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 Work 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. 20004 
Six-Year 3 ICR November 2009

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TABLE OF CONTENTS 

1 IDENTIFICATION OF THE INFORMATION 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 AND 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–AGENCY 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 ............................................................ 32
Six-Year 3 ICR November 2009

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LIST OF EXHIBITS

Exhibit 4-1: Occurrence Data 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 Costs to EPA for Occurrence Data Collection and 

Analysis............................................................................................................................. 32
Six-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 Drinking Water Administrators 

CFR Code of Federal Regulations 

DQO Data Quality Objective 

DBPR Disinfectants and Disinfection 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 Industry 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 Rule 
Six-Year 3 ICR November 2009

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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 National 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) review existing National Primary Drinking Water 

Regulations (NPDWRs) no less often than every six years and, if appropriate, revise them. EPA 

is currently completing its second Six-Year Review cycle (2003-2009) during 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 States1

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 Request (ICR) as a one-time request for States 

to voluntarily submit historical regulated monitoring 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 across 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) for 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 process, EPA reviews existing NPDWRs and 

evaluates whether potential revisions are appropriate to maintain or improve the health of those 

persons served by public water systems. These compliance monitoring records (including all 

results for analytical detections and non-detections) and other compliance summaries (e.g., 

 1

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

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sanitary survey and corrective action information) provide the data needed to conduct statistical 

estimates of national occurrence of each regulated contaminant and are used to evaluate 

regulation effectiveness. The review of this data will support EPA's decisions regarding whether 

revisions to existing regulations are appropriate. In addition, the 1996 SDWA Amendments 

require the Agency to maintain a national drinking water contaminant occurrence database (i.e., 

the National Contaminant Occurrence Data (NCOD)) 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, secure file transfer protocol (FTP) site. After 

receiving the data, EPA will conduct the necessary 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 management and analysis to provide an overview of 

occurrence estimates at the national level. States will be provided with the edited data and/or the 

log of the edits that were applied to the data upon request prior to the posting and storage of data 

in the NCOD. Following final QA/QC of data, a summary of the data will be made available to 

the public through NCOD and/or other appropriate mechanisms. 

Although these data submissions are not required of the State agencies, EPA is required 

to conduct this ICR analysis because more than nine non-Federal entities 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 System Supervision (PWSS) Program ICR, which 

includes burden and cost estimates for many other administrative activities and information 

collection requirements of SDWA. 

The total annual burden and costs to the 56 potential State respondents associated with 

this ICR is estimated to be 756 hours and $37,922 per year over the 3-year ICR period of 2010-

2012, or 13.5 hours and $677 per year per State. All respondent costs are for labor activities 

associated with the time it takes to read and understand the request for compliance monitoring 

data, compile and submit existing data in an electronic format, and respond to questions 

regarding these data. This represents the "cost burden" as reported 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 expected to incur an average annual cost of 

$272,444 for labor associated with this program, including: extracting or downloading State data; 

initial data screenings and conversion to uniform structures; communicating and coordinating 

with States; and data management and analysis. 
Six-Year 3 ICR November 2009

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2 NEED FOR AND USE OF THE COLLECTION 

2(a) Need/Authority for the Collection 

Through the Six-Year Review process, the Agency reviews existing NPDWRs and 

evaluates whether potential revisions are appropriate 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 often than every 6 years, review and revise, as appropriate, each 

national primary drinking water regulation promulgated 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 provide for greater, protection of the health of 

persons." Compliance monitoring data provide information critical to these assessments. 

Without an understanding of where and at what levels these contaminants are occurring in public 

drinking water, EPA cannot assess the risk to public health and whether potential revisions are 

likely to maintain or improve public health protection. In addition, other compliance data 

(including sanitary survey and 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 information on the occurrence of both regulated and 

unregulated contaminants in public water systems..." 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 water 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 MCL violations were being stored on a nationallevel. 

2(b) Practical Utility/Users of the Data 

This ICR supports the collection of compliance monitoring data (contaminant occurrence 

data and treatment technique information) from States for all regulated chemical 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 goal in evaluating contaminant occurrence is to 

estimate the national number of PWSs at which the individual regulated contaminants occur at 

levels of health concern and/or the feasible level of measurement, and to evaluate the number of 

people exposed to these levels. This information, in conjunction with other 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 and corrective action information) 

will provide EPA with information to evaluate regulation effectiveness. 
Six-Year 3 ICR November 2009

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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 regulators, 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 associated with this ICR 

are not duplicated. Though these monitoring data have already been collected by States to 

comply with existing regulations and/or to investigate 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 unnecessarily 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 all 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 the proposed data collection effort on September 11, 2009 (74 

FR 46767), EPA did not receive any public comments 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 has updated this ICR to reflect the slight 

modification of the scope, revised burden hours, and updated labor costs. 

3(c) Consultations 

EPA first consulted with stakeholders regarding the Six-Year Review process during its 

development of a protocol during 1999 and 2000. A summary of the deliberative process and 

initial approach to occurrence analysis can be found in the 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 States on which States were currently using or 

are planning to use SDWIS/State. 
Six-Year 3 ICR November 2009

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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 Environmental Information, Office of Information 

Collection, Collection Strategies Division. The ICR Handbook provides the most current 

instructions for ICR preparation to ensure compliance with the 1995 PRA Amendments and 

OMB's implementing guidelines. 

This data collection is a request, not a requirement, and EPA is taking an approach that 

minimizes burden to the respondents. In addition, this collection does not violate any of the 

OMB guidelines for information collection activities. 

3(f) Confidentiality 

This information collection does not require respondents to disclose confidential 

information. 

3(g) Sensitive Questions 

No questions of a sensitive nature are included in any of the information collection 

requirements outlined in this ICR. 
Six-Year 3 ICR November 2009

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4 RESPONDENTS AND THE INFORMATION 

4(a) Respondents and NAICS/SIC Codes 

Data associated with this ICR are collected and maintained by State drinking water 

agencies. The North American Industry Classification System (NAICS) code for State agencies 

that include drinking water programs are classified as 92411 (Administration 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 will take place in response to a specific EPA 

data call-in to State drinking water programs. Though this is not a requirement, the ICR is 

necessary to estimate reporting burden and costs to the States. This ICR summarizes the data 

items and respondent activities associated with the reporting effort. All data being called-in are 

historic (i.e., data already exist); no States or PWSs will 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 information 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 format. The requested data include analytical 

detections and non-detections for routine compliance monitoring samples (including repeat and 

confirmation samples) and other compliance summaries (including sanitary 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 analytical 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 monitoring data stored and maintained by States typically 

includes most, if not all, of those data elements. EPA expects that it would be a greater burden 

for States to remove specific, otherwise available 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 subset of data, EPA has identified essential data 

categories that the Agency needs to most effectively evaluate the occurrence data. If States elect 
Six-Year 3 ICR November 2009

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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 appropriate 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-Dichloroethylene Nitrate (as N) 

Arsenic Dichloromethane (Methylene 

chloride) 

Nitrite (as N) 

Asbestos 1,2-Dichloropropane Oxamyl (Vydate) 

Atrazine Di(2-ethylhexyl) adipate (DEHA) Pentachlorophenol 

Barium Di(2-ethylhexyl) phthalate (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 Ethylbenzene 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

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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; see 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 code 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, conventional filtration, and other permitted values) 
Six-Year 3 ICR November 2009

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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 status, alternative return location, corrective 

action requirements, and recycle flows and frequency). 

Sample-Specific Information

Sampling Point 

Identification Code 

A sampling point identifier established by the State, unique within each applicable 

facility, for each applicable sampling location (e.g., entry point to the distribution 

system). This information enables occurrence assessments that address intra-system 

variability. 

Sample Identification 

Number Identifier assigned by State or the laboratory 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 collected (e.g., compliance, routine, repeat, 

confirmation, additional routine samples, duplicate, 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 was originally collected: 

• Upstream 

• Downstream 

• Original 

 Contaminant Contaminant name, 4-digit SDWIS contaminant 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 analysis 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

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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 

μg/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 concentration value of a contaminant's MRL. 

(Not required for TCR data)

Source Water Monitoring 

Information 

Total organic carbon (TOC), including 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, alternative 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 technique 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 record keeping requirements are associated with 

this information collection request. Each of these respondent activities is described in more 

detail below. 

Reading/Understanding EPA's Request

EPA will send a letter to 56 States that explains the purpose of the data collection, the 

specific information EPA is requesting, and the procedure for submitting these data. 

Compiling and Submitting Monitoring Data

EPA is asking States to compile and submit data that have already been collected from 

water systems, and which already exist in electronic format. EPA is not expecting States or 

water systems to collect new data in response to this 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

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To facilitate the consistency and quality of data across States, EPA will ask States to: 

provide a brief description of the basic format and structure of each data set, and definitions of 

all data elements, column/row headings, 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 expected that the data from States 

using or are planning to use SDWIS/State will more closely match the needed data formats and 

elements, and thus are assumed to have less burden for submissions than non-SDWIS States. To 

ease this burden, EPA will provide extraction scripts to use with the SDWIS/State database. 

However, all States will have the option of submitting 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 information, 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 choose not to submit data at this time; such 

States are assumed to incur no burden related to this data request beyond the initial reading of the 

request. 

Follow-up with EPA 

Based on the Agency’s experience with occurrence information provided by States for 

the Six-Year Review 2, EPA expects that it may need to contact some States' data management 

staff to address questions regarding the data quality such as possibly 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 their codes, headers, etc. It is 

assumed that these communications and confirmations will be handled primarily through 

telephone and e-mail. 
Six-Year 3 ICR November 2009

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5 INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT 

5(a) Agency Activities 

EPA Headquarters will conduct the following activities associated with the collection of 

regulated monitoring data: 

• Extract or download data; 

• Initial data screening/conversion 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 discussed in more detail below. 

Extract or Download Data

EPA's data extraction/downloading activities will depend to some degree on the type of 

data system used in each State, and on the level 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 use 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 requested 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 States, regardless of type of data system, will 

submit their data using security protocol 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 set 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

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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 and 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 contaminant 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 the Six-Year Review 3 contaminant 

occurrence analyses is development of a consistent 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 data 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 analytical results are 

generated by laboratories that are certified for drinking water programs. Therefore, some 

assumptions are made regarding the general quality of the raw compliance monitoring data 

received from the States. Data problems will certainly exist, but efforts will be taken to reduce 

the problems and increase the dependability and quality of the State occurrence data used in 

these analyses. 

The number of systems with compliance monitoring data in each State will be checked 

against total system inventory numbers from SDWIS/FED, and other more appropriate 

supplemental information, where needed. The number of analytical records per system (per 

contaminant) will also be evaluated to assess completeness of the submitted analytical records. 

Contaminant-specific analytical values are also assessed as part of the QA/QC review. For 

example, the assessment of the range of all analytical values for a specific 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 appropriate 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 data 
Six-Year 3 ICR November 2009

Page 15 of 34 

representativeness and to analyze the compliance monitoring data from 45 States. This approach 

will also be used for the third Six-Year Review for the chemical, radiological and 

microbiological contaminants. States' compliance 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 analytical 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 result exceeding specific threshold values. The "Stage 2" analysis 

estimates long-term mean concentrations of contaminants 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 procedures conducted to develop the national dataset, 

and the statistical analytical methods employed (using 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 Water 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 Disinfectants and Disinfection Byproducts Rules 

(DBPRs), and Filter Backwash Recycling Rule (FBRR) 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 Agency reviews and assesses risks to human 

health posed by existing drinking water contaminants. The collection of the occurrence data, and 

the quantity, coverage, representativeness, 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 nationally representative probabilistic survey in lieu of 

requesting data from all States. EPA assessed numerous 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 compliance monitoring data and 

treatment technique information for all NPDWRs in an efficient or reasonable manner.2

 The 

potential problems associated with survey design are explained in more detail as follows: 

 2

 A list of these contaminants is provided 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 would result in a wide range of confidence 

intervals and precision terms based on the surveyed systems' data. Conversely, to 

design a single survey so that the individual contaminant with the most variable 

occurrence data still meets minimum DQOs would 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 expect an increased non-response rate if data 

were requested directly from systems. 

• Based on the Agency's experience working 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 for select individual 

PWSs. 

• Monitoring schedules can vary across contaminants and across systems, and can be 

quarterly, annual, triennial, or every nine years. Actual contaminant-specific 

sampling frequencies are unknown, and therefore, are difficult to address in any 

survey design. (Different sampling frequencies are attributed to waiver programs and 

historical results showing contaminant occurrence (or lack of occurrence).) 

An alternative to a single survey for all NPDWRs would be multiple surveys for groups 

of related contaminants as well as treatment techniques. However, the Agency anticipates that 

the burden for EPA, the States, and/or systems 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 required by the Freedom of Information Act (40 CFR, 

Chapter 1, Part 2). A summary of the data, after a complete and thorough QA/QC review, will 

be available to the public 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 several reasons: this 

information collection is potentially significantly larger in scale than the previous collections; the 

FTP site to be used offers a high level of data security; 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-compatible file formats: Dbase (.dbf); Access tables 

(.mdb); comma or tab delimited files (such as .csv or .txt), or; Excel (.xls). In addition, EPA's 
Six-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; and 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 clarification 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 currently stored in, and submitting that copy of the 

electronic data to EPA. If States only submit the minimum data element information, EPA will 

extract the additional inventory information from SDWIS/FED, based on the PWSID number. 

Other communications and confirmations (regarding data set follow-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 small 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 drinking water agency qualifies as a small entity, 

as defined under the Regulatory Flexibility Act (RFA), and summarized below.3

• A small business is any business that is independently owned and operated 

and not dominant in its field as defined 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 dominant in its field. 

• A small governmental jurisdiction is the government of a city, county, town, 

township, village, school district or special district that has a population of 

fewer than 50,000. This definition may also include Indian tribes. 

The major requirement under SBREFA is a regulatory flexibility analysis of all rules that 

have a "significant economic impact on a substantial number of small entities." Since this data 

request is not part of a rule, and does not affect any small entities as defined above, this ICR is 

not subject to SBREFA. 

 3

 These definitions were taken 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. States will be responding to this request in 2012. Data analysis 

is expected to continue through 2015, when EPA plans to release its final review results for SixYear 3. 
Six-Year 3 ICR November 2009

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6 ESTIMATING THE BURDEN AND 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 discussed further in Section 6(a). The burden and cost estimates for 

State drinking water primacy agencies are discussed 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 about the burden associated with activities 

that would likely be needed to fulfill the request. To the extent possible, assumptions were based 

on similar activities for past data collections. EPA emphasizes that the per-respondent estimates 

represent the average burden and cost over the 3-year period covered by this ICR (2010-2012). 

Some respondents may incur higher costs and some will fall below the average. Summary 

burden and cost estimates for States and EPA are provided in Exhibits 6-1 and 6-2. Detailed 

estimation tables for States and EPA are provided 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 Agency 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 categories 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 considering the request for data, as they may 

need to identify which of their 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 combination 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 occurrence 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 occurrence data and treatment technique 
Six-Year 3 ICR November 2009

Page 20 of 34 

information, and follow up with EPA is also expected to be easier for 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 the requested data stored 

electronically or those that are considered generally not likely to submit data are expected 

only to spend a minimal amount of time considering the request. No further burden is 

assumed. EPA will incur no burden for these States. 

6(a) Estimating Respondent Burden 

The average annual respondent burden (in labor hours) for States is shown in Exhibit 6-1. 

Appendix A provides detail of the estimated respondent 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 average 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 includes 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 regarding 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 software 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 estimated 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 likely 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 States that will submit with proprietary software 

is estimated at 44 hours. Those States with a mix of proprietary software for some rules, and 

SDWIS/State for others is estimated 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 codes, headers, etc. will need to 

spend little follow-up time with EPA. States submitting 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. States with proprietary software are estimated to spend 13 hours of 
Six-Year 3 ICR November 2009

Page 21 of 34 

follow-up time with EPA. Those States with a mix of proprietary software for some rules, and 

SDWIS/State for others is estimated at 11 hours. States with SDWIS/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 incur capital or operations and maintenance 

(O&M) costs associated with this ICR. EPA estimates each State will incur an annual average 

labor cost of $677 for this data collection effort. 

State labor costs are based on information provided in the "2001 ASDWA Drinking 

Water Program Resource 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 key variables. 

Labor costs per hour are based on the default annual 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 collection 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

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6(c)(i) Agency Burden 

For the 3-year ICR period (2010-2012), EPA estimates that the average annual burden to 

the Agency will be 3,149 hours. This estimate includes burden incurred by EPA or its 

contractors for the activities outlined in Section 5(a) above. EPA burden is estimated based on 

similar activities conducted during the Six-Year 2 occurrence data analysis. 

Extract or Download Data

EPA is estimating its data extraction and downloading burden based on the types of data 

systems that States use to submit data. To coordinate 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 use either all proprietary, or a mix of 

proprietary and SDWIS/State. 

Initial Data Screening/Conversion to Uniform Structures

EPA's data screening and conversion is also estimated on a per State basis. Based on its 

experience during Six-Year 2, EPA assumes that burden 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. EPA 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 use 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 will require less burden for those State with 

SDWIS/State than for those with a proprietary database. 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 use either all proprietary, or a mix of 

proprietary and SDWIS/State. 
Six-Year 3 ICR November 2009

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Data Management and Analysis

Data management and analysis activities include: quality assurance/quality control and 

review/editing of data; data analysis and report of findings; and 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), EPA 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 participate), which equals approximately 108 hours 

per State. However, because burden for the occurrence analyses and treatment techniques will 

not vary greatly with the addition 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 contaminant 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 annual burden hours are associated with 

annual labor costs of $272,444 to collect and analyze 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 Management 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 government 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 EPA1

(38 SDWIS States) (16 Non-SDWIS 

States) Burden Cost

Extract/download data 11.0 17.0 230 $19,906

Initial data 

screening/conversion to 

uniform structures 36.0 71.0 835 $72,739

Communicate, coordinate 

with States 6.0 11.0 135 $11,669
Six-Year 3 ICR November 2009

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Exhibit 6-2: Annual EPA Burden and Costs 

(for ICR period of 2010-2012) 

Activity

EPA Burden Per State Annual EPA1

(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 and 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 this ICR are shown in Exhibit 6-3. This 

includes the burden and costs to the 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 Average 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 Respondents 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 $310,366
Six-Year 3 ICR November 2009

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6(f) Reasons for Change in Burden 

This ICR is a one-time data collection effort in support of the 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 modification in the scope (i.e., to request data for several additional rules such 

as Ground Water Rule (GWR), Surface Water Treatment 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 Disinfectants and Disinfection Byproducts Rules 

(DBPRs), and Filter Backwash Recycling Rule (FBRR). 

6(g) Burden Statement 

The reporting burden for data collections included 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 this is a one-time data request 

for this Six-Year Review, there is only one response per respondent, and all burdens and costs 

related to this response are included in these estimates. The Agency expects that most, if not all, 

respondent activities will take place during 2012. Estimates 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, disclose, or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology, 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a 

request for information collection unless it displays a currently valid OMB control number. The 

OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OW-2005-0019, which is available for public viewing at the Water 

Docket in the EPA Docket Center (EPA/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 through 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 version 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, and to access those documents in the public docket 

that are available electronically. Once in the system, select "search," then key in the docket ID 
Six-Year 3 ICR November 2009

Page 26 of 34 

number identified above. Also, you can send comments to the Office of Information and 

Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 

20503, Attention: Desk Office for EPA. Please 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 

APPENDICES
Six-Year 3 ICR November 2009

Page 28 of 34 

Appendix A: Detailed Burden and Cost for States 

Exhibit A-1: Estimated State Burden 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 $2,459
Six-Year 3 ICR November 2009

Page 29 of 34 

Exhibit A-1: Estimated State Burden 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 $2,320
Six-Year 3 ICR November 2009

Page 30 of 34 

Exhibit A-1: Estimated State Burden 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 (SDWIS/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 combination of proprietary software and SDWIS/State to store data. All others 

assigned "Unlikely." Total of 56 potential participating States. 

(b-e) Average burdens based on estimated level of involvement and likely knowledge of the data. EPA assumes 

highest burden for States that are likely 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 suggested 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 illustrates 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 Resource 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 key variables. These hourly estimates are based on the 

default annual rates for 2010 that are provided in the model. 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, copiers, fax machines, postage, basic 

computing needs, etc.).
Draft Six-Year 3 ICR 

Page 32 of 34 

Appendix B: Detailed Burden and Cost for EPA 

Exhibit B-1: Estimated Burden and Labor Costs to EPA for Occurrence Data Collection 

Activity 

SDWIS and 

Non-SDWIS 

States 

Contractor Burden Contracto

Est. # of 

SDWIS 

States to 

Respond 

Est. # of 

NonSDWIS 

States to 

Respond 

Est. 

Contractor 

Hours per 

SDWIS 

State 

Est. 

Contractor 

Hours per 

NonSDWIS State 

Est. Total 

Contractor 

Hours for 

SDWIS 

States 

Est. Total 

Contractor 

Hours for 

NonSDWIS 

States 

Est. Total 

Contractor 

Hours for 

All States 

Cost per 

Hour for 

Contractual 

Labor 

Est. Tota

Contracto

Labor Co

for SDWI

States 

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

Extract or download data (r) 38 16 9 15 342 240 582 $87.24 $29,837 Initial data screening/conversion to uniform structures 38 16 35 70 1,330 1,120 2,450 $87.24 $116,03Communicate and coordinate with the States 38 16 5 10 190 160 350 $87.24 $16,576 Data Management and Analysis: QA/QC; review/edit data; analyze/report findings; record keeping 38 16 83 83 3,167 1,333 4,500 $87.24 $276,27

TOTAL 38 16 132 178 5,029 2,853 7,882 $87.24 $438,71
Draft Six-Year 3 ICR 

Page 33 of 34 

Exhibit B-1: Estimated Burden and Labor Costs to EPA for Occurrence Data Collection and A

Activity 

EPA Burden EPA Labor Cost EPA 

Est. 

EPA 

Hours 

per 

SDWIS 

State 

Est. 

EPA 

Hours 

for 

NonSDWIS 

States 

Est. Total 

EPA 

Hours for 

SDWIS 

States 

Est. Total 

EPA Hours 

for NonSDWIS 

States 

Est. Total 

EPA Hours 

for All 

States 

Cost 

per 

Hour 

for 

EPA Staff 

Est. Total 

EPA 

Labor 

Cost for 

SDWIS 

States 

Est. Total 

EPA 

Labor 

Cost for 

NonSDWIS 

States 

Est. Total 

EPA 

Labor 

Cost for 

All States 

Est. Total 

EPA and 

Contractor 

Burden 

Per 

SDWIS 

State 

E

E

C

Bu

No

(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

Extract or download data (r) 2 2 76 32 108 $82.81 $6,294 $2,650 $8,944 11.0 Initial data screening/conversion to uniform structures 1 1 38 16 54 $82.81 $3,147 $1,325 $4,472 36.0 Communicate and coordinate with the States 1 1 38 16 54 $82.81 $3,147 $1,325 $4,472 6.0 Data Management and Analysis: QA/QC; review/edit data; analyze/report findings; record keeping 25 25 950 400 1,350 $82.81 $78,670 $33,124 $111,794 108.3 

TOTAL 29 29 1,102 464 1,566 $82.81 $91,257 $38,424 $129,681 161 

 Annual Ave. 2010-2

(c, d, l, m, u, v) Estimates for Data Management and Analysis assume: 100 contractor hours for each of 45 contaminants for which occTo show this on a per State basis, as all other activities are shown, this 4,500 hours (100 hours x 45 contaminants) is divided by 54 Stat

number of States expected to participate), which equals 83.3 hours per State. Similarly, 30 EPA hours for each of the 45 contaminants State. Thus, total estimated burden per State for this activity is approximately 108 hours. However, burden for the analyses will not va

or subtraction of State data sets; and burden would not be reduced or increased by the approximate 108 hours with each addition or sub

other 3 listed aspects of EPA burden (data download, screening, and communication) will vary directly on a per State basis. Because th
Draft Six-Year 3 ICR 

Page 34 of 34 

collectively smaller (at 53/State for SDWIS/States from columns (c) and (l), and 99/State for Non-SDWIS/State from columns (d) and burden, the "per State" burden will increase as the 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 app(q) EPA internal labor costs are estimated using the federal government general schedule (GS) pay scale; assuming a labor level of GS the Washington-Baltimore-Northern Virginia, DC-MD-VA-WV-PA rate schedule effective January 2009 (see the U.S. Office of Personwww.opm.gov). With these assumptions, labor and contractor rates were based on a 2,080 hour work year, with a $98,518 annual salaravailable) 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 fmanagement, and 16 using a proprietary data system or a combination of SDWIS/State and a proprietary data system. For estimation pconservative assumption that State burdens will vary with their primary data system (i.e., the 16 States using primarily a proprietary datof data systems are assumed to incur more burden than if they were primarily using SDWIS/State).