## Information Collection Request for

Contaminant Occurrence Data in Support of EPA's Second Six-Year Review of National Primary Drinking Water Regulations

August 2006

Prepared by: The Cadmus Group, Inc.

57 Water Street Watertown, MA 02472

Prepared for: Jane Holtorf, Project Officer Peter Lassovszky, Work Assignment Manager U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water EPA East, 2 nd Floor 1200 Pennsylvania Avenue, NW Washington, DC 20460Draft Six-Year 2 ICR August 2006

Page i of iii 

### 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 ................................................................................................................... 6 3(d) Effects of Less Frequent Collection ................................................................................ 6 3(e) General Guidelines .......................................................................................................... 7 3(f) Confidentiality ................................................................................................................ 7 3(g) Sensitive Questions ......................................................................................................... 7

4 RESPONDENTS AND THE INFORMATION ...................................................................... 8 4(a) Respondents and NAICS/SIC Codes .............................................................................. 8 4(b) Information Requested .................................................................................................... 8

4(b)(i) Data Items ..................................................................................................................... 8 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 A ND COST OF THE COLLECTION ............................... 19 6(a) Estimating Respondent Burden ..................................................................................... 20 6(b) Estimating Respondent Costs ....................................................................................... 20 6(c) Estimating Agency Burden and Costs .......................................................................... 21

6(c)(i) Agency Burden ........................................................................................................... 21 6(c)(ii) Agency Cost................................................................................................................ 23 6(d) Estimating the Respondent Universe and Total Burden and Costs .............................. 23 6(e) Bottom Line Burden Hours and Cost Tables ................................................................ 24 6(f) Reasons for Change in Burden ..................................................................................... 24 6(g) Burden Statement .......................................................................................................... 24

APPENDICES .............................................................................................................................. 26 Appendix A: Detailed Burden and Cost for States ................................................................... 27 Appendix B: Detailed Burden and Cost for EPA ..................................................................... 31Draft Six-Year 2 ICR August 2006

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### LIST OF EXHIBITS

Exhibit 4-1: Regulated Contaminan t Occurrence Data to Be Requested ...................................... 9 Exhibit 4-2: Requested Data Elements ........................................................................................ 10 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 ..................................... 27

Exhibit A-2: 2007 Salaries and Overhead Costs from ASDWA State Resource Model ............. 30

Exhibit B-1: Estimated Burden and Labor Costs to EPA for Occurrenc e Data Collection and Analysis

............................................................................................................................... .......... 31Draft Six-Year 2 ICR August 2006

Page iii of iii ACRONYMS

AMWA Association of Metropolitan Water Agencies

AWWA American Water Works Association

ASDWA Association of State Drinking Water Administrators CDX Central Data Exchange CFR Code of Federal Regulations CMR Chemical Monitoring Reform CWS Community Water System DQO Data Quality Objective EPA Environmental Protection Agency FR Federal Register FTE Full Time Equivalent

FTP File Transfer Protocol ICR Information Collection Request

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 NTNCWS Non-transient Non-community Water System 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

TCR Total Coliform RuleDraft Six-Year 2 ICR August 2006

Page 1 of 33 

### 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 Second Six-Year Review of Nationa l Primary Drinking Water Regulations

OMB Control Number: 2040- NEW

EPA Tracking Number: 2231.01

1(b) Short Characterization

The Safe Drinking Water Act (SDWA), as am ended in 1996, requires that the U.S. EPA review existing National Primary Drinking Wate r Regulations (NPDWRs) no less often than every six years. This cyclical evaluation is referred to as the "Six-Y ear Review of National Primary Drinking Water Regulations" or, simply, the "Six-Year Review." Through the Six-Year Review process, EPA reviews and assesses risks to human health posed by regulated drinking

water contaminants. For the first Six-Y ear Review cycle (1996–2002), EPA reviewed 68

chemical NPDWRs and the Total Coliform Rule (TCR), which were promulgated prior to the

1996 Amendments. The occurrence assessments c onducted for the first Six-Year Review were based on compliance monitoring data from 1993 to 1997, which were provided by States. EPA published the results of this review in the July 18, 2003, edition of the Federal Register (68 FR 42907–42929).

EPA is issuing this Information Collection Re quest (ICR) as a one-time request for States to submit historical regulate d monitoring data on a voluntary basis to EPA during the 2007 and 2008 timeframe. To comply with the 1995 Am endments to the Paperwork Reduction Act (PRA), this ICR estimates the potential cost to States for data submission across the 3-year ICR period of 2007-2009.

EPA's Office of Water is requesting that States 1 submit compliance monitoring data for community water systems (CWSs) and non- transient non-commun ity water systems (NTNCWSs). EPA is requesting contaminan t occurrence data from 1998 to 2005 for all regulated chemical and radiolog ical contaminants, as well as data from the TCR. EPA anticipates that the compliance mo nitoring records from this information collection (including all results for analytical detections and non-detec tions) will provide the data needed to conduct statistical estimates of national occurrence for each regulated contaminant. These national occurrence estimates will be used to support EPA's review of existing regulations, and the Agency’s decision on whether any revisions are needed. In addition, the 1996 SDWA section 1445(g) requires the Agency to maintain a national drinking water contaminant occurrence

1 Throughout this document, the terms "S tate" or "States" are used to refe r to the 56 States and territories.Draft Six-Year 2 ICR August 2006

Page 2 of 33 database (i.e., the National Contaminant Occurrence Data (NCOD)) using occurrence data for both regulated and unregulated contaminants in public water systems (PWSs). This data collection will provide new occurrence data on regul ated contaminants to maintain the NCOD.

States can submit 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 prior to posting and storage of data in the NCOD. Following final QA/QC of data, it will be made available to the public through NCOD.

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 681 hours and $30,608 pe r year over the 3-year ICR period of 2007- 2009, or 12.2 hours and $547 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. , SDWIS/State vs. proprietary data systems) and e xpected participation levels. No burden to PWSs is associated

with this data collection.

Over the ICR years of 2007-2009, EPA is expect ed to incur an average annual cost of $231,916 for labor associated with this program, including: extracting or downloading State data; initial data screenings and conversi on to uniform structur es; communicating and coordinating with States; and data management and analysis.Draft Six-Year 2 ICR August 2006

Page 3 of 33 2 NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection
Through the Six-Year Review process, the Agency reviews and assesses risks to human health posed by regulated drinking water contam inants. Section 1412(b)(9) of SDWA states: "The Administrator shall, not less often than ev ery 6 years, review and revise, as appropriate, each national primary drinking water regulation prom ulgated 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." Occurrence data provide informati on critical to these assessments. Without an understanding of where and at what levels thes e contaminants are occurring in public drinking water, EPA cannot assess the risk to public healt h. With this occurrence data, national statistical estimates for occurrence of each regu lated contaminant can be conducted.

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 systems. . ." Se ction 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 MCL violations was bei ng stored on a national

level.

In addition to fulfilling SDWA requirements, there are several reasons for requesting this occurrence data: to date, a national database of the complete records of compliance monitoring for drinking water contaminants does not exist; these records are the best occurrence data available to support the national occurrence assessments necessary for the Six-Year Review 2;

this set of data will enable the most direct temporal occurrence comparisons to the compliance monitoring data records collect ed for Six-Year Review 1 ( i.e. , complete data records from 1993 to 1997 from the 16 States comprising the 16-State National Cross-Section). 2

2(b) Practical Utility/ Users of the Data

This ICR supports the collection of comp liance monitoring (contaminant occurrence) data from States for all regulated chemical cont aminants and radionuclides, as well as data from the TCR. A list of these contaminants is provided as Exhibit 4-1. These occurrence data will be

used to derive detailed statistical estimates of national occurren ce of these regulated contaminants. EPA's specific goal in evaluatin g contaminant occurrence is to estimate the

national number of PWSs at whic h the individual regulated cont aminants occur at levels of

2 Compliance monitoring data from the 16 states were compiled through two separate submissions of State data. Eight States

submitted data for occurrence assessments conducted for the Chem ical Monitoring Reform EPA project work conducted in 1997 and 1998. Additional compliance monitoring data were submitte d by 8 other States in 2000 and 2001 for EPA’s Six-Year Review 1. Collectively these two groups of data comprise the 16-State National Cr oss-Section data set used for occurrence analyses in the Six-Year Review 1.Draft Six-Year 2 ICR August 2006

Page 4 of 33 health concern, and to evaluate the number of people exposed to these levels. This, in conjunction with other contaminan t-specific analyses conducted as part of the Six-Year Review (e.g., health assessment), will provide EPA with info rmation to determine whether or not there is a need to revise a regulation to maintain or provide for greater prot ection of human health.

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 regulat ors, 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.Draft Six-Year 2 ICR August 2006

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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. EPA has consulted with AS DWA as part of its efforts to ensure nonduplication of this information collection.

Ten of the States that provided occurrence data for Chemical Monitoring Reform (CMR)

or Six-Year Review 1 also incl uded chemical monitoring data for one or more years during 1998 through 2000. EPA will specify that States can omit any previously submitted data sets if they prefer. If it is easier for States to submit their data sets as a whole, rather than filtering the data set for transfer to EPA, States have the option to re-submit data, and EPA will filter duplicate data prior to analysis. In addition, SDWIS contains some inventory-related data elements that EPA is requesting be submitted with each sample re sult. As discussed in Section 4(b), EPA will give States the option of repor ting all requested data elements or having the Agency access inventory data from SDWIS based on the Federa l public water system identification (PWSID)

number.

Though these monitoring data have already b een collected by Stat es 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 unn ecessarily duplicative of information otherwise available to the Agency.

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

Following public notice of the proposed da ta collection rule on June 5, 2006 (71 FR 32340), EPA received one public comment during the comment period related to this ICR. The Association of State Drinking Wate r Administrators (ASDWA) submitted comments addressing concerns that States may have related to the da ta collection. In summary, the comments from the organization, and EPA responses are as follows:

• The commenter does not support mandatory reporting of occu rrence data (beyond the current Lead and Copper Rule requireme nts) due to limited State resources.

The commenter believes that data colle ction through a properly developed and implemented voluntary ICR is appropriate. EPA plans to conduct this data collection as a voluntary effort. Any possible future changes regarding the collection of drinking water contaminant occurrence data will be handled through a separate public comment process.Draft Six-Year 2 ICR August 2006

Page 6 of 33 • The commenter recommends that EPA make ev ery effort to minimize the effort it

takes States to share these data with the Agency, including developing extraction scripts that allow states using SDWIS/ State to easily dow nload the occurrence data. In addition, the commenter recomm ends that EPA accept data in each State's existing format with EPA then unde rtaking whatever da ta conversion, edit checks, and transfer tasks that may be neces sary to transfer and use the data. EPA agrees with the commenter and plans to allow States to submit the data to EPA in

whatever electronic format is most suita ble for each State. EPA plans to make every effort possible to minimize burden on the States, including use of extraction scripts for SDWIS/State data, if States agree with this method of data transfer.

• Finally, the commenter believes that EPA should not attribute the data to any particular system in an enforcement cont ext, and that use of the occurrence data for purposes other than those for whic h the data were intended would be inappropriate, and would tend to discourage participation. EPA agrees with the commenter and plans to use the da ta for occurrence assessment only.

No changes to the data collection format, or to the cost and burden estimates were suggested or necessitated by these comments.

3(c) Consultations

EPA first consulted with stakeholders rega rding 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).

In 2003, ASDWA conducted a survey of States about their abilities and interest in submitting occurrence data. ASDWA received res ponses from 32 States. This information helped EPA to gauge which States would be more lik ely to participate in th is data collection. In preparing for Six-Year Review 2, EPA consu lted with ASDWA regard ing the collection and analysis of States' drinking water data. Speci fically, EPA worked closely with ASDWA on the initial design and planning of the data request.

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 co llected on a one-time basis for this Six-Year

Review to meet the SDWA statutory requirements.Draft Six-Year 2 ICR August 2006

Page 7 of 33 3(e) General Guidelines

This ICR was prepared in accordance with the October 2001 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 re quest, 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 information 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 in cluded in any of the information collection requirements outlined in this ICR.Draft Six-Year 2 ICR August 2006

Page 8 of 33 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 (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 for samples collected by CWSs and NTNCWSs during January 1998 through December 2005 for the contaminants listed in Exhibit 4-1. This request only includes existing data that the States have already stored in electronic format. The request ed data include analy tical detections and nondetections for routine compliance monitoring samples (including repe at and confirmation samples), as well as any special study samp ling 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 17 data elements (see Exhibit 4-2) th at the Agency will request that States provide with their sample results. In general, thes e data elements are based on those used for the Unregulated Contaminant Monitori ng Regulation and the first Si x-Year Review. 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 "a s is." However, for States that elect to submit a subset of data, EPA has identified essential data elements (marked in the table with an asterisk) that the Agency needs to most effectivel y evaluate the occurrence data. If States elect to submit their data with only these data elements, EPA will use the PWSID number to acquireDraft Six-Year 2 ICR August 2006

Page 9 of 33 additional system inventory da ta from SDWIS/FED (adjusted using information from the 1999 Drinking Water Infrastructure Needs Survey).

Exhibit 4-1: Regulated Contaminan t 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 N itrate (as N)

Arsenic Dichloromethane (Methylene chloride) N itrite (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

Gross beta Tritium Combined Radium-226/228; and

Radium-226 & Radium-228 (if available) Iodine-131

Gross alpha Strontium-90 Uranium

Microbiological Contaminants

Total coliforms Fecal coliforms E scherichia coli (E. coli)Draft Six-Year 2 ICR August 2006

Page 10 of 33 Exhibit 4-2: Requested Data Elements

The 9 data elements in bold and marked with an asterisk (*) are needed to most eff ectively analyze the occurrence data, although ideally, all 17 data elements would be submitted with occurrence data.

Data Element Description

Inventory Data

* 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 a: • 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.

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) (see note below)

Note : Some States may not distinguish GWUDI fro m surface water sources. In those States, a GWUDI source should be reported as a surface water source type.

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 Purpose Indicates why the sample is being collected (e.g., compliance/routine, confirmation, duplicate, repeat, 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.Draft Six-Year 2 ICR August 2006

Page 11 of 33 Exhibit 4-2: Requested Data Elements

The 9 data elements in bold and marked with an asterisk (*) are needed to most eff ectively analyze the occurrence data, although ideally, all 17 data elements would be submitted with occurrence data.

Data Element Description

* 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.

* Sample Analytical Result

- Unit of Measure Unit of measurement for the analytical resu lts reported (usually expressed in either Φ g/L or mg/L for chemicals; or pCi/l or mrem/yr for radionuclides).

(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)

4(b)(ii) Respondent Activities

Potential respondents to this information co llection are assumed to include the drinking water agencies for the 56 State and territories li sted in exhibit A-1 in Appendix A. Activities needed to respond to the information collec tion include reading and understanding EPA's request, compiling and submitting the requested dr inking water contaminant data in electronic format, and communication and coordination with EPA. No record keeping requirements are associated with this information collection reque st. 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 e xplains 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 dataDraft Six-Year 2 ICR August 2006

Page 12 of 33 into an electronic format. All data will be submitted using security protocol to a designated FTP

site.

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 horizontal 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 SAS-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 SDWIS/State will more closely match the need ed data formats and elements,

and thus are assumed to have less burden for su bmissions than non-SDWIS States. However, all States will have the option of submitting data "as is", thus, the assumption of higher burden for

non-SDWIS States is a conservati ve (highest possible cost) assu mption. If States submit only the minimum data element information, EPA will extract the additional inventory information from SDWIS/FED (adjusted by the most recent Needs Survey, if necessary), based on the PWSID number. (States will be notified of these details in communications from EPA.)

EPA also assumes that some States will c hoose 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 its experience with occurrence info rmation provided by States for the CMR and Six-Year Review 1, EPA expects th at it may need to contact some States' data management staff to address questions regarding the data quality su ch as possibly incorrect units of measurement, outlier values, incorrect, missing, or undefined data elements, or other possible data problems. This follow-up may not be needed for those States that provide their data in the requested format with an explanation of their codes, headers, et c. It is assumed that these communications and confirmations will be handled prim arily through telephone and e-mail.Draft Six-Year 2 ICR August 2006

Page 13 of 33 5 INFORMATION COLLECTED–AGENC Y ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA Headquarters will conduc t the following activi ties associated with the collection of regulated monitoring data:

• Data extraction or download data;

• Initial data screening/convers ion to uniform structures;

• Communication and coordination with States; and

• Manage and analyze the data, including

-- Quality assurance/quality co ntrol and review/edit data;

-- Data analysis and report of findings; and

-- Record keeping.

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

Data Extraction or Download

EPA's data extraction/downloading activities will depend to some degree 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 SDWIS/State will most closely reflect the data elements and format being requested. Data from States us ing 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 in formation from SDWIS/FED (adjusted using information from the 1999 Drinking Water Infrastr ucture Needs Survey, or other more recent supplemental information, as appropriate). 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 determin e 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 a horizontal structure, with ea ch analytical result o ccupying a discrete row accompanied by the system inventory and sample-specific data items. Data formatting work will be done using Microsoft ® Excel with the aid of specialized programs written in Visual Basic ®

.Draft Six-Year 2 ICR August 2006

Page 14 of 33 Communication and Coordination with States

Based on the Agency's experience with data submitted in response to CMR and Six-Year Review 1, EPA will need to communicate and coordi nate 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 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 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 th e Six-Year Review 2 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 that have been adjusted using information from the 1999 Drinking Water Infrastr ucture Needs Survey, or other more recent supplemental information, as appropriate. The nu mber of analytical r ecords 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.Draft Six-Year 2 ICR August 2006

Page 15 of 33 Data Analysis and Report of Findings: For the first Six-Year Review, EPA developed, peer reviewed, and used a data management and two-staged analytical approach to assess data representativeness and to analyze the compliance m onitoring data from 16 States. This approach

will also be used for the second Six-Year Revi ew. Data will be assessed and compiled into a

cross-section of State da ta sets indicative of national occurrenc e. The national cross-section data will be analyzed using a two-staged analytical approach. The "Stage 1" analysis provides simple, non-parametric estimates of the percen t of PWSs (and the tota l population served by those PWSs) with at least one analytical result exceeding specific threshold values. The "Stage 2" analysis uses more rigorous probabilistic mo deling to estimate the number of systems (and the corresponding affected populations) with estimate d mean contaminant concentrations above the levels of regulatory interest. A national contam inant occurrence report will then be prepared that describes the data management, national cross-s ection development, and the resulting national extrapolation of occurrence findi ngs from the national cross-section of the States' compliance monitoring data sets.

Record Keeping: EPA will store and track: the original (pre-QA/QC) data sets that it receives from States; final data sets used for the Six-Year Review 2 analyses ; and logs of all data QA/QC and editing conducted on th e original data sets. After final review, formatting, and analysis of the data collected th rough this ICR, the data will be made available to the public through the NCOD, as was done with the data collected and analy zed for the Six-Year Review 1.

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 contamin ants. Occurrence data provide information

critical to these assessments. The collection of the occurrence data, a nd the quantity, coverage, representativeness, and management of the data collected pursuant to this ICR is an important component of the planned Si x-Year Review 2 process.

EPA considered developing a nationally repr esentative 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 ag gregation of compliance monitoring data for all 79 regulated contaminants in an efficient or reasonable manner 3 . The potential problems associated with survey design are ex plained in more detail as follows:

• The significant within- and between-syste m 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 survey ed systems' data. Conversely, to design a single survey so that the i ndividual contaminant with the most variable occurrence data still meets minimum DQOs would require a surv ey that included tens of thousands of

systems.

3 The 79 regulated contaminants include: 69 chemical; 7 radiological; and 3 microbi ological contaminants. Radium-226 and - 228 are counted as one contaminant ( i.e. , as combined radium). A list of these contam inants is provided in Exhibit 4-1 in section 4(b)(i).Draft Six-Year 2 ICR August 2006

Page 16 of 33 • A survey would require data requests either directly from thousands of individual systems (requesting submission of 6 years of historic compliance monitoring data); or from States (to extract the system-level data for each of th e systems selected in the survey). Further, the Agency would expect an increased non-respon se rate if data were requested directly from systems.

• Based on the Agency's experience working with the 16 States that submitted complete compliance monitoring data sets for CMR or Si x-Year Review 1, 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 c ontaminants and across systems, and can be quarterly, annual, triennial, or every 9 years. Actual contaminant-specific sampling frequencies are unknown, and therefore, are di fficult to address in any survey design. (Different sampling frequencies are attributed to waiver prog rams and historical results showing contaminant occurrence (or lack of o ccurrence).)

An alternative to a single survey for a ll regulated contaminants would be multiple surveys for groups of related contaminants. Howe ver, the Agency anticipates that the burden for EPA, the States, and/or systems may be signi ficant 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). 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 1, EPA received data sets through electronic FTP, email, and mailed/shipped diskettes or other inform ation storage formats. For Six-Year Review 2, all States are being asked to submit their data th rough a secure FTP site. FTP is being specified

for several reasons: this information collection is potentially significantly larger in scale than the previous collections, during which no more than 8 States' data were received at a time; the FTP site to be used offers a high leve l of data security; and EPA anticipat es that most, if not all, States will have computer/internet resources which will a llow 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 SAS-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 will request that the data set structure is horizontal, with each analytical result occupying a discrete row accompanied by the system inventory and sample-s pecific data items listed above in 4(b)(i). EPA will also request that non-SDWIS/State user s 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 reduceDraft Six-Year 2 ICR August 2006

Page 17 of 33 the amount of time needed for questions and clar ification later. Stat es 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 (r egarding 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 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 drinking water agency qualifies as a small entity, as defined under the Regulatory Flexib ility Act (RFA), and summarized below. 4

• 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 dominant 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 regula tory flexibility analys is 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.

4 These definitions were take n from section 601 of the RFA.Draft Six-Year 2 ICR August 2006

Page 18 of 33 5(d) Collection Schedule

EPA is issuing this ICR as a one-time data request from the States for regulated monitoring data for 1998 - 2005. St ates will be responding to this request during 2007. Most of the data clean-up by EPA and follow-up with Stat es will occur during 2007. Data analysis is expected to continue through 2009, when EPA plans to make its final Six-Year 2 determinations.Draft Six-Year 2 ICR August 2006

Page 19 of 33 6 ESTIMATING THE BURDEN A ND COST OF THE COLLECTION

This section describes the estimated averag e annual burden and costs for the information

collection activities in support of Six-Year Review 2. 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 about the burden associ ated 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 (2007-2009). 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 pr ovided in Appendices A and B, respectively.

Estimates of State and EPA burden are influenced by State data management capabilities and likelihood to submit the requ ested 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, the ASDWA 2003 survey, as well as other direct knowledge of data capabilities and resources. To estimate burden, the Agency organized States into 3 categories of expected burden level, as follows:

Submit occurrence data using proprietary software - 21 States 5

. 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 follow up with EPA is expected to be the highest. EPA expect s that Agency burden, which is estimated primarily on a per State basis, wi ll be higher for these States.

Submit occurrence data using SDWIS/State software - 19 States. Those with 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 corres pond closely to those requested. Compilation and submission of their occurrence data, and fo llow up with EPA is also 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.

5 There are approximately 30 States th at currently use SDWIS/St ate for managing only their TCR data. For the majority of the regulated contaminant data being requested (76 of 79 contaminants), there are approximately 19 States using SDWIS/State for data storage and management, and 21 using a proprietary data system. For estimation purposes, EPA makes the conservative assumption that State burdens will vary with their primary data system (i.e., the 21 States using primarily a proprietary data system are assumed to incur more burden than if they were primarily using SDWIS/State). However, because TCR data are typically maintained in a separate database module from chemical data, additional burden has been allotted for extracting and downloading these data.Draft Six-Year 2 ICR August 2006

Page 20 of 33 Will not submit data - 16 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 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 2007-2009, EPA estimates a total av erage annual respondent burden of 681 hours

for activities associated with this reporting effort; or an average of 12.2 hours per State (681 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 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 with proprietary software is estimated at 7 hours; States with SDWIS/ State are estimated to spend 4 hours; and States th at will not submit data are estimated to spend 1

hour.

Compiling and Submitting Monitoring Data

State burden for this reporting activity is li kely 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. St ates with SDWIS State are estimated to spend 24 hours.

Follow-up with EPA

EPA expects that those States that use SDWIS/State or provid e their data in the requested format with an explanation of their codes, header s, 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 their own database system are estimated to spend 13 hours of follow-up time with

EPA. States with SDWIS/State are estim ated to only 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 2007-2009. Appendix A provides detailed cost and burden estimations for the information collectionDraft Six-Year 2 ICR August 2006

Page 21 of 33 activities covered by this ICR. Average annual labor costs for all States for this ICR period are estimated to be $30,608. 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 $547 for this da ta collection effort.

State labor costs are based on informa tion 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 2007 that are provided in the

model.

Exhibit 6-1: Average Annual State Burden and Costs (for ICR period of 2007-2009)

Burden Hours Labor Costs Number of States All States Per State All States Per State

56 681 12.2 $30,608 $547

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.

6(c)(i) Agency Burden

For the 3-year ICR period (2007-2009), EPA estimates that the av erage annual burden to the Agency will be 2,979 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 1 o ccurrence 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 c oordinate and download files to its database, including special consideration for security protocols, EPA estimates that it will need:Draft Six-Year 2 ICR August 2006

Page 22 of 33 • 11 hours per State for those 19 States that use SDWIS/State, and

• 17 hours per State for the 21 States that use databases other than 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 1, 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 19 St ates that use SDWIS/State; and

• 71 hours per State for the 21 States that use databases other than 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 database. EPA estimates that it will need:

• 6 hours per State for those 19 St ates that use SDWIS/State; and

• 11 hours per State for the 21 States that use databases other than SDWIS/State.

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 40 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 40 States (i.e., the number of States expected to participate), which equals 146.3 hours per State. However, because burden for the occurrence analyses will not vary greatly with the addition or

subtraction of State data sets , burden would not be reduced or increased by the full 146.3 hours

with each addition or subtraction of a State. Th is is because the analyses are conducted on a per contaminant basis, and the amount of data analyz ed in each does not greatly factor into the amount of time needed to run the analyses, a nd 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.Draft Six-Year 2 ICR August 2006

Page 23 of 33 6(c)(ii) Agency Cost

For the ICR period of 2007-2009, EPA's 2,979 an nual burden hours are associated with annual labor costs of $231,916 to collect and anal yze the occurrence data , and evaluate and report on the occurrence findings. Direct EPA per hour labor costs were derived using the Office of Personnel Management January 2006 GS Pay Sc hedule for government employees in the D.C. area. EPA used the GS-13 Step 5 salary of $87,664 per year, and by adding the standard government overhead factor of 1.6 (as well as a 3% inflation factor to account for 2007 salaries), the average hourly rate is estimated to be $69.46 per hour. Contracted labor costs are based on historical hourly costs pertaini ng to the management and analysis of occurrence data, which were approximately $79.57 per hour.

Exhibit 6-2: Annual EPA Burden and Costs (for ICR period of 2007-2009)

EPA Burden Per State Annual EPA 1

Activity (19 SDWIS States) (21 Non-SDWIS States) Burden Cost

Extract/download data 11.0 17.0 189 $14,742

Initial data

screenin g /conversion to

uniform structures 36.0 71.0 725 $57,552

Communicate, coordinate

with States 6.0 11.0 115 $9,015

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

analyze/report findings; record keeping 146.3 146.3 1,950 $150,607

Total 199 246 2,979 $231,916

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 hourly labor rates (EPA or Contractor, as appropriate). See Appendix B, Exhibit B-1, 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.Draft Six-Year 2 ICR August 2006

Page 24 of 33 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 who 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 2007-2009)

Total Avera g e Per Year over

2007-2009

Number of Respondents 56 States n/a

Total Responses 56 18.7

Number of Responses per State 1 0.3

Total State Burden Hours 2,044 681

Hours per Response (Total hours from above/Total responses from above) 36.5 12.2

State O&M Costs $0 $0

Total State Costs (Labor plus O&M costs) $91,825 $30,608

National Total of Hours (States plus Agency) 10,980 3,660

National Total of Costs (States plus Agency) $787,573 $262,524

6(f) Reasons for Change in Burden

Since this is an ICR for a one-time data co llection effort in support of this Six-Year Review process, this ICR does not modify an existing ICR.

6(g) Burden Statement

The reporting burden for data collections incl uded in this ICR is detailed above. The total annual respondent burden (for years 2007-2009) imposed by these collections is estimated to be 681 hours, or 12.2 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, and 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 2007 and 2008. Estimates include time for submitting data to EPA and addresses questions raised by the Agency regarding the submitted

information.Draft Six-Year 2 ICR August 2006

Page 25 of 33 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 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 displa ys 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 Number EPA-HQ-OW-2005-0019, whic h is available for online viewing at www.regulations.gov, or in person viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Consti tution Avenue, NW, Washington, D.C. 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 Water Docket is (202) 566-2426. An electronic version of the public docket is available at www.regulations.gov. Th is site can be used 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 electroni cally. When in the system, select "search," then key in the Docket ID Number identified above. Also, you can send

comments to the Office of Information and Re gulatory Affairs, Offi ce of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please

include the Docket ID Number EP A-HQ-OW-2005-0019 in any correspondence.Draft Six-Year 2 ICR August 2006

Page 26 of 33 

### APPENDICESDraft Six-Year 2 ICR August 2006

Page 27 of 33 Appendix A: Detailed Burden and Cost for States

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

Average Burden Per State Labor Costs

State Likely to

Submit

Data? Reading

EPA Request Compiling, Submitting

Data Follow-up

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/NonSS 7 44 13 64 s $39.38 $2,520

Alaska Likely/SS 4 24 8 36 m $42.42 $1,527

American

Samoa Unlikely 1 0 0 1 vs $40.02 $40

Arizona Unlikely 1 0 0 1 m $42.42 $42

Arkansas Unlikely 1 0 0 1 m $42.42 $42

California Likely/NonSS 7 44 13 64 vl $69.30 $4,435

Colorado Unlikely 1 0 0 1 m $42.42 $42

Connecticut Likely/SS 4 24 8 36 m $42.42 $1,527

Delaware Unlikely 1 0 0 1 vs $40.02 $40

District of

Columbia Unlikely 1 0 0 1 s $39.38 $39

Florida Likely/NonSS 7 44 13 64 l $49.02 $3,137
Georgia Likely/SS 4 24 8 36 m $42.42 $1,527

Guam Unlikely 1 0 0 1 vs $40.02 $40

Hawaii Unlikely 1 0 0 1 vs $40.02 $40

Idaho Likely/SS 4 24 8 36 m $42.42 $1,527

Illinois Likely/SS 4 24 8 36 l $49.02 $1,765

Indiana Likely/SS 4 24 8 36 m $42.42 $1,527

Iowa Likely/SS 4 24 8 36 m $42.42 $1,527

Kansas Likely/NonSS 7 44 13 64 m $42.42 $2,715

Kentucky (i) Likely/NonSS 7 44 13 64 s $39.38 $2,520

Louisiana Likely/SS 4 24 8 36 m $42.42 $1,527

Maine Likely/SS 4 24 8 36 s $39.38 $1,418
Maryland Unlikely 1 0 0 1 m $42.42 $42

Massachusetts Likely/NonSS 7 44 13 64 m $42.42 $2,715

Michigan (i) Likely/NonSS 7 44 13 64 l $49.02 $3,137

Minnesota Likely/NonSS 7 44 13 64 m $42.42 $2,715
Mississippi Unlikely 1 0 0 1 m $42.42 $42Draft Six-Year 2 ICR August 2006

Page 28 of 33 Exhibit A-1: Estimated State Bu rden for Occurrence Data Submission

Average Burden Per State Labor Costs

State Likely to

Submit

Data? Reading

EPA Request Compiling, Submitting

Data Follow-up

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)

Missouri Likely/SS 4 24 8 36 m $42.42 $1,527

Montana Likely/SS 4 24 8 36 m $42.42 $1,527

Nebraska Likely/SS 4 24 8 36 s $39.38 $1,418

Nevada Likely/SS 4 24 8 36 s $39.38 $1,418

New Hampshire Unlikely 1 0 0 1 m $42.42 $42

New Jersey (i) Likely/NonSS 7 44 13 64 m $42.42 $2,715

New Mexico Likely/NonSS 7 44 13 64 s $39.38 $2,520

New York Likely/SS 4 24 8 36 l $49.02 $1,765

North Carolina (i) Likely/NonSS 7 44 13 64 l $49.02 $3,137

North Dakota Likely/SS 4 24 8 36 vs $40.02 $1,441

Northern

Mariana Islands Unlikely 1 0 0 1 vs $40.02 $40

Ohio Likely/NonSS 7 44 13 64 l $49.02 $3,137

Oklahoma Likely/SS 4 24 8 36 m $42.42 $1,527
Oregon Likely/SS 4 24 8 36 m $42.42 $1,527

Pennsylvania Likely/NonSS 7 44 13 64 l $49.02 $3,137

Puerto Rico Unlikely 1 0 0 1 s $39.38 $39

Rhode Island (i) Likely/NonSS 7 44 13 64 vs $40.02 $2,561

South Carolina Likely/NonSS 7 44 13 64 m $42.42 $2,715

South Dakota Likely/NonSS 7 44 13 64 s $39.38 $2,520

Tennessee (i) Likely/NonSS 7 44 13 64 m $42.42 $2,715

Texas Likely/NonSS 7 44 13 64 vl $69.30 $4,435

Utah Unlikely 1 0 0 1 s $39.38 $39

Vermont (i) Likely/NonSS 7 44 13 64 s $39.38 $2,520

Virginia (i) Likely/NonSS 7 44 13 64 l $49.02 $3,137
Virgin Islands Unlikely 1 0 0 1 vs $40.02 $40
Washington Unlikely 1 0 0 1 l $49.02 $49
West Virginia Likely/SS 4 24 8 36 s $39.38 $1,418Draft Six-Year 2 ICR August 2006

Page 29 of 33 Exhibit A-1: Estimated State Bu rden for Occurrence Data Submission

Average Burden Per State Labor Costs

State Likely to

Submit

Data? Reading

EPA Request Compiling, Submitting

Data Follow-up

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)

Wisconsin Likely/NonSS 7 44 13 64 l $49.02 $3,137
Wyoming Likely/SS 4 24 8 36 vs $40.02 $1,441

TOTAL 239 1,380 425 2,044 $91,825

Annual Ave. 2007-2009 681.3 $30,608

Annual Ave. Per State 2007-2009 12.2 $547

(a) States divided into three major groups: likely to provide data (indicated by "Likely/SS" (19 States) or "Likely/Non-SS" (21 States)); and those that are unlikely to provide data (indi cated by "Unlikely" (16 States)). Likely/SS (SDWIS/State) means State stores all or most of data using SDWIS/State. Likely/Non-SS means State provided data to EPA for the first Six-Year Review and had a strong record of electronic reporting, but does not use SDWIS/State (or only used it for LCR 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 differe nt sized State programs (very small, sm all, 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.

(i) These are States that use SDWIS/State for TCR only ( no chemical data stored/manag ed within SDWIS/State as of March 2006). For estimation purposes, EPA makes the conservative assumption that State burdens will vary with their primary data system (i.e., the 21 States using primar ily a proprietary data system are assumed to incur more burden than if they were primarily us ing SDWIS/State). However, because T CR data are typically maintained in a separate database module from chemical data, additional burden has been allotted fo r extracting and downloading

these data.Dra ft Six-Year 2 ICR August 2006

Page 30 of 33 Exhibit A-2: 2007 Salaries and Overhead Costs from ASDWA State Resource Model

Professional

Staff Support

Staff State Size (a) (adjusted for fringe benefits at 22% of base salary) Hourly Ave. ~

80% Prof and 20% Support Hourly Rate (adjusted for

overhead at 23%)

Very Small (applies to 9 States, including VI, GU, AS, NM) $62,720 $41,960 $32.54 $40.02

Small (applies to 12 States, including DC and PR) $62,917 $36,470 $32.02 $39.38

Medium (applies to 23 total) $67,274 $41,297 $34.49 $42.42

Large (applies to 10 total) $75,950 $54,897 $39.86 $49.02

Very Large (applies to 2 total) $111,800 $59,908 $56.35 $69.30

(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 2007 that are provided in the m odel. The model assumes 1,800 work hours per full-time equivalent employee. Hourly rate labo r costs are adjusted to account for fringe benefits (i.e., holidays, sick days, vacation, pension, health, de ntal, and life insurance); and overhead (i.e., office space, furniture, utilities, copiers, fax machines, postage, basic computing needs, etc.).Draft Six-Year 2 ICRApril 2006Page 31 of 33Appendix B: Detailed Burden and Cost for EPAExhibit B-1: Estimated Burden and Labor Costs toEPA for Occurrence Data Collection and AnalysisSDWIS andNon-SDWISStatesContractor BurdenContractor Labor CostActivityEst. # 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)Data Extractionor Download (r)1921915171315486$79.57$13,606$25,064$38,670Initial datascreening/conversion to uniformstructures192135706651,4702,135$79.57$52,912$116,964$169,877Communicationandcoordinationwith the States192151095210305$79.57$7,559$16,709$24,268DataManagementand Analysis:QA/QC;review/edit data;analyze/reportfindings;record keeping1921112.5112.52,1382,3634,500$79.57$170,076$187,978$358,054TOTAL1921161.5207.53,0694,3587,426$79.57$244,153$346,715$590,868Draft Six-Year 2 ICRApril 2006Page 32 of 33Exhibit B-1: Estimated Burden and Labor Costs to EPAfor Occurrence Data Collection and Analysis (continued)EPA BurdenEPA Labor CostEPA and Contractor TotalsActivityEst.EPAHoursperSDWISStateEst.EPAHoursforNonSDWISStatesEst.TotalEPAHoursforSDWISStatesEst.TotalEPAHoursforNonSDWISStatesEst.TotalEPAHoursfor AllStatesCostperHourforEPAStaffEst. TotalEPALaborCost forSDWISStatesEst. TotalEPALaborCost forNonSDWISStatesEst. TotalEPA LaborCost for AllStatesEst.TotalEPAandContractorBurdenPerSDWISStateEst.TotalEPAandContractorBurdenPerNonSDWISStateEst. TotalEPA andContractorBurdenfor AllStatesEst. TotalEPA andContractorLabor Costfor All 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)Data Extractionor Download (r)22384280$69.46$2,639$2,917$5,55711.017.0566$44,226Initial datascreening/conversion to uniformstructures11192140$69.46$1,320$1,459$2,77836.071.02,175$172,655Communicationand coordinationwith the States11192140$69.46$1,320$1,459$2,7786.011.0345$27,046DataManagement andAnalysis:QA/QC;review/edit data;analyze/reportfindings;record keeping33.833.86417091,350$69.46$44,539$49,228$93,767146.3146.35,850$451,821TOTAL37.837.87177931,510$69.46$49,818$55,062$104,8801992458,936$695,748Annual Ave. 2007-20092,979$231,916Draft Six-Year 2 ICRApril 2006Page 33 of 33(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. Toshow this on a per State basis, as all other activities are shown,this 4,500 hours (100 hours x 45 contaminants) is divided by40 States (i.e., the maximum numberof States expected to participate), which equals 112.5 hours per State. Similarly, 30 EPA hours for each of the 45 contaminants is shown as 33.8 hours per State.Thus, total estimated burden per State for this activity is 146.3.However, burden for the occurrence analyses will not vary greatly with the addition or subtractionof State data sets; and burden would not be reduced or increased by the full 146.3 hours with each addition or subtraction of aState. The other 3 listed aspects ofEPA burden (data download, screening, and communication) will vary directly on a per State basis. Because these 3 other burdenitems are collectively smaller (at49/State for SDWIS/States, and 93/State for Non-SDWIS/State) thanthe data analysis burden, the "per State" burden will increase as the number of participatingStates decreases.(h) Contractor costs are based on historical hourly costs pertaining to the management and analysis of occurrence data, which were approximately $79.57 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 Maryland/District of Columbia rate schedule during the firstquarter of 2006 (see the U.S. Office of Personnel Management website: www.opm.gov). Withthese assumptions, labor and contractor rates were based on a 2,080 hour work year, with a $87,664 annual salary during 2006 (most current available) plus a 3%inflation factor for 2007 salaries, and 60 percent overhead, or $69.46 per hour.(r) There are approximately 30 States that currently use SDWIS/State for managing only their TCR data. For the majority of theregulated contaminant data beingrequested (76 of 79 contaminants), there are approximately 19 States using SDWIS/State for data storage and management, and 21using a proprietary data system.For estimation purposes, EPA makes the conservative assumption thatState burdens will vary with their primary data system (i.e., the 21 States using primarily aproprietary data system are assumed to incur more burden than if they were primarily using SDWIS/State). However, because TCRdata are typically maintainedin a separate database module from chemical data, additionalburden has been allotted for extracting and downloading these data.