminants, as well as data from the Ground Water Rule (GWR), Surface Water Treatment Rules (SWTRs), Long Term 1 and 2 Enhanced Surface Water Treatment Rules (LT1 and LT2)
and Interim Enhanced Surface Water Treatment Rule (IESWTR), Stage 1 and 2 Disinfectants and Disinfection Byproducts Rules (DBPRs), and Filter Backwash Recycling Rule (FBRR). This review cycle, hereafter referred to as Six- Year Review 3, encompasses the review cycle of 2009-2015. Through the Six-Year Review proce ss, EPA reviews existing NPDWRs and evaluates whether potential revisions are appropriat e to maintain or improve the health of those persons served by public water systems. Thes e compliance monitoring records (including all results for analytical detections and non-de tections) and other compliance summaries (e.g.,

1 Throughout this document, the terms "State " or "States" are used to refer to th e States, Tribal Programs and Territories.Six-Year 3 ICR November 2009

Page 2 of 34 sanitary survey and corrective action information) provide the data needed to conduct statistical estimates of national occurrence of each regula ted contaminant and are used to evaluate regulation effectiveness. The re view of this data will support EPA's decisions regarding whether revisions to existing regulati ons are appropriate. In addi tion, the 1996 SDWA Amendments require the Agency to maintain a national dr inking water contaminant occurrence database ( i.e.

, the National Contaminant Occurrence Data (NC OD)) using occurrence data for both regulated and unregulated contaminants in PWSs. Thus, through this data collection, EPA will also be fulfilling some of its SDWA requirements as they relate to national occurrence data.

States can upload data using a designated, secu re file transfer protocol (FTP) site. After receiving the data, EPA will conduct the n ecessary data review, editing, and quality assurance/quality control (QA/QC) across all State data sets to allow uniform assessments across all the data sets, and allow subsequent data mana gement and analysis to provide an overview of
occurrence estimates at the national level. States will be provided with th e edited data and/or the log of the edits that were applie d to the data upon request prior to the posting and storage of data in the NCOD. Following final QA/QC of data, a su mmary of the data will be made available to the public through NCOD and/or ot her appropriate mechanisms.

Although these data submissions are not requir ed of the State agen cies, EPA is required to conduct this ICR analysis because more than nine non-Federal entiti es will be asked to respond to these data requests. Because this is a data request, not a regulation, this ICR will remain separate from the Public Water Syst em Supervision (PWSS) Program ICR, which includes burden and cost estimates for many ot her administrative activities and information collection requirements of SDWA.

The total annual burden and co sts to the 56 potential State respondents associated with this ICR is estimated to be 756 hours and $37,922 pe r year over the 3-year ICR period of 2010- 2012, or 13.5 hours and $677 per year per State. A ll respondent costs are for labor activities
associated with the time it takes to read a nd understand the request for compliance monitoring data, compile and submit existing data in an electronic format, and respond to questions regarding these data. This repr esents the "cost burden" as repo rted in the official Office of Management and Budget (OMB) inventory. Note that these costs are for labor; there are no capital costs associated with the activities covered by this ICR. Estimated burden and labor cost varies across States, depending on their current data storage system ( i.e. , State Drinking Water Information System/State version (SDWIS/State) vs. proprietary data systems) and expected participation levels. No burden to PWSs is associated with this data collection.

Over the ICR years of 2010-2012, EPA is expect ed to incur an average annual cost of $272,444 for labor associated with this program, in cluding: extracting or do wnloading State data; initial data screenings and conversion to uni form structures; communi cating and coordinating with States; and data management and analysis.Six-Year 3 ICR November 2009

Page 3 of 34 2 NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Through the Six-Year Review process, th e Agency reviews existing NPDWRs and evaluates whether potential revisions are appropriat e to maintain or improve the health of those persons served by public water systems. Section 1412(b)(9) of SDWA States: "The Administrator shall, not less ofte n than every 6 years, review a nd revise, as appropriate, each national primary drinking water regulation promul gated under this title. Any revision of a national primary drinking water regulation shall be promulgated in accordance with this section, except that each revision shall maintain, or pr ovide for greater, protec tion of the health of persons." Compliance monitoring data provide information critical to these assessments. Without an understanding of where and at what le vels these contaminants are occurring in public drinking water, EPA cannot assess the risk to public he alth and whether pote ntial revisions are likely to maintain or improve public health protection. In addition, other compliance data (including sanitary survey a nd corrective action information) can help in evaluating the effectiveness of current regulations.

Section 1445(g)(1) requires EPA to "assemble and maintain a national drinking water contaminant occurrence database, using inform ation on the occurrence of both regulated and unregulated contaminants in public water sy stems..." Section 1445(g)(6) requires that for regulated contaminants, the database ( i.e. , NCOD) include "information on the detection of the contaminant at a quantifiable level in public wate r systems." This includes levels which are less than or equal to the maximum contaminant level (MCL) for a specific contaminant. Prior to the establishment of NCOD, only data related to MC L violations were being stored on a nationallevel.

2(b) Practical Utility/ Users of the Data

This ICR supports the collection of complia nce monitoring data (contaminant occurrence data and treatment technique information) from St ates for all regulated ch emical and radiological contaminants, microbiological contaminants, as well as data from the GWR, SWTRs, DBPRs,
and FBRR. A list of the occurrence data to be requested is provided as Exhibit 4-1. The
occurrence data will be used to derive detailed statistical estimates of national occurrence of these regulated contaminants. EPA's specific goa l in evaluating contaminant occurrence is to
estimate the national number of PW Ss at which the individual re gulated contaminants occur at
levels of health concern and/or the feasible leve l of measurement, and to evaluate the number of people exposed to these levels. This informati on, in conjunction with othe r contaminant-specific analyses conducted as part of the Six-Year Review (e.g., health assessment, technology, implementation issues, etc.), will provide EPA with information to determine whether or not it is appropriate to consider revisions to a regulation to maintain or provide for greater protection of human health. The monitoring data (including sanitary survey a nd corrective action information) will provide EPA with information to evaluate regulation effectiveness.Six-Year 3 ICR November 2009

Page 4 of 34 The primary user of the information collected under this ICR will be EPA's Office of Water. Other users of this information may include the following:

• Primacy agencies, which include State re gulators, Indian Tribes, and, in some instances, EPA Regional Administrators

• PWS managers

• Staff from other EPA programs

• Federal Emergency Management Administration

• Centers for Disease Control and Prevention

• Military bases

• Rural Development Administration/Farmers Home Administration

• Department of Interior

• Department of Housing and Urban Development

• U.S. Army Corps of Engineers

• White House task forces

• American Water Works Association (AWWA)

• Association of Metropolitan Water Agencies (AMWA)

• National Rural Water Association

• National Association of Water Companies

• Association of State Drinking Water Administrators (ASDWA)

• Natural Resources Defense Council

• Consumers Federation of America

• Small Business Administration

• Other environmental and industry groups

• News organizations

• Private industries

• Individuals.Six-Year 3 ICR November 2009

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### 3 NON-DUPLICATION, CONSULTATIONS AND OTHER
COLLECTION CRITERIA

3(a) Non-duplication

EPA has made an effort to ensure that data collection activities asso ciated with this ICR are not duplicated. Though these monitoring data have already been collected by States to comply with existing regulations and/or to inve stigate State and local contamination concerns, this information has not been collected and analyzed at the national-level. This data request only targets the transmittal of existing electronic data from States to EPA. Thus, the final compilation and analysis of this information is not unn ecessarily duplicative of information otherwise available to the Agency.

In addition, SDWIS/FED contains some inventory-related data elements that EPA is requesting be submitted with each data record. As discussed in Section 4(b), EPA will give States the option of reporting a ll requested data elements or having the Agency access inventory
data from SDWIS/FED based on the Federal public water system identification (PWSID)
number.

3(b) Public Notice Required Prior to ICR Submission to OMB

Following public notice of th e proposed data collection effort on September 11, 2009 (74 FR 46767), EPA did not receive any public comment s during the comment period related to this ICR. As no public comments were submitted related to this ICR, no changes to the data collection format were necessary. Although no public comments were submitted on the ICR, as noted in the September 11, 2009 notice, EPA ha s updated this ICR to reflect the slight modification of the scope, revised bu rden hours, and updated labor costs.

3(c) Consultations

EPA first consulted with stakeholders regard ing the Six-Year Revi ew process during its development of a protocol during 1999 and 2000. A summary of the deliberative process and initial approach to occu rrence analysis can be found in th e docket for EPA's final announcement of the Six-Year Review process on July 18, 2003, entitled: "National Primary Drinking Water Regulations; Announcement of Completion of EPA's Review of Existing Drinking Water Standards" (68 FR 42908).

To prepare for Six-Year Review 3, EPA used information from the previous Six-Year Review process and collected information from St ates on which States were currently using or are planning to use SDWIS/State.Six-Year 3 ICR November 2009

Page 6 of 34 3(d) Effects of Less Frequent Collection

EPA is required by SDWA to conduct a Six- Year Review of existing NPDWRs. The information requested under this ICR is being collected on a one-time basis for the Six-Year
Review 3 to meet the SDWA statutory requirements.

3(e) General Guidelines

This ICR was prepared in accordance with the November 2005 version of the ICR Handbook developed by EPA's Office of Environm ental Information, Office of Information Collection, Collection Strategies Division. The ICR Handbook provide s the most current instructions for ICR preparat ion to ensure compliance with the 1995 PRA Amendments and OMB's implementing guidelines.

This data collection is a reque st, not a requirement, and EPA is taking an approach that minimizes burden to the respondents. In additi on, this collection does not violate any of the OMB guidelines for informati on collection activities.

3(f) Confidentiality

This information collection does not requi re respondents to disclose confidential
information.

3(g) Sensitive Questions

No questions of a sensitive nature are incl uded in any of the information collection requirements outlined in this ICR.Six-Year 3 ICR November 2009

Page 7 of 34 4 RESPONDENTS AND THE INFORMATION

4(a) Respondents and NAICS/SIC Codes

Data associated with this ICR are collect ed and maintained by State drinking water agencies. The North American Industry Classifi cation System (NAICS) code for State agencies that include drinking water progr ams are classified as 92411 (Adm inistration of Air and Water Resources and Solid Waste Management Programs) or 92312 (Administration of Public Health Programs). There will be no burden included for water systems, because systems will not be asked to collect, submit, or review new data, and will not be affected by the States' efforts for the
data submission.

4(b) Information Requested

This ICR covers reporting activities that wi ll take place in response to a specific EPA data call-in to State drinking water programs. Though this is not a re quirement, the ICR is necessary to estimate reporting burden and costs to the States. This ICR summarizes the data items and respondent activities associated with th e reporting effort. All data being called-in are historic ( i.e. , data already exist); no States or PWSs w ill be required to collect any new data. Further, no recordkeeping burden will be imposed on the States as a result of this request ( i.e.

, States are already required to maintain these records as part of NPDWRs).

4(b)(i) Data Items

EPA is requesting that States voluntarily submit compliance monitoring data and treatment technique informa tion collected by PWSs during January 2006 through December
2011 for the occurrence data listed in Exhibit 4-1. This request only includes existing data that the States have already stored in electronic fo rmat. The requested data include analytical detections and non-detections for routine comp liance monitoring samples (including repeat and confirmation samples) and other compliance summaries (including sa nitary survey and corrective action information), as well as any special study sampling results that States choose to
submit.

Note that although this data collection is not a requirement, certain parameters are essential for the Agency to uphold high standards of data quality and anal ytical integrity. EPA has identified the data categories (see Exhibit 4- 2) that the Agency will request that States provide with their data results. In general, these data elements are based on those used for the
second Six-Year Review and the data elements needed for the GWR, SWTRs, DBPRs, and FBRR. Although some of the inventory-related data elements listed in Exhibit 4-2 are available from SDWIS/FED, compliance mo nitoring data stored and main tained by States typically includes most, if not all, of t hose data elements. EPA expects that it would be a greater burden for States to remove specific, otherwise av ailable data elements from their compliance monitoring records than to simply submit complete compliance monitoring data sets "as is." However, for States that elect to submit a subs et of data, EPA has identified essential data categories that the Agency needs to most effectivel y evaluate the occurrence data. If States electSix-Year 3 ICR November 2009

Page 8 of 34 to submit their data with only these data categories, EPA will use the PWSID number to acquire additional system-specific data from SDWIS/FED, and appropria te supplemental information,
where needed.

Exhibit 4-1: Occurrence Data to Be Requested

Chemical Contaminants (Phase I, II, IIB, and V Rules; Arsenic Rule; Lead and Copper Rule)
Acrylamide 1,1-Dichloroethylene Methoxychlor
Alachlor cis-1,2-Dichloroethylene Monochlorobenzene (Chlorobenzene)
Antimony trans-1,2-Dichloro ethylene Nitrate (as N)
Arsenic Dichloromethane (Methylene chloride) Nitrite (as N)

Asbestos 1,2-Dichloropropane Oxamyl (Vydate)
Atrazine Di(2-ethylhexyl) adip ate (DEHA) Pentachlorophenol
Barium Di(2-ethylhexyl) ph thalate (DEHP) Picloram
Benzene Dinoseb Polychlorinated biphenyls (PCBs)
Benzo[a]pyrene Diquat Selenium
Beryllium Endothall Simazine
Cadmium Endrin Styrene
Carbofuran Epichlorohydrin 2,3,7,8-TCDD (Dioxin)
Carbon tetrachloride Ethylb enzene Tetrachloroethylene
Chlordane Ethylene dibromide (EDB) Thallium

Chromium (total) Fluoride Toluene
Copper Glyphosate Toxaphene
Cyanide Heptachlor 2,4,5-TP (Silvex)
2,4-D Heptachlor epoxide 1,2,4-Trichlorobenzene
Dalapon Hexachlorobenzene 1,1,1-Trichloroethane
1,2-Dibromo-3-chloropropane (DBCP) Hexachlorocyclopentadiene 1,1,2-Trichloroethane

1,2-Dichlorobenzene ( o -Dichlorobenzene) Lead Trichloroethylene

1,4-Dichlorobenzene ( p -Dichlorobenzene) Lindane Vinyl chloride

1,2-Dichloroethane (Ethylene dichloride) Mercury (inorganic) Xylenes (total)

Radiological Contaminants

Combined Radium-226/228; and
Radium-226 & Radium-228 (if available) Gross beta Tritium

Iodine-131 Uranium

Gross alpha Strontium-90
Microbiological Contaminants

Total coliforms Fecal coliforms Escherichia coli (E. coli)Six-Year 3 ICR November 2009

Page 9 of 34 Exhibit 4-1: Occurrence Data to Be Requested

Disinfectants and Disinfection Byproducts Rules (DBPRs)

Total Trihalomethanes (TTHMs):

Chloroform

Bromodichloromethane

Dibromochloromethane

Bromoform Haloacetic Acids (HAA5):

Monochloroacetic acid
Dichloroacetic acid
Trichloroacetic acid
Bromoacetic acid

Dibromoacetic acid Bromate

Chlorite

Chlorine

Chloramines

Chlorine dioxide

Ground Water Rule (GWR)

Escherichia coli (E. coli) Enterococci Coliphage
Surface Water Treatment Rules (SWTRs)

Chlorine Cryptosporidium Heterotrophic Plate Count (HPC)

Chloramines Giardia lamblia
Filter Backwash Recycling Rule (FBRR)
No specific occurrence data collected; s ee Exhibit 4-2 for data elements for FBRR

Exhibit 4-2: Requested Data Categories

Data Category Description

System-Specific Information

Public Water System
Identification Number (PWSID) The code used to identify each PWS. The co de begins with the standard 2-character postal State abbreviation or Region code; the remaining 7 numbers are unique to
each PWS in the State.

System Name Name of the PWS.

Federal Public Water System Type Code A code to identify whether a system is: • Community Water System; • Non-transient Non-community Water System; or • Transient Non-community Water System.

Population Served Highest average daily number of people served by a PWS, when in operation.

Federal Source Water Type Type of water at the source. Source water type can be: • Ground water; or • Surface water; or
• Ground water under the direct influence of surface water (GWUDI) (Note : Some States may not distinguish GWUDI from surface water sources. In those States, a GWUDI source should be reported as a surface water source type.)

Sanitary Survey
Information Site visit information for TCR, GWR, and SWTRs, including: site visit type, date completed, associated deficiencies identified, corrective actions taken.

Treatment Information

Water System Facility System facility data, including: treatment plant identification number, treatment plant information, treatment unit process/ objectives, facility flow, treatment train (train or flow of water through treatment units within the treatment plant).

Filtration Type Information relating to system filtration, including: filtration status, types of filtration (e.g., unfiltered, conventiona l filtration, and other permitted values)Six-Year 3 ICR November 2009

Page 10 of 34 Exhibit 4-2: Requested Data Categories

Data Category Description

Treatment Technique
Information Information pertaining to treatment processes. Types of treatment technique information including: coagulant/coagulant aid type and dose, disinfectant concentration (amounts, types, primary and secondary types of disinfection, disinfection profile/bench mark data), log of viral inactivation/removal, contact time, contact value, pH, temperature.

Filter Backwash
Information Information about filter backwash that is returned to the treatment plant influent (e.g., information on: recycle/schematic stat us, alternative return location, corrective action requirements, and recycle flows and frequency).
Sample-Specific Information

Sampling Point
Identification Code A sampling point identifier established by th e State, unique within each applicable facility, for each applicable sampling location (e.g., entry point to the distribution system). This information enables occurrenc e assessments that address intra-system variability.

Sample Identification
Number Identifier assigned by State or the laborat ory that uniquely identifies a sample.

Sample Collection Date Date the sample is collected, including month, day and year.

Sample Type Indicates why the sample is being collect ed (e.g., compliance, routine, repeat, confirmation, additional routine samples, dup licate, special, special duplicate, etc.).

Sample Analysis Type
Code Code for type of water sample collected. • Raw (Untreated) water sample • Finished (Treated) water sample

For lead and copper only:

• Source • Tap

For TCR Repeats only; indicator of sampling location relative to sample point where positive sample wa s originally collected:

• Upstream

• Downstream
• Original

Contaminant Contaminant name, 4-digit SDWIS contamin ant identification number, or Chemical Abstracts Service (CAS) Registry Number for which the sample is being analyzed.

Sample Analytical Result
- Sign The sign indicates whether the sample analytical result was: • (<) "less than" means the contaminant was not detected or was detected at a level "less than" the minimum reporting level (MRL). • (=) "equal to" means the contaminant was detected at a level "equal to" the value reported in "Sample Analytical Result - Value."
(Not required for TCR data)

Sample Analytical Result

- Value Actual numeric (decimal) value of the anal ysis for the chemical results, or the MRL if the analytical result is less than the contaminant's MRL.
For the TCR, results will indicate presence/absence.Six-Year 3 ICR November 2009

Page 11 of 34 Exhibit 4-2: Requested Data Categories

Data Category Description

Sample Analytical Result

- Unit of Measure Unit of measurement for the analytical results reported (usually expressed in either

μ g/L or mg/L for chemicals; or pCi/l or mrem/yr for radiological contaminants).
(Not required for TCR data)

Sample Analytical Method
Number EPA identification number of the analytical method used to analyze the sample for a given contaminant.

Minimum Reporting Level (MRL) - Value MRL refers to the lowest concentration of an analyte that may be reported.
(Not required for TCR data)

MRL - Unit of Measure Unit of measure to express the concentr ation value of a contaminant's MRL.
(Not required for TCR data)

Source Water Monitoring
Information Total organic carbon (TOC), includin g percent TOC removal, TOC removal summary, pH, alkalinity, monitoring data entered as individual results or included in DBP (or monthly operating report (MOR)) summary records, a lternative compliance
criteria.

Sample Summary Reports Sample summaries for DBPRs, SWTRs, and LCR associated with analytical result records. Values used for compliance determination [e.g., turbidity (combined effluent/individual effluent), disinfectant residual levels in treatment plant and distribution system, treatment tec hnique information, HPC, etc.]

4(b)(ii) Respondent Activities

Potential respondents to this information collection are assumed to include 56 State drinking water agencies listed in Exhibit A-1 in Appendix A. Activities needed to respond to the information collection include reading and understanding EPA's request, compiling and submitting the requested drinking water contaminant data in electronic format, and
communication and coordination with EPA. No r ecord keeping requirements are associated with this information collection request. Each of th ese respondent activities is described in more
detail below.

Reading/Understanding EPA's Request

EPA will send a letter to 56 States that expl ains the purpose of the data collection, the specific information EPA is requesting, a nd the procedure for submitting these data.

Compiling and Submitting Monitoring Data

EPA is asking States to compile and submit da ta that have already been collected from water systems, and which already exist in electr onic format. EPA is not expecting States or water systems to collect new data in response to th is reporting request or to enter hard copy data into an electronic format. All data will be submitted using security protocol to a designated FTP
site.Six-Year 3 ICR November 2009

Page 12 of 34 To facilitate the consistency and quality of data across States, EPA will ask States to: provide a brief description of the basic format a nd structure of each data set, and definitions of all data elements, column/row h eadings, codes, acronyms, etc., used in each data set; submit the data in a format with each analytical result occupying a discrete row accompanied by the system inventory and sample-specific data items ( i.e. , those listed in Exhibit 4- 2 in section 4(b)(i)); and submit the data in a EPA-compatible file format , such as Dbase (.dbf), Access tables (.mdb), comma or tab delimited files (.csv or .txt), or Excel (.xls). It is e xpected that the data from States using or are planning to use SD WIS/State will more closely match the needed data formats and elements, and thus are assumed to have less burd en for submissions than non-SDWIS States. To ease this burden, EPA will provid e extraction scripts to use wi th the SDWIS/State database. However, all States will have the option of subm itting data "as is", thus, the assumption of higher
burden for non-SDWIS States is a conservative (highest possible cost) assumption. If States submit only the minimum data element informa tion, EPA will extract the additional inventory information from SDWIS/FED, and appropriate supplemental information, where needed, based
on the PWSID number.

EPA also assumes that some States will choos e not to submit data at this time; such
States are assumed to incur no burden related to th is data request beyond the initial reading of the
request.

Follow-up with EPA

Based on the Agency’s experience with occu rrence information provided by States for the Six-Year Review 2, EPA expects that it may n eed to contact some States' data management staff to address questions regarding the data quality such as possibl y incorrect units of measurement, outlier values, incorrect, missing, or undefined data elements, or other possible data problems. This follow-up may be minimal or may not be needed for those States that provide their data in the requested format with an explanation of thei r codes, headers, etc. It is
assumed that these communications and conf irmations will be handled primarily through telephone and e-mail.Six-Year 3 ICR November 2009

Page 13 of 34 5 INFORMATION COLLECTED–AGENC Y ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA Headquarters will conduct the following activitie s associated with the collection of regulated monitoring data:

• Extract or download data;

• Initial data screening/convers ion to uniform structures;

• Communicate and coordinate with States; and

• Data management and analysis, including

– Quality assurance/quality control and review/edit data;

– Data analysis and report of findings; and

– Record keeping.

Each of these activities is disc ussed in more detail below.

Extract or Download Data

EPA's data extraction/downloading activities will depend to some de gree on the type of data system used in each State, and on the leve l of State participation. EPA assumes that data
from States that use or are planning to use SDWIS/State will most closely reflect the data elements and format being requested due to the us e of the provided database extraction scripts. Data from States using other databases are more likely to differ from the requested format. In cases where States do not provide all of the reque sted data, EPA will, where possible, extract the needed additional inventory information from SDWIS/FED, and appropriate supplemental information, where needed. EPA assumed that it will take longer to extract or download all
needed information for non-SDWIS States. All St ates, regardless of type of data system, will submit their data using security prot ocol to a designated FTP site.

Initial Data Screening/Conversion to Uniform Structures

Each data set will be reviewed to determine if it contains the appropriate contaminants, basic data elements, and definitions of any special (State-specific) codes needed to conduct a consistent analysis for this study. The data se t structure will be assessed and converted, if needed, into an appropriate structure, with each analytical result occupying a discrete row accompanied by the sample-specific data items. Data formatting work will be done using
Microsoft ® Access with the aid of specialized programs written in Visual Basic.Six-Year 3 ICR November 2009

Page 14 of 34 Communication and Coordination with States

Based on the Agency's experience with data submitted in response to Six-Year Review 2,
EPA will need to communicate and coordinate with States to assist with successful data submission, to resolve data editing and QA/QC issues, and to address any other data set questions that EPA or the State may have.

Data Management and Analysis

Data management and analysis includes: quality assurance/quality control and data review/editing; data analysis a nd report of findings; and record keeping. These activities take place after the initial State data sets have been made uniform, and the data sets have been combined to be analyzed on a per contamin ant basis (versus a per State basis).

Quality Assurance/Quality Control and Review/Editing of Data : An important objective regarding the data to be called- in and subsequently used for th e Six-Year Review 3 contaminant occurrence analyses is development of a consiste nt and repeatable data management approach. Consistent data editing, and QA/QC assessments (e.g., identification of obvious incorrect units, outliers, duplicate entries, etc.) across all State da ta received will allow the individual State data sets to be aggregated, and jointly evaluated, to provide an overview of national occurrence patterns for individual contaminants.

Uniform, detailed QA/QC assessments will be conducted on the State compliance monitoring data sets. The only data requested and used will be from State drinking water programs ( i.e. , official compliance monitoring data from the regulated drinking water program). All compliance monitoring samples are collected by trained PWS staff and an alytical results are generated by laboratories that are certified for drinking water programs. Therefore, some assumptions are made regarding the general qua lity of the raw compliance monitoring data received from the States. Data problems will cert ainly exist, but efforts will be taken to reduce the problems and increase the dependability and quality of the State o ccurrence data used in these analyses.

The number of systems with compliance mon itoring data in each State will be checked against total system inventory numbers from SDWIS/FED, and other more appropriate supplemental information, where needed. The num ber of analytical records per system (per contaminant) will also be evaluated to assess comp leteness of the submitted analytical records. Contaminant-specific analytical values are also assessed as pa rt of the QA/QC review. For example, the assessment of the range of all analyt ical values for a specif ic contaminant supports identification of possible analytical unit errors or the presence of outliers. Identified errors that do not have straight-forward solutions will be addressed through consultations with State data management staff to ensure consistent and approp riate interpretations. Once data quality issues are resolved, each data set will be converted into a consistent format. As part of the data QA/QC procedures, all edits or changes made to the raw monitoring data will be documented.

Data Analysis and Report of Findings: For the second Six-Year Review, EPA developed and used a data management and two-staged analytical approach to assess dataSix-Year 3 ICR November 2009

Page 15 of 34 representativeness and to analyze the compliance m onitoring data from 45 States. This approach
will also be used for the third Six-Year Review for the chemical, radiological and microbiological contaminants. States' complia nce monitoring data will be assessed and compiled into a data set that is indicative of national occurrence. The national data set will be analyzed using a two-staged anal ytical approach. The "Stage 1" analysis provides simple, nonparametric estimates of the percent of PWSs (and the total population served by those PWSs) with at least one analytical resu lt exceeding specific threshold va lues. The "Stage 2" analysis estimates long-term mean concentrations of c ontaminants in all systems (and the corresponding affected populations) nationwide above levels of regulatory interest. A national contaminant occurrence report will then be prepared that describes the national contaminant occurrence dataset compiled, the data management procedur es conducted to develop the national dataset, and the statistical analytical methods employed (u sing the national dataset) to generate national estimates of regulated contaminant occurrence in public drinking water systems.

The compliance summaries (including sanitary survey and corrective action information) collected for the Ground Water Rule, Surface Wa ter Treatment Rules, Long Term 1 and 2 Enhanced Surface Water Treatment Rule (LT1 and LT2) and Interim Enhanced Surface Water Treatment Rule (IESTR), Stage 1 and 2 Disi nfectants and Disinfection Byproducts Rules (DBPRs), and Filter Backwash Recycling Rule (F BRR) will be evaluated to determine regulation
effectiveness.

Record Keeping: EPA will store and track: the original raw (before QA/QC) data sets that it receives from States; final data sets used for the Six-Year Review 3 analyses; and logs of all data QA/QC and editing conducted on the original data sets. After final review, formatting, and analysis of the data collected through this ICR, a summary of the data will be made available to the public through the NCOD, as was done with the data collected and analyzed for the SixYear Review 2.

5(b) Collection Methodology and Management

Through the Six-Year Review process, the Ag ency reviews and assesses risks to human health posed by existing drinking wa ter contaminants. The collecti on of the occurrence data, and the quantity, coverage, representa tiveness, treatment techniques and management of the data collected pursuant to this ICR is an important component of the planned Six-Year Review 3

process.

EPA considered developing a na tionally representative probabilistic survey in lieu of requesting data from all States. EPA assessed nu merous survey designs that were intended to meet different data quality objectives (DQOs) and found no single design that would allow the Agency to acquire a nationally representative aggregation of complian ce monitoring data and treatment technique information for all NPDWRs in an efficient or reasonable manner. 2 The potential problems associated with survey de sign are explained in more detail as follows:

2 A list of these contaminants is provi ded in Exhibit 4-1 in section 4(b)(i).Six-Year 3 ICR November 2009

Page 16 of 34 • The significant within- and between-system variance differences likely present when considering all the regulated contaminants w ould result in a wide range of confidence intervals and precision terms based on the su rveyed systems' data. Conversely, to design a single survey so that the indivi dual contaminant with the most variable occurrence data still meets minimum DQOs wo uld require a survey that included tens of thousands of systems.

• A survey would require data requests either directly from thousands of individual systems (requesting submission of six years of historic compliance monitoring data); or from States (to extract the system-level data for each of the systems selected in the survey). Further, the Agency would exp ect an increased non-re sponse rate if data were requested directly from systems.

• Based on the Agency's experience worki ng with the 45 States that submitted complete compliance monitoring data sets for Six-Year Review 2, EPA anticipates that the burden on the States may be smaller when simply requesting all data records, as compared to requesting dozens or hundreds of specific records fo r select individual

PWSs.

• Monitoring schedules can vary across cont aminants and across systems, and can be quarterly, annual, triennial, or every nine years. Ac tual contaminant-specific sampling frequencies are unknown, and theref ore, are difficult to address in any survey design. (Different sampling frequenc ies are attributed to waiver programs and historical results showing contaminant o ccurrence (or lack of occurrence).)

An alternative to a single survey for all NP DWRs would be multiple surveys for groups
of related contaminants as well as treatment tech niques. However, the Agency anticipates that the burden for EPA, the States, and/or system s may be significant for designing, implementing, and managing multiple surveys.

The information described in the previous sections will be collected by EPA and made available to the public upon request, as require d by the Freedom of Information Act (40 CFR, Chapter 1, Part 2). A summary of the data, after a complete and t horough QA/QC review, will be available to the pub lic through EPA's NCOD.

For the previous Six-Year Review 2, EPA received data sets through electronic FTP, email, or mailed/shipped compact discs. For Six- Year Review 3, all States are being asked to submit their data through a secure FTP site. FTP is being specified for se veral reasons: this information collection is potentially significantly la rger in scale than the previous collections; the FTP site to be used offers a high level of data se curity; and EPA anticipates that most, if not all, States will have computer/internet resources which will allow them to submit data sets electronically.

Regarding data set file formats, EPA will request that non-SDWIS/State users submit their data sets in one of the following EPA-compa tible file formats: Dbase (.dbf); Access tables (.mdb); comma or tab delimited files (such as .csv or .txt), or; Excel (.xl s). In addition, EPA'sSix-Year 3 ICR November 2009

Page 17 of 34 preferred data set structure is for the data to be formatted with each analytical result occupying a discrete row accompanied by the system inventory and sample-specific data items listed above in 4(b)(i). EPA will also request that non-SDWIS/ State users provide: a brief description of the basic format and structure of each data set; a nd definitions of all data elements, column/row headings, codes, acronyms, etc., used in each data set. EPA anticipates that this information will reduce the amount of time needed for questions and cl arification later. States have the option of submitting the requested data "as is," by simply copying the compliance monitoring records in whatever structure or condition they are curren tly stored in, and submitting that copy of the electronic data to EPA. If States only subm it the minimum data element information, EPA will extract the additional inventory information fr om SDWIS/FED, based on the PWSID number.

Other communications and confirmations (reg arding data set follo w-up questions with State data management staff, etc.) will be primarily handled through telephone and e-mail.

5(c) Small Entity Flexibility

Since only State drinking water agencies will be asked to submit existing electronic data to EPA, no small entities, and specifically no sm all PWSs, will incur burden as a result of this data request.

In developing this ICR, EPA considered the requirements of the Small Business Regulatory Enforcement Fairness Act (SBREFA) to minimize the burden of information
collections on small entities. Small entities include "small businesses," "small organizations," and "small government jurisdictions." No State dr inking water agency qualifies as a small entity, as defined under the Regulatory Flexib ility Act (RFA), and summarized below. 3

• A small business is any business that is in dependently owned and operated
and not dominant in its field as defi ned by the Small Business Administration (SBA) regulations under Section 3 of the Small Business Act.

• A small organization is any non-profit enterprise that is independently owned and operated and not domi nant in its field.

• A small governmental jurisdiction is the government of a city, county, town, township, village, school district or sp ecial district that has a population of fewer than 50,000. This definition may also include Indian tribes.

The major requirement under SBREFA is a regulato ry flexibility analysis of all rules that have a "significant economic impact on a substantia l number of small entities." Since this data request is not part of a rule, a nd does not affect any small entitie s as defined above, this ICR is not subject to SBREFA.

3 These definitions were take n from section 601 of the RFA.Six-Year 3 ICR November 2009

Page 18 of 34 5(d) Collection Schedule

EPA is issuing this ICR as a one-time data request from the States for regulated monitoring data for 2006-2011. Stat es will be responding to this request in 2012. Data analysis is expected to continue through 2015, when EPA plan s to release its final review results for SixYear 3.Six-Year 3 ICR November 2009

Page 19 of 34 6 ESTIMATING THE BURDEN A ND COST OF THE COLLECTION

This section describes the estimated average annual burden and costs for the information
collection activities in support of Six-Year Review 3. For this data submission, PWSs have no burden and costs; this is discu ssed further in Section 6(a). Th e burden and cost estimates for State drinking water primacy agencies are discusse d in detail in Section 6(b). The Agency's
burden and cost estimates are outlined in Section 6(c).

To estimate the costs, EPA made assumptions a bout the burden associat ed with activities that would likely be needed to fulfill the request. To the extent possible, assumptions were based on similar activities for past da ta collections. EPA emphasizes that the per-respondent estimates represent the average bu rden and cost over the 3-year peri od covered by this ICR (2010-2012). Some respondents may incur higher costs and so me will fall below the average. Summary
burden and cost estimates for States and EPA ar e provided in Exhibits 6-1 and 6-2. Detailed estimation tables for States and EPA are prov ided in Appendices A and B, respectively.

Estimates of State and EPA burden are influenced by State data management capabilities and the likelihood of submitting the requested data. EPA's assessments of individual State data capabilities and likeliness to participate are based on Agen cy experience conducting data verifications in State program offices, as well as other direct knowledge of data capabilities and resources. To estimate burden, the Agency organized States into 4 categorie s of expected burden level, as follows:

Submit occurrence data using proprietary software - 7 States. These States are expected to spend the most time reading and co nsidering the request for data, as they may need to identify which of thei r data elements correspond to those requested. For similar reasons, compilation and submission of their occurrence data and treatment technique information, and follow up with EPA is expected to be the highest. EPA expects that Agency burden, which is estimated primarily on a per State basis, will be higher for these

States.

Submit occurrence data using a combin ation of SDWIS/State software and proprietary software - 9 States. These States are expected to spend more time reading and considering the request for data, as they may need to identify which of their data elements from which data system correspond to those requested. For similar reasons, compilation and submission of their occu rrence data and treatment technique information, and follow up with EPA is expected to be somewhat higher than States using only SDWIS/State. EPA expects that Agency burden, which is estimated primarily on a per State basis, will be higher for these States.

Submit occurrence data using SDWIS/State software - 38 States. Those with or planning to use SDWIS/State are expected to spend less time than States with proprietary software. Reading and considering the request for data is expected to be less time consuming, as the SDWIS/State data elements will correspond closely to those requested. Compilation and submission of their occu rrence data and treatment techniqueSix-Year 3 ICR November 2009

Page 20 of 34 information, and follow up with EPA is also ex pected to be easier fo r these States. EPA will provide the States with extraction scripts for SDWIS/State database, thus expected to be easier for these States. EPA expects that Agency burden, which is estimated primarily on a per State basis, will be lower for these States.

Will not submit data - 2 States. States that do not have th e requested data stored electronically or those that are considered gene rally not likely to submit data are expected only to spend a minimal amount of time consid ering the request. No further burden is
assumed. EPA will incur no burden for these States.

6(a) Estimating Respondent Burden

The average annual respondent bur den (in labor hours) for States is shown in Exhibit 6-1. Appendix A provides detail of the estimated re spondent burden for States to complete the activities described in section 4( b)(ii). There is no burden for public water systems. Over the ICR years of 2010-2012, EPA estimates a total av erage annual respondent burden of 756 hours
for activities associated with this reporting effort; or an average of 13.5 hours per State (756 hours divided by 56 States). This estimate incl udes costs for reading and understanding EPA's request, compiling and submitting the data to EPA, and any needed follow-up with the Agency to address questions re garding the data.

Reading/Understanding EPA's Request

The Agency assumes that all States will read EPA's request letter. A one-time burden for States that will submit data with proprietary so ftware is estimated at 7 hours; States with SDWIS/State are estimated to spend 4 hours; those States with a mix of proprietary software for some rules, and SDWIS/State for others is esti mated at 5 hours; and States that will not submit data are estimated to spend 1 hour.

Compiling and Submitting Monitoring Data

State burden for this reporting activity is like ly to vary widely depending on the level of
effort each State chooses to invest. All States will follow a security protocol when submitting data through a designated FTP site. Burden for St ates that will submit with proprietary software
is estimated at 44 hours. Those States with a mi x of proprietary software for some rules, and
SDWIS/State for others is estim ated at 34 hours. States with SDWIS/State are estimated to spend 24 hours.

Follow-up with EPA

EPA expects that those States that use or are planning to use SDWIS/State or provide their data in the requested format with an explanation of their c odes, headers, etc. will need to spend little follow-up time with EPA. States su bmitting data with proprietary database software, (and particularly those that send their data "as is") are expected to need more time on follow-up
clarifications with EPA. Stat es with proprietary software ar e estimated to spend 13 hours ofSix-Year 3 ICR November 2009

Page 21 of 34 follow-up time with EPA. Those States with a mi x of proprietary software for some rules, and
SDWIS/State for others is estimat ed at 11 hours. States with SD WIS/State are estimated to only to require 8 hours of follow-up.

6(b) Estimating Respondent Costs

Exhibit 6-1 shows the annual average costs for States over the ICR period of 2010-2012. Appendix A provides detailed cost and burden estimations for the information collection activities covered by this ICR. Average annual labor costs for all States for this ICR period are estimated to be $37,922. Respondents will not in cur capital or operations and maintenance (O&M) costs associated with th is ICR. EPA estimates each St ate will incur an annual average labor cost of $677 for this da ta collection effort.

State labor costs are based on informati on provided in the "2001 ASDWA Drinking Water Program Resource Needs Self Assessm ent." In 2000, the United States General Accounting Office used a previous version of this model to es timate nationwide drinking water program needs for Congress. The tool was late r updated and improved based on comments from 27 States. To make the model easier to use, ASDWA established suggest ed salary and benefit ranges ( i.e. , default values), resource needs for the various NPDWRs, and other key variables. Labor costs per hour are based on the default an nual rates for 2010 that are provided in the
model.

Exhibit 6-1: Average Annual State Burden and Costs (for ICR period of 2010-2012)

Number of States Burden Hours Labor Costs

All States Per State All States Per State

56 756 13.5 $37,922 $677

6(c) Estimating Agency Burden and Costs

EPA's drinking water program in Headquarters will incur burden and costs for the coordination and implementation of this data co llection effort. Cost and burden estimates for
EPA's activities associated with this request are detailed in Exhibit 6-2 and Appendix B.Six-Year 3 ICR November 2009

Page 22 of 34 6(c)(i) Agency Burden

For the 3-year ICR period (2010-2012), EPA es timates that the aver age annual burden to the Agency will be 3,149 hours. This estimate includes burden incurred by EPA or its
contractors for the activities out lined in Section 5(a) above. EPA burden is estimated based on
similar activities conducted during the Six-Year 2 o ccurrence data analysis.

Extract or Download Data

EPA is estimating its data extraction and dow nloading burden based on the types of data systems that States use to submit data. To c oordinate and download files to its database, including special consideration for security protocols, EPA estimates that it will need:

• 11 hours per State for those 38 States that use or are planning to use SDWIS/State, and

• 17 hours per State for the 16 States that us e either all proprietary, or a mix of proprietary and SDWIS/State.

Initial Data Screening/Conversion to Uniform Structures

EPA's data screening and convers ion is also estimated on a per State basis. Based on its experience during Six-Year 2, EPA assumes that burde n to review the data and to convert it into a consistent format will be influenced primarily by whether the data are stored in SDWIS/State or another proprietary database. EP A estimates that it will need:

• 36 hours per State for those 38 States that use or are planning to use SDWIS/State; and

• 71 hours per State for the 16 States that us e either all proprietary, or a mix of proprietary and SDWIS/State.

Communication and Coordination with States

EPA assumes that the need to communicate and coordinate with States to ensure successful data submission and interpretation w ill require less burden for those State with SDWIS/State than for those with a proprietary da tabase. EPA estimates that it will need:

• 6 hours per State for those 38 States that use or are planning to use SDWIS/State;
and

• 11 hours per State for the 16 States that us e either all proprietary, or a mix of proprietary and SDWIS/State.Six-Year 3 ICR November 2009

Page 23 of 34 Data Management and Analysis

Data management and analysis activities in clude: quality assurance/quality control and review/editing of data; data an alysis and report of findings; a nd record keeping. Although some of these tasks take place after State data sets have been combined for analysis on a per contaminant basis (versus a per State basis), EP A has estimated a "per State" burden with the assumptions that 54 States will participate, and that 45 contaminants will be fully analyzed. Based on prior similar activities, EPA estimates 100 contractor and 30 EPA hours for each of 45 contaminants that will be analyzed for occurrence . To present this on a per State basis (as all other activities are shown), this 5,850 hours ( 130 hours x 45 contaminants) is divided by 54 States ( i.e. , the number of States expected to partic ipate), which equals approximately 108 hours per State. However, because burden for the occurrence analyses and treatment techniques will not vary greatly with the additi on or subtraction of State data sets, burden would not be reduced or increased by the approximately 108 hours with each addition or subtraction of a State. This is because the analyses are conducted on a per contam inant basis, and the amount of data analyzed in each does not greatly factor into the amount of time needed to run the analyses, and write-up the outcome. In addition, burden for this activity is not influenced by whether data came from SDWIS/State or another database, because data at this step in the process has already been
cleaned and converted to uniform structures.

6(c)(ii) Agency Cost

For the ICR period of 2010-2012, EPA's 3,149 an nual burden hours are associated with annual labor costs of $272,444 to collect and an alyze the occurrence data and treatment technique information, and evaluate and report on the findings. Direct EPA per hour labor costs were derived using the Office of Personnel Ma nagement January 2009 General Schedule (GS) Pay Scale for government employees in the D.C. area. EPA used the GS-13 Step 5 salary of $98,518 per year, and by adding the standard governm ent overhead factor of 1.6 (as well as a 3% inflation factor per year to account for 2012 salaries ), the average hourly rate is estimated to be $82.81 per hour. Contracted labor costs are based on historical hourly costs pertaining to the management and analysis of occurrence data , which were approximately $87.24 per hour.

Exhibit 6-2: Annual EPA Burden and Costs (for ICR period of 2010-2012)

Activity EPA Burden Per State Annual EPA 1

(38 SDWIS States) (16 Non-SDWIS States) Burden Cost

Extract/download data 11.0 17.0 230 $19,906

Initial data
screenin g /conversion to
uniform structures 36.0 71.0 835 $72,739 Communicate, coordinate
with States 6.0 11.0 135 $11,669Six-Year 3 ICR November 2009

Page 24 of 34 Exhibit 6-2: Annual EPA Burden and Costs (for ICR period of 2010-2012)

Activity EPA Burden Per State Annual EPA 1

(38 SDWIS States) (16 Non-SDWIS States) Burden Cost

Data Mgt and Analysis : QA/QC; review/edit data;

analyze/report findings; record keeping 108.3 108.3 1,950 $168,130

Total 161 207 3,149 $272,444

1 Burden is calculated by: per State burden, times number of States, all divided by the 3 ICR years. Cost is calculated by burden times the hourly labor rates (EPA or Contractor, as appropriate). See Appendix B, Exhibit B1, for details on EPA burden and cost estimations.

6(d) Estimating the Respondent Universe and Total Burden and Costs

The only respondents for this ICR are States. This ICR estimates the number of State potential respondents at 56. The total burden and costs for these respondents are summarized in Section 6(b) and Exhibit 6-1. Agency burden an d costs are detailed in Section 6(c) and in
Exhibit 6-2.

6(e) Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and costs for th is ICR are shown in Exhibit 6-3. This
includes the burden and costs to th e 56 States that are affected by this ICR, as well as the burden
and cost to EPA for this collection and analysis.

Exhibit 6-3: Bottom Line Burden and Costs (for ICR period of 2010-2012)

Total Avera g e Per Year over
2010-2012
Number of Respondents 56 States n/a Total Responses 56 18.7 Number of Responses per State 1 0.3
Total State Burden Hours 2,268 756 Hours per Response ( Total hours from above/Number of Resp ondents from above) 40.5 13.5
State O&M Costs $0 $0
Total State Costs (Labor plus O&M costs) $113,765 $37,922
National Total of Hours (States plus Agency) 11,716 3,905
National Total of Costs (States plus Agency) $931,098 $310,366Six-Year 3 ICR November 2009

Page 25 of 34 6(f) Reasons for Change in Burden

This ICR is a one-time data co llection effort in support of th e Six-Year Review 3. This ICR is a renewal of ICR No. 2231.01 (71 FR 32340). The change in burden hours and costs reflect the slight modi fication in the scope ( i.e. , to request data for several additional rules such as Ground Water Rule (GWR), Surface Water Tr eatment Rules (SWTRs), Long Term 1 and 2 Enhanced Surface Water Treatment Rule (LT1 and LT2) and Interim Enhanced Surface Water Treatment Rule (IESTR), Stage 1 and 2 Disi nfectants and Disinfection Byproducts Rules (DBPRs), and Filter Backwash Recycling Rule (FBRR)

.

6(g) Burden Statement

The reporting burden for data collections includ ed in this ICR is detailed above. The total annual respondent burden (for years 2010-2012) imposed by these collections is estimated to be 756 hours, or 13.5 hours per respondent per year. Because th is is a one-time data request for this Six-Year Review, there is only one response per respondent, an d all burdens and costs related to this response are included in these estima tes. The Agency expects that most, if not all, respondent activities will take place during 2012. Es timates include time for submitting data to EPA and addressing questions raised by the Agency regarding the submitted information.

Burden means the total time, effort, or financial resources expended by people to generate, maintain, retain, disclo se, or provide information to or for a Federal agency. This
includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology, and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing ways to comply with any previously applicable instructio ns and requirements; train personnel to be able to respond to a collection of info rmation; search data sources; co mplete and review the collection of information; and transmit or othe rwise disclose the information.

An agency may not conduct or sponsor, a nd a person is not required to respond to, a request for information collection unless it displa ys a currently valid OMB control number. The OMB control numbers for EPA's regulations are li sted in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OW-2005-0019, which is available for public viewing at the Water Docket in the EPA Docket Center (E PA/DC), EPA West Building, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday thro ugh Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Docket is (202) 566-2426. An electronic vers ion of the public docket is available through regulations.gov. Use regulations .gov to submit or view public comments, access the index listing of the contents of the public docket, a nd to access those documents in the public docket that are available electronically. Once in the sy stem, select "search," then key in the docket IDSix-Year 3 ICR November 2009

Page 26 of 34 number identified above. Also, you can send co mments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Pleas e include the EPA Docket ID No. EPA-HQ-OW2005-0019 and OMB control number 2040-0275 in any correspondence.Six-Year 3 ICR November 2009

Page 27 of 34 

### APPENDICESSix-Year 3 ICR November 2009

Page 28 of 34 Appendix A: Detailed Burden and Cost for States

Exhibit A-1: Estimated State Bu rden for Occurrence Data Submission

State Likely to
Submit Data? Average Burden Per State Labor Costs

Reading

EPA Request Compiling, Submitting

Data Followup with

EPA Total
Burden State Program

Size Cost

per Hour Labor Cost per State

(a) (b) (c) (d) (e)= (b)+(c)+(d) (f) (g) (h)=(e)*(g)

Alabama Likely/SS 4 24 8 36 s $45.65 $1,643 Alaska Likely/SS 4 24 8 36 m $49.18 $1,770

American

Samoa Likely/NonSS 7 44 13 64 vs $46.40 $2,969 Arizona Likely/SS 4 24 8 36 m $49.18 $1,770 Arkansas Likely/SS 4 24 8 36 m $49.18 $1,770 California Likely/SS 4 24 8 36 vl $80.34 $2,892 Colorado Likely/SS 4 24 8 36 m $49.18 $1,770 Connecticut Likely/SS 4 24 8 36 m $49.18 $1,770 Delaware Likely/SS 4 24 8 36 vs $46.40 $1,670

District of Columbia Likely/SS 4 24 8 36 s $45.65 $1,643

Florida Likely/NonSS 7 44 13 64 l $56.83 $3,637 Georgia Likely/SS 4 24 8 36 m $49.18 $1,770 Guam Likely/SS 4 24 8 36 vs $46.40 $1,670 Hawaii Likely/SS 4 24 8 36 vs $46.40 $1,670 Idaho Likely/SS 4 24 8 36 m $49.18 $1,770 Illinois Likely/SS 4 24 8 36 l $56.83 $2,046 Indiana Likely/SS 4 24 8 36 m $49.18 $1,770

Iowa Likely/MixedSS 5 34 11 50 m $49.18 $2,459 Kansas Likely/SS 4 24 8 36 m $49.18 $1,770 Kentucky Likely/SS 4 24 8 36 s $45.65 $1,643 Louisiana Likely/SS 4 24 8 36 m $49.18 $1,770

Maine Likely/MixedSS 5 34 11 50 s $45.65 $2,283 Maryland Likely/SS 4 24 8 36 m $49.18 $1,770

Massachusetts Likely/NonSS 7 44 13 64 m $49.18 $3,147 Michigan Likely/SS 4 24 8 36 l $56.83 $2,046

Minnesota Likely/NonSS 7 44 13 64 m $49.18 $3,147 Mississippi Likely/SS 4 24 8 36 m $49.18 $1,770

Missouri Likely/MixedSS 5 34 11 50 m $49.18 $2,459 Montana Likely/Mixed- 5 34 11 50 m $49.18 $2,459Six-Year 3 ICR November 2009

Page 29 of 34 Exhibit A-1: Estimated State Bu rden for Occurrence Data Submission

State Likely to
Submit Data? Average Burden Per State Labor Costs

Reading

EPA Request Compiling, Submitting

Data Followup with

EPA Total
Burden State Program

Size Cost

per Hour Labor Cost per State

(a) (b) (c) (d) (e)= (b)+(c)+(d) (f) (g) (h)=(e)*(g)

SS Nebraska Likely/SS 4 24 8 36 s $45.65 $1,643 Nevada Likely/SS 4 24 8 36 s $45.65 $1,643

New Hampshire Likely/NonSS 7 44 13 64 m $49.18 $3,147 New Jersey Likely/SS 4 24 8 36 m $49.18 $1,770 New Mexico Likely/SS 4 24 8 36 s $45.65 $1,643 New York Likely/SS 4 24 8 36 l $56.83 $2,046

North Carolina Likely/SS 4 24 8 36 l $56.83 $2,046 North Dakota Likely/SS 4 24 8 36 vs $46.40 $1,670

Northern
Mariana Islands Likely/SS 4 24 8 36 vs $46.40 $1,670 Ohio Likely/SS 4 24 8 36 l $56.83 $2,046 Oklahoma Likely/SS 4 24 8 36 m $49.18 $1,770 Oregon Likely/SS 4 24 8 36 m $49.18 $1,770 Pennsylvania Unlikely 1 0 0 1 l $56.83 $57 Puerto Rico Likely/SS 4 24 8 36 s $45.65 $1,643

Rhode Island Likely/MixedSS 5 34 11 50 vs $46.40 $2,320

South Carolina Likely/SS 4 24 8 36 m $49.18 $1,770

South Dakota Likely/NonSS 7 44 13 64 s $45.65 $2,922

Tennessee Likely/MixedSS 5 34 11 50 m $49.18 $2,459 Texas Likely/SS 4 24 8 36 vl $80.34 $2,892 Utah Likely/SS 4 24 8 36 s $45.65 $1,643 Vermont Likely/SS 4 24 8 36 s $45.65 $1,643

Virginia Likely/MixedSS 5 34 11 50 l $56.83 $2,841

Virgin Islands Likely/MixedSS 5 34 11 50 vs $46.40 $2,320 Washington Unlikely 1 0 0 1 l $56.83 $57 West Virginia Likely/SS 4 24 8 36 s $45.65 $1,643

Wisconsin Likely/NonSS 7 44 13 64 l $56.83 $3,637

Wyoming Likely/MixedSS 5 34 11 50 vs $46.40 $2,320Six-Year 3 ICR November 2009

Page 30 of 34 Exhibit A-1: Estimated State Bu rden for Occurrence Data Submission

State Likely to
Submit Data? Average Burden Per State Labor Costs

Reading

EPA Request Compiling, Submitting

Data Followup with

EPA Total
Burden State Program

Size Cost

per Hour Labor Cost per State

(a) (b) (c) (d) (e)= (b)+(c)+(d) (f) (g) (h)=(e)*(g)

TOTAL 248 1,526 494 2,268 $113,765

Annual Ave. 2010-2012 756.0 $37,922

Annual Ave. Per State 2010-
2012 13.5 $677
(a) States divided into four major groups: likely to provide data (indicated by "Likely/SS" (38 States), "Likely/Mixed-SS" (9 States) or "Likely/Non-SS" (7 States)); and those that are unlikely to provide data (indicated by "Unlikely" (2 States)). Likely/SS (S DWIS/State) means State stores all or most of (or are planning to store all or most) data using SDWIS/State. Likely/Non-SS means State provided data to EPA for the second Six-Year Review and had a strong record of electronic reporting, but does not use SDWIS/State for all data management. Likely/Mixed-SS means State uses a comb ination of proprietary software and SD WIS/State to store data. All others assigned "Unlikely." Total of 56 potential participating States.

(b-e) Average burdens based on estimated level of invo lvement and likely knowledge of the data. EPA assumes highest burden for States that are likel y to submit data but that do not have SDWIS/State; States with SDWIS/State are assigned a mid-level amount of burden for these activities, as these States are likely to "on average" have more knowledge of the needed data. EPA expects that States that are unlikely to participate may spend a small amount of time considering the request, and none beyond that.

(f-h) Average hourly State labor costs are from the "2001 ASDWA Drinking Water Program Resource Needs Self
Assessment". To make the cost assessment model easier to use, ASDWA established su ggested salary and benefit ranges ( i.e. , default values) for different sized State programs (very small, small, medium, large, very large; as indicated by initials). See Exhibit A-2, which illustrate s the basic model assumptions that were used here to estimate hourly labor costs.Six-Year 3 ICR November 2009

Page 31 of 34 Exhibit A-2: Estimated 2012 Salaries and Overhead Costs from ASDWA State

Resource Model

State Size (a) Professional
Staff Support
Staff Hourly Ave. ~
80% Prof and 20% Support Hourly Rate (adjusted for

overhead at 23%) (adjusted for fringe benefits at 22% of base salary)

Very Small (applies to 9 States, including VI, GU, AS, NM) $72,710 $48,643 $37.72 $46.40

Small (applies to 12 States, including DC and PR) $72,938 $42,279 $37.11 $45.65

Medium (applies to 23 total) $77,989 $47,875 $39.98 $49.18

Large (applies to 10 total) $88,047 $63,640 $46.20 $56.83

Very Large (applies to 2 total) $129,607 $69,450 $65.32 $80.34

(a) State labor costs are from the "2001 ASDWA Drinking Water Program Re source Needs Self Assessment". In 2000, the United States General Accounting Office used a previous version of this model to estimate nationwide drinking water program needs for Congress. The tool was later updated and improved based on comments from 27 States. To make the model easier to use, ASDWA established suggested salary and benefit ranges ( i.e. , default values), resource needs for the various NPDWRs, and other ke y variables. These hourly estimates are based on the default annual rates for 2010 that are provided in the mode l. These default rates are estimated forward from 2010 to 2012 using a 3% inflation factor. The model assumes 1,800 work hours per full-time equivalent employee. Hourly rate labor costs are adjusted to account for fringe benefits ( i.e. , holidays, sick days, vacation, pension, health, dental, and life insurance); and overhead ( i.e. , office space, furniture, utilities, copi ers, fax machines, postage, basic computing needs, etc.).Draft Six-Year 3 ICRNovember 2009Page 32 of 34Appendix B: Detailed Burden and Cost for EPAExhibit B-1: Estimated Burden and Labor Costs toEPA for Occurrence Data Collection and AnalysisActivitySDWIS andNon-SDWISStatesContractor Burden Contractor Labor CostEst. # ofSDWISStates toRespondEst. # ofNonSDWISStates toRespondEst.ContractorHours perSDWISStateEst.ContractorHours perNonSDWISStateEst. TotalContractorHours forSDWISStatesEst. TotalContractorHours forNonSDWISStatesEst. TotalContractorHours forAll StatesCost perHour forContractualLaborEst. TotalContractorLabor Costfor SDWISStatesEst. TotalContractorLabor Costfor NonSDWISStatesEst. TotalContractorLabor Costfor AllStates(a) (b) (c) (d) (e)=(a)*(c) (f)=(b)*(d)(g)=(e)+(f) (h) (i)=(e)*(h) (j)=(f)*(h)(k)=(i)+(j)Extract or downloaddata (r)38 16 9 15 342 240582$87.24 $29,837 $20,938$50,776Initial datascreening/conversionto uniform structures38 16 35 70 1,330 1,1202,450$87.24 $116,034 $97,713$213,746Communicate andcoordinate with theStates38 16 5 10 190 160350$87.24 $16,576 $13,959$30,535Data Managementand Analysis:QA/QC; review/editdata; analyze/reportfindings;record keeping38 16 83 83 3,167 1,3334,500$87.24 $276,271 $116,324$392,595TOTAL38 16 132 178 5,029 2,8537,882$87.24 $438,718 $248,934$687,652Draft Six-Year 3 ICRNovember 2009Page 33 of 34Exhibit B-1: Estimated Burden and Labor Costs to EPAfor Occurrence Data Collection and Analysis (continued)ActivityEPA Burden EPA Labor CostEPA and Contractor TotalsEst.EPAHoursperSDWISStateEst.EPAHoursforNonSDWISStatesEst. TotalEPAHours forSDWISStatesEst. TotalEPA Hoursfor NonSDWISStatesEst. TotalEPA Hoursfor AllStatesCostperHourforEPAStaffEst. TotalEPALaborCost forSDWISStatesEst. TotalEPALaborCost forNonSDWISStatesEst. TotalEPALaborCost forAll StatesEst. TotalEPA andContractorBurdenPerSDWISStateEst. TotalEPA andContractorBurden PerNon-SDWISStateEst. TotalEPA andContractorBurden forAll StatesEst. TotalEPA andContractorLaborCost forAll States(l) (m) (n)=(a)*(l) (o)=(b)*(m) (p)=(n)+(o) (q) (r)=(n)*(q) (s)=(o)*(q) (t)=(r)+(s) (u)=(c)+(l) (v)=(d)+(m) (u)=(g)+(p) (v)=(k)+(t)Extract or downloaddata (r)2 2 76 32108$82.81 $6,294 $2,650$8,944 11.0 17.0 690 $59,719Initial datascreening/conversionto uniform structures1 1 38 1654$82.81 $3,147 $1,325$4,472 36.0 71.0 2,504 $218,218Communicate andcoordinate with theStates1 1 38 1654$82.81 $3,147 $1,325$4,472 6.0 11.0 404 $35,007Data Managementand Analysis:QA/QC; review/editdata; analyze/reportfindings;record keeping25 25 950 4001,350$82.81 $78,670 $33,124$111,794 108.3 108.3 5,850 $504,389TOTAL29 29 1,102 4641,566$82.81 $91,257 $38,424$129,681 161 207 9,448 $817,333Annual Ave. 2010-20123,149 $272,444(c, d, l, m, u, v) Estimates for Data Management and Analysis assume: 100 contractor hours for each of 45 contaminants for which occurrence will be analyzed.To show this on a per State basis, as all other activities are shown, this 4,500 hours (100 hours x 45 contaminants) is dividedby 54 States (i.e., the maximumnumber of States expected to participate), which equals 83.3 hours per State. Similarly, 30 EPA hours for each of the 45 contaminants are shown as 25 hours perState. Thus, total estimated burden per State for this activityis approximately 108 hours. However, burden for the analyseswill not vary greatly with the additionor subtraction of State data sets; and burden would not be reduced or increased by the approximate 108 hours with each additionor subtraction of a State. Theother 3 listed aspects of EPA burden (data download, screening,and communication) will vary directly on a per State basis. Because these 3 other burden items areDraft Six-Year 3 ICRNovember 2009Page 34 of 34collectively smaller (at 53/State for SDWIS/States from columns (c) and (l), and 99/State for Non-SDWIS/State from columns (d)and (m)) than the data analysisburden, the "per State" burden will increase asthe number of participating States decreases.(h) Contractor costs are based on historical hourly costs pertaining to the management and analysis of occurrence data, which were approximately $87.24 per hour.(q) EPA internal labor costs are estimated using the federal government general schedule (GS) pay scale; assuming a labor levelof GS 13, Step 5, and taken fromthe Washington-Baltimore-Northern Virginia, DC-MD-VA-WV-PA rate schedule effective January 2009(see the U.S. Office of Personnel Management website:www.opm.gov). With these assumptions, labor and contractor rates were based on a 2,080 hour work year, with a $98,518 annual salary during 2009 (most currentavailable) plus 60 percent overhead, and then carried forward to 2012 using a 3% inflation factor, to arrive at $82.81 per hour.(r) For the majority of the NPDWR data being requested, there are approximately 38 States are using or planning to use SDWIS/State for data storage andmanagement, and 16 using a proprietary data system or a combination of SDWIS/State and a proprietary data system. For estimation purposes, EPA makes theconservative assumption that State burdens will vary with their primary data system (i.e., the 16 States using primarily a proprietary data system or a combinationof data systems are assumed to incur more burdenthan if they were primarily using SDWIS/State).