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UCMR3 Sampling Workshop:What You Need to Know

Presented by: Joseph Mattheis Life and Health SciencesWater Quality Account Executive

Agenda

About UL

UCMR 3 Overview

UCMR 3 Methods

UCMR 3 Sample Collection

UCMR 3 Costs

Questions

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UCMR 3 Overview

• Purpose

• Timeline

• Applicability

• Monitoring

• Lists

• Contaminants

• Sampling Frequency

• Sampling Locations

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• Reporting• PWSs• Elements• Dates• Data

• Contacts

• Methods

• Sampling Instructions

Purpose of UCMR 3

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• 1996 Amendments to SDWA require EPA to monitor unregulated contaminants

• Specifies frequency of every 5 years

• Data generated allow for Public exposure assessment to unregulated contaminants of concern

• Data provide the basis for regulatory decisions – which contaminants to regulate

UCMR 3 Time Frame

• December 21, 2010 – applicability date

• State monitoring plans developed (including national representative sample based on SDWIS/Fed population)

• March 3, 2011 – proposed rule published

• Laboratory approval program begins

• May 2, 2012 – final rule published

• States/EPA begin to inform PWSs and finalize monitoring plans

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UCMR 3 Timeline

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2012 2013 2014 2015 2016

Pre-monitoring Implementation • Lab Approval • SDWARS Registration - Inventory - Schedule Sampling Period

One consecutive 12-month period during January 2013 – December 2015 (monitoring can span more than 1 calendar year, as long as conducted in a consecutive 12- month period).

Complete Reporting to SDWARS

• Review Data

• Post to NCOD

UCMR 3 Applicability – Who is Required To Test?

Assessment Monitoring (List 1 Contaminants)

• All CWS & NTNCWS serving populations >10,000 (~4,200) plus 800 randomly selected serving populations ≤ 10,000

Screening Survey (List 2 Contaminants)

• All CWS & NTNCWS serving populations >100,000 (~410) ; ~320 randomly selected serving populations 10,001 to 100,000 and 480 randomly selected serving populations ≤ 10,000

Pre-Screen Testing (List 3 Contaminants)

• 800 Randomly selected systems serving populations ≤ 1,000

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UCMR 3 Monitoring Lists

Assessment Monitoring – List 1 Contaminants

• EPA Method 524.3 Volatile Organic Compounds

- 1,2,3-trichloropropane

- 1,3-butadiene

- chloromethane

- 1,1-dichloroethane

- bromomethane

- chlorodifluoromethane

- bromochloromethane

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UCMR 3 Monitoring Lists

Assessment Monitoring – List 1 Contaminants (cont.)

• EPA Method 537 - Perfluorinated Compounds

- perfluorooctane sulfonic acid (PFOS)

- perfluorooctanoic acid (PFOA)

- perfluorononanoic acid (PFNA)

- perfluorohexane sulfonic acid (PFHxS)

- perfluorophtanoic acid (PFHpA)

- perfluorobutaneseulfonic acid (PFBS)

• EPA Method 522 - Synthetic Organic Compounds

- 1,4-Dioxane

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UCMR 3 Monitoring Lists

Assessment Monitoring – List 1 Contaminants (cont.)

• EPA Method 300.1 - Chlorate

- chlorate

• EPA Method 200.8 - Metals (alternate methods also available)

- vanadium

- molybdenum

- cobalt

- strontium

- chromium

• EPA Method 218.7 - Chromium6 (Cr6)

- chromium-6

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UCMR 3 Monitoring Lists

Screening Survey – List 2 Contaminants

• EPA 539 - Hormones

• 17-β-estradiol

• 17-α-ethynylestradiol (ethinyl estradiol)

• 16-α-hydroxyestradiol (estriol)

• equilin

• esterone

• testosterone

• 4-androstene-3,17-dione

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UCMR 3 Monitoring Lists

Pre-Screen Testing – List 3 Contaminants

• Cell Culture or QPCR

- enterovirus

• QPCR

- norovirus

• Various Methods - Microbiological Indicators

- total coliforms

- E. coli

- enterococci

- bateriophage

- aerobic spores

EPA will collect the samples from List 3 sampling locations and will pay for all analytical and shipping costs

associated with viruses and indicators for these small systems (≤ 1,000).

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UCMR 3 Monitoring Frequency

PWSs must monitor during a consecutive 12-month period between 2013 - 2015

• Number of times a PWS samples is directly related to the sample point source- Surface Water and Ground Water under the Direct Influence of Surface

Water – must monitor quarterly during their 12-month schedule (sampling events three months apart)

- Ground Water – must monitor twice during their 12-month schedule (sampling events five to seven months apart)

• EPA established a monitoring schedule for all PWSs- PWSs can change their pre-determined schedule in SDWARS by

November 29, 2012, independently, or after that date with EPA permission

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UCMR 3 Monitoring Locations

All samples for UCMR 3 contaminants will be collected at the Entry Point to the Distribution System (EP or EPTDS); in addition three methods will also be collected at the Distribution System Maximum Residence Time (DSMRT)

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List 1: Assessment Monitoring ContaminantsContaminant Type Sampling Location Type  EPTDS DSMRT

EPA 524.3: Volatile Organic Compounds x  EPA 537: Perfluorinated Compounds x  EPA 522: Synthetic Organic Compounds x  EPA 300.1: Chlorate x xEPA 200.8: Metals x xEPA 218.7: Chromium-6 x x

List 2: Screening Survey ContaminantsContaminant Type Sampling Location Type

  EPTDS DSMRTEPA 539: Hormones x  

UCMR 3 Monitoring Locations – Field Blanks

List 1

• EPA Method 524.3• Collected at the EPTDS

• EPA Method 537• Collected at the EPTDS

• EPA 200.8• Collected at the EPTDS & at

the DSMRT

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Due to susceptibility to outside source contamination, UCMR3 requires field blanks to be processed, extracted and analyzed for three of the List 1 Methods and the List 2 Method if there is a contaminant detected in the associated field sample. Field Blanks will be included with the following methods:

List 2

• EPA Method 539- Collected at the EPTDS

UCMR 3 Monitoring and Reporting

Small PWSs serving 10,000 or fewer people are not responsible for the costs associated with the analysis

• EPA coordinates sample analyses with contracted laboratories

• Laboratories submit the data directly to the EPA

• EPA examines the quality control results and generates reports

• EPA collects samples for only List 3 contaminants

• PWS reviews and can act upon data in SDWARS 3

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UCMR 3 Monitoring and Reporting

Large PWSs serving more than 10,000 people are responsible for the costs associated with the analyses

• PWS coordinates sample analyses with an approved laboratory,

and that lab sends the data to the Safe Drinking Water Accession

and Review System (SDWARS 3)

• http://cdx.epa.gov/epa_home.asp

• PWS reviews and can act upon data in SDWARS 3

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UCMR 3 Reporting Elements

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UCMR 3 Reporting Elements

Public Water System Identification Code

Disinfection Type Sample Analysis Type

Public Water System Facility Identification Code

Sample Collection Date Analytical Results - Sign

Water Source Type Sample Identification Code Analytical Results - Value

Sampling Point Identification Code

Contaminant Laboratory Identification Code

Sampling Point Type Identification Code

Analytical Method Code Sample Event Code

As a one-time reporting requirement, PWSs must report the U.S. Postal Service Zip Code(s) for all areas being served water by that PWS.

UCMR 3 Reporting Elements

All of the disinfectants that have been added to the water being sampled must be reported by systems for each sampling point with possible choices being:

• CLGA – Gaseous chlorine

• CLOF – Offsite Generated Hypochlorite (stored as liquid)

• CLON – Onsite Generated Hypochlorite (no storage)

• GAGC – 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 – All other Types of Disinfectant

• NODU – No Disinfectant Used24

UCMR 3 Key Dates – November 29, 2012

Systems must submit contact information to SDWARS.

• Subsequent changes must be submitted within 30 days of the change occurring

Systems can change their monitoring schedule, and review and edit if necessary, inventory information for sampling locations.

• After November 29th, systems must request a change (with an explanation) and obtain EPA approval of the change

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UCMR 3 Data Reporting

Samples must be analyzed by EPA-approved laboratories.

• EPA-approved laboratories will be listed on the UCMR website at: http://water.epa.gov/lawsregs/rulesregs/sdwa/ucmr/ucmr3/laboratories.cfm

• Within 120 days of sample collection

- Laboratories post data to SDWARS

• Within 60 days of lab posting data

- PWS reviews and approves the data. If the PWS has not taken action after 60 days, the data are considered approved and ready for state and EPA review

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EPA Use of UCMR 3 Data

• Updated quarterly by EPA and posted in the National Contaminant

Database (NCOD)

• www.epa/safewater/databases/ncod/index.html

• Data will continue to be added and may be corrected upon further

review

• Use caution when interpreting the data before the dataset is

complete

• UCMR 3 is one of the primary sources of occurrence and exposure

information the agency uses to develop regulatory decisions for

contaminants of concern

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UCMR 3 Contacts

• UCMR Message Center: (800) 949-1581

• This number may change later this year, but as of Sept 7th is still in use

• Safe Drinking Water Hotline: (800) 426-4791

• CDX/SDWARS Help Desk: (888) 890-1995

• UCMR Sampling Coordinator or Laboratory Approval Coordinator

UCMR_Sampling_Coordinator@epa.gov

USEPA Technical Support Center

26 West Martin Luther King Drive (MS 140)

Cincinnati, OH 45268

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UCMR 3 EPA Online Resources

• UCMR 3 EPA Website• http://water.epa.gov/lawsregs/rulesregs/sdwa/ucmr/ucmr3/

- Home

- Basic Information

- Methods & Contaminants

- Laboratories

- Reporting

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UCMR 3 Methods

Assessment Monitoring (List 1 Contaminants) primarily utilize common analytical method technologies used by drinking water laboratories.

• 524.3 GC/MS

• 522 Quadrupole GC/MS

• 300.1 Ion-Chromatography

• 218.7 Ion-Chromatography

• 200.8 ICP-MS

• 537 LC/MS/MS

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UCMR 3 Methods

Screening Survey (List 2 Contaminants) primarily uses common analytical method technologies used by drinking water laboratories.

• 539 LC-ESI-MS/MS

Pre-Screen Testing (List 3 Contaminants) uses newer method technologies not as commonly used by drinking water laboratories. For UCMR 3 these PWSs are ground water systems that:

• Serve less than 1,000 people

• Do not disinfect

• Are located in areas of karst or fractured bedrock

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UCMR 3 Sampling Information

Partnering with your selected laboratory is crucial to your success!

• Complete and Accurate detail on the Chain of Custody and bottle labels is critical for successful data uploads to SDWARS

• Following the collection schedule

• Understand the collection and preservation instructions (Method 522 requires a 2 step preservation process)

• Be certain that both you and your selected laboratory clearly understand the field blank protocols

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UCMR 3 Sampling Information

Properly handling Field Blanks is critical to avoid costly and time consuming recollections.

• Four Methods require field blanks with each sample

• 524.3 (in duplicate)

• 200.8 (at both the EPTDS and the DSMRT)

• 537

• 539

• Collection protocols differ depending on the method

• Any field sample with a detect requires analysis of the associated field blank

• Field Samples with a detect greater than >1/3 MRL requires re-collection

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UCMR 3 Sampling Information

Both the sample collector and the primary PWS contact (if not the same person) need to know and understand the Field Blank protocols.

• 524.3 (EPTDS)• Pre-preserved vials filled with reagent water shipped with collection containers

• DO NOT open in the field

• 200.8 (EPTDS and DSMRT)• Bottle filled with reagent water shipped with collection containers

• At the collection site, OPEN the Field Blank, recap, and return with the field samples to the laboratory

• 537 and 539 (EPTDS)• Pre-preserved bottles with reagent water as well as a empty bottle shipped with

collection containers

• At the collection site, transfer the preserved reagent water into the corresponding empty container and return with the field samples to the laboratory

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Sampling Instructions

Before Sampling

• Read all instructions thoroughly as there are multiple sampling procedures required.

• Remove refrigerant packs from shipping container and place in freezer. The packs must be frozen before returning samples to the laboratory.

• Plan to have samples collected just prior to the normal pick-up time of your overnight carrier.

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Sampling Instructions

Sampling Steps

1.If your sampling point has a faucet with an aerator, it must be removed prior to collection of the samples.

2.Flush the cold water sampling line approximately 10 minutes immediately prior to sampling.

3.Do not touch inside the cap or around the edge of the bottle.

4.Slow the water stream before collection.

5.Refer to the method-specific sampling instructions described below.

6.Indicate sampling date, time, site, and name of sampler on both the bottle labels and the enclosed Chain of Custody.

7.Information on the Chain of Custody and labels must match and be complete.

8.Caution: Bottles and vials may contain chemical preservatives. Avoid skin contact!

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Method-Specific Sampling InstructionsUCMR 3 Volatiles – EPA 524.3:

• Fill three vials so that no air remains when capped.

• Do not overfill. Do not flush away the preservative.

• After tightening the cap, the vial should be inverted and tapped to check for air bubbles.

• If bubbles are present, do not empty the vial. Slowly add several additional drops of water until all air is eliminated.

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3 Amber glass 40 ml vials with Teflon-faced silicone septa in polypropylene caps.

Storage temp: <= 10 C first 48 hrs., <= 6 C after 48 hrs.

Hold Time: 14 days

Preservative: 20-30 mg ascorbic acid + 180-220 mg maleic acid

UCMR 3 Volatiles – EPA 524.3 Field Reagent Blanks:

• The bottles with the blue label

are Field Reagent Blanks

(FRB).

• DO NOT OPEN in the field.

These field blanks must

remain sealed.

• Return with field sample.

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UCMR 3- Method 524.3Field Reagent Blanks

*DO NOT OPEN

UCMR 3 Hexavalent Chromium – EPA 218.7:

• Remove cap, fill the sample bottle to the neck, then replace cap and tighten.

Do not overfill. Do not flush away the preservative.

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1 High density polyethylene (HDPE) 120 ml bottle, collect 100 ml of sample.

Storage temp: <= 10 C first 48 hrs., <= 6 C after 48 hrs.

Hold Time: 14 days

Preservative: 68.2-73.8 mg solid Na2CO3/NaHCO3/(NH4)2SO4 buffer mixture

UCMR 3 Chlorate – EPA 300.1

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No

Use Standard Sampling Procedures

Yes

Use Sparging Procedure Prior to Sampling

Is chlorine dioxide used as part of your disinfection treatment process?

UCMR 3 Chlorate – EPA 300.1: Standard Sampling Procedure

• Remove cap, fill the sample bottle to the neck

• Replace cap and tighten. Do not overfill.

• Do not flush away the preservative.

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1 Plastic 120 ml bottle

Storage temp: Ambient

Hold Time: 28 days

Preservative: 0.12 ml 5% EDA

UCMR 3 Chlorate – EPA 300.1: Sample Sparging Procedure for Systems Using Chlorine Dioxide

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120 mL plastic labeled sample bottle (pre-preserved) plus a 250 mL plastic unlabeled sparging bottle

UCMR 3 Chlorate – EPA 300.1: Sample Sparging Procedure for Systems Using Chlorine Dioxide (cont.)

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Sparging gas should bean inert gas such as a lecture bottle of nitrogen or helium fitted with a regulator.

Disposable glass Pasteur pipette with PVC tubing.

UCMR 3 Chlorate – EPA 300.1: Sample Sparging Procedure for Systems Using Chlorine Dioxide (cont.)

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• Remove cap from the unlabeled 250 mL plastic bottle and fill approximately ¾ full with sample

• Insert the pipette and adjust gas flow to produce a steady flow of bubbles

• Sparge the sample for approximately 10-15 minutes. The chlorine dioxide should be effectively removed from the sample.

UCMR 3 Chlorate – EPA 300.1: Sample Sparging Procedure for Systems Using Chlorine Dioxide (cont.)

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• Transfer the sparged sample into the EDA preserved 120 mL bottle filling to the neck of the bottle.

• Replace the cap on the 120 mL bottle and tighten. • Dispose of any extra sparged sample and its

container.

UCMR 3 Metals – EPA 200.8:

• Remove cap, fill the sample bottle to the neck, then replace cap and tighten.

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250 mL Plastic Bottle

Hold Time: 14 days for unpreserved samples, 6 months for samples preserved within 14

days

UCMR 3 Metals – EPA 200.8 Field Trip Blank:

• The bottle with the blue label is a Field Trip Blank (FTB).

• Break the custody seal and

OPEN the bottle.• Recap the bottle at the

sampling site after collecting field samples.

• Return with the field sample. • The custody seal must be

broken.

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UCMR 3-200.8 Field Trip Blank

*Open at the sampling site

*Replace cap and tighten,

safety seal must be broken

UCMR 3-1,4-Dioxane – EPA 522:

• Remove cap, fill the sample bottle to the neck, then replace cap and tighten.

• Do not overfill. Do not flush away the

preservative.

• Cap the bottle and shake vigorously to dissolve the de-chlorinating agent sodium sulfite.

• Uncap the bottle. Add entire contents of vial of sodium bisulfate preservative into the sample.

• Cap the bottle and shake vigorously to dissolve the preservative.

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3 Amber Glass 250 ml bottles with Teflon lined caps pre-preserved with 20 +/- 2 mg Na2SO3

1 small vial of 250 +/- 25 mg NaHSO4 to be added at sampling

Storage temp: <= 10°C first 48 hrs., <= 6°C after 48 hrs. Do not freeze.

Hold Time: 28 days

UCMR 3 PFCs – EPA 537:

• Nitrile gloves (provided) MUST be worn during the sampling steps.

• Remove cap, fill the sample bottle to the raised line on the bottle.

• Replace cap and tighten.

• Do not overfill. Do not flush away the preservative.

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3 Plastic 250 ml bottles with polypropylene caps.

Storage temp: <= 10 C first 48 hrs., <= 6 C after 48 hrs.

Hold Time: 14 days

Preservative: 1.2-1.3 g Trizma Pre-set

UCMR 3 PFCs – EPA 537 Field Trip Blank:

• The bottle with the blue label is a

Field Trip Blank (FTB).• Break the custody seal, open the

bottle, and then pour the Field Trip Blank Water into the empty bottle with a blue label.

• Return with the field sample.

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UCMR 3-537 Field Trip Blank*Transfer the filled bottle into the

empty FTB bottle

UCMR 3 Hormones – EPA 539:

• Nitrile gloves (provided) MUST be worn during the sampling steps.• Remove cap, fill the sample bottle to the neck, then replace cap and

tighten.• Do not overfill. Do not flush away the preservative.

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3 Amber Glass 1 L bottles with Teflon lined caps.

Storage temp: <= 10 C first 48 hrs., <= 6 C after 48 hrs.

Hold Time: 28 days

Preservative: 75-85 mg sodium thiosulfate + 60-70 mg sodium omadine

UCMR 3 Hormones – EPA 539 Field Trip Blank:

• The bottle with the blue label is a Field Trip Blank (FTB).

• Break the custody seal, open the bottle, and then pour the Field Trip Blank into the empty bottle with a blue label.

• Return with the field sample.

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UCMR 3-539 Field Trip Blank*Transfer the filled bottle into the empty

FTB bottle

Sample Shipping Instructions

Shipping Instructions:

• Place frozen refrigerant packs, bags of wet ice, samples and Chain of Custody into shipping container and return to the laboratory immediately after collection.

• Sample bottles must be hand delivered or sent by an overnight carrier.

• Laboratory must be notified prior to shipment of samples for Saturday delivery.

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UCMR 3 Distribution Kit

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Chain Of Custody - DSMRT

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UCMR 3 List 1 Kit

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Chain Of Custody – EPTDS List 1

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UCMR 3 List 1 + List 2 Kit

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Chain Of Custody – EPTDS List 1 and 2

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UCMR 3 Collection Video

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Why is UCMR 3 Testing Expensive?

EPA made assumptions that laboratories would take steps with all field blanks to ensure that if analysis of any of the blanks becomes necessary, required holding times would not be exceeded.

These assumptions include:

• All 524.3 field blanks would be analyzed

• All 537 and 539 blanks would be extracted

• EPA’s conservative assumption that all 537 and 539 Field Blanks will be extracted

• Extraction is only part of the process, it only covers a portion of the total cost if a sample does end up requiring analysis such as

• Costs associated with additional analytical batches

• Additional staff salaries for analysis, peer review, client notifications, report generation, and reporting to the client and SDWARS

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Why is UCMR 3 Testing Expensive? (cont.)

Parameter CAS #

Number of Finished Water

samples Analyzed

Number of Detects >

UCMR3 MRLUCMR3 MRL

% w/ Detects >MRL

 Chromium  7440-47-3 16269 12441 0.2 ug/L 76%

 Cobalt  7440-48-4 7949 516 1.0 ug/L 6%

 Molybdenum  7439-98-7 8232 4221 1.0 ug/L51%

 Strontium  7440-24-6 9427 9049 0.3 ug/L 96%

 Vanadium  7440-62-2 8809 4996 0.2 ug/L 57%

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• 200.8 Field Blanks were NOT mentioned in EPA’s cost assumptions.• Based on a high rate of occurrence as illustrated in the table above,

expect field blanks for 200.8 to require analysis.• A Field Blank that requires analysis is not different than a field sample

and cost the laboratory the same amount to analyze.• Assuming a PWS has just 1 EPTDS and 1 DSMRT, this makes four

analyses

UCMR 3 Costs - Budgeting & Planning

There is no doubt that UCMR 3 is an inexpensive regulation. There are, however, a few things that you can do to spread the cost out and minimize the potential for additional costs.

• Adjust your schedule in SDWARS so collections fall over 2 fiscal years instead of 1

• 12 consecutive months does not mean those twelve months must be in the same calendar year

• If you are required to perform Assessment Monitoring (List 1), a SW supply can collect the last two quarters of one year and the first two of the next year

• If you are required to perform Screening Survey monitoring, you could collect all of your List 1 samples in one year and all of your List 2 samples in the next year

• Memorize the Field Blank protocols, this will reduce the likelihood of contamination during collection and potentially avoid additional laboratory fees (some may bill all or a percentage for sample and Field Blank analysis if it is invalid due to contamination during collection)

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Questions?