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Meeting the Requirements of the EPA’s Unregulated Contaminant Monitoring Rule 3


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Since the establishment of the federal Safe Drinking Water Act (SDWA) more than 35 years ago, the safety of the U.S. drinking water supply has been an ongoing priority for health officials. Operating under the authority of the SDWA, the U.S. Environmental Protection Agency (EPA) sets drinking water standards to control contaminants in the public drinking water supply. To date, the EPA has identified nearly 90 separate contaminants whose concentrations in drinking water are regulated under its National Primary Drinking Water Regulations.

The fact that contaminants are detected in trace amounts in drinking water does not alone imply risk to humans. Significant research is needed to understand both the scope of the problem and its implications for the public drinking water supply. To determine whether a contaminant should be regulated, the EPA analyzes peer- reviewed science addressing a number of variables, including the occurrence levels of a contaminant in the environment, routes of human exposure and the potential health effects of exposure.

The EPA also collects data under its Unregulated Contaminant Monitoring program on contaminants that are suspected to be present in drinking water but that are not currently regulated. In support of that data collection effort, the EPA has recently implemented its third Unregulated Contaminant Monitoring Rule (UCMR 3), which will require public water systems (PWSs) to conduct assessment monitoring for the presence of 28 additional chemicals and two viruses during a 12-month period beginning in January 2013. The EPA will use the data from this and prior UCMR assessment phases to determine whether further drinking water regulations are in the interest of public health.

This UL white paper provides a detailed overview of the EPA’s UCMR 3 monitoring program for PWSs. Beginning with background information on the EPA’s role in the regulation of drinking water contaminants, the paper then offers specific details on the UCMR 3 monitoring program requirements, including the specific substances subject to monitoring, sampling and testing methods, and important program schedules and deadlines. The white paper concludes with considerations for PWSs regarding compliance with UCMR 3 monitoring requirements and recommendations on the selection of a testing laboratory to conduct UCMR sample testing.



The Importance of Safe Drinking Water

The EPA estimates that Americans drink more than 1 billion glasses of tap water per day.1 Although the safety of drinking water is largely taken for granted, there are a number of natural and man-made factors that can affect water quality. These factors range from naturally occurring chemicals and animal waste to pesticides, chemical byproducts of manufacturing processes, and improper chemical disposal. In addition, improperly treated or disinfected water, or water passing through a distribution system that has not been sufficiently maintained can pose potential health risks to humans.

Federal efforts to control contaminants in drinking water began in 1974 with the passage of the SDWA. Under the SDWA, the EPA is mandated to set enforceable maximum contaminant levels (MCLs) for contaminants. The EPA’s National Primary Drinking Water Regulations set maximum levels for 90 separate contaminants, and requires PWSs to test samples of water from their systems to assure compliance with these MCLs.2

Regulated contaminants are identified after a rigorous process that evaluates potential health risks from exposure and determines an MCL that is below the level of potential risk. PWSs are then required to ensure that the concentrations of contaminants in their water supplies comply with the MCLs, most often by using suitable technologies to treat the water and to minimize the risk of the contaminants. The EPA may also require PWSs to treat water supplies in cases

where a reliable detection method for a particular contaminant does not exist or where it is not technically or economically feasible to set an applicable MCL.3

National drinking water regulations and standards apply to the more than 170,000 separate PWSs operating in the U.S., including approximately 54,000 individual community water systems. The regulations and standards are legally enforceable by both the EPA and individual state water authorities. PWSs that fail to monitor concentrations of regulated contaminants or treat water supplies as required are subject to administrative penalties, monetary forfeitures and other legal action.

The EPA’s UCMR Program

In addition to currently regulated drinking water contaminants, the EPA maintains a Contaminant Candidate List (CCL) comprised of other contaminants that may be subject to future regulation. CCL-listed contaminants include those that have been found in drinking water at PWSs, or others that have been identified through EPA research. Contaminants on the list are prioritized based on their potential health risk to humans, as assessed by the EPA’s Office of Water’s Office of Science and Technology.

The EPA’s UCMR program is an important source of data and information for unregulated contaminants on the CCL. Established under the SDWA as amended in 1996, the UCMR program is designed to measure the occurrence and levels of specific contaminants found in drinking water at U.S. PWSs. The data collected under the UCMR program is stored in

the National Contaminant Occurrence Database, and is used by the EPA to prioritize unregulated contaminants and to determine whether further regulatory action is appropriate.

The UCMR program requires the EPA to issue a list every five years of not more than 30 currently unregulated contaminants to be monitored by PWSs. To date, the EPA has conducted two separate rounds of UCMR drinking water monitoring. The first, UCMR 1, monitored 25 separate contaminants (24 chemicals and one bacterium) during the period from 2001 to 2003. The second UCMR round, UCMR 2, monitored an additional 25 chemical contaminants during the period from 2008 to 2010. UCMR 3 was published in April 2012, and will monitor 30 new additional contaminants (28 chemicals and two viruses) during the period from 2013 to 2015.

Specific Requirements of UCMR 3

Under UCMR 3, PWSs will be required to monitor a total of 30 different contaminants. The specific contaminants to be monitored are detailed in the sections that follow.

Assessment Monitoring (List 1 Contaminants)

All PWSs serving more than 10,000 people, along with 800 EPA-selected PWSs serving 10,000 or fewer people, will be required to monitor 21 separate contaminants. The contaminant list includes seven different volatile organic compounds, six different metals, six perfluorinated compounds, one synthetic


organic compound and one oxyhalide anion. Specific List 1 contaminants to be monitored include:

• 1,2,3—trichloropropane

• 1,3—butadiene

• chloromethane (methyl chloride)

• 1,1—dichloroethane

• bromomethane (methyl bromide)

• chlorodifluoromethane (HCFC—22)

• bromochloromethane (halon 1011)

• 1,4—dioxane

• vanadium

• molybdenum

• cobalt

• chromium

• chromium-6

• chlorate

• perfluorooctanesulfonic acid (PFOS)

• perfluorooctanoic acid (PFOA)

• perfluorononanoic acid (PFNA)

• perfluorohexanesulfonic acid (PFHxS)

• perfluoroheptanoic acid (PFHpA)

• perfluorobutanesulfonic acid (PFBS)

• strontium

Selected PWSs must monitor for these contaminants continuously for any

12-month period from January 2013 through December 2015. Analysis of water samples for List 1 contaminants will utilize analytical technologies commonly used by laboratories that evaluate drinking water.

Screening Survey (List 2 Contaminants)

All PWS serving more than 100,000 people, as well as 320 EPA-selected PWSs serving between 10,000 and 100,000 people and 480 selected PWSs serving 10,000 or fewer people, will be required to monitor seven hormones. The List 2 contaminants to be monitored include:

• 17-ß-estradiol

• 17-α-ethynylestradiol (ethinyl estradiol)

• 16-α-hydroxyestradiol (estriol)

• equilin

• estrone

• testosterone

• 4—androstene—3, 17—dione

Selected PWSs must monitor for these additional contaminants continuously for any 12-month period from January 2013 through December 2015. Unlike the analysis of List 1 contaminants, the analysis of samples of List 2 contaminants will require the use of specialized technologies available only through selected testing laboratories.

Pre-Screen Testing (List 3 Contaminants)

For this monitoring phase, the EPA will select 800 representative PWSs serving 1,000 or fewer people with wells located

in areas of karst or fractured bedrock, i.e., complex geographic environments with distinctive hydrologic features and that do not disinfect drinking water. The List 3 contaminants to be monitored include the following two viruses:

• enteroviruses

• noroviruses

PWSs identified to participate in pre-screen testing will monitor these two contaminants continuously for any 12-month period from January 2013 through December 2015.

Sampling and Testing Methodologies

Consistent with the practice employed in UCMR 2, sampling conducted under UCMR 3 is to take place at all entry points to the distribution system of the PWS. However, PWSs may perform sampling at representative entry points when ground water is collected from multiple sources, or when they receive purchased water through multiple connections from the same wholesale supplier. Representative sampling in these circumstances is subject to additional conditions.

Samples collected under UCMR 3 are subject to testing consistent with established EPA analytical methods, as follows:

• Volatile organic compounds— EPA Method 524.3, “Measurement of Purgeable Organic Compounds in Water by Capillary Column Gas Chromatography/Mass Spectrometry”


• Synthetic organic compounds—EPA Method 522, “Determination of 1,4-Dioxane in Drinking Water by Solid Phase Extraction (SPE) and Gas Chromatography/ Mass Spectrometry (GC/MS) with Selected Ion Monitoring (SIM)”

• Metals (other than chromium-6)—EPA Method 200.8, Rev 5.4, “Determination of Trace Elements in Waters by Inductively Coupled Plasma – Mass Spectrometry”

• Chromium-6—EPA Method 218.7, “Determination of Hexavalent Chromium in Drinking Water by Ion Chromatography with Post Column Derivatization and UV-Visible Spectroscopic Detection”

• Oxyhalide Anion—EPA Method 300.1, “Determination of Inorganic Anions in Drinking Water by Ion Chromatography”

• Perfluorinated compounds—EPA Method 537, Rev 1.1, “Determination of Selected Perfluorinated Alkyl Acids in Drinking Water by Solid Phase Extraction and Liquid Chromatography/Tandem Mass Spectrometry”

• Hormones—EPA 539, “Determination of Hormones in Drinking Water by Solid Phase Extraction and Liquid Chromatography Electrospray Ionization Tandem Mass Spectrometry”

• Viruses—EPA Method 1615, “Measurement of Enterovirus and Norovirus Occurrence in

Water by Culture and Reverse Transcription-Quantitative Polymerase Chain Reaction”

Under the UCMR 3 program, the EPA is responsible for all cost associated with the preparation of samples and sample analysis for those PWSs serving 10,000 or fewer people. In addition, the EPA will arrange for the collection of samples from those PWSs selected to participate in the pre-screen testing of List 3 contaminants.

Reporting Requirements and Important Program Deadlines

Data on the analysis of samples collected under UCMR 3 will be posted by testing laboratories to the EPA’s Safe Drinking Water Accession and Review System (SDWARS). This online database is accessible to registered PWSs through the EPA’s electronic reporting system, allowing PWSs, the EPA and state officials to review sample data and take action when appropriate.

In addition to the required SDWARS reporting, PWSs are subject to the agency’s rules requiring public disclosure. Specifically, the Consumer Confidence Report Rule requires that PWSs report monitoring results when unregulated contaminants are detected. The EPA’s Public Notification Rule requires PWSs to provide public access to testing results.

The following UCMR 3 program deadlines apply to PWSs and testing laboratories:

• Oct. 1, 2012—For PWSs serving more than 10,000 people, PWS contact information must be reported to SDWARS


• Oct. 1, 2012—For PWSs serving more than 10,000 people, sample inventory locations and schedules must be updated in SDWARS

• Jan. 1, 2013—Water sampling commences

• 120 days from collection of samples—Laboratories must post sample analysis results to SDWARS

• 60 days from posting of laboratory assessment data—PWSs serving more than 10,000 people must review laboratory data and take any necessary actions

• Dec. 31, 2015—All monitoring, sampling and reporting to be completed

Choosing a Laboratory to Conduct UCMR 3 Sample Analysis

The EPA requires that all samples collected under the UCMR 3 program be analyzed by a testing laboratory that has been registered under the agency’s Laboratory Approval Program and approved by the EPA to conduct testing to each specific test method. Laboratory approval to a specific test method is based on the successful completion by the testing laboratory of an EPA-administered proficiency test study that involves the analysis of a set of samples for each method approved. Approved testing laboratories must

also meet specified quality assurance and quality control requirements to achieve and maintain approval under the UCMR 3 program.

PWS operators should consider selecting a laboratory that holds EPA approval to test for all of the contaminants their system is required to monitor under UCMR 3. This approach is likely to be considerably more efficient than dealing with multiple laboratories evaluating samples to different methods, and should also streamline the reporting process. For those PWSs responsible for paying the cost of sampling and testing themselves, working with a single testing laboratory will also prove to be more cost-effective.


Conclusion

The UCMR 3 program is a key element of the EPA’s effort to monitor the occurrence and levels of unregulated drinking water contaminants, and an essential part of the agency’s overall effort to protect the safety of drinking water in the U.S. The program, which begins in January 2013, requires most PWSs to monitor their water supply for 30 specific unregulated contaminants for a period of 12 months and to report their findings to the EPA. The data collected will be used in conjunction with research from the EPA, industry and the scientific community to determine possible future efforts to regulate additional contaminants.

UL has been approved by the EPA to analyze water samples collected under the UCMR 3 program for all 28 List 1 and List 2 contaminants, and is the only testing laboratory in the U.S. certified in all 50 states for drinking water analysis. UL has analyzed over 2.5 million samples for thousands of water utilities, bottled water producers, engineering firms, and state and federal governments. Using the most efficient testing methods available, UL can analyze drinking water for a broad range of contaminants, thereby streamlining the testing process and reducing testing costs.

For further information about the UCMR 3 program and UL’s water testing services, contact Nathan Trowbridge, customer experience manager, at [email protected].

UL and the UL logo are trademarks of UL LLC © 2012. No part of this document may be copied or distributed without the prior written consent of UL LLC 2012.

1 “Water Facts,” U.S. Environmental Protection Agency, Office of Water. June 2004. Web. 30 July 2012. http://water.epa.gov/lawsregs/guidance/sdwa/upload/2009_08_28_sdwa_fs_30ann_waterfacts_web.pdf

2 “Understanding the Safe Drinking Water Act,” U.S. Environmental Protection Agency, Office of Water. June 2004. Web. 30 July 2012. http://water.epa.gov/lawsregs/guidance/sdwa/upload/2009_08_28_sdwa_fs_30ann_sdwa_web.pdf

3 “SDWA Statute, Regulations and Enforcement,” U.S. Environmental Protection Agency. Web. 30 July 2012. http://www.epa.gov/compliance/civil/sdwa/sdwaenfstatreq.html

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