UCMR (1999) Frequently Asked Questions (FAQ)

Foreword

Please note that the U.S. Environmental Protection Agency (EPA) regulations described in this document contain legally binding requirements. The answers provided here do not substitute for those regulations, nor is this document a regulation itself. It does not impose legally-binding requirements on EPA, States, or the regulated community, and may not apply to a particular situation based upon the circumstances. EPA decision-makers retain the discretion to adopt approaches on a case-by-case basis that differ from this FAQ document where appropriate. Any decisions regarding a particular Public Water System (PWS) will be made based on the applicable statutes and regulations. Therefore, interested parties are free to raise questions and objections about the appropriateness of the application of an issue in this document to a particular situation. EPA will consider whether or not the recommendations or interpretations are appropriate in that situation based on the law and regulations. EPA may change this FAQ document in the future.

This FAQ document provides answers for many of the questions that have been presented to the Unregulated Contaminants Monitoring Rule (UCMR) Implementation Team during regulatory development and the first year (2001) of the UCMR implementation. Some of these issues may not have always been specifically or clearly addressed in the Preamble, the Rule or other implementation guidance materials or the question just may have been asked on more than one occasion. Each question, with the associated EPA response, has been generally categorized by topic. To quickly advance to the respective section of the FAQ document, just click on the appropriate section below.

A. Compliance Issues
B. Consecutive Public Water Systems
C. Data Handling and Review
D. Data Reporting: Safe Drinking Water Accession and Review System (SDWARS/UCMR)
D.1 General Questions
D.2 SDWARS/UCMR Registration
D.3 SDWARS/UCMR data submission
D.4 SDWARS/UCMR data review
E. EPA Notification of Requirements
F. Laboratory Approval/Analytical Methods
G. List 3, Prescreening Survey Issues
H. Safe Drinking Water Information System (SDWIS) / Inventory Issues
I. Sampling Location and Monitoring Issues
J. State Issues about Data
K. State Monitoring Plans (SMPs)
L. Acronyms

If your question is not covered by any of the above topics, please contact Dan Hautman (513-569-7274) for the UCMR implementation issues or Jeff Bryan (202-564-3942) for SDWARS/UCMR database issues.

A. Compliance Issues

A.1 Question: Does the unregulated contaminant monitoring period from January 2001 to December 2003 apply to monitoring all the contaminants on List 1 at each sampling point?
Answer: Yes, all List 1 contaminants must be monitored at each required sampling point. However, large systems (serving more than 10,000 persons) can select any 12 consecutive month period from January 2001 to December 2003 to monitor for all the List 1 contaminants. This flexibility was included to allow large systems to coordinate unregulated contaminant monitoring with their compliance monitoring. A public water system (PWS) which has not initiated its monitoring by 2003 will be out of compliance.

A.2 Question: Will tracking system compliance be the responsibility of the EPA Regional offices, EPA HQ, or the State?
Answer: System compliance tracking will include coordination between EPA HQ and Regions, and may also be provided by some States.

A.3 Question:The UCMR states that Assessment Monitoring for List 1 contaminants must be conducted over a consecutive 12 month period from 2001 to 2003. Does unregulated contaminant monitoring need to be conducted within a calendar year or when two monitoring events are 5 to 7 months apart, does that constitute the "12-month period?"
Answer: The monitoring does not need to fall within a specific calendar year and can overlap into an earlier or later year (e.g., in July 2001 and in January 2002). By collecting these two samples at a groundwater system, 5 to 7 months apart , the regulatory requirement of collecting the samples during a "12-month" period is satisfied.

B. Consecutive Public Water Systems

B.1 Question: If System A treats and sells water to System B, which system has to monitor for the unregulated contaminants which have a sampling location listed as entry point to the distribution system ("EPTDS")?
Answer: System A must monitor for contaminants with a sampling location listed as the "EPTDS" in Table 1 of the UCMR. System B has no monitoring requirement for these "EPTDS" locations.

B.2 Question: If System A treats and sells water to System B, which system has to monitor for the unregulated contaminants which have a sampling location listed as "Distribution System?"
Answer: If the sampling location is listed as "Distribution System", then samples only need to be collected for each PWS required to do the monitoring. For the UCMR (1999), this is exclusive to monitoring for Aeromonas. Each PWS selected to monitor for Aeromonas will have to collect 3 samples per sampling event. These 3 samples are expected to be taken from the distribution system "owned or controlled" by System A. You can find a listing of the systems required to conduct List 2 Aeromonas monitoring on-line.

B.3 Question: If a small system is consecutive to a large system should it have to monitor for distribution system locations? If so, does EPA pay for it?
Answer: In general, no, the small system will not need to be monitored, but the State and EPA have some discretion in these circumstances and may require the monitoring if the small consecutive system is considered an appropriate location for sampling. Even though the sampling location may be located in the small system, the large system is responsible for sample collection, analysis, and payment. The large system is also responsible for reporting the results.

B.4 Question: Does the State have flexibility to change the sampling locations listed in the UCMR?
Answer: Yes, there is flexibility for the State to do this. When these situations arise, the State and/or EPA should be asked to assist in making these determinations which can only be evaluated on a case-by-case basis.

C. Data Handling and Review

C.1 Question: How will EPA provide small systems with their data for review and record keeping?
Answer: EPA will provide the results in hard copy to the small systems with a copy sent to the respective State.

C.2 Question: If small systems do not respond to EPA concerning their results, what will EPA do?
Answer: There is no "acceptance" of small systems data per se, because EPA's lab will analyze the data. Since EPA is paying for the analysis of the data, no "approval" by the PWS is required. Once the PWS receives the results, the data will be considered valid after a 30-day review period. Small systems with questions about their data are asked to contact the implementation contractor, GLEC (231-941-2230).

C.3 Question: How will EPA provide a copy of data to the States?
Answer: For small systems, EPA is mailing a printed report of the data to the respective State. For large systems, the State determines how it would like to receive data. States can review the approved data at their large systems through SDWARS/UCMR after they have established an account via CDX.

C.4 Question: Will EPA provide health effects language for Consumer Confidence Reports (CCR) or Public Notification (PN) use?
Answer: No. For the CCR, health effects language is generally only required when there is a violation—the contaminant is detected above the Maximum Contaminant Level (MCL). This can't occur for unregulated contaminants, since they have no MCLs. However, EPA does provide information on likely sources and potential health effects from fact sheets and health advisories. The only requirements of the PN specific to unregulated contaminants is to indicate that the results are available and to provide a contact phone number for any interested party wishing to obtain more information.

C.5 Question: If an unregulated contaminant becomes regulated, would the PWS be allowed to use the data from the UCMR (1999) as the initial monitoring profile?
Answer: This would be determined during the rule-making process to establish a national primary drinking water standard for the contaminant.

C.6 Question: We have been testing extensively for MTBE and perchlorate during the past few years. Will the grandfather clause allow these data to be used to meet the requirements of the UCMR?
Answer: The UCMR has a grandfather clause for data (§141.35(g)). However, to meet the regulatory requirements of the UCMR, this data must meet the reporting requirements of §141.35 in the revised UCMR (September 17, 1999). This is so that EPA can establish a nationally consistent database for making decisions relative to these contaminants. EPA certainly encourages the use of existing data to save resources.

C.7 Question: How and when will EPA request that water systems take water quality parameter samples?
Answer: Water quality parameters are only required for microbial contaminants. They will be taken at the same time and place as the microbial contaminants; i.e., at 3 points in the distribution system for each of 6 months during the year. This means there will only be 300 (180 small and 120 large) randomly selected PWS which will take water quality parameter samples in 2003.

D. Data Reporting: Safe Drinking Water Accession and Review System (SDWARS/UCMR)

D.1 General Questions
D.1.a Question: Where does a user go to report unregulated contaminant monitoring data electronically to EPA?
Answer: SDWARS/UCMR is accessed through the CDX home page.

D.1.b Question: What should a user do if they forget their CDX User Name and/or password?
Answer: In either case access can be restored immediately. Call the CDX Help Desk between 8:00 a.m. and 6:00 p.m. (EST/EDT) Monday through Friday. Call the toll-free line at 1-888-890-1995.

D.1.c Question: What software and/or equipment is needed to use CDX?
Answer: Users should ensure that they have the following before getting started:

• Personal Computer with a 486 MHz processor or better, Pentium processor or equivalent is recommended.
• One of the following versions of Microsoft Windows operating systems: Microsoft Windows 95B with Y2K Service Pack installed (Original Equipment Manufacturer Service Release 2), Windows 98, Windows 2000 or Windows NT4.0 (Service Pack 5).
• To determine which version of Windows you are using, on the desktop click Start | Settings | Control Panel | System. The system version is listed under the General tab.
• To determine if you have the Y2K upgrade installed in Windows 95 environments, check for the presence of the Y2KW95.txt file in the Windows folder by going to Windows Explorer, select View, then click on Details, look in C:\Windows folder to find the Y2KW95.txt file.
• Internet access with an e-mail address.
• Supported Web browser: Internet Explorer 5.5 or higher with 128-bit encryption strength.
• To determine which version of Internet Explorer you are using, on the toolbar click Help | About Internet Explorer. This will also provide the encryption strength (Cipher Strength) supported by your version of Internet Explorer.
• To update to 128-bit encryption strength, Microsoft provides updates for Internet Explorer. These updates can be downloaded from Microsoft.
• Adobe Acrobat Reader 4.0 or higher.
• Printer.

For more information, call the CDX Help Desk at 1-888-890-1995.

D.2 SDWARS/UCMR Registration
D.2.a Question: What is the process for registering with CDX?
Answer: In order to set up your account with CDX, do the following:

• Use the Internet, via Internet Explorer 5.5 or higher, to access the CDX home page.
• Select the option for "If you are new to CDX and wish to register, please click here." You will be prompted to select a user name and password. You will also be asked for your contact information, your organization and the role you will play for your organization for SDWARS/UCMR.
• Supply a "sponsor letter" from your employer indicating that you are authorized to act on behalf of your organization. Samples of the sponsor letter are available online (see D.2.e).
• Create a question that the CDX Help Desk can use to authenticate you if you forget your password.

D.2.b Question: How long does it take to register?
Answer: It takes about 20 minutes.

D.2.c Question: What happens after registration?
Answer: After successful completion of the registration process and the required sponsor letter has been submitted and approved, the account will be activated and the user will be able to access SDWARS/UCMR within CDX.

D.2.d Question: How long does it take to activate my account?
Answer: Your CDX account is active after completion of online registration. Your SDWARS/UCMR account is activated after receipt and approval of your sponsor letter.

D.2.e Question: What does a sponsor letter look like?
Answer: Sample sponsor letters are available. You may view a sample Lab Sponsor Letter or a sample PWS Sponsor Letter in Adobe Acrobat format.

D.2.f Question: What must I do when my password expires?
Answer: Before your password expires, you should be prompted to change your password. Your password must be changed every 90 days.

D.2.g Question: What must I do to renew my account?
Answer: Before your account expires, you will be prompted to reregister and asked to renew your account.

D.2.h Question: Whom do I contact if there is a problem?
Answer: Three support options are available:

• By telephone: Person-to-person telephone support is available from 8:00 a.m. to 6:00 p.m. (EST/EDT) Monday through Friday. Call the CDX Help Desk at 1-888-890-1995.
• By e-mail: Send e-mail to epacdx@lmi.org with "UCMR Tech Support" in the Subject line.
• By fax: Assistance requests are accepted 24 hours a day at 703-917-7105. Support personnel will respond to faxed requests Monday through Friday from 8:00 a.m. to 6:00 p.m. (EST/EDT).

The Office of Ground Water and Drinking Water UCMR Web site might also be helpful in answering questions about reporting.

D.2.i Question: Where can I get an e-mail account if I do not have one?
Answer: In order to complete the registration process and therefore to use SDWARS/UCMR, you will need to have an e-mail address. If you do not already have one, there are free services available. There are many free e-mail services.

D.2.j Question: What is my PWSID assigned by EPA?
Answer: Your PWSID is a 9-character alphanumeric code. It begins with the 2-letter postal abbreviation for your state, followed by a 7-digit number. You can use the Safe Drinking Water Query Form to search the SDWIS database to find your PWSID. Click on your state, and search for your PWS by name or county.

D.2.k Question: What is my Laboratory ID assigned by EPA?
Answer: The Laboratory ID is a 7-character alphanumeric code. It begins with the 2-letter postal abbreviation for your State, followed by a 5-digit number. It may be obtained in one of the following ways:

• Go back to a past PE Study. It will be on the results form, as well as the reporting form.
• Contact your State Certification Officer.
• Contact the Safe Drinking Water Hotline at 1-800-426-4791.
• Contact Charles Feldmann, EPA, at 513-569-7671.

D.2.l Question: Why hasn't my SDWARS/UCMR account been activated?
Answer: There are several reasons for this, but the most common is that you did not enter a proper Program ID during the registration process. The Program ID for a PWS must be its EPA-assigned PWSID (see D.2.j). The Program ID for a laboratory must be its EPA-assigned Laboratory ID (see D.2.k).

D.2.m Question: I'm a State. How do I get registered so that I can review unregulated contaminant data?
Answer: The registration process is slightly different for State and EPA users. They are all preregistered or must be nominated by a peer (see J.6).

D.3 SDWARS/UCMR data submission
D.3.a Question: As a laboratory, how do I submit data to SDWARS/UCMR through CDX?
Answer: Using your self-assigned User Name and password, you will log in to CDX. You will submit your data by one of three methods: Web form, XML file, or flat file.

D.3.b Question: Which submission method should I use?
Answer: Laboratories are free to choose their method for submitting data from the following options:

Submission Method	What is it?	Is it best for you?	What does it require?
Web form	A form we provide to your account on the Web.	If you currently report your data manually it allows you to keystroke your data on the Internet.	Filling out the screens as they are presented. See the Web form guidance (*.pdf file) .
XML file	eXtensible Mark-up Language provides formats/structures used for Internet-based electronic commerce.	If you are using XML for other business activities and store your data in a database; or if you are creating a new system to store this data.	See the XML guidance (*.pdf file).
Flat file	A specified ASCII-based file structure that is positional.	If you are using a database or spreadsheet to manage the data; or if the data is not overly complex; or if you don't want to manually enter the data into a Web form.	See the flat file guidance(*.pdf file).

D.3.c Question: If we use subcontract laboratories to help support our clients unregulated contaminant analytical needs, do the subcontract laboratories need to report those data?
Answer: Yes, only the subcontract laboratory should report the data. The SDWARS/UCMR reporting system was designed to minimize reporting errors. Therefore, data can not be reported many times through multiple parties. The laboratory responsible for analyzing unregulated contaminants is also responsible for posting these data for their client PWSs, into the SDWARS/UCMR system.

D.3.d Question: When a laboratory has data to post to SDWARS/UCMR, how will the data be correctly associated to a specific monitoring location at a PWS?
Answer: The key referential elements that laboratories will need include: PWSID, Facility ID and Sampling Point ID. These elements define a specific monitoring location at a PWS and must be listed in SDWARS/UCMR. They must be known by both the PWS and the laboratory which is posting these data. Active PWS registrants in the SDWARS/UCMR can review and can update their respective inventory specific to their unregulated contaminant monitoring locations (Facility ID and Sampling Point ID). Active laboratory registrants in the SDWARS/UCMR can review the unregulated contaminant monitoring location data for any PWS, but the laboratory can not update any of the inventory information.

D.3.e Question: Does a PWS have to collect unregulated contaminant monitoring samples from all the facilities listed in SDWARS/UCMR?
Answer: Only EPTDS monitoring locations are required for unregulated chemical contaminant monitoring. Additional inventory data are displayed in SDWARS/UCMR because it was populated with data from SDWIS-Fed. (SDWIS-Fed should include all facilities at the PWS.) This should ensure that any potential monitoring location is captured by SDWARS/UCMR. All of the identified facilities are not necessarily expected to be monitored. Many PWSs have Sampling Point IDs that have been defined by their State as the unregulated contaminant monitoring locations. When facilities or sampling points are omitted or incorrectly listed in SDWARS/UCMR, the PWS will need to add or correct the information in SDWARS/UCMR. Your State Drinking Water Administrator may be able to help you with this process. (See H.2 for more information.)

D.3.f Question: What is the significance of facilities with no Sampling Point IDs defined?
Answer: SDWIS-Fed does not contain information about sampling points. Sampling Point IDs were to be supplied by the States during the development of SDWARS/UCMR. Some States have chosen not to partner with EPA. Hence, there are missing Sampling Point IDs.

D.3.g Question: What happened to the large flat file I submitted?
Answer: Large files (>200 KB) submitted to SDWARS/UCMR are put in a different queue to be processed overnight. Flat files are converted to XML before being loaded into SDWARS/UCMR. This will expand a flat file size by about a factor of 15 (e.g., the 200 KB file is expanded to 3 MB). If the file is too large, it still may not get loaded during the off-peak time and may get caught in an infinite loop. Please try to limit the size of the files you submit electronically.

D.3.h Question: I entered my results and hit the "Enter" key, but nothing happened. What happened?
Answer: SDWARS/UCMR is a mouse-driven data entry system. The "Enter" key does not work. This prevents the user from entering partial data. Also, many screens have more than one possible option. The user must select how they want to leave the screen by using the mouse to select the appropriate option after entering all the data.

D.4 SDWARS/UCMR data review
D.4.a Question: Why does search take a long time to display the results?
Answer: The result of the search page displays a lot of information. Several factors affect the speed that data are displayed.

• Server use: The busier the SDWARS/UCMR server, the longer it will take to complete a search. Try to do searches for large amounts of data at off-peak times (after 7 p.m. EST/EDT).
• Size of the search: The more information requested or the broader the scope of the search the longer the time that SDWARS/UCMR will take to display your results. Limit your search as much as possible.


• Communication lines: The speed of the Internet connection will affect how quickly data is retrieved. If the search is large or if you have a slow connection, the search may "time out".

D.4.b Question: Why did the results of my search produce a page that has display errors? This results in a page that is nonfunctional (i.e., I can't approve results).
Answer: The result of the search page displays a lot of information. Several factors affect the display of data:

• PC memory: The amount of memory your PC has may affect the display of the data.
• Number of applications running: If several applications are running, then your machine may not be able to display the requested information properly.

D.4.c Question: What is a Range Check?
Answer: A Range Check is a data interval SDWARS/UCMR uses to compare data entered by the laboratory to meet certain logic criteria. These were created to reduce the number of data entry errors in SDWARS/UCMR. All data entered into SDWARS/UCMR must conform to the "Must be" criteria specified in the table below. When data violates a "Must be" condition, attempting to submit the data to the database will trigger an error message and the record will not be entered. If data is outside one of the "Should be" conditions the database will accept the data but it will request that the laboratory confirm the data value is correct or change the data value before allowing the record to be approved.

D.4.d Question: What should be done when a "Should be" range check is triggered?
Answer: Range checks based on the "Should be" criteria listed in D.4.c require the laboratory to verify the data entry. The laboratory can instruct SDWARS/UCMR to override the range check or correct the data if it is wrong. Each notice of a "Should be" range check must be independently verified. There is no global override function, nor is the override function available on the results of search screen. To override the range check, the lab must locate the responsible record(s) in SDWARS/UCMR and click on the Range Check link to the right of the data. The range check(s) associated with the record will be shown and provides each with a check box to indicate if the lab wishes to override the range check. More information on range checks is available in the Web Form Implementation Guidance (Vol II) for SDWARS/UCMR and in the on-line tutorial.

D.4.e Question: How and when will data entered into SDWARS/UCMR by labs be purged if "Rejected" by a PWS during their review?
Answer: Data, once identified by the PWS as "Rejected", is marked for immediate deletion from the database.

D.4.f Question: What should a PWS do if they have no Internet access (i.e., how will they review/approve their data)?
Answer: No special software is needed (it's all Web-based) such that a PWS with access to any Internet-equipped computer (e.g., the local library) would be able to access SDWARS/UCMR. As an additional alternative, the PWS could designate a third party or even their laboratory with the authority to approve their data as a representative of the PWS. The PWS would need to submit a sponsor letter identifying this representative by name and CDX User Name. The representative will also need to register as the "Approver" for that PWS in CDX.

D.4.g Question: What is the purpose of the different "Roles" in CDX?
Answer: There are three roles: "Reviewer", "Submitter", and "Approver". The "Reviewer" can not enter data nor approve data, but can only view data for their entity. The "Submitter" is allowed to enter data, but not approve data. The "Approver" can enter and approve data.

D.4.h Question: Why can't I approve my own data?
Answer: The ability to approve data is dependent upon the role you submitted on your sponsor letter. Only users with the role "Approver" may actually approve data. For this reason, each entity (PWS and Laboratory) must have at least one user with a defined role of "Approver".

E. EPA Notification of Requirements

E.1 Question: Will EPA do direct mailings to large systems to notify them about the UCMR or to provide them with guidance materials?
Answer: Maybe. It will depend on what responsibilities a State assumes. Several States have assumed this responsibility as part of the Partnership Agreement with EPA to assist with the UCMR implementation. For those States where notification was not adopted, EPA issued notification letters and guidance materials to all affected systems. EPA provided a template letter with supplemental guidance materials to all other States which had agreed to notify their respective systems. Guidance materials are also available on-line.

E.2 Question: When will the List 2 and List 3 systems (300 and 200 systems respectively) be notified of their participation?
Answer: As mentioned in E.1, EPA notified affected systems which were required to conduct List 2 chemical monitoring in 2002 in those States which did not adopt the notification responsibility. In 2002, EPA will be issuing notification letters to those affected systems which are required to conduct List 2 Aeromonas monitoring in 2003 in those States which did not adopt the notification responsibility. No List 3 monitoring has been mandated at this time, consequently no notifications have been issued.

F. Laboratory Approval/Analytical Methods

F.1 Question: For states where the State laboratory normally performs all routine analyses for large systems, but the State laboratory will not be performing unregulated contaminant analyses, how are large systems to be supported? Should the State identify commercial labs, or will the labs contracting to EPA for small systems be able to fill this need?
Answer: Many State laboratories are able to support List 1 analyses, since the List 1 contaminants' methods are already in use for compliance monitoring. If not, the large systems would need to contract for these analyses and testing with commercial labs. Certainly, these large systems could contract with the same labs that EPA is using for small systems' sample analyses, but EPA is not paying for the analyses for large systems. The State can identify certified commercial labs which support the analyses for regulated compliance parameters. The labs must meet the approval requirements of the UCMR. See F.2 and F.3 or go to the UCMR Laboratory approval page for more details.

F.2 Question: How can a PWS best determine whether a laboratory is approved to support their unregulated contaminant monitoring needs?
Answer: A PWS should be able to determine this from discussions with the laboratory. For all List 1 contaminants, except perchlorate, if a laboratory is certified under 40 CFR §141.28 for compliance analysis using an associated analytical method in Table 1 of 40 CFR §141.40, the laboratory is approved to perform unregulated contaminant monitoring analysis using any of the methods listed in the UCMR table as being approved for that unregulated contaminant. See F.3 regarding perchlorate. For unregulated contaminant monitoring purposes, certification may be by a certifying authority (State or Region). As with compliance monitoring, it is the responsibility of the PWS to ensure that they are using an appropriate laboratory. They may do so by asking the laboratory to demonstrate that it meets the approval requirements for the UCMR by providing evidence of the certification described above.

F.3 Question: How can a PWS identify labs approved by EPA for perchlorate analysis under the UCMR?
Answer: EPA set up an approval process for perchlorate analysis under the UCMR. This was based on criteria promulgated in "Unregulated Contaminant Monitoring Regulation for Public Water Systems; Analytical Methods for Perchlorate and Acetochlor; Announcement of Laboratory Approval and Performance Testing (PT) Program for the Analysis of Perchlorate" (65 FR 11372). Perchlorate has unique requirements since laboratories are not certified for the approved perchlorate method (EPA Method 314.0). For all other assessment monitoring contaminants, see F.2. EPA has compiled a list of approved perchlorate laboratories and associated contact information.

F.4 Question: Does approval of a laboratory for unregulated contaminants analyses depend on that laboratory's certification status in their State?
Answer: No. The UCMR is a direct-implementation rule rather than a State-primacy rule. The approval process (see F.2 and F.3) for the UCMR is based on certification by a certifying authority (State or Region).

F.5 Question: Does a State need to update its certification program for the unregulated contaminants?
Answer: No. A State does not need to update its certification program for unregulated contaminants.

G. List 3, Prescreening Survey Issues

G.1 Question: Can States decide not to address List 3 contaminants in the Partnership Agreement and wait to deal with them when analytical methods are approved to test for them?
Answer: Yes. The "Model" Partnership Agreement describes the complete list of activities that a State and EPA could agree to do. At this time, no monitoring schedule for List 3 contaminant monitoring has been promulgated during this 5-year (2001-2005) listing cycle. If there are approved methods for List 3 contaminant testing within this listing cycle, and EPA decides that the monitoring can be conducted, including the selection of vulnerable systems, then discussions will be held on this matter with the States. EPA still needs to prepare the guidance for selecting "vulnerable systems" for the purposes of monitoring the List 3 contaminants.

G.2 Question: The UCMR states that List 3 contaminants will require method development. How should systems prepare?
Answer: Systems do not need to prepare for List 3 monitoring at this time. EPA is conducting research on the List 3 contaminant methods. EPA does not anticipate that these contaminants will be ready for monitoring during this listing cycle.

G.3 Question: Do the States notify the systems that have been identified for inclusion in the prescreen testing of the sampling requirements before they notify EPA which systems are included?
Answer: This decision is left to the discretion of the State. This can be done before, concurrently, or after notification to EPA.

G.4 Question: Who decides how many vulnerable systems the State needs to identify?
Answer: The rule sets the minimum number of vulnerable systems for List 3 contaminants at 5 systems per state and the maximum at 25 systems per state. It is at the State's discretion exactly how many they will include. The final number of systems for the Pre-Screening Survey will be 200, taken from across the country, and they will be selected at random from those systems provided by each State.

H. Safe Drinking Water Information System (SDWIS) / Inventory Issues

H.1 Question: Should States confirm contact, address and telephone information for systems listed in the large system inventory, similar to the information to be checked for the small systems in the State Monitoring Plan (SMP)?
Answer: The State is encouraged to correct the contact, address, and telephone information for large systems to facilitate implementation of the UCMR.

H.2 Question: How will SDWARS/UCMR be populated with inventory data?
Answer: The inventory data in SDWIS will be used to initially populate SDWARS/UCMR. After this initial population, the PWS will need to update the inventory in SDWARS/UCMR so that it is current for unregulated contaminant monitoring. Since they are two separate systems, updating SDWARS/UCMR will have no effect whatsoever on inventory data in SDWIS.

H.3 Question: How can States be assured that no change to SDWIS will be initiated unless they agree that the change was warranted?
Answer: EPA recognizes that updating SDWIS is specifically a State function. EPA is creating a parallel database (SDWARS/UCMR) to be used only for reporting unregulated contaminant data. Only the State has the authority to change SDWIS data.

H.4 Question: Shouldn't any contact between EPA and the systems include the State, to avoid problems between SDWIS-Fed and the State databases?
Answer: SDWIS can only be altered by State directive. Contact between EPA and PWSs will be communicated to the State if the State has entered into a Partnership Agreement with EPA.

I. Sampling Location and Monitoring Issues

I.1 Question: What are the options for sampling if a PWS's status changes during the monitoring? For example, the PWS begins to purchase all of its water from another PWS.
Answer: If a PWS anticipates its status will change to a consecutive system (purchasing all of its water) or it will become inactive before or during the year it planned to conduct unregulated contaminant monitoring, the PWS should contact its State or EPA. If the status will not change until after the year monitoring was conducted, then the UCMR's requirements are applicable to the PWS.

I.2 Question: If a small system misses sampling, samples incorrectly, or collects samples at the end of the vulnerable period and the samples are not valid, and the vulnerable period is already over, what should be done?
Answer: Some problems will undoubtedly occur. This is why EPA and many States have expressed interest in the States collecting samples from the few small systems they will actually have in the program in a given year. In general, if a system has not submitted its samples, or if samples are taken incorrectly, or are damaged in shipment or at the lab, the EPA lab will be in contact with the system to arrange for re-sampling, as soon as possible. (The UCMR calls for resampling within 14 days of receipt of the replacement sampling kit.) The intent of this program is to gather good quality data. A difficult question is what to do when resampling is necessitated for the vulnerable period, and the period is already over. Because of many considerations EPA does not want to postpone resampling to the next year. Resampling should be performed as soon as possible (e.g., in August), and this should not result in a great loss of data quality, particularly for the few samples it will likely affect.

I.3 Question: Can States receive fees from small systems for sample collection and analysis for unregulated contaminant monitoring?
Answer: The State can certainly continue to collect samples, but the samples for small systems must be sent to the EPA contract laboratory. EPA pays for sample shipping and analysis for these systems. Whether or not the State may continue to collect its fee for sample collection, and the fee structure is a matter of State authority.

I.4 Question: Will EPA pay the State to collect samples at an Index System?
Answer: No. The administrative costs of such small "grants" are typically prohibitive for both States and EPA. Index System sampling is being done by the implementation contractor, Great Lakes Environmental Center (GLEC). The State is welcome to accompany the contractor on any Index System sampling.

I.5 Question: Can a State reschedule the timing of Assessment Monitoring samples to address concerns about laboratory capacity?
Answer: Yes.

I.6 Question: What are the sampling locations within systems for unregulated contaminant monitoring?
Answer: For chemical monitoring, the sampling location is designated as the entry point to the distribution system (EPTDS). These sites are typically keyed to the Phase II/V sites that the States and systems have already approved and determined are representative. Using the Phase II/V sites should be clear for the systems and should provide data consistent with the compliance program. For sampling locations designated as "Distribution System" in the UCMR, the locations are again keyed to sites the State and systems have previously defined for other sampling (e.g., total coliforms, THMs-DBPs). Three sites are designated:

• the midpoint in the distribution system, such as the representative total coliforms location;
• the location of the maximum residence time; and
• the location of lowest disinfectant residual.

I.7 Question: When a system has both groundwater and surface water sources, how will the monitoring be done?
Answer: If the surface water sources enter the distribution system at locations separate from the groundwater sources, the surface water supplies must be monitored four times (four consecutive quarters) and the groundwater supplies must be monitored twice, 5 to 7 months apart. The sampling locations should be the entry points to the distribution system (EPTDS). If the surface water and groundwater are mixed or blended before the water enters the distribution system, then the monitoring must be done every 3 months for four consecutive quarters.

I.8 Question: Will testing for the List 2 and List 3 contaminants fall within the same time frame of 2001-2003?
Answer: List 2 Screening Survey for chemical contaminants will occur in 2001 at the selected small systems and in 2002 for the selected large systems. List 2 Screening Survey for Aeromonas, will occur in 2003 at all the selected systems. List 3 monitoring has not been mandated at this time.

I.9 Question: If a small system in the State Monitoring Plan (SMP) is listed as a "groundwater" system and purchases surface water at different times during the year, how should it be included in the plan? How should it be monitored?
Answer: The small system should remain on the SMP as a "groundwater" system. Only the groundwater would be subject to unregulated contaminant monitoring since the purchased surface water is supplied from a wholesale water supplier. The wholesaler would be responsible for unregulated contaminant monitoring of this supplied surface water.

I.10 Question: If a system which utilizes two primary sources as the water sources for 20 water treatment plants, would it need to take samples at each entry point to the distribution system (EPTDS) for all 20 systems?
Answer: The Rule states that a PWS must take samples at each EPTDS representing each non-emergency water source in routine use over the entire 12 month monitoring period or the compliance monitoring point specified by the State. However, the Rule also provides the State with the power to select alternate sampling points for those systems in the SMP. EPA would expect the system to conduct unregulated contaminant monitoring at the representative set of EPTDS since these are the typical Phase II/V monitoring sites.

I.11 Question: Can sampling dates be changed to match up with other monitoring already scheduled?
Answer: For large systems (serving more than 10,000), this is clearly the intent of the Rule. For small systems, this sampling schedule change will need to be specified in the SMP. The SMP was designed to specifically distribute the sampling effort equitably over the three year period, but EPA allows the State to coordinate the unregulated contaminant monitoring sampling with compliance monitoring already scheduled.

I.12 Question: Can a PWS take fewer unregulated contaminant monitoring samples than are required for Phase II/V? For example: a PWS which has one aquifer feeding into several Water Treatment Plants (WTPs). Does every EPTDS at each of these WTPs have to monitor for unregulated contaminants?
Answer: That decision is left to the State. States have the ability to change the locations of unregulated contaminant monitoring samples from all entry points to representative Phase II/V compliance sites. The UCMR states that the Phase II/V monitoring sites could be used to reduce the burden on systems. If this has resulted in many "representative monitoring sites", then the State probably had a good rationale for selecting many sites, such as the possibility of contaminant sources nearby, or previously observed contaminants in the system.

I.13 Question: If a water system adds a new source in the middle of the year that they are monitoring, is the water system required to monitor for one year from the activation date of the new EPTDS? Is the PWS or the State supposed to notify EPA of the new EPTDS?
Answer: If the EPTDS brought on-line during the year that the PWS is monitoring for unregulated contaminants, then the PWS must monitor at the new EPTDS for the remainder of the 12 consecutive month period of monitoring for unregulated contaminants. This may result in less than a full set of data for this EPTDS. This new location will need to be added by the PWS with respective Facility ID and Sampling Point ID to the SDWARS/UCMR data system, in effect notifying EPA and the State of the new EPTDS.

I.14 Question: What is a water system to do if their well is not operational during the month that unregulated contaminant monitoring samples are to be collected?
Answer: Sampling for unregulated contaminants would be required for the chemical parameters at the EPTDS or well(s) which are in operation during the month of the scheduled sampling event. So, if a PWS is scheduled to sample in April, but the particular EPTDS or well is off-line during the entire month of April, then no unregulated contaminant monitoring sample would be required. If, however, it was operated for any one day in the month of April, it would be required to take samples for unregulated contaminants. Since Aeromonas is being sampled in the distribution system, there should never be a time when it is "off-line." Therefore, Aeromonas will have to be monitored for all 6 months.

I.15 Question: What types of treatment are considered to affect the measurement of the unregulated contaminants?
Answer: Finished drinking water is the focus of unregulated contaminant monitoring, because the UCMR is designed to assess both contaminant occurrence and human exposure. When unregulated contaminant monitoring is performed at source water locations and the results are negative, it is reasonable to assume that water treatment will not introduce any of these unregulated contaminants. However, some of these contaminants may be affected by treatment and the only way to evaluate exposure is to monitor the finished water. For unregulated contaminant monitoring, EPA considers water treatment to include any physical or chemical process which improves the suitability of the water for consumption and/or alters the composition of the source water. These processes include, but are not limited to, processes such as filtration, aeration, coagulation, sedimentation, softening, oxidation, and disinfection. For blended water, if processes are applied to the blend prior to the first customer, unregulated contaminant monitoring must be conducted after the blending to evaluate any affects of that treatment. If no such treatment is applied, and the source water is directly blended with finished water, no additional unregulated contaminant monitoring would be required.

I.16 Question: What should a PWS do when an invalid sample necessitates a resample which occurs outside of the original quarterly monitoring period? How will this impact the data from other analytes that were not invalid?
Answer: EPA recognizes that on occasion, circumstances beyond anyone's control can invalidate a sample (e.g., broken vials, samples out of temperature range, internal standard failures, etc.). Samples should be recollected as soon as possible if for any reason the sample data becomes invalid. These problems could be immediately apparent or they may result from QC failures within the analysis batch or specific to an individual sample analysis. These QC problems could be interpreted as "sampling deviations" as identified in §141.40(a)(5)(ii)(F) of the September 17, 1999 UCMR. Any problem with QC that may occur at the lab will need to be relayed back to the PWS through, "...notification from the laboratory that you must resample." Resampling should occur "...within 14 days of observing the occurrence of the error" (§141.40(a)(5)(ii)(F)). If there is a QC problem, it should be documented (verifying the intent to comply with the regulation). Even if the subsequent sampling event is out of the official sampling month, data slightly out of phase is better than no data at all. On a case by case basis, EPA will generally deem these data to satisfy the monitoring requirement for the original sampling period. If the entire data set from that system for all collected unregulated contaminant monitoring samples is invalid, then, all of the samples should be resampled, and the schedule should be revised accordingly. If the impact is on an individual method's data, the system can maintain their original sampling schedule. The affected method should be resampled as soon as possible and then subsequent sampling events for the affected method can correspond with the original schedule.

J. State Issues about Data

J.1 Question: Can a State require submission of unregulated contaminant monitoring data, which has been received by the PWS, before the specified State review period?
Answer: A State may request these data earlier, but it can't require it, unless there are specific State regulations. In those cases, it is the responsibility of the PWS to expedite the report of these data to the responsible State representative. EPA does not have a legal obligation to make these data available prior to the specified State review period.

J.2 Question: The States are very concerned about what will happen when the data are reported and people start asking questions about what the data mean to public health. What is EPA doing about the CCR language for detects reported under the UCMR, and what is EPA doing to prepare for citizen concerns when the detects are reported in the CCRs?
Answer: EPA has drafted fact sheets on the unregulated contaminants and their potential health effects. Fact sheets and health advisories are available on-line and are available through the Safe Drinking Water Hotline at 1-800-426-4791. See C.4.

J.3 Question: Are States required to keep an active database of their unregulated contaminant monitoring data?
Answer: No, a State is not required to keep any unregulated contaminant data. The reporting relationship is between the PWS and EPA. States may request specific data reports from their PWSs and may access the SDWARS/UCMR data system to review the PWS approved unregulated contaminant monitoring results.

J.4 Question: Is a PWS in a State which has not entered into a Partnership Agreement required to report unregulated contaminant results in its CCR?
Answer: Yes, a PWS must report positive unregulated contaminant results in its CCR.

J.5 Question: Will the data collected by EPA be available to the States to view?
Answer: Yes, the data can be viewed through SDWARS/UCMR.

J.6 Question: What is the procedure for providing data to a State when it goes directly from the PWS to EPA?
Answer: Once data has been reviewed and approved by a PWS, individuals at the State and EPA with review responsibilities can concurrently view the data directly on-line within the Safe Drinking Water Accession and Review System (SDWARS/UCMR). The State and EPA personnel will need to register with CDX for access to SDWARS/UCMR, establishing a User Name and password on CDX. State users cannot register through the normal open registration process provided to a PWS or laboratory. States should contact their EPA Regional representative for the UCMR for more information. Contact information is shown in the following table:

K. State Monitoring Plans (SMPs)

K.1 Question: When should a primary small water system be replaced by an alternate small system in a State Monitoring Plan?
Answer: Some specific examples are discussed in this Section. In general, the primary small systems randomly selected for unregulated contaminant monitoring should only be replaced by an alternate if they have become ineligible. This would include any system that:

• is inactive;
• has merged with another water system (i.e., effectively changing its source);
• purchases all of its water from another system;
• is a transient non-community system;
• has changed type (e.g., from CWS to NTNCWS);
• has changed water source (e.g., from GW to SW); or
• has changed population size category (e.g., from a very small system, serving <500 people to a small system serving between 501 and 3,300).

K.2 Question: When should a primary small water system NOT be replaced by an alternate small system in a State Monitoring Plan?
Answer: A small system cannot be removed because of a known history of contaminant occurrence or lack of occurrence. While there will be other circumstances that may cause an alternate system to be selected, these rules must be followed carefully to ensure the statistical integrity of the national sample.

K.3 Question: If a system has changed population, from 700 to 2,100, for example, but hasn't changed size category (i.e., it is still in the 500-3,300 category) should it be replaced?
Answer: No, it should not be replaced.

K.4 Question: If a small system is under an enforcement action should it be replaced?
Answer: Yes, if the system has changed source waters as part of the action (i.e., it is having water trucked in) then it should be replaced. No, if it is still using the same source it should not be replaced.

K.5 Question: If a small system gets taken over by a larger system should it be replaced?
Answer: Yes, if by virtue of changing ownership, it is now 100% supplied by the large system it should be replaced. If only the ownership changes, but the operation of the system remains static, then no, the system should not be replaced.

K.6 Question: If a small system is a continual problem because it does not collect samples on time, etc., can it be replaced?
Answer: For the integrity of the national sample it would be best if the system could be kept in the program. If the State can help to sample such a system it would be helpful. In an extreme case it could be replaced, but enforcement action may result for noncompliance of the small system.

K.7 Question: Are the small systems that are selected now on the State Monitoring Plan for 5 years or do they stay on the State Monitoring Plan forever?
Answer: The small systems selected for the State Monitoring Plans are included only for this 5-year listing cycle (2001-2005). It would be expected that the random selection process will produce a different set of small systems in the next 5-year listing cycle (2006-2010). One deviation from this might be a State/Territory which only has one or two small systems.

K.8 Question: How will changes that happen to some systems between State Monitoring Plan approval and 2003 be dealt with?
Answer: States should inform EPA or the implementation contractor (GLEC, 231-941-2230) when any change causes a small system to become ineligible.

K.9 Question: Can all the small systems selected in a State Monitoring Plan be sampled in the same year?
Answer: They should not be sampled in the same year. The basis for the national representative sample of small systems has specific scientific, technical, and practical underpinnings that are incorporated into its approach. The UCMR indicates that States may modify the State Monitoring Plan by changing the monitoring year and months. This was done, in part, to recognize the three-year compliance monitoring cycle used in most States. The reasons for scheduling "one-third per year" are that:

• National surveys of monitoring for water quality should be done over at least a three-year period to ensure that monitoring is not focused only in an extreme event year, thus, taking into account changes over the hydrologic cycle.


• Spreading the monitoring over three years also provides for variations in chemical use from year to year.


• The assignment of the year to a system was random, improving the representativeness of the sample (less bias toward any particular year).


• EPA has contracts with a limited number of laboratories to conduct unregulated contaminant analyses and these contract labs will have finite capacity to support analysis. Consequently, limiting the number of samples to be analyzed in a particular year improves laboratory efficiency.

K.10 Question: How were the 800 small PWS chosen?
Answer: All systems serving less than 10,000 persons were given a weight proportional to the population they served, then they were selected at random.

K.11 Question: How were the 800 small PWS assigned a year in which to sample?
Answer: Once a system was chosen it was assigned randomly to 1 of the 3 years in which the unregulated contaminant monitoring will be conducted.

L. Acronyms

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