Matthew Hartz Laboratory Director PFAS Monitoring in a Post Health Advisory World-What Should We Be Doing? Monrovia South Bend www.eatonanalytical.com Poly- and Perfluoroalkyl Substances (PFASs) Large class (200+) of surfactants with unique chemical properties • • Fluorinated carbon chain with various functional group(s) • Used since 1940s in products that resist heat, stains, water, oil and grease; production increased rapidly in 1970s • Many other specialized industrial and commercial uses (operative word: non-stick) Courtesy of Virginia Yingling (MDH) PFCs vs PFASs – What’s The Difference?  Perfluoro- means “fully” fluorinated • • • • All carbons in the chain bonded only to F “PFCs” actually is correct in this case Example: PFOA, PFOS, PFBA, PFBS, etc. Essentially non-degradable due to strength of C-F bond  Polyfluoro- means “partially fluorinated” • Some carbons in the chain bonded to H • Example: 6:2 FTSA (polyfluorotelomer sulfonate; 6 CF2, 2 CH2) • Susceptible to degradation (biotic and abiotic) due to weakness of CH bond • Some polyfluorinated PFASs may degrade to PFCs • May constitute the majority of PFASs at many sites, but typically not tested for Courtesy of Virginia Yingling (MDH) PFCs Behave in Unique Ways  Do not break down in the environment • No hydrolysis, photolysis, or biodegradation  Do not adsorb readily to aquifer materials • Infiltrate rapidly to the groundwater • Little or no retardation • Rates affected by PFC chain length and functional group partitioning – Carboxylates (PFBA, PFPeA, PFHxA, PFOA) – prefer water – Sulfonates (PFBS, PFHxS, PFOS) – prefer soil and sediment  Chemical structure of some are similar to fatty acids • Readily adsorbed into blood serum of living organisms Courtesy of Virginia Yingling (MDH) Some “Rules of Thumb”  Adsorption: Longer-chain PFCs > shorter-chain PFCs (Ex: PFOS > PFBS)  Solubility: Perfluorinated carboxylates > perfluorinated sulfonates of similar chain length (Ex: PFOA > PFOS)  Environmental fate (generalized): • PFCs with sulfonate group and/or longer chain: • less mobile • partition more into soil and more persistent in the body • PFCs with carboxylate group and/or short chain: • more mobile • partition more into water Courtesy of Virginia Yingling (MDH) PFASs Are Globally Distributed Numerous studies have documented PFOS, PFOA, and other PFASs in wildlife worldwide, including deep sea and arctic species. Human blood samples from US, Europe, and Asia also detected PFCs – especially PFOS, PFOA, PFHxS – concentrations higher in very young and the elderly. Atmospheric and oceanic transport of PFC precursor chemicals are believed to be major mechanisms in the global distribution. Courtesy of Virginia Yingling (MDH) These Compounds Have Been Studied for a Long Time Jahnke A, Berger U; Journal of Chromatography A 1216 (2009) 410-421 7 How Do You Evaluate PFAS Occurrence (e.g. UCMR 3 Data)?  You can focus on exceedances of Health Advisory Levels (HAs).  You can focus on overall frequency of detection by count or PWS because you are dealing with a strictly anthropogenic contaminant and you don’t know when a detection is part of a plume.  You can focus on either only PFOS and PFOA or a broader suite.  And this is to help you make educated decisions about any non-UCMR monitoring and/or treatment. 8 Consider Some of The Monitoring Option Decisions  How many PFAS compounds should you look for?  2 (PFOS/PFOA)?  6 UCMR compounds?  14 that are in EPA 537?  24 that DOD is now targeting? Clearly there are options to consider 9 Consider Some of The Monitoring Option Decisions  How low should you look?  UCMR 3 limits?  Levels that the method can reliably measure?  EPA established a HA for PFOA & PFOS in drinking water at a combined concertation of 70 ppt     NYDEP recommends labs that meet 2 ppt for PFOA VT has established a HA for PFOA in water at 20 ppt NH recommends at least a 5 ppt RL for PFAS NJ recommends at least a 10 ppt RL and a guidance level of 40 ppt for PFOA 10 UCMR 3 Monitoring Significantly Underestimates PFAS Occurrence  UCMR 3 reporting limits were determined based on a simulation from data from multiple labs (see next slide).  Method 537 is capable of reliably measuring:  Levels that are 10-20X lower than UCMR 3  A much longer list of PFAS compounds 11 LCMRLs from Multiple Labs in Initial Method Validation (2008) Note the DL variation is not nearly as great as the LCMRL variation. The large variation in LCMRLs among labs results in a high “national” MRL for UCMR 3 because these data are used for the simulation to determine the national UCMR MRL. The combined PFOS-PFOA UCMR 3 MRL is 60, just below the HA level. 12 How Can We Determine If There Are Significant Underestimates?  EEA accounts for nearly 40% of the UCMR 3 PFAS data.  EEA’s in-house MRLs for the 6 PFAS compounds are significantly lower than the UCMR 3 limits.  We re-examined all of our data, censoring at 5 ng/L for all 6 UCMR 3 PFAS compounds.  We then compared detection frequencies, and states where there is significant detection. 13 How Representative Are Our Data of the Whole NCOD? Factor # of Samples # of PWS % of PWS with UCMR3 detection % of PWS with HA Exceedances # of States/Territories with samples # of states/territories with detection # of states/territories with HA Exceedances Overall UCMR 3 NCOD* EEA UCMR 3 Data (UCMR 3 MRLs) ~36,000 ~4900 ~10,500 ~1800 3.9% 1.3% All 36 24 5.3% 1.8% All 27 18 * April 2016 release 14 UCMR 3 NCOD PFOS-PFOA Hits ?nl lUl'Ul ia Portland 5 33cm 53 rgnm?o a San Jose B?Llrw?lIA nto .35: eurofins lcun Hey NORTH l? [latent-ed balm HIEIL 1? met MINNESOTA Exceeds HM. [mm Magma: lis I sou-m MIUHIGAN IDAHO II . WWMIHG NEW mm: my? ID. ., ?lmed IOWA Ghlcago NEBRASKA Denver . DHIE- NEVADA 0 311311135 {Lty Indiana pdla comm 0 WEST K?Amb'?'h MISSOURI VIRGINIA HEEWCIW VIRGINIA Las'u'egas a 9? DH UMA SSEE t? Em?? ARKANSAS @narlone MEXICO gnu-[H Dallas 9- GEORGIA .E Pam TEXAS BAJA Aus?n LDUISIANA Jacksonville llI Houston I: 53" Tum? New means 9 rlanda LEQH Montana? a BAJA EINALOA .. CALIFORNIA SUE DURANUU Eaton Analytical new - The Bahamas 9? 15 EEA Subset of UCMR 3 NCOD Data . PFOS-PFOA Hits I. vitae? lcun Hey kn? Seattle . NORTH 9 t? Detect-Ed hem-N HAL more mwnusoTA Amend Exceeds HAL Minna Iis I SOUTH WIsconN DAKDTA VERMONT MIGHIGAN IDAHG NEI WYOMING :1 HAP-1P5 IOWA Chig?go NEBRASKA newer INDIANA DHID 9 Unned States I d. d. LFTAH Ens? t? Ianap IS Sacragnento mum?? MISSOURI 53 IIE TUCKY SanJas! CALIFORNIA Lasgegas OKLAHOMA ARKANSAS NW NISSISSI Dallas Tucson F-Pasn TEXAS BAJA BM. FGRHIA Austin Jacksonville 50mm .3- Hnuatm L-CJUFJIANAE CH IH LIA 53? Tim? New Orleans Orlando Tamp?o umAHuuA 9% FInmnA 4 ?in; NUEW LEQN Mongerrey BAJA nlln?ll?? E?Irfr' .35: eurof ins Eaton Analytical 16 The Picture is Not that Different For . Overall UCMR 3 PFAS Occurrence .. Icon Key a 5 Vt?l?lli Same PFBS NORTH DAKOTA . . 9 mourn a, Duehgc Gm; - MINNESOTA . [gangland PFHILS r" Ottawa Montreal MinVERMONT OREGON IDAHQ PFCIA MIGHIGAN anunluo HAMPS Detr :t fcmg??o NEBRASKA Denver . ILLIH a INDIANA DHID manner. 0 United States r: - - City.r Indlanapalla Sacramento UTAH "0mg 5A5 San Fran? a MISSOURI IRGHIIA VIRGINIA San use CAL mama. Laa Veg as Nashville or: HDMA .3 ARKANSAS harlo Lm?rgms ?5 NEW MExrao SOUTH WWI MI GARGLIHA 5a qlego Dallas 1 BAJA CALIFORNIA Austin Jacksonville SDNOPA D. Houston L-CJUFJMNAE GHrHunruKAe?f? 53? 0 New Oieana glanda Ta ao war-rum '31? FE new a NUEW LEQN Monterrey EIAJA SINALUA c' Gurrnf CALIFORNIA sun IAMAULIPAS 9 m? eurofins Eaton Analytical 17 What if we Start Looking at Frequency by State?  We can look at PFOS/PFOA alone.  We can compare the frequency of occurrence in different states.  We can drill down to see how the EEA database compares.  Most significantly, we can see how the pattern changes when we reduce the reporting limit. 18 NCOD - 24 States/Territories with PWS lwith Health Advisory Exceedances PWS Exceeding Health Advisory Levels PWS Created with mapchartmet (E) .35: eurofins Eaton Analytical 19 NCOD - 36 States with PWS Detections of PFOS and/or PFOA at UCMR3 MRLs Plus MP and GU And GU and MP 20 EEA Data - 27 States with PFOS/PFOA Detections based on UCMR 3 MRLs States with stars are in NCOD, but not EEA at UCMR 3 MRLs Plus GU And MP and and MP GU 21 37 States/Territories have PWS with PFOS-PFOA Detects at 5 ng/L MRL DC of PWS with Detects I 40 PWS I 20-39 PWS I 1-9 PWS A. eurofins Eaton Analytical 22 EEA Data - 511 PWS in 40 States/Territories Have at Least 1 Compound at 5 ng/L or More This represents nearly 28% of PWS in our database. Plus GU and MP Plus 3 more states with NCOD detections but insufficient EEA data 23 Frequency of Detection Comparison by # of Samples Compound Official NCOD Database samples with detection (UCMR 3 MRLs) EEA Subset EEA Subset of Samples of Samples with detection with detection using UCMR 3 using 5 ng/L MRLs MRL EEA Subset of Samples with detection using 2.5 ng/L MRL N PFOS ~36,000 0.8% ~10,500 ~10,500 ~10,500 1.3% 11.5% 20.5% PFOA 1.0% 1.8% 12.5% 23.5% PFNA 0.1% 0.1% 0.6% 1.9% PFHxS 0.6% 1.0% 6.0% 12.3% PFHpA 0.6% 1.5% 3.3% 8.8% PFBS <0.1% 0.2% 5.3% 11.9% 24 Washington Co., MN: A PFC Megaplume Investigated Since 2003  Over 100 mi2 contaminated     4 major aquifers 8 municipal systems 140,000+ residents 4,000+ private wells • PFAS detected in 1,200+  Models under-predicted extent  PFBA most widespread  Short-chain carboxylate  Also detect PFOA, PFOS, PFHxS in abundance  And.. PFPeA, PFHxA, PFBS Courtesy of Virginia Yingling (MDH) Biomonitoring – 3M Plume • • • Three rounds: 2008, 2010, 2014 196 initial participants (164 returned) PFCs decreased in blood of people drinking treated water (but ave. concentrations still > national ave.) Concentrations in micrograms PFC in liter blood (ppb) Courtesy of Virginia Yingling (MDH) Conclusions  The UCMR3 database drastically underestimates the occurrence of PFAS compounds in municipal waters because of MRLs that were too high.  The high frequency of 5 ng/L detection of any PFAS compound (28% of tested PWS) suggests that utilities should proactively consider monitoring to check for potential plumes, even if the UCMR3 database showed no detection.  The megaplume in MN shows how complex the problem may be and if you restrict yourself to monitoring PFOS/PFOA you may be short sighted. 27 Acknowledgements Virginia Yingling MN Department of Health Dr. Andrew Eaton Eurofins Eaton Analytical Any Questions? Matthew Hartz MatthewHartz@EurofinsUS.com 574.472.5578 Eurofins Eaton Analytical, Inc. www.eurofinsus.com The Third Unregulated Contaminant Monitoring Rule (UCMR 3): Data Summary, January 2017 EPA uses the Unregulated Contaminant Monitoring Rule (UCMR) program to collect data for contaminants suspected to be present in drinking water, but that do not have health-based standards set under the Safe Drinking Water Act (SDWA). Every five years EPA develops a new list of UCMR contaminants, largely based on the Contaminant Candidate List (CCL). The SDWA Amendments of 1996 provide for:  Monitoring no more than 30 contaminants per 5-year cycle  Monitoring only a representative sample of public water systems (PWSs) serving less than or equal to 10,000 people  Storing analytical results in a National Contaminant Occurrence Database (NCOD) UCMR 3 required monitoring for 30 contaminants (28 chemicals and two viruses) between 2013 and 2015 using analytical methods developed by EPA, consensus organizations or both. This monitoring provides a basis for future regulatory determinations and/or other actions to protect public health. This dataset represents the twelfth and final NCOD release of analytical results for UCMR 3. Additional reference material is available to assist with the assessment of the UCMR 3 data.  EPA’s UCMR 3 website  Instructions for importing and viewing UCMR 3 results  Additional information for the UCMR 3 contaminants on the CCL & Regulatory Determination website UCMR 3 Data Considerations To perform additional data analyses, EPA suggests importing each field into your choice of software as text. Some of the IDs can be misinterpreted as long integer field types when they actually contain alpha characters. Data are presented as tab delimited text files, with field names included in the first row of each file and no text qualifier:  Select “UCMR 3 Occurrence Data” to find the text file containing ALL results to date (UCMR3_All.txt)  Select “UCMR 3 Occurrence Data by State” to find the text files containing ALL results to date for tribes and states AK-LA (UCMR3_All_Tribes_AK_LA.txt) and states MA-WY (UCMR3_All_MA_WY.txt)  Select “UCMR 3 Occurrence Data by Method Classification” to find method-specific text files (UCMR3_MethodNumber.txt, example UCMR3_200_8 for EPA method 200.8)  Text file containing disinfectant residual type (UCMR3_DRT.txt)  Text file containing the U.S. Postal Service zip code(s) for all areas served by a PWS (UCMR3_ZipCodes.txt) Samples collected at the maximum residence time in the distribution system (MR) were required to be analyzed for metals (including chromium-6) and chlorate. PWSs monitoring for Method 300.1 (chlorate) reported disinfectant types. In addition to reporting occurrence data for UCMR 3 target analytes, EPA tasked its small-system contract-support laboratories with reporting results for sec-butylbenzene, n-propylbenzene, tellurium, germanium and manganese. These additional unregulated analytes are within the scope of the methods already being performed for the UCMR analytes. Population categories are based on retail population as indicated by the Safe Drinking Water Information System (Federal) (SDWIS/FED) as of December 31, 2010. Office of Water (MS-140) EPA 815-S-17-001 January 2017 UCMR 3 Data Field Names and Definitions Field Name Definition PWSID Public Water System Identification Code, 9-character identification code (Begins with the standard 2-character postal State abbreviation or Region code, and the remaining seven numbers are unique to each PWS in the state) PWSName Name of the Public Water System (PWS) Size Size category of the PWS for UCMR, based on retail population as of December 31, 2010: S (≤ 10,000), L (> 10,000) FacilityID Public Water System Facility Identification Code, 5-digit identification code FacilityName Name of the facility at the PWS FacilityWaterType Source of water at the facility: SW (surface water), GW (ground water), GU (ground water under the direct influence of surface water), MX (Any combination of: SW, GW and GU) SamplePointID Identification code for each sample point location in the PWS SamplePointName Name of the sample point for every sample point ID at a PWS SamplePointType Sampling Point Type Code: EP (entry point to the distribution system), MR (distribution system at maximum residence time) AssociatedFacilityID The facility ID of the associated MR AssociatedSamplePointID The sample point ID of the associated MR Disinfectant Type CLGA (Gaseous Chlorine), CLOF (Offsite Generated Hypochlorite, stored as liquid), CLON (Onsite Generated Hypochlorite, no storage), CAGC (Chloramine, formed from gaseous chlorine), CAOF (Chloramine, formed from offsite hypochlorite), CAON (Chloramine, formed from onsite hypochlorite), CLDO (Chlorine Dioxide), OZON (Ozone), ULVL (Ultraviolet Light), OTHD (All other types of disinfectant), NODU (No Disinfectant Used) CollectionDate Date of sample collection (month, day, year) SampleID Identification code for each sample, as defined by the laboratory Contaminant Unregulated contaminant being analyzed in UCMR 3 MRL Minimum Reporting Level defined by UCMR 3 in µg/L for the chemicals UCMR 3, January 2017 Page 2 of 12 Field Name Definition MethodID Identification code of the analytical method AnalyticalResultsSign Less than (<) the minimum reporting level (MRL) or equal to (=) a numeric value at or above the MRL AnalyticalResultValue Numeric value of the analytical result in µg/L for the chemicals, null values represent less than MRL SampleEventCode Identification code for each sample event. Includes sample event one (SE1), sample event two (SE2), sample event three (SE3), and sample event four (SE4). MonitoringRequirement AM (Assessment Monitoring, List 1), SS (Screening Survey, List 2), PST (Pre-Screen Testing, List 3) Region EPA Region (States): 1 (CT, ME, MA, NH, RI, VT), 2 (NJ, NY, PR (Puerto Rico), VI (Virgin Islands)), 3 (DE, DC, MD, PA, VA, WV), 4 (AL, FL, GA, KY, MS, NC, SC, TN), 5 (IL, IN, MI, MN, OH, WI), 6 (AR, LA, NM, OK, TX), 7 (IA, KS, MO, NE), 8 (CO, MT, ND, SD, UT, WY), 9 (AZ, CA, HI, NV, AS (American Samoa), GU (Guam), MP (Northern Marianas Islands), NN (Navajo Nation)), 10 (AK, ID, OR, WA) State State abbreviation ZipCode U.S. Postal Service zip code(s) for all areas being served water by a PWS UCMR 3, January 2017 Page 3 of 12 UCMR 3 Chemical Contaminants and Methods Contaminant Contaminant Full Name CAS1 Number Method ID Method Name 1,2,3-trichloropropane 1,3-butadiene Chloromethane 1,1-dichloroethane Bromomethane HCFC-22 Halon 1011 1,4-dioxane Vanadium Molybdenum Cobalt Strontium Chromium Chromium-6 Chlorate PFOS PFOA PFNA PFHxS PFHpA PFBS 17β-estradiol 17α-ethynylestradiol Estriol Equilin Estrone Testosterone 4-androstene-3,17-dione 1,2,3-trichloropropane 1,3-butadiene methyl chloride 1,1-dichloroethane methyl bromide chlorodifluoromethane bromochloromethane 1,4-dioxane vanadium molybdenum cobalt strontium total chromium chromium-6 chlorate perfluorooctanesulfonic acid perfluorooctanoic acid perfluorononanoic acid perfluorohexanesulfonic acid perfluoroheptanoic acid perfluorobutanesulfonic acid estradiol ethinyl estradiol 16-α-hydroxyestradiol equilin estrone testosterone 4-androstene-3,17-dione 96-18-4 106-99-0 74-87-3 75-34-3 74-83-9 75-45-6 74-97-5 123-91-1 7440-62-2 7439-98-7 7440-48-4 7440-24-6 N/A 18540-29-9 14866-68-3 1763-23-1 335-67-1 375-95-1 355-46-4 375-85-9 375-73-5 50-28-2 57-63-6 50-27-1 474-86-2 53-16-7 58-22-0 63-05-8 524.3 524.3 524.3 524.3 524.3 524.3 524.3 522 200.8 200.8 200.8 200.8 200.8 218.7 300.1 537 537 537 537 537 537 539 539 539 539 539 539 539 Volatile Organic Compounds Volatile Organic Compounds Volatile Organic Compounds Volatile Organic Compounds Volatile Organic Compounds Volatile Organic Compounds Volatile Organic Compounds Synthetic Organic Compound Metals Metals Metals Metals Metals Chromium-6 Oxyhalide Anion Perfluorinated Compounds Perfluorinated Compounds Perfluorinated Compounds Perfluorinated Compounds Perfluorinated Compounds Perfluorinated Compounds Hormones Hormones Hormones Hormones Hormones Hormones Hormones 1Chemical Monitoring Requirement AM AM AM AM AM AM AM AM AM AM AM AM AM AM AM AM AM AM AM AM AM SS SS SS SS SS SS SS Abstract Service UCMR 3, January 2017 Page 4 of 12 UCMR 3 Microbiological Contaminants and Methods Contaminant Method ID Method Name Monitoring Requirement Enteroviruses EPA 1615A Enterovirus cell culture PST Enteroviruses EPA 1615B Enterovirus RT-qPCR PST Noroviruses EPA 1615C Norovirus genogroup I with RT-qPCR primer set A PST Noroviruses EPA 1615D Norovirus genogroup I with RT-qPCR primer set B PST Noroviruses EPA 1615E Noroviruses genogroup II PST Total coliforms SM 9223B Colilert® PST E.coli SM 9223B Colilert® PST Enterococci ASTM D6503-99 Enterolert® PST Aerobic spores SM 9218 Aerobic endospores PST Somatic phage EPA 1602 Bacteriophage PST Male specific phage EPA 1602 Bacteriophage PST UCMR 3, January 2017 Page 5 of 12 UCMR 3 Reference Concentrations for Chemical Contaminants For the third Unregulated Contaminant Monitoring Rule (UCMR 3) chemicals were being studied at levels that were often significantly below those in prior UCMR cycles. Importantly, UCMR 3 minimum reporting levels (MRLs) were established based on the capability of the analytical method, not based on a level established as “significant” or “harmful.” In fact, the UCMR 3 MRLs are often below current “health reference levels” (to the extent that HRLs have been established). Results of UCMR 3 measurements should be interpreted accordingly. The detection of a UCMR 3 contaminant above the MRL does not represent cause for concern, in and of itself. Rather, the implications of the detection should be judged considering health effects information (which is often still under development or being refined for unregulated contaminants). The intent of the following table is to identify draft UCMR reference concentrations, where possible, to provide context around the detection of a particular UCMR contaminant above the MRL. The draft reference concentration does not represent an “action level” (EPA requires no particular action 1,2 based simply on the fact that UCMR monitoring results exceed draft reference concentrations), nor should the draft reference concentration be interpreted as any indication of an Agency intent to establish a future drinking water regulation for the contaminant at this or any other level. Decisions as to whether or not to regulate the contaminant in drinking water will continue to be made following the Agency’s Regulatory Determination process. Visit EPA’s Regulatory Determination website for more information. The following key principles guided the development of the table: (1) The reference concentrations are based on publically-available health information found in the following EPA resources: 2012 Drinking Water Standards and Health Advisories, the CCL 4 Contaminant Information Sheets, the Human Health Benchmark for Pesticides (HHBPs), the Integrated Information Risk System (IRIS), or the 2014 Preliminary Regulatory Determinations for Contaminants on CCL 3. The primary/secondary sources of health information vary with respect to scientific rigor from health assessment to single studies and are cited in the table. (2) If health information was available from more than one of the EPA resources listed above, the most recent health information was used for the draft reference concentrations. (3) Where both cancer and non-cancer draft reference concentrations existed, the lower (more conservative) of the two concentrations was used. For chemicals with reference concentrations based on a cancer endpoint, the table presents a range of values associated with 10-6 to 10-4 cancer risk. For chemicals with reference concentrations based on a non-cancer endpoint, the duration of exposure (short-term, intermediate/long-term, chronic) of the toxicity factor (e.g., Reference Dose) used as the basis for the reference concentration is shown. Recognizing that additional health effects information will become available over time, those attempting to assess UCMR occurrence data are encouraged to visit EPA’s Drinking Water Contaminant Human Health Effects Information website for the most recent information. 1 Consumer Confidence Report (CCR) and Public Notification (PN) reporting requirements (see 40 CFR 141.153(d) and 141.207, respectively) apply to PWSs; CCR requires particular reporting based on measurements relative to the UCMR method reporting limits (MRLs) defined in 40 CFR 141.40. 2States may establish requirements for drinking water contaminants not yet regulated by EPA, and those requirements may be based on stateestablished levels that differ from EPA’s reference concentrations. PWSs are responsible for being aware of and complying with their state’s requirements, if any. UCMR 3, January 2017 Page 6 of 12 MRL (µg/L) Reference Concentration (µg/L) Cobalt 1 70 Molybdenum1 1 40 Strontium2 0.3 1,500 Vanadium3 0.2 21 Chromium (Total) 0.2 100 Chromium-64 0.03 NA 20 210 1,4-dioxane5 0.07 1,1-dichloroethane5 1,2,3-trichloropropane5,6,7 Contaminant Chlorate Reference Concentration based on a Cancer Endpoint (Y/N) N (intermediate exposure) N (chronic exposure) N (chronic exposure) N (intermediate exposure) N (chronic exposure) - EPA Reference(s) CCL 4 Contaminant Information Sheets 2012 Edition of the Health Advisories Table Federal Register Notice for the Preliminary Regulatory Determinations for Contaminants on CCL 3 CCL 4 Contaminant Information Sheets The MCL for the National Primary Drinking Water Regulation - 0.35 to 35 N (chronic exposure) Y CCL 4 Contaminant Information Sheets 2012 Edition of the Health Advisories Table 0.03 6.14 to 614 Y CCL 4 Contaminant Information Sheets 0.03 0.0004 to 0.04 Y 2009 IRIS Assessment 1 The 2012 Edition of the Health Advisories Table and the CCL 4 Contaminant Information Sheets (35 µg/L) have slightly different numbers due to rounding. The reference concentration is based on the HRL cited in the preliminary regulatory determination for strontium [Docket No. EPA-HQ-OW-2012-0155]. 3 The ATSDR, 1992 used for the CCL 4 Contaminant Information Sheets is no longer publically available and has been replaced by a new assessment (ATSDR, 2012). The minimum risk level (RfD equivalent) was 0.003 mg/kg/day for minor renal effects in an animal study (ATSDR, 1992) compared to 0.01 mg/kg/day for lack of minor effects in blood pressure, body weight, and hematological parameters in a human study with a 12 week exposure (ATSDR, 2012). 4 The contaminant is on the IRIS Agenda for either a new assessment or an updated assessment; check status here. 5 Reference Concentration range based on cancer risk of 10-6 to 10-4. 6 10-6 cancer risk < MRL < 10-4 cancer risk. 7 To derive the reference concentration, age dependent adjustment factors were applied to the IRIS oral slope factor of 30 per mg/kg-day (calculated using adult exposure data) to address presumed early-life susceptibility for this chemical (per EPA’s Guidelines for Carcinogen Risk Assessment). 2 UCMR 3, January 2017 Page 7 of 12 MRL (µg/L) Reference Concentration (µg/L) 1,3-butadiene5,6 0.1 0.0103 to 1.03 Reference Concentration based on a Cancer Endpoint (Y/N) Y HCFC-22 (chlorodifluoromethane) 8 Chloromethane (methyl chloride)5 Halon 1011 (bromochloromethane)9 Bromomethane (methyl bromide) PFBS 0.08 NA - - 0.2 2.69 to 269 Y CCL 4 Contaminant Information Sheets 0.06 90 2012 Edition of the Health Advisories Table 0.2 140 Human Health Benchmark for Pesticides (HHBPs) 0.09 NA N (chronic exposure) N (chronic exposure) - PFHpA 0.01 NA - - PFHxS 0.03 NA - - PFNA 0.02 NA - - PFOS 0.04 0.07 N (chronic exposure) Health Advisory and Supporting Documentation for PFOS PFOA 0.02 0.07 N (chronic exposure) Health Advisory and Supporting Documentation for PFOA 0.0009 0.035 CCL 4 Contaminant Information Sheets 0.0004 0.0009 to 0.09 N (chronic exposure) Y Contaminant 17α-ethynylestradiol (ethinyl estradiol) 17β-estradiol (estradiol)5 8 9 EPA Reference(s) CCL 4 Contaminant Information Sheets - CCL 4 Contaminant Information Sheets The CCL 4 Contaminant Information Sheets provide a reference level of 31.5 µg/L; the number is based on a single LOAEL from a 1983 study. The 2012 Edition of the Health Advisories Table and the CCL 4 Contaminant Information Sheets (70 µg/L) have slightly different numbers due to rounding. UCMR 3, January 2017 Page 8 of 12 Contaminant MRL (µg/L) Reference Concentration (µg/L) Equilin 0.004 0.35 Estriol (16-α-hydroxyestradiol) Estrone 0.0008 0.35 0.002 0.35 4-androstene-3,17-dione 0.0003 NA Reference Concentration based on a Cancer Endpoint (Y/N) N (chronic exposure) N (chronic exposure) N (chronic exposure) - Testosterone 0.0001 NA - UCMR 3, January 2017 EPA Reference(s) CCL 4 Contaminant Information Sheets CCL 4 Contaminant Information Sheets CCL 4 Contaminant Information Sheets - Page 9 of 12 Terms a) UCMR Draft Reference Concentration = The reference concentrations are based on publically-available health information found in the following EPA resources: 2012 Drinking Water Standards and Health Advisories (HAs), the CCL 4 Contaminant Information Sheets (i.e., HRLs), the Human Health Benchmark for Pesticides (HHBPs), or the 2014 Preliminary Regulatory Determinations for Contaminants on CCL 3 (i.e., HRLs). The primary/secondary sources of health information vary with respect to scientific rigor from health assessment to single studies. Many of the contaminants are currently under regulatory review or development and are subject to change as new health assessments are completed. b) MRL = UCMR Minimum Reporting Level. [Note that the Agency for Toxic Substances & Disease Registry (ATSDR) uses the term “MRL” for a different purpose (i.e., to describe “Minimal Risk Levels”). The UCMR term and the ATSDR term have no relationship to each other.] c) HAs = Health advisories. HAs provide information on contaminants that can cause human health effects and are known or anticipated to occur in drinking water. EPA's health advisories are non-enforceable and non-regulatory and provide technical information to state agencies and other public health officials on health effects, analytical methodologies, and treatment technologies to assist with risk management decisions. d) HRLs = Health Reference Levels. The CCL process derives HRLs using single studies to health assessments for screening purposes. The CCL HRLs derived from health assessments are used in the Regulatory Determination process as risk-derived concentrations against which to evaluate the occurrence data to determine if contaminants may occur at levels of public health concern. HRLs are not final determinations about the level of a contaminant in drinking water that is necessary to protect any particular population and are derived prior to development of a complete exposure assessment. e) MCL = Maximum Contaminant Level. The highest level of a contaminant allowed in drinking water. MCLs are enforceable standards. f) Cancer Risk of 10-6 to 10-4 = the concentration of a contaminant in drinking water corresponding to an excess estimated lifetime cancer risk of one-in-a-million (1x 10-6) to one-in-ten-thousand (1 x 10-4). The 2012 Drinking Water Standards and Health Advisories provide the cancer risk at 1 x 10-4. The CCL 4 Contaminant Information Sheets provide the cancer risk at 1x 10-6. g) LOAEL = Lowest Observed Adverse Effect Level h) NA = Not Available i) Short-term = Typically refers to animal toxicological studies with an exposure duration of days to weeks. j) Intermediate/Longer-term = Typically refers to animal toxicological studies with an exposure duration of weeks to months. k) Chronic = Typically refers to animal toxicological studies with an exposure duration of months to years; representing a lifetime exposure in humans. References 2012 Drinking Water Standards and Health Advisories (https://www.epa.gov/dwstandardsregulations/drinking-water-contaminant-human-health-effects-information) CCL 4 Contaminant Information Sheets (https://www.epa.gov/sites/production/files/2016-11/documents/815r16003.pdf) Human Health Benchmark for Pesticides (HHBPs) (https://ofmpub.epa.gov/apex/pesticides/f?p=109:3) Announcement of Preliminary Regulatory Determinations for Contaminants on the Third Drinking Water Contaminant Candidate List (https://www.epa.gov/ccl/regulatorydetermination-3) Integrated Risk Information System (IRIS) (http://cfpub.epa.gov/ncea/iris2/atoz.cfm) UCMR 3, January 2017 Page 10 of 12 January 2017 UCMR 3 Data Summary for Chemical Contaminants 4,916 Number of PWSs with results ≥MRL 67 Number of PWSs with results >Reference Concentration 67 / 551 0.005% / 0%1 4,916 2 2 / 01 0.04% / 0%1 20 / 01 0.05% / 0%1 4,916 138 8 / 01 0.2% / 0%1 835 1 / 01 0.003% / 0%1 4,916 244 1 / 01 0.02% / 0%1 36,848 115 0 0% 4,916 49 0 0% 36,847 827 -- -- 4,916 286 -- -- 36,847 655 0 4,916 309 0 Reference Concentration (µg/L) Total number of results Number of results ≥MRL Number of results >Reference Concentration % of total results >Reference Concentration Total number of PWSs with results 0.03 0.0004 / 0.041 36,848 256 256 / 1971 0.7% / 0.5%1 1,3-butadiene 0.1 0.0103 / 1.031 36,848 2 2 / 01 Chloromethane 0.2 2.69 / 2691 36,845 283 0.03 6.14 / 6141 36,848 0.2 140 HCFC-22 0.08 NA Halon 1011 0.06 90 Contaminant 1,2,3-trichloropropane 1,1-dichloroethane Bromomethane 1,4-dioxane Vanadium Molybdenum Cobalt MRL (µg/L) 0.07 0.35 / 351 0% 36,810 4,197 1,081 / 01 2.9% / 0%1 % of PWSs with results >Reference Concentration 1.4% / 1.1%1 0% 4,915 1,077 341/ 01 6.9% / 0%1 0.2 21 62,981 37,954 1,680 2.7% 4,922 3,625 163 3.3% 1 40 62,986 25,377 151 0.2% 4,922 2,546 40 0.8% 1 70 62,982 833 3 0.005% 4,922 247 3 0.06% Strontium 0.3 1,500 62,913 62,799 1,739 2.8% 4,922 4,922 286 5.8% Chromium 0.2 100 62,917 31,773 1 0.002% 4,922 3,660 1 0.02% 0.03 NA 62,837 47,503 -- -- 4,919 4,401 -- -- 20 210 62,859 34,426 9,796 15.6% 4,918 3,391 1,896 38.6% PFOS 0.04 0.07 36,972 292 124 0.3% 4,920 95 46 0.9% PFOA 0.02 0.07 36,972 379 32 0.09% 4,920 117 13 0.3% PFNA 0.02 NA 36,972 19 -- -- 4,920 14 -- -- PFHxS 0.03 NA 36,971 207 -- -- 4,920 55 -- -- PFHpA 0.01 NA 36,972 236 -- -- 4,920 86 -- -- PFBS 0.09 NA 36,972 19 -- 4,920 8 -- Chromium-6 Chlorate 17β-estradiol 0.0004 0.0009 / 17α-ethynylestradiol 0.0009 Estriol Equilin Estrone 0.091 11,795 4 1/ 0.035 11,796 4 0 0.0008 0.35 11,796 4 0.004 0.35 11,796 0 0.002 0.35 11,796 Testosterone 0.0001 NA 4-androstene-3,17-dione 0.0003 NA -01 0.008% / 0%1 -01 0.08% / 0%1 1,201 2 1/ 0% 1,201 4 0 0% 0 0% 1,201 4 0 0% 0 0% 1,201 0 0 0% 0 0 0% 1,201 0 0 0% 11,795 72 -- -- 1,201 65 -- -- 11,796 101 -- -- 1,201 77 -- -- 1Where two reference concentrations are listed, the first number is associated with a 10-6 cancer risk; the second number a 10-4 cancer risk. Where two results are presented the first number is associated with the first reference concentration; the second number is associated with the second reference concentration. UCMR 3, January 2017 Page 11 of 12 January 2017 UCMR 3 Data Summary for Microbiological Contaminants Number of results ≥MRL Total number of PWSs with results Number of PWSs with results ≥MRL Contaminant MRL Unit Total number of results Aerobic spores 1 SFO1/100 mL2 1,047 317 793 252 E. coli 1 MPN3/100 mL 1,045 3 791 3 Enterococci 1 MPN/100 mL 1,044 41 792 41 Enteroviruses (cell culture) 0.002 MPN/L4 1,044 2 789 2 Enteroviruses (RT-qPCR5) 0.398 GC6/L 1,044 6 789 6 Male specific phage 1 PFU7/100 mL 1,029 14 783 14 Noroviruses GIA8 0.398 GC/L 1,044 4 789 4 Noroviruses GIB9 0.398 GC/L 1,044 2 789 2 Noroviruses GII10 0.398 GC/L 1,044 4 789 4 Somatic phage 1 PFU/100 mL 1,029 5 783 5 Total coliforms 1 MPN/100 mL 1,045 57 791 53 1SFO 6GC 2mL 7PFU = Spore Forming Units = milliliters 3MPN = Most Probable Number 4L = liters 5RT-qPCR = Reverse Transcription-Polymerase Chain Reaction = Genomic Copies = Plaque Forming Units 8Noroviruses GIA = qPCR analysis of Norovirus genogroup I with RT-qPCR primer set A 9Noroviruses GIB = qPCR analysis of Norovirus genogroup I with RT-qPCR primer set B 10Noroviruses GII = qPCR analysis of Norovirus genogroup II UCMR 3 Minimum Reporting Levels for Microbiological Contaminants Under UCMR 3 microbe analytical results are reported as “below”, “at” or “above” MRL. UCMR 3 MRLs were established based on the capability of the analytical method. It is important to note that microbial contamination can be transient in nature and microbial detections under UCMR 3 should be interpreted in the context of the time samples were collected. However, the presence of any UCMR 3 microbe indicates a potential vulnerability of the PWS to contamination. UCMR 3, January 2017 Page 12 of 12 Questions asked by this news organization, answers provided by EPA. 1. Has EPA staff conducted any significant analyses on the occurrence of PFAS compounds in public water systems below the MRL levels used in the UCMR3 program? Additionally, has it done any reexamination of UCMR3 data looking below the previously-used MRL levels (20 ng/l PFOA, 40 ng/l PFOS?) EPA has not collected PFAS occurrence data at levels below the Unregulated Contaminant Monitoring Rule (UCMR 3) maximum residue levels (MRLs). Under UCMR 3, laboratories only reported results at or above the MRL. 2. Is EPA staff familiar with the attached report from Eurofins Eaton Analytical? Either way, how does EPA respond to the report's statement that "The UCMR3 database drastically underestimates the occurrence of PFAS compounds in municipal waters because of MRLs that were too high" and does EPA agree or disagree that "The high frequency of 5 ng/L detection of any PFAS compound (28% of tested PWS) suggests that utilities should proactively consider monitoring to check for potential plumes, even if the UCMR3 database showed no detection?" EPA is aware that some laboratories are able to achieve reporting limits lower than those established for UCMR 3. However, UCMR 3 MRLs were established so that a national array of laboratories could meet them and were based on looking at the capability of multiple commercial laboratories. 3. In my understanding, the UCMR program is to help the EPA decide which chemicals require regulation. Where is the EPA in the regulatory determination process for UCMR3 chemicals, and if decisions have been made, were PFOS and PFOA included or excluded from a list of "to-be" regulated chemicals? EPA is currently conducting the scientific data collection and analysis called for under the Safe Drinking Water Act to evaluate PFOA and PFOS. EPA will consider occurrence data along with health effects information to determine whether or not to initiate the process to develop a National Primary Drinking Water Regulation (NPDWR) under Regulatory Determination 4. The agency expects to publish the fourth Regulatory Determination (RD4) in 2021.