United States
       Environmental Protection    Office of Water      EPA 81 6-P-01-001
       Agency             4606           February 2001

v>EPA  Options for the Office of Ground
        Water and Drinking Water
        Information Strategy
       (Working Draft)
         Background Document for the
         Information Strategy Stakeholders Meeting
         March 8-9, 2001
         Washington, DC

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DISCLAIMER

The Options paper represents an effort by EPA staff to consolidate into a single working draft a
number of suggestions and ideas generated by the Office of Ground Water and Drinking Water's
Infrastructure Branch. This draft will be subject to extensive revision, development and
qualification as the Agency proceeds through both external public and internal EPA deliberative
processes. The information presented in this document is a discussion of possible options
available to the EPA and should not be interpreted as EPA policy.

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                   Table of Contents

                                                                     Page
Executive Summary                                                    4
Part I: Overview                                                       5
Part II: Vision, Mission, Scope and Principles                               5
Part IE: Revising OGWDW s Information Strategy                          6
      A. Driving Forces for Change                                      6
             1. Age and Cost of Maintaining Existing System
             2. Changing Information Needs and Focus
             3. Decisions Needed
             Textbox: SDWIS/STATE Cost Comparison                   8
      B. Challenges to Modernization and OGWDW s Response             9
PART IV: Areas for Discussion                                          10
      A. Defining Data Needs and Uses                                   10
      B. Reporting                                                    12
      Textbox:     Drinking Water Data Management Steering Committee
                   Draft Work Plan                                    14
      C. Improving System Performance                                  16
      Textboxes:    SDWIS/FED Challenges                             17
                   SDWIS/ONE Recommendations                       18
      D. Improving Data Quality                                        19
      Textbox:     Possible Future Platform for OGWDW Data Systems     20
      E. Data Access                                                  21
      Textbox:     Benefits of Data Warehousing/OLAP             22
      F. System Economics                                             23
PART V: ALTERNATE VISIONS OF FUTURE DATA MANAGEMENT     24
      Table 1. Comparison of Visions for Drinking Water Data               26
PART VI. TIME LINE                                                         27
VII. NEXT STEPS                                                     27
   . APPENDICES                                                    29
      A. Draft Source Water Protection Measures of Progress
      B. Unregulated Contaminant Monitoring Reporting Requirements
      Cl. SDWIS/FED Attributes
      C2. SDWIS/FED DTF Attributes Being Analyzed for Reporting Reduction
      D. Draft Guiding Principles on Information Requirements and Data Management
      E. The Need for  Single, Unique Data Identifiers
      F. FY 2000 IB SDWIS/FED Factoids
      G. Questions and Answers About Section 508 of the Rehabilitation Act Amendments
      H. Geospatial Data and Geographic Information System Technology
      I. U.S. EPA's Safe Drinking Water Goals for 2005

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                                   EXECUTIVE SUMMARY

Information is critical to the management of major national programs and shapes responses to rapidly
changing events in the public health arena.  The Office of Ground Water and Drinking Water must bring
its information management into strategic alignment with the needs of both its internal and external
stakeholders to maintain credibility in a data-driven environment.  Information management in the private
sector provides examples of reduced costs and improved decision support systems using current
technology that can be applied in the public sector.  This Office of Ground Water and Drinking Water
(OGWDW) Information Strategy is a first step in revising its Information Strategic Plan (ISP) to focus on
essential data, reporting and analyses supporting decisions of the national ground water and drinking
water programs to protect public health. The objective of the OGWDW Information Strategy is to
identify a range of actions in the near term to modernize its information systems and to define achievable
direction in the intermediate and longer terms that recognize evolving information needs and technology,
and effective and efficient information management to  support public health protection.

"Driving forces" to revise the OGWDW ISP include: (1) Current infrastructure systems are old and
expensive to modify and maintain, with costs escalating; (2) Transaction costs for data entry and retrieval
are high; (3) Current systems are not responsive to program requirements driven by the 1996
Amendments to the Safe Drinking Water Act, such as new regulations required by the Act; (4)  Data are
incomplete from an Office of Water perspective, only focusing on Public Water Supply Supervision
program violations data without similar levels of coverage for  Source Water Protection (e.g., essentially
no regulated contaminant parametric data), Underground Injection Control (UIC) and State Revolving
Fund programs; (5) Because information systems do not share common data elements, linkages to other
significant data sources within the Office of Water and outside EPA are difficult or nonexistent; and (6)
Office of Water information investment policy and Office of Environmental Information standards will
guide future OGWDW information management decisions.

A "paradigm shift" in information management and associated decisions are fundamental to allow
OGWDW to respond to internal and external data and analytical needs and to control costs. To address
this needed shift, OGWDW will consider options relating to:

 - Acquiring parametric data
 - Implementing a new information requirements assessment as part of the regulation development
process
 - Reaching agreement with states to simplify multiple reporting options and therefore reduce complexity
and cost
 - Streamlining SDWIS-FED and STATE to reduce costs in long term after near term investment
 - Integrating NCOD, ICR, SDWARS  and other sealed  up systems to reduce costs
 - Web-enabling SDWIS-STATE to allow states to more easily report data (at initial cost to EPA, but a
long-term savings to both  EPA and states)
 - Improving public access for ad hoc and PWS queries
 - Continuing to work with states to implement data reliability plan
 - Completing revision of Information  Strategy Plan
 - Integrating systems based on function and business need
 - Implementing the EPA/OEI-ECOS data exchange network (SDWIS-FED data submission is very close
to this network model)

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PART I: OVERVIEW

Information is critical to the management of national programs and shapes responses to rapidly
changing events in the public health arena. Sound science and the best available data are the
foundation of decisions that the EPA's Office of Ground Water and Drinking Water (OGWDW)
makes to protect public health and the environment. Information technology has improved, and
the process for developing drinking water standards has changed  significantly since OGWDW
developed its most recent information strategy in 1992. EPA must implement a new strategy that
responds to evolving technology and regulatory needs, maximizes efficiency and minimizes cost
of data transactions, meets national water program needs, and links efficiently to relevant data
sources. The strategy must be business-driven, incorporating the needs of stakeholders both
inside and outside of EPA.

EPA encourages public input into questions that will allow OGWDW to make more informed
decisions regarding its Information Strategy. Once implemented,  the strategy will help OGWDW
to better focus on essential business data, minimizing reporting burden for the necessary data,
obtain early involvement in information requirements for regulations, streamline the federal Safe
Drinking Water Information System (SDWIS-FED) to reduce reporting errors, continue to
support the state Safe Drinking Water Information System (SDWIS-STATE), and provide an
information framework for source water protection. Questions for discussion involve issues of
data use and needs, reporting, system performance, data quality, data access and system
economics.

PART II: VISION. MISSION. SCOPE and PRINCIPLES

A. National Water Program Management Vision:
       The Information Management program supports the management and operations of the
National Water Program's mission to protect public health and water resources by delivering
useful information to decision makers and the public.

B. OGWDW Information Strategy Mission:
       OGWDW's information systems will effectively and efficiently support the overall
program needs to protect public health by providing support to the program designed to prevent
contamination of source waters and protect drinking water supplied to consumers, through:
•      Defining efficient and effective information requirements based on essential business
       needs
•      Synthesizing data for OGWDW decision-makers to manage programs, including
       development of policies to prevent contamination of source waters
•      Enabling scientists and analysts to better assess existing regulations as well as
       determining the need for new regulations
•      Managing and tracking the use of State Revolving Fund resources
       Utilizing enforcement resources to return non-compliant water systems to compliance
•      Providing information to the public in readily-accessible form.

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C. Scope:
       OGWDW's information systems will obtain drinking water and source water data
relevant to public health protection through appropriate means from the regulated community,
support measurement of program progress and decisions affecting compliance of the regulated
community and program management and direction, including standards development and
regulation review, and provide reliable information to the public, over the next five years.

D. Principles:
•      Keep processes and systems simple
       Base systems development on essential business need
•      Contain information system costs
       Minimize reporting burden for public water systems (PWS) and states who are key
       stakeholders in this process
       Maintain  support for core requirements, including SDWIS/STATE and new rules
•      Use data standards to provide consistency of data reporting and data sharing
       Improve data quality through documented procedures
•      Involve stakeholders and identify their roles in data use within their business processes
       Ensure easy access to the system for internal stakeholders and the public at all skill levels
•      Ensure tracking and reporting of GPRA measures
       Modernize in components to reflect funding available

PART III:  REVISING OGWDW'S INFORMATION STRATEGY

A. Driving Forces for Change
       The evolving philosophy of information management focuses on improving data quality
and data sharing while utilizing new technology, minimizing costs associated with building onto
older, less efficient systems. In OGWDW, implementation of the drinking water program
changes on a continuing basis as new regulations are established. OGWDW's traditional
response has been to make expensive, patchwork changes to an existing patch worked expensive
system — driving development and maintenance costs ever higher. OGWDW must change its
approach, implementing a new strategy for meeting changing information needs and
philosophies, taking advantage of new technology and keeping costs under control.

       The previous information systems focus was to make reporting data extremely flexible,
allowing for multiple reporting methods.  This has resulted in overly complex and expensive
software and excessive documentation and training. It has also contributed to significant errors in
data submission and expensive maintenance costs to respond to errors, further complicating the
system.

1. Age and Cost of Maintaining  Existing System
•      Current systems are old and expensive; transaction costs for data entry and retrieval are
       too high
•      Patchwork fixes have neglected opportunities for comprehensive solutions, increasing

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systems' costs in the long term and contributing to significant errors and reduced data quality.
•      Opportunities for utilizing new, more efficient technologies exist to improve information
       system effectiveness and efficiency and reduce costs, but constrained resources have not
       allowed modernization.

2. Changing Information Needs and Focus
•      Current information processes and systems are not responsive to program requirements
       driven by the 1996 SDWA amendments, which require new rules, regular review of
       regulations and standards, protecting source water, and an emphasis on the public's right
       to know about their drinking water. As a result, OGWDW cannot measure the success of
       its programs, or of states and public water systems that are linked in its information
       processes.
•      Current data systems focus only on the Public Water System Supervision program, not
       Underground Injection Control and Source Water Protection, or relationships with the
       Drinking Water State Revolving Fund data.
       Emphasis is  on compliance, with insufficient parametric (contaminant occurrence) data
       for reviewing existing regulations and policy development for source water protection
       Basic questions on the quality of drinking water need attention, in particular as they relate
       to complete reporting between states and EPA and credibility regarding the safety of the
       nation's drinking water.

3. Decisions Needed
       Investing in new technology while maintaining the old technology temporarily will be
necessary to improve systems while not interrupting information flow.  This transformation
requires management decisions at federal, regional and state levels, considering ground water and
drinking water program costs, to  address old business steps  that drive up the potential for
reporting error, data nonacceptance, and near-term and long-term federal database costs.  These
decisions include:
a.     A determination to minimize federal database costs only, or total federal and State
       information system costs. This affects the alternate vision for information systems to be
       followed.

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                     SDWIS/STATE Cost Comparison

Initial Development and
Implementation
Operating Costs over next 5
Years (Annual Average)
Other Costs over 5 Years
(Including software
development to meet future
rule reporting)
Option 1
ADOPTS
SDWIS/STATE
$ 230,400
$1,332,500
($266,500)
$300,000
Option 2
DEVELOPS
NEW
SYSTEM
$1,885,400
$1,732,500
($346,500)
$1,900,000
Option 3
MAINTAINS
EXISTING
SYSTEM
$75,400
$1,732,500
($346,500)
$1,900,000
       Notes: 1) These figures are estimates and are not based on actual state experiences.
             2) Costs for Option 1 include the costs for staff, all new computers, and all
             software, and would be substantially reduced by utilizing existing resources.
Clarification of EPA Headquarters, Regional and State roles and responsibilities for data use.
These include: Who owns the data and determines compliance? What level of State and
Regional program tracking should exist?  How to increase program tracking if it is currently
insufficient? What actions/tools should be available to EPA when reporting requirements are
not met? How should States and EPA partner in the reporting process? Should EPA provide
compliance information at the system level, and if so, how complete should these data be?

Whether to offer single response versus multiple options in reporting to EPA (e.g., reporting
compliance at either entry points or the system to EPA, but selecting only one way) and to
make facility identification numbers permanent (or easily traceable to previous numbers -
constantly changing facility numbers created by the information system or the state reduces
data quality and usability and increases transaction costs of determining the correct data).

Related to (a) and (b), determining whether parametric data should replace, or augment
violations data.  Parametric data is essential to the 6-year review of regulations required under
SDWA and to useful analysis to guide source water protection policy.
Transferring enforcement tracking to the Office of Enforcement and Compliance Assurance,
while continuing to supply that office with system compliance results.

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B. Challenges to Modernization and OGWDW s Response

1. Challenge: Ensuring that decisions made today are not outdated when implemented, given
the rapid pace of change in information technology.
       Response: OGWDW undertook a review of the direction of technology on its own and
participated in development an information strategy across the Office of Water. The OW strategy,
which addressed the direction of technology, is linked to the Agency's "National Environmental
Information Exchange Network" Blueprint.1 These three technology reviews (across public and
private sectors, across OW program offices and within OGWDW for its business needs) provide
insight to potential technological directions and suggest how information systems might develop at the
program  office level. The reviews also point to areas within a future OGWDW plan that the office can
address to reduce risk in its decision making for its information systems.

2. Challenge: General mistrust of change due to uncertainty of outcome.
       Response: Although change can be difficult, especially for data users of information systems,
they can often be made transparent to users because of improved technology. Some changes will
hopefully be viewed by users as positive, enhancing use of the data. The driving forces above point to
advantages of making these changes at this time.

3. Challenge: Conflicting findings resulting from use of data for purposes not  originally
intended.
       Response: Some data suppliers are concerned that making data more accessible to the public
will result in the  data being used for purposes not originally intended.  Such "secondary use" of data is
commonplace —  anyone other than the data generator who uses the data is engaging in secondary use.
Actually, some states with data online, available for public access, have found that such use promotes
data quality. Users tend to point out problems in the data sets, thus encouraging the data generator to
be more careful.  These states also found that making the data public for secondary use reduced burden
on state information system staff and resources because the public could find answers to many of its
questions online. Therefore, allowing broader secondary use of the drinking water data may better
inform the public and improve the data quality at the same time. This benefits PWS by promoting
improvements in water quality and increasing consumer confidence.

4. Challenge: Ensuring that funding implementation of a system modernization plan does not
constrain complete, comprehensive action.
       Response: To address the concern about funding sufficiency, EPA will consider using a phased,
prioritized approach to systems development.  This approach will allow OGWDW to identify discrete
aspects of the information system for improvement as funding allows the office to make the
appropriate investments reflecting the priority across its programs.
             U.S. Environmental Protection Agency, Office of Environmental Information. 2000. National
     Environmental Information Exchange Network Blueprint.  This Blueprint describes activities that would need to
     occur to implement the arrangements being developed with the Environmental Council of the States for exchange of
     environmental information between States and EPA.

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5. Challenge: The relation of rule development to the timing of implementation sometimes
results in phased reporting requirements for which further coordination could improve the
delivery of the benefits of the rulemaking process and database reengineering.
       Response: OGWDW will examine the possibility of bundling rules for effective dates and
reporting dates to bring consistent and coordinated management of the rulemaking process. This action
may result in different implementation dates from those originally established. OGWDW believes that
such an approach may result in a more rational and cost-effective program, especially for information
management purposes, and protect public health at local and state levels.  However, a more complete
evaluation of this matter and its tradeoffs is essential first.

PART IV. AREAS FOR DISCUSSION

A. DEFINING DATA USES AND NEEDS
•      How will OGWDW ensure that it has the data it needs to implement its programs,
       address data gaps and coordinate with other EPA programs?
       OGWDW will conduct a comprehensive information requirements process in 2001. This
process will consider existing reporting requirements that may need to be changed because the conduct
of drinking water program business has changed since the early requirements were developed.  It will
also address future program information needs, relative to new rules and business information gaps in
source water protection. The focus of this information requirements process will be on essential data
necessary for program implementation.  In developing its strategy, OGWDW is working with other
entities, particularly the Office of Water, the Office of Environmental Information, and the
Environmental Council of the States (ECCS).
       Currently, OGWDW information systems do not support the Source Water Protection Program.
To address this gap, the program has conducted its own information requirements process in  the course
of preparing its strategy. OGWDW will build on this and refine these information requirements units
processes planned for 2001. A key objective and option is to build on data in existing information
systems that States and the US Geological Survey already have for ambient source water data, rather
than construct a new information reporting process. See Appendix A, "Draft Source Water Protection
Measures of Progress."

       What essential data does the primary enforcement authority need to track?
The primary enforcement authority, either the states and tribes (if they are delegated primacy) or EPA
for non-primacy states and tribes, must be able to ascertain whether the maximum contaminant level or
treatment technique has been met to ensure protection of public health.  Options include:
       1.     Public water systems only report non-attainment of maximum contaminant levels and
             treatment techniques.

       2.     Public water systems report all parametric data to states, tribes or EPA to allow
             determination as the regulation third party (i.e., not a water supplier or customer)

       3.     For treatment techniques, provide some related public water system operating data
             when determined appropriate (e.g., indication of sanitary survey completion)
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       4.     For treatment techniques, provide all decision-related data to the primary enforcement
             agency. This option would have the highest cost at all levels of the reporting process.

       Related questions are: What of this information should be sent to EPA by the state or tribal
primary enforcement authority to allow EPA to carry out its role in a national enforcement capacity?
Can criteria be established to determine this? How should the response to this question be addressed in
the regulation development process?

       What parametric and ancillary data should be reported to make them of greatest use?
Options may include:
       1.     Use only concentration data associated with the appropriate ancillary data
       2.     Use requirements for unregulated contaminant monitoring reporting as a template
       3.     Adopt a modified unregulated contaminant monitoring regulation approach,  since for
             regulated contaminants, the quality controls are incorporated in the methods which have
             been extensively applied. See Appendix B, "Unregulated Contaminant Monitoring
             Reporting Requirements."

•      How should EPA foster improved processes for identification and confirmation of data
       requested by primacy agencies?
       Option 1: Clarify of roles of EPA HQ (and its subdivisions), EPA regions (and their
subdivisions), the states and other stakeholders.  It may be necessary to revisit, revise and confirm roles
and responsibilities of the various EPA headquarters offices responsible for SDWA, states and other
stakeholders. This would allow parties to reach agreement and provide direction for rule reporting that
is consistent from rule to rule, by establishing the kinds of data that EPA needs to fulfill its
responsibilities.

       Option 2: An alternative could be to utilize the requirements that exist in the current
SDWIS/FED system. However, over time, several new regulations were enacted, each with different
data requirements.  For example, reporting for the Lead and Copper Rule required states to report
milestone data so that EPA could evaluate rule implementation status from data other than violations.
No other rule had reporting requirements this extensive.  In addition, since that time it has been
concluded that this data collection effort never afforded EPA the ability to perform such evaluations,
as states did not report the complete set of information, as it was viewed as a large burden.

       Option 3: EPA could conduct special surveys to determine occurrence of contaminants or
compliance with the Safe Drinking Water Act.

•      What data does EPA need to judge and evaluate the success  of its programs?
       Looking only at noncompliance and exception data does not tell us about how the quality of
source and treated water has improved or declined. Parametric data would allow EPA to track
progress, demonstrate the success of its efforts, and evaluate existing regulations. Reporting
requirements for UCMR parametric data are identified in Appendix B. OGWDW's principal
Government Performance and Results Act (GPRA) goals are identified  in Appendix H. Data should
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provide a basis for measuring these goals.

Are there other priority data uses EPA should consider?
EPA would like to make a number of other uses of drinking water data. Currently, because of limits in
data requirements, EPA cannot do the following:
       1. National analyses tailored to conditions that PWSs face , regardless of location. If we can
associate PWSs to the range of watershed or aquifer features, for example, we can tailor rules to these
conditions, or at least recognize that these conditions exist on a consistent basis.
       2. Consistent national analyses of populations with special needs, sensitive subpopulations, low
income, etc.
       3. Associate nationally, intakes or well fields with land practices to do source water protection
analyses and develop national  policy.
       4. Respond to cross-program requests for national source intake or well field locations to relate
to other national programs' proposed actions and come to meaningful conclusions about whether these
proposals would protect drinking water sources.
       5. Include  drinking water data in EPA's new geo-spatial initiatives, which would allow relation
of water uses, water pollution  sources, stream characterization (including 303(d) impaired waters), to
natural, political, and economic parameters affecting drinking water. "Windows on the Environment"
and the National Hydography Dataset are two existing agency-wide initiatives to enhance the public's
right to know environmental and health information, for which drinking water data are necessary.
       6. Provide linkage of data from unregulated contaminant monitoring to potential contaminant
sources.
       5. Link the source water assessments that EPA will receive from the states to the rest of the
environment. Complete and reliable latitude and longitude data would allow us to relate water supplies
to the resources managed and regulated by other national agencies.

B. REPORTING
•      What changes are necessary to ensure we obtain correct data, while minimizing reporting
       burden for existing and upcoming rules?
       Existing Requirements: As OGWDW evaluates the results of the information requirements
process in 2001, it will determine whether any required reporting should be  eliminated and propose
these steps be taken at that time. OGWDW has completed an initial review of existing required data
elements in SDWIS-FED to identify which are reported on and used. This review may result in the
proposal of several data elements for elimination. See Appendix C, "DTP Attributes to be Analyzed
for Reporting Reduction."
Options include:
       1. No changes in reporting systems
       2. Remove reporting requirements where no longer useful - this would involve changing all
       systems, but potentially making them more efficient.

       Rules in the Pipeline (e.g., proposed or newly final rules with pending final reporting
requirements): OGWDW has reviewed regulations recently proposed to identify opportunities for
minimizing PWS  and State reporting requirements. For example, this review has identified options,


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such as certain data being kept by public water systems and made available to States during inspections
or sanitary surveys, and, likewise, some data could be held by States and provided during program
reviews or data verifications. Additionally, OGWDW is considering options for early involvement of
information and implementation staff in regulation development to identify information requirements
as soon as possible in rulemaking.  This early involvement would potentially provide for a more
complete description of data requested and information processes employed to allow more complete
consideration in rule development by affected stakeholders.
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^                                                                                       N
      Drinking Water Data Management Steering Committee Draft Work Plan

        The following summarizes the draft 2001 Work Plan for the Data Management Steering
 Committee (DMSC). The DMSC, a joint project of the United States Environmental Protection
 Agency and the Association of State Drinking Water Administrators, is an advisory group that
 supports EPA and states in their cooperative efforts to enhance drinking water data management.
 The DMSC has identified the following issues as high priority issues that need to be addressed.
 Once the DMSC has taken final action on an issue,  the Committee will reassess the current status of
 data management issues and revise this Work Plan to include additional issues as appropriate.

 ISSUE #1:  Develop a guideline for data management issues that EPA should consider when
 drafting a policy, developing a new rule, or revising an existing rule.

 Proposed action: The DMSC has formed a work group to develop a set of guiding principles on
 information requirements and data management that EPA should consider when drafting a policy,
 developing a new rule, or revising an existing rule. These guiding principles will be included in a
 "white paper," which, upon completion and approval by the full Committee, will be sent to the states
 and EPA Regions for their review, and ultimately, formally submitted to the Director of the Office of
 Ground Water and Drinking Water. The  Committee  anticipates that these guidelines will be
 incorporated into the rule development process, and that all new rules include a detailed description
 of data management requirements and how the requirements were determined. See Appendix D.

 ISSUE #2:  Determine how to ensure the  data in SDWIS/FED is reliable, complete, and timely.

 Proposed action: The DMSC has formed a work group to develop recommendations, with supporting
 products where appropriate, to states, EPA Regions, and  EPA Headquarters  on ways to ensure that
 the data in SDWIS/FED is reliable, complete, and timely. These recommendations will be included in
 a "white paper," which, upon completion and approval by the Committee, will  be sent to the states
 and EPA Regions for their review. Ultimately, it will be submitted formally to the Director of the Office
 of Ground Water and Drinking Water, the EPA Regional Administrators, and the primacy agency
 responsible  for implementing the drinking water program in  each state. As a result of these
 recommendations, the Committee anticipates improvement in data verification statistics overtime on
 a state-by-state basis.
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       Future Rules (e.g., rules that come out of the Contaminant Candidate List and
Unregulated Contaminant Monitoring Regulation): OGWDW is working with the Association of
State Drinking Water Administrators (ASDWA)-EPA Data Management Steering Committee to
propose a set of criteria for information requirements steps and reporting requirements to guide future
regulation development. OGWDW is also considering the option of bundling effective dates and
reporting requirements. Using this approach, OGWDW would pick an initial date to implement a
regulation and  a subsequent date for reporting to begin, allowing an appropriate readiness period for
states and systems. If a regulation were not ready by that date (i.e., a final rule had not been
promulgated), then it would not be effective until the next annual implementation date (e.g., Jan. 1 of
each year), with the appropriate readiness period already considered. OGWDW will be evaluating the
advantages and disadvantages of such an approach before making decisions about whether or not to
implement it.

•      How should EPA obtain parametric drinking water data to address future information
       requirements?
       The information requirements process in 2001 will explore the business need to report
parametric data in the future to support OGWDW's need to conduct the SDWA 6-year review of
regulations. Currently, OGWDW does not have the data it needs to conduct this review on a routine
basis. Options include:
       •       Changing the regulations to require all parametric data to be reported
              Requiring only a statistically randomly selected set of PWSs  to report parametric data
       •       Arranging with the drinking water industry to have a representative sample of PWSs
              report voluntarily
       •       Arranging with the states voluntarily to allow EPA to retrieve data on a representative
              sample of PWSs from their information systems

•      What improvements  to SDWIS should EPA make to allow for easier data entry by states?
       OGWDW proposes to bring the data models for SDWIS-FED and STATE into alignment and
implement the  two systems as one project. This step should reduce data submission errors for States
using SDWIS-STATE software.  OGWDW is also evaluating the  option of making SDWIS-STATE
web-enabled which should improve data submission capability and reduce errors. Additionally,
OGWDW is considering the option of having the releases of SDWIS-FED and STATE coincide, to
eliminate quarterly changes in SDWIS-FED  and make the releases annual.  Finally, OGWDW is
evaluating the option that it set annual dates  for all rules under development to aim at for
implementation of reporting requirements, rather than allowing each regulation workgroup to decide
independently when reporting requirements would be implemented.  This step should smooth out the
need to respond to constantly  changing reporting requirements and make them more predictable for
information systems planning and funding purposes for EPA and states.
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C. IMPROVING SYSTEM PERFORMANCE

•      How can EPA improve the performance of its information systems, given that any
       improvements would require states to make near-term adjustments to achieve long-term
       reporting benefits?
       Currently, SDWIS-FED reporting requirements provide states options for reporting certain
violation results. Providing for several reporting options in a database increases the complexity and
cost of building and maintaining an information system considerably. It also increases the probability
of modifications that will result in data rejection. Options for flexible reporting also encourage a range
of potential interpretations of regulatory specifications, resulting in inconsistent determination of
compliance and, thus, enforcement. To OGWDW, the simplest way to minimize this problem seems to
be allowing only one way to report each violation or other requirement.

       EPA's rationale for this approach: Today's data reporting characteristics of SDWIS/FED were
derived from the 1980s.  At that time, data management was much less automated, and primacy
agencies  developed capabilities in concert with their own unique requirements, especially after EPA
withdrew support for the old Model States Information System. EPA created data reporting capabilities
that are flexible, allowing multiple ways for the primacy agencies to report data. For example, although
SDWIS/FED requires the use of unique record identification numbers in the database for virtually all
data types,  some primacy agencies did not, in their data systems.  To accommodate them, EPA created
the capability for SDWIS/FED to generate the record identification numbers.  This very issue is
currently providing a daunting challenge to SDWIS/FED participation in EPA's spatial data work,
UCMR and the OEI Facilities Registry System, since records cannot easily be related to the  same
facility to look at the national level.

       Another area of flexibility is that EPA supports four different methods for linking enforcement
actions to their violations, and users have recently petitioned for a fifth.  Such flexibility creates
substantial costs in the information system. Rather than designing these capabilities into the  system,
OGWDW sees new data retrieval software technology (off-the-shelf) that could be set to allow such
analyses to be done independently of the system and allow the system to be simpler and less costly.

       There are several areas where similar reporting flexibility exists. The greatest problem with this
flexibility, from EPA's perspective, is the cost of its maintenance.  For every data element that can be
reported in multiple ways,  software has to exist to support its processing, in traditional and total replace
processing (another  area of flexibility being considered for elimination). Further, reporting,  user, and
training documentation all  must address each of the methods for data entry. When changes are made to
the data system, its impacts on each of these capabilities must be properly managed, or errors will
occur.

       EPA can certainly maintain reporting flexibility in the data system, but at a considerable
expense.  OGWDW has a limited budget for information systems.  Thus, our ability to reduce
escalation of costs is directly related to the amount of flexibility EPA allows in reporting.  The greater
the flexibility, the greater the costs.  A recent study performed to assess the costs of combining the
                                              16

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SDWIS/FED and SDWIS/STATE projects concluded that a significant investment would be required
for the conversion and software revision. However, a primary assumption associated with this
investment is that the multiple options would be simplified to a single response, as in SDWIS/STATE.
After such an investment, future system savings for the PWSS program reporting would be expected
annually with a breakeven point between one and two years, reporting requirements held constant.
These funds could then be applied to other priority data needs, such as source water protection. See
Appendix E, "The Need for Single, Unique Data Identifiers."
                                  SDWIS/FED Challenges

          Database in DB2 is not well supported software in EPA, and is EPA's more expensive
          operations cost platform. EPA does not possess the full extent of DBMS tools or knowledge.
          Data entry is with proprietary data entry format,  used only for SDWIS/FED reporting, is
          antiquated, and has been found to be insufficient to process new UCMR data
          DTP Writer software, in use in many states and  regions, is written in antiquated language;
          therefore, it is difficult to find software maintenance staff
          Data entry error reports are difficult to use, requiring development of additional tools for their
          users to ensure corrections are made (Error code database, Edit/Update Summary Reports)
          Existing standard reports (3, 7, 17, 18, 19 ,20, 24, 32a, 32b, 32c, 35, LCR, list screens) are
          inefficient in that they take long time  to run, principally because they were converted from
          FRDS-II system, a less expensive alternative, rather than re-written with the SDWIS/FED
          data structure in mind
          Users must perform ad hoc retrievals from complicated data structure.  This results in only
          the most knowledgeable and technically proficient users being able to perform their own
          queries
          There are 3 courses just for data retrievals, one for SNC/Exception Tracking  System, one for
          Data Entry Troubleshooting and a new one for data entry. The difficult ad hoc retrieval
          system neccesitates 2 3-day training classes
          SDWIS/FED does not formally take advantage of newer communications/platform
          capabilities (Web browser), software capabilities such as COTS (ACCESS, EXCEL), nor
          report-writing tools (Cold Fusion, Crystal  Reports)
          Current data dictionary design is based the upon incorrect assumption that all information
          needed for inclusion would be contained  in a Central Encyclopedia. As a result, it is difficult
          and more expensive than necessary and awkward to maintain, and many data element
          definitions need to be improved.
          Data submission allows flexibility for reporting, requiring complex software. As a result,
          development, maintenance and enhancements  are complex and expensive to perform,
          document and train users.
                                               17

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           SDWIS/ONE Recommendations: Three Independent Approaches

 1 - Organizational and management
        Include EPA and contractor IT professionals in rule and guidance development.
        Participate in the development of emerging EPA data standards.
        Merge the Federal and State components of SDWIS (SDWIS/FED and SDWIS/STATE) into a
        single project.
               - reduce administrative costs; assure better system consistency
        Streamline data entry software.
               - simplify data entry - more prescriptive approach
               - eliminate "total replace" function?
               - eliminate or reduce multiple methods for reporting same data
               - provide one set of permitted values
               - simplify data entry logic (e.g., eliminate need for c413 - seller id)
        Modernize production control, system user support, and User Documentation.
               - manual production control processes can be automated
               - automated user documentation increased and - made available on website
        Reduce redundant documentation.
               - have in a single media

 2 - General system recommendations
        Move the edits, updates, and other processing that occurs when State data are posted to
        SDWIS/FED from the mainframe computer at the National Computer Center (NCC) to a server at
        a third party.
        Move the SDWIS/FED and SDWIS/STATE Central Encyclopedias (CE) from the mainframe at
        NCC to a server at a third  party.
        Synchronize releases of SDWIS/FED and SDWIS/STATE (to an annual release)

 3 - Medium to long term system development options
        Option 1—Modify the SDWIS/FED Data Structure
               - Remove extraneous tables and attributes from the SDWIS/FED data structure.
               - Synchronize the  SDWIS/FED and SDWIS/STATE models where appropriate.

        Option 2—Merge SDWIS/FED and SDWIS/STATE Logical and Physical Data Models.
               - Combine the models into a single, comprehensive structure.
               - Use the existing  Migration to SDWIS/STATE application as the basis for Migration to
               SDWIS/ONE, a comprehensive data validation and transfer program that updates both the
               SDWIS/ONE central database and SDWIS/ONE  STATE instances of the database.
               - Replace the SDWIS/FED application Data Transfer Format Writer (DTF WRITER) with a
               web-based application that moves data into a more flexible format accepted by the
               SDWIS/ONE central database.
               - Position SDWIS/ONE for compliance with the Central Data Exchange component of the
               proposed National Environmental Information Exchange Network.

        Option 3—Comprehensive Redesign
               - the complete redevelopment of the SDWIS applications using an OO methodology

 4 - Development would take approximately 18 months, with 6 months of parallel processing

V	s
                                              18

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D. IMPROVING DATA QUALITY
       What steps should EPA take to improve data quality?
       OGWDW prepared a Data Reliability Analysis which included a plan for working with states to
improve the quality of data in SDWIS-FED.  The greatest problem in data quality is the under reporting
of data to SDWIS-FED for violations and enforcement actions.  OGWDW and the Association of State
Drinking Water Administrators (ASDWA) are working together to set priorities for implementing the
plan.  Additionally, OGWDW has created a task group to obtain the complete set of latitude/longitude
data for intakes and well fields of public water systems. This will to  allow more comprehensive use of
the drinking water data for national questions that have spatial considerations.

       OGWDW's Infrastructure Branch created a data analysis team to routinely evaluate the data and
ensure its use within the program.  One recent related action was providing ad hoc query capabilities of
SDWIS-FED data directly through OGWDW's web site.  This allows drinking water data users to
formulate their own queries and examine the data for their purposes.

       OGWDW is also participating in Agency processes to encourage use of data reporting standards
across information systems and programs through a common set of data elements. This action will
enable programs to share data across systems and improve the usefulness of existing and future data,
utilizing information systems funding more efficiently.

       The following options are highly recommended and supported by earlier Stakeholder activities
and Agency initiatives. (1) Continue data reliability recommendations and actions summarized in a
report titled DATA Reliability Analysis of the EPA Safe  Drinking Water Information System/Federal
Version (SDWIS/FED) (EPA 816-R-00-020), September 2000;  (2) continue to work with EPA's Office
of Environmental Information to review the extent of compliance with Agency data standards to
improve data quality and sharing. Specifically, continue  to register data elements in the Data Registry
and revise the data verification protocol to address current inventory requirements and electronic
storage approaches; and (3) Reduce or eliminate flexibility in reporting options that contribute to
varying interpretations of regulatory requirements and lead to under reporting.
                                              19

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               Possible future platform for OGWDW data systems
Currently EPA is predominately a NOVELL shop - most of our LANs run on Novell software.  Last
September, Oracle Corporation issued a statement that it would start to phase out its support for
Novell. EPA does use some Microsoft NT servers for applications but not for file servers. If an
application needs to use a file server (i.e., when data is submitted to EPA and written directly to a file
server) and Oracle does not support Novell in future releases, how will this effect our system?

SDWIS/STATE's network versions are NT and Novell. If SDWIS/FED adopts SDWIS/STATE as-is,
two options are using NT and Novell. EPA supports the mainframe platforms, Novell, Unix, and
some NT.

Option 1: Create a UNIX version of SDWIS/STATE. This would avert potential problems caused by
the instability of NT networks (compared to UNIX), and the lack of support for NT servers.
Developing a Unix system would also help many states that may also need to switch from Novell
networks to run their Oracle applications.

Option 2: Encourage EPA central services to increase support for NT servers. Within the next 12
months, OGWDW will move from directly controlling it's LAN (i.e. servers) to the EPA shared
services. The EPA IT Road Map and the Network Blueprint still do not allow for easy use of NT file
servers. We would need to either push for NT file servers be included in the Network Blueprint (may
be security issues) or purchase these products on our own through working capital or other contract
vehicle.

Also, if SDWIS/FED adopts SDWIS/STATE it may chose one of three database platforms - Oracle,
SQL/SERVER, or DB2.  SDWIS/FED is currently a DB2 database on the mainframe. Recently on
the SDWIS/STATE project we have learned many truths concerning migrating data between these
three database platforms. Most problems tend to occur when moving data to DB2.
Platform
Oracle
SQL/Server
DB2
Use at EPA
Original SDWIS/STATE
platform. Long-term track
record in the database
industry
No long-term track record at
EPA
SDWIS/STATE just created a
DB2 version.
Security
Strong security
features
Questionable
security; new
version is said to
have security
improvements

Strengths
Applications may be
ported to many
platforms.
Strong in the OLAP
world
Used primarily for
large amounts of data;
known as a
"transaction"
database.
                                          20

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E. DATA ACCESS

       How should EPA improve retrieval and dissemination of data contained in SDWIS/FED?
       Option 1: Create a data warehouse as our primary means of the retrieval and dissemination of
SDWIS/FED data. Data warehouse technology is improving at a tremendous rate.  Properly designed
data warehouses directly incorporate user needs in an iterative process to provide the users with the
tools they need to use the information easily, quickly and effectively. Thus, users will not be faced with
difficult data structures for ad hoc retrievals. New, more integrated structures would be developed in
the data warehouse, designed to meet specific retrieval needs. Further, warehouses could more easily
incorporate the newer data analysis tools of On Line Analytical Processing (OLAP).

       Option 2: Continue the current SDWIS/FED retrieval system. The current system is composed
of a set of canned reports, and an ad hoc reporting capability. The canned reports are expensive to
develop. The ad hoc reporting capabilities are terribly complex because their use requires detailed
knowledge of traversing highly normalized relational databases. In fact, there are 3 separate
SDWIS/FED training classes for use of these capabilities.  Only a limited number of highly trained and
technical staff have the capability to effectively perform ad hoc retrievals on the existing system. By
staying with the this system, this condition will continue to exist. Appendix I provides summaries of
drinking water data warehousing results and processes.
                                              21

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                             Benefits of Data Warehousing

On-Line Analytical Processing (OLAP) tools are multidimensional databases (MDBs) that enable users to
quickly summarize, cross-tabulate, and analyze large amounts of data. Users can pivot, or rotate, rows
and columns to see different summaries of the source data, filter the data, and drill-down to the details in
the underlying source data.

Meeting current needs more easily and economically:
(Numbers are estimates - input is welcome.)
Activity                                                 Savings
       Yearly summary inventory, compliance and GPRA             $30K/year*2
       statistics can be updated in two days, with  improved
       data quality, for free. Saves tens of thousands of dollars
       in working capital funds and hundreds of hours of
       personnel time. A report that used to take 8.5 months
       is printed in one week.
       Trends Report                                             80K
       Data pulls                                                20K/yr*2
       Statistical analysis for data quality report                             100K
       continued verification of data verification findings                     20K/yr
       Analysis of Surface Water Treatment Rule reporting            30K
       Decrease in Working Capital for EPA mainframe data retrievals  80K/yr*2

Enhanced capabilities
•      Build a number of SDWIS/FED data retrieval products at no cost 150K
       NCOD front-end                                           200K
                                                                $840K
In addition to cost savings:
       OGWDW is able to conduct additional data quality analyses
       OGWDW is "closer to" the data and need not rely on contractors to retrieve it
       OGWGW website allows users to retrieve data themselves, without relying on an IT expert
       Higher data quality - OGWDW is using data more than ever and able to identify and correct data
       quality problems. Quality of summary statistics increased from roughly 70 to 100 percent.
       Continual innovation and refining of products, adding new products to meet user needs.

Future benefits
       Modernization allows OGWDW to do more work in-house and to improve direction of
       contractors.
       Warehousing approach will help OGWDW unify  data systems at the retrieval end.
                                            22

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       How should public access to drinking water data be improved?
       As noted previously, OGWDW has provided on-line capability to conduct ad hoc queries of
SDWIS-FED data from the OGWDW web site. Similar capability will be provided for contaminant
occurrence data in the National Contaminant Occurrence Database. OGWDW will continue to consider
options for enhancing public access to its data, including capability to do online ad hoc queries.

       What does OGWDW need to do to ensure accessibility of electronic information and
computer systems for people with disabilities, in compliance with Section 508 of the
Rehabilitation Act Amendments of 1998?
       The Access Board is an independent Federal agency devoted to accessibility for people with
disabilities. On December 21, 2000, the Board issued accessibility standards for electronic and
information technology under section 508 of the Rehabilitation Act, as amended.  The Board also
develops and maintains accessibility guidelines for the built environment, transit vehicles, and
telecommunications equipment under other laws and enforces design standards for federally funded
facilities. See Appendix F, "Questions and Answers About Section 508 of the Rehabilitation Act
Amendments of 1998."

F. SYSTEM ECONOMICS
       What steps should EPA take to make OGWDW information systems more economically
efficient?
       OGWDW recently conducted two reviews of its information systems for compliance data.
Controlling costs are important alone; however, OGWDW is concerned that it be able to respond to
gaps in data for major programs in source water protection and underground injection control, for which
no national information systems exist to conduct national policy analysis. One option is to reduce costs
in existing information systems to provide for resources to support the unmet needs. The reviews
indicated that:

1.     OGWDW can take near-term steps to reduce costs by integrating certain components of
       SDWIS-FED and STATE
2.     SDWIS-FED can be modernized at a near-term additional expense that provides a long-term
       savings that can be applied to (a) gaps in data for source water protection and UIC; (b) the
       analyses that OGWDW is now conducting and would need to do in the future for more effective
       program management;  and (c) providing links to other data sets in EPA and with the states for
       national source water protection analyses and targeted special studies.
3.     OGWDW will focus on linking to existing data sets for source water protection and UIC rather
       than the alternative of new information reporting processes to the maximum extent possible.
4.     SDWIS-FED may move from its current platform to a third-party site to reduce operation and
       maintenance costs, depending on the direction of mainframe costs.
5.     Using the same architecture for SDWIS-FED and STATE could  also minimize future
       development costs for new rules.
                                             23

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PART V: ALTERNATE VISIONS OF FUTURE INFORMATION MANAGEMENT
       Multiple visions of future information management in OGWDW are possible.  (See attached
figures.) These visions are driven by the principles derived from the Office of Water ISP Performance
Assessment2:
       A. Common functions should share information business systems.
       B. Replicate storage of data should be minimized.
       C. Common data element definitions will enhance data sharing.
       D. Data should be stored in databases and retrieved and analyzed using separate state-of-the-art
          analytical software.
       E. Data should be easily accessible for analysis.

       With these principles in mind, at least four visions of OGWDW's information future can be
described. These visions are depicted in Table 1. The first is an extension of the Safe Drinking Water
Access and Retrieval System (SDWARS) for unregulated contaminants.  In this vision, all users share a
common electronic  space for drinking water data, with access through EPA's Central Data Exchange.
Such a vision potentially reduces transaction costs among senders and receivers of data, as well as
reduces capital expenditures for equipment, especially for pubic water systems and State drinking water
programs. Inventory data for public water systems could be updated directly by the PWS. Source water
protection and underground injection control data could also be maintained in this electronic space.
Data sharing agreements must be arranged between all levels of users to avoid conflicting actions being
taken by different levels, thereby using information and actions stemming from them inefficiently. In
this vision, all levels of users (e.g., local, state or federal governments) use the same basic data for all
decisions, only using the data needed at the appropriate level for decisions at that level. Thus, one
information system  exists, rather than being replicated in every state or public water system. The
information system  could even be maintained by a separate third party agreed to by all principal
participants in the system.

       A second vision is the "post and exchange" or "come and get it" approach of the Environmental
Council of the states.3 This approach is consistent with the EPA "Blueprint for a National
Environmental Information Exchange Network" (October 9, 2000).4 In this vision, states place their
PWSS, source water and UIC data in an electronic space outside their firewall, which the state
maintains. EPA retrieves the data at the appropriate time. If all states used SDWIS/STATE or
SDWIS/STATE-like systems - or all states used the same format for reporting, OGWDW retrieval
could be reasonably smooth. A "UIC/STATE" software capability would need to be established. If
States used different formats, this could be much more complicated, with unsuccessful data acquisition
possible, and thus an increase in transaction costs. OGWDW could place the data in SDWIS/FED or in
            2 U.S. Environmental Protection Agency, Office of Water. 2000. Information Strategy Plan Performance
     Assessment.

             Environmental Council of the States. 2000. E-commerce today - e-environmental protection tomorrow.

            Environmental Protection Agency. Office of Environmental Information. 2000. Blueprint for a National
     Environmental Information Exchange Network.

                                               24

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an EPA data warehouse through its Central Data Exchange. Under this vision, data could be replicated
as many as five times, with transfers of data providing the potential for data errors. Two of these data
replications could be within state programs, since each state would maintain data behind its firewall and
outside its firewall in a separate electronic space within which the  state and EPA would exchange
drinking water data. Development and maintenance of these five or more replicates of these data
suggest that collective resources for information management may not be efficient at a national level,
but if concerns about use of data by different levels of users creates transaction rationale for holding
data not to be used by  other levels, the additional costs may be warranted. Trading partner agreements
will be necessary to ensure that the data needed at each level is readily available to minimize
transactions costs.

       The third vision combines several features.  In this vision, states would use SDWIS/STATE or
at least SDWIS/STATE-like reporting formats.  SDWIS/STATE becomes web-enabled, providing
single entry of data to  States directly from laboratories. A "UIC/STATE" software capability would also
be developed and web-enabled.  States submit the data over the Internet to EPA, as currently happens.
EPA accepts the data through its Central Data Exchange, including security clearance. The data is
stored in SDWIS-FED residing in the EPA data warehouse. Data users can query drinking water data
along with data from other databases that have used common data  elements for reporting. This vision
minimizes burden for PWSs and States, especially in database capital investment, and makes a range of
data at the national level available for various analyses, similar to the first vision.

       A fourth vision is to continue the "status quo" and maintain the reporting process to
SDWIS/FED and not consider other information needs. Under this vision, costs to maintain the
database would continue to rise without any benefit of new technology. No effort would be taken to
establish links to other databases to set up a source water protection national data set. Transaction costs
are high at State and federal levels, since no changes would in the system that would improve its
operation and acceptance of transmitted data.  Modification costs for each new rule or other change
would be high because of the high cost of making changes to old technology. SDWIS/FED could be
part of data warehouse, such as envisioned in EPA's Network Blueprint, but would not be improved
with technological advances.

       The visions described above relate to systems built for the purpose of obtaining and storing data.
Each includes a "data warehouse" approach to facilitate the retrieval and analysis of these data. The
data warehouse is a  separate system that periodically  extracts data from OGWDW information systems
and other data sources; transforms the data, organizing them by subject matter; and provides
information in several forms including standards reports, On-Line  Analytical Processing (OLAP)
results, and GIS outputs. Users can easily retrieve, organize, and analyze data with little training. A
warehousing approach also facilitates unifying data from several information sources, an interest of the
Source Water Protection Program.

       OGWDW  seeks input from stakeholders on these visions of a future drinking water information
system and the advantages and disadvantages of them and other system approaches.
                                              25

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Table 1. Comparison of Visions for Drinking Water Data
Vision
Single Shared
Electronic Space
Post and Exchange
Specified SDWIS-
STATE Format
Status Quo Using
SDWIS-FED
Description
- Labs report directly
electronically
- All users have access
to all data
- Users arrange data
sharing agreements to
specify each users role
- EPA design to common
template
- States post data
outside firewall at state-
maintained site
- All states use
SDWIS/STATE template
- States send data to
EPA site
- Continue using old
software
- SDWIS/FED on
mainframe
Advantages
- Lower overall costs
- All decision makers use
same data
- Data quality likely to
increase with more
attention on same data
Current management of
data does not change
- All states use the same
template
- Data quality improves
- Data managers
understand current
process
Disadvantages
- Lack of data
management at various
levels of implementation
- Data duplication at
each reporting level. May
increase costs.
- Non-SDWIS/STATE
states would need to
modify systems.
- Costs continue to rise
- Data submission may
still be a challenge
                                          26

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VI. TIME LINE
       The time line of strategy development and implementation below begins with the OGWDW
       Internal Stakeholder Meeting in July 2000 and progresses through SDWIS/STATE web
       enablement completion. OGWDW seeks stakeholder input on the relationship and timing of the
       activities on the time line.
  July 6-7,  Sept.-Oct.,  Nov. 2000
  2000     2000        Internal
  Initial     Analysis of   Strategy
  Internal   Modernization
  Stakeholder Options
  Meeting
March 8-9,
2001
Stakeholder
Meeting

Pilot project
on info reqts
in reg process
July 2001
Information
Requirements
Complete

ASDWA/EPA
recs on reg
process


Aug. 2001
Information
Complete



Dec. 2004
Major
Modernization
Elements
Complete

SDWIS/STATE
web-enabled
* 	 : 	 : 	
Source Water/UIC
Measures Development
— **• *
Assess
Information
Requirements
V V
Create
Information
Strategy
w
Modernize
Systems
VII. NEXT STEPS

The next steps outlined below describe major actions contemplated by OGWDW as one approach to its
information processes and systems modernization. OGWDW seeks stakeholder input on these steps and
options to them..

Near Term (6-18 months)
1 - Stakeholder Information Requirements
- Protection Branch / OECA for compliance/violations data
       - Prevention Branch for parametric (ambient) data and other data (states, etc.)
       - SRMD for parametric data
              - Management for routine tracking and reporting "up the chain"
              - SRMD for new rules
              - Public through stakeholder meetings

2 - Program Modernization
              - Implement new information requirements process as part of the regulation development
process
              - Reach agreement with states to simplify multiple reporting options and therefore
reduce complexity and cost
                                              27

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             - Move SDWIS-FED off mainframe to reduce costs
             - Change regulations, if necessary, to provide for parametric data reporting

3 - Integration of Information Systems
       - Streamline SDWIS-FED and STATE to reduce costs in long term after near term investment
       - Integrate NCOD, ICR, SDWARS and other national and regional sealed up systems to reduce
costs
       - Participate with OW on data element harmonization for all major systems to allow data sharing
       - Web-enable SDWIS-STATE to allow states to more easily report data (at initial cost to EPA,
but a long-term  savings to both EPA and states)

4 - System User Support
       - Maintain support for SDWIS-STATE and expand user support with more states
       - Address early identification of specific PWS and state reporting requirements new rules
       - Improve public access for ad hoc and PWS queries
       - Update training for staff to allow in-house response to database changes in future

5 - Data Quality
             - Continue to work with states to implement data reliability plan, including internal task
group for obtaining updated facility inventory data
             - Register data elements in EPA's Environmental Data Registry to facilitate data sharing

6 - Information Strategy Plan
       - Complete revision of Information Strategy Plan after information requirements process is
completed in Summer 2000

Intermediate  Term (18mos. - 3 years)
             - Obtain parametric data through new reporting or access process
             - Link directly to other databases based on information requirements, especially for
source water protection and UIC national program data needs

Long Term (3-5 years)
             - Integrate systems based on function and business need
             - Implement the EPA/OEI-ECOS data exchange network (SDWIS-FED data submission
       is very close to this network model)
             - Receive all data using the Central Data Exchange (CDX) to ensure secure transmission
                                             28

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                                                                                   Appendix A
DRAFT SOURCE WATER PROTECTION
MEASURES OF PROGRESS
FEBRUARY 2001

Ultimate Goal of Source Water Contamination Prevention: Decreased public health risk by keeping
contaminants out of the sources of drinking water.

Vision of the Source Water Program: For every public water supply, all interested stakeholders are
involved in identifying and establishing barriers that significantly lower the risk of contaminants of concern
entering drinking water resources.

Intended Outcome: Public Water Systems are at decreased risk from contamination due to management
actions taken.

Measuring Progress Towards this Outcome

       The measures presented in the accompanying chart try to show a tiered approach to looking at the
progress of source water protection over time. For the first period of time, the highest level of expected
completeness would be on "the foundation" Tier  1 pieces: source water assessments, UIC inventorying and
ambient water quality standards.  Tier 2 would be to focus on the relation of  those foundation pieces to
reducing the risks to existing drinking water sources.  Tier 3 provides the basis for addressing potential
threats to drinking water sources.

       The intent is not to focus on any one tier  at the exclusion of the others at a given moment in time.
However, it is the expectation that the level of completeness would shift with time. For example in 2002, we
would expect that Tier 1 would show much progress, but there would be less completeness in Tiers 2 and 3
three. It is understood that management actions will be taken and UIC management will be ongoing at the
same time as necessary, but in the short term, these tiers would be less complete.

       Finally, in the longer term, the ultimate measure of progress would be the results of re-examining the
susceptibility of water systems and determining if management actions were having any impact on the degree
of risk posed to the system, as well as looking at the trends in ambient water quality.
This Tier 4  would be further in the future.  However, if the actions are not taking place as described in Tiers 2
and 3 two and three, then it will be difficult see changes in susceptibility and water quality as related to
preventative management actions.
                                               29

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Source Water Contamination Prevention: Measures of Progress, February 2001 Draft
Tier One: Are the state and tribal source water assessments and UIC Inventories getting completed
and what is their quality? Are the CWA Water Quality Standards in Place to Support SWP?
National Locational
Data Layer of the
source water protection
areas
# of State and Tribal
source water
assessments completed
(delineations, inventories,
susceptibility, made
available to public)
50-state and tribe
Analysis of source water
assessment quality
Locate Class IV wells
and gather lat/long for
Class l-lll
Increase* of
inventoried class V
Wells
# of States with water
quality standards and
designated uses protective
of source water
Tier Two: What is the extent of risks to source waters?
% of source waters of
most concern to
states and tribes
Reporting of the most
prevalent potential
contaminant sources of
concern identified in
source water protection
areas

Conduct analysis of
Class l-lll wells in
SWPAs and other high
priority areas
Conduct analysis of
class V wells in SWPAs
and other high priority
areas
Ambient Source Water
Quality Monitoring Baseline
Tier Three: How are Drinking Water Supplies being protected?
# of local management
actions taken to protect
source waters
(including wellhead
protection plans/SWP
plans implemented)
# of source water policies
adopted by other state
programs (and # of
national policies adopted
by federal programs)
Analysis of SSA MOUs
and actions by federal
agencies that have led
to wider GW protections
# of Class IV wells
closed.
Maintain low risk of
contamination from
Class l-lll wells (see
detailed chart)
Reduce risk from
inventoried class V
wells through adequate
management (see
detailed chart)
# of existing drinking water
supply source water
reaches with adequate
water quality standards in
place
                        Longest Term Tier Four: Are Source Water Contamination Prevention Actions
                                       Making a Difference to Public Health Protection?
     # of water systems with lower susceptibility due to combinations of
     management actions (incl. Sub-set of UIC actions)
Trends in ambient source water quality
                                                            30

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DRAFT SUMMARY CHART
Specifics to the UIC "Maintaining Adequate Management"
                 Are Source Water Contamination Prevention Measures Making A Difference to Public Health?
 1. Maintain low risk of contamination to USDWs from
 Class I - III injection wells through adequate
 management
                                          2. Maintain low risk of
                                          contamination to USDWs from
                                          Class IV wells
                                   3. Reduce risk of contamination from
                                   currently inventoried Class V wells
                                   through adequate  management, and from
                                   non-inventoried Class V wells by locating
                                   them and then adequately managing them
 Tier Three
1.2 Percentage of Class I - III wells properly
permitted and/or ruled authorized

1.3 Percentage of Class I hazardous waste wells
with approved no-migration petitions

1.4 Percentage (#?) of Class I - III wells that
pass MIT & is witnessed by regulatory authorities

1.5 # of properly abandoned wells in the AOR of
Class I - III wells

1.6 # of injection wells in hydrocarbon/mineral
bearing aquifers

[Enforcement and Compliance (???)]
1. 7 # Class I -III wells addressed by
enforcement & returned to compliance (includes
SNC data)

1.8 # of civil & criminal actions against Class I -
III wells
1.9 # of administrative orders issued by
States/Tribes/DI Programs to Class I - II
o/o (includes SNC)
                                                  I wells
                  1.10 # of contamination investigations linked to
                  Class I - III wells
2.2 Close all Class IV wells after
location
3.3  # of large capacity cesspools closed

3.4  # of MVWDW wells closed and/or permitted in
GWPAs & other sensitive areas

3.5  # of field inspections of Class V wells in SWPAs &
other high-priority areas of States and Tribal lands

[Enforcement and Compliance (???)]

3.6  # Class V wells addressed by enforcement &
returned to compliance (includes SNC data)

3.7  # of civil & criminal actions against Class V well o/o

3.8  # of administrative orders issued by
States/Tribes/DI Programs to Class V o/o (includes
SNC)

3.9  # of contamination investigations linked to Class V
wells
                                                                     31

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PRELIMINARY- Do not cite or quote
                                               Appendix B
Table 1
Unregulated Contaminant Monitoring Reporting Requirements

Data Element
1. Public Water System (PWS)
Identification Number

2. Public Water System Facility
Identification Number - Sampling
Point Identification Number and
Sampling Point Type Identification

























3. Sample Collection Date

4. Sample Identification Number


5. Contaminant/Parameter

Definition
The code used to identify each PWS. The code begins with the standard
two-character postal State abbreviation; the remaining seven characters
are unique to each PWS.
The Sampling point identification number and sampling point type
identification must either be static or traceable to previous numbers and
type identifications throughout the period of unregulated contaminant
monitoring. The Sampling point identification number is a three-part
alphanumeric designation, made up of:
a. The Public Water System Facility Identification Number is an
identification number established by the State, or at the State's
discretion the PWS, that is unique to the PWS for an intake for each
source of water, a treatment plant, a distribution system, or any other
facility associated with water treatment or delivery and provides for the
relationship of facilities to each other to be maintained;
b. The Sampling Point Identification Number is an identification
number established by the State, or at the State's discretion the PWS,
that is unique to each PWS facility that identifies the specific sampling
point and allows the relationship of the sampling point to other facilities
to be maintained; and
c. Sampling Point Type Identification is one of following:
SR - Untreated water collected at the source of the water system facility.
EP - Entry point to the distribution system.
MD - midpoint in the distribution system where the chlorine residual
would be expected to be typical for the system such as the location for
sampling conform indicator bacteria as described in 40 CFR 141.21.
MR - point of maximum retention is the point located the furthest from
the entry point to the distribution system which is approved by the State
for trihalomethane (THM) (disinfectant byproducts (DBF)) and/or total
coliform sampling.
LD - location in the distribution system where the disinfectant residual
is the lowest which is approved by the State for THM (DBF) and/or
total coliform sampling.
The date the sample is collected reported as 4-digit year, 2-digit month,
and 2-digit day.
An alphanumeric value of up to 15 characters assigned by the laboratory
to uniquely identify containers or groups of containers containing water
samples collected at the same time and sampling point.
The unregulated contaminant or water quality parameter for which the
sample is being analyzed.
              32

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6. Analytical Results - Sign
An alphanumeric value indicating whether the sample analysis result
was:

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

b. (=) "equal to" means the contaminant was detected at a level "equal
to" the value reported in "Analytical Result - Value."
7. Analytical Result - Value
The actual numeric value of the analysis for chemical and
microbiological results, or the minimum reporting level (MRL) if the
analytical result is less than the contaminant's MRL
8. Analytical Result - Unit of Measure
The unit of measurement for the analytical results reported, [e.g..
micrograms per liter, (• g/L); colony-forming units per milliliter,
(CFU/mL), etc.]	
9. Analytical Method Number
The identification number of the analytical method used.
10. Sample Analysis Type
The type of sample collected. Permitted values include:

a. RFS - Raw field sample - untreated sample collected and submitted
for analysis under this rule.

b. RDS - Raw duplicate field sample - untreated field sample duplicate
collected at the same time and place as the raw field sample and
submitted for analysis under this rule.

c. TFS - Treated field sample - treated sample collected and submitted
for analysis under this rule.

d. TDS - Treated duplicate field sample - treated field sample duplicate
collected at the same time and place as the treated field sample and
submitted for analysis under this rule.
11. Sample Batch Identification
Number
The sample batch identification number consists of three parts:

a. Up to a 10-character laboratory identification code assigned by EPA;

b. Up to a 15-character code assigned by the laboratory to uniquely
identify each extraction or analysis batch.

c. The date that the samples contained in each extraction batch extracted
or in an analysis batch were analyzed, reported as an 8-digit number in
the form 4-digit year, 2-digit month, and 2-digit day.	
12. Minimum Reporting Level
Minimum Reporting Level (MRL) refers to the lowest concentration of
an analyte that may be reported.  Unregulated contaminant monitoring
(UCM) MRLs are established in §141.40 monitoring requirements for
unregulated contaminants.	
13. Minimum Reporting Level Unit of
Measure
The unit of measure to express the concentration, count, or other value
of a contaminant level for the Minimum Reporting Level reported.
(e.g., • s/L, colony forming units/mL (CFU/mL), etc.).	
                                                  33

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14. Analytical Precision
Precision is the degree of agreement between two repeated
measurements and is monitored through the use of duplicate spiked
samples. For purposes of the Unregulated Contaminant Monitoring
Regulation (UCMR), Analytical Precision is defined as the relative
percent difference (RPD) between spiked matrix duplicates. The RPD
for the spiked matrix duplicates analyzed in the same batch of samples
as the analytical result being reported is to be entered in this field.
Precision is calculated as Relative Percent Difference (RPD) of spiked
matrix duplicates from the mean using:

RPD = absolute value of [(Xl - X2) /(Xl +X2)/2 ] x 100%

where:

Xj is the concentration observed in spiked field sample minus the
concentration observed in unspiked field sample

X2 is the concentration observed in duplicate spiked field sample minus
the concentration observed in unspiked field sample	
15. Analytical Accuracy
Accuracy describes how close a result is to the true value measured
through the use of spiked field samples. For purposes of unregulated
contaminant monitoring, accuracy is defined as the percent recovery of
the contaminant in the spiked matrix sample analyzed in the same
analytical batch as the sample  result being reported and calculated
using:

% recovery = [(amt. found in spiked sample  - amt. found in sample) /
amt.  spiked] x 100%	
16. Spiking Concentration
The concentration of method analytes added to a sample to be analyzed
for calculating analytical precision and accuracy where the value
reported use the same unit of measure reported for Analytical Results
17. Presence/Absence
Reserved
                                                  34

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                                            SDWIS/FED DTP Attributes
                                                                                                          Appendix Cl
DTF
NUMBER    ATTRIBUTE NAME

  C101        PWS-ID

  C105        PWS-TYPE



  C107        PWS-ACTIVITY-FLAG

  C1101       VIO-ID

  C1103       VIO-CONTAMINANT

  C1105       VIO-TYPE

  C1107       VIO-COMP-PERIOD-BEGIN-DATE



  C1109       VIO-COMP-PERIOD-END-DATE



  C1111       VIO-COMP-PERIOD-MONTHS

  C1115       VIO-AWARE-DATE

  C1123       VIO-ANALYSIS-RESULT

  C1125       VIO-MCL-VIOLATED



  C1127       VIO-SAMPLES-REQUIRED



  C1129       VIO-SAMPLES-TAKEN



  C113        PWS-DEACT-YYYYMM

  C1131       VIO-MAJOR-VIOLATION-FLAG



  C1143       VIO-SE-ID

  C117        PWS-RETAIL-POP-SERVED



  C1201       ENF-ID

  C1203       ENF-ACTION-DATE

  C1205       ENF-FOLLOW-UP-ACTION
DEFINITION

A unique value used to identify a PWS

Describes the type of water system, i.e., CWS, TNCWS,
NTNCWS, NP


A value that categorizes the activity of the water system

Code used to identify the violation incurred by a PWS

Contaminant for which a PWS incurred a violation

The type of violation, i.e. MCL, M/R, TT

The beginning data of a monitoring period in which a PWS was in
violation
The end date of a monitoring period in which a PWS was in
violation
Duration of compliance period in Months

Date state became aware of a PWS violation

Analytical result(s) that caused the MCL violation

The maximum contaminant level which was exceeded that led to
the issuance of an MCL violation


The number of samples that were required to be collected,
analyzed and reported by a PWS for a specific monitoring period


The number of samples that were actually collected, analyzed
and reported by a PWS for a specific monitoring period


Year and month the system was deactivated

A code that indicates the severity of an M&R violation, major or
minor


Source/entity ID at which the violation was incurred

The estimated average daily population count for a given type of
population served


Code used to uniquely identify a specific enforcement action

Date on which enforcement action was taken

Code used to represent an enforcement action taken by the State,
 EPA Region, or EPA headquarters
                                                                                        Page 1 of 8
                                                           35

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 DTF
NUMBER    ATTRIBUTE NAME

  C121        PWS-PCT-SURFACE



  C1215       ENF-COMMENT



  C123        PWS-PCT-GROUND



  C125        PWS-PCT-PUR-SURFACE



  C127        PWS-PCT-PUR-GROUND



  C1281       ENF-LINK-VIO-ID



  C1283       ENF-LINK-RANGE-BEGIN



  C1285       ENF-LINK-RANGE-END



  C1287       ENF-LINK-PERIOD-BEGIN



  C1289       ENF-LINK-VIO-TYPE

  C1291       ENF-LINK-CONTAMINANT



  C131        PWS-SY STEM-NAME



  C132        PWS-SYSTEM-RESPONSIBLE PARTY
              -NAME


  C133        PWS-SYSTEM-ADDR-LINE-1

  C135        PWS-SYSTEM-ADDR-LINE-2

  C137        PWS-SYSTEM-CITY

  C139        PWS-SY STEM-STATE

  C141        PWS-SY STEM-ZIP

  C143        PWS-TEL-NUM

  C147        PWS-SERVICE-CONNECTIONS

  C149        PWS-AVG-DAILY-PROD
DEFINITION

Annual percentage of water from non-purchased, permanently
available surface water sources
Description or attribute applicable to the associated enforcement
action
Annual percentage of water from non-purchased, permanently
available ground water sources
Annual percentage of water from purchased, permanently
available surface water sources
Annual percentage of water obtained from purchased,
permanently available ground water sources


ID that represents a specific violation that is related to unique
enforcement action
Start period covered by violation(s) which are associated w/
enforcement action
End of monitoring period  Covered by violation(s) which are
associated w/ enforcement action
Start of monitoring period in which a violation that is related to the
enforcement action was incurred
Violation type that is related to the enforcement action

Contaminant ID for a violation that is related to the enforcement
action
The formal, legal, or common name used most generally referring
to the PWS
The name of a legal entity associated with a water system


The first line of an address applicable to a legal entity

Address data for the primary facility location of the PWS

City name of the primary facility location of the PWS

State abbreviation of the primary facility location of the PWS

Zip Code +4 of the primary facility location of the PWS

Telephone number of the PWS

Number of retail service connections for a PWS

The average daily gallons of water produced by a PWS
                                                                                          Page 2 of 8
                                                           36

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DTF
NUMBER   ATTRIBUTE NAME

  C151        PWS-DESIGN-CAP



  C153        PWS-EMERGENCY-PROD



  C155        PWS-STORAGE-CAP

  C159        PWS-NON-COMM-SE-BEGIN



  C161        PWS-NON-COMM-SE-END



  C163        PWS-OWNER-TYPE

  C2101       SAMPLE-ID

  C2103       SAMPLE-BEGIN-DATE



  C2105       SAMPLE-END-DATE



  C2107       SAMPLE-CONTAMINANT



  C2109       SAMPLE-RESULT-SIGN



  C2111       SAMPLE-ANALYSIS- RESULT

  C2112       SAMPLE-RESULT-UM

  C2113       SAMPLE-ANALYSIS-METHOD

  C2115       SAMPLE-SOURCE-TYPE

  C2119       SAMPLE-SE-ID

  C2125       SAMPLE-QTY-COMPOSITED

  C2137       SAMPLE-TYPE

  C2139       SAMPLE-RECONCIL-ID



  C3001       VE-ID



  C3003       VE-CONTAMINANT
DEFINITION

The total gallons per day of water a PWS was designed and
approved to produce


The gallons per day of water that can be produced by a PWS
using emergency power generation under its control


Number of gallons of water that can be stored by a PWS

The month and day a NC or NTNC water system's season of
operation normally begins


The month and day a NC or NTNC water system's season of
operation normally ends


The type of owner of a PWS

Code used to uniquely identify a specific sampling occurrence

The first day of the monitoring period in which sample data was
acquired


The last day of the monitoring period in which sample data was
acquired


Code indicating the contaminant for which sample data has been
reported
Code indicating whether a result was below the method detection
 limit or detected
Value representing the results obtained from a samples analysis

Units of measurement for the analytical result

EPA method used to analyze the sample

The source type represented by the sample

Unique ID for each sampling point

Number of sampling sites included in composite sample

The water type represented by the sample

Comment field for Primacy Agencies to store information that
uniquely identifies a sample
Code used to uniquely identify a specific variance, exemption, or
other event related to a PWS
Code used to denote the contaminant for which a variance,
exemption, or other event has been granted
                                                                                       Page 3 of 8
                                                         37

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DTF
NUMBER    ATTRIBUTE NAME

  C3005       VE-RECORD-TYPE
  C3007       VE-EFFECTIVE-DATE
  C3009       VE-EXPI RATION-DATE
  C301
PWS-AD-ID
  C3011       VE-STATUS-CODE



  C3013       VE-MODIFIED-MCL



  C3015       VE-TREAT-PROCESS

  C3017       VE-ALT-PROCESS



  C3019       VE-REASON-CODE



  C3027       VE-VULNER-FLAG



  C3029       VE-ALT-MON-FREQUENCY



  C303       PWS-AD-TYPE

  C3031       VE-SE-ID



  C305       PWS-AD-NAME

  C307       PWS-AD-ADDR-LINE-1

  C309       PWS-AD-ADDR-LINE-2

  C3101       VE-SCHEDULE-ID



  C3103       VE-ACTION



  C3105       VE-SCHEDULE-DATE
  C3107
VE-ACCOM-DATE
DEFINITION

Code indicating whether the variance exemption data record is a
variance, exemption, or other event


Date on which variance, exemption, or other event has or will
become effective


Date on which variance, exemption, or other event has or will
expire


Unique code identifying an owner address, treatment facility
address or other address related to the PWS


Code used to denote current status of variance, exemption, or
other event


Value used to  represent a modified MCL that has been approved
as a condition  of a variance or exemption


Code representing the treatment process

Indicates whether an alternative treatment process  has been
approved as a condition of a V/E


Code representing the reason for which a variance, exemption,
or other event  is being granted to a PWS


Code indicating (Y)es or (N)o, the associated source-entity is
vulnerable  for contaminant specified


Number of months representing an alternative monitoring
frequency for the given contaminant


The type of addressee or facility of a PWS

Code uniquely identifying a specific source of water utilized  by,
or an entity associated with V/E or other related data


The name  of a legal entity associated with a PWS

First line of an address applicable to a PWS adressee or facility

Second line of an  address applicable to a treatment plant

Code uniquely identifying a specific V/E schedule related to the
variance, exemption or other event


Code representing an event or action to be taken by relating to a
variance, exemption or other event


Calendar date on which a schedule event or action relating to V/E
 record is or was scheduled to occur


Calendar date on which a schedule event or action relating to a
V/E record was accomplished, if completed
                                                                                          Page 4 of 8
                                                            38

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DTF
NUMBER    ATTRIBUTE NAME

  C311        PWS-AD-CITY

  C313        PWS-AD-STATE

  C315        PWS-AD-ZIP

  C355        PWS-SE-TREATMENT-AD-NAME

  C356        PWS-AD-ADDR-LINE-1

  C357        PWS-AD-ADDR-LINE-2

  C358        PWS-AD-CITY

  C359        PWS-AD-STATE

  C360        PWS-AD-ZIP

  C401        PWS-SE-ID



  C403        PWS-SE-NAME

  C405        PWS-SE-RECORD-TYPE

  C407        PWS-SE-WATER-TYPE-CODE

  C409        PWS-SE-AVAI LABILITY



  C411        PWS-SE-SELLERID

  C415        PWS-SE-LATITUDE (as degrees,
              minutes, and seconds)


  C417        PWS-SE-LONGITUDE (as degrees,
              minutes, and seconds


  C418        PWS-SE-MERIDIAN-NAME

  C419        PWS-SE-TOWNSHIP

  C421        PWS-SE-RANGE



  C423        PWS-SE-SECTION

  C425        PWS-SE-QTR-SECTION

  C426        PWS-QUARTER-QUA-SEC
DEFINITION

The city in which a treatment plant is located

The state abbreviation in which a treatment plant is located

The zip code in which a treatment plant is located

The name of a treatment plant

First line of an address applicable to a PWS adressee or facility

Second line of an address applicable to a treatment plant

The city in which a treatment plant is located

The state abbreviation in which a treatment plant is located

The zip code in which a treatment plant is located

Code which uniquely identifies the water system facility or
source of water


Water system facility name or water source

Code which categorizes the water facility or source

Code that represents the source of water or facility type

The circumstances under which a source  of water or facility is
utilized by a PWS


Seller's PWS ID

Degrees,  minutes and seconds of Latitude for the location of the
entity being  reported


Degrees,  minutes and seconds of Longitude for the location of
the entity  being recorded


The name of a North-South line used to locate a specific township

The location of a township in relationship to a known base line

A number representing a range in relationship to a known
principle Meridian


Numerical value  representing one of 36 sections of a township

A code representing a particular quadrant of a section

A code representing one of four quadrants of a particular
quadrant  section.
                                                                                          Page 5 of 8
                                                            39

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DTF
NUMBER    ATTRIBUTE NAME

  C427        PWS-RIVER-REACH
                                    DEFINITION

                                    The hydrologic unit code and the segment number for the location
                                     of the source or entity being reported
  C429        PWS-ON-REACH
                                    Value representing whether a source of water is on or off a
                                    defined river reach
  C431
PWS-REACH-MILES
The distance of a surface intake in relationship to the
downstream end of the river reach
  C433        PWS-SOURCE-TRE-CODE

  C435        PWS-SE-SELLER-TREATED
                                    Code specifying whether or not a source facility is being treated

                                    Code representing whether or not the seller of a purchased
                                    source is treating the source
  C441        LATITUDE (as a decimal number)
                                     Latitude entered in decimal degrees for the location of the entity
                                    being reported
  C443        LONGITUDE (as a decimal number)
                                    Longitude entered in decimal degrees for the location of the entity
                                    being reported
  C445        METHOD OF COLLECTION
                                    The method used to determine the Lat/Long coordinates of the
                                    water system facility
  C447        ACCURACY VALUE AND UNIT
                                    The amount of deviation from the value in a measurement for
                                    Lat/Long
  C449        DESCRIPTION CATEGORY
                                    The feature referenced by the Lat/Long coordinates or the water
                                    system facility
  C451        HORIZONTAL DATUM
                                    The horizontal control datum for the Lat/Long coordinates of the
                                    water system facility
  C453        SOURCE SCALE
                                    The scale of map used to determine the Lat/Long of the water
                                    system facility
  C455        POINT LINE AREA
                                    Code indicating whether the Lat/Long of the water system facility
                                    represent a point, multiple points or an area
  C457        DATE OF COLLECTION
                                    Date when the Lat/Long coordinates of the water system facility
                                    were determined
  C459        SOURCE
                                    Responsible party code for collecting, or providing the Lat/Long
                                    coordinates of the water system facility
  C461        DESCRIPTION COMMENTS
                                    A text field relating to the location or vertical measure of the
                                    water system facility
  C463        VERIFICATION
                                    Code indicating the process by which the Lat/Long coordinates of
                                    the water system facility have been verified
  C465        VERTICAL MEASURE
                                    Vertical distance from the vertical datum to the land surface or
                                    other measuring point
  C467        VERTICAL MEASURE METHOD OF
              COLLECTION
                                    The method used to determine the vertical measure of the water
                                    system facility
                                                                                          Page 6 of 8
                                                            40

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DTF
NUMBER    ATTRIBUTE NAME

  C469        VERTICAL MEASURE ACCURACY



  C471        VERTICAL DATUM



  C481        PWS-SE-TREATMENT-ID

  C483        PWS-SE-TREATMENT-OBJECTIVE 5

  C485        PWS-SE- TREATMENT-PROCESS

  C487        PWS-SE-TREATMENT-INNOVATIVE-FL
              AG


  C489        PWS-INNOVATIVE-TREATMENT-DESC
              RIPTION

  C501        PWS-GA-ID

  C503        PWS-ADMIN-REGION



  C505        PWS-ADMIN-DISTRICT



  C507        PWS-FED-CON-DISTRICT



  C508        PWS-STATE-COUNTY



  C509        PWS-GA-FI PS-COUNTY-CODE



  C513        PWS-GA-CITY-SERVED



  C515        PWS-INDIAN-RES



  C601        PWS-SERV-ID

  C603        PWS-SERV-CATEGORY

  C605        PWS-SERV-PRIMARY-FLAG

  C701        PWS-VISIT-ID



  C703        PWS-VISIT-DATE

  C705        PWS-VISIT-REASON
DEFINITION

Quantitative measure of the amount of deviation from true value in
 the vertical measure (estimate of error)


Code representing the vertical control datum for the vertical
measure of the water system facility


Unique value representing a treatment record for a source of

Identifies specific objective to be obtain through treatment

Identifies the specific treatment process used at a source or plant

Code identifying whether a treatment objective  and process is
innovative


A text field describing an innovative treatment process


Code uniquely identifying a specific geographic area served

Code representing the state administrative region being served by
 aPWS


Code representing the state administrative district being served
by a PWS


Code representing the federal congressional district being served
 by a PWS
A state county code representing the county being served by the
PWS
FIPS county code, representing the county being served by the
PWS
Name of the city, community or jurisdiction being served by the
PWS
Code representing the Indian reservation or Alaska remote village
being served by a PWS


A code uniquely identifying a specific service area

Code characterizing the type of area serviced by the PWS

Primary, most prevalent type of area served by the PWS

A code used to uniquely identify a specific on-site visit made to a
PWS


Calendar date on which a visit was made to a PWS

Code representing the reason a visit was made to a PWS
                                                                                          Page 7 of 8
                                                           41

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DTF
NUMBER   ATTRIBUTE NAME

  C801       PWS-MILESTONE-ID

  C803       PWS-MI LESION E-DATE

  C805       PWS-MILESTONE-CODE

  C813       PWS-MI LESTONE-COMMENT

  C815       PWS-MI LESION E-VALUE



  C817       PWS-MI LESION E-REASON
DEFINITION

Code used to uniquely identify a specific milestone

Date associated with the milestone occurrence

Code that represents a specific milestone occurrence

Commentary use/field uesd by State or EPA region

The Copper Level Exceedance or Lead Service Line
Replacement rates


Reason code for DEEM and DONE milestones
                                                                                     Page 8 of 8
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                                                                                  Appendix C2
                                SDWIS/FED DTP Attributes
                          Being Analyzed for Reporting Reduction


 DTFNUM            C105

 A TTRIBUTE NAME    P WS-TYPE

 DEFINITION         Describes the type of water system, i.e., CWS, TNCWS, NTNCWS, NP

          DATA ELEMENT NAME                   TableName

          D_PWS_ST_TYPE_CD                         TINWSYS
          TYPE_CODE                                TINPOPSV


 DTFNUM            C107

 ATTRIBUTE NAME    PW8-ACTIVITY-FLAG

 DEFINITION         A value that categorizes the activity of the water system

          DATA ELEMENT NAME                   TableName

          ACTMTY_STATUS_CD                         TINWSF


 DTFNUM            C117

 ATTRIBUTE NAME    PWS-RETAIL-POP-SERVED

 DEFINITION         The estimated average daily population count for a given type of
                      population served

          DATA ELEMENT NAME                   TableName

          AVG_DAILY_CNT                             TINPOPSV


 DTFNUM            C121

 ATTRIBUTE NAME    PWS-PCT-SURFACE

 DEFINITION         Annual percentage of water from non-purchased, permanently
                      available surface water sources

          DATA ELEMENT NAME                   TableName

          SURF_WTR_RATIO                            TINWSYS

DTFNUM             C123

 ATTRIBUTE NAME    PWS-PCT-GROUND

 DEFINITION         Annual percentage of water from non-purchased, permanently
                      available ground water sources

          DATA ELEMENT NAME                   TableName

                                              43

-------
          GRND_WTR_RATIO                             TINWSYS


DTFNUM             C125

ATTRIBUTE NAME    PWS-PCT-PUR-SURFACE

DEFINITION          Annual percentage of water from purchased, permanently available
                      surface water sources

          DATA ELEMENT NAME                    TableName

          SURF_WTR_PUR_RATIO                         TINWSYS


DTFNUM             C127

ATTRIBUTE NAME    PWS-PCT-PUR-GROUND

DEFINITION          Annual percentage of water obtained from purchased, permanently
                      available ground water sources

          DATA ELEMENT NAME                    TableName

          GRND_WTR_PUR_RATIO                         TINWSYS


DTFNUM             C149

ATTRIBUTE NAME    PWS-AVG-DAILY-PROD

DEFINITION          The average daily gallons of water produced by a PWS

          DATA ELEMENT NAME                    TableName

          AVG_DAILY_PROD_MSR                         TINWSYS


DTFNUM             C151

A TTRIBUTE NAME    P WS-DESIGN-CAP

DEFINITION          The total gallons per day of water a PWS was designed and approved
                      to produce

          DATA ELEMENT NAME                    TableName

          TOTAL_DSGN_CAP_MSR                         TINWSYS


DTFNUM             C153

ATTRIBUTE NAME    PWS-EMERGENCY-PROD

DEFINITION          The gallons per day  of water that can be produced by a PWS using
                      emergency power generation under its control

          DATA ELEMENT NAME                    TableName

          TTL EMERG CAP MSR                          TINWSYS
                                              44

-------
DTFNUM             C155

ATTRIBUTE NAME    PWS-STORAGE-CAP

DEFINITION          Number of gallons of water that can be stored by a PWS

          DATA ELEMENT NAME                    TableName

          D_TTL_STOR_CAP_MSR                         TINWSYS


DTFNUM             C3001

A TTRIBUTE NAME    VE-ID

DEFINITION          Code used to uniquely identify a specific variance, exemption, or other
                      event related to a PWS

          DATA ELEMENT NAME                    TableName

          D_GEN_ID_SRC_CD                            TFRDEVIA
          FED_FISCAL_YR_NUM                          TFRDEVIA
          ST_ASGN_IDENT_NUM                          TFRDEVIA

DTFNUM             C3005

A TTRIBUTE NAME    VE-RECORD-TYPE

DEFINITION          Code indicating whether the variance exemption data record is a
                      variance,  exemption, or other event

          DATA ELEMENT NAME                    TableName

          TYPE_CODE                                 TFRDEVIA


DTFNUM             C3007

ATTRIBUTE NAME    VE-EFFECTIVE-DATE

DEFINITION          Date on which variance, exemption, or other event has or will become
                      effective

          DATA ELEMENT NAME                    TableName

          EFFECTIVE_DATE                              TFRDEVIA


DTFNUM             C3009

ATTRIBUTE NAME    VE-EXPIRATION-DATE

DEFINITION          Date on which variance, exemption, or other event has or will expire

          DATA ELEMENT NAME                    TableName

          EXPIRATION DATE                             TFRDEVIA
                                               45

-------
DTFNUM             C3011

ATTRIBUTE NAME    VE-STATUS-CODE

DEFINITION         Code used to denote current status of variance,  exemption, or other

          DATA ELEMENT NAME                     TableName

          STATUS_CODE                                TFRDEVIA


DTFNUM             C3013

A TTRIBUTE NAME    VE-MODIFIED-MCL

DEFINITION         Value used to represent a modified MCL that has been approved as a
                      condition of a variance or exemption

          DATA ELEMENT NAME                     TableName

          MODIFIED_MCL_MSR                            TFRDEVIA


DTFNUM             C3019

A TTRIBUTE NAME    VE-REASON-CODE

DEFINITION         Code representing the reason for which a variance, exemption, or
                      other event is being granted to a PWS

          DATA ELEMENT NAME                     TableName

          REASON_CODE                                TFRDEVIA


DTFNUM             C3029

A TTRIBUTE NAME    VE-ALT-MON-FREQ UENCY

DEFINITION         Number of months representing an alternative monitoring frequency
                      for the given contaminant

          DATA ELEMENT NAME                     TableName

          ALT_MONITORING_RT                           TFRDEVIA


DTFNUM             C3101

ATTRIBUTE NAME    VE-SCHEDULE-ID

DEFINITION         Code uniquely identifying a specific V/E schedule related to the
                      variance, exemption or other event

          DATA ELEMENT NAME                     TableName

          ST_ASGN_IDENT_NUM                           TFRDSCHD

DTFNUM             C3103
                                               46

-------
 ATTRIBUTE NAME    VE-ACTION

 DEFINITION          Code representing an event or action to be taken by relating to a
                       variance, exemption or other event

          DATA ELEMENT NAME                    TableName

          ACTION CODE                                TFRDSCHD
 DTFNUM             C3105

 ATTRIBUTE NAME    VE-SCHEDULE-DATE

 DEFINITION          Calendar date on which a schedule event or action relating to V/E
                       record is or was scheduled to occur

          DATA ELEMENT NAME                    TableName

          PLANNED_DATE                               TFRDSCHD


 DTFNUM             C3107

 ATTRIBUTE NAME    VE-ACCOM-DATE

 DEFINITION          Calendar date on which a schedule event or action relating to a V/E
                       record was accomplished, if completed

          DATA ELEMENT NAME                    TableName

          ACTUAL_DATE                                TFRDSCHD


 DTFNUM             C409

 ATTRIBUTE NAME    PWS-SE-AVAILABILITY

 DEFINITION          The circumstances under which a source of water or facility  is utilized
                       byaPWS

          DATA ELEMENT NAME                    TableName

          AVAILABILITY_CODE                            TINWSF

DTFNUM              C427

 ATTRIBUTE NAME    PWS-WVER-REACH

 DEFINITION          The hydrologic unit code and  the segment number for the location of
                       the source or entity being reported

          DATA ELEMENT NAME                    TableName

          USGS HYDRO UNIT CD                         TINWSF
 DTFNUM             C429
 ATTRIBUTE NAME    PWS-ON-REACH

                                               47

-------
DEFINITION          Value representing whether a source of water is on or off a defined
                      river reach

          DATA ELEMENT NAME                    TableName

          ON_RVR_RCH_IND_CD                          TINWSF


DTFNUM             C431

ATTRIBUTE NAME    PWS-REACH-MILES

DEFINITION          The distance of a surface intake in relationship to the downstream end
                      of the river reach

          DATA ELEMENT NAME                    TableName

          RVR_RCH_MILES_QTY                          TINWSF


DTFNUM             C483

ATTRIBUTE NAME    PWS-SE-TREATMENT-OBJECTIVE 5

DEFINITION          Identifies specific objective to be obtain through treatment

          DATA ELEMENT NAME                    TableName

          TYPE_CODE                                 TFRDEVIA

DTFNUM             C485

ATTRIBUTE NAME    PWS-SE- TREATMENT-PROCESS

DEFINITION          Identifies the specific treatment process used at a source or plant

          DATA ELEMENT NAME                    TableName

          TYPE_CODE                                 TFRDEVIA


DTFNUM             C513

ATTRIBUTE NAME    PWS-GA-CITY-SERVED

DEFINITION          Name of the  city, community or jurisdiction being served by the PWS

          DATA ELEMENT NAME                    TableName

          FIPS CODE                                  TINGEOAR
                                              48

-------
                                                                                       Appendix D
                               Proposed Draft Guiding Principles for
                    Information Requirements in the Rule Development Process

The ASDWA/EPA Data Management Steering Committee is developing a proposal for criteria that EPA
could consider in the development of information requirements for new rules. An early draft of these
principles includes the following concepts for these criteria:

1.  Focus on essential data at local, State and Federal levels for public health protection;
2.  Not all data needs to be reported at all levels;
3.  Include data management representatives and consider information requirements early in the rule process;
4.  Describe reporting burden in sufficient detail;
5.  Have rule managers be accountable for making sure that reporting requirements and burden are adequately
considered and clearly defined;
6.  Be consistent across  rules to reduce overlap of reporting;
7.  Keep an outcome-based focus during the rule development process.
8.  Improve communication throughout the development process with states to better determine the impact
the changes will have on data management.
9.  Standardize data elements and definitions, including Significant Non-Compliance (SNC) and Return to
Compliance (RTC)
10. Improve the process for determining the start date for monitoring and reporting for more effective and
efficient implementation, such as: consolidate all dates for monitoring and reporting to a single date each
year.
11. Incorporate reporting timetables into the standard monitoring framework of 3/6/9 years, where
applicable, to reduce "scattered" deadlines.
12. Evaluate  or understand how other programs in the Agency may be using or gathering data that could be
used to meet drinking water data needs.
13. Recognize shifts in information technology that could benefit system development, maintenance and use.
                                                49

-------
                                                                                        Appendix E
                            The Need for Single, Unique Data Identifiers

 EPA does not have a policy concerning the reporting of Facility Identification Numbers and associated data,
except that they be updated annually. Therefore, the agency cannot consistently and confidently identify
facilities over time.  Therefore, users cannot reliably refer to "points of interest" within Public Water Systems
(PWSs) in SDWIS/FED, EPA's drinking water compliance database of record.

 EPA and its repository of PWS information, SDWISVFED, has almost totally depended on primacy agencies
to provide information on the inventory of PWSs under their purview. The SDWA requires primacy agencies
to provide the EPA with updates to their inventory or PWSs on an annual basis.  Most primacy agencies
comply with this requirement, some providing this information more frequently.  A small percentage of states
update EPA less frequently. PWSs are uniquely identified by a 9 character PWS Identification Numbers
(PWS-IDs) assigned by primacy agencies. Generally, they have been assigned under a range of numbering
conventions and reqorting with varying frequencies. In cases where primacy agencies needed to re-number
one or more PWSs, the primacy agencies have typically provided EPA with a table identifying old PWS-IDs
and new PWS-IDs. While not perfect, this informal process has worked sufficiently well to preclude most
problems relating to PWS Identification. However, the process allows considerable variety and inconsistency
from state to state.

 The PWS inventory information that states are required to report includes both general characteristics of
PWSs (e.g., Retail Population Served, PWS type, Active or Inactive) as well a significant amount of data
describing the points of interest within a PWS  of concern to US EPA.  These points of interest include all
sources of water for the PWS, all  treatment plants associated with a PWS, all places where sampling occurs
in support of EPA studies.  Points of interest are generally referred to as "PWS-Facilities" and generally can
be described as having some spatial characteristic and must be reported according to US EPA's Locational
Data Policy. PWS-Facilities are uniquely identified within a PWS by  a PWS Facility  Identification Number.
These numbers may be assigned by either the primacy agency or by EPA.

 Since no EPA policy has existed concerning the reporting of Facility  Identification Numbers EPA cannot
consistently and  confidently identify facilities over time.  Contributing to this problem are, at a minimum, the
following:
 1. EPA will "generate" a PWS Facility Identification Number if the primacy agency instructs EPA to do so.
 2. EPA will "generate" a Treatment Plant for a source of water and a  PWS Facility Identification Number
for that treatment plant if the primacy agency instructs EPA to do so.
 3. EPA's maximum length for a PWS Facility Identification Number is 5 numbers, and this is frequently of
insufficient length (e.g., the primacy agency assigns a longer PWS Facility Identification Number because the
longer ID number meets primacy  agency requirements, however, a shorter number, 5 digits, is assigned when
the data is reported to the US EPA).
 4. Since no policy exists, primacy agencies may re-number their facilities at states' discretion.
 5. In its production database (SDWISVFED) does not keep track of previously reported facilities.
 6. Data related to PWS facilities, and gathered by organizations other than the primacy agency, cannot be
consistently and  reliably associated with the facilities in SDWISVFED.

 What are options for long- and short-term solutions? Note that short-term options must be attainable in a
reasonably short time, enforceable, and consistently usable while minimizing burden and cost. Also, short-
term solutions may be constrained by limitations in SDWIS/FED  design and/or current data transfer metheds,
but long-term solutions would not.

                                                50

-------
                                                                                       Appendix F
                            FY2000 IB SDWIS/FED Factoids
FY2000  Inventory data
Active, current systems, from SDWIS/FED OOQ4 frozen inventory table
System size
by population served
               Very Small
               500 or less
  Small
501-3,300
  Medium
3,301-10,000
    Large
10,001-100,000
Very Large
 >100,000
Total
cws
NTNCWS
TNCWS
# systems
Pop. served
% of systems
% of pop
# systems
Pop. served
% of systems
% of pop
# systems
Pop. served
% of systems
% of pop
31,688 14,149 4,458 3,416 353
5,148,696 19,931,399 25,854,061 96,709,145 116,282,810
59% 26% 8% 6% 1%
2% 8% 10% 37% 44%
17,598 2,839 96 23 3
2,440,352 2,795,510 480,243 620,719 579,937
86% 14% 0% 0% 0%
35% 40% 7% 9% 8%
90,391 2,632 130 54 3
7,521,276 2,617,526 731,889 1,329,043 735,001
97% 3% 0% 0% 0%
58% 20% 6% 10% 6%
54,064
263,926,111
100%
100%
20,559
6,916,761
100%
100%
93,210
12,934,735
100%
100%
             Total # systems
                  139,677
    19,620
CWS
NTNCWS
TNCWS
Community Water System
Non-Transient Non-Community Water System
Transient Non-Community Water System
      4,684
       3,493
       359
 167,833
System source
    Type
              Ground Water Surface Water
                 Totals
CWS
NTNCWS
TNCWS
# systems
Pop. served
% of systems
% of pop
# systems
Pop. served
% of systems
% of pop
# systems
Pop. served
% of systems
% of pop
42,661 1 1 ,403
85,868,456 178,057,655
79% 21 %
33% 67%
19,738 821
5,984,416 932,345
96% 4%
87% 13%
91,298 1,912
12,017,370 917,365
98% 2%
93% 7%
54,064
263,926,111
100%
100%
20,559
6,916,761
100%
100%
93,210
12,934,735
100%
100%
             Total # systems
                  153,697
               103,870,242
    14,136
179,907,365
    167,833
 Ground water systems = ground water (GW), purchased ground water (GWP)
 Surface water systems = surface water (SW), purchased surface water (SWP),
             ground water under the direct influence of surface water (GU),
             purchased ground water under the direct influence of surface water (GUP).

SDWIS/FED OOQ4 tables are "frozen" in early January 2001

Additional drinking water data tables are available at the website listed below
1/25/01 12:38PM
                               IB SDWIS/FED Factoids
                        www.epa.gov/safewater/data/getdata.html
                                                Lee Kyle 202/260-1154

-------
 FY2000  data~by State
 Active, current systems, from SDWIS/FED OOQ4 frozen inventory table
 Health-based (TT & MCL) violations, from OOQ4 frozen violations table
     AK

     AL

     AR

     AZ

     CA

     CO

     CT

     DC

     DE

     FL

     GA

      HI

      IA

      ID

      IL

      IN

     KS

     KY

     LA

     MA

     MD

     ME

      Ml

     MN

     MO

     MS
                      CWS   NTNCWS
TNCWS
Total
Ground
Surface
CWSs w/ reported
health-based violations
442 208 995
445,954 45,579 105,725
575 38 89
4,934,31 1 25,090 8,500
726 114 359
2,258,368 12,597 17,789
799 216 672
4,356,171 149,965 158,447
3,283 1,290 3,573
34,084,987 584,333 1,111,711
830 166 1,105
3,835,139 54,404 221,455
599 627 2,479
2,648,571 125,787 80,540
2
595,000
240 96 215
605,342 24,192 53,476
2,009 1,083 3,515
15,655,773 285,318 297,517
1,673 276 623
6,560,186 79,736 116,078
121 14 6
1,262,878 7,307 2,450
1,153 167 612
2,575,716 46,942 80,213
747 258 1 ,075
907,653 55,155 125,908
1,801 438 3,562
10,947,281 157,030 395,476
916 759 3,162
4,119,623 492,393 364,396
917 35 127
2,418,352 14,364 14,287
467 89 156
4,294,353 31,569 11,494
1,207 213 400
5,162,586 82,274 95,925
513 224 891
8,640,236 70,774 160,019
511 572 2,732
4,614,127 160,236 141,310
399 455 1 ,249
611,531 72,718 203,762
1,472 1,826 9,052
7,044,085 504,705 1,108,745
953 646 6,753
3,798,571 100,705 393,760
1,439 235 1,027
4,715,214 79,873 149,546
1,228 117 140
2,876,508 87,810 26,393
1,645
597,258
702
4,967,901
1,199
2,288,754
1,687
4,664,583
8,146
35,781,031
2,101
4,110,998
3,705
2,854,898
2
595,000
551
683,010
6,607
16,238,608
2,572
6,756,000
141
1,272,635
1,932
2,702,871
2,080
1,088,716
5,801
11,499,787
4,837
4,976,412
1,079
2,447,003
712
4,337,416
1,820
5,340,785
1,628
8,871,029
3,815
4,915,673
2,103
888,01 1
12,350
8,657,535
8,352
4,293,036
2,701
4,944,633
1,485
2,990,711


























1,395 250
294,842 302,416
455 247
1,455,370 3,512,531
850 349
909,925 1 ,378,829
1,573 114
1,491,970 3,172,613
7,030 1,116
9,386,226 26,394,805
1 ,636 465
564,841 3,546,157
3,636 69
508,833 2,346,065
2
595,000
546 5
225,785 457,225
6,545 62
14,009,538 2,229,070
2,361 211
1,639,424 5,116,576
122 19
1,183,658 88,977
1,776 156
1 ,448,927 1 ,253,944
1 ,991 89
832,503 256,213
5,118 683
3,252,037 8,247,750
4,715 122
2,705,505 2,270,907
748 331
773,298 1,673,705
322 390
329,847 4,007,569
1,737 83
3,267,000 2,073,785
1,446 182
2,017,089 6,853,940
3,738 77
818,033 4,097,640
2,027 76
469,260 418,751
12,047 303
3,328,383 5,329,152
8,239 113
2,878,930 1,414,106
2,454 247
1,796,583 3,148,050
1 ,477 8
2,880,102 110,609


























77 17%
62,040 14%
21 4%
120,996 2%
104 14%
179,370 8%
68 9%
387,396 9%
181 6%
1,939,618 6%
43 5%
375,303 10%
67 11%
53,286 2%
0%
0%
18 8%
101,907 17%
83 4%
568,565 4%
52 3%
62,308 1%
8 7%
68,494 5%
64 6%
126,386 5%
114 15%
155,469 17%
258 14%
1 ,032,236 9%
124 14%
301,173 7%
93 10%
121,863 5%
18 4%
131,715 3%
108 9%
321 ,738 6%
125 24%
4,997,224 58%
35 7%
60,854 1%
86 22%
215,096 35%
89 6%
114,019 2%
24 3%
33,252 1%
133 9%
88,592 2%
51 4%
257,681 9%
1/25/01 12:38PM
       IB SDWIS/FED Factoids
www.epa.gov/safewater/data/getdata.html
                                                                                                      Lee Kyle 202/260-1154

-------
 FY2000 data~by State, cont.
 Active, current systems, from SDWIS/FED OOQ4 frozen inventory table
 Health-based (TT & MCL) violations, from OOQ4 frozen violations table
     MT

     NC

     ND

     NE

     NH

     NJ

     NM

     NV

     NY

     OH

     OK

     OR

     PA

     Rl

     SC

     SD

     TN

     TX

     UT

     VA

     VT

     WA

     Wl

     WV

     WY
                     CWS   NTNCWS
TNCWS
Total
Ground
Surface
CWSs w/ reported
health-based violations
645 225 1,153
2,716,262 44,769 165,756
2,374 658 4,479
5,794,107 193,761 412,002
321 29 200
555,123 3,958 17,152
619 178 532
1,392,476 43,190 66,639
674 446 1,036
766,072 88,587 207,906
602 940 2,737
7,678,147 279,033 351,179
616 155 503
1,489,113 34,508 208,412
292 100 283
1,579,690 40,380 59,527
2,868 761 7,001
17,690,198 358,726 856,655
1,429 1,106 3,404
10,142,141 275,606 543,094
1,171 123 438
3,434,926 18,645 43,495
884 331 1 ,430
3,095,044 69,529 220,176
2,200 1,266 6,923
10,518,120 509,453 864,529
83 71 325
950,151 24,566 53,135
692 221 614
3,303,073 75,407 55,421
474 30 214
631,186 3,924 36,049
633 60 480
5,082,640 30,592 54,130
4,574 862 1 ,429
20,920,423 339,537 288,783
430 64 459
2,471,221 47,314 82,361
1 ,326 623 1 ,827
6,496,739 285,368 944,111
438 215 694
502,741 39,473 716,196
2,300 316 1,595
5,060,995 263,654 301,376
1,140 1,020 9,564
3,645,732 210,193 725,062
583 196 635
1,810,721 101,298 42,424
272 86 378
410,396 16,240 75,279
2,023
2,926,787
7,511
6,399,870
550
576,233
1,329
1,502,305
2,156
1 ,062,565
4,279
8,308,359
1,274
1 ,732,033
675
1,679,597
10,630
18,905,579
5,939
10,960,841
1,732
3,497,066
2,645
3,384,749
10,389
11,892,102
479
1,027,852
1,527
3,433,901
718
671,159
1,173
5,167,362
6,865
21,548,743
953
2,600,896
3,776
7,726,218
1,347
1,258,410
4,211
5,626,025
11,724
4,580,987
1,414
1,954,443
736
501,915

























1,801 222
2,064,878 861 ,909
6,955 556
1,942,355 4,457,515
469 81
222,900 353,333
1 ,300 29
946,096 556,209
2,102 54
567,170 495,395
4,182 97
3,028,425 5,279,934
1,222 52
1 ,523,385 208,648
614 61
271,798 1,407,799
9,554 1,076
5,488,212 13,417,367
5,595 344
4,128,314 6,832,527
1,016 716
714,820 2,782,246
2,361 284
905,085 2,479,664
9,825 564
2,870,279 9,021,823
454 25
203,572 824,280
1,282 245
785,769 2,648,132
584 134
288,745 382,414
719 454
1 ,388,694 3,778,668
5,700 1,165
7,253,194 14,295,549
847 106
960,145 1,640,751
3,416 360
1,616,680 6,109,538
1,214 133
747,583 510,827
3,923 288
2,708,630 2,917,395
11,679 45
2,919,649 1,661,338
1 ,036 378
340,038 1,614,405
621 115
182,251 319,664

























45 7%
103,982 4%
166 7%
188,836 3%
31 10%
22,058 4%
197 32%
267,605 19%
125 19%
59,799 8%
41 7%
1,172,024 15%
85 14%
96,959 7%
17 6%
19,579 1%
63 2%
2,076,220 12%
33 2%
83,733 1%
44 4%
195,553 6%
1 77 20%
186,658 6%
105 5%
417,400 4%
6 7%
60,118 6%
81 12%
751 ,300 23%
45 9%
15,012 2%
29 5%
142,167 3%
182 4%
439,618 2%
41 10%
148,073 6%
188 14%
122,363 2%
56 13%
35,640 7%
272 12%
1,240,497 25%
96 8%
551,949 15%
37 6%
103,956 6%
15 6%
13,317 3%
52,662 20,244 92,902 165,808 152,455 13,353 4,221
258,105,953 6,748,567 12,835,771 102,536,576 175,153,715 20,390,997
1/25/01 12:38PM
       IB SDWIS/FED Factoids
www.epa.gov/safewater/data/getdata.html
                                                                                                   Lee Kyle 202/260-1154

-------
 FY2000 data-Tribal systems
 Active, current systems, from SDWIS/FED OOQ4 frozen inventory table
 Health-based (TT & MCL) violations, from OOQ4 frozen violations table
   Region
     01

     02

     04

     05

     06

     07

     08

     09

     10
CWS    NTNCWS
TNCWS
Total
Ground
          CWSs w/ reported
Surface   health-based violations
1 2 3
120 60 670
4 1
2,929 300
14 3 23
15,893 1,225 3,360
80 34 11
34,762 28,762 646
41 8 20
63,536 966 1 ,329
9 4
6,173 525
107 9 1
66,660 4,51 1 26
406 21 71
222,190 10,557 65,184
86 13 5
24,586 4,525 485
6
850
5
3,229
40
20,478
125
64,170
69
65,831
13
6,698
117
71,197
498
297,931
104
29,596









6
850
4 1
1,229 2,000
37 3
15,957 4,521
123 2
63,681 489
67 2
57,305 8,526
12 1
6,200 498
100 17
50,609 20,588
462 36
259,853 38,078
99 5
25,340 4,256









0%
0%
0%
0%
0%
0%
7 9%
417 1%
14 34%
24,768 39%
2 22%
3,298 53%
10 9%
4,493 7%
11 3%
5,428 2%
11 13%
3,866 16%
748 90 139 977 910 67 55
436,849 50,606 72,525 481,024 78,956 42,270
 FY2000 data-Commonwealths and Territories
 Active, current systems, from SDWIS/FED OOQ4 frozen inventory table
 Health-based (TT & MCL) violations, from OOQ4 frozen violations table
   Amer.
   Samoa
   Guam
 N. Marianas
   Islands
 Puerto Rico

    Palau
   Virgin
   Islands
                    CWS   NTNCWS
                     TNCWS
               Total
            Ground
                        CWSs w/ reported
              Surface   health-based violations
22
52,458
10 2
109,070 770
30 6 7
50,769 3,039 620
438 46 6
5,059,931 38,836 2,215
16 2
12,060 1,163
138 169 156
99,021 73,780 23,604
22
52,458
12
109,840
43
54,428
490
5,100,982
18
13,223
463
196,405






12 10
49,618 2,840
8 4
20,990 88,850
43
54,428
263 227
722,633 4,378,349
2 16
400 12,823
4 459
4,573 191,832






14 64%
6,045 12%
0%
0%
0%
0%
313 71%
4,197,044 83%
0%
0%
9 7%
1,009 1%
654 225 169 1,048 332 716 336
5,383,309 117,588 26,439 852,642 4,674,694 4,204,098
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                           IB SDWIS/FED Factoids
                    www.epa.gov/safewater/data/getdata.html
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GPRA
% of population served by CWSs without any reported  health-based violations
 Nationally
2000
1999
1998
1997
1996
1995
1994
1993
91%
91%
89%
87%
86%
84%
83%
79%
 By region
                                         IV
            v
VI
VII
VIM
IX
2000
1999
1998
1997
1996
1995
1994
1993
62%
75%
64%
62%
60%
57%
57%
60%
76%
61%
60%
55%
53%
52%
55%
56%
97%
98%
97%
97%
92%
91%
87%
85%
95%
95%
95%
93%
93%
92%
90%
90%
95%
95%
95%
92%
92%
92%
88%
77%
96%
95%
95%
93%
94%
89%
87%
92%
95%
95%
94%
95%
95%
95%
94%
93%
94%
94%
93%
91%
92%
90%
91%
92%
94%
97%
95%
95%
91%
88%
90%
69%
83%
94%
89%
74%
74%
75%
87%
85%
CT NJ DE AL IL AR IA CO AZ AK
ME NY DC FL IN LA KS MT CA ID
MA PR MD GA Ml NM MO ND HI OR
NH VI PA KY MN OK NE SD NV WA
Rl VA MS OH TX UT AS
VT WV NC Wl WY GU
SC MP
TN PW
Health-based violations include Maximum Contaminant Level (MCL) and Treatment Technique (TT) violations.
Population data are based on active, current water systems
For FY2000, population and violation data are from SDWIS/FED OOQ4 frozen tables.
For FY1999, population and violation data are from SDWIS/FED 99Q4 frozen tables.
For FY1998, population and violation data are from SDWIS/FED 98Q4 frozen tables.
For FY1997 and earlier, population and violation data are from SDWIS/FED 98Q1 frozen tables.
1/25/01 12:38PM
       IB SDWIS/FED Factoids
www.epa.gov/safewater/data/getdata.html
                                Lee Kyle 202/260-1154

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CWS violations  reported
byFY
                   FY2000 data from SDWIS/FED OOQ4 frozen tables, except for Chem M/Rs which will be from 01Q1
                   FY1999 data from SDWIS/FED 99Q4 frozen tables, except for Chem M/Rs which are from OOQ1
                   FY1998 data from SDWIS/FED 98Q4 frozen tables, except for Chem M/Rs which are from 99Q1
                   FY1997 and earlier data from SDWIS 98Q1 frozen tables
   Number of violations
FY           MCL             TT              MIR           Other*           Total
2000
1999
1998
1997
1996
1995
4,753
5,528
6,340
5,804
7,391
7,147
3,045
2,246
2,520
2,743
3,078
3,766

58,384
54,440
64,385
121,253
139,072
10,650
1,038
1,614
1,471
1,151
1,983

67,196
64,914
74,403
132,873
151,968
            Number of systems in violation
            Population affected
by system size
            Number of violations
                      MCL
                                                      M/R
                                                                     Other
FY MCL
2000
1999
1998
1997
1996
1995
3,160
3,321
3,746
3,721
4,411
4,652
TT
1,677
1,057
1,105
1,109
1,329
1,795
M/R

9,447
10,002
10,949
13,039
14,584
Other*
8,948
627
899
860
738
959
Total

12,151
13,024
14,016
16,418
18,230
FY MCL
2000
1999
1998
1997
1996
1995
11,946,983
11,079,343
10,393,015
13,848,094
16,040,225
23,547,689
TT
15,391,464
15,854,722
18,485,545
22,059,698
22,683,315
26,409,050
M/R

19,868,126
28,313,863
27,224,547
32,529,745
40,672,345
Other*
13,882,763
2,529,718
2,369,301
3,879,160
4,671 ,792
8,707,791
Total

38,161,938
48,945,871
58,086,370
63,686,726
73,201 ,326
                                                                                     Total
Very small
Small
Medium
Large
Very large
3,046
1,122
318
251
16
Number of systems
MCL
Very small
Small
Medium
Large
Very large
2,001
710
251
186
12
Population affected
MCL
Very small
Small
Medium
Large
Very large
324,588
999,776
1,574,032
4,449,100
4,599,487
1,604
850
249
294
48
in violation
TT
944
435
124
152
22

TT
161,408
600,020
740,753
4,790,097
9,099,186
7,973
1,996
447
219
15






M/R Other Total
6,592
1,738
412
193
13






M/R Other Total
949,875
2,309,815
2,350,790
4,693,943
3,578,340





* Jump in FY2000 due to new violations for failing to issue, or issuing an insufficient, Consumer Confidence report
** Totals for the number of systems in violation, and for population affected, should be lower than the sum in each row.
This is because some systems will have incurred more than one type of violation.
1/25/01 12:38PM
                                          IB SDWIS/FED Factoids
                                  www.epa.gov/safewater/data/getdata.html
                                                                                                      Lee Kyle 202/260-1154

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NTNCWS violations reported
                          FY2000 data from SDWIS/FED OOQ4 frozen tables, except for Chem M/Rs, which will be from 01Q1
                          FY1999 data from SDWIS/FED 99Q4 frozen tables, except for Chem M/Rs which are from OOQ1
                          FY1998 data from SDWIS/FED 98Q4 frozen tables, except for Chem M/Rs which are from 99Q1
                          FY1997 and earlier data from SOWS/FED 98Q1 frozen tables
           Number of violations
        FY           MCL             TT           M/R         Other       Total
2000
1999
1998
1997
1996
1995
1,245
1,349
1,322
1,349
1,792
1,672
837
225
165
202
405
659

25,796
26,043
28,249
53,345
54,543
201
120
255
159
189
255

27,490
27,785
29,959
55,731
57,129
           Number of systems in violation
        FY           MCL             TT
       2000
       1999
       1998
       1997
       1996
       1995
      M/R
           Population affected
        FY           MCL
       2000
       1999
       1998
       1997
       1996
       1995
      M/R
                  Other
                  Other
                              Total
924
958
945
985
1,281
1,244
580
178
103
98
252
416

3,629
3,942
4,623
6,066
6,275
162
88
157
105
134
166

4,398
4,672
5,355
6,945
7,272
                              Total
276,448
292,367
232,755
280,021
380,187
392,311
217,596
53,500
23,963
32,041
93,138
150,148

848,516
994,786
1 ,241 ,807
1,435,181
1,684,183
36,519
34,947
47,772
33,877
30,201
49,236

1,112,853
1,187,783
1 ,483,754
1 ,736,465
2,010,395
TNCWS violations reported
           Number of violations
        FY           MCL             TT
       2000
       1999
       1998
       1997
       1996
       1995
      M/R
           Number of systems in violation
        FY           MCL             TT
       2000
       1999
       1998
       1997
       1996
       1995
      M/R
           Population affected
        FY           MCL
       2000
       1999
       1998
       1997
       1996
       1995
      M/R
                  Other
                  Other
                  Other
                              Total
4,407
4,956
5,201
5,408
5,934
4,879
314
226
284
379
564
492

36,266
28,116
32,581
55,420
48,843
908
752
2,159
1,794
1,810
2,082

42,200
35,760
40,162
63,728
56,296
                              Total
3,634
3,876
3,799
4,070
4,539
3,857
182
140
90
128
150
153

19,694
15,997
17,497
25,614
25,075
652
498
1,115
975
1,064
1,161

22,233
18,771
20,532
28,520
27,689
                              Total
507,741
646,469
481 ,642
539,292
625,342
671 ,739
46,201
42,582
58,801
62,557
48,098
65,295

2,217,212
2,102,061
2,230,009
3,411,919
3,219,663
78,494
63,264
143,464
128,471
115,250
128,290

2,706,984
2,458,001
2,651,801
3,731 ,987
3,622,946
* Totals for the number of systems in violation, and for population affected, should be lower than the sum in each row.
This is because some systems will have incurred more than one type of violation.
1/25/01 12:38PM
       IB SDWIS/FED Factoids
www.epa.gov/safewater/data/getdata.html
                                                                                                      Lee Kyle 202/260-1154

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FY2000 MCL and TT violations reported
From SDW1S/FED OOQ4 frozen violations table






Very small
25-500


Small
501-3,300


Medium
3,301-10,000


Large
10,001-100,000
Key:


# violations
# systems
Pop. affected
Very Large
>1 00,000 Total
Applies to all water systems

TCR/T

7,481
5,824
640,751
1,066
766
1 ,008,878
284
234
1 ,480,350
197
155
3,712,812
11
9
3,726,152
9,039
6,988
10,568,943
Organics:
Applies to CWS and NTNCWS
TTHM (VOC)
Other VOC
SOC
2
2
146
47
28
3,632
8
5
790
6
3
2,890
8
8
16,647
5
4
4,579

4
3
23,579

20
10
206,809
5
4
94,325
1
1
14,390

2
1
535,335
2
1
180,000
28
15
209,845
66
44
673,518
16
11
199,759
Inorganics:
Applies to CWS and NTNCWS

Nitrates


Other IOC

624
377
44,431
67
43
8,615
157
67
87,287
15
8
10,549
13
7
30,444
8
7
35,924
9
5
142,829
2
2
42,058
1
1
158,000



804
457
462,991
92
60
97,146
             Applies to CWS
Radionuclides
166
89
18,685
130
72
100,322
25
18
98,61 1
25
16
356,727

346
195
574,345
Applies to surface water systems
SWTR
1,236
518
91,012
Applies to CWS and
Lead & Copper
1,381
1,078
158,200
588
235
328,257
NTNCWS
390
320
388,147
180
84
508,909

76
51
285,072
197
97
3,163,152

100
84
2,666,466
33
11
6,729,982
2,234
945
10,821,312

15
15
4,577,567
1,962
1,548
8,075,452
1/25/01 12:38PM
                          IB SDWIS/FED Factoids
                    www.epa.gov/safewater/data/getdata.html
Lee Kyle 202/260-1154

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 FY2000 M/R violations  reported
From SDW1S/FED OOQ4 frozen violations table (except for Chem M/Rs)
Chem M/R data will be from SDWIS/FED 01Q1 frozen violations table (April 2001)
Very small Small Medium Large Very Large
25-500 501-3,300 3,301-10,000 10,001-100,000 >1 00,000 Total
Applies to all water systems
TCR/T
33,842
19,739
1 ,991 ,992
Organics: Applies to CWS
TTHM (VOC)
Other VOC
SOC
2,661 458 220 20
1,723 324 172 10
2,127,499 1,868,571 4,965,205 3,556,204
37,201
21 ,968
14,509,471
and NTNCWS






Inorganics:	Applies to CWS and NTNCWS
Nitrates
Other IOC




                Applies to CWS

Radionuclides

33,842
19,739
1 ,991 ,992
2,661
1,723
2,127,499
458
324
1 ,868,571
220
172
4,965,205
20
10
3,556,204
37,201
21 ,968
14,509,471
                Applies to surface water systems

SWTR

1,868
445
71 ,431
439
144
191,121
110
50
270,656
70
40
1 ,380,844
33
11
3,419,872
2,520
690
5,333,924
                Applies to CWS and NTNCWS

Lead & Copper

1 1 ,281
8,424
1,099,127
1,794
1,396
1 ,692,760
414
326
1 ,857,371
272
209
6,448,697
25
20
4,796,504
13,786
10,375
15,894,459
1/25/01 12:38PM
       IB SDWIS/FED Factoids
www.epa.gov/safewater/data/getdata.html
Lee Kyle 202/260-1154

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                                                                                       Appendix G

                  Questions & Answers about Section 508 of the Rehabilitation Act
                                        Amendments of 1998

Source: The Access Board web site, http://www.access-board.gov/news/508-fmal.htm

 1) What is Section 508?

Section 508 is a part of the Rehabilitation Act of 1973 which requires that electronic and information
technology developed, procured, maintained, or used by the Federal government be accessible to people with
disabilities. On August 7, 1998, the President signed into law the Workforce Investment Act of 1998, which
includes the Rehabilitation Act Amendments of 1998. Section 508 was originally added to the Rehabilitation
Act in 1986; the 1998 amendments significantly expand and strengthen the technology access requirements in
Section 508.

2) How do these changes to Section 508 improve upon the earlier version?

The 1986 version of Section 508 established non-binding guidelines for technology accessibility, while the
1998 version creates binding, enforceable standards and will incorporate these standards into Federal
procurement regulations. Federal  agencies will use these standards in all their electronic and information
technology acquisitions.  Consistent government-wide standards will make it easier for Federal agencies to
meet their existing obligations to make their technology systems accessible to people with disabilities, and
will promote competition in the technology industry by clarifying the Federal market's requirement for
accessibility in products intended for general use. The new version of Section 508 also establishes a
complaint procedure and reporting requirements, which further strengthen the law.

3) To whom does Section 508 apply?

Section 508 applies to Federal departments and agencies.

4) Does Section 508 apply to the private sector?

No, it does not regulate the private sector and does not apply to recipients of Federal funds.

5) What does Section 508 require of Federal agencies and departments?

Section 508 requires that when Federal agencies develop, procure, maintain, or use electronic and
information technology, they must ensure that it is accessible to people with disabilities, unless it would pose
an undue burden to do so. Federal employees and members of the public who have disabilities must have
access to and use of information and services that is comparable to the access and use available to
non-disabled Federal employees and members  of the public.

6) How will Federal agencies and departments  know whether the electronic and information
technology is accessible?

New standards have been established to help Federal agencies determine whether or not a technology product
or system is accessible. Federal agencies must comply with these technology accessibility standards for all
electronic and information technology acquired on or after six months from the date the Access Board issued

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its final standards (December 21, 2000). Technology developed or acquired for a Federal agency by a
contractor must also comply with the standards. If a Federal agency determines that it would pose an undue
burden to comply with the standards, it must still provide information and data to individuals with disabilities
through an alternative means of access that can be used by the individuals.

7) How will these technology accessibility standards be developed?

The Board was required to issue standards that define which electronic and information technology is
covered by Section 508, and describe what is meant by 'accessible technology' by setting forth the technical
and functional performance criteria necessary to implement the accessibility requirements. The Board was
required to consult with the Departments of Education, Commerce,  and Defense, the General Services
Administration, the Federal Communications Commission, the electronic and information technology
industry,  and disability  organizations in developing its standards. The Access Board created an Electronic and
Information Technology Access Advisory Committee (EITAAC) to advise it on the standards. The
Committee's final report was delivered to the Board on May 11, 1999. On March 31, 2000, the Board
published a Notice of Proposed Rulemaking based on the Committee's recommendations.

8) How will the standards be applied to federal procurement?

Six months after the Access Board published the final  standards, the Federal Acquisition Regulatory Council
is required to revise the Federal Acquisition Regulation and each Federal department or agency shall revise
the Federal procurement policies and directives under their control to incorporate the standards. The Access
Board will periodically review and update the standards as necessary.

9) What are Federal agencies required to do in the short term to comply with Section 508?

Agencies must evaluate their current electronic and information technology systems for accessibility to
individuals with disabilities, and submit a report to the Attorney General containing the results of the
evaluation.

10) What reporting requirements does Section 508 create?

The Attorney General must submit a report to the President on the extent to which the electronic and
information technology of the Federal Government is accessible to individuals with disabilities. The
Department of Justice issued its report April 19, 2000. In addition, every two years thereafter the Attorney
General must report to the President and the Congress  on Federal  agency compliance with the requirements
of the law, and on any actions on individual complaints.

11) Where can Federal  agencies go  for technical assistance?

The General Services Administration and the Access Board will provide technical assistance  on the
requirements of Section 508. Agencies and individuals may also seek information from the many public,
non-profit, educational, or private institutions and organizations that specialize in making technology
accessible to people with disabilities. These organizations, along with companies in the electronic and
information technology industry, can assist agencies in identifying innovative technology or in developing
accessible technology solutions.

12) Are there any exemptions to the technology accessibility standards?


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A Federal agency does not have to comply with the technology accessibility standards if it would impose an
undue burden to do so. This is consistent with language used in the Americans with Disabilities Act (ADA)
and other civil rights legislation, where the term 'undue burden' has been defined as "significant difficulty or
expense." However, the agency must explain why meeting the standards would pose an undue burden for a
given procurement action, and must still provide people with disabilities access to the information or data
that is affected.

Section 508 contains a limited exemption for national security systems as defined by the Clinger-Cohen Act
of 1996. These are systems used for military command, weaponry, intelligence, and cryptologic activities.
The exemption does not apply to routine business and administrative systems used for other defense-related
purposes or by defense agencies or personnel.

13) How will Section 508 be enforced?

Because the Section 508 standards will be incorporated into the Federal Acquisition Regulation (FAR),
agencies' procurement of accessible technology will be subject to the same stringent compliance and
enforcement mechanisms as other parts of the FAR.

There is an administrative complaint process which becomes effective six months after the Board issued its
final standards. It enables any individual with a disability to file a complaint alleging that a Federal
department or agency has not complied with the accessible technology standards in a procurement made after
that date. The complaint process is the same as that used for Section 504 of the Rehabilitation Act, for
complaints alleging discrimination on the basis of disability in Federally-conducted programs or activities. It
provides injunctive relief and attorney's fees to the prevailing party, but does not include compensatory or
punitive damages.

Individuals may also file a civil action against an agency.

14) What is meant by "electronic and information technology"?

The Access Board defined "electronic and information technology" consistent with the Clinger-Cohen Act of
1996. That Act defines "information technology" to include "any equipment or interconnected system or
subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management,
movement, control, display, switching, interchange, transmission, or reception of data or information." It
includes computer hardware, software, networks,  and peripherals as well as many electronic and
communications devices commonly used in offices.

15) Does Section 508 apply to Web sites  of federal agencies?

Yes. Federal agencies  which provide information  to the public or to their employees through Web sites must
ensure that such sites are available to all persons with Internet or Intranet access, including persons with
disabilities.

16) Does this requirement also apply to commercial or private sector Web sites?

No. Section 508 does not apply to a private sector Web site unless such site is provided under contract to a
covered entity. For example,  a Federal agency might contract with a consulting firm to collect and analyze
some demographic data and make that information available to the public on a Web site. In that case, the
Web site or portion devoted to fulfilling the contractual obligation would be subject to Section 508. The

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firm's general Web site, or the portion not devoted to the contracted study, would not be subject to Section
508.

17) Does this mean Web sites can't have graphics?

Not at all. Actually, designing an accessible Web site is not as difficult as most people believe.  Often it is a
matter of identifying graphics, elements, frames, etc. For example, HTML code already provides the
" AltText" tag for graphics which some designers simply forget or ignore.

18) Won't accessible Web sites be less appealing?

On the contrary, accessible sites have several advantages. For one thing, some people turn off graphics so
sites will load faster. Without "alt" tags, graphics-intense sites may be unusable. Also, with the  growth of
PDAs, and even Web site content delivered to cell phones, having text-based content is becoming more
important. Because the screens on such devices are so small, graphics will probably never be a viable option.
So the busy executive, waiting in an airport, who wants to check her stock portfolio on her cell  phone isn't
going to turn to the graphics-only site. Furthermore, with the growth of voice technology the harried
commuter can have the headlines from his favorite news site read to him, but only if there is a text-based
content. Finally, if a digitized video has synchronized captions, the text can be searched.

19) What does the law mean by "accessible'?

The standards developed by the Access Board explain the  detailed technical and functional performance
criteria that will determine whether a technology product or system is 'accessible.'

In general, an information technology system is accessible to people with disabilities if it can be used in a
variety of ways that do not depend on a single sense or ability. For example, a system that provides output
only in audio format would not be accessible to people with hearing impairments, and a system that requires
mouse actions to navigate would not be accessible to people who cannot use a mouse because of a dexterity
or visual impairment. Section 508 focuses on the overall accessibility of electronic and information
technology systems, not on providing accommodations at individual work sites. Section 501 of the
Rehabilitation Act requires Federal agencies to provide reasonable accommodations for individuals with
disabilities; it generally covers individual work sites but not overall technology systems. Even with an
accessible system, individuals with disabilities may still need specific accessibility-related software or
peripheral devices as an accommodation to be able to use it. For example, in order to use an accessible
word-processing program, a person who is blind may need add-on software that reads text aloud;  if the
word-processing program could not be made compatible with a screen-reading program, it might not be
accessible.

20) How does Section 508 apply to other Federal laws?

Section 508 in no way replaces or otherwise limits the rights or remedies available under any other existing
Federal law that protects the rights of people with disabilities. As part of the Rehabilitation Act, it clarifies
and strengthens the Federal government's existing obligation to ensure that technology is accessible to people
with disabilities.
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                                                                             Appendix H

                    Geospatial Data and Geographic Information System Technology

1. National GIS Program

       EPA's use of GIS technology first started in the mid-1980's in the development of a
GIS application to assist state permit writers to effectively evaluate landfill permits submitted
to EPA. This project with its innovative and unanticipated uses for spatially-referenced data
led to the development of an Agency-wide GIS management structure that was established in
1987 (OAGL0489). During that time the Agency funded support for regional GIS support
teams and promoted standardization for acquiring GIS software, hardware and supporting
relational databases. Further developments in GIS fell to individual program offices
subsequent to Agency office reorganizations.

       The Office of Environmental Information (OEI),  formed in 1999, is beginning to frame
a blueprint for an Agency Geospatial Program from an enterprise (as opposed to program)
perspective and link other major activities (such as Central Data Exchange, Facility Registry
System and others) to this initiative. This document is also intended as the foundation for
setting the Agency's involvement in interagency geospatial efforts.  The blueprint will present
EPA's "vision" for an Agency-wide geospatial program. The blueprint will lay out program
needs and the direction and  priorities for the Agency Geospatial Program over  the next five
years in the data, technology infrastructure, applications/tools, access, and partnerships
arenas. This includes, but is not limited to GIS, remote sensing, visualization and
georeferencing activities.  This blueprint effort will build on the Baseline Report on Agency
Geospatial Activities to be completed in Fall 2000. The purpose of the Baseline Report on
Agency Geospatial Activities is to document key geospatial activities and associated resources
across EPA. OEI has conducted a series of structured interviews with headquarters, regional,
and laboratory programs as well as geospatially oriented initiatives.  OEI will also review the
results of the baseline  assessment and, to the extent possible, identify needs requirements and
convene a series of users requirements meetings.  Once  completed, the Baseline Report will
be provided to key EPA offices and officials, and OEI's  external stakeholders.

       In addition, the Office of Water (OW) is currently developing a (separate) information
strategic plan (ISP) that will likely incorporate a coordinated geospatial effort across OW.
The OW plan will describe future business needs, document the current inventory of
geospatial activities and technologies, and provide plans for spatial integration across the
office.

2.      Agency Locational Data Policy

       The basis for all locational data in EPA is the Locational Data Policy (LDP) issued in
1991. The Agency LDP applies a  standard to all programs which record locational
information. This standard  issued in April 1991 (LDP, 1991) lists five mandatory and nine
optional data elements in addition  to the required latitude and longitude coordinates. The
business rules for the data standard was issued on February 1, 2000 (EPA, 2000). It provides
the roles and responsibilities for implementing the standard.  It is noted that the LDP applies
to (single) point locations and that the documentation requirements for linear or polygonal
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locations are established by the Federal Geographic Data Committee (FGDC). OGWDW
provided guidance on the locational data requirements for SDWIS in August 1998 (OGWDW,
1998) which specifically addresses public water supplies (PWS) that require locational
coordinates and sets the information coding standards and collection schedule for obtaining
this data.

       Fortunately, EPA has established GIS software and telecommunications standards to
track the guiding principles outlined in the 1991 policy.   These standards allow for an "open
system architecture" that promotes the sharing of information both within and outside EPA.
The Agency has adopted the Environmental Systems Research Institute Inc. (ESRI)
architecture as the standard geographic information system (EPA, 1993). ARCINFO® and
Arc View® are the primary ESRI GIS  applications.

       ARCINFO®, which runs primarily on Intel-based workstations and servers, provides
GIS staff with a large array of tools for developing GIS applications and managing large
databases. Arc View® in contrast is an easier to use application with fewer "whistles and
bells." However, the needs of users have driven the technology so rapidly that many more
advanced application tools are being added to "simpler" software packages making
distinctions quite minimal for the average user.

       GIS tools allow for map automation, data conversion, map overlay, and spatial
analysis. The  database defines map elements and their relationship to other elements, and it
binds data to each element. The application includes: command line interface, application
programming language, relational database analysis, and extensive peripheral support.

3.      OGWDW Locational Data Review

       The importance of conducting a user needs assessment or requirements analysis of
OGWDW programs should be part of the ISP.  A user needs assessment refers to the
identification, evaluation, prioritization and communication of mapping, surveying,
geographic and related spatial data requirements to fulfill the mission of the Agency (SDMP,
1992). It is indeed necessary for the user and management to develop its own specific
guidance and  models on how GIS will be used in the office before any decisions are made on
the selection of the technology. In addition, up-to-date comparisons of available technologies
are required to assess these needs.   A GIS capability must be built around the needs of EPA,
and specifically, OGWDW programs. The needs of the  programs need to be identified from
the beginning as these lay the basis and priorities for implementing a GIS. GIS is a tool that
will be used to assist the program managers in the mission of the office.
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                                                                           Appendix I

                    US EPA's Safe Drinking Water Goals for 2005

As required by the Government Performance and Results Act (GPRA) of 1993, US EPA has,
in conjunction with states, tribes , and other stakeholders, established performance-based goals
for 2005 which are objective, quantifiable, and measurable.

OVERALL GOAL: By 2005, protect human health so that 95% of population served by
                    community water systems will receive water that meets health-based
                    drinking water standards ... for

Watersheds

By 2005, 50% of the population served by community water systems will receive their water
from systems with source water protection programs in place.

By 2005, increase protection of ground water resources by managing all Class I, II and HI
injection wells and by managing identified, high-risk Class V wells in 100% of high priority
protection areas (e.g., wellhead , source water, sole source aquifer, etc.).

By 2005, protect drinking water sources by increasing by 50% the waters that meet the
drinking water use that States designate under the Clean Water Act.

Treatment

By 2003, provide a stronger scientific basis for future implementation of Safe Drinking Water
Act.

By 2005, standards that establish protective levels for an additional 10 high-risk contaminants
(disinfection byproducts, arsenic, radon) will be issued.

Users

By 2001, every customer served by a community water system will have access to a consumer
confidence report that contains information about the systems's source water and the quality
of the drinking water.

By 2005,
       the population served by community water systems providing drinking water that
       meets all 1994 health-based standards will increase to 95% from a baseline of 83% in
       1994.
•      95% compliance will be achieved  for any new standards within 5 years after the
       effective date of each rule.
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