At an April 2010 stakeholder’s meeting, the EPA discussed proposed plans for the third phase of the Unregulated Contaminant Monitoring Regulation (UCMR) program. If approved, approximately 4,800 public water utilities will be required to monitor up to 30 contaminants starting in 2013.
The second phase of UCMR (UCMR 2) sampling, which began in 2008, concludes at the end of this year. UCMR 2 required certain water utilities to perform assessment monitoring and screening survey monitoring for 25 unregulated contaminants using five associated analytical methods. The EPA will review the UCMR 2 data in 2011.1
UCMR 3 would require Public Water Systems (PWSs) to begin assessment monitoring for seven pharmaceuticals; 1,4–Dioxane; nine volatile organic compounds; four metals; chlorate and two additional microbials. Some will be required to perform an additional screening survey for six perfluorinated compounds. The proposal would impact approximately 4,000 PWSs serving more than 10,000 people and nearly 800 systems that serve less than 10,000 people.2
The UCMR program originated from amendments to the Safe Drinking Water Act (SDWA) enacted in 1996, which required the EPA to establish a program for monitoring up to 30 unregulated contaminants every five years. UCMR also requires three different screening techniques for unregulated contaminants: those commonly used; those more recently developed; and new or specialized techniques for pre-screen testing. PWSs are required to use EPA-approved laboratories for all analyses.
The EPA develops each UCMR list from the Contamination Candidate List (CCL), a catalog of contaminants currently unregulated by federal authorities, but which are known or anticipated to be present in PWSs. The EPA considered approximately 7,500 potential contaminants and microbial agents when creating the CCL. Contaminants were evaluated based on their likelihood of occurrence in the PWS as well as their potential impact on public health. The final CCL3, published in September 2009, included 104 chemicals or chemical groups and 12 microbiological contaminants, of which, 30 appear on the UCMR 3’s list of contaminants. 3 These include:
- Two additional specific microbial contaminants: Enteroviruses and Norovirus. Enteroviruses are a genus of viruses associated with several diseases including poliovirus, coxsackievirus, and echovirus. Symptoms of Infection can range anywhere from mild respiratory illness to paralysis, while Norovirus usually results in mild, self-limiting gastrointestinal illness.4 Besides specific tests for these viruses, there are 5 indicators for the presence of these microbials including Total coliform, E. coli, Enterococci, Bacteriophage, and Aerobic Spores.
- Seven pharmaceutical hormones are proposed for testing at the Entry Point(s) to the Distribution System (EPTDS) using the forthcoming EPA Method 539 – Determination of Hormones in Drinking Water Using Liquid Chromatography Tandem Mass Spectrometry. They are 17-a Ethynylestradiol, 17-ß-Estrdiol, Equilin, Estriol, Estrone, Testosterone and 4-Androstene-3, 17-dione.1
- Nine volatile organic compounds:1,1-Dichloroethane; 1,2,3-Trichloropropane; 1,3-Butadiene; Bromochloromethane; Chlorodifluoromethane; Chloromethane; Methyl bromide; n-Propylbenzene; sec-Butylbenzene. The EPA will require public water utilities to test for these compounds using EPA Method 524.3 – Measurement of Purgeable Organic Compounds in Water by Capillary Column Gas Chromatography/Mass Spectrometry, Version. 1.0.1
- Four metals being considered are cobalt, molybdenum, strontium, and vanadium. The EPA is calling for these metals to be tested at the maximum residence time in the distribution system using EPA Method 200.8 – Determination of Trace Elements in Waters by Inductively Coupled Plasma – Mass Spectrometry, Version 5.4.1
- Chlorate compounds. These are believed to appear in drinking water via their use in disinfectants. The EPA’s proposal mandates that PWSs use EPA Method 300.1 -Determination of Inorganic Anions in Drinking Water by Ion Chromatography, Revision 1.0. to test for chlorate at the EPTDS.1
- 1,4-Dioxane, a solvent or solvent stabilizer used in the manufacture of paper, cotton, textile products, automotive coolant, cosmetics and shampoos. It will be tested at the EPTDS through EPA Method 522 – Determination of 1,4-Dioxane in Drinking Water by Solid Phase Extraction and Gas Chromatography/Mass Spectrometry with Selective Ion Monitoring, Version 1.0.5
- Perfluorinated chemicals: Perfluorononanoic acid (PFNA), Perfluorobutane sulfonic acid (PFBS), Perfluoroheptanoic acid (PFHpA), and Perfluorohexane sulfonic acid (PFHxS), Perfluorooctane sulfonate (PFOS), and Perfluorooctanoic acid (PFOA). The proposed testing method for perflourinated chemicals is EPA Method 537 – Determination of Selected Perfluorinated Alkyl Acids in Drinking Water by Solid Phase Extraction and Liquid Chromatography/Tandem Mass Spectrometry, Version 1.1.1
Other changes include the addition of previously unregulated PWSs that purchase 100% of their water to those PWSs subject to UCMR testing requirements. Under the proposed changes, all purchased sources will be considered unique entry points and will require monitoring.1
Under UCMR 3, the EPA will match their required sampling schedules to PWSs where a monitoring location may be down or only in use during certain seasons. The PWSs will identify sampling options in those cases.
The EPA also addresses system sizes in UCMR 3. Under UCMR 2, system size was based on the combined retail and wholesale service population, whereas under UCMR 3, the EPA would require the measurement to be based exclusively on retail service population.
Laboratories upload data from samples taken at PWSs directly into the Safe Drinking Water Accession and Review System (SDWARS). The PWSs can then review the data and either accept it or reject some or all of it. Under UCMR 2 the PWS did not have to explain rejected data. Under UCMR 3 they must explain the reason for any data rejection.
In the past, Ground Water Representative Monitoring Plans (GWRMP) were based on geographic location, contamination susceptibility, and similarities of groundwater quality with no backup sampling point required. Under the proposed changes for UCMR 3, the priorities for GWRMP will be the highest annual volume producing and most consistently active in the representative array.1
With the release of the proposed changes at the April meeting, the EPA is now soliciting feedback from stakeholders. According to EPA spokesman Daniel Hautman, the proposed UCMR 3 changes will be published in the Federal Register in early 2011, with a final rule publish date set for 2012. Hautman stated that the changes become official once the EPA Administrator approves the recommendations.6
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- Stakeholder Meeting Regarding Revisions to the Unregulated Contaminant Monitoring Regulation, meeting notes from stakeholder meeting at the Crystal City Marriott, meeting of April 7, 2010.
- Sandy Nance, Streamlines by the American Waterworks Association, UCMR 3 draft unveiled by USEPA, http://www.awwa.org/publications/StreamlinesArticle.cfm?itemnumber=54292&showLogin=N, April 13, 2010.
- U. S. Environmental Protection Agency Contaminant Candidate List 3 – CCL,
http://water.epa.gov/scitech/drinkingwater/dws/ccl/ccl3.cfm, Last accessed September 23, 2010.
- U.S. Environmental Protection Agency Contaminant Candidate List 3- CCL, Microbials, http://water.epa.gov/scitech/drinkingwater/dws/ccl/ccl3.cfm#microbial, Last accessed September 23, 2010.
- U.S. Environmental Protection Agency Contaminant Candidate List 3 – CCL, Chemical, http://water.epa.gov/scitech/drinkingwater/dws/ccl/ccl3.cfm#chemical, Last accessed September 23, 2010.
- Dan Hautman, US EPA Technical Support Center Deputy Director, telephone interview, August 2, 2010.