AMWA’s May 2 comment letter to EPA on its proposed Unregulated Contaminant Monitoring Rule (UCMR 3) responded to 16 specific issues and requests for comment. AMWA’s letter generally supports EPA’s proposed list of contaminants, but made several recommendations
regarding analytical methods, revised data elements and EPA’s proposed use of specific data elements for additional occurrence and exposure analyses.
AMWA’s letter also recommends that EPA include hexavalent chromium (Cr-VI) in UCMR 3 “if the agency can clearly state that Cr-VI poses a significant public health risk at the low levels likely to be found in finished drinking water.” The letter says that including Cr-VI in UCMR 3 will result in a reliable, nationally consistent dataset not currently available, and the data obtained from the UCMR monitoring would help inform EPA’s decision about “whether to regulate Cr-VI on its own, rather than as total chromium.”
The letter also urges EPA not to use sample point zip codes for determining population served at a utility, noting that it is an inaccurate approximation of the population served. Finally, the letter makes several other recommendations about the data elements to be reported under the rule as well as the analytical methods and method reporting levels to be used.
AMWA’s letter is online.