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, 2nd Floor 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 
Draft 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–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 ....................................................................................... 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..................................................................... 31 
Draft Six-Year 2 ICR August 2006

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LIST OF EXHIBITS

Exhibit 4-1: Regulated Contaminant 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 Occurrence Data Collection and 

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

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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 Industry 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 Rule 
Draft 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 National 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 amended in 1996, requires that the U.S. EPA 

review existing National Primary Drinking Water Regulations (NPDWRs) no less often than 

every six years. This cyclical evaluation is referred to as the "Six-Year 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-Year 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 conducted 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 Request (ICR) as a one-time request for States 

to submit historical regulated monitoring data on a voluntary basis to EPA during the 2007 and 

2008 timeframe. 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 2007-2009. 

EPA's Office of Water is requesting that States1

 submit compliance monitoring data for 

community water systems (CWSs) and non-transient non-community water systems 

(NTNCWSs). EPA is requesting contaminant occurrence data from 1998 to 2005 for all 

regulated chemical and radiological contaminants, as well as data from the TCR. EPA 

anticipates that the compliance monitoring records from this information collection (including all 

results for analytical detections and non-detections) 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 "State" or "States" are used to refer 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 regulated contaminants to maintain the NCOD. 

 States can submit 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 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 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 681 hours and $30,608 per year over the 3-year ICR period of 2007-

2009, or 12.2 hours and $547 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., 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 2007-2009, EPA is expected 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 conversion to uniform structures; communicating and 

coordinating with States; and data management and analysis. 
Draft Six-Year 2 ICR August 2006

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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 and assesses risks to human 

health posed by regulated drinking water contaminants. 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." Occurrence 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. With this occurrence data, national statistical 

estimates for occurrence of each regulated contaminant can be conducted. 

 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 was being 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 collected 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 compliance monitoring (contaminant occurrence) 

data from States for all regulated chemical contaminants 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 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 

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 Chemical Monitoring Reform EPA project work conducted in 1997 

and 1998. Additional compliance monitoring data were submitted 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 Cross-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 contaminant-specific analyses conducted as part of the Six-Year Review 

(e.g., health assessment), will provide EPA with information to determine whether or not there is 

a need to revise a regulation to maintain or provide for greater protection 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 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. 
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 associated with this ICR 

are not duplicated. EPA has consulted with ASDWA 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 included 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 result. 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 based on the Federal public water system identification (PWSID) 

number. 

 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. 

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

 Following public notice of the proposed data 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 Water Administrators (ASDWA) submitted comments addressing 

concerns that States may have related to the data collection. In summary, the comments from the 

organization, and EPA responses are as follows: 

• The commenter does not support mandatory reporting of occurrence data (beyond 

the current Lead and Copper Rule requirements) due to limited State resources. 

The commenter believes that data collection 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 every 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 download the occurrence 

data. In addition, the commenter recommends that EPA accept data in each 

State's existing format with EPA then undertaking whatever data conversion, edit 

checks, and transfer tasks that may be necessary 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 suitable 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 context, and that use of the occurrence data 

for purposes other than those for which the data were intended would be 

inappropriate, and would tend to discourage participation. EPA agrees with the 

commenter and plans to use the data 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 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). 

 In 2003, ASDWA conducted a survey of States about their abilities and interest in 

submitting occurrence data. ASDWA received responses from 32 States. This information 

helped EPA to gauge which States would be more likely to participate in this data collection. In 

preparing for Six-Year Review 2, EPA consulted with ASDWA regarding the collection and 

analysis of States' drinking water data. Specifically, 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 collected on a one-time basis for this Six-Year 

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

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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 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. 
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 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 (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 requested data include analytical detections and nondetections for routine compliance monitoring samples (including repeat and confirmation 

samples), 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 17 data elements (see Exhibit 4-2) that the Agency will request that States provide 

with their sample results. In general, these data elements are based on those used for the 

Unregulated Contaminant Monitoring Regulation and the first Six-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 "as 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 effectively evaluate the occurrence data. If States elect 

to submit their data with only these data elements, EPA will use the PWSID number to acquire 
Draft Six-Year 2 ICR August 2006

Page 9 of 33 

additional system inventory data from SDWIS/FED (adjusted using information from the 1999 

Drinking Water Infrastructure Needs Survey). 

Exhibit 4-1: Regulated Contaminant 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 Gross beta Tritium

Radium-226 & Radium-228 (if 

available)

Iodine-131

Gross alpha Strontium-90

Uranium

Microbiological Contaminants 

Total coliforms Fecal coliforms Escherichia 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 effectively 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 from 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 effectively 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 results reported (usually expressed in either Φg/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 collection are assumed to include the drinking 

water agencies for the 56 State and territories 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 
Draft 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 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 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 needed data formats and elements, 

and thus are assumed to have less burden for submissions 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 conservative (highest possible cost) assumption. 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 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 its experience with occurrence information provided by States for the CMR and 

Six-Year Review 1, 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 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. 
Draft Six-Year 2 ICR August 2006

Page 13 of 33 

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: 

• Data extraction or download data; 

• Initial data screening/conversion to uniform structures; 

• Communication and coordination with States; and 

• Manage and analyze the data, 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. 

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 level 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 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 (adjusted using 

information from the 1999 Drinking Water Infrastructure 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 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 a horizontal structure, with each analytical result occupying 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 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 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 2 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 that have been adjusted using 

information from the 1999 Drinking Water Infrastructure Needs Survey, or other more recent 

supplemental information, as appropriate. 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. 
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 monitoring data from 16 States. This approach 

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

cross-section of State data sets indicative of national occurrence. 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 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 uses more rigorous probabilistic modeling to estimate the number of systems (and the 

corresponding affected populations) with estimated mean contaminant concentrations above the 

levels of regulatory interest. A national contaminant occurrence report will then be prepared that 

describes the data management, national cross-section development, and the resulting national 

extrapolation of occurrence findings 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 the original data sets. After final review, formatting, and 

analysis of the data collected through this ICR, the data will be made available to the public 

through the NCOD, as was done with the data collected and analyzed 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 contaminants. Occurrence data provide information 

critical to these assessments. The collection of the occurrence data, and the quantity, coverage, 

representativeness, and management of the data collected pursuant to this ICR is an important 

component of the planned Six-Year Review 2 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 for all 

79 regulated contaminants in an efficient or reasonable manner3. The potential problems 

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

 • 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. 

3

 The 79 regulated contaminants include: 69 chemical; 7 radiological; and 3 microbiological contaminants. Radium-226 and -

228 are counted as one contaminant (i.e., as combined radium). A list of these contaminants 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 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 16 States that submitted complete 

compliance monitoring data sets for CMR or Six-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 contaminants and across systems, and can be 

quarterly, annual, triennial, or every 9 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 regulated contaminants would be multiple 

surveys for groups of related contaminants. 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). 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 information storage formats. For Six-Year Review 2, 

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, during which no more than 8 States' data were received at a time; 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 SAS-compatible file formats: Dbase (.dbf); Access tables 

(.mdb); comma or tab delimited files (such as .csv or .txt), or; Excel (.xls). 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-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 
Draft Six-Year 2 ICR August 2006

Page 17 of 33 

 

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.4

• 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. 

4

 These definitions were taken 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. States will be responding to this request during 2007. Most of 

the data clean-up by EPA and follow-up with States 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 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 2. 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 (2007-2009). 

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 likelihood to submit 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, 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 States5

. 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 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 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 correspond closely to those requested. Compilation 

and submission of their occurrence data, and follow 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 that currently use SDWIS/State 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 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 2007-2009, EPA estimates a total average 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 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 with proprietary software is estimated at 7 hours; States with SDWIS/ 

State are estimated to spend 4 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. States with SDWIS State are estimated to spend 24 hours. 

Follow-up with EPA

 EPA expects that those States that 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 their own database system are estimated to spend 13 hours of follow-up time with 

EPA. States with SDWIS/State are estimated 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 collection 
Draft 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 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 $547 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 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 collection 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 average annual burden to 

the Agency will be 2,979 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 1 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: 
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 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 19 States 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 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 19 States 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 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 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. 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. 
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 annual burden hours are associated with 

annual labor costs of $231,916 to collect and analyze 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 Schedule 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 pertaining 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 EPA1

Activity (19 SDWIS 

States)

(21 Non-SDWIS 

States) Burden Cost

Extract/download data 11.0 17.0 189 $14,742

Initial data 

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

includes the burden and costs to the 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 Average 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 collection 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 included 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 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 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, 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 Number EPA-HQ-OW-2005-0019, which 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 Constitution 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. This 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 electronically. 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 Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

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

Page 26 of 33 

APPENDICES
Draft Six-Year 2 ICR August 2006

Page 27 of 33 

Appendix A: Detailed Burden and Cost for States 

Exhibit A-1: Estimated State Burden 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 $42
Draft Six-Year 2 ICR August 2006

Page 28 of 33 

Exhibit A-1: Estimated State Burden 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 $1,418
Draft Six-Year 2 ICR August 2006

Page 29 of 33 

Exhibit A-1: Estimated State Burden 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 (indicated 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 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. 

(i) These are States that use SDWIS/State for TCR only (no chemical data stored/managed 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 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 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 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 2007 that are provided in the model. 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 2 ICR 

Page 31 of 33 

Appendix B: Detailed Burden and Cost for EPA 

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

SDWIS and 

Non-SDWIS 

States 

Contractor Burden Contractor 

Activity 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 

Contract

ual 

Labor 

Est. Total 

Contractor 

Labor Cost for SDWIS 

States 

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

Data Extraction 

or Download (r) 19 21 9 15 171 315 486 $79.57 $13,606 

Initial data 

screening/conver

sion to uniform 

structures 19 21 35 70 665 1,470 2,135 $79.57 $52,912 

Communication 

and 

coordination 

with the States 19 21 5 10 95 210 305 $79.57 $7,559 

Data 

Management 

and Analysis:

QA/QC; 

review/edit data; 

analyze/report 

findings; 

record keeping 19 21 112.5 112.5 2,138 2,363 4,500 $79.57 $170,076 

TOTAL 19 21 161.5 207.5 3,069 4,358 7,426 $79.57 $244,153 
Draft Six-Year 2 ICR 

Page 32 of 33 

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

EPA Burden EPA Labor Cost EPA and 

Activity 

Est. 

EPA 

Hours 

per 

SDWI

S 

State 

Est. 

EPA 

Hours 

for 

NonSDWI

S 

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 

Contra

ctor 

Burden 

Per 

SDWIS 

State 

Est. 

Total 

EPA 

and 

Contra

ctor 

Burden 

Per 

NonSDWIS 

State 

(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) 

Data Extraction 

or Download (r) 2 2 38 42 80 $69.46 $2,639 $2,917 $5,557 11.0 17.0 

Initial data 

screening/convers

ion to uniform 

structures 1 1 19 21 40 $69.46 $1,320 $1,459 $2,778 36.0 71.0 

Communication 

and coordination 

with the States 1 1 19 21 40 $69.46 $1,320 $1,459 $2,778 6.0 11.0 

Data 

Management and 

Analysis: QA/QC; 

review/edit data; 

analyze/report 

findings; 

record keeping 33.8 33.8 641 709 1,350 $69.46 $44,539 $49,228 $93,767 146.3 146.3 

TOTAL 37.8 37.8 717 793 1,510 $69.46 $49,818 $55,062 $104,880 199 245 

 Annual Ave. 2007-2009 
Draft Six-Year 2 ICR 

Page 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 occshow this on a per State basis, as all other activities are shown, this 4,500 hours (100 hours x 45 contaminants) is divided by 40 States (of States expected to participate), which equals 112.5 hours per State. Similarly, 30 EPA hours for each of the 45 contaminants is showThus, total estimated burden per State for this activity is 146.3. However, burden for the occurrence analyses will not vary greatly with 

of State data sets; and burden would not be reduced or increased by the full 146.3 hours with each addition or subtraction of a State. ThEPA burden (data download, screening, and communication) will vary directly on a per State basis. Because these 3 other burden item49/State for SDWIS/States, and 93/State for Non-SDWIS/State) than the data analysis burden, the "per State" burden will increase as thStates 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 Maryland/District of Columbia rate schedule during the first quarter of 2006 (see the U.S. Office of Personnel Management websitethese assumptions, labor and contractor rates were based on a 2,080 hour work year, with a $87,664 annual salary during 2006 (most cuinflation 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 the regula

requested (76 of 79 contaminants), there are approximately 19 States using SDWIS/State for data storage and management, and 21 usinFor estimation purposes, EPA makes the conservative assumption that State burdens will vary with their primary data system (i.e., the 2proprietary data system are assumed to incur more burden than if they were primarily using SDWIS/State). However, because TCR da

in a separate database module from chemical data, additional burden has been allotted for extracting and downloading these data.