Office of Water (MLK 140) Page 1 of 10 

## Chat Questions/ Answers and Public Statements from the Webinar on Revisions to the Unregulated Contaminant Monitoring Rule (UCMR 4) January 13, 2016

The following represent questions that were asked and answered during the webinar. Some of the initial an swers have been edited or expanded upon for clarity/accuracy/completeness.

Robin Carpenter
Q: We d o the following compounds: Per methrin, Chlorpyrifos & Butylated Hydroxyanisol e by EPA Method 525.2, with 95 other compounds, when these three compounds are regulated can we still report these compounds by EPA Method 525.2 or will we have to switch to EPA 525.3?

A: Robin, as the proposed rule is currently written, you would have to switch to EPA 525.3 to report data for UCMR 4 purposes, as that is the method proposed in UCMR 4. If those compounds are regulated at some time in the future, it is possible 525.2 would also be approved, but that is unknown at this time.

Cynthia Andrews

- Tate Q: In the handout, the additional contaminants and indicators considered for UCMR 4 states that the methods were not ready at the time of proposal. Are methods available now for these
contaminants?

A: The additional contaminants will be discussed in the next presentation. If your question still remains unanswered please ask again. [Note: the subsequent presentation did address the question and apparently answered it to the satisfaction of Ms. Andrews

- Tate .]

Kourtney Wunschel
Q: Are HAA samples to be taken at regular Stage 2 DBPR sites, or will new sites be required?

A: As proposed, UCMR 4 reflects that i f your water system is subject to Stage 2 DBPR, you must take your UCMR 4 HAA samples at the distribution system sites identif ied under that rule. A new site would not be required.

Damon Guterman Q: What is the rationale for requiring HAA sampling at PWSs not subject to DBPR? Is there some question about alternate formation mechanisms?

A: EPA encourages you to submit your comme nt to the docket so we can adequately respond

.

Tim Young
Q: Will there be just a simple list of what we need to sample and where on our system and at what frequency?

A: Consistent with prior UCMR cycles, EPA intends to provide fact sheets that should assist water systems in determining the requirements for sampling. EPA also intends to offer a webinar after the final rule is published to assist with implementation questions.Office of Water (MLK 140) Page 2 of 10 Steve Rhode
Q: Please clarify how consecutive systems that purchase all of their water would get source
water data for HAAs

. A: The proposal indicates that s ystems that purchase 100% of their water do not have to collect source water samples.

Carla Glaser
Q: W ould you please clarify the zip code info requirements for SDWARS? Do we need to enter every zip code for the area served or just the sampling points? (We are in NYC where there are MANY zip codes)

. A: EPA has propos ed that PWSs report zip codes for the e ntire service area. This has not changed from UCMR 3. For UCMR 3, there was a reporting mechanism to enter a large list at one time, which is likely to be available for UCMR 4. I should add, you only have to report the zip codes one time, not with every re sult.

Tim Young
Q: May we enter comments at a later date, as questions come up?

A: You may comment to the docket until February 9, 2016. You are always welcome to contact
EPA with the q uestions. Our contact information was on slide 96 of the webinar or you can email the UCMR_Samping_Coordinator@epa.gov

.

Lily Sanchez
Q: Please confirm that new groundwater drinking water sources (i.e., new we lls) coming on

- line after 12/31/ 2015 are not required to test for UCMR 4 chemicals.

A: Consistent with prior UCMR rules, a PWS deemed subject to the rule ( i.e. , as of the 12/31/15 applicability date) would be required to conduct monitoring for all of its sources (including new wells) in use during the monitoring period (proposed as 1/1/18

- 12/31/20).

Damon Guterman Q: Would EPA want 22,000 manganese results from 1600 PWSs in MA?

A: If MA has manganese results that can be shared, please email the UCMR_Sampling_Coordinator@epa.gov for more information.

Lily Sanchez
Q: For groundwater sources (not GWUDI) the monitorin g window should be 12 months to allow for the second sample to be collected five to seven months after the first sampling event because groundwater travel time is much longer that surface water that may warrant sampling during peri ods of high application r ates. Also wells may not be operating 12

- month s per year due to demand; allowing a 12 month sampling period assures greater possible occurrence samples.

A: EPA encourages you to submit your comment to the docket so that we can adequately respond.Office of Water (MLK 140) Page 3 of 10 Lily Sanchez
Q: Entering CDX information for either source information or entering results needs to be streamlined as every entry requires starting over for a system to enter information for sources.

A: EPA encourages you to submit your comment to the docket s o that we can adequately respond.

Cynthia Andrews

- Tate Q: O ther than knowing when the additional contaminants and indicators method s would be
available

, and where (sampling points) for proposed Legionella would take place, I don 't need to speak this morni ng, thanks.

A: Okay, thank you for letting us know. Legionella was not one of the 30 contaminants proposed for UCMR 4 monitoring

. The proposal invites comment on whether or not Legionella (and/or other contaminants) should be part of the final UCMR 4 list

.

Kimberly Childress
Q: Has EPA considered consecutive systems that purchase all of their water from the same

so urce that have the same EPTDS? We sell to two systems and the point we meter the water
sold to e ach system is in the same pit. We had this same situation with UCMR 3 and had to collect two separate samples at the exact location and report is for two PWSIDs. It cost us twice
as much for the same results. I hope this will be taken in consideration before the final rule is published.

A: EPA encourages you to submit your comment to the docket so that we can adequately respond.Office of Water (MLK 140) Page 4 of 10 Notes from Webinar Public Statements

The following represent statement s that were made during the webinar. In those cases where EPA received a written statement from the participant, EPA included that statement; in the
other cases EPA has summarized the participant’s remarks. Where practical, EPA is providing answers and/or clarifying infor mation, based on the proposed rule and/or docket material , in response to questions raised during the statements

.

Lynn Thorp (Clean Water Action) written statement submitted by email to EPA : Thank you for the opportunity to participate in this webinar and to provide preliminary thoughts on the proposed revisions to the Unregulated Contaminant Monitoring Rule (UCMR 4). Clean Water will be submitting written comments to the docket.

My comments today are an overview of subjects we will cover in written comments on the proposed Rule.

Cyanotoxins We support monitoring for the ten cyanotoxins as proposed. There is evidence that Harmful Algal Blooms are occurring more frequently in more places and there is increased public and policymaker concern over cyanotoxins. More information on occurrence in drinking water sources is essential to support analysis of the need for National Primary Drinking Water Regulations and to support the work outlined in EP A’s Algal Toxin Risk Assessment and Management Strategic Plan for Drinking Water

.

Brominated Haloacetic Acid Groups, Bromide and TOC We support monitoring for Brominated Haloacetic Acid Groups that are currently unregulated
because of health effects information and elevated levels of bromide in source water. We support monitoring for bromide because we need nationwide data on occurrence. We also agree that information on Total Organic Carbon occurrence, on disinfection and treatment can
contribute to a better understanding of DBP formation and treatment efficacy.

Specific EPA Questions EPA has asked specifically for comments on whether Legionella pneumophila, Mycobacterium

avium and ammonia should be included in UCMR 4. Because each of these is related to high

profile issues of public health concern it may be advisable to include them in UCMR 4 in order
to obtain nationwide data on actual occurrence.

Purpose of the UCMR
The Unr egulated Contaminant Monitoring Rule was developed primarily to obtain occurrence data to support development of National Primary Drinking Water Regulations. The proposed

UCMR 4 highlights the potential for this program to be used to support source water p rotection efforts and research and recommendations to improve Public Water System operation. We urge EPA to work with stakeholders to identify ways that EPA and stakeholders can use UCMR data to better achieve these goals. In support of EPA’s Drinking Wate r Strategy and ongoingOffice of Water (MLK 140) Page 5 of 10 Clean Water Act/Safe Drinking Water Act integration efforts, one initial step would be to ensure that the final UCMR 4 Rule prompts interagency discussions on how other EPA offices and authority outside the Safe Drinking Water Act ca n be invoked to reduce occurrence of UCMR 4 contaminants in drinking water sources.

Steve Via (AWWA) written statement submitted by email to EPA : The American Water Works supports the effective use of EPA’s authority to require unregulated

contaminant monitoring as described in the Safe Drinking Water Act. In order for us to comment more effectively on the UCMR 4 proposal, it would be helpful if EPA could explain
several items:

1. We are having difficulty reconc iling the UCMR notice and previous informatio n distributed regarding the total microcystin ELISA method performance. Is it possible for laboratories to certify performance at levels 1/3 rd the health advisory level or is the MRL EPA anticipates setting the MRL for total microcystins at 0.45 ug/L?

Answer : As noted in the proposal, EPA anticipates having an EPA ELISA method available by the publication of the final rule and anticipates that this method will be similar to the Ohio EPA methodology. As part of that method development EPA is evaluating Q C
parameters . Laboratory Reagent Blank (LRB) acceptance criteria is included in this
evaluation. EPA encourages you to submit your comment to the docket so that we can respond further

.

2. How does EPA anticipate systems handling source water cyanotoxin observations in consumer confidence reports? We have some previous experience with CCR reporting
of source water Cryptosporidium observations. Is that the model the Agency has in
mind?

Answer : EPA encourages you to submit your comment to the docket so tha t we can adequately respond

.

3. The SDWA provisions for unregulated contaminant monitoring focus on collecting
occurrence of contaminants in finished water. And to this end, the number of contaminants in any one cycle is limited to 30. The UCMR 4 proposal i ncludes 44 parameters, and involves collecting data in both source and finished water. Could you sort out for us the authorizing framework? Are there specific linkages between the
finis hed water contaminants and the source water and water quality parameters the Agency expects to draw from proposed data collection (e.g., source water total microcystin and finished water individual microcystin data, pH, TOC, temperature,
bromide and finish ed water contaminant observations, etc.)?

Answer : As part of its responsibilities under SDWA, EPA implements section 1445(a)(2), Monitoring Program for Unregulated Contaminants. This section, as amended in 1996, requires that once every five years EPA iss ue a list of no more than 30 unregulated contaminants to be monitored by PWSs. EPA is using this authority as the basis forOffice of Water (MLK 140) Page 6 of 10 monitoring 29 of the 30 contaminants/groups proposed under this rule. Section 1445(a)(1)(A) of SDWA, as amended in 1996, requires th at every person who is subject to any SDWA requirement establish and maintain such records, make such reports, conduct such monitoring and provide such information as the Administrator may reasonably require by regulation to assist the Administrator in est ablishing SDWA regulations. Pursuant to this provision, EPA can also require the monitoring of contaminants already subject to EPA’s drinking water standards. EPA is using this authority as the basis for monitoring one of the chemical groups (Haloacetic Ac ids 5 (HAA5)) proposed under this rule. EPA has proposed a phased sample analysis approach for the microcystins which includes source water sampling using ADDA ELISA , as a first phase, to creat e a more cost

- effective design

.

EPA ’s proposed list of 30 co ntaminants for UCMR 4 consist s of ten cyanotoxins/groups; two metals; eight pesticides plus one pesticide manufacturing byproduct; three brominated haloacetic acid groups of disinfection byproducts; three alcohols; and three semivolatile organic chemicals. As proposed, PWSs would report HAA groups as three summations ( HAA5, HAA6 Br , HAA9 ) and laboratories would provide data for the individual HAAs as quality control information to allow the Agency to evaluate the accuracy of the three HAA summations

. The proposal includes measurement of t otal organic carbon (TOC ) and b romide (Br) as potential indicators for HAAs. The proposal
includes measurement of pH and temperature as potential indicators for cyanotoxins

. The data from these indicators would aid in the understanding of unregulated

contaminant occurrence . The practice of collecting data for potential indicators and water quality parameters is cons istent with prior UCMR cycles

.

The proposal invites comments regarding the usefulness of collecting the indicator
information

, the appropriateness of the proposed list of 30 contaminants , and the proposed quality control parameters

. EPA encourages you to submit your comment to the docket so that we can respond further

.

4. The proposed UCMR DBP overlaps substantially with compliance monitoring. What are barriers to better integrate routine compliance monitoring with UCMR monitoring so that sampling can be more efficient and the resulting data more robust?

Answer : As noted in the proposal, UCMR 4 HAA samp les and HAA5 Stage 2 DBPR compliance samples may be collec ted by the PWS at the same time; but if a single analysis is to support both UCMR 4 and Stage 2

, PWSs would need to use laboratories
that are state

- certified /accredited for Stage 2 DBPR and approved by EPA to support

UCMR 4 monitoring

, and would need to use EPA method 552.3 or 557.

5. There is a strong interest in cyanotoxins with the recent Report to Congress, but the notice does not provide a clear indication of why other analytes are includ ed. Could you

s peak to EPA’s priorities in the listed contaminants and in particular the value of including the alcohols as proposed?Office of Water (MLK 140) Page 7 of 10 Answer : The Federal R egister notice explain s EPA’s stepwise prioritization and selection process for the proposed analytes and cites the “UCMR 4 Candidate Contaminant

– Information Compendium,” located in the docket, for additional information.

EPA selected the proposed UCMR 4 contaminants using a stepwise prioritization process. The first step included identifying contaminants that: (1) were not monitored under UCMR 2 or UCMR 3; (2) are anticipated to have significant occurrence nationally; and (3) are expected to have a completed, validated drink ing water method in time for rule proposal. This resulted in a set of 45 draft CCL 4 contaminants and another set of
related non

- CCL analytes with potential health effects of concern that can be measured concurrently using the analytical methods for the CC L contaminants. Including related

non

- CCL analytes creates a more cost

- effective design and reduces the likelihood of needing to include them in a subsequent UCMR.

The next step was to select contaminants associated with one or more of the following

consi derations: an available health assessment to facilitate regulatory determinations; high public concern; critical health endpoints (e.g., likely or suggestive carcinogen); active use (e.g., pesticides); and an occurrence data gap. This step identified 31 CC L contaminants, and 18 related non

- CCL analytes.

During the final step, EPA considered workgroup and stakeholder input; looked at cost

effectiveness of the method/contaminant groups; considered implementation factors (e.g., laboratory capacity); and furth er evaluated health, occurrence, and persistence/mobility data to identify a proposed list of 30 UCMR 4 contaminants.

Please refer to the proposal and Compendium for additional, contaminant

- specific
details. EPA encourages you to submit your comment to th e docket so that we can respond further.

6. To

- date, the UCMR has been well accepted as providing a sound understanding of national occurrence of contaminants in finished drinking water. The proposal makes several changes from typical practice. It moves to a biased sample structure for cyanotoxins. Also, there is no sampling in December, January or February for surface or ground water systems; and consequently, there is a subsequent effect on sample density in other months due to the fixed monito ring period cycles. Has EPA analyzed, perhaps using UCMR 2 and UCMR 3 data, how these changes will impact the utility of the resulting UCMR data and the questions that can be posed using the UCMR 4 data?

Answer : As noted in the proposal, t he Assessment Monitoring sampling time frame would take place during the compressed period of March through November to better reflect the times of year when contaminants are more likely to occur in drinking water. Populations of cyanobacteria generally pe ak when water temperature is highest. Seasonality of pesticide occurrence in surface waters has been well documented, andOffice of Water (MLK 140) Page 8 of 10 genera lly relates to the timing of pesticide applications in the watershed, rainfall or irrigation patterns and watershed size . Based on this information, EPA anticipates that sampling in the December through February time period would not accurately reflect occurrence for some of the contaminants, particularly cyanotoxins and pesticides. Industry and laboratory stakeholders have also ob served that the traditional UCMR approach has the potential to underestimate exposure for some contaminants because
of seasonal occurrence

. Therefore, EPA is proposing that no sampling take place during those winter months, except for resampling purposes. T he proposal notes that EPA welcomes comments on this approach. EPA encourages you to submit your comment to the docket so that we can respond further.

Paul Monroy (Babcock Laboratories, Inc.) asked whether there would be a preferred method for HAA9 analy sis for small systems (i.e., method 552.3 or 557). He noted that in past contracts, EPA had specified requirements for certain methodologies and if this was going to be the c ase again, communication of the requirements could help the labs determine which m ethodology

to use.

Answer : EPA will work with our contracts office to properly forecast and communicate potential future contracts. The procurement should be placed on EPA’s Acquisition Forecast Database, with a brief synopsis that will include some details on the intended requirements. The actual procurement announcement on FedConnect will also contain details on the specific requirements and methods to be used.

A manda Foss (Greenwater Lab) noted that Greenwater Lab agrees that monitoring for microcystins is important, but they do not agree with the proposed analytical approach; specifically the use of method 544 as follow

- up analysis to ADDA ELISA for samples over 0.3 μg/L total microcystins. She asked why EPA is considering using a method that will under report total microcystins concentration, is not considered confirmatory as stated in the webinar, and whether EPA would consider using an alternate confirmatory t echnique such as the MMPB approach (which is published) to confirm total microcystins and thereby confirm the ADDA ELISA data. Ms. Foss noted that their concern is that only providing data for six of over 150 congeners of microcystins might cause some conf usion in the water industry and the public. Greenwater Lab will submit official comments to the docket to explain further their position on why method 544 would under report occurrence.

Answer : The proposal reflects that EPA Method 544 and the ADDA ELISA technique measure different parameters; thus it is understood that the concentrations reported from the two techniques may not be equivalent. As Ms. Foss notes, EPA Method 544 is not intended to be used as a confirmatory technique. Rather, Method 544 allows for the quantitation of six particular microcystin congeners and nodularin after a positive ADDA ELISA measurement for microcystins at the EPTDS based on the proposed phased

- analysis approach

. Using Method 544 to analyze EPTDS samples that tested p ositive for microcystins by ADDA ELISA is expected to help EPA and the states to establish the degree to which particular congener occurrenceOffice of Water (MLK 140) Page 9 of 10 compares with total microcystin occurrence as measured by ADDA ELISA . E PA encourages you
to submit your comment to the docket so that we can respond further

.

Andrew Eaton (Eurofins Eaton Analytical Lab) noted that he has been involved in the UCMR process for over 15 years and today he wanted to raise issues in three different areas including the laboratory data requirements, the number of sample rounds for ground water systems, and ground water sampling pe riods.

Dr . Eaton noted that based on information presented in the preamble and the webinar, EPA is proposing to require that the same quality control (QC) elements be used for both small and large systems. He noted that in his experience, getting all th at information in the Laboratory Information Management System ( LIMS) can be challenging unless EPA provides a data checker to all approved labs so that they can verify that they have included all the necessa ry information before uploading all the data. Ev en with the data checker, the process will be time consuming and expensive especially for labs that do not have a lot of experience, and for utility labs that do not have many samples.

Dr . Eaton asked if it is EPA’s intent to provide immediate feedback o n data entry and QC elements after an upload, and if yes, he encouraged EPA to validate this approach before promulgation of the final rule. He stated that under UCMR 3, there was a lag between the
program start and EPA ’s completion of their own internal data checker . His last comment on the data element was to question whether EPA’s database is robust enough to handle all the additional data. It is his understanding that even without these addi tional data elements, EPA
has been challen ged running queries and making data available with the current UCMR database as the data points approach/exceed 1 million.

Answer : As proposed EPA intends to have one data reporting system for small and large system data to hopefully streamline some of th e concerns. E PA encourages you to submit your comment to the docket so that we can respond further

.

Dr . Eaton also questioned whether it is necessary to require two sample rounds for ground water systems. He stated that th ere are several teams looking at the UCMR 3 data as of the October 2015 data release, doing statistical analyses on probability plots using the Kolmogorov

Smirnov tests and the Mann

- Whitney tests of probability distributions for all constituents. What they have seen is that with the excep tion of chlorate (since the DBP formation is highly dependent upon the disinfection process), and total chromium (because there may be issues with reliability of low

- level measurements), there is no difference with the prob ability plots for any of the cons tituents, even for the ones with negligible occurrence. He strongly urged EPA to do a detailed analysis of the existing UCMR 3 data, similar to what he has done, to determine if two sample rounds are actually needed for gro und water systems. Mr. Eaton stat ed that with 2,000 ground water systems, by eliminating one sampling round, EPA could save utilities as much as $20 million over the course of UCMR 4 monitoring which is a significant change in the

burden.Office of Water (MLK 140) Page 10 of 10 Answer: As noted in the proposal, EPA recognizes the trade

- off between PWS burden and

occurrence

- data representativeness, and has attempted to strike a reasonable balance in selecting the affected PWSs and establishing the monitoring frequency. The Agency welcomes comment on this particular point, includ ing input regarding the appropriateness of collecting occurrence data from fewer PWSs. This could include employing the Screening Survey approach used in UCMR 3 or an alternative design. EPA requests that commenters suggesting alternatives
describe how the ir proposed approach would be nationally representative of the frequency and
level of contaminant occurrence.

EPA encourages you to submit your comment to the docket so that we can respond further.

Dr. Eaton also asked: for those ground water systems do ing semi

- annual testing, if EPA excludes
the December

– February timeframe, how will systems that start sampling in June, July, or August avoid having a problem of having fewer samples during that period which may be the most vulnerable in terms of the pesticides.

Answer : EPA anticipates clarifying the requirements for those systems that start sampling in June, July, or August in the final rule. EPA encourages you to submit your comment to the
docket so that we can respond further

.

Jane DeRose

- Bamen ( Albuquerque Bernalillo County Water Utility Authority (ABCWUA)) questioned the used of the phrase, “concurrent with the collection of” in two places in the proposed rule. She noted that if this phrase means that the system must take the samples at the same time, then the rule should say that. If it means that EPA wants the system to monitor the same water as it passes from the source to the entry point, then systems may have problems with lag time. EPA should state its intent.

She also questioned the phased collection for the microcystins and the five

- day hold time (unless the sampl e is frozen) under the ELISA method. She assumes that if a system collects samples from the source and the entry point, then the entry point samples will have to be frozen to give the lab time to analyze the source samples and determine if they have to run the ELISA method on the entry point samples.

Answer: EPA expects to clarify the term “concurrent with the collection of” in the final rule. EPA

enco urages you to submit your comment regarding the phased collection approach to the
docket so that we can adequately respond.