DRIPS & DROPLETS
www.ca-nv-awwa.org 13
Regulatory Update—
What to Expect in 2017 and Beyond
By Rick Zimmer
AS 2016 WOUND DOWN, the California Division of Drinking
Water (DDW) was busy finalizing several key initiatives we
have previously reported on. The following is an update.
SSS 1,2,3-Trichloropropane
ONCE THE PROPOSED MCL for 1,2,3-Trichloropropane
(TCP) is published, the official 45-day comment period
begins. State Water Resources Control Board (SWRCB) approval
is expected in March of 2017, which would mean a July 1, 2017
effective date. DDW has made a preliminary recommendation
for an MCL at the five points per trillion detection limit for
reporting (DLR).
SSSS Lead in California Schools
DDW IS COLLABORATING with the California Department of
Education on a statewide program to address lead in California
schools, based on USEPA’s recently released Lead and Copper Rule
Revisions White Paper and the 3 Ts—Training, Testing and Telling.
DDW’s goal for the end of 2016 was to contact water systems about
the program, which requires water agencies to provide free sam-pling
and technical assistance to schools in their service areas. DDW
is basing its authority to implement this new program on the gener-al
authority to revise permits “whenever it is deemed necessary for
the protection of public health” (Health & Safety Code section 11625
part C). California Senate Bill 1398, which would require water sys-tems
to inventory their delivery infrastructure to identify any lead
service lines, also remains an active legislation.
SSSS ELAP Quality Standards
IN NOVEMBER 2016, SWRCB’s Environmental Laboratory
Technical Advisory Committee (ELTAC) met to discuss op-tions
(remove, revise delay) in adopting a California version
of the NELAC Institute (TNI) 2016 standard. The California
version of TNI 2016 is considering two criteria: 1) degree of
implementation difficulty to the analyzing lab, and 2) the val-ue
to the regulatory agency recipient of the data it receives
from an accredited lab. In addition to the new quality stan-dard,
ELAP and ELTAC are also considering a revision to the
fee structure for laboratory accreditation. Both are expected to
be adopted and phased in within the next three years and will
be the basis for accreditation for both municipal and commer-cial
laboratories in California.
SSSS Unregulated Contaminants Rule 4 (UCMR4)
USEPA IS ON SCHEDULE to release the final version of
its UCMR4. The draft rule, published in December 2015,
required all large water systems to collect source, entry
point, and distribution system samples for 36 chemical and
microbiological constituents including metals, pesticides,
alcohols, semi-volatiles, brominated HAAs and algal toxins.
Monitoring starts in January of 2018.
UCMR4 laboratory approval applications were submitted
starting July 2016 and the first Proficiency Evaluation sample for
applying laboratories was expected to be received at the end of
December 2016.
SSSS Contaminant Candidate List 4 (CCL4)
USEPA ANNOUNCED THE FINAL CCL4 on November
17, 2016. The final CCL list includes 97 chemicals and 12
microbials. Only disulfoton, fenamiphos, and molinate were
dropped from the draft list.
SSSS Perfluorochemicals (PFCs) and
Perfluoroalkyl Substances (PFAS)
EARLIER THIS YEAR, USEPA PUBLISHED 0.07 ppb health
advisories (HAs) for perfluorooctanoic acid (PFOA)
and perfluorooctyl sulfonate (PFOS) individually or in
combination. Both PFOA and PFOS were included in the
UCMR3, where only two percent of systems had detections.
However, based on requests from USEPA and states for water
systems to conduct post-UCMR3 monitoring, many affected
water systems are now being asked to evaluate PFCs in water
sources and if detected to develop a mitigation plan that can
include shutting down an affected source and/or establishing
treatment to remove the contaminant. Related to the HAs,
USEPA has also issued a technical advisory of potential PFOA
under-reporting when using the approved PFCs analytical
method (EPA537) unless branched isomers are identified in
addition to linear isomers. For more on PFOA and PFOS Health
Advisories, see Alan Roberson’s article in Fall 2016 SOURCE.
SSSS Nevada
ACCORDING TO NEW DRINKING WATER BUREAU CHIEF
My-Linh Nguyen at the Nevada Divison of Environmental
Protection, state regulators are at work helping small systems
with arsenic compliance and evaluating implications of
the USEPA’s new guidance on the Lead and Copper Rule in
the state. S
Rick Zimmer is a Senior Account Manager at Eurofins Eaton Analytical,
Inc. where he manages projects in California, Hawaii and elsewhere. He is
chair of CA-NV AWWA’s Safe Drinking Water Committee and Regulatory
Committee Chair for the Sacramento Area Water Works Association.
/www.ca-nv-awwa.org
