UCMR Stakeholder Meeting Page 1 of 11

Stakeholder Meeting 

Regarding Revisions to the 

Unregulated Contaminant 

Monitoring Regulation – 

Meeting Minutes

 

April 7, 2010 
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STAKEHOLDER MEETING REGARDING REVISIONS TO THE 

UNREGULATED CONTAMINANT MONITORING REGULATION

April 7, 2010 

Crystal City Marriott 

Introduction – Logistics and Agenda

Dave Munch – Welcome. Introductions of all meeting attendees (see Attachment 1 for complete list).

Welcome

Phil Oshida – Thank you for being here. This is a very knowledgeable audience. UCMR data serves as largest source 

of occurrence data for the RegDet program. There were many lessons learned from UCMR 1 and 2, and we are 

making adjustments as needed. This is the last year of sampling for UCMR 2, preparing now for UCMR 3. Today we 

are presenting EPA’s perspective and background on UCMR. Please remember, the planning is still in early stages

(see Attachment 2 for the day’s slide presentations). Stakeholder perspectives are very important to us.

Overview of the UCMR Program, presented by Dave Munch ~9:10-9:25 am

Steve Via – Are the data generated from List 2 strong enough to support Regulatory Determinations?

Dave – Yes, we think so. List 2 was designed to be robust enough to support RegDet. Alternatively we may 

promote a contaminant to Assessment Monitoring. 

Andy Eaton – UCMR 2 detects of NDMA were at approximately 25%. Is there a specific frequency that would 

trigger RegDet, or are there additional considerations?

Dave – It’s situation-specific. We look at all data, see if occurrence is on a national level or in local pockets, and look 

at the heath effects considerations. 

Ron Warila – What is the timeframe to take a contaminant with a lot of occurrence data and go to RegDet? 

Pam Barr – 2013 is when next RegDet is due. Whether it is regulated depends on health effects and occurrence 

information. 

Dave – Yes, we have to look at treatment, health effects, everything.

Ben Stanford – Is there any mechanism in UCMR 3 for seasonal sampling, such as for algal toxins?

Dave – We looked at that option, but seasonality is different in Florida vs. Alaska. So, it gets tough to create a 

schedule that will work nationally.

Dan – Aeromonas was collected in the summer months for UCMR 1. 

Andy – For acetanilides, most surface water hits are right after application. So, systems could schedule around it to 

avoid positives. 

Dave – We’re trying to avoid that by requiring monitoring at certain intervals throughout the year.
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UCMR 2 Status, presented by Brenda Parris; ~9:25-9:35 am

Mae Wu – Are the data in NCOD the actual results from systems? 

Brenda – Yes.

Steve – UCMR analysis is ongoing. At some point when the analysis is complete, will there be another stakeholder 

meeting?

Brenda – That would be in the RegDet team’s court. We’re not sure what they’re planning, but we will note your 

question to them. 

Proposed Changes Between UCMR 2 and UCMR 3, presented by Dan Hautman; ~10:15 to 10:40

Andy – Identifying representative ground water sampling locations was a big issue with UCMR 2; many utilities with 

a lot of wells had difficulty in coming up with plans. Are you thinking of ways to make it easier to submit plans?

Dan – Region 9 directly interfaced with California. They wanted to standardize the information, and avoid all the 

back and forth. But systems are diverse, and we need to recognize that a plan must be generic enough to be 

applicable to everyone, but that is very difficult to do. 

Andy – For systems that purchase water, there is often a wholesaler and a retailer with water that comes from same 

location. In this situation, systems could be paying to analyze samples from the same water.

Dan – We are sensitive about replicating reporting for multiple samples from one source; and need to consider that. 

There are some situations where these could be considered unique entry points and other situations where it may be 

valid to take multiple samples from the same place. 

Darrell Osterhoudt – For representative ground water location, there are Ground Water Rule requirements; systems 

will have developed that for the Ground Water Rule already.

Dan – That simplifies things greatly. Some of this was done under UCMR 2; we could accept some plans that are 

already in place.

Steve – For consecutive systems, if there are multiple entry points, would they sample all of them? 

Dan – Yes. 

Steve – You could have issues with wholesale/retail relationships and how would an emergency consecutive 

connection be handled?

Dan – Emergency sources are exempt.

Mae – With regard to changes in requirements for retail vs. wholesale systems; what impact will these changes have 

on large and small systems?

Dan – There are approximately 3,400 current large systems. This will increase by approximately 400 – 600; and, 

others may fall out. For instance, if a wholesale system serving a total population of 12,000 (retail plus wholesale) 

under UCMR 2, is now shown to be selling to two retail systems that purchase 100% (one serving ~4,000, and the 

other ~ 7,000), the original system serving 12,000 might not monitor under UCMR 3, unless they get selected as part 

of the representative sample of systems serving 10,000 or fewer people (because they’re only serving ~1,000 retail 

customers). 
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Mae – If a system rejects data, will that be in the public database so we could see it?

Dan – We haven’t talked about that, but it is something we will consider. 

Jessie Varab – Will labs see rejection of their data?

Dan – We will also consider this. 

Steve – Regarding scheduling, it might help to point out to systems that your goal is to “ensure that EPA gets the 

most comprehensive set of data possible”.

Dan – Good point, and with this flexibility we are trying to respect system cost and burden as well.

Ron – Will the UCMR database be starting from scratch, or will there be any prepopulating (based on UCMR 2)?

Dan – Minnesota provides new data, so, in that case we will replace what was already there. If there is no 

Partnership Agreement with the State, we will try to look at SDWIS, but we don’t want to delete what work has 

already been done under UCMR 2.

Erica Brown – Any discussion about leveraging UCMR data in light of the new EPA strategy for drinking water, 

with FIFRA or TSCA, for example, in terms of getting the information over to other programs?

Dan – Everything goes to NCOD, so they should be able to access the data.

Erica – I mean more than just accessing the data, but rather, an actual interface with other programs to specifically 

send other programs the UCMR data?

Pam – We are trying to do more of that, and we do talk to other programs. They can call in data from 

manufacturers, we have already been talking to them about the type of data they can collect for CCL contaminants; 

there are still outstanding questions with few answers.

Mae – For seasonality, you mention there weren’t significant changes in detections, but we did see it for atrazine. 

Can you please explain?

Dan – It really depends on what contaminants and how it is used. We don’t have the full picture yet; only ~67% of 

data so far. 

Sampling Design Considerations for UCMR 3; presented by George Hallberg; ~11-11:20am

Ben Stanford – How do you address acute toxicity events? 

George Hallberg – It is difficult with this type of program to ensure that we capture acute events; but, it’s an 

important consideration.

Sanwat Chaudhuri – Sampling will be done at EPTDS, but also at Maximum Residence (MR)? 

George – Yes for metals. 

Sanwat – This will be confusing for the smaller systems, so you should be clear on training.

Andy – On the List 3 approach: is it essentially no holds barred? Instead of looking at viruses, could you use qPCR

for algal toxins? 
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Dave – Well yes, but it isn’t open to just everything. Cost and practicality of implementation can’t be ignored. Any 

design will go through public comment, and cost analysis reviewed by OMB.

Pam – It’s more tailored than open ended.

Erica – On slide 12, it states that a limited number of systems identified as vulnerable will be sampled. Have 

vulnerability criteria been developed yet?

George – Not yet for these specific viruses. However, we have done research on defining vulnerability.

Steve – Where would we get information on the rationale for the small system sample size/design? 

George – Design support documents that were developed for UCMR 1. There is a sample component for small 

systems; plus a census of large systems, to look at the majority of population. To achieve 1% margin of error, the 

small system sample size could be lower than 800, but a buffer was built into the sample size to account for various 

factors, including that each state would have a minimum of two small systems in the sample.

Steve – What is the rationale for sampling at maximum residence time?

Dave – To capture changes occurring in the distribution system, sloughing off in system, etc. 

Andy – Regarding entry point sampling for purchased water systems: interconnections are not considered entry 

points. Has any thought been given to looking at those the same way as representative ground water wells? 

Dan – We could consider that, but it's a different dynamic. 

UCMR 3 Candidate Selections and Rationale – Potential Methods; presented by Dave Munch; 

1:15-1:25pm

and

UCMR 3 Candidate Selections and Rationale – Chemicals; presented by John Martin; 1:25-2:00pm

Ben – For chlorate, will monitoring include onsite generation of solution? Will there be a distinction in the data for 

contamination vs. generation during treatment?

Dave – Yes, we are asking about treatment type. This information will be shown in the results. 

Erica – Why would you use indicators for the viruses, if there are proposed methods for the actual contaminants?

Dave – The methods are expensive, so in the long run it would be better to use the surrogates as a trigger to more 

expensive monitoring.

Andy – 537 is proposed for List 2 because of problems with blanks and false positives, but HRLs for PFOS and 

PFOA are high in relation to occurrence data, so you’ll need to set the MRL at place method can capture. I think 

that Method 539 should be List 2 because of birth control interference. 

Dave – There are problems with hormones, they are used in birth control and other prescriptions, so contamination 

is something to closely monitor. 

Mae – For some contaminants there are a lot of occurrence data, do you think there still isn’t enough? There are a 

lot that couldn’t go onto CCL because there were no occurrence data, so shouldn’t they be here? Will the UCMR 

give you the data you need?
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John Martin – The existing data suggest that if we look for it, we may find it. The 30 target contaminants do not 

have enough data to become a basis for regulation; but there is enough data to indicate that monitoring through 

UCMR may be worthwhile. 

Dave – The NIRS data are old, and UCM data is spotty. CCL looked at production and release, as well as 

occurrence in water. We need better, newer, national level drinking water occurrence data. 

Sanwat – Are there more human exposure data available other than CDC?

John – Nothing we know of that’s been compiled for EPA. 

Andy – There are compounds proposed here that are not on CCL (e.g., PFCs). Is this a fishing expedition? Also, 

you should use caution to set MRL based on HRL, so we are not chasing down occurrence values that are below 

values of health concern. Regulatory determination needs to be based on the HRL, not strictly on occurrence. 

Dave – We are not fishing. PFCs were seen in CDC samples, so there is some mechanism of exposure. The industry 

has moved from a C8 to a C4 backbone, and there are high levels in sewage sludge. 24 of 30 proposed contaminants 

were on CCL 3. And yes, HRLs are definitely part of the equation, but sometimes they can change significantly (e.g., 

perchlorate), so we include a buffer.

Ben – Have you considered using ELISA for algal toxins?

Dave – The method wasn't working. Algal toxins are very large compounds, and we don’t have enough information 

on ELISA.

Alan Roberson – [to Phil Oshida] Will there be another batch of degradates and parents? There are things not on 

CCL that are a real concern. If you have two contaminants, one on CCL, one not on CCL, how do you weight them

for inclusion on UCMR? 

Phil – Some of those contaminants may end up on next CCL. The process is cyclic, not linear. It is remarkable that 

24 of 30 proposed contaminants are on CCL 3. We develop methods before CCL is published, so there can be 

overlap, and we can move around within limit of 30. Public comment is good venue to suggest contaminants.

George – In addition, some PFC and other data came out after CCL was in proposal.

Andy – TCE and PCE couldn’t go straight to RegDet, but if you go to 10 contaminants in one method it is cost 

prohibitive.

Dave – PCE and TCE are regulated, so can’t be on UCMR.

Steve – It seems like the explanations during the discussion were better than on the slides. We need more 

transparency. It isn’t really a rationale, because it is not clear how you got from CCL to the UCMR list. There are 

five contaminants with extrapolated data and iffy Kolpin data.

Dave – The timelines between CCL and UCMR don’t mesh as nicely as one would hope; 24 of 30 UCMR proposed 

contaminants is very good. While health effects and occurrence are big parts of what we look at, efficiency and 

practicality are also real concerns. We have methods for pesticides and degradates, but both are LC/MS/MS 

methods, and this leads to lab capacity questions; especially since one instrument will need to be altered for PFCs. 

Andy – Methods 538 and 509.1 are both direct injection, so not a huge burden. But Method 509.1 is really sensitive, 

so cost goes up. Method 539 should be included on List 2, but more information is needed to make decisions, and 

538 method contaminants have low HRLs. 
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Sanwat – Bigger labs can afford to have the instruments; but difficult for smaller labs.

Andy – Three years from now many labs will have this equipment; the cost is going down.

Dave – We do think about costs for States, utilities and EPA. We don’t want to run five contaminants from a 

certain method in UCMR 3; and then a different five contaminants from that same method in UCMR 4. It’s not cost 

effective.

UCMR 3 Candidate Selections and Rationale – Microbes; presented by Sandhya Parshionikar; 

2:20-2:25pm

Andy – Considering standardization of qPCR, would a single lab do all the analysis?

Dan – That hasn’t been determined; this idea is only two to three months old. We want to focus on small vulnerable 

ground water systems, but the rest of the details are being worked out.

Dave – We can standardize primers and platforms, so that is not a concern. 

Sandhya – There is also a good QA system in place.

Sanwat – The cell culture method under the Information Collection Rule was very labor intensive. Are there any 

modifications to simplify? 

Sandhya – Unfortunately no. 

Dan – That’s why it’s on List 3; it’s very expensive. 

Alan – The Ground Water Rule is supposed to address this. This idea is 10 years out of date, why are you proposing 

this?

Greg Carroll – They are on CCL, so they represent contaminants of interest. 

Stig – There is nothing in the Ground Water Rule to distinguish sensitive or non-sensitive wells. We tried to tease 

them out, but could not, so we want better data on sensitive wells.

Alan – I agree in theory. But if we can't include TCE and PCE because they are NPDWRs, why can we talk about 

modifying the Ground Water Rule through UCMR? 

Stig – The Ground Water Rule does not regulate a specific virus.

Alan – But it is written for viruses, not bacteria.

Steve – qPCR is very difficult, and there are questions about whether the method can be trusted. We want quality 

data that is reproducible. It is not quite ready to do this large of a survey.

Sandhya – That’s why there needs to be rigorous QA; we are aware of the problems.

Greg – For norovirus, there is not a cell culture option.

Steve – However, I was at a recent workshop where a method for adenovirus was discussed that might be better 

choice. I will send that information along.
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Stig – We do not see the same correlation of disease with adenovirus as with enterovirus and norovirus, so they are 

more significant to disease pattern. To inform risk, it would be better to monitor for norovirus or enterovirus.

Steve – The Ground Water Rule does not talk about risk assessment, so co-occurrence should be measurable. 

Approval of Laboratories Supporting UCMR 3; presented by Dan Hautman; 3:00-3:15pm

Ron – Are the contract labs for UCMR 3 the same as UCMR 2?

Dan – We anticipate there will be contract labs for small systems. EPA will generate requests for proposal. 

Laboratories need to be approved for UCMR 3 methods prior to submitting a proposal to be considered for the 

small system lab contracts. 

Establishment of Reporting Limits for UCMR 3; presented by John Martin; 3:20-3:50pm

Andy – Have you done modeling to determine how many data sets you need?

John – EPA has been doing 200 iterations.

Dave – Have to use at least three labs; but would prefer five or six. Most importantly, where methods take three to 

five years of analysis and thousands of samples, the LCMRLs came out dead on.

Steve – How does analysis of three sets of results from established labs translate to something applicable to a lab 

that is just now buying equipment for this program?

Dave – 524.3 went to several labs for a variety of reasons, and the quality of data was all over the map; instrument 

manufacturers had some of the worst problems with data, so we didn’t just seek out the best labs.

Steve – There is a limited number of data points; so, does the low spike drive the model?

John – It turns out that the spikes at the high end of the range are also important. One of the most important things 

is the change in variance with concentration.

Andy – Was LCMRL calibration where we expect it to be?

Dave – Labs are supposed to be using calibration close to actual. So, if they did targeted calibration it would affect 

the MRL. 

Ray Martrano – What was the approach for the 200 weighted runs?

John – The data are pooled from all labs and weighted to produce modeled results based on the observed results. 

Ray Martrano – How were labs selected?

John – There have been some labs volunteering, and some contract work.

Dave – We’re trying to get five or six labs; but, you could use 500 and still get an outlier. We’re looking at variance 

within labs.

Dan – We will try to get the word out wider and earlier to labs next round. 
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CONCLUDING DISCUSSION 

Alan – You have done a good job in laying out your plan for UCMR 3. There will always be debate on 

contaminants, but the framework is good. Can we talk about this publicly, on blogs, newsletter etc? 

Dave – Thanks, yes.

Andy – If there is a response from stakeholders, should we e-mail you?

Dave – Yes.

Mae – Will there be a formalized process for comments? 

Dave – After proposal (early next year) there will be a formal public comment period.

Mae – A lot of what is on UCMR 3 was driven by methods development. So, how do you decide what to develop in 

next five years?

Dave – One way for the public to give input is through CCL; another is for stakeholders to provide us information 

directly. 

Erica – You presented a lot of good information today; we appreciate it. But, also think would be nice to see a better 

connection between the contaminant selection and rationale; it was clearer for List 3 than List 1 and 2.
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ATTACHMENT 1:

UCMR 3 STAKEHOLDER MEETING ATTENDEES

April 7, 2010 

Crystal City Marriott 

STAKEHOLDER ORGANIZATIONS

Erica Brown, Association of Metropolitan Water Agencies (AMWA) 

Darrell Osterhoudt, Association of State Drinking Water Agencies (ASDWA) 

Alan Roberson, American Water Works Association (AWWA) 

Steven Via, American Water Works Association (AWWA) 

Olga Naidenko, Environmental Working Group (EWG) 

Kathy Dolan, Food and Water Watch (FWW) 

Mae Wu, Natural Resource Defense Council (NRDC) 

Ed Thomas, National Rural Water Association (NRWA) 

PUBLIC WATER SYSTEMS AND LABORATORIES

Susan Magness, Analytical Laboratory Services, Inc. (ALSI) 

William Deckelmann, American Water Central Laboratory 

Cherie Casari, Microbac Laboratories 

Ray Martrano, Microbac Laboratories 

Andrew Eaton, MWH Laboratories/American Water Works Association (AWWA) 

Ron Krueger, Northern Lake Service, Inc 

Ron Warila, Premier Laboratory, Inc. 

Bruce Li, Underwriters Laboratories (UL) 

Jessie Varab, Underwriters Laboratories (UL) 

Sanwat Chaudhuri, Unified State Laboratories: Public Heath

Utah Department of Health 

Alfredo Pierri, Weck Laboratories (phone)

Melissa Dale, Metropolitan Water District of Southern California 

OTHER

Benjamin Stanford, Hazen and Sawyer, P.C. 
UCMR Stakeholder Meeting Page 11 of 11

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, OFFICE OF WATER

Pam Barr, OGWDW

Greg Carroll, TSC (phone)

Carol DeMarco, OGWDW

Chris Frebis, TSC (phone)

Derek Losh, TSC (phone)

Dan Hautman, TSC

Roger Howard, OGWDW

Jillian Hutson, TSC

Maria Leiter, TSC

Clint Lemmons, OGWDW

David Munch, TSC

Phil Oshida, OGWDW

Brenda Parris, TSC

Sandhya Parshionikar, TSC (phone)

Stig Regli, OGWDW (phone)

USEPA CONTRACTORS

Susan Bjork, The Cadmus Group, Inc. 

George Hallberg, The Cadmus Group, Inc. 

John Martin, The Cadmus Group, Inc. 

Maureen Stone, The Cadmus Group, Inc. 

Doug Setzer, CGI (SDWARS Programmer)