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 answers have been edited or expanded upon for clarity/accuracy/completeness.

Robin Carpenter 

Q: We do the following compounds: Permethrin, Chlorpyrifos & Butylated Hydroxyanisole 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 if your water system is subject to Stage 2 DBPR, you must 

take your UCMR 4 HAA samples at the distribution system sites identified 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 comment 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 systems that purchase 100% of their water do not have to collect 

source water samples.

Carla Glaser

Q: Would 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 proposed that PWSs report zip codes for the entire 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 result.

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 questions. 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 wells) 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 monitoring 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 periods of high application rates. Also wells may not be operating 12-months 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 so that we can adequately 

respond.

Cynthia Andrews-Tate

Q: Other than knowing when the additional contaminants and indicators methods would be 

available, and where (sampling points) for proposed Legionella would take place, I don't need 

to speak this morning, 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 

source that have the same EPTDS? We sell to two systems and the point we meter the water 

sold to each 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 statements 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 information, 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 EPA’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 highprofile 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 Unregulated 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 protection 

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 Water Strategy and ongoing 
Office 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 can 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 reconciling the UCMR notice and previous information 

distributed regarding the total microcystin ELISA method performance. Is it possible for 

laboratories to certify performance at levels 1/3rd 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 QC 

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 that 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 includes 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 

finished 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 finished 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 issue a list of no more than 30 unregulated 

contaminants to be monitored by PWSs. EPA is using this authority as the basis for 
Office 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 that 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 establishing 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 Acids 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 create a more cost-effective design.

EPA’s proposed list of 30 contaminants for UCMR 4 consists 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, HAA6Br, 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 total 

organic carbon (TOC) and bromide (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 consistent 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 samples and HAA5 Stage 2 DBPR

compliance samples may be collected 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 included. Could you 

speak 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 Register notice explains 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 drinking 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 CCL 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 

considerations: 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 CCL 

contaminants, and 18 related non-CCL analytes.

During the final step, EPA considered workgroup and stakeholder input; looked at costeffectiveness of the method/contaminant groups; considered implementation factors 

(e.g., laboratory capacity); and further 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 the 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 monitoring 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, the 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 peak when water temperature is highest. 

Seasonality of pesticide occurrence in surface waters has been well documented, and 
Office of Water (MLK 140) Page 8 of 10

generally 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 observed 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. The 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 analysis 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 case 

again, communication of the requirements could help the labs determine which methodology 

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. 

Amanda 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 technique 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 confusion 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 positive for microcystins by ADDA ELISA is expected to 

help EPA and the states to establish the degree to which particular congener occurrence 
Office of Water (MLK 140) Page 9 of 10

compares with total microcystin occurrence as measured by ADDA ELISA. EPA 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 periods.

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 that 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 necessary 

information before uploading all the data. Even 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 on 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 additional data elements, EPA 

has been challenged 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 the concerns. EPA 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 there are several teams looking at the UCMR 3 data as of the 

October 2015 data release, doing statistical analyses on probability plots using the KolmogorovSmirnov tests and the Mann-Whitney tests of probability distributions for all constituents. What 

they have seen is that with the exception 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 probability plots for 

any of the constituents, 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 ground water systems. Mr. Eaton stated 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, including 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 their 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 doing 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 sample 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 

encourages you to submit your comment regarding the phased collection approach to the 

docket so that we can adequately respond.