Draft Information Collection Request for

Contaminant Occurrence Data 

in Support of the EPA's Fourth Six-Year Review of 

National Primary Drinking Water Regulations

October 2019

Updated by:

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water

Standards and Risk Management Division

1201 Constitution Ave, N.W. 

Washington, D.C. 20004

TABLE OF CONTENTS

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc246836628"  1
IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc246836628 \h 
1  

  HYPERLINK \l "_Toc246836629"  1(a)	Title and Number of the Information
Collection	  PAGEREF _Toc246836629 \h  1  

  HYPERLINK \l "_Toc246836630"  1(b)	Short Characterization	  PAGEREF
_Toc246836630 \h  1  

  HYPERLINK \l "_Toc246836631"  2	NEED FOR AND USE OF THE COLLECTION	 
PAGEREF _Toc246836631 \h  3  

  HYPERLINK \l "_Toc246836632"  2(a)	Need/Authority for the Collection	 
PAGEREF _Toc246836632 \h  3  

  HYPERLINK \l "_Toc246836633"  2(b)	Practical Utility/Users of the Data
  PAGEREF _Toc246836633 \h  3  

  HYPERLINK \l "_Toc246836634"  3	NON-DUPLICATION, CONSULTATIONS AND
OTHER COLLECTION CRITERIA	  PAGEREF _Toc246836634 \h  5  

  HYPERLINK \l "_Toc246836635"  3(a)	Non-duplication	  PAGEREF
_Toc246836635 \h  5  

  HYPERLINK \l "_Toc246836636"  3(b)	Public Notice Required Prior to ICR
Submission to OMB	  PAGEREF _Toc246836636 \h  5  

  HYPERLINK \l "_Toc246836637"  3(c)	Consultations	  PAGEREF
_Toc246836637 \h  5  

  HYPERLINK \l "_Toc246836638"  3(d)	Effects of Less Frequent Collection
  PAGEREF _Toc246836638 \h  6  

  HYPERLINK \l "_Toc246836639"  3(e)	General Guidelines	  PAGEREF
_Toc246836639 \h  6  

  HYPERLINK \l "_Toc246836640"  3(f)	Confidentiality	  PAGEREF
_Toc246836640 \h  6  

  HYPERLINK \l "_Toc246836641"  3(g)	Sensitive Questions	  PAGEREF
_Toc246836641 \h  6  

  HYPERLINK \l "_Toc246836642"  4	RESPONDENTS AND THE INFORMATION	 
PAGEREF _Toc246836642 \h  7  

  HYPERLINK \l "_Toc246836643"  4(a)	Respondents and NAICS/SIC Codes	 
PAGEREF _Toc246836643 \h  7  

  HYPERLINK \l "_Toc246836644"  4(b)	Information Requested	  PAGEREF
_Toc246836644 \h  7  

  HYPERLINK \l "_Toc246836645"  4(b)(i)	Data Items	  PAGEREF
_Toc246836645 \h  7  

  HYPERLINK \l "_Toc246836646"  4(b)(ii)	Respondent Activities	  PAGEREF
_Toc246836646 \h  11  

  HYPERLINK \l "_Toc246836647"  5	INFORMATION COLLECTED–AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	14 

  HYPERLINK \l "_Toc246836648"  5(a)	Agency Activities	14 

  HYPERLINK \l "_Toc246836649"  5(b)	Collection Methodology and
Management	16 

  HYPERLINK \l "_Toc246836650"  5(c)	Small Entity Flexibility	18 

  HYPERLINK \l "_Toc246836651"  5(d)	Collection Schedule	  PAGEREF
_Toc246836651 \h  18  

  HYPERLINK \l "_Toc246836652"  6	ESTIMATING THE BURDEN AND COST OF THE
COLLECTION	  PAGEREF _Toc246836652 \h  19  

  HYPERLINK \l "_Toc246836653"  6(a)	Estimating Respondent Burden	 
PAGEREF _Toc246836653 \h  20  

  HYPERLINK \l "_Toc246836654"  6(b)	Estimating Respondent Costs	 
PAGEREF _Toc246836654 \h  21  

  HYPERLINK \l "_Toc246836655"  6(c)	Estimating Agency Burden and Costs	
 PAGEREF _Toc246836655 \h  21  

  HYPERLINK \l "_Toc246836656"  6(c)(i)	Agency Burden	  PAGEREF
_Toc246836656 \h  22  

  HYPERLINK \l "_Toc246836657"  6(c)(ii)	Agency Cost	  PAGEREF
_Toc246836657 \h  23  

  HYPERLINK \l "_Toc246836658"  6(d)	Estimating the Respondent Universe
and Total Burden and Costs	  PAGEREF _Toc246836658 \h  24  

  HYPERLINK \l "_Toc246836659"  6(e)	Bottom Line Burden Hours and Cost
Tables	  PAGEREF _Toc246836659 \h  24  

  HYPERLINK \l "_Toc246836660"  6(f)	Reasons for Change in Burden	 
PAGEREF _Toc246836660 \h  25  

  HYPERLINK \l "_Toc246836661"  6(g)	Burden Statement	  PAGEREF
_Toc246836661 \h  25  

  HYPERLINK \l "_Toc246836662"  APPENDICES	  PAGEREF _Toc246836662 \h 
27  

  HYPERLINK \l "_Toc246836663"  Appendix A:  Detailed Burden and Cost
for States	  PAGEREF _Toc246836663 \h  28  

  HYPERLINK \l "_Toc246836664"  Appendix B:  Detailed Burden and Cost
for the EPA	  PAGEREF _Toc246836664 \h  32  

 

LIST OF EXHIBITS

  TOC \h \z \t "Style Caption + Centered" \c    HYPERLINK \l
"_Toc526166759"  Exhibit 4-1:  Occurrence Data to Be Requested	  PAGEREF
_Toc526166759 \h  8  

  HYPERLINK \l "_Toc526166760"  Exhibit 4-2:  Requested Data Categories	
 PAGEREF _Toc526166760 \h  9  

  HYPERLINK \l "_Toc526166761"  Exhibit 6-1:  Average Annual State
Burden and Costs	  PAGEREF _Toc526166761 \h  21  

  HYPERLINK \l "_Toc526166763"  Exhibit 6-2:  Annual the EPA Burden and
Costs	  PAGEREF _Toc526166763 \h  23  

  HYPERLINK \l "_Toc526166765"  Exhibit 6-3:  Bottom Line Burden and
Costs	  PAGEREF _Toc526166765 \h  24  

  HYPERLINK \l "_Toc526166767"  Exhibit A-1. Estimated State Burden for
Occurrence Data Submission	  PAGEREF _Toc526166767 \h  28  

  HYPERLINK \l "_Toc526166768"  Exhibit A-2:  Estimated 2019 Salaries
and Overhead Costs from ASDWA State Resource Model	  PAGEREF
_Toc526166768 \h  31  

  HYPERLINK \l "_Toc526166769"  Exhibit B-1:  Estimated Burden and Labor
Costs to the EPA for Occurrence Data Collection and Analysis	  PAGEREF
_Toc526166769 \h  32  

 

ACRONYMS

AMWA	Association of Metropolitan Water Agencies

AWWA	American Water Works Association

ASDWA	Association of State Drinking Water Administrators

CFR	Code of Federal Regulations 

DQO	Data Quality Objective

DBPR	Disinfectants and Disinfection Byproducts Rule

EPA	U.S. Environmental Protection Agency

FBRR	Filter Backwash Recycling Rule

FR	Federal Register 

GWR	Ground Water Rule

ICR	Information Collection Request

IESWTR	Interim Enhanced Surface Water Treatment Rule

MCL	Maximum Contaminant Level

mg/L	Milligrams per Liter

NAICS	North American Industry Classification System

NCOD	National Contaminant Occurrence Database

NPDWR	National Primary Drinking Water Regulation 

O&M	Operation and Maintenance

OMB	Office of Management and Budget 

PRA	Paperwork Reduction Act 

PWS	Public Water System

PWSID	Public Water System Identification Number

PWSS	Public Water System Supervision

QA/QC	Quality Assurance/Quality Control

RFA	Regulatory Flexibility Act

SBA	Small Business Administration

SBREFA	Small Business Regulatory Enforcement Fairness Act

SDWA	Safe Drinking Water Act

SDWIS	Safe Drinking Water Information System

SWTR	Surface Water Treatment Rule

TCR	Total Coliform Rule

1	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Number of the Information Collection 

Title:	Information Collection Request for Contaminant Occurrence Data in
Support of EPA's Fourth Six-Year Review of National Primary Drinking
Water Regulations

OMB Control Number:	2040-NEW

EPA ICR No.:	2574.01

1(b)	Short Characterization 

The Safe Drinking Water Act (SDWA), as amended in 1996, requires that
the U.S. Environmental Protection Agency (EPA) review existing national
primary drinking water regulations (NPDWRs) no less often than every six
years and, if appropriate, revise them. The EPA completed its third
Six-Year Review cycle in December 2016 and published the review results
on January 11, 2017 (82 FR 3518). During the third Six-Year Review, the
EPA performed a review of chemical, microbial, and radiological
contaminants or indicators, along with treatment technique data from 88
NPDWRs, which were promulgated prior to August 2008. The occurrence
assessments conducted for the third Six-Year Review were based on
compliance monitoring data collected from 2006 to 2011 and voluntarily
submitted by states and other primacy agencies under Information
Collection Request (ICR No. 2231.02, 76 FR 6780, February 8, 2011). 

The EPA is issuing this new Information Collection Request (ICR), ICR
No. 2574.01, as a one-time request for states to voluntarily submit
NPDWR compliance monitoring data collected between 2012 and 2019. 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 2020 to 2022. 

With this ICR, the EPA's Office of Water is requesting that states
submit compliance monitoring data (occurrence data and treatment
technique data) for public water systems (PWSs) to support the
Agency’s fourth Six-Year Review. The EPA plans to request monitoring
data collected between January 2012 and December 2019, during the
implementation of NPDWRs promulgated prior to 2015. This review cycle,
hereafter referred to as Six-Year Review 4, encompasses the review
process cycle of 2016-2022. Through the Six-Year Review process, the EPA
reviews existing NPDWRs and evaluates whether potential revisions are
appropriate to maintain or improve the health of those persons served by
PWSs. These compliance monitoring records (including all results for
analytical detections and non-detections) and other compliance summaries
provide the data needed to conduct statistical estimates of national
occurrence of each regulated contaminant and are used to evaluate
regulation effectiveness. The review of this data will support the EPA's
consideration of whether revisions to existing regulations are
appropriate. In addition, SDWA section 1445(g) requires the EPA to
maintain a national drinking water contaminant occurrence database
(i.e., the National Contaminant Occurrence Database (NCOD)) using
occurrence data for both regulated and unregulated contaminants in PWSs.
Thus, through this data collection, the EPA will also be fulfilling some
of the SDWA requirements as they relate to national occurrence data.

States can upload data using a designated, secure system. After
receiving the data, the EPA will conduct the necessary data review,
editing, and quality assurance/quality control (QA/QC) across all state
datasets to allow uniform assessments across all the datasets, and
subsequent data management and analysis, to provide an overview of
occurrence estimates at the national level. Upon request, the EPA will
provide states with the edited data and/or the log of the edits that
were applied to the data prior to the posting and storage of data in the
NCOD. Following final QA/QC of the data, a summary of the data will be
made available to the public through NCOD and/or other appropriate
mechanisms. 

Although these data submissions are not required of the state agencies,
the 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 request for voluntary submission of data (not
submission of data required by 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
and implementation activities and information collection requirements
under the SDWA.

The total annual burden and costs to the 56 potential state respondents
associated with this ICR is estimated to be 765 hours and $43,021 per
year over the 3-year ICR period of 2020-2022, or 13.7 hours and $768 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. 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 vary
across states, depending on their current data storage system (e.g.,
State Drinking Water Information System/State version (SDWIS/State) vs.
proprietary data systems) and expected participation levels. No burden
to PWSs is associated with this data collection.

Over the ICR years of 2020-2022, the EPA is expected to incur an average
annual cost of $408,763 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

2(a)	Need/Authority for the Collection 

Through the Six-Year Review process, the EPA reviews existing NPDWRs and
evaluates whether potential revisions are appropriate to maintain or
improve the health of those persons served by public water systems.
Section 1412(b)(9) of the SDWA states: "The Administrator shall, not
less often than every 6 years, review and revise, as appropriate, each
national primary drinking water regulation promulgated under this title.
Any revision of a national primary drinking water regulation shall be
promulgated in accordance with this section, except that each revision
shall maintain, or provide for greater, protection of the health of
persons."  Compliance monitoring data provide information critical to
these assessments. Without an understanding of where and at what levels
these contaminants are occurring in public drinking water, the EPA
cannot assess the risk to public health and whether potential revisions
are likely to maintain or improve public health protection. In addition,
other compliance data can help in evaluating the effectiveness of
current regulations.

Section 1445(g)(1) requires the EPA to "assemble and maintain a national
drinking water contaminant occurrence data base [sic], 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 that are less than or equal to the
maximum contaminant level (MCL) for a specific contaminant. Prior to the
establishment of NCOD, only data related to MCL violations were being
stored on a national-level.

2(b)	Practical Utility/Users of the Data 

This ICR supports the collection of compliance monitoring data
(contaminant occurrence data and treatment technique information)
collected between January 2012 to December 2019, during the
implementation of NPDWRs promulgated prior to 2015. A list of the
occurrence data to be requested is provided as Exhibit 4-1. The
occurrence data will be used to derive detailed statistical estimates of
national occurrence of these regulated contaminants. The EPA's specific
goal in evaluating contaminant occurrence is to estimate the national
number of PWSs at which the individual regulated contaminants occur at
levels of health concern and/or the feasible level of measurement, and
to evaluate the number of people exposed to these levels. This
information, in conjunction with other contaminant-specific analyses
conducted as part of the Six-Year Review (e.g., health assessment,
technology, implementation issues, etc.), will provide the EPA with
information to determine whether or not it is appropriate to consider
revisions to a regulation to maintain or provide for greater protection
of human health. The monitoring data (including compliance summaries)
will provide the EPA with information to evaluate regulation
effectiveness.

The primary user of the information collected under this ICR will be the
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, the EPA’s 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

3(a)	Non-duplication 

The EPA has made an effort to ensure that data collection activities
associated with this ICR are not duplicative. 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 the EPA. Thus, the final
compilation and analysis of this information is not unnecessarily
duplicative of information otherwise available to the EPA.

In addition, the State Drinking Water Information System/Federal
(SDWIS/FED) contains some inventory-related data elements that the EPA
is requesting be submitted with each data record. As discussed in
Section 4(b), the EPA will give states the option of reporting all
requested data elements or having the Agency access inventory data from
SDWIS/FED based on the federal public water system identification
(PWSID) number.

3(b)	Public Notice Required Prior to ICR Submission to the Office of
Management and Budget (OMB) 

 

Public notice will be published two times. The first ICR Federal
Register notice will be published with a 60-day publish comment period.
The second ICR Federal Register notice and supporting statement reflect
any changes made to the ICR as a result of public comments received from
the first Federal Register notice and is then submitted to OMB; the
second Federal Register notice is published with 30-day public comment
period (to inform OMB of any additional public concerns with the ICR as
submitted by the EPA).

Public Comment on the 1st FRN for Proposed Information Collection: 

Three comments were received during the EPA’s first ICR Federal
Register notice’s 60-day comment period (83 FR 50361, October 5,
2018). The Office of Ground Water and Water determined that none of the
public comment affected the proposed information collection for the
fourth Six-Year Review. The commenters included a member of the public
requesting the EPA to reduce the Maximum Contaminant Level for fluoride
related to the EPA’s third Six-Year Review revision efforts, a member
of the public using the docket for political opinion on matters
unrelated to the ICR, and a non-profit group providing their support for
the proposal of the ICR and the EPA’s fourth Six-Year Review.

3(c)	Consultations 

The 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 the EPA's final announcement of
the Six-Year Review process on July 18, 2003, entitled: "National
Primary Drinking Water Regulations; Announcement of Completion of the
EPA's Review of Existing Drinking Water Standards" (68 FR 42908). 

To prepare for Six-Year Review 4, the EPA used information from the
previous Six-Year Review process, in addition to consulting with the
Association of State Drinking Water Administrators (ASDWA) through email
correspondence in June 2018 about burden estimates. 

3(d)	Effects of Less Frequent Collection 

The EPA is required by the SDWA to conduct a Six-Year Review of existing
NPDWRs. The information requested under this ICR is being collected on a
one-time basis for the Six-Year Review 4 to meet the SDWA statutory
requirements.

3(e)	General Guidelines 

Activities undertaken in support of this collection will not exceed any
of the parameters set out in 5 CFR 1320.5(d)(2).  

3(f)	Confidentiality 

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

3(g)	Sensitive Questions 

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

4	RESPONDENTS AND THE INFORMATION

4(a)	Respondents and NAICS/SIC Codes 

Data associated with this ICR are collected and maintained by state
drinking water agencies. The North American Industry Classification
System (NAICS) code for state agencies that include drinking water
programs are classified as 92411 (Administration of Air and Water
Resources and Solid Waste Management Programs) or 92312 (Administration
of Public Health Programs). There will be no burden included for water
systems, because systems will not be asked to collect, submit, or review
new data, and will not be affected by the states' efforts for the data
submission.

4(b)	Information Requested 

This ICR covers reporting activities that will take place in response to
a specific EPA data call-in (for existing monitoring/occurrence data) to
state drinking water programs. Though this is not a requirement, the ICR
is necessary to estimate reporting burden and costs to the states. This
ICR summarizes the data items and respondent activities associated with
the reporting effort. All data being called-in are historic (i.e., data
already exist); no states or PWSs will be required to collect any new
data. Further, no recordkeeping burden will be imposed on the states as
a result of this request (i.e., states are already required to maintain
these records as part of NPDWRs).

4(b)(i)	Data Items

The EPA is requesting that states voluntarily submit compliance
monitoring data and treatment technique information collected by PWSs
during January 2012 through December 2019 for the occurrence data listed
in Exhibit 4-1. This request only includes existing data that the states
have already stored in electronic format. The requested data include
analytical detections and non-detections for routine compliance
monitoring samples (including repeat and confirmation samples) and other
compliance summaries, 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 EPA to uphold high standards of data
quality and analytical integrity. The EPA has identified the data
categories (see Exhibit 4-2) that the Agency will request that states
provide with their data results. In general, these data elements are
based on those used for the third 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 include most, if not all, of those data elements. The 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 datasets
"as is." However, for states that elect to submit a subset of data, the
EPA has identified essential data categories that the Agency needs to
most effectively evaluate the occurrence data. If states elect to submit
their data with only these data categories, the EPA will use the PWSID
number to acquire additional system-specific data from SDWIS/FED, and
appropriate supplemental information, where needed. 

The compliance data collected for the Total Coliform Rule, Revised Total
Coliform Rule, Ground Water Rule, Surface Water Treatment Rules, Long
Term 1 and 2 Enhanced Surface Water Treatment Rule (LT1 and LT2), Stage
1 and 2 Disinfectants and Disinfection Byproducts Rule (DBPRs) and
Filter Backwash Recycling Rule (FBRR) will be evaluated to determine
regulation effectiveness.

Exhibit 4-  SEQ Exhibit_4- \* ARABIC  1 :  Occurrence Data to Be
Requested



Chemical Contaminants (Phase I, II, IIB, and V Rules; Arsenic Rule; Lead
and Copper Rule)



Acrylamide	1,1-Dichloroethylene 	Methoxychlor

Alachlor	cis-1,2-Dichloroethylene 	Monochlorobenzene (Chlorobenzene)

Antimony	trans-1,2-Dichloroethylene	Nitrate (as N)

Arsenic	Dichloromethane (Methylene chloride)	Nitrite (as N)

Asbestos	1,2-Dichloropropane	Oxamyl (Vydate)

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

Barium	Di(2-ethylhexyl) phthalate (DEHP)	Picloram

Benzene	Dinoseb	Polychlorinated biphenyls (PCBs)

Benzo[a]pyrene	Diquat	Selenium

Beryllium	Endothall	Simazine

Cadmium	Endrin	Styrene

Carbofuran	Epichlorohydrin	2,3,7,8-TCDD (Dioxin)

Carbon tetrachloride	Ethylbenzene	Tetrachloroethylene

Chlordane	Ethylene dibromide (EDB)	Thallium

Chromium (total)	Fluoride	Toluene

Copper	Glyphosate	Toxaphene

Cyanide	Heptachlor	2,4,5-TP (Silvex)

2,4-D	Heptachlor epoxide	1,2,4-Trichlorobenzene

Dalapon	Hexachlorobenzene	1,1,1-Trichloroethane

1,2-Dibromo-3-chloropropane (DBCP) 	Hexachlorocyclopentadiene
1,1,2-Trichloroethane

1,2-Dichlorobenzene 

(o-Dichlorobenzene)	Lead	Trichloroethylene

1,4-Dichlorobenzene 

(p-Dichlorobenzene) 	Lindane	Vinyl chloride

1,2-Dichloroethane (Ethylene dichloride)	Mercury (inorganic)	Xylenes
(total)

Radiological Contaminants 



Combined Radium-226/228; and Radium-226 & Radium-228 (if available)
Gross beta	Tritium

	Iodine-131	Uranium

Gross alpha	Strontium-90

	Total Coliform Rule (TCR) and Revised Total Coliform Rule (RTCR)

Total coliforms (TC)	Fecal coliforms	Escherichia coli (E. coli)

Disinfectants and Disinfection Byproducts Rules (DBPRs)



Total Trihalomethanes (TTHMs):

Chloroform

Bromodichloromethane

Dibromochloromethane

Bromoform	Haloacetic Acids (HAA5):

Monochloroacetic acid

Dichloroacetic acid

Trichloroacetic acid

Bromoacetic acid

Dibromoacetic acid	Bromate



Chlorite



Chlorine



Chloramines



Chlorine dioxide

Ground Water Rule (GWR)

Escherichia coli (E. coli)	Enterococci	Coliphage

Surface Water Treatment Rules (SWTRs)



Chlorine	Cryptosporidium	Heterotrophic Plate Count (HPC)



Chloramines	Giardia lamblia

	Filter Backwash Recycling Rule (FBRR)



No specific occurrence data collected; see Exhibit 4-  SEQ Exhibit_4- \*
ARABIC  2  for data elements for FBRR



Exhibit 4-2:  Requested Data Categories



Data Category	Description

System-Specific Information



Public Water System Identification Number (PWSID) 	The code used to
identify each PWS. The code begins with the standard 2-character postal
state abbreviation or Region code; the remaining 7 numbers are unique to
each PWS in the state.

	System Name	Name of the PWS. 

	Federal Public Water System Type Code	A code to identify whether a
system is:

• Community Water System;

• Non-transient Non-community Water System; or 

• Transient Non-community Water System.

	Population Served	Highest average daily number of people served by a
PWS, when in operation.

	Federal Source Water Type	Type of water at the source. Source water
type can be:

• Ground water; or

• Surface water; or

• Ground water under the direct influence of surface water (GWUDI).
(Note: Some states may not distinguish GWUDI from surface water sources.
In those states, a GWUDI source should be reported as a surface water
source type.)

Treatment Information 



Water System Facility	System facility data, including: treatment plant
identification number, treatment plant information, treatment unit
process/objectives, facility flow, treatment train (train or flow of
water through treatment units within the treatment plant).

	Filtration Type	Information relating to system filtration, including:
filtration status, types of filtration (e.g., unfiltered, conventional
filtration, and other permitted values).

	Treatment Technique Information	Information pertaining to treatment
processes. Types of treatment technique information including:
disinfectants used and their doses for primary and secondary
disinfection, coagulant/coagulant aid type and dose, disinfectant
concentration, disinfection profile/bench mark data, log of viral
inactivation/removal, contact time, contact value, pH, temperature. 

	Filter Backwash Information	Information about filter backwash that is
returned to the treatment plant influent (e.g., information on:
recycle/schematic status, alternative return location, corrective action
requirements, and recycle flows and frequency).

Sample-Specific Information



Sampling Point Identification Code	A sampling point identifier
established by the state, unique within each applicable facility, for
each applicable sampling location (e.g., entry point to the distribution
system). This information enables occurrence assessments that address
intra-system variability.

	Sample Identification Number	Identifier assigned by state or the
laboratory that uniquely identifies a sample. 

	Sample Collection Date	Date the sample is collected, including month,
day, and year.

	Sample Type	Indicates why the sample is being collected (e.g.,
compliance, routine, repeat, confirmation, additional routine samples,
duplicate, special, special duplicate, etc.).

	Sample Analysis Type Code	Code for type of water sample collected. 

• Raw (Untreated) water sample

• Finished (Treated) water sample

For lead and copper only:

Source

Tap

For TCR Repeats only; indicator of sampling location relative to sample
point where positive sample was originally collected:

• Upstream

• Downstream

• Original

	Contaminant	Contaminant name, 4-digit SDWIS contaminant identification
number, or Chemical Abstracts Service (CAS) Registry Number for which
the sample is being analyzed.

	Sample Analytical Result 

- Sign	The sign indicates whether the sample analytical result was: 

• (<) "less than" means the contaminant was not detected or was
detected at a level "less than" the minimum reporting level (MRL). 

• (=) "equal to" means the contaminant was detected at a level "equal
to" the value reported in "Sample Analytical Result - Value."

• (+) “positive result” (For RTCR data, only positive E. coli
result sign to be included.)

	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 and RTCR, TC and E. coli will indicate presence/absence,
and positive E. coli will have numeric results.)

	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 radiological contaminants). 

(Not required for TCR and RTCR data)

	Sample Analytical Method Number	The 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 and RTCR data)

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

(Not required for TCR and RTCR data)

	Source Water Monitoring Information	Total organic carbon (TOC),
including percent TOC removal, TOC removal summary, pH, alkalinity,
monitoring data entered as individual results or included in DBP (or
monthly operating report (MOR)) summary records, alternative compliance
criteria, results from round 2 monitoring under LT2 ESWTR (including
Cryptosporidium, E. coli, turbidity, or state-approved alternate
indicators).

	Sample Summary Reports	Sample summaries for DBPRs, SWTRs, GWR
corrective actions, and the Lead and Copper Rule (LCR) associated with
analytical result records. Values used for compliance determination
[e.g., turbidity (combined effluent/individual effluent), disinfectant
residual levels in treatment plant and distribution system, treatment
technique information, HPC, etc.]



4(b)(ii)	Respondent Activities

Potential respondents to this information collection are assumed to
include 56 state drinking water agencies listed in Exhibit A-1 in
Appendix A. Activities needed to respond to the information collection
include reading and understanding the EPA's request, compiling and
submitting the requested drinking water contaminant data in electronic
format, and communication and coordination with the EPA. No
recordkeeping requirements are associated with this information
collection request. Each of these respondent activities is described in
more detail below.

Reading/Understanding the EPA's Request

The EPA will send a letter to 56 states that explains the purpose of the
data collection, the specific information the EPA is requesting, and the
procedure for submitting these data.

Compiling and Submitting Monitoring Data

The EPA is asking states to compile and submit data that have already
been collected from water systems, and which already exist in electronic
format. The 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, secure system.

To facilitate the consistency and quality of data across states, the EPA
will ask states to:  provide a brief description of the basic format and
structure of each dataset, and definitions of all data elements,
column/row headings, codes, acronyms, etc., used in each dataset; submit
the data in a format with each analytical result occupying a discrete
row accompanied by the system inventory and sample-specific data items
(i.e., those listed in Exhibit 4-2 in section 4(b)(i)); and submit the
data in a the EPA-compatible file format, such as Dbase (.dbf), Access
tables (.mdb or .accdb), comma or tab delimited files (.csv or .txt), or
Excel (.xls or .xlsx). It is expected that the data from states using or
are planning to use SDWIS/State will more closely match the needed data
formats and elements, and thus are assumed to have less burden for
submissions than non-SDWIS States. To ease this burden, the EPA will
provide extraction scripts to use with the SDWIS/State database.
However, all states will have the option of submitting data as is; thus,
the assumption of higher burden for non-SDWIS states is a conservative
(highest possible cost) assumption. If states submit only the minimum
data element information, the EPA will extract the additional inventory
information from SDWIS/FED, and appropriate supplemental information,
where needed, based on the PWSID number.

 This SDWIS/FED system offers the public and agency capability to query
the Safe Drinking Water Information System (SDWIS) Fed Data Warehouse
via report filters and various reporting options. Data management plays
a critical role in helping states and the EPA to protect public
health. The term "states" refers to any entity with primacy under the
Safe Drinking Water Act (SDWA) to implement and enforce national
drinking water regulations. States supervise the public water systems
within their jurisdictions to ensure that each system meets state and
EPA standards for safe drinking water. The Safe Drinking Water
Act requires states to report drinking water information (for
example, the system’s inventory), periodically to the EPA. This
information is maintained in a federal database, the SDWIS Fed Data
Warehouse.

States report the following information to the EPA: 

Basic information about each public water system, including:

the system's name

ID number

city or county served

number of people served

type of system (residential, transient, non-transient)

whether the system operates year-round or seasonally

characteristics of the system's source(s) of water

Violation information for each public water system, including
whether the system has:

failed to follow established monitoring and reporting schedules

failed to comply with mandated treatment techniques

violated any Maximum Contaminant Levels (MCLs)

failed to communicate required information to their customers

Enforcement information, including actions states or the EPA have taken
to ensure that a public water system returns to compliance if it is in
violation of a drinking water regulation.

The 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 the EPA 

Based on the EPA’s experience with occurrence information provided by
states for previous Six-Year Reviews, the EPA expects that it may need
to contact some states' data management staff to address questions
regarding the data quality such as possibly incorrect units of
measurement, outlier values, incorrect, missing, or undefined data
elements, or other possible data problems. This follow-up may be minimal
or may not be needed for those states that provide their data in the
requested format with an explanation of their codes, headers, etc. It is
assumed that these communications and confirmations will be handled
primarily through telephone and e-mail.

5	INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT

5(a)	Agency Activities 

The EPA’s Headquarters will conduct the following activities
associated with the collection of regulated monitoring data:

Extract or download data;

Initial data screening/conversion to uniform structures;

Communicate and coordinate with states; and 

Data management and analysis, including 

Quality assurance/quality control and review/edit data;

Data analysis and report of findings; and 

Recordkeeping.

Each of these activities is discussed in more detail below.

Extract or Download Data

The 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. The EPA assumes that data from states that use
or are planning to use SDWIS/State will most closely reflect the data
elements and format being requested due to the use of the provided
database extraction scripts. Data from states using other databases are
more likely to differ from the requested format. In cases where states
do not provide all of the requested data, the EPA will, where possible,
extract the needed additional inventory information from SDWIS/FED, and
appropriate supplemental information, where needed. The 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, secure
system. 

Initial Data Screening/Conversion to Uniform Structures

Each dataset 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 dataset structure will be assessed and converted, if
needed, into an appropriate structure, with each analytical result
occupying a discrete row accompanied by the sample-specific data items.
Data formatting work will be done using Microsoft® Access with the aid
of specialized programs written in Visual Basic.

Communication and Coordination with States

Based on the EPA's experience with data submitted in response to
Six-Year Review 3, the 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 dataset questions
that the EPA or the state may have.

Data Management and Analysis

Data management and analysis includes: quality assurance/quality control
and data review/editing; data analysis and report of findings; and
recordkeeping. These activities take place after the initial state
datasets have been made uniform, and the datasets 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 4 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 datasets 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 datasets. The only data requested and used will be
from state drinking water programs (i.e., official compliance monitoring
data from the regulated drinking water program). All compliance
monitoring samples are collected by trained PWS staff and analytical
results are generated by laboratories that are certified for drinking
water programs. Therefore, some assumptions are made regarding the
general quality of the raw compliance monitoring data received from the
states. Data problems will certainly exist, but efforts will be taken to
reduce the problems and increase the dependability and quality of the
state occurrence data used in these analyses. 

The number of systems with compliance monitoring data in each state will
be checked against total system inventory numbers from SDWIS/FED, and
other more appropriate supplemental information, where needed. The
number of analytical records per system (per contaminant) will also be
evaluated to assess completeness of the submitted analytical records.
Contaminant-specific analytical values are also assessed as part of the
QA/QC review. For example, the assessment of the range of all analytical
values for a specific contaminant supports identification of possible
analytical unit errors or the presence of outliers. Identified errors
that do not have straight-forward solutions will be addressed through
consultations with state data management staff to ensure consistent and
appropriate interpretations. Once data quality issues are resolved, each
dataset 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 previous two Six-Year
Reviews, the EPA developed and used a data management and two-staged
analytical approach to assess data representativeness and to analyze the
compliance monitoring data submitted by states. This approach will also
be used for the fourth Six-Year Review for the chemical, radiological,
and microbiological contaminants. States' compliance monitoring data
will be assessed and compiled into a dataset that is indicative of
national occurrence. The national dataset 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 estimates
long-term mean concentrations of contaminants in all systems (and the
corresponding affected populations) nationwide above levels of
regulatory interest. A national contaminant occurrence report will then
be prepared that describes the national contaminant occurrence dataset
compiled, the data management procedures conducted to develop the
national dataset, and the statistical analytical methods employed (using
the national dataset) to generate national estimates of regulated
contaminant occurrence in public drinking water systems.

The compliance summaries collected for the Total Coliform Rule, Revised
Total Coliform Rule, Ground Water Rule, Surface Water Treatment Rules,
Long Term 1 and 2 Enhanced Surface Water Treatment Rule (LT1 and LT2),
Stage 1 and 2 Disinfectants and Disinfection Byproducts Rule (DBPRs) and
Filter Backwash Recycling Rule (FBRR) will be evaluated to determine
regulation effectiveness.

Recordkeeping: The EPA will store and track the original raw (before
QA/QC) datasets that it receives from states, final datasets used for
the Six-Year Review 4 analyses, and logs of all data QA/QC and editing
conducted on the original datasets. After final review, formatting, and
analysis of the data collected through this ICR, a summary of the data
will be made available to the public through the NCOD, as was done with
the data collected and analyzed for the Six-Year Review 3.

5(b)	Collection Methodology and Management

Through the Six-Year Review process, the EPA reviews and assesses risks
to human health posed by existing drinking water contaminants. The
collection of the occurrence data, and the quantity, coverage,
representativeness, treatment techniques and management of the data
collected pursuant to this ICR is an important component of the planned
Six-Year Review 4 process.

The EPA considered developing a nationally representative probabilistic
survey in lieu of requesting data from all states. The EPA assessed
numerous survey designs that were intended to meet different data
quality objectives (DQOs) and found no single design that would allow
the Agency to acquire a nationally representative aggregation of
compliance monitoring data and treatment technique information for all
NPDWRs in an efficient or reasonable manner.  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 six years of historic
compliance monitoring data); or from states (to extract the system-level
data for each of the systems selected in the survey). Further, the EPA
would expect an increased non-response rate if data were requested
directly from systems. 

Based on the EPA's experience working with the states that submitted
complete compliance monitoring datasets for the previous two Six-Year
Reviews, the EPA anticipates that the burden on the states may be
smaller when simply requesting all data records, as compared to
requesting dozens or hundreds of specific records for select individual
PWSs. 

Monitoring schedules can vary across contaminants and across systems,
and can be quarterly, annual, triennial, or every nine years. Actual
contaminant-specific sampling frequencies are unknown and are,
therefore, difficult to address in any survey design. (Different
sampling frequencies are attributed to waiver programs and historical
results showing contaminant occurrence (or lack of occurrence). 

An alternative to a single survey for all NPDWRs would be multiple
surveys for groups of related contaminants as well as treatment
techniques. The EPA, however, anticipates that the burden for the 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
the EPA and made available to the public upon request, as required by
the Freedom of Information Act (40 CFR, Chapter 1, Part 2). A summary of
the data, after a complete and thorough QA/QC review, will be available
to the public through the EPA's NCOD.

As with Six-Year Review 3, for Six-Year Review 4, all states are being
asked to submit their data through a secure system at EPA’s National
Computer Center. The system offers a high level of data security and
capacity for large amounts of data, hence, the EPA anticipates that
most, if not all, states will have computer/Internet resources that will
allow them to submit datasets electronically. 

Regarding dataset file formats, the EPA will request that
non-SDWIS/State users submit their datasets in one of the following the
EPA-compatible file formats:  Dbase (.dbf); Access tables (.mdb or
.accdb); comma or tab delimited files (such as .csv or .txt), or; Excel
(.xls or .xlsx). In addition, the EPA's preferred dataset structure is
for the data to be formatted with each analytical result occupying a
discrete row, accompanied by the system inventory and sample-specific
data items listed above in 4(b)(i). The EPA will also request that
non-SDWIS/State users provide: a brief description of the basic format
and structure of each dataset; and definitions of all data elements,
column/row headings, codes, acronyms, etc., used in each dataset. The
EPA expects 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 the EPA. If
states only submit the minimum data element information, the EPA will
extract the additional inventory information from SDWIS/FED, based on
the PWSID number. 

Other communications and confirmations (regarding dataset follow-up
questions with state data management staff, etc.) will be primarily
handled through telephone and e-mail.

5(c)	Small Entity Flexibility 

Since only state drinking water agencies will be asked to submit
existing electronic data to the EPA, no small entities, and specifically
no small PWSs, will incur burden as a result of this data request.

5(d)	Collection Schedule

The EPA is issuing this ICR as a one-time data request from the states
for regulated monitoring data for 2012-2019. States will be asked to
respond to this request in 2020. Data analysis is expected to continue
through 2022, when the EPA plans to release its final review results for
Six-Year Review 4.

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section describes the estimated average annual burden and costs for
the information collection activities in support of Six-Year Review 4.
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 EPA's burden and cost estimates are outlined in Section 6(c).

To estimate the costs, the 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. The EPA emphasizes that the
per-respondent estimates represent the average burden and cost over the
3-year period covered by this ICR (2020-2022). Some respondents may
incur higher costs and some will fall below the average. Summary burden
and cost estimates for states and the EPA are provided in Exhibits 6-1
and 6-2. Detailed estimation tables for states and the EPA are provided
in Appendices A and B, respectively.

Based on submissions in Six-Year Review 2, estimates of state and the
EPA burden are influenced by state data management capabilities and the
likelihood of submitting the requested data. The EPA's assessments of
individual state data capabilities and likeliness to participate are
based on Agency experience conducting data verifications in state
program offices, as well as other direct knowledge of data capabilities
and resources. To estimate burden, the EPA organized states into 4
categories of expected burden level, as follows:

Submit occurrence data using proprietary software - 6 states. These
states are expected to spend the most time reading and considering the
request for data, as they may need to identify which of their data
elements correspond to those requested. For similar reasons, compilation
and submission of their occurrence data and treatment technique
information and follow-up with the EPA is expected to be the highest.
The EPA expects that Agency burden, which is estimated primarily on a
per State basis, will be higher for these states. 

Submit occurrence data using a combination of SDWIS/State software and
proprietary software - 10 states. These states are expected to spend
more time reading and considering the request for data, as they may need
to identify which of their data elements from which data system
correspond to the data requested. For similar reasons, compilation and
submission of their occurrence data and treatment technique information
and follow-up with the EPA is expected to be somewhat higher than states
using only SDWIS/State. The EPA expects that Agency burden, which is
estimated primarily on a per state basis, will be higher for these
states. 

Submit occurrence data using SDWIS/State software - 38 states. Those
with or planning to use SDWIS/State are expected to spend less time than
states with proprietary software. Reading and considering the request
for data is expected to be less time- consuming, as the SDWIS/State data
elements will correspond closely to the data requested. Compilation and
submission of their occurrence data and treatment technique information,
and follow-up with the EPA is also expected to be easier for these
states. The EPA will provide the states with extraction scripts for
SDWIS/State database, thus data extraction is also expected to be easier
for these states. The EPA expects that Agency burden, which is estimated
primarily on a per state basis, will be lower for these states. 

Will not submit data - 2 States. States that do not have the requested
data stored electronically or those that are considered generally not
likely to submit data are expected only to spend a minimal amount of
time considering the request. No further burden is assumed. The EPA will
incur no burden for these states. 

6(a)	Estimating Respondent Burden 

The average annual respondent burden (in labor hours) for states is
shown in Exhibit 6-1. Appendix A provides detail of the estimated
respondent burden for states to complete the activities described in
section 4(b)(ii). There is no burden for public water systems. Over the
ICR years of 2020-2022, the EPA estimates a total average annual
respondent burden of 765 hours for activities associated with this
reporting effort; or an average of 13.7 hours per state (765 hours
divided by 56 states). This estimate includes costs for reading and
understanding the EPA's request, compiling and submitting the data to
the EPA, and any needed follow-up with the Agency to address questions
regarding the data. 

Reading/Understanding the EPA's Request

The EPA assumes that all states will read the Agency's request letter. A
one-time burden for states that will submit data with proprietary
software is estimated at 7 hours; states with SDWIS/State are estimated
to spend 4 hours; those states with a mix of proprietary software for
some rules, and SDWIS/State for others is estimated at 5 hours; and
states that will not submit data are estimated to spend 1 hour.

Compiling and Submitting Monitoring Data

State burden for this reporting activity is likely to vary widely
depending on the level of effort each state chooses to invest. All
states will follow a security protocol when submitting data through a
designated, secure system. Burden for states that will submit with
proprietary software is estimated at 44 hours. Those states with a mix
of proprietary software for some rules, and SDWIS/State for other rules,
is estimated at 34 hours. States with SDWIS/State are estimated to spend
24 hours.

Follow-up with the States

The EPA expects that those states that use or are planning to use
SDWIS/State or provide their data in the requested format with an
explanation of their codes, headers, etc., will need to spend little
follow-up time with the Agency. 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 the EPA.
States with proprietary software are estimated to spend 13 hours of
follow-up time with the EPA. Those states with a mix of proprietary
software for some rules, and SDWIS/State for other rules, is estimated
at 11 hours. States with SDWIS/State are estimated to only to require 8
hours of follow-up.

6(b)	Estimating Respondent Costs 

Exhibit 6-1 shows the annual average costs for states over the ICR
period of 2020-2022. 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 $43,021. Respondents will not incur capital or
operations and maintenance (O&M) costs associated with this ICR. The EPA
estimates each state will incur an annual average labor cost of $768 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
U.S. General Accounting Office used a previous version of this model to
estimate nationwide drinking water program needs for Congress. The tool
was later updated and improved based on comments from 27 states. To make
the model easier to use, ASDWA established suggested salary and benefit
ranges (i.e., default values), resource needs for the various NPDWRs,
and other key variables. Labor costs per hour are based on the default
annual rates for 2010, which are provided in the model. These default
rates are estimated forward from 2010 to 2019 using a 1-3% inflation
factor for each year, using the Bureau of Labor Statistics Employment
Cost Index data from 2010 to 2017 labor costs and adding an inflation
rate of 3% for 2018 and 2019; 2020 is expected to be the year that data
is submitted.

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 2020-2022)





	Burden Hours

Labor Costs

	Number of States	All States	Per State	All States	Per State

56	765	13.7	$43,021	$768



6(c)	Estimating Agency Burden and Costs 

The EPA's drinking water program in the Agency’s Headquarters will
incur burden and costs for the coordination and implementation of this
data collection effort. Cost and burden estimates for the EPA's
activities associated with this request are detailed in Exhibit 6-2 and
Appendix B. 

6(c)(i)	Agency Burden

For the 3-year ICR period (2020-2022), the EPA estimates that the
average annual burden to the Agency will be 3,143 hours. This estimate
includes burden incurred by the EPA or its contractors for the
activities outlined in Section 5(a) above. The EPA burden is estimated
based on similar activities conducted during the Six-Year 3 occurrence
data analysis.

Extract or Download Data

The 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, the EPA estimates that it will
need:  

11 hours per state for those 38 states that use or are planning to use
SDWIS/State, and 

17 hours per state for the 16 states that use either all proprietary, or
a mix of proprietary and SDWIS/State.

Initial Data Screening/Conversion to Uniform Structures

The EPA's data screening and conversion is also estimated on a per state
basis. Based on its experience during Six-Year 2, the 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. The EPA estimates that it
will need:  

36 hours per state for those 38 states that use or are planning to use
SDWIS/State; and 

71 hours per state for the 16 states that use either all proprietary, or
a mix of proprietary and SDWIS/State.

Communication and Coordination with States

The EPA assumes that the need to communicate and coordinate with states
to ensure successful data submission and interpretation will require
less burden for those states with SDWIS/State than for those with a
proprietary database. The EPA estimates that it will need:  

6 hours per state for those 38 states that use or are planning to use
SDWIS/State; and 

11 hours per state for the 16 states that use either all proprietary, or
a mix of proprietary and SDWIS/State.

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 recordkeeping. Although some of these tasks take
place after state datasets have been combined for analysis on a per
contaminant basis (versus a per state basis), the EPA has estimated a
"per state" burden with the assumptions that 54 states will participate,
and that approximately 45 contaminants will be fully analyzed for
occurrence (i.e., undergo both Stage 1 and Stage 2 occurrence analysis
as described in section 5(a) of this document). Based on prior similar
activities, the EPA estimates 100 contractor and 30 the EPA hours for
each of the 45 contaminants. To present this on a per state basis (as
all other activities are shown), these 5,850 hours (130 hours x 45
contaminants) are divided by 54 states (i.e., the number of states
expected to participate), which equals approximately 108 hours per
state. However, because burden for the occurrence analyses and treatment
techniques will not vary greatly with the addition or subtraction of
state datasets, burden would not be reduced or increased by the
approximately 108 hours with each addition or subtraction of a state.
This is because the analyses are conducted on a per contaminant basis,
and the amount of data analyzed for each contaminant does not greatly
factor into the amount of time needed to run the analyses and write-up
the outcome. In addition, burden for this activity is not influenced by
whether data came from SDWIS/State or another database, because data at
this step in the process has already been cleaned and converted to
uniform structures.

6(c)(ii)	Agency Cost

For the ICR period of 2020-2022, the EPA's 3,143 annual burden hours are
associated with annual labor costs of $408,763 to collect and analyze
the occurrence data and treatment technique information and evaluate and
report on the findings. Direct the EPA per hour labor costs were derived
using the Office of Personnel Management January 2018 General Schedule
(GS) Pay Scale for government employees in the D.C. area. The EPA used
the GS-13 Step 5 salary of $109,900 per year, and by adding the standard
government overhead factor of 1.6 (as well as a 3% annual inflation
factor per year to account for 2020 salaries), the average hourly rate
is estimated to be $89.68 per hour. Contracted labor costs are based on
historical hourly costs pertaining to the management and analysis of
occurrence data, which were approximately $135.90 per hour.

Exhibit 6-  SEQ Exhibit_6- \* ARABIC  2 :  Annual EPA Burden and Costs

(for ICR period of 2020-2022)





	EPA Burden Per State

Annual EPA1

	Activity	(38 SDWIS States)	(16 Non-SDWIS States)	Burden Hours	Cost

Extract/download data	11	17	230	$29,987

Initial data screening/conversion to uniform structures	36	71	835
$112,796

Communicate, coordinate with States	6	11	135	$17,666

Data Mgt and Analysis:  QA/QC; review/edit data; analyze/report
findings; recordkeeping	108	108	1,944	$248,313

Total	161	207	3,143	$408,763

1 Burden is calculated by: per state burden, times number of states, all
divided by the 3 ICR years. Cost is calculated by burden times the
hourly labor rates (EPA or Contractor, as appropriate). See Appendix B,
Exhibit B-1, for details on EPA burden and cost estimations.

6(d)	Estimating the Respondent Universe and Total Burden and Costs 

The only respondents for this ICR are states. (The terms “state” or
“states” refers to primacy agencies in states of the United States,
the District of Columbia, the Commonwealth of Puerto Rico, the Virgin
Islands, Guam, American Samoa, the Commonwealth of the Northern Mariana
Islands, the Trust Territory of the Pacific Islands, or an eligible
Indian tribe.) 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. EPA’s burden and costs are
detailed in Section 6(c) and in Exhibit 6-2.

6(e)	Bottom Line Burden Hours and Cost Tables 

The bottom line burden hours and costs for this ICR are shown in Exhibit
6-3. This includes the burden and costs to the 56 states that are
affected by this ICR, as well as the burden and cost to the EPA for this
collection and analysis. 

 

Exhibit 6-  SEQ Exhibit_6- \* ARABIC  3 :  Bottom Line Burden and Costs

(for ICR period of 2020-2022)



	Total	Average Per Year over 

2020-2022

Number of Respondents (States)	56 States	n/a

Total Responses	56	18.7

Number of Responses per State	1	0.3

Total State Burden Hours	2,296	765

Hours per Response (Total hours from above/Number of Respondents from
above)	41	13.7

State Labor Costs	$129,065	$43,021

State O&M Costs	$0	$0

Total State Costs (Labor plus O&M costs)	$129,065	$43,021





Agency Total of Hours	9,430	3,143

Agency Labor Costs	$1,226,289	$408,763

Agency Non-Labor Costs	$0	$0







6(f)	Reasons for Change in Burden

Based on information received through the EPA’s consultation with
ASDWA, the EPA has updated Texas from a state that is likely to use
SDWIS/State to a state that is likely to use a combination of
proprietary software and SDWIS/State to store data, and therefore, the
EPA has also updated the burden hours for Texas to reflect this new
information. Labor costs have been adjusted to reflect inflation.

RTCR data collection is not expected to add any additional burden
because: 

the routine monitoring frequencies remained the same as under the TCR
and the number of repeat samples collected were reduced; and

the EPA is not requesting RTCR Level 1 and Level 2 Assessment data in
this information request. 

The EPA conservatively estimates the same monitoring data burden as
collected under the TCR since the Agency is uncertain how much the
burden may decline for some states. States using SDWIS/State will not
have any burden change because the time taken to use the data extraction
tool does not change. The 17 states depending upon proprietary software
will be providing the same or less volume of data as compared to what
was collected under TCR. With respect to RTCR Level 1 and 2 Assessment
data, SDWIS/Fed already collects sufficient information about Level 1
and 2 Assessments for Six-Year Review purposes and so the EPA does not
require an additional request for information in this ICR. 

6(g)	Burden Statement 

The reporting burden for data collections included in this ICR is
detailed above. The total annual respondent burden (for years 2020-2022)
imposed by these collections is estimated to be 765 hours, or 13.7 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 EPA expects that most, if not all, respondent activities
will take place during 2020. Estimates include time for submitting data
to the EPA and addressing questions raised by the Agency regarding the
submitted information.

Burden means the total time, effort, or financial resources expended by
people to generate, maintain, retain, disclose, or provide information
to or for a federal agency. This includes the time needed to review
instructions; develop, acquire, install, and utilize technology, and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information. 

An agency may not conduct or sponsor, and a person is not required to
respond to, a request for information collection unless it displays a
currently valid OMB control number. The OMB control numbers for the
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,
the EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OW-2018-0241, which is available for public viewing at the Water
Docket in the EPA Docket Center (EPA/DC), EPA West Building, Room 3334,
1301 Constitution Ave., NW, Washington, DC 20004. The EPA Docket Center
Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through
Friday, excluding legal holidays. The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the Docket is (202)
566-2426. An electronic version of the public docket is available
through regulations.gov. Use regulations.gov to submit or view public
comments, access the index listing of the contents of the public docket,
and access those documents in the public docket that are available
electronically. Once 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, DC 20503, Attention: Desk
Office for the EPA. Please include the EPA Docket ID No.
EPA-HQ-OW-2018-0241 and OMB control number 2040-NEW in any
correspondence.



APPENDICES

Appendix A:  Detailed Burden and Cost for States 

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



Average Burden Per State



Labor Costs



State	Likely to Submit Data?	Reading EPA Request	Compiling, Submitting
Data	Follow-up with EPA	Total Burden	State Program Size	Cost per Hour
Labor Cost per State

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

Alabama	Likely/SS	4	24	8	36	s 	$50.79	$1,828

Alaska	Likely/SS	4	24	8	36	m	$54.71	$1,970

American Samoa	Likely/Non-SS	7	44	13	64	vs	$51.61	$3,303

Arizona	Likely/SS	4	24	8	36	m	$54.71	$1,970

Arkansas	Likely/SS	4	24	8	36	m	$54.71	$1,970

California	Likely/SS	4	24	8	36	vl	$89.38	$3,218

Colorado	Likely/SS	4	24	8	36	m	$54.71	$1,970

Connecticut	Likely/SS	4	24	8	36	m	$54.71	$1,970

Delaware	Likely/SS	4	24	8	36	vs	$51.61	$1,858

District of Columbia	Likely/SS	4	24	8	36	s	$50.79	$1,828

Florida	Likely/Non-SS	7	44	13	64	l	$63.22	$4,046

Georgia	Likely/SS	4	24	8	36	m	$54.71	$1,970

Guam	Likely/SS	4	24	8	36	vs	$51.61	$1,858

Hawaii	Likely/SS	4	24	8	36	vs	$51.61	$1,858

Idaho	Likely/SS	4	24	8	36	m	$54.71	$1,970

Illinois	Likely/SS	4	24	8	36	l	$63.22	$2,276

Indiana	Likely/SS	4	24	8	36	m	$54.71	$1,970

Iowa	Likely/Mixed- SS	5	34	11	50	m	$54.71	$2,736

Kansas	Likely/SS	4	24	8	36	m	$54.71	$1,970

Kentucky	Likely/SS	4	24	8	36	s	$50.79	$1,828

Louisiana	Likely/SS	4	24	8	36	m	$54.71	$1,970

Maine	Likely/Mixed- SS	5	34	11	50	s	$50.79	$2,540

Maryland	Likely/SS	4	24	8	36	m	$54.71	$1,970

Massachusetts	Likely/Non- SS	7	44	13	64	m	$54.71	$3,501

Michigan	Likely/SS	4	24	8	36	l	$63.22	$2,276

Minnesota	Likely/Non-SS	7	44	13	64	m	$54.71	$3,501

Mississippi	Likely/SS	4	24	8	36	m	$54.71	$1,970

Missouri	Likely/Mixed- SS	5	34	11	50	m	$54.71	$2,736

Montana	Likely/Mixed- SS	5	34	11	50	m	$54.71	$2,736

Nebraska	Likely/SS	4	24	8	36	s	$50.79	$1,828

Nevada	Likely/SS	4	24	8	36	s	$50.79	$1,828

New Hampshire	Likely/Non- SS	7	44	13	64	m	$54.71	$3,501

New Jersey	Likely/SS	4	24	8	36	m	$54.71	$1,970

New Mexico	Likely/SS	4	24	8	36	s	$50.79	$1,828

New York	Likely/SS	4	24	8	36	l	$63.22	$2,276

North Carolina	Likely/SS	4	24	8	36	l	$63.22	$2,276

North Dakota	Likely/SS	4	24	8	36	vs	$51.61	$1,858

Northern Mariana Islands	Likely/SS	4	24	8	36	vs	$51.61	$1,858

Ohio	Likely/SS	4	24	8	36	l	$63.22	$2,276

Oklahoma	Likely/SS	4	24	8	36	m	$54.71	$1,970

Oregon	Likely/SS	4	24	8	36	m	$54.71	$1,970

Pennsylvania	Unlikely	1	0	0	1	l	$63.22	$63

Puerto Rico	Likely/SS	4	24	8	36	s	$50.79	$1,828

Rhode Island	Likely/Mixed- SS	5	34	11	50	vs	$51.61	$2,581

South Carolina	Likely/SS	4	24	8	36	m	$54.71	$1,970

South Dakota	Likely/Non- SS	7	44	13	64	s	$50.79	$3,251

Tennessee	Likely/Mixed- SS	5	34	11	50	m	$54.71	$2,736

Texas	Likely/Mixed-SS	7	44	13	64	vl	$89.38	$5,720

Utah	Likely/SS	4	24	8	36	s	$50.79	$1,828

Vermont	Likely/SS	4	24	8	36	s	$50.79	$1,828

Virginia	Likely/Mixed- SS	5	34	11	50	l	$63.22	$3,161

Virgin Islands	Likely/Mixed- SS	5	34	11	50	vs	$51.61	$2,581

Washington	Unlikely	1	0	0	1	l	$63.22	$63

West Virginia	Likely/SS	4	24	8	36	s	$50.79	$1,828

Wisconsin	Likely/Non-SS	7	44	13	64	l	$63.22	$4,046

Wyoming	Likely/Mixed- SS	5	34	11	50	vs	$51.61	$2,581

TOTAL

248	1526	494	2296

	$129,065



Annual Ave. 2020-2022

	765

	$43,021



Annual Ave. Per State 2020-2022

	13.7

	$768



(a) States divided into four major groups based on type of Six-Year
Review 2 submission: likely to provide data (indicated by "Likely/SS"
(38 states), "Likely/Mixed-SS" (9 states) or "Likely/Non-SS" (7
states)); and those that are unlikely to provide data (indicated by
"Unlikely" (2 states)). Likely/SS (SDWIS/State) means state stores all
or most of (or are planning to store all or most) data using
SDWIS/State. Likely/Non-SS means state provided data to the EPA for the
second Six-Year Review and had a strong record of electronic reporting
but does not use SDWIS/State for all data management. Likely/Mixed-SS
means state uses a combination of proprietary software and SDWIS/State
to store data. All others assigned "Unlikely." Total of 56 potential
participating states.

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

Exhibit A-2:  Estimated 2019 Salaries and Overhead Costs from ASDWA
State Resource Model

	Professional Staff	Support 

Staff	Hourly Ave. ~ 

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

overhead at 23%)

State Size (a)	(adjusted for fringe benefits at 22% of base salary)





Very Small (applies to 9 States, including VI, GU, AS, NM)	$80,888
$54,114	$41.96	$51.61

Small (applies to 12 States, including DC and PR)	 $81,142	$47,034
$41.29	$50.79

Medium (applies to 23 total)	 $86,761	$53,260	$44.48	$54.71

Large (applies to 10 total)	 $97,950	$70,798	$51.40	$63.22

Very Large (applies to 2 total)	 $144,184	$77,262	$72.67	$89.38

(a)  State labor costs are from the "2001 ASDWA Drinking Water Program
Resource Needs Self Assessment". In 2000, the United States General
Accounting Office used a previous version of this model to estimate
nationwide drinking water program needs for Congress. The tool was later
updated and improved based on comments from 27 states. To make the model
easier to use, ASDWA established suggested salary and benefit ranges
(i.e., default values), resource needs for the various NPDWRs, and other
key variables. These hourly estimates are based on the default annual
rates for 2010 that are provided in the model. These default rates are
estimated forward from 2010 to 2019 using a 1-3% inflation factor each
year using the Bureau of Labor Statistics Employment Cost Index data
from 2010 to 2017 labor costs and then inflated 3% for 2018 and 2019.
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 the EPA  TC "Appendix B:  Detailed
Burden and Cost for EPA" \f C \l "1"  

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

	SDWIS and Non-SDWIS States

Contractor Burden





Contractor Labor Cost



	Activity	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)

Extract or download data (r)	38	16	9	15	342	240	582	$135.90	$46,478
$32,616

$79,094

Initial data screening/conversion to uniform structures	38	16	35	70
1,330	1,120	2,450	$135.90	$180,747	$152,208

$332,955

Communicate and coordinate with the States	38	16	5	10	190	160	350
$135.90	$25,821	$21,744

$47,565

Data Management and Analysis: QA/QC; review/edit data; analyze/report
findings; 

recordkeeping	38	16	83	83	3,154	1,328	4,482	$135.90	$428,629	$180,475

$609,104

TOTAL	38	16	132	178	5,016	2,848	7,864	$135.90	$681,674	$387,043

$1,068,718





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

	EPA Burden



	EPA Labor Cost



EPA and Contractor Totals



	Activity	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)

Extract or download data (r)	2	2	76	32	108	$100.62	$7,647	$3,220	$10,867
11	17	690	$89,961

Initial data screening/conversion to uniform structures	1	1	38	16	54
$100.62	$3,824	$1,610	$5,433	36	71	2,504	$338,388

Communicate and coordinate with the States	1	1	38	16	54	$100.62	$3,824
$1,610	$5,433	6	11	404	$52,998

Data Management and Analysis: QA/QC; review/edit data; analyze/report
findings; 

recordkeeping	25	25	950	400	1,350	$100.62	$95,589	$40,248	$135,837	108
108	5,832	$744,941

TOTAL	29	29	1,102	464	1,566	$100.62	$110,883	$46,688	$157,571	161	207
9,430	$1,226,289









 	  	Annual Ave.	2020-2022	3,143	$408,763

(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, these 4,500 hours (100 hours x 45 contaminants)
are divided by 54 states (i.e., the maximum number of states expected to
participate), which approximately 83 hours per state. Similarly, 30 EPA
hours for each of the 45 contaminants are shown as 25 hours per state.
Thus, total estimated burden per state for this activity is
approximately 108 hours. However, burden for the analyses will not vary
greatly with the addition or subtraction of state datasets; and burden
would not be reduced or increased by the approximate 108 hours with each
addition or subtraction of a state. The other 3 listed aspects of the
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 53/state for SDWIS/States from columns (c) and
(l), and 99/state for Non-SDWIS/State from columns (d) and (m)) 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
$135.90 per hour.

(q) The 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 Washington-Baltimore-Northern Virginia,
DC-MD-VA-WV-PA rate schedule effective January 2018 (see the U.S. Office
of Personnel Management website:  www.opm.gov). With these assumptions,
labor rates were based on a 2,080-hour work year, with a $109.900 annual
salary during 2018 (most current available) plus 60 percent overhead,
and then carried forward to 2020 using a 3% annual inflation factor, to
arrive at $89.68 per hour.

(r) For the majority of the NPDWR data being requested, there are
approximately 38 states are using or planning to use SDWIS/State for
data storage and management, and 16 using a proprietary data system or a
combination of SDWIS/State and a proprietary data system. For estimation
purposes, the EPA makes the conservative assumption that state burdens
will vary with their primary data system (i.e., the 16 states using
primarily a proprietary data system, or a combination of data systems
are assumed to incur more burden than if they were primarily using
SDWIS/State).

(u) The total EPA and contractor hours for all states for Data
Management and Analysis 5,832 is different from that stated on p.23 by
18 hours and that is due to rounding of input numbers. 

In the remainder of this document, the terms “state” or “states”
refers to primacy agencies in states of the United States, the District
of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam,
American Samoa, the Commonwealth of the Northern Mariana Islands, the
Trust Territory of the Pacific Islands, or an eligible Indian tribe.

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Page   PAGE  iii  of iii

Draft Six-Year 4 ICR	October 2019

Page   PAGE  34  of 34

Draft Six-Year 3 ICR	October 2019

