UCMR3 - Unregulated Contaminant Monitoring Rule
Eurofins Eaton Analytical is highly qualified to help clients comply with UCMR regulations. Eurofins Eaton Analytical provided the EPA with expert review on all of the prior UCMR regulations, beginning with UCMR1 in 2001. We also co-authored the official EPA method (314.0) for perchlorate analysis, and served on the AWWARF/EPA Chemical Contaminant List (CCL) research team that evaluated test methods for List 2 contaminants for UCMR1.
During UCMR1 and again in UCMR2, Eurofins Eaton Analytical served as a primary EPA contractor for monitoring UCMR compounds for small systems across the country. In these contracts, we analyzed over 3000 samples using a variety of methods, including 524.2, 525.2, 515.4, 314, 521, 526, 527, 528, 529, 532 and 535, with QC requirements that exceeded Federal regulations. Our experience with some of these methods dates back nearly ten years, when we performed the National Pesticide Survey for the EPA.
For UCMR2, Eurofins Eaton Analytical was the first lab in the country to submit an application package to EPA for laboratory approval. UCMR2 methods included 529 (explosives), 527 (PDBEs), 521 (nitrosamines), 525 (pesticides), and 535 (pesticide degradation products).
Our laboratory provided UCMR3 methods second lab validation to EPA, including determination of Lowest Concentration Minimum Reporting Limits data (LCMRL) for method 218.7 (hexavalent chromium), 539 (hormones), 524.3 SIM (low level volatiles) 200.8 (metals), and 300.1 (chlorate). Additionally we provided critical holding time data to EPA to support the extension of the holding time for hexavalent chromium, and acted as an official reviewer for method 218.7.
Eurofins Eaton Analytical has also evaluated the performance of method 539 under WaterRF project 4167. In April 2012, prior to publication of the final UCMR3, we received notice that we had passed the proficiency testing requirements for all compounds/methods included in UCMR3. The extensive experience that Eurofins Eaton Analytical has with the UCMR regulations and the analytical methods supports our ability to help proactively support our clients.
UCMR3 was promulgated on May 2, 2012. Eurofins Eaton Analytical has prepared a summary of the UCMR3 Rule requirements that is available upon request. Monitoring began in January, 2013, and requires the same stringent quality control and EPA approval of all participating labs, based on data packages and proficiency testing. Eurofins Eaton Analytical was the first commercial lab to be fully approved for all UCMR3 methods (UCMR3 Lab Approval), based on having submitted all required demonstrations of capability and passing the first available proficiency test for all methods. We were the only commercial lab to be approved for all methods as of the date of promulgation.
Systems must participate in UCMR3 based on retail population, so even purchased water systems will need to test. In UCMR3 there will be tiered monitoring depending on system size. UCMR3 will require Assessment Monitoring (also known as List 1) for all of the following compounds in all systems serving >10,000 people.
- 6 Perfluorinated Compounds (EPA 537)
- A solvent, 1,4-dioxane (EPA 522)
- 7 VOCs (EPA 524.3 with Selected Ion Monitoring detection)
- 5 metals by ICPMS (V, Mo, Co, Cr and Sr)
- Chlorate (EPA 300.1)
- Hexavalent chromium (EPA 218.7)
Additionally, any systems serving >100,000 people, along with a subset of systems serving between 10,000 and 100,000 will need to also monitor for 7 hormones using EPA method 539. This is referred to as Screening Survey (List 2).
A special study is also planned for viruses by qPCR in sensitive groundwater settings for very small systems (<10,000). This will be paid for directly by EPA. This is referred to as Prescreen Testing (List 3).