A guide for PWS’s on sampling and monitoring requirements for UCMR3

1. A guide for PWS’s on sampling and monitoring requirements for UCMR3 Suzanne Lindblom – Laboratory Manager Mobile Area Water and Sewer System, Mobile, AL

2. TOPICS COVERED • Timeline Summary • PWS’s affected by this Ruling • Contaminate List and Methods • Sampling Requirements • Frequency of Sampling • Sampling Locations • Approved Laboratories • Reporting

3. TIMELINE SUMMARY

4. PREVIOUS DEADLINES • Letter notifying PWS of monitoring requirements. • Mobile Water must Monitor for List 1 & List 2 • Safe Drinking Water Accession and Review System (SDWARS) registration • July 31, 2012 – entered Contact info into SDWARS • November 29, 2012 – review and update sample location and if needed, revise monitoring schedule. • Questions? Contact CDX Help Desk @ 1-888-890-1995

5. SCHEDULE ON SDWARS

6. UCMR 3 TIMELINE OF EVENTS

7. TIMELINE Monitoring Data Deadlines Large Systems Laboratory must post data to SDWARS within 120 days after collection PWS must review, approve and submit data to State and EPA within 60 days of laboratory submittal 2016 – allows for systems whose last sampling event was late 2015 to report and approve data.

8. HOW DOES THIS AFFECT ME?

9. APPLICABILITY OF UCMR3 TO PWS BY TYPE AND SIZE

10. COST OF UCMR3 • Large systems must budget 100% of cost – labor, sample collection, analysis and shipping. • Systems serving <10,000 persons will have to only pay labor costs. EPA and State will pay for other costs. Estimated cost (as listed in Federal Register) • List 1 - $1,085 per event • List 2 - $418 per event Cost includes shipping (est. 25 lb)

11. UCMR MONITORING LISTS

12. UCMR MONITORING LISTS • LIST 1 – Methods used are common analytical methods used by drinking water laboratories • List 2 – Specialized methods not commonly used • List 3 – New methods

13. LIST 1 - ASSESSMENT • 7 Volatile Organic Compounds (VOC) EPA Method 524.3 • 1,2,3 Trichloropropane • 1,3 butadiene • Chloromethane (methyl chloride) • 1,1-dichloroethane • bromomethane( (methyl bromide) • Bromochloromethane (Halon 101) • Chlorodifluromethane (HCFC-22)

14. LIST 1 ASSESSMENT • Synthetic Organic Compound Using EPA Method 522 • 1,4 – dioxane • 4 Metals using EPA Method 200.8 (alternate SM & ASTM) • Cobalt • Molybdenum • Strontium • Vanadium • Chromium (concurrent with chromium-6)

15. LIST 1 ASSESSMENT • Oxyhalide Anion Method 300.1 (or SM/ASTM alternate) • Chlorate • 6 Perflurinated Chemicals EPA 537 • Perfluorooctanesulfonic acid (PFOS) • Perfluorooctanoic acid (PFOA) • Perfluorononanoic acid (PFNA) • Perfluorohexanesulfonic acid (PFHxS) • Perfluoroheptanoic acid (PFHpA) • Perfluorobutanesulfonic acid (PFBS) • Hexavalent Chromium (chromium -6) EPA 218.7

16. LIST 2 SCREENING • 7 Hormones by EPA 539 • 17-β-estradiol • 17-α –ethynylestradiol (ethinylestradiol) • Estriol • Equilin • Estrone • Testosterone • 4-androstene-3,17 dione

17. LIST 3 PRE-SCREEN • Enterovirus • Norovirus • Pathogen indicators (total coliforms, E. coli, bacteriophage, Enterococci and aerobic spores) • 800 randomly selected systems serve ≤1,000 customers and use undisinfected ground water in karst or fractured bedrock environments.

18. SAMPLING REQUIREMENTS

19. UCMR3 SAMPLING • Hand out on sampling requirements from each method • Each method had different sets of requirements • If budget allows, set up trial sample and analysis run before actual sample date. • Trial run helps to determine what all involved, especially if have many sample points • Data helps evaluate if any contamination present

20. VOLATILE ORGANICS • Method 524.3 • Amber Glass vials (40 or 60 mL’s) with PTFE silicon septa caps – preservative ascorbic acid, maleic acid. • If sample foams vigorously when sample added to pre-preserved vial – discard and place in unpreserved container. Make sure to mark UNPRESERVED – HOLDING TIME 24 HRS. • Always fill containers up completely and free of headspace. Fill slowly so as to not loose preservative. • Field Blanks must always accompany samples. Keep closed at all times and return to lab.

21. SYNTHETIC ORGANIC COMPOUNDS • 1,4 – Dioxane – EPA Method 522 • Glass containers, 1L 2-step preservation process • Headspace not an issue – collect so that preservative not flushed out. Fill bottle as full as possible. • After sample collection, shake so that sodium sulfite completely dissolves. Add sodium bisulfate. Mix well.

22. METALS • Select Metals by EPA Method 200.8, ASTM D5673-10; SM 3125 • Plastic containers, 250-500 mL with Nitric acid as preservative. • Headspace not an issue, collect to fill most of bottle. Do not flush out preservative. • Field Blanks accompany samples. Open in field, but do not transfer contents

23. OXYHALIDE ANION • Chlorate by EPA Method 300.1, ASTM D 6581, SM 4110D • Plastic opaque bottles, 250 mL with EDA as preservative. This preservative keeps chlorate from breaking down to chorite/chlorate ions. • If water treatment plant uses chlorine dioxide, sparge sample with inert gas prior to adding preservative. • For this step – may need laboratory to add preservative and sparge when dropped off – ASK UCMR3 LAB! • Headspace not an issue, collect mostly full to not flush out preservative.

24. PERFLUORINATED COMPOUNDS • Method 537 • 250 mL polypropylene bottles with polypropylene caps. • Trizma is preservative. • SAMPLER MUST WASH HANDS AND WEAR NITRITE GLOVES WHEN SAMPLING! • PFAA contamination can occur from common sources such as food packaging and some food and beverages. • Headspace not an issue, fill containers mostly full and do not flush out preservative. • Field blanks to accompany samples. At sample site, transfer shipped reagent water to empty bottle.

25. HEXAVALENT CHROMIUM • Chromium-6, Cr+6, Chromium VI – Method 218.7 • Preserved with a combined buffer/dechlorinating reagent. 100 mL plastic sample bottle. • To sample: open tap and allow system to flush for approximately 5 minutes. Fill bottle carefully not to flush out preservative. Invert bottle several times to mix preservative. • Sample should be analyzed as soon as possible, but not to exceed 14 days from sample date.

26. HORMONES • Method 539 • 1 L amber glass bottles. • Preservative sodium thiosulfate & sodium omadine. • Fill samples to neck of bottle. • Each site should have a minimum of 2 – 1L preserved bottles and a 1L bottle of reagent water. • Advise to wear dusk mask to avoid contaminating sample. • During sampling, pour reagent water into one of the empty preserved containers – field blank to determine if human hormones contribute to sample results.

27. List 3 – Pre-Screen Microbioal Contaminants • Enterovirus and norovirus by EPA method 1615 • Other microbiological indicators include: • Total coliforms • E. coli • Enterococi • Bacteriophage • Aerobic spores • EPA will collect samples for these analysis.

28. FIELD SAMPLE REQUIREMENTS

29. Why are Field Blanks Important? • Any sample with a detection must analyze the field blank. • If the field blank shows a detection above 1/3 the minimum reporting level (MRL), then re-sampling is required.

30. Field Blank Procedures • Volatiles (524.3) – pre-preserved bottle with volatile free water. Shipped in field with samples. Do not open in field. • 200.8 Metals – pre-preserved bottle with DI water. Open in field and re-cap but do not transfer contents.

31. Field Blank Procedures, Cont • For Perfluorinated Compounds (PFC’s – 537) and Hormones (539) • Lab sends pre-preserved bottle with DI water to accompany field sampling. • Empty bottle is also shipped • Sampler transfers DI water to empty bottle and this becomes the field blank analyzed by laboratory. A SEPARATE FIELD BLANK IS REQUIRED FOR EACH SITE AND EACH SAMPLING EVENT!

32. Laboratory Fortified Sample Matrix • This is a sample that is fortified with known concentration of analyte(s) of interest. • EPA requires laboratories to analyze a LFSM and a LFSM duplicate one set per 20 samples. • Utility is to provide laboratory with enough sample to satisfy this requirement. • At least one sample set per sampling event has additional volume collected and sent to laboratory.

33. FREQUENCY OF SAMPLING

34. FREQUENCY WATER SOURCE TYPE DEPENDENT

35. Frequency • Samples must be collected within the time frame and frequency in previous table based on contaminant type and water source type for each sampling location. • For the second or subsequent sampling periods: • If location is non-operational for more than one month prior or after scheduled sampling month, you must notify the EPA to reschedule your sampling. • This is only applicable if you are not able to sample within the window from the previous table.

36. SAMPLING LOCATIONS

37. WHERE TO SAMPLE?

38. EPTDS • Entry Point to Distribution System – LIST 1,2,&3 • Sampling to occur at the EPTDS after treatment is applied that represents each non-emergency water source in routine use over the 12-month period of monitoring. • Systems that purchase water with multiple connections from the same wholesaler may select one representative connection from that wholesaler, • Location must be representative of the highest annual volume connections. • If connection selected as the representative EPTDS is not available for sampling, an alternative highest volume representative connection must be sampled.

39. EPTDS, cont. • Ground Water Representative Sampling Locations: • UCMR3 clarified the definition so that the proposed representative well must be representative of the highest annual volume producing and most consistently active wells in the representative array. • If the representative well is not in use at the scheduled sampling time, an alternative representative well must be selected to sample.

40. DSMRT • Distribution System Maximum Residence Time • An active point (location that currently provides water to customers) in the distribution system where the water has been in the system the longest in relation to the EPTDS. • Systems subject to Stage 2 disinfection By-Products Rule should use their total trihalomethanes (TTHM) highest concentration sampling site(s) as their DSMRT sampling site(s).

41. DSMRT cont. • List 1 parameters include: total chromium, chromium 6, cobalt, molybdenum, strontium, vanadium and chlorate. • Collected at one Distribution sampling point per treatment plant.

42. HOW TO FIND AN APPROVED LABORATORY?

43. PWS >10,000 PEOPLE SERVED • The PWS must coordinate sample analysis with an approved laboratory and is responsible for all costs. • Laboratory sends data to the SDWARS system. • Contact local third party lab who currently does utilities required testing. They may be able to coordinate with an approved lab. • Get quotes from several different labs.

44. PWS <1,000 PEOPLE SERVED • EPA coordinates sample analysis with contracted laboratories and pays for analysis cost. The lab will submit data directly to EPA. • EPA examines all data and QC elements and generates reports. • However, EPA only collects samples for the PWS for List 3.

45. APPROVED LABORATORIES • How many of the UCMR3 methods is the laboratory EPA approved to perform? • How long has the laboratory been approved? • How familiar is the laboratory with UCMR3 details? • Talk with other utilities on who they used during UCMR2. Many of the labs are also certified for UCMR3 Word of mouth is the best advertisement! • Do you homework – find approved labs on EPA website: http://water.epa.gov/lawsregs/rulesregs/sdwa/ucmr/ucmr3/upload/lablist-ucmr3-pdf.pdf

46. APPROVED LABS

47. REPORTING DATA

48. Reporting Elements Note: PWS’s were required to report US Postal Code(s) for all areas served by the PWS

49. DISINFECTION TYPE • What is this? • The PWS must report the disinfectant that has been added to the water that is sampled. This must be reported at each sampling point. The possible choices are as follows:

50. DISINFECTION TYPE CODES • CLGA – Gaseous Chlorine • CLOF – Offsite Generated Hypochlorite (stored as liquid form) • CLON – Onsite Generated Hypochlorite (no storage) • CAGC – Chloramine (formed from gaseous chlorine) • CAOF – Chloramine (formed from offsite hypochlorite) • CAON –Chloramine (formed from onsite hypochlorite) • CLDO – Chlorine dioxide • OZON – Ozone • ULVL – Ultraviolet Light • OTHD – Other types of Disinfectant • NODU – No Disinfectant Used