Dear Community PWS:
US EPA sent out instructional letters prior to 2015 to the PWSs who were selected for Unregulated Contaminant Monitoring Rule 3 (UCMR3) testing. MassDEP also sent PWSs an email with instructions on UCMR3. Both of these letters reminded PWSs that UCMR3 results must be put in the Consumer Confidence Report (CCR) and that Public Notice (PN) is also required.
The email sent to PWSs on June 16, 2016 recaps all UCMR3 PN and CCR requirements.
The MA Drinking Water regulations at 310 CMR 22.16A(4)(f)2 require reporting in the CCR of unregulated contaminants for which monitoring is required; and the UCMR3 is required testing by EPA.
MA Drinking Water Regulations at 310 CMR 22.16(7) state that PN must be given for UCMR results within 12 months of the result date.
To help community PWSs that inadvertently missed this information and did not put their UCMR3 detections and/or PN in their CCR, there is now another way to fulfill these two requirements.
If you failed to include the required UCMR3 information in your CCR you may use the following process to comply with the UCMR3 PN and CCR requirements.
- Please use the special combination UCMR3 PN/CCR template linked below and fill in your system’s information. Include a table of your system’s unregulated detections with their average and the high to low range. (Change the sample table in the template to accommodate your system’s results.) Include a PWS contact person’s name and phone number should the consumer want more information.
Template for UNCMR3 Public Notification
- Deliver your combination UCMR3 PN/CCR to customers using one of the options below:
- Directly mail the combination PN/CCR to billed customers or postal patrons
- Upload the combination PN/CCR to a website and mail a postcard with the URL on it out to all billed customers or add the URL to water bills
- Post the combination PN/CCR in local newspapers, public places, apartment complex lobbies, and community organizations.
- Your combination UCMR3 PN/CCR must be completed no later than September 1, 2016.
- You must also send a copy of your combination UCMR3 PN/CCR and completed PN Certification Form to MassDEP by September 1, 2016. A copy of the PN Certification Form is below. You may submit this information electronically to firstname.lastname@example.org, Subject line: PWS ID# - UCMR3 PN/CCR.
Public Notification Certification Form
This is a one-time event to help PWS that missed this UCMR3 requirement in their CCRs. If you have missed the CCR/PN requirement for any previous years’ CCRs (2013, 2014) you can use this form as well.
If you have any questions please contact Marie Tennant at 617-292-5885.
Has your system been required by the US Environmental Protection Agency (EPA)to test for unregulated contaminants under the Unregulated Contaminant Monitoring Rule 3 (UCMR3)?
To answer the above questions, US EPA provided the following guidance on April 22, 2014.
All community systems have been required since 1998 to distribute CCRs to their consumers. (Non-community systems are not required.) One requirement of the CCR Rule is to report unregulated contaminant monitoring results whenever they are detected, that is, any detect above the minimum reporting level (MRL). A community system should include the average of the year’s monitoring results and the range of detections, and should briefly explain in the CCR why it is monitoring for unregulated contaminants.
Unregulated contaminants are those that don’t yet have a drinking water standard set by US Environmental Protection Agency. The purpose of monitoring for these contaminants is to help US EPA decide whether the contaminants should have a standard.
Those community PWSs who wish to provide additional information to their customers may refer to the UMCR3 Data Summary at: http://www.epa.gov/dwucmr/third-unregulated-contaminant-monitoring-rule. This data includes health-based "reference concentrations" with explanations for many of the UCMR3 contaminants.
American Water Works Association (AWWA) has more information at: http://www.drinktap.org/water-info/whats-in-my-water/unregulated-contaminant-monitoring-rule.aspx.
EPA provided the following additional information for small community water systems:
Reporting UCMR3 results (for samples collected in 2013) in the 2014 CCR
EPA is responsible for the analysis of UCMR3 samples from small PWSs and for the development, review, and distribution of monitoring results. Based on the lag time between sample collection and laboratory reporting of analytical results, the time required for EPA’s quality control review of the results, and the time required to develop and distribute UCMR3 reports to small systems, many small PWSs that had UCMR3 samples collected in 2013 have not yet received their monitoring results. Though EPA's Technical Support Center is working diligently to develop, review, and distribute those reports, it is clear that some PWSs will not receive results from UCMR3 sampling conducted in 2013 before their 2014 CCR is to be distributed.
With respect to UCMR3, EPA's view is that the CCR for a given year (due by July 1 of that year) is to report UCMR3 detections (i.e., results above minimum reporting limits) based on results received by the PWS during the previous calendar year. For example, a PWS's 2014 CCR would include UCMR3 results received during 2013. If a small PWS does not receive its UCMR3 monitoring report from EPA until 2014, EPA's view is that those results do not need to be included in the CCR until 2015 (even if the sample was collected during 2013).
Information on preparing your CCR can be found on the MassDEP website at: http://www.mass.gov/eea/agencies/massdep/water/drinking/water-systems-ops.html.
Additional CCR help can be found by contacting the regional MassDEP staff:
NERO – James.Persky@state.ma.us or 978-694-3227
SERO – Courtland.Ridings@state.ma.us or at 508-946-2722
CERO – Robert.Bostwick@state.ma.us or at 508-849-4036
WERO - Deirdre.Doherty@state.ma.us or at 314-755-2148
Boston – Marie.Tennant@state.ma.us or at 617-292-5885
For UMCR3 help please contact Kenneth.Pelletier@state.ma.us or at 617-348-4014.
The Public Notification (PN) Rule was mandated in the year 2000 and applies to all PWS systems: community, non-transient non-community systems, and transient non-community systems.
In addition to requiring notification of violations, the PN rule requires PWSs to provide special notices for certain situations, including the availability of unregulated contaminant monitoring data. Special public notices of unregulated contaminant monitoring data are different from other public notices because they do not have to contain all the elements required of other types of public notices. Instead, systems need only report that the results are available, and provide a phone number or contact where the results can be obtained.
EPA's Revised Public Notification Handbook for CWSs and NTNCWSs (EPA 816-R-09-013) and Public Notification Handbook for Transient Non-community Water Systems (EPA 816-R-09-009) provide useful information for water system operators on how to write and distribute effective public notices. The handbooks and other information regarding the PN rule are available at http://www.epa.gov/dwreginfo/public-notification-rule.