UCMR2 –Regulatory & Technical Information

1. UCMR2 –Regulatory & Technical Information Kimberly Kunihiro Water Quality Manager Orange County Utilities FSEA Spring Meeting May 22, 2008

2. UCMR2-The Questions ??? • What Is It? • Who is Affected? • What Does it Require? • When is Action Required ? • What Should Utilities and Labs be doing or have already done? • How much can this cost?

3. What is the UCMR program • Established under 1986 SDWA • Updated in the 1996 SDWA • Monitoring on a 5-year cycle • No more than 30 contaminants per cycle • Includes a representative sampling of small systems

4. UCMR2-What is It? • Unregulated Contaminant Rule-Part 2 • Continuing Series-UCMR1 was conducted from 2001-2005 25 compounds & Aeromonas • Part of the Contaminant Candidate List (CCL) process to evaluate future contaminants for regulation.

5. First Posted in August, 2005 • Published for comment October 2005 • Promulgated on January 4, 2007

6. Purpose • Collect occurrence data for contaminants that may be in drinking water but have no health-based standards in SDWA 2,2’, 4,4’,5,5’-hexabromobiphenyl (HBB) Alachlor RDX

7. What is Being Monitored? • Targets new compounds including pesticides, flame retardants, and explosives • Requires specialized laboratory certification from EPA with specific turnaround and reporting requirements • Specifies minimum reporting levels for each compound • Compliance point is the point of entry to the distribution system at each plant and Max Residence Time location for List 2 selected method

8. The 2 Lists • List 1-Assessment Monitoring (AM) • 10 compounds by 2 methods • Explosives 3 compounds (EPA 529) • Insecticides 2 compounds (EPA 527) • Flame Retardants 5 compounds (EPA 527) • Perchlorate was on original list but removed • List 2- Screening Survey (SS) • 15 compounds by 3 methods • Nitrosamines – 6 compounds (EPA 521) • Acetanilide Parents- 3 compounds (EPA 525.2) • Acetanilide Degradates- 6 compounds (EPA 535)

9. List 1- Compounds & MRL’s

10. List 2- Compounds & MRL’s

11. List 2- Compounds & MRL’s (cont.)

12. Affected Utilities-List 1 • Community Water Systems (CWSs) and Non-Transient Non-Community Water Systems (NTNCWSs) serving > 10,000 people • Requires 3500+ systems to conduct assessment monitoring for 10 priority chemicals over 12 consecutive months (2008-2010) • 800 Systems under 10,000 monitored by EPA • Not required for systems that purchase 100% of their water

13. Affected Utilities-List 2 • All CWSs and NTNCWSs serving over 100,000 people • 800 systems under 100,000 considered representative by EPA

14. Monitoring requirements • Surface water and GWUDI systems- • Quarterly monitoring for 1 year approximately 90 days apart • Groundwater Systems • Twice per year (5-7 months apart)

15. Where are samples collected? • List 1 • Entry point to the distribution system (EPTDS) All methods • List 2 • Entry point to the distribution system All methods • Distribution System Maximum Residence Time location (DSMRT) • Method 521 only

16. EPA Responsibilities • Inform PWSs of need for monitoring • Administer Lab Approval Program • Register ended April 4, 2007 • Last PE samples were sent • More than 2400 letters were sent out to affected systems

17. State-Roles & Responsibilities • Determined by Partnership Agreement (PA) • PA invitation sent to all states/territories/tribes • Most have partnered with EPA-Florida has not • PA assistance varies: • All reviewed State Monitoring Plan (SMP) • Most provided PWS sample location inventory • Many to notify PWSs of monitoring requirements

18. PWSs Responsibilities • Reporting under SDWARS • Register/Establish a CDX account • Enter PWS Contact information by 4/4/07 • Review sample location inventory, monitoring schedule by 8/2/07 • Prior to Monitoring • Establish an agreement with an EPA approved UCMR2 lab • During Monitoring Period • Collect or ensure proper sample collection/shipment • Review/approve data posted by labs to SDWARS

19. Info Prior to Monitoring • New Schedule Request • Prior to August 2, 2007 • Budget analysis across fiscal years • After August 2nd must send request to EPA sampling coordinator with justification • GW Representative Entry Points • By May 4, 2007 needed to: • Submit a previously approved plan from Phase II/V or UCMR1 • Submit a new proposal for GW representative sampling

20. PWS Inventory

21. Prior to Reporting • PWS must enter official and Technical Contacts in SDWARS • Name • Organization • Mailing address • Phone number • E-mail

22. PWS info from EPA/CDX • Dear Kimberly Kunihiro • The Safe Drinking Water Accession and Review System (SDWARS) indicates that your public water system (PWS) listed below is scheduled to monitor for the second cycle of the Unregulated Contaminant Monitoring Regulation (UCMR2). • PWSID: FL3481546 • PWS Name: Orange County Utilities Dept. - West Upcoming Scheduled Sampling Event: Mar, 2008 • ______________________________________________ • United States Environmental Protection Agency • Central Data Exchange • A New Paradigm for Environmental Reporting.

23. Lab- Roles & Responsibilities • Must have EPA certification from UCMR Lab Approval Process • Letter of interest sent August 2005 • Registration process ended April 4, 2007 • Qualify for PT Study • Participate/Pass PT Studies • Register on CDX and agree to Post data to SDWARS • Adhere to specific quality control • EPA audits • Paper • May have On-site Audit

24. Approved Labs • As of April 14, 2008 only 14 labs in the country approved for all methods • Only 1 in Florida- Orange County Utilities • 50 labs approved for at least 1 method • List of approved labs available on http://www.epa.gov/safewater/ucmr/ucmr2/pdfs/list_ucmr2_approvedlabs.pdf

25. Lab QC Requirements • Must meet MRLs Demonstrated with: • Calibration Checks • After every 10th Field sample and End of a Batch • Daily Performance Checks • LFM at or Below MRL Level • Lab Fortified Blank (<MRL) • LFM With each extraction batch or with every 20 samples • LFMD • Requires triplicate sample collection

26. Analytical Challenges-New Technologies • LC/MS/MS and GC/MS/MS • MS/MS using positive or negative ionization • Product ions are used for quantitation • No Spectral Libraries • Internal CI technology for Ion trap • Developed on Varian instrumentation

27. Analytical Challenges-SS • Low detection limits for 521 • ng/L vs. ug/L detection • Use large volume injection 20 uL vs 0.5 or 1 uL • Compounds such as NDMA are fairly volatile and don’t chromatograph well NDMA

28. Analytical Challenges-MRLs • LC-MRL Calculator EPA 815-R-05-006 dated November 2004 • Requires multiple levels and multiple replicates • Uses a statistical program to determine MRLs • MRLs submitted prior to certification as part of lab approval process

29. Analytical Challenges-Multiple LFBs • Differing recovery acceptance depending on concentration of LFB • +/- 50% low level • +/- 30% at Mid and High Level • Need to run multiple LFBs at varying levels depending on # of samples in batch • Have to run multiple levels of LFM and LFMD because of various concentrations of analytes in the method 521 and 527

30. Chromatography

31. Sampling Guidance

32. Sampling Guidance • Collect samples early for overnight delivery • Sample 525.2 and 535 at same time and place • No compositing • Add proper dechlorination agents and preservatives at time of sampling • Store samples at <10 oC during storage and shipment • Ship samples on ice • Do not freeze

33. Sample Collection Procedures * Triplicate volume is required for LFM/LFMD

34. Sample info for Chain of Custody • Sampling Date, time, Sampler’s Signature • Sampling Event Code (SE1, SE2, …etc) • Key information: • PWSID and PWS Name • Sample Location • Facility ID Sampling Point ID • Facility Name Sampling Point Name • Sampling Point Type • If Resampling is required should be within 30 days of original sampling date • Include original sample event code

35. Data Reporting • Labs report results to SDWARS within 120 days of sample collection • Data can be manually entered or electronically downloaded • Lab enters results of sample and LFM, LFMD and CF • Lab certifies that data meets or exceeds all methods required QC

36. SDWARS Lab Posting

37. Data Reporting (cont.) • PWS reviews & approves data 60 days from lab posting • EPA & State reviews • Public Release of Data • Consumer Confidence reporting • CWSs only • Average and Range of results • May give brief explanation of reason for monitoring • Remains in Report for 5 years • Public Notification for Violations

38. Costs of Analysis • Orange County Costs • List 1 $525/sample/event • List 2 $925/sample/event • Nitrosamines only by 521 $325 Private Lab: • List 1 $400/sample/event • List 2 $900/sample/event • 521 only $350 Other Costs: PT costs Instrumentation Costs- LC/MS/MS GC/MS/MS QC/Reporting Costs Sampling Costs for Utilities

39. Summary • UCMR2 is Part 2 of a continuing series • Similar monitoring programs will happen in the future • The costs of these programs are born by the larger Utilities • We will see regulation at some future point for some of these compounds- NDMA, insecticides

40. Summary (cont.) • In general, the private lab community has not responded to the special certification requirements • Analytical Costs are high due to the specialized instrumentation and training of personnel • Labs should get ready to provide these services • An investment in the equipment now may prove useful for other programs such as microconstituents or emerging contaminants

41. EPA Contacts • OGWDW Technical Support Center UCMR Sampling Coordinator USEPA Technical Support Center 26 W Martin Luther King Dr. (MS140) Cincinnati, OH 45268 Fax: 513-569-7191 E-mail: UCMR_Sampling_Coordinator@epa.gov UCMR2@glec.com • UCMR Message Center: 800-949-1581 • CDX Help Desk: 888-660-1995 Email: epacdx@csc.com Ucmr2: http://www.epa.gov/safewater/methods/sourcalt.html#M527

42. Questions ? Contact Info: Kim Kunihiro Water Quality Manager Orange County Utilities 407-254-9550 Kim.kunihiro@ocfl.net