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EPA’s Unregulated Contaminant Monitoring Rule Program

Monitoring for unregulated drinking water contaminants isn’t a new concept for most public water systems (PWSs). The 1996 Safe Drinking Water Act (SDWA) amendments require EPA to issue a new list of no more than 30 unregulated contaminants every five years to be monitored by public water systems. EPA uses UCMR to collect data for contaminants that are suspected to be present in drinking water and do not have health-based standards set under the Safe Drinking Water Act. UCMR is the process used by EPA to determine if contaminants are sufficiently present in drinking water and need to be regulated.

Sampling for the UCMR4 is now underway and ends in 2020. Earlier UCMR monitoring events occurred as follows:

· UCMR 1 monitoring took place between 2001 and 2003 and included 26 contaminants.

· UCMR 2 monitoring took place between 2008 and 2010 and included 25 contaminants.

· UCMR 3 monitoring took place between 2013 and 2015 and included 30 contaminants.

· UCMR 4 monitoring began 2018 and added 30 new contaminants for monitoring.

To date occurrence data on 81 UCMR contaminants have been collected including data on inorganic and organic compounds, along with bacterium and viruses data now stored in the National Contaminant Occurrence Database (NCOD). EPA uses this data to determine whether further regulatory action is appropriate and in the interest of protecting public health. While it may seem like the Unregulated Contaminant Monitoring Rule is in place to protect the public from any and all emerging contaminants, it is not a hard and fast rule designed to expedite regulation — rather, it is a lengthy process for collecting data that has not yet resulted in any meaningful water quality regulations. Most of the 81 compounds monitored in previous UCMR programs have not made it to EPA’s Regulatory Determination Assessment Phase.

However, in 2011, EPA determined that perchlorate (included in UCMR 1) meets SDWA’s criteria for regulating a contaminant and announced its decision to establish a maximum contaminant level (MCL). EPA has spent nearly eight years working on perchlorate regulations but a date for the final MCL remains uncertain. Meanwhile, some states have taken regulatory action upon themselves, setting standards, guidelines and advisories. In 2007, California promulgated a perchlorate standard of 6 µg/L, while Massachusetts in 2006 adopted a perchlorate drinking water standard of 2 µg/L. Twelve other states have established non-enforceable guidance, action or advisory levels. Other emerging contaminants included in past UCMRs, like PFOA, PFOS, and chromium-6, have been regulated in specific states but EPA struggles to established regulatory limits on these compounds. For more information about monitoring unregulated drinking water contaminants, visit EPA’s website by clicking here.

The most important takeaway from the UCMR program is that it isn’t going to end anytime soon. Thousands of potential contaminants are currently present in the environment and need to be assessed in the interest of protecting public health. States and environmental groups will continue monitoring UCMR data pushing for their own regulations.

Where is your legacy UCMR data? It has been nearly twenty years since the first UCMR data was collected. Many staff involved in earlier monitoring programs have left or retired. Much of this old data is stored in spreadsheets and possibly in outdated LIMS databases, subject to being loss with time. Would you be able to rapidly access UCMR1 – UCMR3 data if needed?

SAMS Water is the perfect repository for all legacy UCMR data. Once uploaded into SAMS Water, data is safely stored and easily accessible for years to come. Queries to access individual UCMR constituents, or complete monitoring events, are available in SAMS Water.

What about UCMR4 monitoring and laboratory data? The current batch of contaminants includes nine cyanotoxins, two metals, nine pesticides, three disinfection byproducts, three alcohols, and three semivolatile organic chemicals. Required monitoring is complicated and confusing for many utilities already stretched for resources.

SAMS Water Criticality can keep your utility on track with all upcoming UCMR4 monitoring events. UCMR4 data can seamlessly be uploaded into SAMS Water from your EPA approved laboratory. Notification by E-mail can be established alerting you of any detected UCMR4 contaminant. Finally, UCMR4 data can easily be compiled for reporting in your annual Consumer Confidence Report. Contact us today to discuss other ways SAMS Water can help manage your drinking water compliance data.

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