UCMR Stakeholder Meeting Page 1 of 11 

# Stakeholder Meeting Regarding Revisions to t he Unregulated Contaminant Monitoring Regulation – Meeting Minutes April 7, 2010UCMR Stakeholder Meeting Page 2 of 11 

## 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

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

are present ing 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 perspect ive s 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 A ssessment M onitoring

. 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?

D ave – 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 occu rrence 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 h ave to look at treatment, health effects , every thing.

Ben Stanford – Is there a ny 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 a cetanilides, 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.UCMR Stakeholder Meeting Page 3 of 11 

### 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 . A t some point when the analysis is complete, will there be another s takeholde r 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 representa tive 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. T hey 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 purchas e 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 c ould be considered unique entry points and other situations where it may be valid to tak e multiple samples from the same place.

Darrell Osterhoudt – For representative ground wa ter 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 c onsecutive systems, if there are multiple entry points, would they sample all of them?

Dan – Y es

. Steve – You c ould 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 4 00 – 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, 00 0) , 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)

.UCMR Stakeholder Meeting Page 4 of 11 Mae – If a system rejects data, will that be in the public database so we could see it?

Dan – We h aven’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 s cheduling, 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 P artnership A greement with the State, we wi ll 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 get ting 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 access ing 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 outstandi ng 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 d on’t have the fu ll 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 Res idence (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: i s it essentially no holds barred ? I nstead of looking at viruses, could you use qPCR for algal toxins ?UCMR Stakeholder Meeting Page 5 of 11 Dave – Well yes, but it is n’t open to just everything. Cost and practicality of implementation c an’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 identifie d as vulnerable will be sampled. H ave vulnerability criteria been developed yet? George – Not yet for these specific viruses

. However, we have done research on defining vulnerability.

Steve – W here would we get info rmation on the rationale for the small system sample size/design ? George – Design suppo rt documents that were developed for UCMR 1

. There is a s ample 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 s ampling 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 though t been given to looking at those the same wa y as representative g round 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 interfere nce.

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 sh ouldn’t they be here? Will the UCMR give you the dat a you need?UCMR Stakeholder Meeting Page 6 of 11 John Martin – The existing data suggest that if we loo k 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 l ooked at production and release , as well as occurrence in water. W e 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) . I s this a fishing expedition? Also, you should use c aution to set MRL based on HRL , so we are not chasing down occurrence values that are below values of health concern . R eg ulatory determination need s 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 C 8 to a C 4 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 tox ins?

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 . I f you have two contaminants, one on CCL, one not on CCL, how do you weight them for inclusion on UCMR ?

Phil – Some of those contaminant s 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 i f 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 s eems like the explanation s during the discussion were be tter than on the slide s. 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 – T he 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 h ave method s for pes ticides and degradate s , 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 . B ut 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.UCMR Stakeholder Meeting Page 7 of 11 Sanwat – Bigger labs can afford to have the instruments ; but difficult for small er labs. Andy – Three years from now many labs will have this equipment; the cost is going down.

Dave – We do think about costs for S tates, utilities and EPA. We d on’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. I t’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 co ncern

. Sand hy a – There is also a good QA system in place.

Sanwat – The cell culture method under the Information Collection Rule was very labor intensive . A re there any modifications to simplify ?

Sandh y a – 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 . T his 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 n ot quite ready to do this large of a survey. Sandhya – That’s w hy 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 a denovirus was discussed that might be better choice. I will send that information along.UCMR Stakeholder Meeting Page 8 of 11 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 – H ave 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

. M ost important ly, 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 manufacture r s had some of the worst problems with data , so we didn’t just seek out the best labs.

Steve – There is a l imited 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 s upposed to be using calibration close to actual. So, if the y 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 wi der and earlier to labs next round.UCMR Stakeholder Meeting Page 9 of 11 

### CONCLUDING DISCUSSION

Alan – You have done a good job in laying out your plan for UCMR 3. T here will always be debate on contaminants, but the framework is good. Can we talk about this publicly, on blog s , newsletter etc ?

Dave – Thanks, yes. Andy – If there is a response from stakeholders, should we e

- mail you?

Dave – Y es.

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 l ot 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 in put is through CCL ; an other 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.UCMR Stakeholder Meeting Page 10 of 11 

## ATTACHMENT 1: UCMR 3 S TAKEHOLDER MEETING AT TENDEES 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 Thom as, 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, OGW DW 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)