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- 1 Appendix B: The National UIC Database

EPA Headquarters develop ed the National UIC Database, a well

- centric database t hat collect s and store s state 1 and regional direct implementation ( DI ) program data to support UIC
p rogrammatic data needs. The UIC sys tem contains approximately 120 data elements related to various aspects of the UIC P rogram (e.g., permit information and enforcement and compliance data). The database include s a tool to electronically transfer data between existing state databases and th e National UIC Database

, a tool to generate standard reports, and a tool to support data quality assurance/ quality control ( QA/QC ) reviews

.
Headquarters deploy ed the National UIC Database in December 2007. As of July 201 4

, 1 4 programs have transitioned t o e

- reporting

. For burden estimation purposes, 15 programs are expected to transition to e

- reporting in 2015

, 10 programs are expected to transition in 2016 , and 1 1 program s are expected to transition in 2017

.
To assist with funding challenges

, EPA’s Ex change Network (EN) Grants can be used to establish a data flow. Grant funds provide additional benefits to states for their own internal data management by allowing them to complete other related activities, such as building a state database or establish i ng an electronic data flow from owners or operators. Twenty

- five UIC
programs have already received funds to support activities to populate the National UIC Database

. The EN Grant program provides funding, technical support, and tools to support these acti vities ; p rograms have used funds to create a program database, improve the quality of source data, integrate state and federal data, and prepare internal system s to allow electronic data submission.

While the UIC regulations do not mandate the format in w hich the data must be submitted

, historically

, programs have provided information in paper format using the UIC program’s 7520 reporting forms

. States that transition to e

- reporting are no longer required to submit the paper 7520 forms or complete web

- base d inventory and Program Activity M easures (PAM s ) reporting ; this eliminat e s the current burden associated with gathering and compiling data

, completing the 7520 forms , and maintaining paper records

. Although t here is still burden associated with e

reportin g, after establishing the data flow

, the burden is less than that for paper based reporting. EPA developed tools to replicate the paper reports to ensure consistency in program management after transition to e

- reporting

. P rograms have also reported data qu ality improvements as a result of the data flow process. The improvement in data quality may result in more efficient program management by both the states and EPA.

This Appendix describes the status of UIC data management by primacy states and DI progra ms and the burden and cost associated with data transfer.

B1

. Burden a nd Cost Associated With Data Transfer

State UIC programs will incur burden and cost s associated with the necessary start

- up activities to prepare their databases and prepare data for transfer to Headquarters . A ctivities associated

1 The term state includes states, tribes, and terri tories.Underground Injection Control Program

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with data entry and semi

- annual data transfers to Headquarters represent ongoing burden

. EPA support s program s with funding thr ough the EN grant s , by providing technical assistance and training, and by creati ng individualized tools for programs to flow data.

Burden associated with s tart

- up activities

Prior to initiating data transfer, state s must prepare UIC program applications and data to flow data to the National UIC Database

. The e ffort and associated cost will vary depending on the
stat us of the program’s database.

Programs with Existing UIC D atabases

S tart

- up costs include the costs associated with developing the data to transfer to the National UIC Database and setting up the data flow process

. A ctivities include a dding new data fields and new data tables (if needed) to align the state’s UIC data to the national data model , cleaning up existing data, and in some cases, inputting historic data from records available in hard co py only

. On average, the total “data development” cost to these programs is about 310 hou rs . A nnualizing the effort over an estimated 6

- year phase

- in schedule , this equals 51.6 hours per program , annually. Note that much of this is contractor labor, w hich is presented as non

- labor costs in the UIC Programmatic ICR.

Programs must also set up the data flow infrastructure. This includes the following activities:

 Data mapping and data set generation

, includ ing m ap ping data from the state database
struct ure to the National UIC Database structure and generat ing data set s with valid records

,

 Convert to Extensible Markup Language ( XML )

, 2 and

 Data f low via a National Environmental Exchange Network (NEIEN) Node in volves

s et ting up/test ing automatic data su bmission and transfer to EPA’s Central Data Exchange ( CDX )

.

Th e total data flow burden is estimated to be 21 0 hours per program . Annualized over 6 years, this equates to 3 5 hours ( in state and contractor labor) per year per program

.
Programs with Lit tle or no Electronic Data

States with little or no electronic data are assumed to require a less intensive effort than for those
programs that already have a database as described above because there is less complexity in their data management needs

. EPA estimates the start

- up burden to these programs is 250 hours/
program (state and contractor labor), or 41.6 hours per year, annualized over 6 years

.

Cost associated with start

- up activities

2 Extensible Markup Language ( XML ) is a set of rules for encoding documents in machine

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Start

- up non

- labor costs include contractor support and one

- ti me hardware costs to set up a state NEIEN N ode

. EPA developed a Node Client that programs without a data node can use to submit UIC data. States may choose to develop a n NEIEN N ode to serve all state programs but it is no longer a cost they must incur to submit data to the National UIC Database

.

EPA assumes that most start

- up activities (estimated at 80 percent of the burden cited above), will be performed by contractors at an estimated labor rate of $ 91.58 hour. In addition, each UIC program will incur $7,000 ($1,167/year, annualized over 6 years) for costs associated with the development and maintenance of a state NEIEN Node to support the UIC data flow

.
Ongoing activities

Annual activities include the incremental data entry burden for those program s that currently do not enter UIC data into a state database. ( Programs that have a database are already incurring a data entry burden ; thus, th e ICR assume s no additional paperwork burden for these programs as a result of the new database .) The annual d ata entry burden is estimated to be 4 0 hours. Note that

some programs have developed software that allow inspection data gathered in the field to be directly uploaded into their program database

, further reducing data entry burden. Other
programs have also establish ed web

- based permitting and inventory data entry applications that flow data to their program database further reducing burden.

All programs will submit their data to the National UIC Database through CDX and respond to QA and data validation i ssues. EPA estimates these tasks will require 4 hours per semi

- annual submission

, or 8 hours per year , per program

.

B2

. Burden Reduction and Cost Savings

Over the long run, the National UIC Database will reduce the programs’ reporting burden. Following transfer to e

- reporting

, programs will no longer need to complete the 7520 forms and report on inventory and PAMs . This eliminate s the current burden associated with gathering and compiling UIC data

, c ompleting the reporting forms , and maintaining records

.

A s described above, programs will need to make a time and hardware investment to develop the automated data transfer process. However, w hen the data transfer is complete, the current annual burden associated with completing the 7520 forms and reporting inventory and PAMs data will be replaced with a lower burden associated with placing data on the state NEIEN Node to flow it to Headquarters and provid ing QA to assure data accuracy, as described below:

 Under a paper

- based system, programs would collecti vely incur over $ 625,000 annually in reporting and recordkeeping cost s ; this equals about $1 0

, 800 annually per state.

 Between 201 5 and 201 7

, programs will collectively incur $ 1, 49 7, 20 9 in start

- up costs to convert from paper

- based to electronic reportin g

. This equates to an average of $4 9

, 38 2 in labor and hardware costs for each program that currently has a database, and $2 7

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 When their initial data transfer is complete, programs will incur lower annual costs: an estim ated average annual cost over the ICR clearance period of about $ 80,860 for all
programs collectively to enter data and transfer it to Headquarters semi

- annually

. Note that this unit burden is lower in this ICR, based on the results of a survey of e

- report ing programs by Headquarters and a reduction in the frequency of data transfers

.

Table B

- 1 presents the annual and cumulative costs to programs under paper based and electronic reporting system s

. When the initial data population and transfer are complete

, programs will collectively save over $ 5 00,000 annually.

Table B

- 1 : Comparison of Costs

– Paper

- B ased Reporting vs. Electronic Reporting
Paper

- Based Reporting Electronic Reporting

Year Annual cost Cumulative cost Annual cost * Cumulative cost
2015 $625,875 $3,755,251 $690,406 $1,458,480

2016 $625,875 $4,381,127 $485,374 $1,943,854

2017 $625,875 $5,007,002 $564,008 $2,507,862

2018 $625,875 $5,632,877 $345,631 $2,853,494

2019 $625,875 $6,258,752 $115,324 $2,968,818

2020 $625,875 $6,884, 627 $115,324 $3,084,143

2021 $625,875 $7,510,503 $115,324 $3,199,467

2022 $625,875 $8,136,378 $115,324 $3,314,791

2023 $625,875 $8,762,253 $115,324 $3,430,116

2024 $625,875 $9,388,128 $115,324 $3,545,440

2025 $625,875 $10,014,003 $115,324 $ 3,660,765

2026 $625,875 $10,639,879 $115,324 $3,776,089

* Includes the cost for new programs transitioning to e

- reporting plus ongoing costs (e.g., for data entry and QA/QA) following transfer.