40 SOURCE winter 2017
Fourth Unregulated Contaminant Moni-toring
Rule (UCMR4) this winter (2017).
The UCMR4 proposal listed 11 analyt-ical
methods for 30 chemical contami-nants/
groups including 10 cyanotoxins/
groups; two metals; eight pesticides plus
one pesticide manufacturing by-product;
three brominated haloacetic acid groups
of disinfection by-products (DBPs); three
alcohols; and three semi-volatile organic
chemicals. The final UCMR4 will almost
certainly include most if not all of the
contaminants proposed, particularly cy-anotoxins,
disinfection byproducts, and
manganese. In 2017, utilities will need to
prepare for monitoring that is to begin
in 2018. It’s important to note that the
UCMR3 process illustrated the impor-tance
of communicating proactively and
clearly about observed values in UCMR
monitoring.
Risk Management Plans
In March 2016, USEPA proposed revis-ing
Clean Air Act requirements for risk
management plans, which would sub-stantially
impact facilities across the water
sector. The proposal included extensive
requirements for third-party audits, in-formation
disclosure with security impli-cations,
potential requirements for evalu-ation
of safer alternatives, and expanding
oversight of facility processes and coor-dination
with local emergency planning
committees. The agency’s Office of Land
and Emergency Management (OLEM)
was set to finalize this rule in the closing
days of the Obama administration. If it’s
finalized as proposed, there is a high likeli-hood
that elements of the rule will be chal-lenged
in court.
The USEPA’s actions were prompted
by a 2013 fertilizer explosion in western
Texas, and the Risk Management Plan
proposal reflects a continuing interest in
advancing inherently safer technology
and minimizing off-site consequences
from industrial release. In the case of the
water sector, the primary focus is on treat-ment
chemicals such as chlorine and am-
MANAGER’S CORNER
AWWA Water Matters!
Fly-In
ONE OF THE MOST PRODUCTIVE
opportunities for individual mem-ber
involvement in AWWA comes
through the annual Water Matters!
Fly-In, which is held every spring in
Washington, D.C. Section leader-ship
appoints delegates from each
state to travel to the nation’s cap-ital
and speak directly about the
water sector’s concerns and fed-eral
policy. The California-Nevada
Section always sends a strong and
influential group, given that a large
number of members of Congress
are from California and Nevada
and often hold positions of con-gressional
leadership. The next
Fly-in will be March 22-23, 2017.
For information, contact Tommy
Holmes, tholmes@awwa.org.