&EPA
United States Office of Water EPA-812-F-94-001
Environmental Protection (Mail Code 4601) August 1994
Agency
Fact Sheet on State Reporting
Guidance for Unregulated
Contaminant Monitoring
BACKGROUND
EPA has developed and is distributing to the Regions and States a document
entitled "State Reporting Guidance for Unregulated Contaminant Monitoring". As the
name indicates, this guidance document is intended for use by States and Regions in
reporting unregulated contaminant data to EPA Headquarters. These data will be used
together with other available data to assist EPA in determining the occurrence of
unregulated contaminants in drinking water and whether or not any of these contami
nants should be regulated. The requirement for EPA to issue regulations and collect
data for this purpose was established at Section 1445 of the Safe Drinking Water Act
Amendments of 1986. This provision applies to all public water systems; however, any
system serving less than 150 service connections is deemed to have complied if such
system makes its facilities available for sampling by the State. The Act further requires
that sampling for unregulated contaminants be required every 5-years. Section 141.40
of the Phase I, II and V regulations implement this section of the Act. Further
background on these provisions is provided in the guidance document. Over 25,000
public water systems nationally are subject to these requirements and have already
reported data to the States and EPA.
The guidance itself is' intended to simplify and reduce reporting and data
management costs to both States and EPA by providing a standardized set of data
elements and a consistent data format. Although not essential to the mechanics of data
management, the guidance also contains information on the use of waivers by the
States to relieve public water systems that did not detect contaminants in their samples
from repeat sampling for the same contaminants. This aspect of the reporting guidance
derives from EPA regulations and discussions in the preambles of regulations related to
unregulated contaminant monitoring.
A draft reporting guidance document was issued for comment in late January of
1993. EPA urged at that time that the guidance be used in the interim to hold to sched
ules already established by EPA and the States for the Phase II and V unregulated
monitoring cycles. A number of States have been using the interim guidance, and data
from several States have been received through the existing automated information
system (FRDS) as requested.
Comments were received oh the draft document from all EPA Regional offices
and 12 States as well. The draft document was also reviewed by the Association of
State Drinking Water Administrators (ASDWA) and a revised version shared with the
ASDWA/EPA Data Management Steering Committee. The comments received were
fully considered in finalizing this document.
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Concurrent with the development of this reporting guidance, EPA has developed
a new automated data management system to replace FRDS named the Safe Drinking
Water Information System (SDWIS). While not scheduled to be fully operational until
January 1995, the new system has been designed to accept the unregulated contami
nant data in the existing FRDS format and provides a simplified data entry capability
which will reduce the data entry burden of the previous system by automating data entry
when a group of contaminants measured by a single analytic method are all below the
method detection limit. This capability of SDWIS to handle unregulated contaminant
data is currently operational in FADS.
SUMMARY OF MAIN PROVISIONS OF REPORTING GUIDANCE
Under current regulations, there are a total of 48 unregulated contaminants for
which a public water system may have to monitor. Twenty non-discretionary from the
Phase I list, 14 at the discretion of the State from the Phase I list, 11 non-discretionary
from the Phase II list and three aldicarbs from 1992 EPA regulatory stay of the
Maximum Contaminant limit for these substances. As discussed in the guidance:
States are advised to consider exercising their waiver authority for second round
monitoring of non-discretionary contaminants from the Phase I list for contami
nants not detected in a public water system’s first round monitoring;
States may defer requiring monitoring for Dicamba from the Phase II list until
December 31, 1995. This would provide States additional time to make waiver
determinations for individual public water systems for this contaminant which can
reduce the monitoring cost to a public water system for the Phase II group by
about one-third;
States are encouraged to waive second round monitoring of contaminants on
Phase I State discretionary list;
States are no longer requested to routinely enter Method Detection Limits for
each individual contaminant. The SDWIS provides an automated group method
which virtually reduces contaminant data entry to only those public water
systems that have positive detects;
the number of data elements to be reported by States to EPA have been reduced
from 25 in the interim-draft guidance to 12 in the final guidance.
The cumulative effect of the above provisions, if properly implemented, will be a
substantial reduction of the cost of monitoring for public water systems, a substantially
reduced data management burden for the States and EPA and higher quality and more
timely availability of results of the unregulated monitoring to the regulatory decision
making process.
For further information call Abe Siegel (202) 260-2804 in EPA Headquarters.
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