|
 |
|
UCMR Update Issue
7
The "We Survived" Issue
EPA 815-N-04-003a, March 2004
UMCR Update Issue Number 7 - This information sheet, The UCMR
Update, is the seventh to be issued by the Technical Support Center
(TSC) of the Office of Ground Water and Drinking Water (OGWDW). Future
issues will be distributed as needed to maintain information flow related
to the Unregulated Contaminant Monitoring Regulation (UCMR for those of
you who may have forgotten).
Editor's Note: With this issue, I am pleased to announce that
UCMR sampling is, technically, over! I say technically because only
the rule defined sample period has expired. However, EPA does not have
all the data from the PWSs at the current time. Those of you that may
be questioning whether or not you are done, please read on to help determine
whether your water system has satisfied all of its UCMR responsibilities.
The rest of you, read on for fun and amusement!
Now, for the group of PWSs that have met their UCMR requirements, I’d
like to give out a hearty “We survived!” What a fine way
to toast the New Year! Speaking of holidays, I want to wish you all
happy belated holidays for all the ones that have gone by since you
last heard from me. These include Easter, Independence Day, Memorial
Day, Halloween, Thanksgiving, Christmas, Kwanzaa, Chanukah, and New
Years among others. Yes my readers, it has been a long time. I’d
like to tell you that I was off exploring the world, or on a secret
mission for the CIA, or on a trip to the Mars for NASA, but none of
these would be true. Unfortunately, I lost my passport in my junk drawer,
the CIA never returned my calls, and I was too tall to fit on the Spirit
or Opportunity rovers. Instead, I have simply been in Cincinnati trying
to finish up work on my Masters Degree. The increase in workload coupled
with the decrease in UCMR news has left you bereft of this fine publication
for far too long. It was my New Years resolution to get another issue
out before it had been a whole year and, as you can see, I have made
good on it. Just barely though. As for my diet however….
As you have noticed, this is a special edition of The Update because
it is being received by all the large PWSs in addition to the usual
readership. Welcome all new readers and welcome back to all of those
who have previously enjoyed this publication. Since the theme of this
issue is survival, I will use the format of a popular game show that
cannot be mentioned by name for legal reasons.
I. PWS "Tribal" Status
As you all well know, the PWSs in the UCMR program have been broken
into
two groups or “tribes”, if you will. These “tribes”,
dubbed “Large” and “Small”, have been engaging
in sampling for List 1 and List 2 contaminants. These two “tribes”
have performed very well up to this point. The Small Systems are 99%
done with their sampling and reporting. This is an excellent job, but
we’d like to see more improvement from the large systems. So get
out there on-line, review, approve and submit your data. If you don’t,
you will be voted off the “I complied with the UMCR” list.
The next article will address this further.
II. Immunity Challenge I: Approve and Submit Data
The challenge today is a simple one: approve and submit your UCMR data.
To successfully meet this challenge, the public water system must form
an “alliance” with their analytical laboratory. This “alliance”
requires both the laboratory and the PWS to separately register in the
Central Data Exchange (CDX) for access to the Safe Drinking Water Accession
and Review System (SDWARS). The laboratory posts the UCMR monitoring
data to SDWARS. The PWS then reviews, approves and submits these posted
results to EPA.
Immediately following CDX registration for SDWARS, laboratories and
PWSs must submit a sponsor letter to EPA (a template sponsor letter
example is available on-line after completing CDX registration). If
your laboratory is performing work for other PWSs and has registered
in CDX, they do not need to register again; all they need to do is add
your PWS to their SDWARS “client list.” It is important
that the laboratory that analyzed your samples submit the data to SDWARS
(this is critically important in cases where subcontract labs have conducted
the analysis).
As for those who have submitted/approved partial sets of data or none
of your data, please complete your reporting as soon as possible. As
some of you may recall from last September, the Great Lakes Environmental
Center (GLEC) called many of the systems that hadn’t approved
any data in SDWARS to remind them to do so and to troubleshoot any problems.
Now, the Regional EPA Enforcement Offices are preparing to follow up
with those PWSs that have not completed their monitoring and reporting
under the UCMR. If you have not approved and submitted your UCMR results,
the next correspondence may be from your EPA Regional Enforcement office.
Please realize that these data are very important, as they help to determine
the need for future drinking water regulations for the contaminants
for which you have been sampling. If you are having trouble with the
reporting, or have any questions about the process, please review the
UCMR reporting web page on the EPA web site, http://www.epa.gov/safewater/standard/ucmr/reporting.html,
or call the CDX Help Desk at 1-888-890-1995. Remember that immunity
from enforcement action is at stake here. That is something we all want!
III. Immunity Challenge II: Entry Point Sampling for
Source Water Detections
As you may recall, several states have elected to have their PWSs monitor
for UCMR contaminants at the source water. What you may have forgotten
is that CFR 141.40(a)(5)(ii)(c) requires all systems that are performing
source water sampling to conduct entry point sampling upon the detection
of a UCMR contaminant. The entry point sampling is required only for
the detected contaminant or contaminants. All other sampling may continue
to be performed at the source water, provided no subsequent detections
occur. When a PWS does have a UCMR contaminant detection, it must sample
at the entry point to the distribution system for a 12-month time frame,
beginning with the next scheduled sample event. This may carry the PWS
beyond the listed sample period but is required. The only exception
to this rule is if there is no treatment between the source water and
the distribution system. This must be determined by either EPA or the
state before the system is released from the entry point monitoring
requirement. Please make sure that you do not overlook this clause,
as it is a requirement of the UCMR. If you are already sampling at the
entry point due to a source water detection, be sure that you carry
it out over a 12-month period.
 IV. Reward Challenge: The UCMR “ Golden Faucet ” Award
This Golden Faucet Award is actually more of a lifetime achievement
award. The recipient of this award didn’t eat any bugs, put together
puzzles, grab keys to escape a prison cell with sticks banded together
with rope, or dive to release floats on the bottom of a lagoon. As a
result, he won’t be getting a fabulous dinner, SUV, or trip to
Paris. What he did do was much more amazing. He created and maintained
the data systems that EPA uses to organize the data that we receive
from the small systems for the UCMR. Without him, we’d have been
tracking all this information with pen, paper, disks, and whatever else
we could devise. We’d probably all also be quite insane, like
we were back in the ICR days. Maybe even more impressive, this individual
was able to work with and help upgrade SDWARS while maintaining his
sanity. He recently retired from EPA after numerous years of service
and will be sorely missed. The Faucy goes to Michael Cummins of the
Technical Support Center, U.S. EPA. Again, if anyone would like to nominate
someone for a Faucy, please email me at wagner.cory@epa.gov.
V. Future Episodes
Well, UCMR 1 is now over (for most of you anyway) but coming right on
its
heels is UCMR 2. The rule should be proposed in late 2004, but, in the
meantime, EPA would welcome your input on how we can improve this process.
After all, you were the ones that went through it. We are all in this
together and your feedback will help us shape the new rule so that it
is as easy to comply with as possible. EPA wants your honest opinion
on how things went. If you think there are ways to improve it, please
give us some constructive feedback on how we can make it better. If
you liked aspects of the UCMR, then let us know so we can keep them
as they are. We promise to listen and take into consideration all comments.
Possible topics for discussion could be: The ease of use of SDWARS,
the establishment of predefined monitoring periods for all systems,
the helpfulness of the UCMR Update, the amount and utility of guidance
documents and FAQs from EPA, and likes and dislikes about the UCMR.
These are just possible ideas and all topics are open for discussion.
Send any comments about the UCMR to the UCMR coordinator.
VI. Contact Information
A general reminder to laboratories and PWSs: when contacting EPA about
UCMR issues, please use your USEPA Lab ID number or PWSID number, respectively.
General UCMR questions may be directed to the Drinking
Water Hotline at:
1 - 800- 426 - 4791
Questions regarding registration for or use of the SDWARS/UCMR
reporting
system may be directed to the SDWARS Help Desk at:
1 - 888 - 890 - 1995
Correspondence with TSC and comments on the Update
(c/o Cory Wagner) may be directed to:
UCMR Coordinator
Technical Support Center (MS-140)
U.S. Environmental Protection Agency
26 W. Martin Luther King Drive
Cincinnati, OH 45268
Fax: 513 - 569 - 7191
|
