Drinking Water Compliance Monitoring Data Strategic Plan SDWA 1414, as Amended by Section 2011 of America’s Water Infrastructure Act


Drinking Water Compliance
Monitoring Data Strategic Plan

SDWA 1414, as amended by
Section 2011 of America's
Water Infrastructure Act

United States Environmental Protection Agency
Office of Ground Water and Drinking Water
Drinking Water Protection Division
EPA 810-R-19-002

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Contents

Contents

1.	AWIA Section 2011: Improved Accuracy and Availability of Compliance 1
Monitoring Data

2.	Data Requirements UndertheSDWA: Howthe Data Are Used by	1
Water Systems, States, EPA, and the Public

3.	Data Accuracy Challenges and ActionsTo Improve It	5
State and EPA Actions Implementing Electronic Reporting	7
EPA Experience with Electronic Reporting	10
Compliance Monitoring Data Portal (CMDP)	14

4.	Drinking Water Data Access and Availability	15

5.	Key Findings and Recommendations	18

6.	EPA Action Plan	20
Acronyms	22
Glossary	23
References	24

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Contents

Figures

Figure 1: SDWIS State Process	3

Figure 2: Current Federal Reporting Process	4

Figure3: NPDESeRule Implementation Progress Dashboard	11
[June 25,2019]

Figure 4: Drinking Water Watch User Interface, Adapted by	15
Indiana Department of Environmental Management

Figure 5: Connecticut Public Health Data Explorer	"16

Figure 6: DWMAPS Drinking Water Provider Tool Example Results	17

Figure 7. EPA Enforcement and Compliance History Online	17

(ECHO) Drinking Water System Search

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1. AWIA Section 2011: IMPROVED ACCURACY AND
AVAILABILITY OF COMPLIANCE MONITORING DATA

On October 23, 2018, America's Water Infrastructure Act (AWIA) was signed into law (P.L. 115-270) (U.S.
Congress, 2018). AWIA amended Safe Drinking Water Act (SDWA) Section 1414 to direct the U.S.
Environmental Protection Agency (EPA) to develop and provide to Congress a strategic plan for
improving the accuracy and availability of monitoring data collected to demonstrate compliance with
National Primary Drinking Water Regulations (NPDWRs) and submitted by public water systems
(PWSs) to states, or by states to the EPA. EPA is directed to evaluate any challenges faced in ensuring
the accuracy and integrity of submitted data; faced by states and water systems in implementing
electronic submission of data; and faced by users in being able to access the data. Finally, EPA is
directed to include a summary of findings and recommendations on practicable, cost-effective
methods and means that can be employed to improve the accuracy and availability of submitted data.

To meet this statutory requirement, EPA coordinated with states, PWSs, and other interested
stakeholders to inform this effort. These discussions included staff from state drinking water programs,
PWSs, and state laboratories, as well as staff from relevant offices at EPA.

This document highlights actions and tools developed by EPA and the drinking water community to
support improved data quality and increased electronic reporting. It also identifies a plan for further
actions. Based on feedback EPA has received from state programs, electronic reporting of drinking
water data has both improved data quality and reduced overall burden. The Agency intends to continue
to work with stakeholders to expand use of electronic reporting and to improve the accessibility of
drinking water data.

2. DATA REQUIREMENTS UNDER THE SDWA: HOW
THE DATA ARE USED BY WATER SYSTEMS, STATES,
EPA, AND THE PUBLIC

EPA is committed to improving the accuracy and availability of drinking water data that states, EPA,
and the public receive to inform public health actions. Access to drinking water compliance monitoring
data can empower communities to take needed action. It also provides a more complete picture of
water quality than simple violation information, and this can improve consumer confidence or identify
a potential problem.

Public health protection relies on accurate and complete data. PWSs, primacy agencies* the EPA, and
consumers all need accurate, timely, and accessible drinking water data to make informed decisions.
State and federal regulators need data of known and documented quality and completeness to develop
effective and appropriate policy decisions, provide training and technical assistance, and conduct
oversight. Accurate and timely monitoring data, along with resultant state enforcement information,
also allows EPA to conduct its enforcement oversight responsibility. Consumers want access to reported
monitoring data from the water system that supplies their home. PWSs use the monitoring results to
make changes in treatment or other operational decisions.

*The terms state and 'primacy agency' are both used in this document and are defined as the agency with primary
responsibility for implementing the SDWA. The U.S. territories, the Navajo Nation, and all states except Wyoming have
been approved to exercise primary responsibility in their jurisdictions. EPA implements the SDWA in Wyoming,
Washington,DC, and on all other tribal lands.

Drinking Water Compliance Monitoring Data Strategic Plan

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PWSs regulated under the SDWA must conduct
compliance monitoring in accordance with 40 CFR
141 Subpart C to show that the water is meeting
health standards.

The EPA's and states' primary method of
monitoring PWS compliance with the SDWA and
its implementing regulations is the review and
evaluation of analytical results of water samples
and operating reports collected by PWSs, These
monitoring results and reports provide the water
systems and regulators with the data they need to
ensure that drinking water monitoring is ongoing,
that treatment processes are working, and that the
drinking water standards are being met. In some
cases, monitoring is done to determine if specific
contaminants such as arsenic are present at levels
higher than the public health standard. In other
cases, water systems are required to conduct indicator monitoring to assess for contamination and
to ensure treatment is effective. Indicator monitoring is performed when it is not feasible to measure
the contaminants of concern and there are other measures that have been associated with the
presence of these contaminants in drinking water. For example, it is not feasible to measure for ali
waterborne pathogens that could be in drinking water; therefore, coliform and E. coli are monitored
as an indicator of fecal contamination and turbidity is monitored as an indicator of the removal of
pathogens by filtration. Monitoring requirements vary based on the size of the water system, the
water source, and previous monitoring results.

EPA is required to ensure that primacy agencies are properly implementing the Public Water System
Supervision program, including conducting monitoring and collecting data as EPA requires by
regulation to protect human health. The primacy agencies report violation information quarterly to
EPA. EPA uses the violation information, along with annual reviews of primacy programs and other
interactions, to oversee the national program and to provide information to the public.

EPA does not currently receive all water system compliance monitoring data except in Wyoming,
Washington, D.C., and tribal lands other than the Navajo Nation. This limits EPA's ability to determine
the completeness of the data received by the Agency and hinders the development of national
training, technical assistance, and oversight. For its oversight, EPA has identified additional data needs
such as having consistent access to compliance monitoring data, along with system inventory and
violations data, to ensure data quality and national consistency. This report focuses on ongoing and
potential future steps to address the data needs.

How Compliance Monitoring Data Are Transmitted to
Primacy Agencies

Drinking water monitoring requirements are based on the health
effects of the contaminant, the type of system, the size of system,
and other water system characteristics for each regulation.
In most cases the water system is responsible for conducting
monitoring.

Each primacy agency receives compliance monitoring data directly from the laboratory conducting
the analyses or from the PWSs. The laboratory will report the analytical results either electronically or
by mailed hardcopy. When the laboratory results are only received by the PWS, the system then sends
the results to the primacy agency either electronically or via mailed hardcopy. The paper results are,
generally, manually entered by the primacy agency into an electronic system to be used for
compliance determinations.

EPA and states define
monitoring periods for the
water systems based on the
National Primary Drinking
Water Regulations.

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Safe Drinking Water Information System State

Most drinking water primacy agencies store compliance
monitoring data in the Safe Drinking Water Information
System (SDWIS) State. SDWIS State is a software package
developed and maintained by the EPA and provided to
the primacy agencies for installation and operation in their
local computing environments to manage their Public
Water System Supervision Programs. SDWIS State houses
compliance data and makes automated initial compliance
determinations on the data as it is entered into the system.

This allows primacy agency staff to determine follow up
actions, including training, technical assistance, or
enforcement. SDWIS State is delivered as a set of software
components (Figure 1) that consist of separate software
configuration management items and optional add-on
components, such as a public access portal. Many primacy
agencies use the add-ons, but many others have
developed their own components that replicate many of
the features of the EPA-distributed add-ons.

Compliance monitoring data can be entered into SDWIS
State or a primacy agency's separate database in several
ways. In addition to state staff hand entering data from
the lab reports into the system, there are electronic systems available to facilitate the process. Examples
of these types of systems are: SDWIS Migrate to State, SDWIS XML Sampling, and the Compliance
Monitoring Data Portal (CMDP). Descriptions of these systems can be found in Section 3 in this
document.

Figure 1: SDWIS STATE PROCESS

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Safe Drinking Water Information System Federal Version

EPA does not receive most compliance monitoring
data provided to primacy agencies. All primacy
agencies submit a subset of drinking water data to
EPA through the Safe Drinking Water Information
System Federal Version (SDWIS Fed). SDWIS Fed is
the EPA's national database that manages and
collects PWS information from primacy agencies,
which includes violations of drinking water health-
based standards, reporting and monitoring violations,
and other basic inventory information, such as water
system location, type, and population served. SDWIS
Fed is primarily used for EPA oversight of primacy
agencies, for national implementation efforts, and for
informing the public about the reported compliance
status of their PWSs, and, indirectly, the safety of their
drinking water.The EPA uses the information in
SDWIS Fed to perform various analyses that support
programmatic decisions and identify trends,
problems, and opportunities for improvement in the
states' implementation of rules as well as their
program oversight. Consequently, the utility of SDWIS
Fed information for these purposes highly depends
on the quality completeness, and timeliness of the
data provided by primacy agencies.

Figure 2 shows the way data enters SDWIS Fed.

Figure 2: CURRENT FEDERAL REPORTING PROCESS

Manual Entry of
Monitoring
Data

[Paper transfer of
monitoring data]

Compliance

1

Monitoring



Data Portal



(CMDP)



[Electronic transfer



of monitoring data]

l

SDWIS State

[Determine compliance,
quarterly export system
inventory & violations]

SDWIS FedRep

[Ensure inventory
& violations file
integrity]

SDWIS Fed
Production
Control Tool

[Identify inventory &
violations data
quality errors]

SDWIS Fed Data
Warehouse

[Receive quarterly system
inventory & violations]

Non-SDWIS

State
Application

[Determine
compliance> export
system inventory &
violations]

Legend



| Green

- Primacy Agency Network

¦ Blue

- EPA Network

Yellow

- EPA Developed Software Installed



on Primacy Agency Network

Public Access Tools

•	SDWIS Fed Reporting Services

•	Enforcement and Compliance
History Online (ECHO)

•	Envirofacts

•	Drinking Water Mapping
Application for Protecting
Source Water (DWMAPS)

•	How's My Waterway?

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3. DATA ACCURACY CHALLENGES AND ACTIONS TO
IMPROVE IT

Data accuracy includes both the accurate recording of the sample result and the completeness of the
set of samples provided to the primacy agency and EPA. The SDWA requires PWSs to routinely monitor
and report compliance monitoring samples and other data to primacy agencies to show water quality
and the effectiveness of treatment. If a system does not monitor and report the quality of its water
in a complete and accurate way consumers and primacy agencies cannot know whether the water
meets health-based standards. If the EPA does not receive complete, timely and accurate data from
primacy agencies, then the Agency cannot conduct its statutorily required oversight and support of
state programs. EPA currently receives information from states related to violations and inventory and
provides this information to the public through various EPA internet data access tools. EPA does not
receive from states all compliance monitoring data that states collect from drinking water systems and
labs. As the demands for state and EPA drinking water activity have increased significantly in recent
years, EPA's limited access to compliance monitoring data is hampering efforts to support state
responses to systems in violation and identification of systems at risk of violation. Because EPA only
receives information when the state determines a violation and sends that violation information to EPA,
the lack of violation information in EPA's database may mean there was no violation, or that the state
incorrectly or inadvertently determined no violation, or that no data was submitted by the primacy
agency.

Data quality management involves the entire lifecycle of a point of data from collection to
documentation and to submission. The shorter the distance from the beginning of the lifecycle to the
end use in analysis the better, since an error can be introduced into the data flow each time the data
changes hands. This is particularly true for those systems and labs using manual entry of compliance
data into paper spreadsheets. Copy/paste errors, misinterpreted handwriting, and the loss of physical
copies reduces the quality and completeness of data. This is also the case for the manual entering of
data into electronic systems.

The EPA evaluates state and EPA direct implementation programs in part by conducting primacy
agency file review audits for each primacy agency approximately once every four years. The file review
audits evaluate primacy agency compliance decisions and reporting to SDWIS Fed. These reviews
specifically include the assessment of monitoring and reporting issues. The data quality challenges
relate to both those data submitted to SDWIS Fed as well as those data cataloged and submitted via
labs to primacy agencies.

In 2009, the Office of Ground Water and Drinking Water (OGWDW) conducted an analysis of data
quality in SDWIS Fed that demonstrated that data quality was an ongoing and significant issue
requiring the attention of EPA and primacy agencies. Data quality for health-based violations was
61 percent, and data quality for monitoring violations was as low as 21 percent. This meant that the
health-based violation shown for a system or the lack of identified violation could be incorrect
nearly one third of the time. The reasons for low data quality were both incorrect compliance
determinations and correct information not flowing to EPA's database. Following this analysis, the
EPA initiated a dialogue with primacy agency officials regarding corrective measures to be taken.

In 2011, the U.S. Government Accountability Office (GAO) also found that the data states reported to
the EPA for measuring compliance with health and monitoring requirements of the SDWA did not
reliably reflect the number of health-based and monitoring violations that community water systems
have committed or the status of enforcement actions.

Since then, the EPA has implemented a suite of automated data quality and analytics tools to protect
the integrity of drinking water data and improve dataset interoperability and analysis capabilities. The
EPA and primacy agency staff have had an ongoing data management committee to discuss and
address issues in data reporting, and this has improved data quality. The EPA's Office of the Inspector
General (IG) published a report in 2017 which determined that the EPA is taking actions to improve

Drinking Water Compliance Monitoring Data Strategic Plan

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oversight tools used to determine whether PWSs are monitoring and reporting drinking water quality
in accordance with the SDWA.

Throughout the entire SDWIS suite of software there are edit checks and data validations to increase
the accuracy of compliance monitoring data. The following are examples of how data quality and data
integrity checks have been implemented with the SDWIS software.

Core SDWIS State

The core SDWIS State component supports the functions necessary for effective management of a
primacy agency Public Water System Supervision Program:

¦ Sample Result System for storing results of all compliance monitoring.

¦ Compliance Determination System for evaluating sampling results against schedules and
federal standards and identifying and accepting or rejecting candidate violations.

¦ Enforcement Management System for managing enforcement actions associated with
violations.

¦ PWS Inventory Management System for maintaining information characterizing water systems
relevant to EPA oversight and maintaining engineering data relevant to the primacy agency.

SDWIS State includes basic information on each
system such as the type of system (community
transient, non-transient non-community), source of
water (ground or surface), and the population served
by the system. This is the main tool that primacy
agency staff will use to enter/update data. Every
screen in SDWIS State has buiit-in edit checks that
will verify that the data being saved will meet federal
and state needs for data integrity.

SDWIS XML Sampling

SDWIS XML Sampling is the product for processing
and transferring compliance monitoring data to
a SDWIS State database. This application has edit
checks that verify the sample and result information
being migrated into SDWIS State meets data quality
and completeness criteria, such as accurate system
identification and locational information.

SDWIS Migration to State

SDWIS Migration to State is the product that supports
batch insert and, in some cases, update of SDWIS
State data. This application has edit checks that verify
that the data being migrated into SDWIS State meets
data quality and completeness criteria.

SDWIS Fed Rep

SDWIS FedRep is an integrated set of tools that assist the EPA and primacy agencies with the
extraction, formatting, validation, and preparation of federally reportable drinking water data. When
SDWIS FedRep processes data that will be submitted to the federal data system, the data are first

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reviewed by SDWIS FeciRep to ensure they are complete and accurate. SDWIS FedRep has over 500
data quality checks that it will apply as appropriate when validating violations, and other federally
reportable drinking water data, to ensure the data are complete and accurate. This is the last set of edit
checks before the data reach the federal data system.

The systems, tools, and procedures the EPA developed for data accuracy include:

¦ Data Quality Matrix - One of the secure reports accessible through Central Data Exchange (CDX)
is the Data Quality Report. These reports generate data quality scores based on criteria including
locational data, timeliness ofviolations reporting, and updated software use. The EPAdelivers data
quality awards to primacy agencies based on those scores in the data quality matrix. These awards,
delivered annually, serve as a baseline for successful data quality as well as performance metrics for
state drinking water programmatic staff.

¦ Production Control Tool- For state data submitted to SDWIS Fed. This tool provides validation
of the data submitted to the EPA by the primacy agencies so that the data meet data quality
requirements. Thistool provides a wayfor primacy agencies and the EPA to reviewthe data they
are submitting and review any errors or issues with the submissions prior to the EPA approving
and processing the data into the operational data store and quarterly processing into the Safe
Drinking Water Data Warehouse (SFDW). It also includes a summary of any issues with the
data identified by the SDWIS FedRep tool (described in the previous section) prior to submittal to
the EPA

¦ SDWIS Data Quality Check Tool - This tool allows primacy agencies to check the data quality
of their entire SDWIS State data set. The checks include the SDWIS FedRep data validations
and many others that are meant to check other SDWIS State data and not just the data to be
submitted to the EPA.

STATE AND EPA ACTIONS IMPLEMENTING
ELECTRONIC REPORTING

Electronic reporting has proven to be a very successful
tool for improved data quality. Several states and the EPA
have experience successfully utilizing electronic reporting
to improve and modernize data reporting in multiple
programs and across different environmental media.

The motivation behind a move to e-reporting of any data is
ease of use, burden reduction, and increased data accuracy.
Utilizing web-based platforms for data submission and
processing provides real and immediate burden reduction
through streamlining of resources in both materials and
staff. For instance, Utah reported that it has experienced a
burden reduction of approximately 80 percent by moving
to e-reporting. The move from hand-entered analog data
to digital web-based systems also supports adaptable and
centralized data quality controls. Kentucky reported that
it currently has 82 percent of its laboratories reporting via
an electronic portal and has seen as much as a 40 percent
reduction in reporting errors.

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Buiiding on state efforts to support electronic reporting of drinking water data, in October 2016 the EPA
launched software allowing water laboratories and PWSs to electronically share drinking water data
with their states and tribal agencies (U.S. EPA, 2016). The Compliance Monitoring Data Portal (CMDP)
allows primacy agencies to replace paper-based processes, leading to more timely and higher-quality
monitoring data by incorporating data validations and quality checks at the initial point of entry. By
reducing the hours previously spent manually entering data from lab reports, identifying data-entry
errors, and issuing data resubmittal requests, states and tribes are now able to free up more time to
focus on preventing and responding to public health issues in their communities. In one example of
burden reduction, Utah drinking water staff indicated they went from approximately a 20 percent error
rate in submitted files to approximately 0.4 percent once they began using CMDP.

STATE-SPECIFIC EXPERIENCE WITH
ELECTRONIC REPORTING

EPA has garnered feedback from many of the
states with e-reporting rules and/or experience
implementing their own e-reporting online portals.
The examples below outline the experience of a few
of those states as programmatic case studies:

Alaska

Alaska's drinking water program has been accepting
electronically reported compliance monitoring data
from laboratories in the state since 2005, before EPA
released the CMDP. In 2005, Alaska implemented its
own online porta! for capturing electronic
compliance monitoring data. The state mandated
that ail laboratories submit their sampling
data via an online e-reporting portal. Some smaller
systems were given more time to implement the
practice since there are large areas in Alaska with
broadband accessibility issues. Many of Alaska's
drinking water systems, both small and large,
expressed concern when this e-reporting rule was
implemented in 2005. Yet, the overwhelming
majority of users transitioned without issue and
acknowledged the process was helpful once it was
implemented. There were no technical obstacles in
the way of transitioning to e-reporting. Technical
support and ongoing trainings were (and are)
available to portai users.

Alaska drinking water managers identified early in the e-reporting process the benefits of data
accuracy improvements. Alaska's own proprietary portal allowed the drinking water program staff
to create their own targeted data quality checks, which are captured on both the "data-in" (user
interface) side during data entry as well as the "data-out" side (database population and reporting).

Alaska had a head start in transitioning to CMDP in 2017, having already set up its own data portal. The
IT infrastructure required for data management, storage, and flow was built so that potential technical
barriers and challenges were reduced. This contrasts with primacy agencies that plan to transition or
have transitioned to CMDP directly from paper reporting.

O ,

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The success of Alaska's adoption of CMDP is amplified
by the data quality improvements realized through the
additional utilization of a state-derived data validation
tool. During the first six months after adopting CMDP,

14,395 sample records were submitted to the state.

Of those, only 224 records were rejected by the state
data validation tool. Alaska credits the training and
documentation they provided to the labs before
moving to CMDP as the reason they experienced a
relatively low percentage of errors with the tool. The
software for this validation tool is available for other
states to adapt and utilize.

Ohio

Ohio EPA's Division of Drinking and Ground Waters
(DDAGW) has been accepting electronically reported
compliance data from both laboratories and PWSs
since 1998. DDAGW's first e-reporting solution was
called DrinkWare and was a stand-alone application
that was installed on the customer's computer. It could
be used for reporting laboratory results as well as PWS
monthly operational reporting (MOR) data. Data was
entered and transmitted to the Agency through email
loaded into DDAGW's legacy system (DRINKs). Use of
DrinkWare was voluntary.

In 2006 DDAGW purchased from Enfotech e-Drinking Water Reports (eDWR). The new eDWR
application is web based and therefore unlike the previous DrinkWare application does not require
any software installation. Enfotech was hired to customize eDWR to work in Ohio EPA's public portai.
During implementation, DDAGW consolidated 19 forms to just four. Use was still voluntary when
eDWR was released in 2008. In 2010 Ohio EPA required all laboratories to submit sample data
electronically using eDWR. In 2012 Ohio EPA updated their rules to require water systems to submit
MOR data electronically using eDWR.

Water systems were phased in using a three-tier approach:

¦ Water systems with a population of 3,301 and greater byJulyl,2012.

¦ Water systems with a population of 501 - 3,300 by July 1,2013.

¦ Water systems with a population of 500 or fewer by July 1, 2014.

DDAGW realized the greatest benefits once laboratories and water systems were required to submit
data electronically:

¦ Data quality vastly improved because of data validation by eDWR and XML Sampling.

¦ The number of full-time equivalents (FTEs) needed to support data entry has been greatly reduced
to about ha if an FTE from a high of six or seven FTEs back in 1998.

¦ DDAGW can better ensure water quality because data that once took months to be entered into
the database is now loaded in hours once received from customers.

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eDWR by the numbers:

¦ Annually DDAGW receives around 22,300 Plant Distributions MORs and 1,696 Surface Water MORs.

¦ Over 5,190 chemical submissions are received annually for a total of over 187,000 sample results.

¦ Over 10,000 Total Coliform Rule (TCR) submissions are received annually for a total of over 160,000
sample results.

¦ There are over 2,470 registered users submitting MOR data from 1,918 PWSs and over 770
registered users submitting sample data from 237 laboratories.

Utah

The Utah Division of Drinking Water (DDW) was involved in the early testing stage of the CM DP
through the 2016 calendar year. In February of 2017, Utah was the first state in the nation to have a
laboratory begin submitting electronic data through the CMDP production environment. Within six
months, four laboratory organizations were registered and actively implementing the new portal.
Currently, thirteen laboratories are active.

Utah's approach for training each lab involves a walkthrough of the submittal process, as well as
identifying and understanding validation errors. This is either completed through conference calls with
a DDW staff member, or they visit onsite to provide the training in person.

When a lab is new to the CMDP, Utah encourages the organization to focus on submitting routine
total coliform data through the portal. As competency solidifies, more sample types and categories are
introduced until they no longer rely on paper reporting.

EPA EXPERIENCE WITH ELECTRONIC REPORTING

The EPA published the National Pollutant Discharge Elimination System (NPDES) Electronic Reporting
Rule (eRule) in 2015. The EPA's Office of Air and Radiation (OAR) also developed an Electronic Reporting
Tool (ERT) for emissions source test data in 2014. Additionally, and most programmatically relevant to
this strategic plan, the Office of Water has been using electronic data submission for the Unregulated
Contaminant Monitoring Rule (UCMR) since 2001 via the Safe Drinking Water Accession and Review
System (SDWARS). The EPA also established a policy in 2013 that it will start new regulations with the
assumption that reporting would be electronic and not paper-based (U.S. EPA, 2013).

NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM ELECTRONIC REPORTING
RULE

The most recent example of large-scale e-rule implementation was when the EPA signed the NPDES
eRule on September 24, 2015, and published it in the Federal Register on October 22, 2015 (40 CFR
127) (U.S. EPA, 2015). This rule modernizes the Clean Water Act (CWA) reporting for municipalities,
industries, and other facilities. The rule replaces most paper-based NPDES reporting requirements with
e-reporting (U.S. EPA, 2018a).

The NPDES Permit Program regulates point sources that discharge pollutants to a water of the United
States. This requires regulated entities to report information via reports to the EPA. The data that these
regulatory authorities share with the EPA include permit, compliance monitoring (e.g., inspection),
violation determination, and enforcement action data.

Drinking Water Compliance Monitoring Data Strategic Plan

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The rule also requires the EPA to assess the progress each authorized state is making in implementing
NPDES e-reporting and to repeat these assessments annually. Figure 3 illustrates the dashboard that
tracks this progress.

The NPDES eRule sets a start date for all regulated municipalities, industries, and facilities to report
their required data electronically by the dates set forth in 40 CFR 127.16. Discharge Monitoring Reports
and Biosolids Reports, a significant component for adherence to CWA regulations, were set for
implementation a year after rule passage (December 21, 2016). An additional four years was provided for
other entities to report electronically by December 21, 2020 (e.g., general permit and program reports).

Figure 3: NPDES ERULE IMPLEMENTATION PROGRESS DASHBOARD [JUNE 25, 2019]

| Permit Limits Not in ICIS H DMR Tracking "Off" Unresolved DMRs DMR Ready

No selections applied

NPDES eRule Readiness and Data Completeness Dashboard

Percentage of Permits In Evaluation Categories by State

ieex
sen

60%

40%

20%
0%

% R*lat*d Tool* O H*lp |
¦

III,hill,lliijllilA,III

AK AL AR AS A2 CA CO CT DC DE FL GA GM GU HI IA ID II IN KS KY U MA MD ME Ml MN MO MP MS MT MW

miimiiimnimiiimiimmiiiiiiiiiiiiiiiiiiiiiiiiii

Permitting State

Region

Major/Minor

Evaluation Category

Components

Issuing Agency

PermlttJ...

Number of Permits in Selection o,ato Q.

36,177

DMR Ready Unresolved DMRs Tracking Off Permit Limits Not in ICIS

23766 8651 735 3025

Data submission methods (paper vs. electronic) were completely up to the states prior to the NPDES
2015 eRule. In 2009, approximately 24 facilities were starting to migrate to digital data submission and
more followed over the years; by 2015, approximately 10,000 users were submitting data digitally to
the EPA's national NPDES data system (Integrated Compliance Information System (ICIS)). In the past
three years since the passage of the mandatory eRuie, the NPDES Program has more than tripled
that number to more than 37,000 facilities that have submitted discharge monitoring reports (DMRs)
through NetDMR (EPA's e-reporting tool for DMRs).

The burden imposed on regulated entities and states is minimal due to the flexibilities built into the
rule. States couid use the EPA NetDMR e-reporting tool, or they could use their own online portal
for data submission. There are also three separate waivers available to permittees and issued by the
states. These waivers to e-reporting are granted on either a temporary or emergency basis and provide
the flexibility to states, regions, and biosolids programs. These are mainly employed due to a lack of
broadband internet access or the staff level expertise necessary to conduct electronic data entry. The
result, however, is that states have a buiit-in incentive to discourage widespread waiver use because, if
they do grant a waiver, they themselves must perform the necessary data entry using the hard copy
submissions.

One additional, and challenging, aspect of implementing any e-reporting rule is the need for digital
security in an increasingly digital United States government. The EPA's Cross-Media Electronic
Reporting Rule (CROMERR) provides the legal frameworkfor e-reporting under the EPA's regulatory

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programs. It provides performance-
based, technology-neutral system
standards and a uniform process for
the EPA review and approval of e-
reporting. Additionally the CROMERR
program ensures the enforceability
and security of regulatory information
collected electronically by the EPA
and the EPA's state, tribal, and local
government partners (U.S. EPA,
2019a). In the case of the NPDES
eRule, the EPA's CDX website
provides the digitally secure
framework from which to verify the
identity of users submitting data and
hosting those data on a secure
web-based platform. Granting users access to CDX is an additional step in the electronic data
submission process and is an additional hurdle for some users to navigate as well as the EPA to support.
Information technology security is a major consideration that should be discussed early and often when
designing data reporting workflow.

EPA ELECTRONIC REPORTING OF AIR EMISSIONS DATA

Other environmental programs also use electronic reporting. The EPA's OAR developed an ERT used
by affected industrial facilities to electronically create stationary source sampling test plans and reports
that are submitted regularly to the EPA (U.S. EPA, 2017a). In January 2012, OAR released the Compliance
and Emissions Data Reporting Interface (CEDRI) where affected facilities submit files containing
emissions source test data (or Performance Test Reports/Performance Evaluation Reports) to CDX
via CEDRI. As with other EPA systems, the use of CDX allows the program to comply with CROMERR
requirements and security identification standards. The CDX Web is the application used by EPA
programs and various stakeholders to manage environmental data transmitted to EPA in order to meet
EPA's electronic reporting requirements. The EPA regulations codified in 40 CFR Parts 60, 62, and 63
require affected sources to electronically submit performance test reports, notification reports, and
periodic reports to the EPA.

The CEDRI program application was developed in response to the EPA promulgating rules with
e-reporting requirements that require affected sources to electronically submit source test results,
emissions monitoring data, compliance reports, and emissions reports to the EPA. The CEDRI
program service supports the submittal of four reporting types: Performance Test Reports (including
Performance Evaluation Reports), Notification Reports (i.e., Notification of Compliance Status (NOCS)
Reports), Periodic Reports, and Information Collection Requests (used to gather information that will
heip the agency review of ruies).

The ERT provides a format that:

¦ highlights the need to document the key information and procedures required by the existing
EPA federal test methods;

¦ facilitates coordination among the source, the test contractor, and the regulatory agency in
planning and preparing for the emissions test;

¦ provides for consistent criteria to quantitatively characterize the quality of the data collected
during the emissions test;

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¦ standardizes the reports; and

¦ provides for future capabilities to electronically exchange information in the reports with facility,
state, or federal data systems.

CEDRI supports submission of multiple reports at one time. The source then certifies and signs the
package using the CDX CROMERR service. The reports are stored in the CDX CROMERR archive and
are available to industry submitters and authorized EPA, regional, state, local, and tribal reviewers
immediately upon submission. A copy of the report(s) is also sent to WebFIRE after a 30 or 60-day
processing period where the report is available for public access.

EPA DRINKING WATER UNREGULATED CONTAMINANT MONITORING RULE
REPORTING

EPA has been accepting electronically reported drinking water monitoring data under the UCMR since
2001 (U.S. EPA, 2018c). The system designed to capture these data is the SDWARS. These data
ultimately reside in the EPA's National Contaminant Occurrence Database (NCOD) and on UCMR's
online occurrence data page (U.S. EPA, 2019d). The SDWA, as amended in 1996, requires EPA to design
and implement a program under which PWSs monitor a new set of unregulated contaminants every
five years. EPA identifies contaminants and specifies validated drinking water analytical methods
for monitoring. Laboratories apply and are approved to analyze UCMR samples. Approved labs are
required to report results to SDWARS, which must be updated every UCMR cycle to support the
changes in monitoring requirements. The PWSs that are subject to UCMR are required to report
inventory, contacts, zip codes, and other additional data to SDWARS prior to and during monitoring.
In recent UCMR cycles, EPA has used SDWARS to manage approximately one million sample
results per cycle. In the next cycle, the volume of sample results will approximately double, as the
scope is expanded to include all PWSs serving 3,300-10,000 people.

The 1996 SDWA amendments required all systems serving populations over 10,000 people, and a
nationally representative set of smaller systems, to report monitoring data from various locations at
the PWSs (depending on the contaminant monitored) including the entry points to the drinking water
distribution system and, for some UCMR cycles, locations within the distribution system. The 1996
SDWA amendments also established requirements for the EPA to pay for the sampling and analysis
costs for systems serving 10,000 or fewer individuals. These small system samples are analyzed via
multiple award contracts with analytical laboratories. In past UCMR cycles, 800 water systems serving
10,000 or fewer people were randomly selected for monitoring as part of the nationally representative
small-system array within each five-year cycle. Until recently, large systems exclusively reported
through SDWARS and EPA directly received electronic data deliverable files from the contract labs
that included not only field sample results but comprehensive quality control data, which were loaded
into a MS Access database for review. Starting with UCMR 4, all monitoring results, inventory, contacts,
and data elements are reported through SDWARS from both large and small systems, including
comprehensive laboratory quality control data. In addition, EPA's small-system data management was
integrated into SDWARS (e.g., kit tracking, schedules, data review, compliance assistance, and
invoicing). SDWARS also provides a centralized location for various user groups (laboratories, PWSs,
states, Regions, EPA staff, and contractors) to review, edit and review the information reported to
SDWARS.

The advancement of the UCMR program, along with the expanding scope for what is reported, presents
ongoing data management challenges. One example is managing the complete array of method
quality control data with all field sample results. Labs continue to work with the program to implement
these changes and continue to benefit from the advantages SDWARS provides.

Drinking Water Compliance Monitoring Data Strategic Plan

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COMPLIANCE MONITORING DATA PORTAL (CMDP)

EPA released the CMDP in 2016 to support electronic reporting of drinking water data. CMDP enables
drinking water utilities and laboratories to report data electronically to primacy agencies with fewer
errors and in a more efficient manner. The portal increases data accuracy and completeness and can
potentially decrease the overall reporting burden for primacy agencies by hundreds of thousands of
hours.

Drinking water primacy agencies can use the portal-reported data to make more informed decisions
about water system compliance and focus their limited resources on preventing and responding to
public health problems. Primacy agencies, water systems, and laboratories will continue to report data
to EPA based on the content and schedule outlined in the current regulations.

Water system and legal entity information is loaded into the CMDP from a primacy agency's SDWIS
State system (or other compliance determination system) from the Data Synchronization Engine
(DSE) installed within the primacy agency environment. Sample data are transferred after certification
through the DSE to the primacy agency for compliance determination.

As of September 2021,19 primacy agencies are using the CMDP. Ten additional primacy agencies are
currently moving toward CMDP adoption.

While CMDP was initially envisioned to support only federally regulated contaminants, it has been
expanded to support state regulated contaminants and other contaminants of interest as well. This
support provides a platform for more consistent water data collection across primacy agencies and
greater sharing opportunities.

The use case highlighted below from a utility in Louisiana provides a look at CMDP implementation
from a laboratory perspective.

Lafayette Utilities System (LUS) Drinking Water Laboratory

Serving approximately 145.000 people, LUS has a dedicated drinking water laboratory that
processes all the municipality's own raw data and samples. Louisiana adopted CMDP in 2016
and LUS began electronically reporting their data. Just one individual staff member is able to
sample and process lab data via their current procedures. There are both mid-level and final
quality assurance checks completed as the data moves through the process and before the
data are batch uploaded to CMDP. Additionally, LUS has had success due to the data validation
checks via CMDP. Even in the narrative text fields within the lab results, there are error flags
thrown within CMDP that allow errors to be rectified by the user. The submitted results are then
certified by the state. The LUS Drinking Water Laboratory is a relatively small operation without
extensive IT expertise; however, it has built a successful electronic reporting process using
CMDP. State drinking water managers have visited to see how they can recreate their successes
elsewhere in the state. LUS also works with other municipalities, has developed resource
materials to aide in CMDP adoption, and works with others if technical problems arise.

Drinking Water Compliance Monitoring Data Strategic Plan

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4. DRINKING WATER DATA ACCESS AND AVAILABILITY

The systems described below are examples of what the LPA and state agencies are producing to
explore those data which are already publicly available.

Drinking Water Watch

Drinking Water Watch is a state-level
web-based application of SDWIS
State used by many state programs
that allows the public to query and
view compliance monitoring data and
other information contained within
a primacy agency's SDWIS State
drinking water database. It allows the
users to easily find information related
to a specific water system such as
violations, analytical results, contact
information, and inspection findings.
Figure 4 depicts the home page of
the Indiana Drinking Water Watch
web page.

Figure 4: Drinking Water Watch User Interface, Adapted by Indiana
Department of Environmental Management

Public Water Supply Systems Search Parameters

Water System No.

Water System Name
Principal County Served
Water System Type
Primary Source Water Type
Point of Contact Type

All
All
All

None

Sample Search Parameters

Sample Class
Sample Collection Date Range

(The Sample Search always produces results for the
last 2 years, unless you provide a specific date range.)

Click to select a value...

To 3/15/2020

Search For Water Systems Search For Samples Review Consumer Confidence Data Clear Glossary
Click Here for the County Map of Indiana

EPA and many states and individual water
utilities currently make drinking water data
available to the public. The more access
PWSs, primacy agencies, federal agencies,
and regulated entities have to drinking
water compliance monitoring data, the
more effective program management can
be. Providing access to a consumer's water
system monitoring data can also empower
the individual or community to take any
necessary action. Data analysis, including
environmental modeling efforts, wouid be
improved dramatically by the increased
availability and sharing of drinking water
data. Currently there is no national access
to compliance monitoring data. Some individual states make compliance monitoring data available
online, but as noted previously EPA does not have access to most compliance monitoring data.
EPA's publicly available national data primarily includes inventory and violations information.

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Connecticut's Drinking Water Health Dashboard

Connecticut's Healthy Connecticut 2020 Performance Dashboard displays in a simple visual format
how the residents of Connecticut are faring in health improvement target areas such as heart disease,
obesity obtaining vaccinations, exposure to environmental risks, and many more as identified in
Healthy Connecticut 2020 State Health Improvement Plan. Drinking water results and indicators
(Figure 5) are from the Healthy Connecticut 2020 State Health Improvement Plan Focus Area 2 -
Environmental Health. The plan is carried out by the Connecticut State Health Improvement Coalition
and seven action teams (CT DPH, 2014).

Figure 5: Connecticut Public Health Data Explorer

,vfe. Connecticut Public Health Data Explorer

ENVIRONMENTAL RISK FACTORS AND HEALTH
Drinking Water Quality

Drinking Water

Drinking Water results and indicator!! are from the Health/ Connecticut 2020 SUte Health Improvement Plan focut Aim 2 • Environmental Health. Safe drinking water from small community
water systems and private wells » a DPH priority area.

Connecticut's Drinking Water is Adequate and Safe.

Risk of consumption of unsafe drinking water from ground water sources serving private wells
(HCT2020).

Risk of waterborne disease outbreaks due to consumption of contaminated drinking water for
all ground-water-based, small community public water systems following an emergency
situation (HCT2020).

3 Percentage of population served by community water systems in CT that provide drinking Q4 2018 95.5%
water that meets all applicable health standards

Q Public Drinking Water

I Percentage of community water systems monitoring for all health-based standards

2018 87%

2	Percentage of sanitary surveys conducted at community water systems where no significant 2018 j 78.0%
deficiencies were identified

3	Pontage of significant deficiencies identified at community water systems that were	2018 ¦
corrected on time

Drinking Water Mapping Application to Protect Source Waters (DWMAPS)

EPA has developed DWMAPS to connect PWS information with other sources of data. DWMAPS uses
an online mapping tool (Figure 6) that helps state and utility drinking water professionals in concert
with other state and local mapping tools to update their source water assessments and protection
plans. Watershed protection groups and source water collaboratives can also use DWMAPS to locate
drinking water providers, potential sources of contamination, and polluted waterways, as well as
information on protection projects and Source Water Collaborative initiatives in their area (U.S. EPA,
2019b).

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-------
Figure 6: DVVMAPS Drinking Water Provider Tool Example Results

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Health-based Violations: No
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-------
5. KEY FINDINGS AND RECOMMENDATIONS

State programs, the EPA, and many water systems have effectively utilized technological advances over
the past decade to improve both the accuracy and accessibility of drinking water data. State programs
and the regulated community have successfully used electronic reporting to transmit compliance
data to EPA. EPA has developed the CMDP to support electronic reporting of drinking water data,
and several states have developed their own electronic portals for compliance monitoring data
submissions. These electronic portals have proven to be effective at increasing data quality while
reducing burden.

While EPA has facilitated electronic reporting of compliance monitoring data, there is no national
requirement for electronic submission. Some states like Alaska and Ohio have mandated electronic
reporting, as shown earlier in this report. Connecticut also has a mandatory drinking water data
e-reporting rule in place which has streamlined the data submission process. Many states do not have
this regulatory authority and have indicated they would follow the form and function of any future
federal e-reporting requirements.

E-Reporting for Small Systems:

Targeted grants to small systems can help
meet the growing data reporting needs.

Additionally, flexibility for adapting e-reporting
is required for small systems is necessary in
areas where broadband is limited. Waivers for
some small systems may be necessary. Most
drinking water systems in the United States are
smaii, serving fewer than 3,300 people.

Increasing e-reporting and increasing the
ability for the public to access the data would
assist in identifying those systems in most
need. These systems also do not generally carry
proportionate funding when it comes to
administration and resources. Removing
barriers for small system adoption of
e-reporting requires closing these financial and
capacity gaps that small systems may
experience.

Laboratories, which are generating the vast majority of compliance monitoring data, are almost all
capable of e-reporting on behaif of their PWS clients and thus hardship waivers may not be necessary
in these cases. In an e-reporting rule, wherever possible, providing timelines years away from the
implementation of a rule will allow entities to find solutions to a mandatory e-reporting requirement.

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Data Access:

EPA has developed a structure and the relevant funding mechanisms to support sharing and reporting
of data. E-Enterprise for the Environment is a model for collaborative leadership among environmental
co-regulators. Working together, environmental leaders at the EPA, states, and tribes are utilizing
the E-Enterprise model to simplify, streamline, and modernize the implementation of environmental
programs (U.S. EPA, 2019c). In July 2019, the EPA drafted an Interim E-Enterprise Digital Strategy
which represents a shared vision among E-Enterprise partners to better coordinate their IT systems,
information, and services. The Digital Strategy incorporates a broad range of input from government
practitioners, the public, and private-sector experts. Implementation of the Strategy will result in
increased collaboration in environmental data and system sharing among the EPA, states, and tribes
to better achieve environmental protection benefits. Programs like this encapsulate the need for
increased collaboration among drinking water stakeholders to maximize the utilization of modern IT
infrastructure.

Exchange Network (EN) Grants are the main avenue for financial support from the EPA to states for the
development of drinking water data shared services in the primacy agencies. The cumulative effect of
EN Grants provides greater advantages from one grant recipient to the next. The impetus behind them
is for the products of each of the grant projects to be held and available for the next recipients to use
to further their programs via subsequent IT development projects. Those projects that clearly define
the improvement to information/data sharing and demonstrate to the EPA that they are most helpful
in this way are the most likely to be funded (e.g., tools for e-reporting). An example of an EN Grant
funded project is SDWIS Drinking Water Watch. This application was initially developed by the State of
Indiana using an EN Grant and, after its completion, Indiana provided the EPA the source code to the
application allowing the EPA to incorporate it into the SDWIS Suite of applications for all states' benefit.
Additionally, EN Grant proposals for the 2022 funding cycle will likely contain provisions for upgrades to
SDWIS State 3.4 and continued support transitioning to CMDP.

States can use the Drinking Water State Revolving Fund (DWSRF) to provide financial assistance to
publicly-owned and privately-owned community water systems, as well as non-profit non-community
water systems, for drinking water infrastructure projects. Projects must either facilitate the system's
compliance with national primary drinking water regulations or significantly further the health
protection objectives of the SDWA. Set-aside funding can be used for an array of activities related to
migrating, maintaining, and updating the state's SDWIS data system.

Many stakeholders acknowledged that, whether the state is managing their data through paper
submissions or through an e-reporting system, there are still management challenges and burdens to
bear. However, the inherent benefits to e-reporting are only achieved through online data submission
via flexible and well-funded IT platforms and effective stakeholder partnerships.

Drinking Water Compliance Monitoring Data Strategic Plan

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6. EPA ACTION PLAN

EPA will promote improved accuracy and availability of compliance monitoring data through continued
support of the CMDP for electronic reporting of data, through SDWIS modernization and stakeholder
discussions, and through the research and analysis under the Drinking Water Learning Agenda. In
coordination with primacy agencies, PWSs, and laboratories, the EPA will continue to document
emerging issues, operational requirements, and barriers related to electronically reporting drinking
water data on an ongoing basis. The outlined actions below are focused on removing identified barriers
to adopting electronic reporting solutions and on identifying additional ways of making compliance
monitoring data more accurate and accessible and are based on feedback received to date in support
of this document, as well as EPA drinking water programmatic goals.

The planned actions below will be conducted in support of the E-Enterprise framework of vital common
goals published in May of 2019 (U.S. EPA, 2019c):

¦ Improving environmental protection by enhancing program performance, streamlining,
and modernizing environmental programs, and deploying advanced technologies.

¦ Enhancing services to stakeholders by reducing transaction costs and burdens and improving the
transparency of environmental conditions and performance.

¦ Operating as a transformative model of shared governance, in which the partnering
environmental agencies jointly identify priorities, define and solve problems, and implement and
improve regulatory programs.

7. Continue Stakeholder Discussions on Electronic Reporting of and
Access to Compliance Monitoring Data

AWIA Section 2011 allows EPA to continue the process of gathering input from and collaborating
with labs, systems, primacy agencies, and other programmatic partners on compliance monitoring
data sharing.

The EPA will extend discussions to additional categories of utilities (e.g., small systems, large
systems) and additional laboratories responsible for processing the compliance monitoring
samples data for the primacy agencies. Discussions will occur on a rolling basis over calendar year
2020 and beyond. The subgroups of SDWIS stakeholder groups described below provide platforms
for stakeholder feedback in a format conducive to candid and constructive informal discussion.

The Data Management Advisory Committee (DMAC) consists of approximately 12 participants
from state drinking water administrators, Association of State Drinking Water Administrators
(ASDWA) association representation, and EPA OGWDW and Regional staff. This group meets
monthly in an engaged committee that also sponsors and organizes quarterly "best practices"
webinars open to the entire SDWIS User Community.

Additional monthly webinars are provided to the entire SDWIS community of stakeholders and
hosted by ASDWA and EPA staff from OGWDW. SDWIS-related program updates are provided,
questions from attendees are fielded, and discussions are facilitated in an online platform hosting
approximately 100 attendees each month. Attendees are from states, utilities, and EPA Regions
and are co-facilitated with drinking water association staff (ASDWA).

These workgroups and webinars are a key part of the outreach conducted by the EPA with its
customers. Their regular associated meetings will be continued in their various capacities to
ensure open and facilitated communication between SDWIS stakeholders and the EPA.

Drinking Water Compliance Monitoring Data Strategic Plan

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2. Explore Additional Improvements to Data Accuracy and Completeness Through
the SDWIS Modernization Process

EPA is in the process of updating both SDWIS State and SDWIS Fed. To guide system
development EPA has established the SDWIS Modernization Board that includes representatives
from state drinking water and information technology programs. The Board will ensure that the
modernized SDWIS database meets programmatic and data quality needs, including facilitation
of electronic reporting of compliance monitoring data from water systems to primacy agencies.
The Board will also look at ways to simplify the data flow from states to EPA and will explore tools
such as Drinking Water Watch that can help make compliance monitoring data available and
understandable.

3. Continue to Support Electronic Reporting of Compliance Monitoring Data
Through Compliance Monitoring Data Portal Implementation and Improvements

Data Validations. Since the initial launch of the CMDP application, EPA has incorporated
additional functionality and more robust data validations to prevent data deficiencies more
comprehensively. CMDP project implementation staff at the EPA will continue to work with
primacy agency and lab CMDP users to identify and prioritize additional data validation checks
and will follow E-Enterprise principles in looking to promote and share additional validations
already in use by primacy agencies. These additional validations will save time and money for labs,
systems, states, and EPA by requiring less manual intervention for ensuring reliably excellent data
quality.

Method/Analyte Code Updates. Over the past year, EPA has implemented a more efficient set
of processes and tools for primacy agencies to update method/analyte code pairings in the CMDP.
This has resulted in greater capabilities for additional labs, systems, and primacy agencies to use
the CMDP to support primacy agency compliance monitoring data business needs more broadly,
such as for state regulated contaminants. The CMDP implementation team will also use this
process to ensure that new methods are promptly incorporated into the application to support
reporting of emerging contaminants.

Continued Funding Mechanisms. The EPA will continue to target EN Grant proposals to
enhance states' ability to support e-reporting activities. Specifically, as previously stated in this
document, the 2022 funding cycle will likely contain provisions for upgrades to SDWIS State 3.4
and continued support transitioning to CMDP. Additionally, states will be able to continue utilizing
the DWSRF set-asides to support transitioning to and implementing CMDP. They will also be able
to use DWSRF set-aside funding for updating or replacing state applications for exchange of data
with CM DP via web services.

4. Follow the Requirements of the Foundations of Evidence-Based Policymaking
Act of 2018 to Create a Framework to Improve Drinking Water Data Quality and
Availability

The Evidence Act, enacted in 2018, provides a framework for institutionalizing rigorous impact
analysis in federal agencies and for the use and generation of evidence to support policy
decisions. Under the Evidence Act EPA is looking at drinking water data quality and
completeness in the Agency's initial implementation of this Act. Specifically, EPA will answer the
question: "Does EPA have ready access to data to reliably and accurately measure drinking water
compliance?" As EPA uses SDWIS data to calculate compliance rates, to conduct its statutory
oversight responsibilities, and to support drinking water policy decisions, EPA will use the rigorous
analysis processes and tools as described in the Evidence Act to closely examine the drinking
water dataset for completeness and accuracy as it relates to informing drinking water policy and
will explore options for improvement. This exploration will include compliance monitoring data.
EPA will consult with stakeholders as it conducts this analysis in 2021 and 2022.

Drinking Water Compliance Monitoring Data Strategic Plan

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ACRONYMS

AA Assistant Administrator SDWARS

ASDWA Association of State Drinking Water Administrators

a SDWIS

AWIA America's Water Infrastructure Act SDWIS Fed

BPA Blanket Purchase Agreement

CDX Central Data Exchange SDWIS State

CEDRI Compliance and Emissions Data Reporting Interface

CFR Code of Federal Regulation SFDW

CMDR Compliance Monitoring Data Portal STAG

CROMERR Cross-Media Electronic Reporting Rule yep

CWA Clean Water Act urMD

DMR Discharge Monitoring Report

DMUC Data Management Users Conference

DSE Data Synchronization Engine

DWMAPS Drinking Water Mapping Application to Protect Source
Waters

DWPD Drinking Water Protection Division

DWSRF Drinking Water State Revolving Fund

ECOS Environmental Council of the States

EN Exchange Network

EPA U.S. Environmental Protection Agency

e-reporting Electronic Reporting

ERT Electronic Reporting Tool

eRule NPDES Electronic Reporting Rule

FTE Full-time Equivalent

GAO U.S. Government Accountability Office

CIS NPDES Integrated Compliance Information System

IWC Implementation Work Group

MOR Monthly Operating Report

MOU Memorandum of Understanding

NCOD National Contaminant Occurrence Database

NDWAC National Drinking Water Advisory Council

NOCS Notification of Compliance Status

NPDES National Pollutant Discharge Elimination System

NPDWR National Primary Drinking Water Regulations

OAR Office of Air and Radiation

OBI Oracle Business Intelligence

OCFO Office of the Chief Financial Officer

OGWDW Office of Ground Water and Drinking Water

OMB Office of Management and Budget

POTW Publicly Owned Treatment Works

PWS Public Water System

SDWA Safe Drinking Water Act

Safe Drinking Water Accession and Review
System

Safe Drinking Water Information System

Safe Drinking Water Information System Federal

Version

Safe Drinking Water Information System State
Version

Safe Drinking Water Data Warehouse
State and Tribal Assistance Grants
Total Coliform Rule

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Drinking Water Compliance Monitoring Data Strategic Plan

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GLOSSARY

Community Water System (CWS)

A public water system that supplies water to the same population year-round.

National Primary Drinking Water Regulations (NPDWR)

Legally enforceable standards that apply to public water systems. These standards protect drinking
water quality by limiting the levels of specific contaminants that can adversely affect public health and
which are known or anticipated to occur in public water supplies.

Non-Transient Non-Community Water System (NTNCWS)

A public water system that regularly supplies water to at least 25 of the same people at least six months
per year. Some examples are schools, factories, office buildings, and hospitals which have their own
water systems.

Primacy

Primary enforcement authority for the drinking water program. Under the Safe Drinking Water Act,
states, United States territories, and Indian tribes that meet certain requirements, including setting
regulations that are at least as stringent as the EPA's, may apply for, and receive, primary enforcement
authority, or primacy.

Public Water System

Any water system that provides water to at least 15 service connections or 25 people for at least 60 days
annually.

Public Water System Supervision Program

Safe Drinking Water Act regulatory requirements for public water systems are implemented through
the Public Water System Supervision (PWSS) program. States maintain PWSS programs in order to
retain primacy over public water systems' compliance with the Safe Drinking Water Act (SDWA) and its
amendments.

SDWIS Fed

The Safe Drinking Water Information System (SDWIS) contains information about public water systems
and their violations of the EPA's drinking water regulations, as reported to the EPA by the states. The
Safe Drinking Water Act (SDWA) requires states to report drinking water information periodically to the
EPA. This information is maintained in a federal database, the SDWIS Fed Data Warehouse.

Transient Non-Community Water System (TNCWS)

A public water system that provides water in a place such as a gas station or campground where people
do not remain for long periods of time.

Drinking Water Compliance Monitoring Data Strategic Plan

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REFERENCES

CT DPH. (2014). Healthy Connecticut 2020 Performance Dashboard. (C. D. Health, Editor) Retrieved
August 2019, from Connecticut Public Health Data Explorer.

NDWAC. (2010). Letter to Lisa P. Jackson re: National Drinking Water Strategy. Washington, DC, United
States of America: EPA National Drinking Water Advisory Council. Retrieved from https://www.
epa.gov/sites/production/files/2015-10/documentsA7letter_ndwac_admin-09-08-10-drin king-
water-strategy, pdf

U.S. EPA. (2010). A New Approach to Protecting Drinking Water and Public Health. EPA 815F10001.

Washington: U.S. Environmental Protection Agency. Retrieved from National Service Center for
Environmental Publications (NSCEP). https://bit.ly/2IAFBWC

U.S. EPA. (2012). State-EPA Data Sharing Implementation Work Group (IWG) Management Report to
SDWIS Steering Committee. Washington, DC: U.S. Environmental Protection Agency.

U.S. Congress. (2018). S.3021 - America's Water Infrastructure Act of 2018. Washington, DC. Retrieved
from https://www.congress.gov/bill/115th-congress/senate-bill/3021/text

U.S. EPA. (2013). E-Reporting Policy Statement for EPA Regulations. Washington, DC: U.S. Environmental
Protection Agency. Retrieved from https://www.epa.gov/compliance/policy-statement-e-
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