UCMR4, On the horizon
SAMANTHA SAULTZ & ANDY EATON
Eurofins Eaton Analytical
The Unregulated Contaminant Monitoring Rule (UCMR) has come a long way in the last 15 years. Passed in 1974, the Safe Drinking Water Act (SDWA) authorized EPA to set enforceable health standards for contaminants in drinking water. In 1986, amendments made to SDWA were the basis for the original UCMR program, which ultimately became a formalized program impacting nearly 5,000 utilities nationwide.
It was the 1996 Amendments to SDWA that required EPA to create and maintain a National Drinking Water Contaminant Occurrence Database (NCOD), storing information for both regulated and unregulated contaminants in public water systems (PWS). The EPA would use this data to develop regulatory decisions for emerging contaminants and to provide a basis for future actions to protect public health. This ultimately established requirements for the UCMR program to issue a list of no more than 30 unregulated contaminants, once every 5 years. Depending on prevalence and the levels of contaminants found, EPA ultimately would then conduct further research to determine whether or not to begin regulating them.
The fourth Unregulated Contaminant Monitoring Rule signed into law on December 20, 2016, and commences in January 2018. There are three unique methods for cyanotoxins: EPA 544, 545, 546; four unique methods for chemicals: EPA 525.3, 530, 541, 200.8; one method for HAA9: EPA 552.3 (or 557) and two indicator methods: Bromide and TOC EPA 300.0 (or 300.1) and SM5310C (or SM5310B). This round of UCMR monitoring will generate more than 1 million sample data points and a huge amount of QC data. Laboratories participating in this round will also gather information on “matrix” impacts and the robustness of the methods.
The deadline for the large water systems to upload their inventory onto the EPA Central Data Exchange (CDX) website is December 31, 2017. There should be roughly 25,000 sample points for Entry and Distribution Sites and 15,000 Source Water Sites uploaded to the EPA inventory plus a large number of distribution points. As of October, almost half of the PWSs still needed to upload their systems sampling points. It is predicted that being ready by the end of December will be a challenge, but EPA is working hard to provide assistance to utilities in the form of webinars for training. Since there has not yet been a ”test drive” of the data entry for UCMR 4 for labs and the requirements are much more stringent than in prior UCMRs and many labs have limited experience with most of the methods introduced this round, there will be a lot of opportunity for challenges for the participating EPA-approved laboratories.
Only EPA-approved laboratories can participate in UCMR4. Both Eurofins Eaton Analytical (EEA) labs facilities (in Monrovia, CA, and South Bend, IN) are fully approved for UCMR 4, having achieved that status when EPA first completed the approval process in June of 2017. The EEA labs are the only commercial labs that have been fully approved for every round of UCMR testing, beginning in 2001. The fourth round of this program, (UCMR 4) kicks off in January 2018 and runs through December 2020.