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

TABLE OF CONTENTS

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc142886371"  1
IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc142886371 \h 
1  

  HYPERLINK \l "_Toc142886372"  1(a)	Title and Number of the Information
Collection	  PAGEREF _Toc142886372 \h  1  

  HYPERLINK \l "_Toc142886373"  1(b)	Short Characterization	  PAGEREF
_Toc142886373 \h  1  

  HYPERLINK \l "_Toc142886374"  2	NEED FOR AND USE OF THE COLLECTION	 
PAGEREF _Toc142886374 \h  3  

  HYPERLINK \l "_Toc142886375"  2(a)	Need/Authority for the Collection	 
PAGEREF _Toc142886375 \h  3  

  HYPERLINK \l "_Toc142886376"  2(b)	Practical Utility/Users of the Data
  PAGEREF _Toc142886376 \h  3  

  HYPERLINK \l "_Toc142886377"  3	NON-DUPLICATION, CONSULTATIONS AND
OTHER COLLECTION CRITERIA	  PAGEREF _Toc142886377 \h  5  

  HYPERLINK \l "_Toc142886378"  3(a)	Non-duplication	  PAGEREF
_Toc142886378 \h  5  

  HYPERLINK \l "_Toc142886379"  3(b)	Public Notice Required Prior to ICR
Submission to OMB	  PAGEREF _Toc142886379 \h  5  

  HYPERLINK \l "_Toc142886380"  3(c)	Consultations	  PAGEREF
_Toc142886380 \h  6  

  HYPERLINK \l "_Toc142886381"  3(d)	Effects of Less Frequent Collection
  PAGEREF _Toc142886381 \h  6  

  HYPERLINK \l "_Toc142886382"  3(e)	General Guidelines	  PAGEREF
_Toc142886382 \h  7  

  HYPERLINK \l "_Toc142886383"  3(f)	Confidentiality	  PAGEREF
_Toc142886383 \h  7  

  HYPERLINK \l "_Toc142886384"  3(g)	Sensitive Questions	  PAGEREF
_Toc142886384 \h  7  

  HYPERLINK \l "_Toc142886385"  4	RESPONDENTS AND THE INFORMATION	 
PAGEREF _Toc142886385 \h  8  

  HYPERLINK \l "_Toc142886386"  4(a)	Respondents and NAICS/SIC Codes	 
PAGEREF _Toc142886386 \h  8  

  HYPERLINK \l "_Toc142886387"  4(b)	Information Requested	  PAGEREF
_Toc142886387 \h  8  

  HYPERLINK \l "_Toc142886388"  4(b)(i)	Data Items	  PAGEREF
_Toc142886388 \h  8  

  HYPERLINK \l "_Toc142886389"  4(b)(ii) Respondent Activities	  PAGEREF
_Toc142886389 \h  11  

  HYPERLINK \l "_Toc142886390"  5	INFORMATION COLLECTED–AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF
_Toc142886390 \h  13  

  HYPERLINK \l "_Toc142886391"  5(a)	Agency Activities	  PAGEREF
_Toc142886391 \h  13  

  HYPERLINK \l "_Toc142886392"  5(b)	Collection Methodology and
Management	  PAGEREF _Toc142886392 \h  15  

  HYPERLINK \l "_Toc142886393"  5(c)	Small Entity Flexibility	  PAGEREF
_Toc142886393 \h  17  

  HYPERLINK \l "_Toc142886394"  5(d)	Collection Schedule	  PAGEREF
_Toc142886394 \h  18  

  HYPERLINK \l "_Toc142886395"  6	ESTIMATING THE BURDEN AND COST OF THE
COLLECTION	  PAGEREF _Toc142886395 \h  19  

  HYPERLINK \l "_Toc142886396"  6(a)	Estimating Respondent Burden	 
PAGEREF _Toc142886396 \h  20  

  HYPERLINK \l "_Toc142886397"  6(b)	Estimating Respondent Costs	 
PAGEREF _Toc142886397 \h  20  

  HYPERLINK \l "_Toc142886398"  6(c)	Estimating Agency Burden and Costs	
 PAGEREF _Toc142886398 \h  21  

  HYPERLINK \l "_Toc142886399"  6(c)(i)	Agency Burden	  PAGEREF
_Toc142886399 \h  21  

  HYPERLINK \l "_Toc142886400"  6(c)(ii)	Agency Cost	  PAGEREF
_Toc142886400 \h  23  

  HYPERLINK \l "_Toc142886401"  6(d)	Estimating the Respondent Universe
and Total Burden and Costs	  PAGEREF _Toc142886401 \h  23  

  HYPERLINK \l "_Toc142886402"  6(e)	Bottom Line Burden Hours and Cost
Tables	  PAGEREF _Toc142886402 \h  24  

  HYPERLINK \l "_Toc142886403"  6(f)	Reasons for Change in Burden	 
PAGEREF _Toc142886403 \h  24  

  HYPERLINK \l "_Toc142886404"  6(g)	Burden Statement	  PAGEREF
_Toc142886404 \h  24  

  HYPERLINK \l "_Toc142886405"  APPENDICES	  PAGEREF _Toc142886405 \h 
26  

  HYPERLINK \l "_Toc142886406"  Appendix A:  Detailed Burden and Cost
for States	  PAGEREF _Toc142886406 \h  27  

  HYPERLINK \l "_Toc142886407"  Appendix B:  Detailed Burden and Cost
for EPA	  PAGEREF _Toc142886407 \h  31  

 

LIST OF EXHIBITS

  TOC \h \z \t "Style Caption + Centered" \c    HYPERLINK \l
"_Toc142886408"  Exhibit 4-1:  Regulated Contaminant Occurrence Data to
Be Requested	  PAGEREF _Toc142886408 \h  9  

  HYPERLINK \l "_Toc142886409"  Exhibit 4-2:  Requested Data Elements	 
PAGEREF _Toc142886409 \h  10  

  HYPERLINK \l "_Toc142886410"  Exhibit 6-1:  Average Annual State
Burden and Costs	  PAGEREF _Toc142886410 \h  21  

  HYPERLINK \l "_Toc142886411"  Exhibit 6-2:  Annual EPA Burden and
Costs	  PAGEREF _Toc142886411 \h  23  

  HYPERLINK \l "_Toc142886412"  Exhibit 6-3:  Bottom Line Burden and
Costs	  PAGEREF _Toc142886412 \h  24  

  HYPERLINK \l "_Toc142886413"  Exhibit A-1:  Estimated State Burden for
Occurrence Data Submission	  PAGEREF _Toc142886413 \h  27  

  HYPERLINK \l "_Toc142886414"  Exhibit A-2:  2007 Salaries and Overhead
Costs from ASDWA State Resource Model	  PAGEREF _Toc142886414 \h  30  

  HYPERLINK \l "_Toc142886415"  Exhibit B-1:  Estimated Burden and Labor
Costs to EPA for Occurrence Data Collection and Analysis	  PAGEREF
_Toc142886415 \h  31  

 

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

1	IDENTIFICATION OF THE INFORMATION COLLECTION  TC "1	IDENTIFICATION OF
THE INFORMATION COLLECTION" \f C \l "1"  

1(a)	Title and Number of the Information Collection  TC "1(a)	Title and
Number of the Information Collection" \f C \l "2"   

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  TC "1(b)	Short Characterization" \f C \l
"2"   

	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 States 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 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.



2	NEED FOR AND USE OF THE COLLECTION  TC "2	NEED FOR AND USE OF THE
COLLECTION" \f C \l "1"  

2(a)	Need/Authority for the Collection  TC "2(a)	Need/Authority for the
Collection" \f C \l "2"   

	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(b)	Practical Utility/Users of the Data  TC "2(b)	Practical
Utility/Users of the Data" \f C \l "2"   

	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 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.



3	NON-DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA  TC "3
NON-DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA" \f C \l
"1"  

3(a)	Non-duplication  TC "3(a)	Non-duplication" \f C \l "2"   

	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 non-duplication 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  TC "3(b)
Public Notice Required Prior to ICR Submission to OMB" \f C \l "2"   

	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.  

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  TC "3(c)	Consultations" \f C \l "2"   

	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  TC "3(d)	Effects of Less
Frequent Collection" \f C \l "2"   

	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.

3(e)	General Guidelines  TC "3(e)	General Guidelines" \f C \l "2"   

	

	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  TC "3(f)	Confidentiality" \f C \l "2"   

	This information collection does not require respondents to disclose
confidential information.

3(g)	Sensitive Questions  TC "3(g)	Sensitive Questions" \f C \l "2"   

	No questions of a sensitive nature are included in any of the
information collection requirements outlined in this ICR.

4	RESPONDENTS AND THE INFORMATION  TC "4	RESPONDENTS AND THE
INFORMATION" \f C \l "1"  

4(a)	Respondents and NAICS/SIC Codes  TC "4(a)	Respondents and NAICS/SIC
Codes" \f C \l "2"   

	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  TC "4(b)	Information" \f C \l "2"   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  TC "4(b)(i)	Data Items" \f C \l "3"  

	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 non-detections 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 additional system inventory data from SDWIS/FED
(adjusted using information from the 1999 Drinking Water Infrastructure
Needs Survey).  

Exhibit 4-  SEQ Exhibit_4- \* ARABIC  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 Radium-226 & Radium-228 (if available)
Gross beta	Tritium

	Iodine-131	Uranium

Gross alpha	Strontium-90

	Microbiological Contaminants

Total coliforms	Fecal coliforms	Escherichia coli (E. coli)



Exhibit 4-  SEQ Exhibit_4- \* ARABIC  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.

*	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 g/L or mg/L for chemicals; or
pCi/l or mrem/yr for radionuclides).  

(Not required for TCR data)

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

	Minimum Reporting Level (MRL) - Value	MRL refers to the lowest
concentration of an analyte that may be reported.

(Not required for TCR data)

	MRL - Unit of Measure	Unit of measure to express the concentration
value of a contaminant's MRL.

(Not required for TCR data)



4(b)(ii)	Respondent Activities  TC "4(b)(ii)	Respondent Activities" \f C
\l "3"  

	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
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.

5	INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT  TC "5	INFORMATION COLLECTED–AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT" \f C \l
"1"  

5(a)	Agency Activities  TC "5(a)	Agency Activities" \f C \l "2"   

	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®.

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.

	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  TC "5(b)	Collection
Methodology and Management" \f C \l "2"  

	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 manner.  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.  

	•	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, e-mail, 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 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  TC "5(c)	Small Entity Flexibility" \f C
\l "2"   

	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.

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.  

5(d)	Collection Schedule  TC "5(d)	Collection Schedule" \f C \l "2"  

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.

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION  TC "6	ESTIMATING
THE BURDEN AND COST OF THE COLLECTION" \f C \l "1"  

	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 States.  These
States are expected to spend the most time reading and considering the
request for data, as they may need to identify which of their data
elements correspond to those requested.  For similar reasons,
compilation and submission of their occurrence data, and 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.  

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  TC "6(a)	Estimating Respondent
Burden" \f C \l "2"   

	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  TC "6(b)	Estimating Respondent Costs"
\f C \l "2"   

	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 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-  SEQ Exhibit_6- \* ARABIC  1 :  Average Annual State Burden
and Costs  TC "Exhibit 6-1:  Average Annual State Burden and Costs" \f F
\l "1"  

(for ICR period of 2007-2009)

Number of States	Burden Hours	Labor Costs

	All States	Per State	All States	Per State

56	681	12.2	$30,608	$547



6(c)	Estimating Agency Burden and Costs  TC "6(c)	Estimating Agency
Burden and Costs" \f C \l "2"   

	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  TC "6(c)(i)	Agency Burden" \f C \l "3"  

	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:  

		•	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.

6(c)(ii)	Agency Cost  TC "6(c)(ii)	Agency Cost" \f C \l "3"  

	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-  SEQ Exhibit_6- \* ARABIC  2 :  Annual EPA Burden and Costs

(for ICR period of 2007-2009)

Activity	EPA Burden Per State	Annual EPA1

	(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  TC
"6(d)	Estimating the Respondent Universe and Total Burden and Costs" \f
C \l "2"   

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

6(e)	Bottom Line Burden Hours and Cost Tables  TC "6(e)	Bottom Line
Burden Hours and Cost Tables" \f C \l "2"   

	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-  SEQ Exhibit_6- \* ARABIC  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  TC "6(f)	Reasons For Change in
Burden" \f C \l "2"  

	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  TC "6(g)	Burden Statement" \f C \l "2"   

	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.

	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.

APPENDICES  TC "APPENDICES" \f C \l "1"  

Appendix A:  Detailed Burden and Cost for States  TC "Appendix A: 
Detailed Burden and Cost for States" \f C \l "1"   

Exhibit A-1:  Estimated State Burden for Occurrence Data Submission

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



Reading EPA Request 	Compiling, Submitting Data	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/Non-SS	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/Non-SS	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/Non-SS	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/Non-SS	7	44	13	64	m	$42.42	$2,715

Kentucky (i)	Likely/Non-SS	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/Non-SS	7	44	13	64	m	$42.42	$2,715

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

Minnesota	Likely/Non-SS	7	44	13	64	m	$42.42	$2,715

Mississippi	Unlikely	1	0	0	1	m	$42.42	$42

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/Non-SS	7	44	13	64	m	$42.42	$2,715

New Mexico	Likely/Non-SS	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/Non-SS	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/Non-SS	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/Non-SS	7	44	13	64	l	$49.02	$3,137

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

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

South Carolina	Likely/Non-SS	7	44	13	64	m	$42.42	$2,715

South Dakota	Likely/Non-SS	7	44	13	64	s	$39.38	$2,520

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

Texas	Likely/Non-SS	7	44	13	64	vl	$69.30	$4,435

Utah	Unlikely	1	0	0	1	s	$39.38	$39

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

Virginia (i)	Likely/Non-SS	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

Wisconsin	Likely/Non-SS	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.



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

State Size (a)	Professional Staff	Support 

Staff	Hourly Ave. ~ 80% Prof and 20% Support	Hourly Rate (adjusted for
overhead at 23%)

	(adjusted for fringe benefits 

at 22% of base salary)



Very Small (applies to 9 States, including VI, GU, AS, NM)	$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.).

Appendix B:  Detailed Burden and Cost for EPA  TC "Appendix B: 
Detailed Burden and Cost for EPA" \f C \l "1"  

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

Activity	SDWIS and Non-SDWIS States	Contractor Burden	Contractor Labor
Cost

	Est. # of SDWIS States to Respond	Est. # of Non-SDWIS States to Respond
Est. Contractor Hours per SDWIS State	Est. Contractor Hours per
Non-SDWIS State	Est. Total Contractor Hours for SDWIS States	Est. Total
Contractor Hours for Non-SDWIS States	Est. Total Contractor Hours for
All States	Cost per Hour for Contractual Labor	Est. Total Contractor
Labor Cost for SDWIS States	Est. Total Contractor Labor Cost for
Non-SDWIS States	Est. Total Contractor Labor Cost for All States

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

Data Extraction or Download (r)	19	21	9	15	171	315	486	$79.57	$13,606
$25,064	$38,670

Initial data screening/conversion to uniform structures	19	21	35	70	665
1,470	2,135	$79.57	$52,912	$116,964	$169,877

Communication and coordination with the States	19	21	5	10	95	210	305
$79.57	$7,559	$16,709	$24,268

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
$187,978	$358,054

TOTAL	19	21	161.5	207.5	3,069	4,358	7,426	$79.57	$244,153	$346,715
$590,868



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

Activity	EPA Burden	EPA Labor Cost	EPA and Contractor Totals

	Est. EPA Hours per SDWIS State	Est. EPA Hours for Non-SDWIS States	Est.
Total EPA Hours for SDWIS States	Est. Total EPA Hours for Non-SDWIS
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
Non-SDWIS States	Est. Total EPA Labor Cost for All States	Est. Total EPA
and Contractor Burden Per SDWIS State	Est. Total EPA and Contractor
Burden Per Non-SDWIS State	Est. Total EPA and Contractor Burden for All
States	Est. Total EPA and Contractor Labor Cost for All States

 	(l)	(m)	(n)=(a)*(l)	(o)=(b)*(m)	(p)=(n)+(o)	(q)	(r)=(n)*(q)
(s)=(o)*(q)	(t)=(r)+(s)	(u)=(c)+(l)	(v)=(d)+(m)	(u)=(g)+(p)	(v)=(k)+(t)

Data Extraction or Download (r)	2	2	38	42	80	$69.46	$2,639	$2,917	$5,557
11.0	17.0	566	$44,226

Initial data screening/conversion to uniform structures	1	1	19	21	40
$69.46	$1,320	$1,459	$2,778	36.0	71.0	2,175	$172,655

Communication and coordination with the States	1	1	19	21	40	$69.46
$1,320	$1,459	$2,778	6.0	11.0	345	$27,046

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	5,850	$451,821

TOTAL	37.8	37.8	717	793	1,510	$69.46	$49,818	$55,062	$104,880	199	245
8,936	$695,748









 	 Annual Ave. 2007-2009	2,979	$231,916

(c, d, l, m, u, v) Estimates for Data Management and Analysis assume: 
100 contractor hours for each of 45 contaminants for which occurrence
will be analyzed. To show this on a per State basis, as all other
activities are shown, this 4,500 hours (100 hours x 45 contaminants) is
divided by 40 States (i.e., the maximum number of States expected to
participate), which equals 112.5 hours per State.  Similarly, 30 EPA
hours for each of the 45 contaminants is shown as 33.8 hours per State. 
Thus, total estimated burden per State for this activity is 146.3. 
However, burden for the occurrence analyses will not vary greatly with
the addition or subtraction 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.  The other 3 listed aspects of EPA burden (data
download, screening, and communication) will vary directly on a per
State basis.  Because these 3 other burden items are collectively
smaller (at 49/State for SDWIS/States, and 93/State for Non-SDWIS/State)
than the data analysis burden, the "per State" burden will increase as
the number of participating States decreases.

(h) Contractor costs are based on historical hourly costs pertaining to
the management and analysis of occurrence data, which were approximately
$79.57 per hour.

(q) EPA internal labor costs are estimated using the federal government
general schedule (GS) pay scale; assuming a labor level of GS 13, step
5, and taken from the Maryland/District of Columbia rate schedule during
the first quarter of 2006 (see the U.S. Office of Personnel Management
website:  www.opm.gov).  With these assumptions, labor and contractor
rates were based on a 2,080 hour work year, with a $87,664 annual salary
during 2006 (most current available) plus a 3% inflation factor for 2007
salaries, and 60 percent overhead, or $69.46 per hour.

(r) There are approximately 30 States that currently use SDWIS/State for
managing only their TCR data.  For the majority of 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.

 Throughout this document, the terms "State" or "States" are used to
refer to the 56 States and territories.

  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.

 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).

  These definitions were taken from section 601 of the RFA.

 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.

Page   PAGE  i  of iii

Draft Six-Year 2 ICR	August 2006

Page   PAGE  1  of 33

Draft Six-Year 2 ICR	April 2006

