ASDWA Submits UCMR5 Comments

This week ASDWA submitted its comments on the proposed Fifth Unregulated Contaminant Monitoring Rule (UCMR5). ASDWA’s comments were organized into the following themes with examples of some of its recommendations below:

1. Needed Communication Resources

• Inclusion of the 29 PFAS in UCMR5 requires significant communication resources from EPA developed with consistent input from both states and water systems. EPA should consider a pre-sample communication strategy through press releases, social media, or other appropriate methods to inform the public of the purpose of UCMR, how the result will be used, what contaminants will be sampled, what a detection means, and how long it takes to get sample result information out to the public.
• Specific to the proposed PFAS, the development of a consistent and pre-established response decision tree is necessary. Communications around analytical results should be clear and precise, providing recommendations and describing any actions required based on levels of risk.
• ASDWA recommended that EPA develop and share resources on one-time sampling, follow-up sampling, resampling, and bottled water distribution (if necessary) for both the proposed PFAS and lithium sampling standards. At a minimum, detailed sampling guidance must be developed and made readily available for all samplers.

2. Needed Contaminant Research

• ASDWA urged EPA to restore the connection between UCMR and Contaminant Candidate List (CCL). Future UCMRs should be designed to generate robust national occurrence data to assist in the decision-making for regulatory determinations from the CCL.
• ASDWA recommended that EPA develop a holistic research strategy in coordination with the Centers for Disease Control to address Legionella pneumophila. The strategy should include directions detailing where to test for Legionella pneumophila and remediation actions to take once it is found.
• As this is the first UCMR that will include contaminants with existing state-level maximum contaminant levels, ASDWA recommended that EPA exempt water systems that already have PFAS treatment in place to reduce duplicative sample collection.

3. Analytical Methods/Lab Capacity/Quality Assurance Concerns and Recommendations

• EPA needs to inform states on how data submitted by laboratories is being adequately reviewed and provide clarity on laboratory expectations for data accuracy and quality beyond the initial laboratory approval process.
• ASDWA recommended that EPA use this opportunity to obtain additional information on total organic fluorine (TOF).
• ASDWA recommended that EPA continue to develop additional analytical methods for PFAS beyond the 29 proposed in this UMCR, considering the full universe of compounds is in the thousands.
• ASDWA recommended that in the final UCMR5, EPA provide flexibility for the states with lower PFAS detections to use labs meeting their state requirements if they are intending for the sample results to be used for compliance purposes in their state.

To view ASDWA’s complete comments, click here.