EPA  570-9-89-001
                   Lead In School's
                   Drinking  Water
                    Prepared by
                    The Office of
                    Drinking Water
                    Office of Water
                    United States Environmental Protection Agency
                    January 1989
                   This booklet has been reviewed by representatives of:
                   American Water Works Association
                   Association of State Drinking Water Administrators
                   Association of Metropolitan Water Agencies
                   Conservation Law Foundation of New England
                   National Parent Teachers Association
                   National Education Association
                   National School Boards Association
                   Council For American Private Education
                   Special thanks to Peter Lassovszky, EPA, and Michael Wojton, Maryland Department of Environment.


                   The mention of any brand names or products does not
                   constitute endorsement by EPA.

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 CONTENTS

Statement of Purpose                                                   1
Why Lead is a Problem for Children                                       2
Lead in School Drinking Water: A Special Concern                          3
The Safe Drinking Water Act                                             4
How Lead Gets Into Your Water                                          8
When to Expect Lead Contamination                                     10
Developing a Plumbing Profile of Your School                              11
What Your Answers Mean                                              13
Getting Your School's Water Tested                                      17
When the Test Results Come In                                         19
Other Steps You Can Take                                              20
Flushing                                                             21
Permanent Solutions                                                  23
Sampling Protocol - Introduction                                        26
Sampling: A Two-Step Process                                         29
General Sampling Procedures                                           30
How to Begin, Sampling Service Connections                             31
Initial Screening Samples                                               33
Follow-Up Samples                                                   37
Sampling Interior Plumbing                                             45
Glossary                                                            49
Appendix, Preservation of Samples and Sample Containers                  50
Charts and Diagrams                                                  51

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LEAD IN SCHOOL DRINKING WATER
                          STATEMENT OF PURPOSE
                              The purpose of this manual, Lead in School Drinking Water, is to assist
                          you, the school official, in the following four ways:

                                 1.  by providing general information on the significance of lead in school
                                        drinking water and specifically its effects on children;

                                 2.  by providing information on how to detect the presence of lead in your
                                        schools' water and how to pinpoint its source;

                                 3.  by providing advice on the steps you can take to reduce or eliminate
                                        lead in your schools' drinking water; and

                                 4.  by providing the information necessary to train your personnel in
                                        sampling and remedial programs.
                              The school official responsible for testing for and remedying lead in drinking
                          water will vary by location.  Examples include: superintendents of schools,
                          principals, heads of buildings and grounds or facilities departments, science
                          department chairpersons, or those hired by the school (district) for this purpose.


                              Lead in drinking water is a complex issue. It is our hope that this manual
                          will also assist you in responding to local concerns  about your schools' drinking
                          water and in preparing informational materials (such as bulletins and handouts)
                          for your community.

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                          WHY LEAD IS A PROBLEM FOR CHILDREN
WHY LEAD IS A PROBLEM FOR CHILDREN
    Children in your school may be drinking water with high concentrations of
lead.

    Medical research shows lead to be a toxic metal which can be harmful to
human health even at low exposure levels.  Young children, infants, and fetuses
are particularly vulnerable to lead because the physical and behavioral effects of
lead occur at lower exposure levels in children than in adults. A dose of lead that
would have little effect on an adult can have a big effect on a child. In fact,
overexposure to lead can permanently impair a child's mental and physical
development.  Comparatively low levels of exposure have been linked to damage
to the central and peripheral nervous system, learning disabilities, shorter stature,
impaired hearing, and impaired formation and function of blood cells.

    Many children with lead poisoning have no symptoms; others have only non-
specific  symptoms such as headache, stomach-ache, or irritability. At its worst,
lead poisoning can result in stupor, coma, kidney damage, or severe brain
damage.

    The degree of harm depends upon the total exposure to lead from all sources.
In recent years, government initiatives such as federal controls on lead in gasoline
have significantly reduced our overall exposure to lead. However, children as
well as adults are still exposed to lead from a number of sources - air, soil, dust,
food (which may contain lead absorbed from air or food containers), and water.
Lead in drinking water can be a significant contributor to overall exposure to
lead, particularly for infants whose diet consists of liquids made with water, such
as baby food formula.

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LEAD IN SCHOOL DRINKING WATER
                         LEAD IN SCHOOL DRINKING WATER

                         A SPECIAL CONCERN

                             Lead levels in school drinking water merit special concern for several
                         reasons.
                             Children are more at risk than adults from exposure to lead. Not
                         only are children particularly susceptible to the toxic effects of lead, but their
                         cumulative exposure to lead from various sources is likely to be greater. This is
                         partly because play activities may bring children into contact with many potential
                         sources of lead contamination such as dirt or soil.  In addition, growing children
                         tend to absorb more of the lead they consume than adults.
                             The "on-again, off-again" water use patterns of most schools
                         can result in elevated lead concentrations -particularly when school
                         resumes after vacations or weekends. Water that remains stagnant in interior
                         plumbing during a weekend or vacation, or even from the close of one school day
                         to the opening of the next, is in longer contact with lead solder or pipes and thus
                         may contain higher levels of lead. For this reason, a school's water system
                         should be thoroughly flushed before it is used by the children returning from
                         vacation or after the weekend. (A discussion of flushing begins on page 21.)
                             The only way to be sure of the amount of lead in the drinking
                         water supply at your school is to have the water tested by a
                         competent state-certified laboratory using EPA-approved methods.
                         Contact your state department of health or environment for a list of certified
                         laboratories in your area.

                             Before making specific arrangements to have your schools' drinking water
                         tested, you should develop a profile of its plumbing and potential for lead
                         contamination.  The questionnaire on page 11 will help you determine whether
                         lead may be a problem in your school's water.  A copy should be completed for
                         each school within your district.

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                                                             THE SAFE DRINKING WATER ACT
SDWA
and the
public water
supplier
The Lead
Contamination
Control Act of
1988
THE SAFE DRINKING WATER ACT

    The Safe Drinking Water Act (SDWA) of 1974 requires the U.S.
Environmental Protection Agency (EPA) to set drinking water standards to
protect the public health. Major amendments to this law, passed in 1986, banned
the use of lead materials in new plumbing and in plumbing repairs, and required
water suppliers to notify the public about lead in drinking water. In August,
1988, EPA proposed new regulations to reduce even further concentrations of
lead in drinking water. These proposed regulations, to be finalized in 1989,
combine Maximum Contaminant Level (MCL) and corrosion control treatment
requirements to achieve this reduction.

    On November 1,1988, a major new amendment to SDWA, known as the
Lead Contamination Control Act of 1988, became law. This amendment requires
the EPA to provide guidance to states and localities to test for and remedy lead
contamination in drinking water in schools and day care centers. It also contains
specific requirements for the testing, recall, repair and/or replacement of water
coolers with lead lined storage tanks or with parts containing lead and attaches
civil and criminal penalties for the manufacture and sale of water coolers
containing lead.  In addition, the new law authorizes grants to states to support
state and local activities in this area.
Revised federal
standard for
lead in drinking
water —
5ppb
PROPOSED REGULATIONS

    Standards to Limit Lead in Water Delivered by the Water Supplier

    It is important to remember that only public water suppliers are regulated
under SDWA. A public water supplier is defined as an organization or individual
that supplies drinking water to 25 or more people or through at least 15 service
connections. Schools which own their water supply are considered public
water suppliers and are subject to the provisions of this law.

    The Maximum Contaminant Level (MCL) is the maximum level of a
contaminant permitted in water delivered to a user by a public water system.
Under the proposed new regulations, drinking water delivered by a public water
system must have lead levels equal to or less than 5 parts per billion (ppb).  This
level is measured at the point the water enters the supplier's distribution system,
i.e., as it leaves the treatment plant.  If a water system exceeds the MCL for lead,
the supplier will be required to bring the concentration down to acceptable levels
by either installing a best available technology or by taking other steps such as
drilling a new well or blending water from other sources. [Note: ppb is often
expressed as micrograms per liter (ug/1).  One ppb is equal to one microgram per
liter (ug/1) or .001 milligrams per liter (mg/1).]

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LEAD IN SCHOOL DRINKING WATER
Contact your
water supplier
first
State programs
help school officials
test for lead
contamination
Water
suppliers
are required
to test
water
regularly
    Schools which purchase their water should first ask their water
supplier what the lead level of the water is when it leaves the treatment plant. If
the lead level exceeds 5 ppb, discuss with your water supplier what steps it is
taking or will soon undertake to comply with the standards and thereby reduce
lead levels at your taps (see page 4).

    The Lead Contamination Control Act of 1988 requires that States establish
programs to help local educational agencies test for and remedy lead
contamination in drinking water from water coolers and other sources of lead and
authorizes EPA to make grants available to States for this purpose. EPA's goal is
to eliminate or reduce lead in drinking water to the lowest feasible level. For this
reason, EPA recommends that you contact your state department of health or
environment for more information.  EPA recommends that if you suspect lead
may be a problem, you begin testing the drinking  water in your school now and
quickly  take remedial steps whenever the lead level at any drinking water outlet
exceeds 20 ppb.
                               Schools which provide their own water and are therefore
                           considered to be public water suppliers  are subject to specific
                           requirements under the regulations. As a public water supplier, you may be
                           required to reduce lead levels of water entering your distribution system to below
                           5 ppb and institute corrosion control and/or other treatment.  Contact your state
                           department of health or environment or the regional EPA office for further
                           assistance.
Requirements to Minimize Lead Due to Corrosion

    Under the proposed regulations, water suppliers would be required to test
regularly the water they distribute to consumers. This testing is to be done not
only as the water leaves the treatment plant, but also as it emerges from
residential taps.

    If the average amount of lead in samples taken at the tap exceeds 10 ppb, or
if the pH of the water is less than 8.0, the public water supplier would be required
to make the water non-corrosive. This is because lead enters drinking water most
often as a by-product of the corrosion of lead pipes, solder, fixtures, or other
parts of a plumbing system. The public water supplier would also be required to

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                                                                                 THE LEAD BAN
                          Other Requirements (continued)

                          implement a public education program to help consumers reduce lead in drinking
                          water at their taps through measures beyond corrosion control. Many of these
                          measures are discussed later in this manual in the section entitled PERMANENT
                          SOLUTIONS. [Note: pH is a measure of the water's acidity.  The higher the pH,
                          the less acidic (and less corrosive) the water.]

                              Again, EPA recommends that you contact your school's water supplier for
                          information on the quality, testing program, and treatment of your water.  If your
                          school owns its own water supply, you will be responsible for carrying out the
                          provisions of the proposed regulations.
The
"Lead Ban"
Check to see
if your state
has implemented
the 'lead ban'
THE "LEAD BAN" AND NOTIFICATION REQUIREMENTS OF SDWA
AMENDMENTS OF 1986

    The Lead Ban

    The Safe Drinking Water Act Amendments of 1986 require the use of "lead-
free" pipe, solder, and flux in the installation or repair of any public water system,
or any plumbing in a residential or non-residential facility connected to a public
water system. Under these amendments, solders and flux are considered "lead-
free" when they contain not more than 0.2 percent lead. (In the past, solder
normally contained about 50 percent lead.) Pipes and pipe fittings will be
considered "lead-free" when they contain not more than 8.0 percent lead.

    Although states were required to adopt this "lead ban" by June, 1988, you
should check with your state's department of health or the environment to see if
the provisions are in effect. Also, check with plumbers or contractors who are
making additions or repairs to the plumbing to assure that only lead-free materials
are used. Test kits are available which will determine the presence of lead solder
in the plumbing. Any violations of the ban should be reported to state officials.
You should also insist that lead soldered joints in new construction or recent
repairs be replaced with lead-free ones.

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LEAD IN SCHOOL DRINKING WATER
Notification
Requirements
    Notification Requirements under SDWA

    If your school owns its own water supply and the school's
distribution/ plumbing system contains any materials that can be a source of lead
contamination, school officials are required by law to notify the consumers (all
school staff, students, and parents or guardians of all students) regardless of the
lead levels in the drinking water. This notice shall be given to the consumers
either by

    (1) three newspaper notices (one for each of three consecutive months); and

    (2) once by mail notice; or

    (3) once by hand delivery; or

    (4) by continuous posting in a conspicuous place for 3 consecutive months.

    The SDWA deadline for such actions was June 19,1988. Since this
deadline has already passed, notice should be given immediately, if you have
not already done so.

    The notice must contain specific language. For assistance and details,
contact your state department of health or environment.  EPA's Office of Water
has published a Handbook for Special Public Notification for Lead for Public
Drinking Water Suppliers.  Copies are available from EPA Regional Offices, your
state department of health or environment, or the National Technical Information
Service, Springfield, VA 22161.

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                                             HOW LEAD GETS INTO YOUR DRINKING WATER
                         HOW LEAD GETS INTO YOUR WATER

                             Lead gets into drinking water in two ways: by being present at the source or
                         through corrosion of lead parts in a distribution/plumbing system.
Lead in
source
waters
At the Source

    Most sources of drinking water have no lead or very low levels of lead
(under 5 ppb). However, lead occurs naturally in the ground and in a few cases
can get into well water. Lead can enter surface waters through direct or indirect
discharges from industrial or municipal waste water treatment plants or when
lead in air settles into water or onto city streets and eventually (via rain water)
flows into storm sewers. Lead from  these sources is removed easily using
existing treatment plant technology.
Lead as
a by-product
of corrosion
Through Corrosion

    It is more likely that lead has entered your school's water supply
through the corrosion of lead pipes, solder, fixtures, or other parts
of the plumbing system which distributes the water within the
buildings. Experts regard the corrosion of lead solder as the major
cause of lead contamination of drinking water today.

    Corrosion, a reaction between the water and the lead pipes or solder, is
commonly caused by "soft" water (which lathers soap easily) and acidic (low
pH) water. However, all kinds of water may be potentially corrosive to lead, and
thus result in high levels of lead in the water. For this reason, corrosion control is
an important requirement of the EPA's proposed regulations to reduce lead in
drinking water.
8

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LEAD IN SCHOOL DRINKING WATER
Factors
affecting
extent of
lead
contamination
Lead levels
may vary from
outlet to
outlet
FACTORS AFFECTING THE EXTENT OF LEAD CONTAMINATION

    The extent of lead contamination is affected by a number of factors
including:

    • the corrosivity of the water;
    • the amount of lead contained in the plumbing, the faucets, or apparatus
       dispensing the water;
    • the contact time of the water with materials containing lead;
    • whether or not electrical systems are grounded to the water pipes;
    • the age of the plumbing.

    Lead contamination may not occur uniformly throughout a school. Large
variations in lead concentrations may be found among individual outlets in a
school where the sources of contamination differ because of differences in flow
rates and/or building materials.

    Where the source of the contamination is at the beginning of the distribution
system, as with lead service connectors, high lead levels in the drinking water
may be widespread throughout the building. (A service connector is the pipe that
carries water from the public water main to the building.)  High lead levels may
also be found in sections of the distribution system where the water is
infrequently used or where recent repair or installation  of plumbing used lead
solder. (Examples of various plumbing configurations  in buildings are
illustrated in the attached diagrams and are explained  on page 28 of this
manual.)

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                                                   WHEN TO EXPECT LEAD CONTAMINATION
Expect
widespread
contamination
if...
Expect
localized
contamination
if...
WHEN TO EXPECT LEAD CONTAMINATION

    In general, you can expect widespread lead contamination in
your school's drinking water if:

    Q the building's plumbing is less than 5 years old and lead solder was used
      in the construction;
    Q the water is corrosive;
    Q sediment in the plumbing and screens contains lead;
    Q lead pipes are used throughout the building;
    Q the service connector is made of lead.

    In general, you can expect localized contamination if:

    Q the building's plumbing is more than 5 years old;
    Q the water is non-corrosive;
    Q there are pipes or fittings containing lead in some locations;
    Q recent repairs or additions to plumbing used materials containing lead
      (solder, brass, etc);
    G numerous solder joints are installed in short sections of pipe;
    Q there are areas of low flow or infrequent use;
    Q sediment in the plumbing and screens at isolated locations contains lead;
    Q water coolers have tanks lined with lead or other construction materials
      made of lead.
The plumbing
profile —
an essential
part of your
overall
program
DEVELOPING A PLUMBING PROFILE OF YOUR SCHOOL

    Completing a survey of your school's plumbing is an essential part of an
overall program to identify high risk areas for lead in your drinking water. In
addition, this survey will help you

    • make decisions about water supply and pipe materials in the school;
    • prioritize sample sites;
    • make overall policy decisions regarding steps to initiate remedial action;
    • inform parents and employees about what the school system is doing about
        lead in the drinking water.

    The survey on the following pages is designed to help you make early
decisions about your buildings. Answers to these questions are discussed  in depth
in the section entitled "What Your Answers Mean" which begins on page  13.
10

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              DEVELOPING A PLUMBING PROFILE OF YOUR SCHOOL
    The following questionnaire will help you determine whether lead is likely to be a problem in your
schools. It will also help you identify which locations have the highest risk of lead contamination. Copies of
this questionnaire should be completed for each school within your district. The questions and their
significance are discussed in depth on the follow pages.


1.  When was the school built?                                                   	
2.  After the construction of the original building, were any new buildings
      or additions added? If so, when?

3.  If built since December, 1986, was lead-free plumbing and solder used in
      accordance with the lead ban?
4. When were the most recent plumbing repairs made?

5. What is the service connector made of?


6. Specifically, what are the pipes made of? (note the locations)

       copper              	             plastic
       galvanized metal     	             lead
       other               	             brass
7. What materials does the solder connecting the pipes in your system contain?
       (Note locations with lead solder)

8. Are brass fittings, fixtures, faucets, or valves used in your drinking water system?
       (Note their location)
9. How many of the following outlets provide water for consumption? (Note their location)

       water coolers       	              drinking fountains  	
       ice makers          	              kitchen faucets     	
       other               	
10. What brands and models of water coolers provide water in your school?


11. Do the faucets have accessible screens?


                                         CONTINUED
                                                                                             11

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                                         Plumbing Profile
                                             (page 2)
12.  Have these screens been cleaned?
13. Can you detect signs of corrosion, such as frequent leaks, rust-colored water,
      or stained dishes or laundry?
14.  Is any electrical equipment "grounded" to water pipes?
       (Note their location)
15.  Have there been complaints about bad (metallic) taste?
16. When were water samples from your building last tested for contaminants?

             What kind of contaminants?	
             Was lead found?
             At what concentration?
             What was the pH level?
             Is testing done regularly?
17. Who supplies your school's drinking water?

       A. If purchased,  you should ask your supplier:

              Does the water system have any lead piping?
              How corrosive is the water?
              Is the water supply being treated now?

       B. If the school supplies its own water, you should ask

              Is the water supply treated to reduce corrosivity?
              If so, what type of treatment is used?
              Is the water treated for any purpose other than corrosion control?
              If so, for what?
12

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LEAD IN SCHOOL DRINKING WATER
1. When was
the school
built?
2. Any new
buildings or
additions?

If so, when were
they built?
3. Was lead
free plumbing
and solder
used?
4. When were the
most recent
plumbing repairs
made?
WHAT YOUR ANSWERS MEAN

    The answers to these questions are important because lead in
drinking water is most often a problem in school buildings with
plumbing that is either very new (less than 5 years old) or very old.

    Old Buildings — Up  through the early 1900's, lead pipes were commonly
used for interior plumbing in public buildings and private homes. Plumbing
installed before 1930 is most likely to contain lead. Between 1920 and 1950,
galvanized pipes were also used for plumbing. After 1930, copper generally
replaced lead as the most commonly used material for water pipes. However, the
use of lead solder with copper pipes remains widespread, even today.  Experts
regard the corrosion of lead solder as the major cause of lead contamination
of drinking water today.

    New buildings — are not likely to have lead pipes in their plumbing
systems, but they are very likely to have copper pipes with lead solder at the
joints between pipes. In states where the 'lead ban' is being implemented
effectively, new plumbing should contain no lead materials. You should be on
the look-out, however, for renegade lead installation, as new plumbing
containing lead can produce very high lead levels.  Report violations of the lead
ban to your state department of health or environment.

    Lead enters the water supply through two different reactions. The first is the
reaction between the lead and the water itself.  Where the water is not too
corrosive, mineral deposits may form a coating on the inside of water pipes. The
coating insulates the water from the lead solder and lead levels caused by this
reaction decrease.  Unless such a coating is formed (or until a corrosion control
system is effective), there is direct contact between the water and any lead in the
plumbing system.

    The second process is the galvanic reaction between the copper in the pipes
and the lead in the solder. This reaction is vigorous in new piping and lead levels
can be extremely high.  After about five years, lead levels are governed largely
by the corrosiveness of the water.  Non-corrosive water will allow a protective
layer to form and the reaction slows down.

     For these reasons, if the school (or an addition, or new plumbing or repair)
is less than five years old and lead solder or other materials were used in the
plumbing, you may have elevated lead levels. If water supplied to the building
is corrosive, however, lead  solder can remain a problem, regardless of the
plumbing's age.
                                                                                              13

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                                                                 WHAT YOUR ANSWERS MEAN
5. What is the
service
connector
made of?
6. What are
your school's
water  pipes
made  of?
7. What materials
comprise the
solder connecting
your pipes?
8. Any brass fittings,
fixtures, faucets
or valves?
    Lead piping was often used for the service connectors that join
buildings to public water supplies. The service connector is the pipe that
carries drinking water from a public water main to the school building. (See
attached diagrams.)  Some localities, as recently as 1986, required the use of
lead service connectors. Although minerals may accumulate on these pipes,
vibrations can cause flaking of any protective mineral build-up and thus allow
lead contamination.

    Survey your building for exposed pipes, preferably accompanied by an
experienced plumber who should be able to readily identify the composition of
pipes on site.  (Most buildings have a combination of different plumbing
materials.)  In general:

    Lead pipes are dull gray in color and may be easily scratched by an object
such as a key or knife.  Lead pipes are a major source of lead contamination in
drinking water.

    Galvanized metal pipes are gray or silver-gray and are usually fitted
together with threaded joints. In some instances, compounds containing lead have
been used to seal the threads joining the pipes. Debris from this material which
has fallen inside the pipes may be a source of contamination.

    Copper pipes are red-brown; corroded portions may show green deposits.
Copper pipe joints have been typically soldered together with lead. Experts
regard the corrosion of lead solder as the major cause of lead contamination of
drinking water today.  Implementation of the "lead ban" will drastically cut lead
contamination in repairs and new plumbing.

    Plastic pipes, especially those manufactured abroad, may contain lead. If
plastic pipes are used, be sure they meet  National Sanitation Foundation (NSF)
standards and are free of plasticizers which contain lead. (Note: copies of this
standard may be obtained from NSF, 3475 Plymouth Road, P.O. Box 1468, Ann
Arbor, MI 48106.)

    Brass pipes, faucets, valves and fittings are a golden yellow color,
similar to copper in appearance, or are plated with chrome. Brass is composed of
two metals, commonly copper and zinc.  Brass fittings commonly used in
drinking water outlets, such as faucets and water coolers, in general contain up to
8 percent lead. However, some older brass fixtures may contain higher
percentages of lead and lead solder in their interior construction, It is important to
verify that these fittings are lead-free.
14

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LEAD IN SCHOOL DRINKING WATER
9. Types of
drinking
water outlets?

10. Brand and
model of
water coolers?
11. Do the faucets
have accessible
screens?

12. Have they
been cleaned?
13. Signs
of
corrosion?
14. Is any
electrical
equipment
grounded to
the water
pipes?
    In addition to lead components in the plumbing system, lead solders or lead
in the brass fittings used in some faucets, water fountains, and refrigerated water
coolers may be a source of lead. It is important to identify the locations of all
such drinking water outlets.

    Water coolers may be a major source of lead contamination. Under the
Lead Contamination Control Act of 1988, water coolers with lead lined tanks are
considered to be "imminently hazardous consumer products" and manufacturers
and importers of these coolers must repair, replace, or recall them and provide a
refund by November 1,1989. The law also requires that solder, flux, and storage
tank interior surfaces in contact with drinking water contain not more than 0.2
percent lead. Other parts of water coolers which may come into contact with
drinking water may not contain more than 8.0 percent lead. In addition, this
amendment to SDWA attaches  criminal and civil penalties for the manufacture
and sale of water coolers containing lead.

    Contact your state department of health or environment for a list of brands
and model numbers of water coolers found to contain lead.  Use the list to help
prioritize your sampling. If your water cooler is listed as having a lead-lined
tank, sample the water immediately (see page 35 for directions) as these coolers
have the highest risk of lead contamination.
    Sediments containing lead which are trapped on screens can be a significant
source of lead contamination. Sediments should be tested for the presence of
lead and the screens should be cleaned frequently.
    Frequent leaks, rust colored water, and stains on fixtures, dishes and laundry
are signs of corrosive waters. Blue/green deposits on pipes and sinks indicate
copper corrosion; brown stains result from the corrosion of iron.  Where such
symptoms occur, high levels of lead, copper, and iron may be present in the
water.
    If electrical equipment, such as telephones, has been installed using water
pipes as a ground, the electric current travelling through the ground wire will
accelerate the corrosion of the interior plumbing containing lead. The practice
should be avoided, if possible. However, if existing wires are already grounded
to water pipes, the wires should not be removed from the pipes unless a qualified
electrician installs an alternative grounding system. Check with your local
                                                                                                15

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                                                                  WHAT YOUR ANSWERS MEAN
                           building inspector. Your state or local building code may require grounding of
                           the wires to the water supplies.  Improper grounding of electrical equipment may
                           cause severe shock.
15. Have there
been complaints
about"bad"
(metallic)
taste?

16. When was the
water in your
building  last
tested for
contaminants?
Is the
water
corrosive?
    Although you cannot see, taste, or smell lead dissolved in water, the presence
of a bad or "metallic" taste may indicate corrosion and possible lead
contamination.
    Results of analysis of the water quality, such as pH, calcium hardness, and
carbonate alkalinity, can provide important clues about the corrosivity of the
water. In addition, these results can help the water supplier develop the most
effective treatment of the water for corrosion control. Effective corrosion control
treatment may include reducing the water's acidity, increasing its alkalinity,
and/or adding a corrosion inhibitor such as zinc orthophosphate. The best choice
among possible treatments will vary depending on the local water quality.

    It is important to know if and how the school's water is treated. Some kinds
of treatment can make the water more corrosive, while others will reduce the
problem. Treatment of the public water to reduce corrosion can reduce lead
levels throughout the system and  can save both you and the supplier money by
reducing damage to plumbing.
17. Who supplies
your school's
drinking water?
    If your school purchases its water, contact your supplier to find out
whether the water is corrosive and what the lead level of the water delivered to
you is. If the water supplied to you exceeds the MCL for lead, your supplier will
be required to bring the level down to acceptable levels by either installing a best
available technology or by taking other steps such as drilling a new well or
blending water from other sources. You should work with your supplier to
ensure that everything possible is being done to avoid lead contamination  either
from source water or from corrosion of the plumbing.

    If you supply your own water, contact your state department of health or
environment or a qualified water treatment professional for assistance. If the pH
of your water supply is less than 8, or if the average lead level from a liter of
water is greater than 10 ppb, under the proposed regulations you will be required
to lower the lead concentration to an acceptable level and implement corrosion
control. Be sure that your treatment of the school's water does not increase the
corrosivity of the water to lead.
16

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LEAD IN SCHOOL DRINKING WATER
How to
begin
A two step
program
                         GETTING YOUR SCHOOL'S WATER TESTED
    If after completing a profile on your school's plumbing, you determine that
you are likely to have lead contamination, you should have your water tested.
Testing is the only sure way of telling whether or not there are harmful
amounts of lead in the school's drinking water.

    Contact your local water utility or your local or state department
of health or environment for information and assistance. As
mentioned previously, the Lead Contamination Control Act of 1988 requires
states to establish programs to help school officials identify and address the
problem of lead in school drinking water. Funding for testing may also be
available.  In some instances, the local water supplier or the state or local
department of health or environment may collect and analyze water samples from
your school, or they will refer you to a state-certified laboratory using EPA-
approved procedures.

    A few laboratories will send trained personnel to collect the samples.  In
most cases, however, the laboratory will provide sample containers and
instructions on how to collect the samples. Detailed sampling instructions begin
on page 26 of this manual. Discuss the sampling instructions in this manual with
the laboratory to make sure they are following similar procedures.  Make sure
that the personnel collecting the samples are thoroughly familiar with the
instructions and that they follow the instructions exactly  - otherwise, the
results may not be reliable.

    The cost of testing ranges from $7 to $30 per sample.
                         GENERAL PROCEDURAL CONSIDERATIONS
    EPA recommends that the sampling program be done in two
Steps, especially in large buildings where many samples will be taken. In the
first step, screening samples are taken to identify the location of outlets providing
water with high lead levels. In the second step, follow-up water samples are
taken from problem locations. By comparing results of initial and follow-up
samples, you should be able to identify the source of the lead contamination.
                                                                                            17

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                                                   GETTING YOUR SCHOOL'S WATER TESTED
General
procedural
considerations
Prioritize
sampling:
take samples
from high risk
outlets first
    Collect samples before school opens and before any water is
used.  These samples, referred to as "morning first-draw samples," are
representative of the water that is consumed at the beginning of the day or after
infrequent use.  If these samples  show no lead contamination, the water the
children are drinking is probably safe.

    Do not take samples immediately after vacations, week-ends or holidays
unless specifically directed to do so. These samples, although they may contain
higher lead levels than ones collected during regular school weeks, are not
representative of water in contact with the plumbing overnight, and therefore
make it more difficult to locate the source of any lead contamination.  EPA
recommends that all schools flush drinking water outlets after week-ends
and vacations (flushing directions begin on page 22),  unless additional tests
are made to determine lead levels for this period.

    In  general, a larger number of samples will result in the best assessment of
the source and extent of the lead  in drinking water. EPA recommends that you
prioritize the sample sites on the basis of likelihood of contamination.  Your
completed plumbing profile (pages 11 and 12 of this manual) will help you
identify these sites in each building.

    Sample sites which are most likely to have  lead contamination include:

    Q  areas containing lead pipes;
    Q  areas of recent construction and repair in which  lead solder or materials
       containing lead were used;
    Q  areas where the plumbing is used to ground electrical circuits;
    Q  areas where corrosive water having low pH and alkalinity is distributed;
    Q  water coolers identified by EPA as having lead-lined storage tanks or lead
       parts;
    Q  areas of low flow and/or infrequent use  (where water is in contact for a
       long time with plumbing  containing lead or with paniculate matter and
       lead debris).
                              (See also section entitled
                           which begins on page 10.)
                           'WHEN TO EXPECT LEAD CONTAMINATION"
18

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LEAD IN SCHOOL DRINKING WATER
If no problem
is found...
If a problem is
found...
                         WHEN THE TEST RESULTS COME  IN
                             The Lead Contamination Control Act of 1988 requires school departments to
                         make available to the public, teachers, other school personnel, and parents the
                         results of any testing for lead contamination, and to notify parent, teacher, and
                         employee organizations of the availability of these results.

                             In light of recent studies which reveal that even very low levels of lead in
                         drinking water can have subtle adverse effects on children, EPA recommends
                         that action be taken to limit exposure or reduce lead in water whenever lead
                         levels exceed 20 ppb.
    If test results from all outlets show that the lead levels in your
school's drinking water do NOT exceed 20 ppb, EPA recommends that
you take additional samples in the morning before school opens after week-ends
or vacations. As mentioned earlier, water sitting in the pipes for a long time may
have higher lead levels than during normal use. An alternative to additional
testing is to flush the water supply after week-ends and vacations.  Flushing the
water system should be omitted only if further analysis from first draw
samples taken on Monday morning or after vacations indicate lead levels
below 20 ppb. Detailed directions for flushing begin on page 22 of this manual.
    If test results show lead levels in excess of 20 ppb, you should start
step 2 of the sampling process to track down the sources of the lead
contamination.  In this second step, follow-up samples are taken from those
outlets which show elevated lead levels. Directions for follow-up samples begin
on page 37.  Identification of the sources of lead contamination is essential to
finding solutions that will work.

    If the lead level of any water fountain or outlet exceeds 20 ppb,
take it out of service immediately until the level of contamination is
reduced to below 20 ppb.

    If your school purchases its water from a public water system,
you should first notify your water supplier, your school board, and your state and
local governments. Find out what your supplier is doing to reduce lead
concentrations in the source water and what corrosion control or other treatment
is planned. By working closely  with your water supplier, you will also avoid
unnecessary expenditures.
                                                                                             19

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                                                          WHEN THE TEST RESULTS COME IN
                              If your school owns its own well or other water source, you must
                          begin to take steps to ensure that the provisions of SDWA which apply to you are
                          carried out (see page 4).  You are required by law to notify the consumers - all
                          school staff and the parents or guardians of all students. If you have not already
                          done so, contact your state department of health or environment for specific
                          instructions regarding this notification. (Refer to page 7 of this manual for
                          additional information on notification requirements  under the law.)
                          OTHER STEPS YOU CAN TAKE
 Interim
 measures
    Until more permanent solutions bring lead levels down, you should
implement interim measures to reduce lead contamination in your school's
drinking water. These interim measures are necessary until corrosion control or
other treatment by the water supplier is effective or until new piping within your
buildings develops a protective coating. You should periodically monitor the
lead levels of your school's drinking water until levels decrease below 20 ppb
and before you decide which interim measures to discontinue.

1. Clean debris from all accessible screens frequently. As mentioned
earlier, sediments containing debris can be a source of lead contamination.
                          2. Use only cold water for the preparation of food and beverages in
                          school cafeterias and cooking classes. Hot water dissolves lead more
                          quickly than cold water and is likely to contain higher levels of lead. If hot water
                          is needed, it should be drawn from the cold-water tap and heated on a stove.
                          3. Purchase bottled water. This can be an expensive alternative.  Bottled
                          water sold in interstate commerce is regulated by the Food and Drug Admin-
                          istration, not by EPA. Water that is bottled and sold within a state is under state
                          regulation.  EPA recommends that schools require a written statement from
                          the bottled water distributor guaranteeing that lead levels in the water do
                          not exceed 5 ppb.
20

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LEAD IN SCHOOL DRINKING WATER
Flushing
Disadvantages
to
flushing
4. Do not use water that has been in contact with your school's
plumbing for more than six hours, such as overnight, or after week-
ends or vacations.  Have the water system "flushed" by the school custodian
or maintenance personnel. Before school begins, flush those outlets where test
results indicated lead levels over 20 ppb.  If the test results show widespread
contamination within your building, flushing the interior plumbing may also be
necessary.

    In some cases, a thorough flushing of the plumbing system on a daily basis
will keep lead levels below 20 ppb throughout the day. This is because most of
the lead in drinking water usually comes from the plumbing in the school
building, not from the local water supply. Flushing is important because the
longer water is exposed to lead solder or pipes, the greater the possible lead
contamination. However, if the water is highly corrosive, or if the plumbing is
new, supplemental testing should be done at the end of the school day to make
sure that lead levels stay below 20 ppb. You may need to flush the system twice
daily — once in the morning before school opens and a second time before the
lunch period. If lead levels return to their original levels  within four hours of
flushing, flushing is not a practical temporary solution.

    There are advantages and disadvantages to flushing. Flushing is often the
quickest and easiest solution to high lead levels, especially when contamination
is localized in a small area or in a small building. It does not require installation
or maintenance of water treatment equipment and it does not require complex
instructions.

    The most obvious disadvantage to flushing is the potential waste of water
involved in the flushing procedures.  If water supplies are limited in your area,
some alternatives to daily flushing include:

     • flushing the pipes only after week-ends or vacations, when lead
       levels may be highest (use only if lead levels do not exceed 20 ppb
       on a daily basis);
     • thoroughly flushing several designated drinking water outlets
       daily, while taking all others temporarily out of service;
     • using bottled water.
                                                                                                21

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                                                                                        FLUSHING
                               Another obvious disadvantage to flushing is the amount of time and staff
                           needed to perform the task:

                                • If the water is very corrosive, flushing may have to be done more than
                                  once a day since lead levels in the water can return to high levels very
                                  quickly.  In order to determine the number of additional flushes required,
                                  additional samples will have to be taken. It is probably not practical to
                                  flush the water more than twice a day.

                                • If contamination is widespread in a large building, flushing will take a lot
                                  of time and can waste water.

                                • Supervisors will have to check on the personnel performing the flushing
                                  to ensure that instructions are followed correctly and that accurate records
                                  are maintained and reviewed.  Taking occasional follow-up samples from
                                  the outlets is one method of checking.

                                • Routine daily flushing of water coolers  is not feasible because they take
                                  such a long time to flush.
Directions
for
flushing
FLUSHING DIRECTIONS:

    Remember that each drinking water outlet must be flushed individually;
flushing a toilet will not flush your water fountains. All flushing should be
recorded in a log submitted daily to the office in charge of this program.

   1.  To flush the interior plumbing, locate the faucet furthest away from the
    service line on each wing and floor of the school building, open the faucets
    wide, and let the water run for 10 minutes (for best results, calculate the
    volume of the plumbing and the flow rate at the tap and adjust the flushing
    time accordingly);

   2.  Open valves at all drinking fountains without refrigeration units and let the
    water run for roughly 30 seconds to one minute;

   3.  Let the  water run on all refrigerated water fountains for 15 minutes
    (because  of the long time required, routinely flushing refrigerated fountains
    may not be feasible);

   4.  Open all kitchen faucets and let the water run for 30 seconds.
22

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LEAD IN SCHOOL DRINKING WATER
                          PERMANENT SOLUTIONS

                              You can take a number of actions to reduce permanently or eliminate the
                          sources of lead which originate in your building's plumbing. Some of these
                          actions may allow the elimination or reduction of routine flushing. Each school
                          system needs to examine these options and make its own decision based on such
                          factors as cost, availability of water, and manpower requirements. Of course, to
                          avoid unnecessary expense, you should first contact your water supplier about its
                          plans for treating the public water supply. If you own your water supply, you
                          must comply with the provisions of SDWA (see pages 4-7).
                          • Water that is soft and/or acidic can be treated at the local
                          treatment plant to make it less corrosive. This option is particularly
                          effective because when water is treated to make it less corrosive, lead levels are
                          reduced throughout the system. Treatment to reduce corrosion will also save you
                          and the water supplier money by reducing damage to plumbing.

                              In some areas, corrosion control alone may not be enough to solve the
                          problem. Follow-up testing should be done after corrosion control treatment
                          begins.  If lead levels remain high, additional remedial actions may be necessary.
                          • Corrosion control devices for individual buildings, such as calcite
                          filters, soda ash or phosphate solution tank and feeder units are
                          commercially available. These point-of-entry treatment devices which are
                          best suited to a school system which provides its own water typically cost $1600-
                          2500 for an average size school. If you purchase your water supply, contact your
                          water supplier to see what corrosion control treatment is planned for the general
                          water supply. Under the proposed regulations, the water supplier would be
                          responsible to treat the water to make it non-corrosive.

                              Factors to be considered in selecting a device for your school include
                          performance record and the corrosion-reduction capabilities of the device.
                          Contact your state department of health or environment for assistance and advice
                          about selecting and installing point-of-entry devices.  Typically, the manufacturer
                          will recommend a practical maintenance program once the device is installed.  A
                          good maintenance and quality assurance program is the best way to be sure that
                          the device performs its intended function.
                                                                                               23

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                                                                   PERMANENT SOLUTIONS
Permanent
solutions:
• Carbon, sand, cartridge filters, and water softeners will not
prevent corrosion. In fact, water softeners can contribute to
corrosion of copper pipes unless installed at the tap.
                         • Lead levels can be reduced at the tap. Point-of-Use treatment devices
                         such as reverse osmosis devices and distillation units are commercially available.
                         Because these devices also soften water, they should be installed only at the tap.
                         Units may be either purchased or leased.  They can be expensive, their
                         effectiveness varies, and they may be vulnerable to vandalism. They also require
                         a maintenance contract for regular upkeep to assure their effectiveness. The
                         National Sanitation Foundation (NSF) has a testing program to evaluate the
                         performance of point-of-use treatment devices. Before purchasing any such
                         device, contact your State department of health or environment and NSF (see
                         page 14).
                         • Existing wires already grounded to the water pipes can be
                         removed by a qualified electrician and an alternative grounding
                         system installed. Electrical current accelerates the corrosion of lead in the
                         piping materials. However, you should make sure that your state or local
                         building codes allow removal of electrical grounding from water pipes. In some
                         instances, removal of grounding from water pipes may create a shock hazard
                         unless an acceptable alternative ground is provided.
                         • If the sources of lead contamination are localized and limited to a
                         few outlets, replacing these outlets may be the most practical
                         solution.
                         • Time-operated solenoid valves can be installed and set to
                         automatically flush the main pipes of the system, known as headers.
                         Drinking water fountains cannot be flushed automatically, but may be manually
                         flushed by staff.
                         • Lead pipes within the system and those portions of the lead
                         service connectors under the water supplier's jurisdiction can be
24

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LEAD IN SCHOOL DRINKING WATER
Permanent
solutions
(continued)
replaced. Contact your water utility about this replacement. However, your
school may be responsible for replacing a portion of a lead service connector that
is under its own administrative jurisdiction, rather than under the jurisdiction of
the water supplier.
                        • In some schools, the plumbing system might be modified so that
                        water supplied for drinking or cooking is redirected to bypass
                        sources of lead contamination.
                         • If other treatment fails, or is impractical, bottled water may be
                         purchased for all consumption by students, teachers, and other
                         school personnel.  Be sure that the bottled water you buy meets drinking
                         water standards (see page 20).
                         • Make sure that any plumber who does repair or replacement work
                         on the school's plumbing system uses only lead-free solders and
                         Other materials, as required by law. Before any repair job to the plumbing is
                         accepted, have a plumbing inspector verify that lead-free materials have been
                         used. Test kits to determine if the plumber used lead-free solder are available at
                         reasonable prices (about $40 — see page 6).
                                                                                        25

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                                   part 2


                          SAMPLING  PROTOCOL
                             Suggested Sampling
                                Procedures to
                                Determine the
                          Location and Source of Lead
                           in School Drinking Water
26

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SAMPLING PROTOCOL
The importance
of testing
Approach
the
sampling
systematically
                           PURPOSE
    Testing is the only sure way of telling whether or not there are harmful
amounts of lead in your school's drinking water. As explained earlier, lead has
most likely entered your school's drinking water through corrosion of the service
connections, pipes, fixtures and other parts of the plumbing system distributing
water within your buildings — rather than from the water supply itself. The
sampling procedures outlined here will help you determine the location and
source of the lead in water obtained from specific components of the system,
such as water fountains, central chiller units, water coolers, bottled water
dispensers, ice making machines, faucets, internal plumbing, and service
connections. Give a copy of the protocol to each person who will take the
samples or evaluate the findings.

    Although the methods outlined in this protocol are similar to the sampling
procedures used by water suppliers to determine compliance with the
requirements of the Safe Drinking Water Act, this protocol is not to be used to
determine whether a water supplier meets the federal standards.

    This protocol has been field tested and found to provide results which are
generally reliable.  Despite the fact that lead levels of samples taken at various
times from the same sample site may vary, the results are usually similar. Thus,
if test results exceed 20 ppb, you can expect lead levels of subsequent samples to
warrant remedial action. The opposite is also true.

    [Note: ppb is often expressed as micrograms per liter (ug/1).  One ppb is
equal to one microgram per liter (ug/1) or .001 milligrams per liter (mg/1).]
BEFORE YOU BEGIN

    Analysis of samples should be done by a state-certified laboratory using
EPA-approved methods. (Contact your local water utility or state department of
health or environment for information and assistance.)

    To keep the number of samples to a minimum, approach the task
systematically:

    a.  Prior to sampling, study the layout of the plumbing system of your
                                                                                                27

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                                                                             BEFORE YOU BEGIN
 Understand
 the
 plumbing
 layout
 of your
 buildings
 Identify
 areas with
 highest risk
 of lead
 contamination
building. The configuration of the interior plumbing can vary depending on the
layout of the building.  (Examples of various plumbing configurations in
buildings are illustrated in the attached diagrams.) Locate service intakes,
headers, laterals, fixture supply pipes, drinking water fountains, central chiller
units, storage tanks, riser pipes and different drinking water loops.

       In multi-story buildings, the water is elevated to the floors by one or more
riser pipes. Water from the riser pipes is usually distributed through several
different drinking water loops. In addition, in some buildings, water may be
stored in a tank prior to distribution. In single-story buildings, the water comes
from the service connection via main plumbing branches, often called headers.
These in turn supply water to laterals. Smaller plumbing connections from the
laterals and loops supply water to the faucets, drinking fountains, and other
outlets.

    The terms "upstream" and "downstream" are used frequently in this
protocol. For sampling purposes, water within a plumbing system moves
"downstream" from the source,  i.e. the distribution main in the street.

    b. Complete the plumbing profile on pages 11 and 12 of this manual. This
will enable you to identify areas of highest risk and prioritize your sites
accordingly. (See also the section entitled WHEN TO EXPECT LEAD
CONTAMINATION which begins on page 10.) Sample sites which  are most
likely to show lead contamination include:

    Q areas where the plumbing is used to ground electrical circuits;
    Q areas where corrosive water having low pH and alkalinity is distributed;
    Q areas of low  flow and/or infrequent use (where water is in contact for a
       long time with sediments or plumbing containing lead);
    Q areas containing lead pipes or areas of recent construction and repair in
       which lead solder or materials containing lead were used;
    Q water coolers identified by EPA as having lead lined storage tanks or
       other parts containing lead.

    If the analyses of these samples indicate contamination of the drinking water
by lead, additional sampling from other sites deemed less vulnerable to lead
contamination may be indicated.
28

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SAMPLING PROTOCOL
Initial
screening
samples identify
location of
lead
contamination
Follow-up
samples
identify
source of
lead
contamination
                          A TWO-STEP PROCESS
                          EPA recommends that the sampling program be done in two steps.
Step 1:

    The purpose of this first step is to identify the outlets which provide
drinking water showing significant lead levels. In step 1, screening samples
from drinking water outlets within the building are collected and analyzed.
Step 2:

    The purpose of step 2 is to pinpoint the sources of lead in the drinking
water from outlets which showed significant lead levels in the initial screening
samples.  In step 2, follow-up samples are collected and analyzed from these
outlets. If necessary, additional samples from the interior plumbing within the
building are taken.

    Once the sources of contamination are known, appropriate remedial actions
may be taken.

    Ultimately, the choice of performing the sampling in one or two steps is up
to the personnel performing the sampling. Small facilities with relatively few
sites to be sampled may be able to perform all of the sampling at once. (A flow
chart outlining the overall general sampling strategy is attached.)

    The number of samples taken from a building depends upon the size of the
building,  the number of outlets used to supply drinking water, and the extent of
the contamination. More outlets with elevated lead levels will require
correspondingly more follow-up samples to pinpoint the sources of
contamination. In general, a larger number of samples will result in the best
assessment of the source and extent of lead in drinking water.
                                                                                               29

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                                                                     SAMPLING PROCEDURES
                          LABORATORY ANALYSIS AND HANDLING OF SAMPLE
                          CONTAINERS
Follow
laboratory's
instructions
exactly
General
sampling
procedures
    The sample containers should be prepared in a clean laboratory environment
by qualified laboratory personnel using the appropriate purity chemicals. Do not
attempt to prepare your own sample containers unless your school has qualified
personnel and an appropriate facility. The laboratory should provide you with
enough sample containers. Follow the instructions provided for handling the
sample containers to ensure accurate results. Do not rinse the sample containers
before filling. The laboratory has prepared the containers to receive the samples
you will take and they may contain a chemical needed to preserve the samples
properly until they reach the laboratory. Avoid any contact with this chemical.
Be careful not to overfill the sampling containers with water. (For information
about the preparation of sample containers and sample preservation,  refer to the
Appendix, page 50.)

    Label all of the sample bottles with the location of the sample site.  Also note
the manufacturer's name and model number of water fountains, water coolers,
central chillers, and any other water dispensing outlets from which samples are
taken.
                          GENERAL SAMPLING PROCEDURES

                                 (1) Collect all samples before school opens and before any water is used.
                                   Ideally, the water should sit in the pipes unused for at least 8 hours but
                                   not more than 18 hours before the sample is taken. However, in some
                                   areas of infrequent use, water from a particular outlet may not have
                                   been used in more than 18 hours. Despite this, the sample would still
                                   be representative of the normal water consumption pattern.

                                 (2) Make  sure that no water is withdrawn from the taps or fountains from
                                   which  the samples are to be collected prior to sampling.  Samples
                                   collected from the designated sites after they have been used will
                                   indicate lower lead levels than may be actually encountered.

                                 (3) Unless specifically directed to do so, do not collect samples in the
                                   morning after vacations, week-ends or holidays. These samples will
                                   contain higher lead levels than  those collected at other times and are
                                   not representative of normal water consumption patterns. Finding the
                                   source of any lead contamination through follow-up samples would
                                   thus be more difficult. (For more details, seepages 18 and 19.)
30

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SAMPLING PROTOCOL
Sampling
service
connections
                           HOW TO BEGIN

                                 First, contact your water supplier.  Under the proposed regulations (see
                           page 4), water delivered by a public water supplier would be required to have
                           lead levels equal to or less than 5 ppb when it leaves the treatment plant. If the
                           lead level of the water exceeds 5 ppb, your water supplier would be required to
                           bring the lead concentration down. If your school supplies its own water, the
                           school is considered a public  water supplier and is subject to the provisions of
                           this law. (See the section entitled THE SAFE DRINKING WATER ACT, page 4.)

                                 If your supplier verifies that the drinking  water leaving the treatment plant
                           has lead levels of 5 ppb or less, take a sample of the water coming into your
                           building.  If the lead level exceeds 20 ppb, the problem may be a lead service
                           connector or the distribution main. (The service connection is the plumbing
                           connection between the distribution main in the street and the plumbing in the
                           building.) If the test result is  low  (5 ppb or less), any problem will be from the
                           interior plumbing of your  building.
SAMPLING SERVICE CONNECTIONS

    Until recently in some locations, lead pipes up to 2 1/2 inches in diameter
were used for service connectors. Other materials used for service connectors
include copper, galvanized steel,  plastic, and iron.  Lead service connectors can
produce significant lead levels in your drinking water.

    EPA recommends using the tap closest to the service connector for
sampling. This is especially important in larger facilities where more than one
service connection is present.

Sample IS

    Take this sample before school opens.  Open the tap closest to the service
connection.  Let the water run and feel the temperature of the water.  As soon as
you feel the water change from warm to cold, collect the sample.  Because water
warms slightly after standing in the interior plumbing, this colder water sample
represents the water that had been standing just outside of the building and in
contact with the service connector. Fill the sample container with 250 mL of
water unless otherwise directed by the laboratory.
                                                                                                31

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                                                           SAMPLING SERVICE CONNECTIONS
The
distribution
main
rarely
causes lead
contamination
Sample 1M

    This sample is representative of the water that has been standing in the
distribution main. Take it from the same location as sample IS.  Let the water
run and feel the temperature of the water.  When you feel the water change from
warm to cold, allow the water to run for an additional 3 minutes and then collect
the sample. Fill the sample container with 250 mL of water.
                          Interpreting the Results

                              • If the lead level of sample IS significantly exceed 5 ppb (for example
                          10 ppb) and is higher than in sample 1M, lead is contributed from the service
                          connector. Check for the presence of a lead service line. In the absence of a lead
                          service connector, lead goosenecks or other appurtenances containing lead in line
                          with the service connection may be the source of contamination. Usually no
                          significant amount of lead (above 5 ppb) comes from the distribution main.

                              • If the lead level of sample 1M significantly exceeds 5 ppb (for example
                          10 ppb), lead in the water may be attributed to the source water, sediments in the
                          main, or possibly from lead joints used in the installation or repair of cast iron
                          pipes. If the water supplied is from a well, a lead packer in the well may also
                          contribute lead to the water.

                              • If the lead level of samples IS and 1M are very low, close to 5 ppb,
                          very little lead is picked up from the service line or the distribution main. If any
                          of the initial screening samples of Step 1 indicate a problem with lead
                          contamination, the source of that contamination is in the interior plumbing and/or
                          outlets (or sediments containing lead which are trapped in the plumbing or on
                          screens), not the water supply or the service connection.
32

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SAMPLING PROTOCOL
Identifying
the location
of drinking
water outlets
with
lead
contamination
Drinking
water
fountains
STEP 1 — TAKING INITIAL SCREENING SAMPLES

SAMPLING INDIVIDUAL OUTLETS

      Next collect initial screening samples for analysis from individual
outlets in areas you have identified as having a high risk of contamination. These
outlets include drinking water fountains (including water coolers), ice making
machines, water faucets and any place where sediment has collected in the
plumbing or on screens.
DRINKING WATER FOUNTAINS

    There are four main types of drinking water fountain systems:

    1. The Bubbler or Drinking Fountain. Water is supplied to the bubbler or
fountain directly from the building's plumbing.

    2. A Central Chiller Unit cools water for a number of drinking fountains or
bubblers in the building.

    3. A Water Cooler is equipped with its own cooling and storage system.
Water is supplied to the water cooler from the building's plumbing.

    4. A Bottled Water Dispenser is a type of water fountain whose water is
supplied from bottled water.

    Note: Do not close the valves to the water fountains to prevent their use.
Minute amounts of scrapings from the valves will produce inaccurate results
showing higher than actual lead levels in the water.  Take all samples with the
taps fully open.
                                                                                           33

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                                                                 INITIAL SCREENING SAMPLES
Bubblers
without
central
chiller
BUBBLERS OR DRINKING FOUNTAINS

Bubblers without Central Chiller

    Fill sample containers with 250 mL of water.

Initial Screening Sample Number 1A

    This sample is representative of the water that may be consumed at the
beginning of the day or after infrequent use. It consists of water that has been in
contact with the bubbler valve and fittings and the section of plumbing closest to
the outlet of the unit.

    Take this sample before school opens and before any water is used. Collect
the water immediately after opening the faucet without allowing any water to run
into the sink.  Follow up samples should be taken from those water fountains
where test results indicate lead levels over 20 ppb.
Bubblers
with
central
chiller
Bubblers with Central Chiller

    Fill sample containers with 250 mL of water.

Initial Screening Sample Number IB

    This sample is representative of the water that is consumed at the beginning
of the day or after infrequent use. It consists of water that has been in contact
with the bubbler valve, the fittings, and the section of plumbing closest to the
outlet of the unit.

    Take this sample before school opens and before any water is used. Collect
the water immediately after opening the faucet without allowing any water to run
into the sink. Follow up samples should be taken from those water fountains
where test results indicate lead levels over 20 ppb.
34

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SAMPLING PROTOCOL
Water
coolers
Bottled
water
dispensers
WATER COOLERS
                              The two types of water coolers used are the wall mounted and the free
                           standing.  Water in the cooler is stored in a pipe coil or in a reservoir. Refrigerant
                           coils in contact with either of these storage units cool the water. Sources of lead
                           in the water may be: the internal components of the cooler, including a lead-
                           lined storage unit; the section of the pipe connecting the cooler to the lateral;
                           and/or the interior plumbing.

                              The Lead Contamination Control Act of 1988 contains specific requirements
                           for the testing, recall, repair and/or replacement of water coolers containing lead.
                           Contact your state department of health or environment to see if the manufacturer
                           and model number of your unit(s) is on the list of water coolers identified by EPA
                           as containing lead. (Refer to pages 4 and 15 of this manual for additional
                           information.)

                              Fill all sample containers with 250 mL of water.

                           Initial Screening Sample Number 1C

                              This sample is representative of the water that may be consumed at the
                           beginning of the day or after infrequent use. (Although in some areas of
                           infrequent use the water may not have been used in more than 18 hours, the
                           sample is still representative of the normal water consumption pattern.) It
                           consists of water that has been in contact with the valve and fittings, the storage
                           unit, and the section of plumbing closest to the outlet of the unit.

                              Take this sample before school opens and before any water is used. Collect
                           the water immediately after opening the faucet without allowing any water to
                           waste.  Follow-up samples should be taken from those water coolers where test
                           results indicate lead levels over 20 ppb.
BOTTLED WATER DISPENSERS

    Fill all sample containers with 250 mL of water.

Initial Screening Sample Number ID

    This sample is representative of the water that may be consumed at the

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                                                                  INITIAL SCREENING SAMPLES
Ice
Making
Machines
                           beginning of the day or after infrequent use. It consists of water that has been in
                           contact with the dispenser valve and fittings incorporated in the outlet of the unit.

                              Take this sample before school opens and before any water is used. Collect
                           the water immediately after opening the faucet without allowing any water to
                           waste. Follow-up samples should be taken from those bottled water dispensers
                           where test results indicate lead levels over 20 ppb.
ICE MAKING MACHINES
                           Initial Screening Sample Number IE

                               Fill a suitable container (250 mL or larger, wide-mouthed bottle or Whirl-
                           Pak TM) prepared by the laboratory at least three quarters full of ice. Do not
                           touch the ice with your hands. Use the non-metal scoop or disposable plastic
                           gloves provided by the lab.

                               If lead levels in the samples taken from the ice-making machine exceed
                           20 ppb, take follow-up sample number 2E to determine if the source of the lead
                           is the plumbing or the ice-making machine itself.
Water
faucets
WATER FAUCETS
                               Fill all sample containers with 250 mL of water.

                           Initial Screening Sample Number IF

                               This sample is representative of the water that may be consumed at the
                           beginning of the day or after infrequent use. It consists of water that has been in
                           contact with the fixture and the plumbing connecting the faucet to the lateral.

                               Take this sample before school opens and before any water is used. Collect
                           the water immediately after opening die faucet without allowing any water to run
                           into the sink. Follow-up samples should be taken from those water faucets where
                           test results indicate lead levels over 20 ppb.
36

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SAMPLING PROTOCOL
Bubbler
without
central chiller
                          STEP 2 — TAKING FOLLOW-UP SAMPLES

                              Take follow-up samples from all drinking water outlets where test results
                          indicate lead levels over 20 ppb.  If the results of the initial screening samples
                          indicate extensive contamination of the drinking water by lead, you should take
                          additional samples from other sites not previously tested. EPA recommends that
                          any drinking water fountain or tap with lead levels over 20 ppb be taken out of
                          service immediately until the lead levels are reduced to below 20 ppb.

                              Refer to page 30 for general sampling procedures to be followed when taking
                          follow-up samples.
BUBBLERS OR DRINKING FOUNTAINS

Bubblers without Central Chiller

    Take follow-up samples from those water fountains where initial sample test
results indicate lead levels above 20 ppb. Fill all sample containers with 250 mL
of water.

Follow-up Sample Number 2A

    This  sample is representative of the water that is in the plumbing upstream
from the bubbler. Take this sample before school opens and before any water is
used.  Let the water from the fountain run for 30 seconds before collecting the
sample.

Interpreting the Results

    To determine the source of lead in the water, compare the test results of
samples 1A and 2A.

    • If the lead level in sample 1A is higher than in sample 2A, a portion of
lead in the drinking water is contributed from the bubbler.

    •  If the lead level in sample 2A  is very low, close to 5 ppb, very little lead
is picked  up from the plumbing upstream from the outlet. The majority or all of
the lead in the water is contributed from the bubbler.
                                                                                             37

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                                                                        FOLLOW-UP SAMPLES
Bubbler
without
central chiller
(continued)
    •  If the lead level in sample 2A significantly exceeds 5 ppb (for example,
10 ppb), lead in the drinking water is also contributed from the plumbing
upstream from the bubbler.

    • If the lead level in sample 2A exceeds 20 ppb, EPA recommends
sampling from the header or loop supplying water to the lateral to locate the
source of the contamination. (Refer to the section entitled INTERIOR
PLUMBING on page 45.)
Bubbler
with
central chiller
Bubbler with Central Chiller

    Take follow up samples from those water fountains where initial screening
sample test results indicate lead levels over 20 ppb. Fill all sample containers
with 250 mL of water.
                          Follow-up Sample Number 2B

                              This sample is representative of the water that is in the plumbing upstream
                          from the bubbler. Take this sample before school opens and before any water is
                          used.  Let the water from the fountain run for 30 seconds before collecting the
                          sample.
                          Interpreting the Results

                              To determine the source of lead in the water, compare the test results of
                          samples IB and 2B.

                              • If the lead level in sample IB is higher than in sample 2B, a portion of
                          lead in the drinking water is contributed from the bubbler.

                              •  If the lead level in sample 2B is very low, close to 5 ppb, very lit^e lead
                          is picked up from the plumbing upstream from the outlet. The majority or all of
                          the lead in the water is contributed from the bubbler.

                              • If the lead level in sample 2B significantly exceeds 5 ppb, (for example,
                          10 ppb), the lead in the drinking water may be contributed from the plumbing
38

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SAMPLING PROTOCOL
Central
chiller unit
                           supplying the water from the chiller to the bubbler, from the chiller, or from the
                           plumbing supplying water to the chiller.

                               • If the lead level in sample 2B exceeds 20 ppb, EPA recommends
                           sampling from the chiller unit supplying water to the lateral to locate the source
                           of the contamination (see procedures for samples 3B and 4Bfrom central chiller
                           unit).
CENTRAL CHILLER UNIT

    Fill all sample containers with 250 mL of water.

Follow-up Sample Number 3B

    This sample is representative of water that has been in contact with the
plumbing supplying water to the chiller. Take this sample before school opens
and before any water is used.  Take the sample from a tap or valve as close to the
inlet of the chiller as possible. Collect the water immediately after opening the
tap or valve, without allowing any water to waste.

Follow-up Sample Number 4B

    This water sample consists of water that has been in contact with the chiller
unit and the plumbing upstream which supplies water to the chiller.  Often, water
supplied to the bubblers is recirculated to the chiller unit. In this instance, sample
4B consists of a mixture of water from the water supply and recirculated water
from the plumbing supplying  water to the  bubblers.

    Take the sample from a tap or valve as close to the outlet of the chiller as
possible. Collect the water immediately after opening the tap or valve, without
allowing any water to waste.

Interpreting the Results

    • If the lead level in sample 2B is higher than in sample 4B, lead is
contributed from the plumbing supplying the water from the chiller to the water
fountain.
                                                                                                 39

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                                                                         FOLLOW-UP SAMPLES
Central
chiller unit
(continued)
    • If the lead level in sample 4B is greater than in sample 3B, a portion of
the lead may be coming from the chiller. Note: sludge and sediments containing
high levels of lead may accumulate in chiller tanks. If the test results indicate
that lead is contributed from the chiller unit, check for the presence of debris and
sludge. Remove any of these materials from the chiller, flush the chiller unit, and
re-sample the water.

    If the lead level in sample 3B exceeds 20 ppb, EPA recommends additional
sampling from the distribution system supplying water to the chiller to locate the
source of contamination.  (Refer to the section entitled INTERIOR PLUMBING
on page 45.)

    • If the lead level in sample 3B is very low, close to 5 ppb, very little lead
is picked up from the plumbing upstream from the chiller.  The majority or all of
the lead in the water may be attributed to the chiller and the plumbing
downstream from the chiller.
Water
coolers
                           WATER COOLERS

                              Follow-up samples are taken from those water coolers where test results
                           indicate lead levels over 20 ppb. Fill all sample containers with 250 mL of water.
                           These samples will help you determine what the source of contamination is. Be
                           aware that:

                              • Some water coolers have storage tanks lined with materials containing
                           lead.  You should contact the manufacturer of any water cooler units you have
                           purchased, or are planning to purchase, for written guarantees that no lead has
                           been used in the unit. A list of brands and model numbers of coolers which
                           contain lead has been prepared by EPA and is available from your state
                           department of health or environment. (Refer to page 4 for additional
                           information.)

                              • Sediments and debris containing lead on screens or in the plumbing
                           frequently produce significant lead levels (Follow-up Sample 4C).

                              • Lead solder in the plumbing can also contribute to the problem.
40

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SAMPLING PROTOCOL
Water coolers
(continued)
Follow-up Sample Number 2 C

    This water sample is representative of the water that is in contact with the
plumbing upstream of the cooler. Take this sample after school closes. Let the
water from the fountain run for 15 minutes before collecting the sample. You
must flush for 15 minutes to ensure that no stagnant water is left in the
storage unit.

Follow-up Sample Number 3C

    Because the water in the cooler was flushed the previous afternoon, this
sample is representative of the water that was in contact with the cooler
overnight, not in extended contact with the plumbing upstream. (In this, it may
differ from Initial Screening Sample 1C.)

    Take this sample before school opens and before any water is used. This
sample must be taken the morning after you collect sample 2C.  Collect the
water immediately after opening the faucet without allowing any water to waste.

Interpreting the Results

    • If the lead level in sample 3C is higher than in sample 2C, the water
cooler is contributing lead to the water.

    • If the lead level in sample 3C is higher than in sample 2C AND the lead
level in sample 1C is higher than in sample 3C, the plumbing upstream from
the water cooler may also be contributing lead to the water.

    • If the lead level  in sample 3C is identical or close to that of sample 2C,
the water cooler probably is not contributing lead to the water.

    • If the lead level in sample 1C is higher than in sample 3C, AND if the
lead levels in sample 2C  and 3C are close or identical, the plumbing upstream
from the cooler and/or the plumbing connection leading to the cooler, or both, are
contributing lead to the water.

    • If the lead level  in sample 2C is in excess of 10 ppb and is equal to or
greater than the lead levels in samples 1C and 3C, the source of the lead may
be sediments contained in the cooler storage tank, screens, or the plumbing
upstream from the cooler.
                                                                                              41

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                                                                         FOLLOW-UP SAMPLES
Water coolers
(continued)
    To verify the source of lead, take the following steps.

    1.  Take a 30 second flushed sample from a tap upstream from the cooler or
compare sample 2C with the results obtained from follow-up samples taken from
outlets upstream from the cooler.  If low lead levels are found in these samples
(close to 5 ppb), the source of lead may be sediments in the cooler or the
plumbing connecting the cooler to the lateral, or lead solder in the plumbing
between the taps.
    2.  If the flushed samples from the upstream outlets have lead levels in
excess of 5 ppb, then the cooler and the upstream plumbing may both contribute
lead to the water.

    To confirm whether the cooler is a source of lead, take and analyze sample 4C.
                          Follow-up Sample Number 4C

                              Turn off the valve leading to the cooler. Disconnect the cooler from the
                          plumbing  and look for a screen at the inlet. Remove the screen.  If there is debris
                          present, check for the presence of lead solder by sending a sample of the debris to
                          the laboratory for analysis.

                              Some coolers also have a screen installed at their bubbler outlet. Carefully
                          remove the bubbler outlet by unscrewing it.  Check for a screen and debris, and
                          have a sample of any debris analyzed.

                              Some coolers are equipped with a drain valve at the bottom  of the water
                          reservoir. Water from the bottom of the water reservoir should be sampled and
                          any debris analyzed.

                              Collect sample 4C from the disconnected plumbing outlet in the same
                          manner as you collected sample number 1C. Compare the results from sample
                          4C to those of the other samples.
                          Interpreting the Results

                                 • If the lead level in sample 4C is less than 5 ppb, then lead is coming
                          from the debris in the cooler or the screen.

                                 • If the lead level in sample 4C is significantly higher than 5 ppb, the
                          source of lead is the plumbing upstream from the cooler.
42

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SAMPLING PROTOCOL
Get written
assurance
of lead
levels
from bottled
water
distributor
Ice
making
machines
BOTTLED WATER DISPENSERS

    Fill all sample containers with 250 mL of water.

Follow-up Sample Number 2D

    Collect this sample directly from the bottle which supplies the water to the
unit. This will enable you to determine the source of lead in the water.

Interpreting the Results

    • If the lead level in sample ID is higher than in sample 2D, lead may be
coming from the dispenser unit.

    • If the lead level in sample 2D is identical or close to sample ID,  the
source of lead is the bottled water.

    Note: The proposed regulations limit the amount of lead in source waters to
5 ppb.  The Food and Drug Administration, which regulates the interstate sale of
bottled water is expected to adopt similar regulations.  EPA recommends that you
do not drink bottled water containing lead levels over 5 ppb and that you contact
your distributor for written assurance that the bottled water does not exceed this
level.
ICE MAKING MACHINES

    If the lead level in the sample taken from the ice-making machine
exceeds 20 ppb, take follow-up sample number 2E to determine if the source of
the lead is the plumbing or the ice making machine itself.

Follow-up Sample Number 2E

    Disconnect the icemaker from the plumbing and look for a screen at the
inlet.  Remove the screen. If debris is present, forward a sample of the debris to
the laboratory for analysis. The laboratory will determine if lead solder is
present. If the debris contains lead, the screen should be cleaned frequently
as a regular routine.

    Collect the sample from the disconnected plumbing as close to the ice maker
as possible.  Fill the sample container with 250 mL of water.
                                                                                              43

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                                                                       FOLLOW-UP SAMPLES
Ice making
machines
(continued)
Interpreting the Results

    • If the lead level in sample 2E is close to 5 ppb, the source of the lead in
the ice is the ice maker.

    • If the lead level in sample 2E significantly exceeds 5 ppb, (for example,
10 ppb), lead is also contributed from the plumbing upstream from the ice maker.

    • If the lead level in sample 2E exceeds 20 ppb, EPA recommends
sampling from the distribution system supplying water to the ice maker. (Refer
to the section entitled INTERIOR PLUMBING on page 45.)
Water
faucets
WATER FAUCETS

    Fill all sample containers with 250 mL of water.

Follow-up Sample Number 2F

    This sample is representative of the water that is in the plumbing upstream
from the faucet. Take this sample before school opens and before any water is
used. Let the water from the faucet run for 30 seconds before collecting the
sample.

Interpreting the Results

    • If the lead level in sample IF is higher than in sample 2F, the source of
lead is the water faucet and/or the plumbing upstream from the faucet.

    •  If the lead level in sample 2F is very low, close to 5 ppb, very little lead
is coming from the plumbing upstream from the faucet. The majority or all of
the lead in the water is from the faucet and/or the plumbing connecting the faucet
to the lateral.

    • If the lead level in sample 2F significantly exceeds 5 ppb, (for example,
10 ppb), lead may be contributed from the plumbing upstream from the faucet.
44

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SAMPLING PROTOCOL
Laterals
                          SAMPLING INTERIOR PLUMBING

                              In general, if lead levels exceed 20 ppb in follow-up samples taken from the
                          drinking water outlets, additional samples from designated sample sites in the
                          interior plumbing should be taken.  These sites include the laterals, loops and/or
                          headers, and riser pipes.  The configuration of the interior plumbing will vary
                          depending on the layout of the building.  (For illustration, refer to the attached
                          diagrams.)

                              The sampling should proceed systematically upstream from the initial
                          follow-up sample sites.  The goal is to isolate those sections of the interior
                          plumbing which contribute lead to the water by comparing the results of these
                          samples with results of previous samples.

                              Fill all sample containers with  250 mL of water.
LATERALS:

    Laterals are the plumbing branches between a fixture or group of fixtures,
such as taps, water fountains, etc.

Sample 1G

    Open the tap that has been designated as the sample site for the lateral pipe.
Let the water run for 30 seconds before collecting the sample. The purpose of
flushing the water is to clear the plumbing between the sample site and the lateral
pipe which will assure collection of a representative sample.

    Note: Sample 1G corresponds to follow-up samples taken from other outlets
such as 2A, 2E, and 2F. Compare the results of these samples from outlets
upstream and downstream of sample 1G for additional information on the source
of the lead within the interior plumbing.

Interpreting the Results

    • If the lead level in sample 1G exceeds 20 ppb, collect additional samples
from the plumbing upstream (the service line, the riser pipe, the loop or header
supplying water to the lateral).
                                                                                                45

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                                                              SAMPLING INTERIOR PLUMBING
Laterals
(continued)
    Note: High lead levels may also be caused by recent repairs and additions
using lead solders, or by sediments and debris in the pipe. Debris in the
plumbing is most often found in areas of infrequent use and a sample should be
sent to the laboratory for analysis.

    • If the lead level of sample 1G is the same as the lead level in a sample
taken downstream from sample site 1G, lead is contributed from the lateral or
from interior plumbing upstream from the lateral.  Possible sources of lead may
be the loop, header, riser pipe, or service connection.

    • If the lead level in sample 1G is very low, close to 5 ppb, the portion of
the lateral upstream from sample site 1G and the interior plumbing supplying
water to the lateral are not contributing lead to the water.

    • If the lead level in sample 1G significantly exceeds 5 ppb  (for example,
10 ppb), and is less than the lead level in a sample taken downstream from
sample site 1G, a portion of the lead is contributed downstream from the sample
site.
Loops and
headers
LOOPS AND/OR HEADERS

    A loop is a closed circuit of a plumbing branch which supplies water from
the riser to a fixture or a group of fixtures. A header is the main pipe in the
internal plumbing system of a building. The header supplies water to lateral
pipes.

    EPA recommends that water samples from each loop and/or header be
collected because use patterns may vary among locations within a building.
Construction materials may also vary among loops, especially in larger schools
where additions and repairs have been made to the original structure.

Sample number 1H (header) or II (loop)

    Locate the sampling point furthest from the service connection or riser pipe
on a floor. Open the faucet and let it run for 30 seconds before collecting this
sample. The purpose of flushing the water is to clear the faucet and plumbing
between the sample site and the loop arid/or header pipe, thus assuring collection
of a representative sample.
46

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SAMPLING PROTOCOL
Loops and
headers
(continued)
Riser
Pipes
Interpretation of Results

    • If the lead level is over 20 ppb, collect additional samples from the
plumbing upstream supplying water to the loop or header. Compare the sample
results with those taken from the service line or the riser pipe which supplies
water to the loop and/or header.

    High lead levels may also be caused by recent repairs and additions using
lead solders, or by sediment and debris in the pipe. Debris in the plumbing is
most often found in areas of infrequent use and a sample should be sent to the lab
for analysis.

    • If the lead level in sample 1H or II is equal to the lead level in a
sample taken downstream from sample site 1H or II, the lead is contributed
from the header or the loop and from the interior plumbing upstream from the
head or loop. Possible sources of lead may be the loop, header, riser pipe, or
service connection.

    • If the lead level in sample 1H or II is close or equal to 5 ppb, the
portion of the header or loop upstream from sample site 1H or II and the interior
plumbing supplying water to the loop or header are not contributing lead to the
drinking water. The source of lead is downstream from the sample site.

    • If the lead level in sample 1H or II significantly exceeds 5 ppb (for
example 10 ppb), and is less than the lead level in a sample taken
downstream from sample site 1H or II, a portion of the lead is contributed
downstream of the sample site.
RISER PIPES

    A riser is the vertical pipe that carries the water from one floor to another.
Fill all  sample containers with 250 mL of water.

Sample Number 1J

    Open the tap closest to the riser pipe. Let the water run for 30 seconds
before collecting the sample. The purpose of flushing the water is to clear the
                                                                                              47

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                                                              SAMPLING INTERIOR PLUMBING
Riser pipes
(continued)
faucet and plumbing between the sample site and the riser pipe which will assure
collection of a representative sample.

Interpreting the Results

    • If lead levels exceed 20 ppb, collect additional samples from the
plumbing upstream from the riser. High lead levels in the riser pipes may also be
caused by recent repairs and additions using lead solder.

    • If the lead level in sample 1J equals the lead level in a sample taken
downstream from sample site 1J, the source of the lead is the riser pipe or the
plumbing and service connection upstream from the riser pipe.

    • If the lead level in sample 1J is close or equal to 5 ppb, the portion of
the riser pipe and plumbing upstream from sample site 1J and the service
connection are not contributing lead to the water. The source of the lead is
downstream of the sample site.

    • If the lead level in sample U significantly exceeds 5 ppb (for  example,
10 ppb) and is less than the lead level in a sample taken downstream from
sample site 1J, a portion of the lead is contributed downstream of the sample
site.
48

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GLOSSARY
                  GLOSSARY
                  Bubbler:   A water fountain fixture connected to the water supply.  A bubbler
                  does not contain a refrigeration unit.

                  Chiller: A central refrigeration unit providing cold water to bubblers.

                  Corrosion:  A dissolving and wearing away of metal caused by a chemical
                  reaction (in this case, between water and the piping that the water contacts).

                  Flux: A substance applied during soldering to facilitate the flow of solder. Flux
                  often contains lead and can itself be a source of lead contamination in water.

                  Header:  The main pipe in the internal plumbing system of a building. The
                  header supplies water to lateral pipes.

                  Lateral: A plumbing branch between a fixture or group of fixtures (taps, water
                  fountains, etc.) and the header.

                  Loop: A closed circuit of a plumbing branch which supplies water from the riser
                  to a fixture or a group of fixtures.

                  Public Water System: Any system that supplies water to 25 or more people or
                  has 15 or more service connections (buildings or customers).

                  Riser: The vertical pipe that carries the water from one floor to another.

                  Service Connector: The pipe that carries tap water from the public water main
                  to a building. In the past, these were often made of lead.

                  Solder: A metallic compound used to seal the joints between pipes.  Until
                  recently, most solder contained about 50 percent lead. Lead-free solders often
                  contain one or more of the following metals: antimony, tin, copper, or silver.
                  Several alloys are available that melt and flow in a manner similar to lead solder.

                  Water cooler: Any mechanical device affixed to drinking water supply plumbing
                  which actively cools water for human consumption. The reservoir can consist of
                  a small tank or a pipe coil.
                                                                                        49

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                                                                                      APPENDIX
                          PRESERVATION OF SAMPLES AND SAMPLE
                          CONTAINERS

                              Contamination of sample containers by dust, dirt, or other impurities
                          containing lead can produce inaccurate test results in an otherwise conscientious
                          sampling program. Contamination of a water sample by the container may
                          indicate higher lead levels than are actually present in the drinking water.

                              Another source of error that may affect the result of analysis is the
                          adsorption of lead from the water onto the surface of the container, which will
                          reduce the amount of lead in the water sample.  In such instances, analytical
                          results will indicate lower lead levels in the  sample than actually are present.

                              In order to avoid analytical errors, pay particular attention to proper
                          collection and handling of the sample before analysis. Preparation of sample
                          containers is described in detail in an EPA manual entitled, "Methods for
                          Chemical Analysis of Water and Wastes." In brief, the sample container, whether
                          borosilicate glass, polyethylene, polyproplyene, or Teflon should be thoroughly
                          washed with detergent and tap water, rinsed with 1:1 nitric acid and tap water, 1:1
                          hydrochloric acid and tap water, and finally deionized distilled water — in that
                          order.

                              Make sure that the containers are kept sealed between the time of their
                          preparation and the collection of the sample. This will assure that no
                          contaminants from the outside are introduced. In order to avoid the loss of lead
                          from the sample through adsorption onto the sample container wall, acidify the
                          sample with concentrated nitric acid to a pH of less than 2. If the nitric acid
                          cannot be used at the time of the collection of the sample because of shipping
                          restrictions, preserve the sample by icing, and ship it immediately to the
                          laboratory. Upon receipt, the laboratory must acidify the sample with
                          concentrated nitric acid to a pH of less than 2.

                              For more detail, refer to EPA manuals entitled

                              "Methods for Chemical Analysis of Water and Wastes," EPA- 600/4-79-020,
                          March, 1979 (available from U.S. EPA, R & D Publications, 26 W. Martin Luther
                          King, Cincinnati, OH 45268) and
                              "Manual for the Certification of Laboratories Analyzing Drinking Water,"
                          EPA-570/9-82-002, October, 1982 (available from U.S. EPA, Drinking Water
                          Hotline, 800-426-4791).
50

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Initial Screening
Sample
IS
1A
IB

1C
ID
IE
IF



Follow-Up
Sample(s)
1M
2A
2B
3B.4B
2C, 3C, 4C
2D
2E
2F

1G
1H
11
Type of Outlet or Plumbing
Service Connection to Distribution Main
Bubbler without Central Chiller
Bubbler with Central Chiller
Central Chiller Unit
Water Cooler
Bottled Water Dispenser
Ice Making Machine
Water Faucet
INTERIOR PLUMBING
Lateral
Header
Loop
u
Riser
                                                                             5/

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                                                            APPENDIX
PRESERVATION OF SAMPLES AND SAMPLE
CONTAINERS

    Contamination of sample containers by dust, dirt, or other impurities
containing lead can produce inaccurate test results in an otherwise conscientious
sampling program. Contamination of a water sample by the container may
indicate higher lead levels than are actually present in the drinking water.

    Another source of error that may affect the result of analysis is the
adsorption of lead from the water onto the surface of the container, which will
reduce the amount of lead in the water sample.  In such instances, analytical
results will indicate lower lead levels in the  sample than actually are present.

    In order to avoid analytical errors,  pay particular attention to proper
collection and handling of the sample before analysis. Preparation of sample
containers is described in detail in an EPA manual entitled, "Methods for
Chemical Analysis of Water and Wastes." In brief, the sample container, whether
borosilicate glass, polyethylene, polyproplyene, or Teflon should be thoroughly
washed with detergent and tap water, rinsed with 1:1 nitric acid and tap water, 1:1
hydrochloric acid and tap water, and finally deionized distilled water — in that
order.

    Make sure that the containers are kept sealed between the time of their
preparation and the collection of the sample. This will assure that no
contaminants from the outside are introduced. In order to avoid the loss of lead
from the  sample through adsorption onto  the sample container wall, acidify the
sample with concentrated nitric acid to a pH of less  than 2. If the nitric acid
cannot be used at the time of the collection of the sample because of shipping
restrictions, preserve the sample by icing, and ship it immediately to the
laboratory. Upon receipt, the laboratory must acidify the sample with
concentrated nitric acid to a pH of less  than 2.

    For more detail, refer to EPA manuals entitled "Methods for Chemical
Analysis  of Water and Wastes," EPA- 600/4-79-020, March,  1979, and "Manual
for the Certification of Laboratories Analyzing Drinking Water," EPA-560/9-82-
002, October, 1982.

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