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Contents
About This Manual 2
Part 1 —Lead in Drinking Water Overview 3
Section 1 —Background Information 3
Health Effects of Lead: Why You Should Be Concerned 3
Distribution and Uses of Lead 4
How Lead Gets into Drinking Water . . . • 5
Factors Contributing to Corrosion • 5
How Lead in Drinking Water Is Regulated 8
Section 2—Preliminary Assessment and General Testing Strategy 12
Development of a Plumbing Profile 12
Development of a Sampling Plan 23
Section 3—Two-Step Sampling Process 28
Overview of the Two-Step Sampling Process 28
Section 4—Remedies 31
Routine Control Measures 31
Interim (or Short-Term) Control Measures .' 31
Permanent Remedies 33
Case Studies 35
Section 5—Public Education 45
Mandatory Public Notice Requirements Under the LCCA 45
The Components of an Effective General Communication Strategy 46
Helpful Hints for Communication 47
Sample Public Notice Materials 47
Part 2—Lead Testing Protocol 50
Section 1 —General Procedures 50
Laboratory Analysis and Handling of Sample Containers 50
Collection Procedures 50
Response Actions 51
Section 2-Initial and Follow-Up Sampling by Outlet Type 52
Appendix A—Directory of EPA and State Drinking Water Programs A-l
Appendix B—Glossary of Terms B-l
Appendix C—Water Cooler Summary C-l
Appendix D—List of Lead Resources D-l
Appendix E—Sample Recordkeeping Form E-l
Appendix F—Preservation of Samples and Sample Containers F-l
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About This Manual
The purpose of this manual is to demonstrate how
drinking water in schools and non-residential buildings can be
tested for lead and how contamination problems can be
corrected if found. This manual is intended for use by
officials responsible for the maintenance and/or safety of
these facilities.
Exposure to lead is a significant health concern, especially
for young children and infants whose growing bodies tend to
absorb more lead than the average adult. Pregnant women
and fetuses are also vulnerable to lead in addition to middle-
aged men and women.
Drinking water represents one possible means of lead
exposure. Some drinking water pipes, taps, and other outlets
(i.e., an apparatus dispensing water) in homes and buildings
may contain lead. The lead in such plumbing may leach into
water and pose a health risk.
The longer water remains in contact with leaded-plumbing,
the more the opportunity exists for lead to leach into water.
As a result, facilities with on again/off again water use
patterns, such as schools and businesses, may have elevated
lead concentrations.
Even though water delivered from your community's public
water supply must meet Federal and State standards for lead,
you may still end up with too much lead in your drinking
water because of the plumbing in your facility and because of
the building's water use patterns. The only way to be certain
that lead is not a problem in a particular home, school, or
building is to test various drinking water outlets (i.e., taps,
bubblers, coolers, etc.) for the substance. If lead problems
are found, they can then be corrected.
This manual is intended to aid you as the concerned school
and non-residential building official in determining whether
your facility has a lead-in-drinking-water problem. This
manual is designed to provide you step-by-step instructions
for sampling your water for lead and correcting lead
problems when found. In addition, the manual provides
background information concerning the sources and health
effects of lead, how lead gets into drinking water, how lead
in drinking water is regulated, and how to communicate lead
issues with users of your facility (e.g., employees, students,
concerned parents).
If you are not the individual responsible for testing
and correcting lead problems in your facility, please
forward this manual to the appropriate person(s). If you
are connected with a school, responsible staff might
include superintendents, principals, physical plant
managers, or science department chairpersons. If you are
associated with a non-residential building, responsible
staff might include building owners or management
agents.
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Part 1
. Lead in Drinking Water Overview
Section 1
Background
Information
This section provides general information concerning
the health effects of lead, how lead is used and distributed in
the environment, how lead gets into drinking water, why it
may be a problem in your facility, and, finally, how lead in
drinking water is regulated. This background information
should provide you with a framework for embarking upon
your own lead testing program.
Health Effects of Lead:
Why You Should Be Concerned
Lead is a toxic metal that can be harmful to human
health when ingested or inhaled. Even small doses of lead
I can be harmful. Unlike most other contaminants, lead is
stored in our bones, to be released later into the bloodstream.
Thus, even small doses can accumulate and become
significant. The groups most vulnerable to lead include
fetuses and young children.
Pregnant Women and Fetuses: Accumulated lead stored in
mothers may damage a child before it is born, causing a
lower birth weight and slowing down normal physical and
mental development. Recently published studies suggest that
even low levels in a mother may later affect an infant's
mental performance.
Young Children: Young children, especially those under the
age of six, are particularly sensitive to the effects of lead.
Because their bodies are still developing, small children
process lead differently than adults. Their growing bodies
tend to absorb more lead than an adult. Thus, lead can affect
them at smaller doses. Even at low levels of lead exposure,
children may experience lower IQ levels, impaired hearing,
reduced attention span and poor classroom performance. At
high levels, lead can seriously damage the brain.
Middle-aged Men and Women: Some recent studies have
found an association between blood-lead levels and slight
increases in blood pressure among adults. The relationship is
more marked in middle-aged men but is also significant for
middle-aged women. The significance of any lead-related
increases in blood pressure in connection to more serious
cardiovascular diseases remains to be determined.
The degree of harm from lead exposure depends on a number
of factors including the frequency, duration, and dose of the
exposure(s) and individual susceptibility factors (e.g., age,
previous exposure history, nutrition and health). In addition,
the degree of harm depends on one's total exposure to lead
from all sources in the environment—air, soil, dust, food,
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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Background Information
Industrial
Sources I
Old Lead
Paint
Imported
Dlnnerware
Lead
Plumbing
Distribution and Uses of Lead
L ** j
^xy-^Vv-^
Exhibit 1 Distribution and Uses of Lead
Lead is distributed in the environment through both
natural and man-made means. Today, the greatest
contributions of lead to the environment stem from past
human activities. As illustrated in Exhibit 1, sources that
produce excess lead exposure include the following:
• Lead based paint (which can flake off onto soil or be
ingested by children).
• Lead in the air (from industrial emissions).
• Dust and soil (lead deposits in soils around roadways
and streets from past emissions by automobiles using
leaded gas, together with paint chips and lead paint
dust, find their way into the mouths of young children
living in polluted environments).
• Lead in food (deposed from air onto crops or lead
glaze on imported dinnerware).
• Lead dust (brought home by industrial workers on (
their clothes and shoes).
• Lead in water (through corrosion of plumbing
products containing lead).
The U.S. government has taken steps over the past several
decades to dramatically reduce new sources of lead in the
environment (e.g., by banning the manufacture and sale of
leaded paint, by phasing out lead additives in gasoline, and
by encouraging the phaseout of lead seams from food cans).
More recently, the government has begun to attack existing
sources of lead in the environment. For example, programs
have been instituted to minimize the hazards posed by old
lead paint covering millions of homes across the United
States, more stringent air control standards are being applied
to industries emitting lead, and more stringent regulations are
in place to control lead in drinking water.
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Background Information
How Lead Gets into Drinking Water
Lead can get into drinking water in two ways: (1) by
being present in the water entering the treatment plant (i.e.,
source water) or (2) through an interaction of the water and
plumbing materials containing lead (i.e., through corrosion).
At the Source
Most sources of drinking water have no lead or very
low levels of lead (i.e., under 5 parts per billion). However,
lead naturally occurs in the ground and in some instances can
get into well water. Lead can enter surface waters (e.g.,
waters from rivers, lakes, streams) through direct or indirect
discharges from industrial or municipal wastewater 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 can be easily removed by
existing treatment plant technologies.
Through Corrosion
Most lead gets into drinking water after the water
leaves the local treatment plant or private well and comes
into contact with plumbing materials containing lead. The
physical/chemical interaction that occurs between the water
and plumbing is referred to as corrosion. The extent to
which corrosion occurs contributes to the amount of lead that
can be picked up by the drinking water.
As illustrated in Exhibit 2, drinking water comes into contact
with plumbing materials that may contain lead once the water
leaves the treatment plant. Some lead may get into the water
from the distribution system — the network of pipes that
carry the water to homes, businesses and schools in the
community. Some communities have lead components in
their distribution systems (i.e., lead joints in cast iron mains,
pipes, service connections, pigtails and goosenecks).
However, the public water supplier is responsible for making
sure that the distribution system under the utility's control
does not contribute harmful amounts of lead. See "How
Lead in Drinking Water is Regulated" in this section for
farther information on this topic.
Interior plumbing, soldered joints, and various drinking water
outlets that contain lead materials are the primary contributors of
lead in drinking water. Pictures of some of the common
drinking water outlets are reflected in Exhibit 3. The glossary
in Appendix B provides definitions of the various drinking water
outlets discussed in this document.
The critical issue is that even though your public water
supplier may send you water that meets all Federal and State
public health standards for lead, you may end up with too
much lead in your drinking water because of the plumbing in
your facility. That is why testing water from your drinking
water outlets for lead is so important.
Factors Contributing to Corrosion
What causes lead to possibly leach from your plumbing
into drinking water? Actually, no single situation or activity
causes this interaction. Rather, it is a combination of several
factors. The corrosion of lead tends to occur more frequently in
"soft" water (i.e., water that lathers soap easily) and acidic (low
pH) water. Other factors, however, also contribute to the
corrosion potential of the water and include water velocity and
temperature, alkalinity, chlorine levels, the age and condition of
plumbing, and the amount of time water is in contact with
plumbing. The occurrence and rate of corrosion depend on the
complex interaction between a number of .these and other
chemical, physical, and biological factors.
Public water system officials routinely undertake activities
aimed at controlling the corrosion characteristics of their
water supplies. Their treatment activities can lead to a
protective coating of minerals being formed on the inside
layer of pipes, thereby insulating the drinking water, in
effect, from lead. Given that the health effects of lead occur
at very low levels, these activities are critical. The activities
undertaken by individual homeowners and building
owners/operators to identify and remove problem plumbing
are also critical.
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Background Information
Exhibit 2 Sources of Lead in Plumbing
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Background Information
Water Cooler
Bubbler
Sources of Lead in
Drinking Water
Common sources of lead in
drinking water include;
• solder
• fluxes
• pipes and pipe fittings
• fixtures (e.g., brass faucets
containing alloys of lead)
• sediments
Faucet (Tap)
Exhibit 3 Common Drinking Water Outlets
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Background Information
How Lead in Drinking Water Is Regulated
Lead is regulated in drinking water under a Federal •
body of law known as the Safe Drinking Water Act
(SDWA). This Act was initially passed in 1974 and, in part,
requires EPA to establish regulations for known or potential
contaminants in drinking water for the purpose of protecting
public health.
The regulations developed by EPA are aimed at public water
systems. These systems are defined as those with 15 or
more service connections in operation at least 60 days a year
or systems serving 25 or more persons daily at least 60 days
a year. Schools or non-residential buildings that own or
operate their own water supply and that meet this or the
State's definition of a public water supply are subject to the
provisions of the SDWA. Facilities in this position should
already be knowledgeable of their legal responsibilities. Any
questions in this regard should be directed to the appropriate
State drinking water office. See Appendix A for a directory
of State programs.
Major amendments were passed to the SDWA in 1986.
These amendments include some specific provisions for
controlling lead in drinking water:
• A new regulation by EPA to minimize the corrosivity
and amount of lead in water supplied by public water
systems (known as the Lead and Copper Rule).
• A requirement that only lead-free materials be used in
new plumbing and in plumbing repairs (called the
Lead Ban).
• A one-time lead public notification requirement.
In 1988, Congress passed the Lead Contamination Control
Act (LCCA), which further amended the SDWA. The
LCCA is aimed at the identification and reduction of lead in
drinking water at schools and day care facilities.
The SDWA
Amendments of
1986
• Require lead to be
further minimized
(Lead & Copper Rule)
Require materials
used In the repair
or constructkDn of
plumbing to be
tead-free
(Lead Ban and
Lead Public Notice)
**
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Background Information
Public Water
Systems Lead
and Copper Rule
8-
In June 1991, EPA. revised the National Primary
Drinking Water Regulation for lead (by promulgating the
Lead and Copper Rule). The regulation requires public
water systems to take 1-liter tap water samples at
representative high-risk residences served by the system.
The total quantity and dates by which the samples are to be
taken are specified in the regulation and are based on the
total population served by the public water system.
If 10 percent or more of the tap samples exceed an action
level of IS parts per billion (ppb) or micrograms per liter
(fig/I), then the public water system must conduct additional
monitoring, implement or enhance corrosion control
I programs, educate consumers served by the system about
lead, and possibly replace lead service lines owned by the
system, if they exist.
Requirement that
Only Lead-Free
Materials be Used in
New Plumbing and in
Plumbing Repairs
(Lead Ban)
This provision of the SDWA requires 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.
Solders and flux are considered to be lead-free when they
contain less than 0.2 percent lead. (Before this ban took
effect in 1986, solders used to join water pipes typically
contained about SO percent lead.) The Lead Ban requires
that any lead solders carry a warning label indicating that
they are not to be used in connection with potable water
plumbing. Pipes, pipe fittings, faucets, and other fixtures are
considered lead-free under the Lead Ban when they contain
less than 8 percent lead.
If you purchase your water, you may wish to
contact your public water system to determine whether the
system is in compliance with the National Primary
Drinking Water Regulation for lead. Ask system officials
to explain the results of their lead tap water sampling
efforts and whether 10 percent or more of these samples
exceeded EPA's action level of IS ppb. If so, ask them
what corrosion control measures are being taken to ensure
that the drinking water delivered to consumers will
minimize lead exposure. Your water supplier may be
able to give you a good indication of what you might
expect in terms of lead problems in your building, based
on the utility's knowledge of the water supply and lead
issues in general. Your water supplier may also be
willing to assist you in conducting a lead testing program
at your facility, although there is no requirement that they
provide this service. A summary of topics to discuss with
your water supplier is included in the Sample Plumbing
Profile Questionnaire on page 14.
Under the Lead Ban, States were to adopt a version
of the prohibition that is at least as stringent as the Federal
version by June 1988. To date, all States have a lead-free
plumbing materials requirement in place that is at feast as
stringent as the Federal version. All major national
plumbing codes have also incorporated these requirements.
You may wish to contact your local plumbing code officials
to ascertain which code(s) is used in your area, if any.
Typically, codes are required on a statewide or smaller
jurisdictional basis. In any event, the codes should reflect
either the national or State lead-free plumbing requirements.
As another measure, check with plumbers or contractors
who are making additions or repairs to any plumbing in your
facilities to ensure that only lead-free materials are being
used. Test kits may be available to determine the presence
of lead solder in plumbing. Any violations of the lead-free
requirements should be reported to State officials (see
Appendix A). You should also insist that any lead materials
used in new construction or recent repairs be replaced with
lead-free materials.
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Background Information
One-Time Lead
Public Notification
Requirement
The SDWA also required that all public water systems
provide a one-time special notice by June 1988 to educate their
customers about the lead-in-drinking-water issue. The format
and content of these notices were specified by EPA. The intent
behind the notices was to inform consumers about the lead-in-
drinking-water issue, about the steps their water system was
taking to reduce opportunities for lead exposure, and about steps
that could be taken in the home to minimize exposure.
The Lead
Contamination
Control Act
(LCCA)
The LCCA required that a number of activities be
conducted by Federal and other parties to identify and correct
lead-in-drinking-water problems at schools and day care
facilities. A listing of some of the major activities and
parties responsible is provided in Exhibit 4. One principal
activity to be conducted by EPA was the development of a
guidance document and testing protocol that could be used by
schools to determine the source and degree of lead
contamination problems and how to remedy such
contamination if found. This document reflects EPA's
second edition of the guidance manual and testing protocol
developed in response to the LCCA.
At the time the LCCA was passed, considerable attention was
being given to water coolers with lead-lined tanks. The law
defined these sources as "imminently hazardous consumer
products." As a result, the legislation specifically stated
requirements to result in the repair, replacement, or recall
and refund of these water coolers and attached civil and
criminal penalties to the manufacture and sale of any drinking
water cooler containing lead. See Appendix Cfor a summary
of-water cooler issues, how to identify whether you have a
problem cooler, and what steps can be taken if you do.
While the LCCA was geared toward identifying and remedying
lead contamination problems in school and day care drinking
water, lead may also pose problems in other buildings. EPA,
therefore, advocates that the owners and/or managers of non-
residential buildings also conduct testing of drinking water
outlets. Since the lead testing protocol to be followed is the
same for non-residential facilities as for school buildings, this
guidance manual has been addressed to representatives of both
facilities. EPA has a separate manual available that
demonstrates how to test drinking water for lead in small
nursery schools and day care facilities. In addition, EPA has a
brochure for homeowners that are interested in testing their
water for lead. See Appendix D for a listing of lead testing and
other information available from EPA.
Since some States and local jurisdictions have
established programs for testing lead in schools and other
buildings, it is to a school or non-residential building
owner/manager's advantage to learn whether additional
requirements beyond those summarized in this section
exist. Consult your State or local education or drinking
water program to learn whether statewide or local
legislation is in effect that relates to lead testing in scl
and/or non-residential buildings. See Appendix A for a
list of State contacts.
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Background Information
Exhibit 4
Key Provisions of the LCCA
EPA
Publish a list of each brand and model of water cooler that is not lead-free, including a separate list
of the brand and model of water coolers with a lead-lined tank and distribute lists to States.
Publish a guidance document and testing protocol to assist schools in determining the source and
degree of lead contamination in school drinking water supplies and in remedying such contamination.
(Document is to, in part, include a testing protocol for identifying coolers that may contribute lead to
drinking water.)
EPA and States •
Publish and make available to the public upon request a list of laboratories certified by EPA (or the State
if the State has been delegated certification authority) to conduct analyses of lead-in-drinking-water.
Consumer
Product Safety
Commission
kJCPSC)
Issue an order requiring manufacturers and importers of water coolers with lead-lined tanks to repair,
replace, or recall and provide a refund for such coolers.
Water Cooler
Manufacturers,
Importers, and
Others
Do not sell in interstate commerce, or manufacture for sale in interstate commerce, any drinking
water cooler listed by EPA or any cooler that is not lead-free, including a lead-lined cooler. (Civil
and criminal penalties are associated with violations.)
States and
Local
Governments
Provide for the dissemination to local educational agencies, private nonprofit elementary or secondary
schools, and day care centers EPA's guidance document and testing protocol and list of water
coolers.
Establish a program to assist local educational agencies in testing for and remedying lead
contamination in drinking water from coolers and other sources of lead contamination at schools
under the jurisdiction of such agencies.
Make available any lead testing results in the administrative offices of the local educational agency
for inspection by the public, including teachers, other school personnel, and parents.
Notify parent, teacher, and employee organizations of the availability of lead testing results.
Repair, replace, permanently remove, or render inoperable water coolers that are not lead-free and
that are located in schools, unless the coolers are tested and found (within the limits of testing
accuracy) to not contribute lead to drinking water.
11
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Preliminary Assessment and General Testing Strategy
Section 2
Preliminary
Assessment
and General
Testing Strategy
Now that you understand the potential dangers of lead
contamination in drinking water and about the laws and'
programs in place to address this problem, it is time to
consider assessing what steps you might take in your facility
to identify and correct any sources of lead. The testing
protocol EPA recommends that you undertake includes such
activities as:
(1) Development of a plumbing profile.
(2) Development of a sampling plan.
(3) Conduct of initial and follow-up sampling and analysis
of test results.
(4) Determination of interim and long-term remedies.
(5) Communication of lead testing results and, if applicable,
corrective measures to the building community.
The first two activities can be considered part of the planning
or building assessment stage and are described in this section.
Steps 3 and 4 involve testing and correction of problems and
are described in greater detail in the next two sections; the
testing protocol for various types of drinking water outlets is
presented in Part 2 of this document. Finally, Step 5
represents a communication activity to let those members of
your building community know what you are doing to protect
them from possible exposure to lead in drinking water. This
subject is discussed in Section 5 of this Part.
Development of a Plumbing Profile
Before testing and correcting lead problems, it is
useful to assess the factors that can contribute to lead
contamination and the extent to which contamination might
occur in your facility. You can best accomplish these
objectives by developing a plumbing profile of your building.
Conducting a survey of your building's plumbing will enable
you to:
• Understand whether you may have a widespread
contamination problem or only localized concerns.
• Identify and prioritize sample sites.
• Plan, establish, and prioritize remedial actions, as
necessary.
Exhibit 5 consists of a questionnaire that has been designed to
help you plan your testing strategy. Planning your strategy will
enable you to conduct testing in a cost-efficient manner. Exhibit
6 provides interpretations of possible answers to the
questionnaire to aid you in developing your sampling plan. The
extent to which all questions can be answered will greatly aid
you in carrying out your sampling program.
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Preliminary Assessment and General Testing Strategy
Exhibit 5 Sample Plumbing Profile Questionnaire
Sample Plumbing Profile Questionnaire
The following questionnaire will help you determine whether lead is likely to be a
problem in your facility and, if so, whether these problems are likely to be localized or wide-
spread. These determinations will enable you to prioritize your sampling effort based on those
outlets you believe to pose the greatest risks. The significance of your answers to these questions
is discussed in Exhibit 6 entitled, What Your Answers to the Plumbing Profile Mean.
(1) When was the building constructed?
(2) After the construction of the original building, were any new buildings or additions
added? If so, when? If built since 1986, were lead-free plumbing and solder used in
accordance with the lead-free requirements of the 1986 Safe Drinking Water Act?
(3) When were the most recent plumbing repairs made (note locations)?
(4) With what materials is the service connector made?
(5) Specifically, what are the potable water pipes made of in your facility (note the locations)?
(6)
(7)
(8)
(9)
Lead
Galvanized Metal
Copper
Plastic
Brass
Other
What materials do the solders connecting the potable water pipes in your system contain
(note locations with lead solder)?
Are brass fittings, faucets, or valves used in your drinking water system (note the loca-
tions)?
How many of the following outlets provide water for consumption (note the locations)?
Water Coolers
Ice Makers
Bubbler
Kitchen Taps
What brands and models of water coolers currently provide water in your facility (note the
locations)?
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Preliminary Assessment and General Testing Strategy
(10) Do the faucets have accessible screens (note locations)?
(11) Have these screens been cleaned (note* locations)?
(12) Can you detect signs of corrosion, such as frequent leaks, rust-colored water, or stained
dishes or laundry?
(13) Is any electrical equipment grounded to water pipes (note locations)?
(14) Have there been any complaints about bad (metallic) taste?
(15) Check building files to determine whether any water samples have been taken from your
building for any contaminants (check with your public water supplier).
Name of contaminant(s)?
Were samples tested for lead?
What concentrations of lead were found?
What is the pH level of the water?
Is testing done regularly at your facility?
(16) Who supplies your facility's drinking water?
If your facility purchases its water, you should ask your public water supplier:
• Is the water supply in compliance with Federal and State standards for lead?
• What are the results of the system's tap water sampling efforts?
• Have 10 percent or more of these samples exceeded EPA's action level for systems
of 15 ppb?
• What is the system doing to minimize corrosion?
Are the system's treatment practices likely to have resulted in a protective coating
being formed on the inside of water pipes in your facility?
• Does the water distribution system have any lead piping, and does the system plan
to remove these sources of lead?
14
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^1552f!2!L!!!^
What tap samples have been taken for lead?
What
were the results of tap sampling and are there prob.ems?
Is the water being treated to minimize ^^
For what other conditions is the water being treated?
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Preliminary Assessment and General Testing Strategy
Exhibit 6 What Your Answers to the Plumbing Profile Mean
What Your Answers to the Plumbing Profile Mean
This exhibit discusses the significance of possible answers to the plumbing profile
questionnaire appearing in Exhibit 5. This discussion illustrates that a variety of factors
affect the extent of lead contamination including: (1) the corrosiveness of the water
supply; (2) the. amount of lead contained in the plumbing, taps, or outlets dispensing
water (i.e., age and condition of the plumbing); (3) the contact time between the water
and the materials containing lead; and (4) whether electrical systems are grounded to
water pipes.
(1) When was the building constructed?
Old Buildings—Up through the early 1900s, 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 19SO, galvanized pipes were also used for
plumbing. After 1930, copper generally replaced lead as the most commonly used
material for water pipes. Up until the mid- to late-1980s (until the lead-free require-
ments of the 1986 Safe Drinking Water Act took effect), lead solders were typically used
to join these copper pipes. The efforts of your public water supplier over the years to
minimize the corrosiveness of the water may have resulted in mineral deposits forming a
coating on the inside of the water pipes ( scaling ). This coating insulates the water from
the plumbing and results in decreased lead levels in water. If the coating does not exist
or is disturbed, the water is in direct contact with the lead in the plumbing system.
(2) Are there any new buildings or additions? If so, when were they built? Were lead-free
plumbing and solder used?
New Buildings—New buildings are not likely to have lead pipes in their plumbing
systems, but they are very likely to have copper pipes with solder joints. Buildings
constructed prior to the late 1980s, before the lead-free requirements of the 1986 Safe
Drinking Water Act, are likely to have joints made of lead solder. Buildings constructed
after this period should have joints made of lead-free solders. You should question the
solders used by plumbers who make repairs or additions to your facility. Report any
violations of the lead-free requirements to your local plumbing inspector or to the state
drinking water program. Furthermore, insist that any lead materials installed be replaced
by lead-free materials.
16
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Preliminary Assessment and General Testing Strategy
Some brass faucets, fittings, and valves, although they contain less than 8 percent lead in
the alloy as required under the SDWA,-can contribute a significant amount of lead to
drinking water. See a more detailed discussion of this issue under the response to
Question 7. Request lead leaching test results from the distributor or manufacturer
before purchasing any brass plumbing materials.
If lead-free materials were not used in new construction and/or plumbing repairs, very
high lead levels can be produced. If the water is non-corrosive, scaling may have
occurred (or be occurring) and will minimize lead exposure. However, if the mineral
coating does not exist, the lead is in direct contact with the water.
(3) When were the most recent plumbing repairs made?
Corrosion occurs (1) as a reaction between the water and the pipes and (2) as a reaction
between the copper and solder (metal-to-metal). This latter reaction is known as galvanic
corrosion. The reaction can be vigorous in new piping. If lead solders were used in the
piping or some brass faucets, valves and fittings containing alloys of lead were installed
(see response to Question 7 below for a further discussion of the brass issue), lead levels
in the water may be high. After about 5 years, however, this type of reaction slows down
and lead gets into water mainly as a result of water being corrosive. If the water is non-
corrosive, scaling is likely to have occurred and to have reduced opportunities for lead to
get into the water supply.
For these reasons, if the building (or an addition, new plumbing, or repair) is less than 5
years old and lead solder or other materials (e.g., brass faucets containing lead alloys)
were used, you may have elevated lead levels. If water supplied to the building is
corrosive, lead can remain a problem regardless of the plumbing's age.
(4) Of what materials is the service connector constructed?
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 a building. Some localities actually required the use of lead service
connectors up until the lead-free requirements of the 1986 Safe Drinking Water Act took
effect. Although a protective layering of minerals may have formed on these pipes,
vibrations can cause flaking of any protective build-up and, thus, allow lead contamina-
tion to occur.
17
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Preliminary Assessment and General Testing Strategy
(5) What materials are used in your facility's water pipes? and
(6) What materials compose the solder connecting your pipes?
»
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:
Lead pipes are dull gray in color and may be easily scratched by an object such as a
knife or key. Lead pipes are a major source of lead contamination in drinking water.
Galvanized metal pipes are gray or silver-gray in color 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 in color. Corroded portions may show green deposits.
Copper pipe joints were typically joined together with lead solders until the lead-free
requirements of the 1986 Safe Drinking Water Act took effect. Full implementation of
these lead-free requirements 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 NSF International standards and are free of plasticizers that
contain lead. (Note: NSF International is an independent, third-party testing organiza-
tion; copies of NSF International standards can be obtained by writing NSF Interna-
tional, 3475 Plymouth Road, P.O. Box 1468, Ann Arbor, MI 48106.)
(7) Any brass fittings, faucets, or valves?
Brass pipes, fittings, faucets, and valves are golden yellow in color, similar to copper in
appearance, or 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. While this percentage is considered lead-
free under the 1986 Safe Drinking Water Act, some contamination problems still may occur.
In addition, some older brass faucets may contain higher percentages of lead and lead solder
in their interior construction and pose contamination problems.
«
18
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Preliminary Assessment and General Testing Strategy
The degree to which lead will leach from brass products containing alloys with less than
8 percent lead is dependent upon the corrosiveness of the water and the manufacturing
process used to develop the product. A recent study comparing the lead leaching
performance of several faucets manufactured under different processes and having
various lead contents revealed that fabricated faucets tend to contribute less lead to the
water than faucets manufactured by the permanent mold process, regardless of the amount
of lead in the alloy.
EPA is working with industry and a private, third-party testing organization toward the
development of a voluntary industry standard on this issue that would result in minimal
amounts of lead being leached from these products. If you purchase any brass plumbing
products, ask the distributor or manufacturer to provide information about tests it has
performed on the product. Refrain from buying any product from a manufacturer that is
unwilling to provide the testing information.
(8) What types of drinking water outlets are located in your facility?
In addition to lead components in the plumbing system, lead solders or lead in the brass
fittings and valves used in some taps, bubblers, and refrigerated water coolers may be
sources of lead. It is important to identify the locations of all such drinking water
outlets.
(9) What are the brand and model of the water coolers?
Water coolers may be a major source of lead contamination. Under the Lead Con-
tamination Control Act of 1988, water coolers with lead-lined tanks are considered to be
imminently hazardous consumer products, and manufacturers and importers are to
repair, replace, or recall these coolers. 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 that may come into contact with drinking
water are not to contain more than 8 percent lead. In addition, the law attaches criminal
and civil penalties for the manufacture and sale of water coolers containing lead.
The CPSC negotiated an agreement with Halsey Taylor through a consent order agreement
published in June 1990 to provide a replacement or refund program that addresses all the
water coolers listed by EPA as having lead-lined tanks. Halsey Taylor was the only company
identified by EPA as manufacturing some water coolers with lead-lined tanks.
19
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Preliminary Assessment and General Testing Strategy
See Appendix C of this manual for a summary of EPA's list of water coolers found to
contain lead. Use the list to help prioHtize your sampling. If your water cooler is listed
as having a lead-lined tank, do not use the water for drinking and sample the water
immediately (seepage 63 for sampling instructions) as these coolers pose the highest risk
of contamination.
(10) Do the faucets have accessible screens? and
(11) Have the screens been cleaned?
Lead-containing sediments that 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.
(12) Are there signs of corrosion?
Frequent leaks, rust colored water, and stains on fixtures, dishes, and laundry are signs of
corrosive water. 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.
(13) Is any electrical equipment grounded to the water pipes?
If electrical equipment, such as telephones, has been installed using water pipes as a.
ground, the electric current traveling through the ground wire will accelerate the corro-
sion of any 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 building inspector on this matter. Your State
or local building code may require grounding of the wires to the water pipes. Improper
grounding of electrical equipment may cause severe shock.
(14) Have there been complaints about bad (metallic) taste?
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.
4
20
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Preliminary Assessment and General Testing Strategy
(15) When was the water in your building last tested for contaminants, if ever?
Results of analyses of water quality, such as measures of pH, calcium hardness, and
carbonate alkalinity, can provide important clues about the corrosiveness of the water. If
your facility owns or operates its own water supply, such test results can help you decide
on effective treatment approaches. 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 upon your water quality conditions.
If your facility purchases its water, contact your public water supplier to find out what
they are doing to comply with the National Primary Drinking Water Regulation for lead.
See also the response to Question 16 below for further information. It is important to
know whether and how the water entering your facility is treated. Some kinds of treat-
ment can make the water more corrosive, while others will reduce the problem. Treat-
ment of 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.
(16) Who supplies your facility's drinking water?
Answers to the types of questions included on the plumbing profile questionnaire will
give you an idea of the type of water you are receiving. From this assessment, you will
then have a better sense of how to organize your testing activities.
If your facility purchases its water, contact your public water supplier to:
• Find out whether the system is in compliance with Federal and State lead require-
ments.
• Learn the results of the system's latest tap water sampling efforts and whether 10
percent or more of these samples have exceeded EPA's action level of 15 ppb (i.e.,
what are the typical lead levels in water being delivered throughout the commu-
nity).
• Learn what activities the system employs to minimize the corrosiveness of the
water supply; identify what type of water you might be receiving in your facility
(e.g., is it corrosive or non-corrosive water? Is the water soft or acidic?).
21
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Preliminary Assessment and General Testing Strategy
• Learn whether protective coatings are likely to have formed on the inside of your
plumbing based on the treatment practices of the public water supplier. Identify
whether the water distribution system contains lead pipes and whether/when the
water system plans to remove these lead materials.
If your facility owns or operates its own water supply, you should already be aware of
your legal requirements to control corrosion and minimize lead at the tap. If you are
uncertain of your responsibilities, contact your State drinking water program (see Appen-
dix Afar a directory of State programs). Some of the questions you might pose to the
treatment operator include:
• Is the system in compliance with Federal and State requirements for lead?
• Where were tap water samples collected in the building, and what are the results of
this sampling effort?
• Does the facility have a lead problem on the basis of the tap'water samples?
• Is the water system being treated for corrosion purposes? Are there any other
types of treatment being pursued that could contribute to lead getting into the
water supply?
22
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Preliminary Assessment and General Testing Strategy
After reviewing the plumbing profile questionnaire and
background regarding what your answers to the profile could
mean (Exhibits 5 and 6), you have learned that lead
contamination may not occur uniformly throughout a
building. Large variations in lead concentrations may be
found among individual outlets in a facility because of
differences in flow rates and/or building materials.
In general, you can expect widespread lead contamination
in your drinking water when:
• The building's plumbing is less than 5 years old and
lead solder was illegally used (i.e., after the "lead-
free" requirements of the 1986 Safe Drinking Water
Act took effect).
• Brass fittings, faucets, and valves were installed
throughout the building less than 1 year ago (even
though they may contain less than 8 percent lead as
required under the lead-free requirements of the Safe
Drinking Water Act).
• The water is corrosive.
• Sediment in the plumbing and screens contains lead.
• Lead pipes are used throughout the building.
• The service connector (i.e., the pipe that carries water
from the public water system main to the building) is
made of lead.
In general, you can expect localized contamination if:
• The water is non-corrosive.
• Lead pipes are used in some locations.
• Some brass fittings, faucets, and valves have been
installed in the last year (even though they may contain
less than 8 percent lead).
• Numerous lead solder joints were installed in short
sections of pipe before 1986 or were illegally installed
after 1986 (i.e., after the lead-free requirements of the
Safe Drinking Water Act took effect).
• There are areas in the building's plumbing with low
flow or infrequent use.
• Sediment in the plumbing and screens at isolated
locations contains lead.
• Some water coolers have lead parts or contain lead-
lined tanks (consult Appendix Cfor a discussion of the
water cooler issue and EPA's listing of coolers).
Development of a Sampling Plan
After identifying potential problem areas in your
facility, through completion of a plumbing profile, the next
step is to have the water tested. Testing is the only sure way
to know whether lead is a problem in your facility.
However, it is first useful to develop a sampling plan before
embarking on the actual testing. The sampling plan activity
will enable you to approach taking water samples in a
systematic fashion. Key issues to consider in devising a
sampling plan include the following:
• Who will be in charge of the sampling effort?
• Who will collect and analyze samples and maintain
records?
• Where will the samples be taken?
Leadership for
Sampling Effort
It is important to designate a leader to take full
responsibility of the sampling program and to ensure that it is
conducted properly. If outside consultants or laboratory
representatives are used to conduct testing, you must first
ensure that they understand and are knowledgeable of the
testing protocol described in this manual. Contact your State
or local health department or drinking water program if you
need advice on how to identify a reputable consultant.
23
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Preliminary Assessment and General Testing Strategy
Collection and
Analysis of Samples
and Recordkeeping
Requirements
Deciding who will collect samples will be based, in
part, on who will analyze the samples. Some State drinking.
water programs or public water suppliers may provide both
services, although there is no requirement that they do so. In
general, most facilities will need to contract with an
analytical laboratory to conduct analyses of any samples
collected. There are some important considerations when
hiring a laboratory. First, the laboratory should be certified
by the State or EPA to conduct drinking water analyses.
Contact your State drinking water program (Appendix A) or
EPA's Safe Drinking Water Hotline (Appendix D) for a list
of certified labs in your area. Once you have identified
possible laboratories, consider the following issues prior to
making a selection:
• Will the lab take samples for you or will they provide
training and sample containers for collectors
designated by you? If you will use your own sample
collectors, be certain to secure sample training from
the laboratory to ensure that your test results will be
reliable. Testing activities can be useless if sample
collectors do not follow proper sampling procedures.
• What is the lab's knowledge of the lead testing protocol
for schools and non-residential buildings? This protocol
is described in the next section. Make sure laboratories
thoroughly understand this protocol and do not confuse it
with the lead testing protocol used by public water
suppliers (for whom the labs may also work), because the
two protocols are different. Ask the lab for references of
other facilities for whom it has provided lead testing
services. Contact these facilities to ascertain the quality
of tfie lab services provided.
What is the cost of the lab's services? Costs for
laboratory analysis of samples should range between
$10 and $30, depending upon the extent of the services
to be provided (e.g., if only analyses are conducted or
if other services such as sample collection are
provided). You may want to contact several labs to
compare prices and services. In most cases, labs will
charge less per sample if they have numerous samples
to test. You might consider combining your lead
testing efforts with those of another facility to secure a
possible bulk analytical rate from a particular lab.
What is the lab's time frame for providing sample
results?
What documentation will the lab provide to note
sample results, and how will this material aid you in
maintaining records for each outlet tested? Record
keeping is a crucial activity. If lead contamination
problems are found, sample records and test results
will assist you in pinpointing the sources of problems.
Be certain to have control over the development and *
maintenance of records. Appendix E contains a
sample recordkeeping form and identifies the type
information you should consider recording.
Establish a written agreement or contract with the
laboratory for all of the services to be provided.
Although actual costs or laboratory analysis of
samples may range for $10 to $30 per sample, other
costs must also be considered (e.g., costs of personnel to
profile the plumbing system, design the sampling plan,
collect samples, and determine and implement remedies).
These costs are highly site-specific and depend on a
number of factors including the size of your facility, the
number of drinking water outlets being tested, and
technicians* salaries. One school system in New York
estimated total costs for their sampling effort to range
from $2,190 to $3,295 per school. This estimate
assumed 40 personnel hours for every 60 samples
collected and also included lab analytical costs.
24
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Preliminary Assessment and General Testing Strategy
Determining
Sample
Locations
You must decide, based on your responses to the
plumbing profile and your knowledge of the facility, where ,
to take samples and how to prioritize the sample sites. If
resources for testing are limited, this is an especially crucial
step. Generally, testing should be conducted at those outlets
that are most likely to have contamination since they would
represent the greatest hazards to human health. Samples sites
that are most likely to have lead contamination include:
• Areas containing lead pipes.
• Areas of recent construction and repair in which lead
solder or materials containing lead were used.
• Areas where the plumbing is used to ground electrical
circuits.
In buildings where corrosive water having low pH and
alkalinity is distributed.
• Water coolers identified by EPA as having lead-lined
storage tanks or lead parts.
• 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).
It may be helpful to diagram the plumbing in your facility
and the outlets that will require testing. The configuration of
interior plumbing can vary depending on the layout of a
given building. Examples of plumbing configurations for a
single-level building and a multilevel building are illustrated
in Exhibits 7 and 8, respectively. Locate service connectors,
headers, laterals, loops, drinking water fountains (bubblers
and coolers), riser pipes and different drinking water loops
(see Appendix Bfor a glossary of these plumbing terms), and
decide in what order you wish to take samples.
In multistory 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 water
fountains, and other outlets. For sampling purposes, water
within a plumbing system moves "downstream" from the
source (i.e., from the distribution main in the street through
the service connection and through the building).
25
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Preliminary Assessment and General Testing Strategy
2*h
£B£§
§5§E
Exhibit 7 Plumbing Configuration for a Single-Level Building
-------
Preliminary Assessment and General Testing Strategy
Exhibit 8 Plumbing Configuration for a Multilevel Building
27
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Two-Step Sampling Process
Section 3
Two-Step Sampling
Process
EPA recommends that a two-step sampling process or
protocol be followed for identifying lead contamination,
especially in large buildings where many samples are to be
taken. In the first step, screening samples are collected 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. The results of initial and follow-up
samples are then compared to determine the sources of lead
contamination and to determine appropriate corrective measures.
This protocol is not to be used to determine whether a
water supplier meets Federal lead standards. You should
be certain that any analytical laboratories or consultants
conducting testing on your facility's behalf are aware that this
protocol differs from the protocol to be used by public water
suppliers. The, protocol described in this booklet is intended
to facilitate the identification of sources of lead causing
contamination problems in single outlets. The testing
protocol to be used by public water suppliers (i.e., under the
Lead and Copper Rule or National Primary Drinking Water
Regulation for lead) is designed to identify system-wide
problems.
The testing protocol described in this section has been field
tested and found to provide results that are generally reliable.
Despite the fact that lead levels of samples taken at various
times from the same sample site may vary, the results will
generally be similar.
Overview of the Two-Step Sampling Process
This section provides a brief definition and overview
of the purpose of each of the two steps in EPA's lead testing
protocol.
Step 1:
Initial Sampling
In Step 1, initial screening
samples are taken to
determine (1) the lead content
of water entering your
facility and (2) the lead
content of water sitting in
various outlets within your
building. The goal of Step 1
is to identify problem
outlets or outlets with high
lead concentrations.
To determine the lead content in water entering your facility,
contact your public water supplier to identify what lead
your might expect. (If you completed the plumbing profii
questionnaire discussed previously, you will already have this
information.) Second, test water representative of your
service connector to determine what contribution the
connector is making to lead concentrations in your building.
Obviously, if the water coming into your facility or through
your service connector contains excessive amounts of lead,
you are likely to see similar or even greater amounts of lead
when you test individual drinking water outlets.
For individual outlets, initial samples generally involve the
collection of "morning, first-draw" water. Such samples
consist of the first "plug" of water emitted from an outlet
after the outlet has been sitting for a period of 8 hours or
more (see general collection procedures on page 50). As
you will recall, the longer water is in contact with plumbing
containing lead, the more opportunity exists for the water to
pick up lead. Morning, first-draw water most often contains
the highest concentrations of lead. Such samples will,
therefore, generally reflect the "worst case scenario" for a
given outlet.
28
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Two-Step Sampling Process
>20 ppb
The Trigger to
Follow-Up Testing
If initial test results
reveal lead concentrations
greater than 20 ppb for a
given outlet, follow-up
testing is recommended.
EPA has established this
numeric cut-off, or trigger to
follow-up testing to ensure that
the sources of lead
contamination in drinking water outlets are identified. The
protocol, which consists of an established sample size volume
and water retention time, is aimed at identifying lead
problems in outlets under "worst case" conditions.1
Step 2:
Follow-Up Sampling
In Step 2, follow-
up samples are collected
and analyzed from outlets
whose initial test results
revealed lead
concentrations greater
than 20 ppb. The
purpose of Step 2 is to
pinpoint where lead is
getting into drinking water so that appropriate corrective
measures can be taken. Additional samples from the interior
plumbing within the building are often necessary to further
pinpoint the sources of lead contamination.
As with initial samples, follow-up samples are to be taken
before a facility opens and before any water is used (see
general collection procedures on page 50). Follow-up
samples generally involve the collection of water from an
outlet where the water has run for 30 seconds. This
sampling approach is designed to analyze the lead content in
the water in the plumbing behind the wall and the outlet.
This is in contrast to the initial sample, which measures the
lead content of the water in the outlet itself. A comparison
of initial and follow-up samples will enable you to assess
where the lead may be getting into the drinking water: either
from the outlet or from the plumbing directly behind the
outlet. Exhibit 9 provides diagrams of some common
drinking water outlets and "cut-aways" of the plumbing
behind these devices.
Depending upon the number of outlets to be tested, both initial
and follow-up testing can be completed in one day, or initial
samples can be taken first with follow-up testing conducted once
initial test results are completed and interpreted.
The total number of samples to be taken from a building will
depend upon the size of the building, the number of outlets
used to supply drinking water, and the expected extent of
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 your drinking water. Part 2 of Ms
document contains the general procedures to be followed in
collecting samples and provides instructions for both initial
and follow-up testing by outlet type. The next section of this
Part explores the remedies than can be employed if lead
problems are found.
'Under the National Primary Drinking Water Regulation for lead, an action
level of 15 ppb is established for samples taken by public water suppliers in
high-risk residences. It is important to note that the testing protocol used by
public water suppliers is aimed at identifying system-wide rather than
individual outlet problems. Moreover, the sample size volume and water
retention time are different. As a result, the action level is lower for public
water suppliers than the level that is recommended under this testing
protocol for schools and non-residential buildings.
When the lab returns your test results, the
concentrations of lead in your drinking water samples wilt
be reported in metric form such as milligrams per liter
(mg/L) or micrograms per liter (pg/L), o£ they will be
reported as a concentration such as parts per million
(ppm) or parts per billion (ppb), respectively.
• One milligram is 1/1,000 of a gram (about the size
of a tiny pinch of salt); 1 mg/L is equal to 1 ppm.
• One microgram is one, one-millionth of a gram
(one thousand times smaller than a milligram);
1 pg/L equals 1 ppb.
• 0.005 mg/L or ppm is equal to 5 /tg/L or ppb (note
the movement of the decimal point).
29
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Two-Step Sampling Process
Connecting
Pip*
Water Cooler
Bubbler
Sources of Lead in
Drinking Water
Common sources of lead in
drinking water include;
• solder
• fluxes
• pipes and pipe fittings
• fixtures (e.g., brass faucets
containing alloys of lead)
• sediments
Faucet (Tap)
Exhibit 9 Common Drinking Water Outlets
30
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Remedies
Section 4
Remedies
Solutions to lead problems typically need to be made
on a short-term as well as permanent basis. For example,
there are steps you can take while you wait for your test
results or until a permanent solution has been put in place
that will successfully reduce lead levels. These types of
solutions are considered interim remedies. The solutions that
are long-term in nature are considered permanent remedies.
There is no set method for selecting remedies. The decision
to follow a particular approach must be based on the
age/condition of your plumbing, the nature of your water
supply, the results of testing, and the sources of lead
contamination. In other words, the selection of remedies is
highly site-specific and typically involves the conduct of
additional follow-up sampling. It is important that you
identify the sources of lead contamination through follow-up
testing before employing permanent remedies. There have
been instances where facilities proceeded to the remedy stage
conducting follow-up testing, only to later learn that
solution did not solve the lead contamination problem.
Outlined below are various routine, interim and permanent
remedies. To aid you in the process of selecting remedies, three
case studies have been included in Exhibits 11 through 13. The
intent of these case studies is to provide you with a sense of the
process involved in selecting a corrective measure and the role
of follow-up testing in pinpointing lead problems.
Routine Control Measures
In addition to employing short-term and permanent
remedies, a number of routine activities should be conducted
to avoid possible exposures to lead:
• Clean debris from all accessible screens frequently.
If you discovered sediments in faucet screens, have the
sediments tested for lead and continue to clean your
screens frequently. If your facility does not appear to
have a sediment problem, you should still continue to
periodically inspect your screens.
• Use only cold water for food and beverage
preparation in cafeterias and cooking classes. Hot
water will dissolve lead more quickly than cold water
and is likely to contain increased lead levels. If hot
water is needed, it should be taken from the cold water
tap and heated on a stove or in a microwave oven.
These procedures should be continued even if the lead
levels in your building are found to be low as a result
of testing.
Interim (or Short-Term) Control Measures
Until more permanent solutions bring lead levels
down, you should implement interim measures to reduce lead
contamination in your facility's drinking water. You might
consider implementing interim control measures while you
are waiting for your test results to return from the lab. You
might also consider implementing short-term measures while
you are waiting to see if more permanent solutions will
work. Before discontinuing any interim measure, you
should be certain (as a result of testing) that the lead
levels of your drinking water do not exceed 20 ppb. Some
examples of interim control measures include:
• "Flush" the piping system in your building. Do not
use water that has been in contact with your building's
plumbing for more than 6 hours, such as overnight or
after weekends and vacations. "Flushing" involves
opening all suspect taps every morning before the
facility opens and letting the water run for a period of
time to clear water standing in the interior pipes and/or
the outlets. The flushing time varies by the type of
outlet being cleared. The degree to which flushing
helps reduce lead levels can also vary depending upon
the age and condition of the plumbing and the
corrosiveness of the water. Below is a discussion of
the advantages and disadvantages of flushing. Review
this information before deciding whether flushing is
appropriate as a short-term remedy in your facility.
Flushing instructions by outlet type are presented in
Exhibit 10.
31
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Remedies
Exhibit 10 Flushing Directions by Outlet Type
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
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. This 10-minute time frame is considered
adequate for most buildings. However, if you are concerned that this flushing time is inadequate because of the size of
your building, the diameter of your pipes, and/or the intricacy of your piping system, you may wish to consult a local
plumber or engineer. The plumber or engineer could calculate a more exact flushing time period based on such factors
as length and diameter of pipe and volume and flow rate of water at the faucet (i.e., the faucet furthest away from the
service line).
(2) Open valves at all drinking water 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 IS minutes. Because of the long time period required,
routinely flushing refrigerated fountains may not be feasible. It may therefore be necessary to replace these outlets with
lead-free drinking devices.
(4) Open all kitchen faucets (and other faucets where water will be used for drinking and/or cooking) and let the water run
for 30 seconds.
Advantages:
Quickest and easiest solution to high lead levels,
especially when contamination is localized in a small
area or in a small building.
Does not require installation or maintenance of water
treatment equipment.
Does not require complex instructions.
Disadvantages:
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:
Flush pipes only after weekends or vacations when
lead levels may be highest (use only if lead levels
do not exceed 20 ppb on a daily basis).
Thoroughly flush several designated drinking
water outlets daily while taking all others
temporarily out of service.
Use bottled water.
Collect water being flushed and use for non-
consumptive purposes.
Another obvious disadvantage to flushing is the amount
of time and staff needed to perform the task:
If the water is very corrosive or if the plumbing is
new, flushing may need to be done more than once a
day, since lead levels in the water can return to high
levels very quickly. To determine the number of
additional flushes required, take additional follow-up
samples at the end of the business day. Depending
upon your test results, you may need to flush the
system twice daily — once in the morning before the
facility opens and a second time before a lunch
period. If lead levels return to their original levels
within 4 hours of flushing, flushing is not a
practical solution.
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Remedies
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.
Provide bottled water. This can be an expensive
alternative but might be warranted if you expect or are
aware of widespread contamination and flushing is not
an option. If you use bottled water, be aware that it is
not regulated by EPA but rather by the Food and Drug
Administration (FDA). The FDA typically adopts
standards for bottled water similar to those standards
established by EPA for public water systems. In
January 1993, the FDA published a proposal in the
Federal Register (at 58 FR 389) to lower the maximum
allowable lead concentration in bottled water from 50
ppb to 5 ppb. The final regulation, which is expected
to include the 5 ppb standard, is due to be published in
May 1994. This value should not be confused with
EPA's action levels of 15 vob for public water
suppliers and 20 ppb for schools and non-residential
buildings. These last values are associated with testing
protocols and are aimed at identifying lead
contamination problems.
Your State may also regulate bottled water, and, in
some instances, these standards may be more stringent
than the Federal requirements._EPA recommends
that you require a written statement from the
bottled water distributor guaranteeing that the
bottled water meets FDA and State standards.
Permanent Remedies
You can take a number of actions to permanently reduce
or eliminate the sources of lead that originate in your building's
plumbing. Some of these actions may allow the elimination or
reduction of routine flushing or other interim measures. After
obtaining an understanding of your water supply and the lead
conditions in your facility (as a result of testing), you need to
examine the permanent treatment options and select those most
appropriate to your situation. Obviously, your decision will be
based on such factors as cost, likelihood of success, availability
of water, and staffing requirements.
• Water that is soft or acidic can be treated by the
public water supplier to make it less corrosive. The
1986 Safe Drinking Water Act generally requires that
public water systems undertake actions to make their
waters non-corrosive if the results of a tap sampling
program reveal elevated lead levels. As recommended
earlier, contact your public water supplier to learn
what it is doing to minimize corrosion throughout the
system. If your water supplier just recently initiated .
corrosion control treatment, you might discuss the
period of time before such treatment will have a
possible effect on the lead in your facility. In the
interim, however, you should implement routine and
short-term remedies to reduce exposure to lead.
Finally, follow-up testing should be conducted after
corrosion control treatment begins before you rely on
this solution on a permanent basis.
If lead levels remain high (above 20 ppb), then you should
consider another type of remedy.
• Corrosion control devices for individual buildings,
such as calcite filters, soda ash or phosphate
solution tanks, and feeder units are commercially
available. These types of devices treat the water for
lead at the point where water enters the building (i.e.,
near the service connection). These devices are known
as point-of-entry (POE) devices and are most suitable
for facilities that provide their own water supply. POE
devices typically cost $900 to $2,500, depending on
the size of the building.
Facilities that provide their own water supply are
subject to the provisions of the 1986 Safe Drinking
Water Act, which means that they must make their
water non-corrosive to minimize lead at the tap. A
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Remedies
POE device is one possible corrosion control measure
such a facility could implement. Note: Facilities that
do not own their own water supply and are considering
a POE device as a permanent remedy should consult
the State drinking water program for guidance (see
Appendix A for a listing of State programs). In some
states, the installation of such a device might define the
facility as a "public water system" and, therefore,
make the facility subject to all applicable laws.
You should consider a number of factors when selecting a
device for your facility, including the devices' records of
performance to reduce corrosion. Typically, a
manufacturer will recommend a practical maintenance
program once a device is installed. A good maintenance
and quality assurance program is important for ensuring
that the device performs as it is intended.
Note: Carbon, sand, cartridge filters, and water
softeners will not prevent corrosion.
Lead levels can be reduced at the tap. Reverse
osmosis and distillation units are commercially
available and can be effective in removing lead. Since
these devices also make the water corrosive, they
should only be used when placed at the tap. Such
placement means the devices only treat the water at the
outlets where they are placed. Such devices are
termed point-of-use (POU) devices. There are a
number of POU cartridge filter units on the market that
effectively remove lead.
POU devices can be either purchased or leased. They
can be fairly inexpensive ($65 to $280) or expensive
(ranging from $250 to $500, and up to $2,100 for a
computerized reverse osmosis treatment unit), their
effectiveness varies, and they are vulnerable to
vandalism. Like POE devices, they also require a
maintenance contract for regular upkeep to ensure
effectiveness. Cartridge filter units need to be replaced
periodically to remain effective. NSF International, an
independent, third-party certification organization, has
a testing program to evaluate the performance of POU
devices. Before purchasing any device, contact NSF
International at 3475 Plymouth Road, P.O. Box 1468,
Ann Arbor, MI 48106.
Existing wires already grounded to the water pipes
can possibly be removed by a qualified electrician,
and an alternative grounding system be installed.
Electrical current accelerates the corrosion of lead in
piping materials. If your local or State building codes
allow, consider finding an alternative grounding system
and have a qualified electrician make the change. Be
aware that the 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. Note that some
new brass fixtures, valves and fittings, even though
they contain less than 8 percent lead under the "lead-
free" requirements of the 1986 Safe Drinking Water
Act, can leach sufficient amounts of lead in drinking
water to warrant concern. In fact, these products may
leach more lead than the old plumbing product because
the water has not had time to build up a protective
scale on the inside of the fixture.
EPA is currently working with industry to develop
voluntary certification standard that will minimize
leaching from brass plumbing products. In the
meantime, you should request the distributor and/or
manufacturer of any product you intend to purchase for
the results of any lead testing studies. Refrain from
purchasing any products from a manufacturer that is
unwilling to provide you with lead testing information.
Lead pipes within the system and those portions of
the lead service connectors under the water
supplier's jurisdiction can be replaced. Contact your
public water supplier about this replacement.
However, your facility 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 facilities, the plumbing system might be
modified so that water supplied for drinking or
cooking is redirected to bypass sources of lead
contamination. Before undertaking such an
alternative, be certain of the sources of lead
contamination. Follow-up testing would also be
necessary, as with the other remedies, to ensure that
the measure results in reduced lead levels at the tap.
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Remedies
Flushing individual problem outlets or all outlets
may also represent a 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. See the Short-term
Remedies section above for a discussion of the
advantages/disadvantages of this remedy in addition to
outlet flushing instructions. Review this information
before deciding whether flushing is appropriate as a
permanent remedy in your facility.
Time-operated solenoid valves can be installed and
set to automatically flush the main pipes (headers)
of the system. It is important to note that solenoid
valves are not practical for flushing water coolers.
These would need to be flushed manually by staff. See
Short-term Remedies section above for flushing
instructions for water fountains.
If other treatment fails or is impractical, bottled
water can be purchased for consumption by the
building community. As noted under the short-term
remedies section above, make sure that the bottled
water you select meets Federal and/or State standards
for lead and other drinking water contaminants. EPA
recommends that you require a written statement from
the bottled water distributor guaranteeing that the lead
levels in the water do not exceed 5 ppb.
Make sure that any plumber who does repair or
replacement work on the faculty's plumbing system
uses only "lead-free" solders and other materials.
The 1986 Safe Drinking Water Act requires that only
"lead-free" materials be used in new plumbing and
plumbing repairs. Make sure all plumbers and other
workers adhere to these requirements. These actions
will ensure that new lead is not introduced into the
facility's plumbing system. Report any violations of
the "lead-free" requirements to your local plumbing
inspector or the State drinking water program (see
Appendix A for a directory of State programs).
Case Studies
The following three case studies are based on real-life
experiences and are intended to illustrate the types of remedial
actions that can be employed to eliminate/reduce lead at drinking
water outlets. The first two case studies involve facilities that
own or operate their own water supply and are, therefore,
subject to the requirements of the Safe Drinking Water Act.
The remaining case study involves a facility that purchases its
water from a public water system. For such facilities, it is
important that the water supplier be contacted to obtain
information regarding the quality of the water being distributed.
The remedies discussed in the following case studies include:
• Removal of outlets from service, replacement of outlets
with lead-free devices, system flushing, and follow-up
sampling (Case Study 1).
• Pipe and outlet replacement, testing of the source water,
and installation of point-of-entry treatment and corrosion
control (Case Study 2).
• Flushing, plumbing replacement, meter replacement, and
POU treatment-(Case Study 3).
These case studies demonstrate that follow-up testing is critical
to a successful lead abatement program. They also illustrate the
importance of planning sample collection efforts and profiling
the plumbing system. System profiling includes such activities
as inspecting all outlets to determine their make and model and
documenting the types, age, and location of piping and plumbing
fixtures. A lead sampling program, consisting of initial and
follow-up testing, involves pinpointing sources of lead problems
(thereby eliminating other sources from consideration) and, in
turn, identifying appropriate remediation measures.
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Remedies
Exhibit 11 Case Study 1
Case Study 1
This case study illustrates haw officials of one public school system, which owns and operates its
water supply, solved a lead problem. This example presents the school system's approach to
determining the sources of lead and selecting corrective measures. The remedies employed
included replacement of problem outlets with lead-free devices, flushing of outlets, and follow-up
sampling.
Study to Determine Lead Sources and Levels
The public school system, together with the county health department, conducted a study to
measure potential lead contamination at drinking water outlets in 33 buildings. The study was
conducted in two phases.
Develop Profile of the System
In Phase I of the study, a questionnaire was developed and used to generate a profile of each
school's plumbing system. All outlets used for drinking water and/or food preparation were
identified by (1) type of outlet (i.e., tap, bubbler, cooler or ice machine), (2) manufacturer of
outlet device, (3) model number of outlet device, and (4) serial number of outlet.
Conduct Testing
In Phase n of the study, outlets identified in Phase I were sampled for water lead content. The
results of lead testing revealed that IS percent of the outlets had lead levels above SO parts per
billion (ppb) and that 25 percent of the outlets had lead levels between 20 and 49 ppb. Follow-
up tests revealed no apparent lead problems in the internal plumbing systems of the 33 schools.
Samples taken of the source water were also found to contain no lead. Moreover, the water
supply was known to not be corrosive. Although this case study was based on a facility that
conducted testing prior to the finalization of EPA's Lead and Copper Rule for public water
systems, the school system would have ultimately been required to minimize lead throughout its
system under EPA's Lead and Copper Rule.
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Remedies
Issue Public Notice
At the conclusion of the study, the school system issued a public notice in the form of a memo-
randum to all staff, parents, and students in the affected schools. The public notice consisted of
the results of the Phase I survey and the Phase II test results, a statement ensuring that there was
no immediate health threat, information concerning the steps the school system was taking to
reduce water lead content, and an explanation of how test results could be obtained and reviewed.
The school system did not experience any problems or negative consequences with members of
the school community as a result of the lead public notice.
Determine and Install Remedies
Having conducted the survey and testing described above, the school system initiated immediate
actions to reduce or eliminate water lead content. These actions included the following:
Outlet Replacement
All drinking water outlets tested that exceeded a level of 50 ppb lead were immediately taken out
of service (by blocking or posting signs) and were replaced with lead-free outlets. Replacements
consisted of (1) water coolers without lead parts or lead-lined tanks and (2) lead-free taps or
valves at sink locations.
Flushing
All drinking water outlets tested with lead levels between 20 and 49 ppb were flushed for a
minimum of 30 seconds daily (i.e., early in the morning) prior to usage. Water coolers with test
results in this range were replaced with lead-free devices, since it was determined that it would
be impractical to flush water coolers for lead (i.e., they require a 15-minute flushing period).
Additional Follow-up Sampling
Additional follow-up sampling was conducted to ensure that lead levels had been reduced at all
outlets where remedies had been employed (including flushing). Test results revealed that lead
levels, following outlet replacement and daily flushing, fell well below 20 ppb, EPA's level of
concern in buildings.
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Remedies
Lessons Learned
• Planning sampling efforts is useful (i.e., developing a profile of the location and
type and manufacturer of each outlet and developing a plan of action based on the
plumbing profile). These activities enable sampling to be approached on a system-
atic basis and, in the long run, save time and money.
• Conducting public notification activities early can be valuable. Early notification
saves the public from becoming panicked needlessly.
• Outlet replacement and flushing can serve as effective lead remedies.
• Follow-up testing should be conducted to ensure that remedies installed are actually
successful in removing lead.
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Remedies
Exhibit 12 Case Study 2
Case Study 2
This case study discusses haw the owners of a four-story office building -with its own water
supply pursued lead testing and corrected lead problems. The remedies employed included
replacement of suspect piping and outlets, installation of a filtration point-of-entry unit, and
corrosion control. This study illustrates why it is important to investigate the water supply as a
potential source of contamination before implementing corrective measures.
Study to Determine Lead Sources and Levels
Building owners decided to test for lead contamination because they suspected lead materials in
the building's plumbing system and they were concerned about the potential health effects of lead
on users of the building.
Develop Profile of the System and Develop Sampling Plan
Prior to conducting testing, building officials conducted a plumbing profile. They learned that
the building was initially constructed in 1941 and that portions of the building had been
replumbed since this time with lead materials. Specifically, they learned that the piping from the
well (the building's water supply) and all the header lines in the facility consisted of copper
piping joined by lead solder.
Based on the results of the plumbing profile, building officials designed a sampling program that
involved testing all outlets used for drinking. Initial test results revealed lead levels between 24
and 996 ppb.
Determine and Install Remedies
Having conducted the initial testing, building officials initiated immediate actions to reduce or
eliminate water lead content in the facility. These actions included the following:
Pipe and Outlet Replacement
Because of the age of the piping and the known use of lead solder, building officials decided to
replace all existing piping with plastic piping as well as replace all existing fixtures with lead-
free devices (i.e., 2 water coolers, 2 bubbler heads, and 4 kitchen taps). Building officials
suspected all of these sources to be the cause of lead contamination.
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Remedies
Follow-up Testing
After the piping and fixtures had been replaced, follow-up testing was performed only to reveal
that lead levels in the water had not been reduced. Results of follow-up tests were between 24
and 996 ppb (the same as for initial testing). These results prompted building officials to
reexamine their original strategy for lead abatement and to consider additional follow-up testing.
Source Water Testing
Building officials then tested water at the wellhead to determine whether the source water
contained lead. Note: It -would have been more appropriate for this step to have been performed
during initial testing to rule out source water as a potential contamination source. This might
have saved time and money spent by building officials on new pipes, outlets, and fixtures.
The results of source water testing, however, did not reveal any apparent lead problems. Yet,
additional water quality tests (i.e., pH, alkalinity, hardness, etc.) did reveal that the water was
very corrosive and, thus, likely to leach lead. It was then suspected that, although the fixtures
had been replaced with lead-free devices, some leaching was still occurring in replacement
fixtures. In general, the replacement fixtures were constructed of brass and legally contained
alloys of less than 8 percent lead. The corrosiveness of the water and the newness of the
fixtures containing lead were considered to be contributing to the excess lead levels still being
witnessed.
Installation of Point-of-Entry Filtration Unit at Sediment Tank
Since the wellhead did not appear to be contributing lead, the next closest point to the wellhead,
a water storage pressure tank, was then tested. Upon examination of the inside of the tank, it was
discovered that a layer of sediment had formed on the bottom of the tank. Testing of the sedi-
ment revealed lead levels in excess of 3,000 ppb.
As a result, building officials cleaned the tank and installed a point-of-entry treatment device
(i.e., a two-stage filtration system) to prevent lead and sediments from entering the water
supplied to the building. Building officials also decided to routinely inspect and remove any
sediment in the water tank. Follow-up testing at outlets throughout the building revealed average
lead concentrations of 27 ppb. While the point-of-entry filtration system significantly reduced
lead levels in the building, the average lead concentration was still higher than EPA's recom-
mended 20 ppb level. This finding was evaluated, and building officials decided that it was
probably due to the corrosiveness of the water and the lead in the new fixtures.
vX
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Remedies
Installation of Treatment System
Building officials then decided to change their water treatment practices to reduce the corrosivity
of the water and hopefully to reduce lead at the outlets. Consulting engineers were hired to aid
in selecting the water treatment practices. After minimizing the corrosiveness of the water,
follow-up testing showed the average concentration of lead at various outlets to be 11 ppb, well
below EPA's 20 ppb level. This case study was based on a facility that conducted a lead
sampling program prior to finalization of EPA's Lead and Copper Rule for public water systems.
Had building officials not conducted a lead sampling program, the Lead and Copper Rule would
have ultimately required testing and treatment of the corrosive water supply.
Lessons Learned
• Profiling the plumbing system and developing a thorough sampling plan (i.e., a plan
that embodies testing of outlets, internal plumbing, and source water) are crucial to
conducting a lead abatement program in a time- and cost-efficient manner.
• Eliminating the possibility that the source water is contributing to high lead levels
during initial testing can save time and money (i.e., do not automatically replace
pipes and fixtures without testing the source water first, and be certain that internal
plumbing is contributing to lead before you replace piping).
• Brass fixtures can be a source of lead even though they legally contain less than 8
percent lead as called for in the lead-free requirements section of the Safe Drinking
Water Act. If fixture replacement is called for, ensure that any new device pur-
chased will leach the least amount of lead. Request the results of lead leaching tests
from manufacturers and/or distributors.
• Reducing/eliminating lead in drinking water can involve a step-by-step, trial and
error process. However, development of a plumbing profile and sampling plan and
the conduct of both initial and follow-up testing should help in reducing the poten-
tial for remedies to be installed that ultimately do not resolve lead contamination
problems. The key is to identify problems first before employing remedies. Follow-
up testing after remedies are in place is also important to ensure success.
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Remedies
Exhibit 13 Case Study 3
Case Study 3
This case study illustrates haw officials of one public school selected remedies after identifying
lead problems. This study further illustrates.how determining remedies can be a step-by-step
process.
Determine Lead Sources and Levels
Initial testing by the local health department revealed high levels of lead at some of the school's
drinking water outlets. As a result, school officials initiated a program to isolate and correct
sources of lead problems.
Rule Out Source Water
Since the school purchases its drinking water from a public water system, the first step involved
contacting the water supplier to determine the corrosivity and lead content of the source water.
In addition, school officials asked the water supplier to determine whether lead materials were
used in the service main and/or the service connector. Other water quality issues were also
investigated.
The public water supplier indicated to school officials that the pH level of the water supply was
between 8 and 9, which meant that the water was not highly corrosive. Recent lead testing by
the supplier also revealed the source water to contain between 0 and 5 ppb of lead, levels below
EPA's at-the-tap requirements for public water systems. School officials were also informed that
the materials in the service main and the service connector were constructed of cast iron and
would not likely contribute lead to the water.
Profile the System
Once school officials ruled out the water supply as a source of lead in their drinking water, they
began a program of testing and visual inspection on the inside of the building to track down lead
sources. First, the internal plumbing was inspected to determine what materials had been used
during construction. The main part of the school, which had been built in the 1920s, appeared
to consist mainly of galvanized steel pipes. Additions to the building in the 1970s appeared to
consist mostly of copper pipes joined by lead solders. Each of these materials has the potential
to cause elevated lead levels in drinking water.
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Remedies
Conduct Sampling
School officials then began a testing program in all parts of the building to identify outlets with
lead problems. Test results indicated that 47 percent of the outlets in the oldest part of the
building (1920s section) and over 80 percent of the outlets in the newer area (1970s section) had
lead levels above 20 ppb. These test results indicated a widespread contamination problem.
Both the school's interior plumbing and the outlets themselves could be considered possible
contributors of lead.
Determine and Install Remedies
Because the contamination appeared to be widespread, school officials determined that simple
solutions, such as merely taking outlets out of service or replacing fixtures, were not feasible.
However, school officials realized that some type of overall solution needed to be implemented.
Because of a limited budget, school officials evaluated several options.
Flushing
School officials first evaluated the effectiveness of flushing as a means to reduce lead levels at
outlets. Flushing is one of the interim solutions that is recommended to alleviate lead problems
until permanent solutions can be implemented. This proved to be an ineffective solution for the
school because, after preliminary trials and testing, it was determined that the outlets would have
to be flushed far too frequently to be feasible (i.e., more than once per day).
Plumbing Replacement
Next, school officials considered the cost-effectiveness of replacing the entire plumbing system to
eliminate the sources of contamination completely (internal plumbing and outlets). However,
because the contamination was widespread and because most of the plumbing was relatively
inaccessible, replacement of the plumbing materials would have been too costly. School officials
abandoned this possible remedy.
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Remedies
Meter Replacement
School officials then decided to replace a portion of the meter, which contained a bronze cham-
ber and which was thought to contribute lead, with a plastic chamber. They thought this action
might reduce lead entering the building and thereby reduce lead at the outlets. This remedy was
employed, however, without prior testing being conducted on the service connection. Follow-up
tests at outlets still revealed high lead levels even after this remedy was in place.
Point-of-Use (POU) Treatment
Officials then decided to perform an evaluation of the effectiveness of POU treatment devices at
problem outlets to minimize lead. School officials selected POU filter devices that had been
listed by NSF International and that were certified to remove lead.
After installing the POU filter devices at problem outlets, the facility collected follow-up
samples. Follow-up first-draw and 30-second flushed samples revealed lead levels to have fallen
well below EPA's 20 ppb concern level. The average concentration at any outlet was 8 ppb.
Lessons Learned
• When a facility purchases water from a water supplier, the supplier should be
queried about the quality of the water (e.g., lead levels, corrosivity, types of pipes).
This information can aid facility officials in developing a sampling plan and in
determining whether lead contamination may be widespread or localized.
• Developing a plumbing profile further aids facility officials in determining whether
lead problems may be widespread or localized.
Many remedial actions are available, and careful consideration of all options is
prudent before implementation. Initial and follow-up testing should be conducted to
pinpoint sources of lead before remedies are installed. Moreover, service connec-
tion samples should be collected prior to selection of remedies. Follow-up testing
should also be conducted once remedies are in place to ensure that the remedies are
successful in reducing lead concentrations.
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Public Education
Section 5
Public Education
In addition to testing for lead and solving any
contamination problems, a lead control program should also
include a public education component. This section discusses
the mandatory public notice requirements for reporting lead.
test results under the Lead Contamination Control Act
(LCCA) and discusses the importance of developing an
overall communication strategy. Finally, helpful
communication hints are provided along with sample public
notice materials.
Mandatory Public Notice Requirements
Under the LCCA
Schools conducting a lead-in-drinking-water sampling
program must comply with the public availability
requirements of the Lead Contamination Control Act. There
are two separate public availability requirements with which
schools must comply:
(1) You must make available—in your administrative
offices—a copy of the sampling results "for inspection
by the public, including teachers, other school
personnel, and parents."
(2) You must also notify relevant parent, teacher, and
employee organizations of the availability of your
sampling program results.
Given the health effects of lead, EPA advocates that any
facility conducting sampling for lead make public any test
results. In addition, such facilities should identify activities
they are pursuing to correct any lead problems found.
Special Note: Facilities regulated as public water
systems must comply with significant additional
regulatory, reporting, and public notice requirements as
stipulated by the Safe Drinking Water Act and EPA's
National Primary Drinking Water Regulation for Lead.
Facilities that provide public drinking water should
already be aware of their public notice responsibilities
with respect to lead. Consult your State drinking water
program with any questions (see Appendix A).
There are five basic public notification methods that—used
alone or in various combinations—can be applied to
communicate lead-in-drinking-water issues/problems and the
meaning and significance of your sampling program results.
These methods are not new, but are commonly employed by
businesses and schools.
Choose the method that best suits your particular situation
and/or protocol. Remember, you should not provide
sampling program results to the public without also providing
a basis for interpreting and understanding the significance of
those results. This will create certain confusion and make
your communication efforts much more difficult than
necessary.
Press Release: A press release in the local newspaper can
potentially inform a broad range of the local public of lead-
in-drinking-water issues and the results of your sampling
program. It is important that the release inform readers of
how to obtain the sampling results and other lead-in-drinking-
water information and perhaps even include the phone
number of an informed and available facility official.
Follow-up Letters/Fliers: Letters or fliers represent the
most direct and effective method of communicating lead-in-
drinking-water activities to parents/guardians and other
members of your school or building community. The letters •
and fliers should be mailed directly using any existing
address lists.
Mailbox or Paycheck Staffers: Mailbox and paycheck
stuffers represent the most direct and effective method of
communicating lead-in-drinking-water activities to employees
such as teachers and business personnel. Stuffers would
contain much the same information as that contained in a
press release or letter/flier.
Staff Newsletter: A notice contained in a staff newsletter is
a further option for directly and effectively communicating
information about the lead program to employees.
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Public Education
Presentations: Providing lead sampling program briefings
and presentations at facility-related meetings is yet another
effective means of communication. Relevant events for
schools include meetings of parent-teacher organizations,
faculty, and the school board. Staff meetings might represent
one option for presenting lead testing program information to
members of a non-residential building.
The Components of an Effective
General Communication Strategy
Lead in drinking water can be an emotional and
sensitive issue, especially for parents who are concerned
about their children's safety. As a result, you should not
view communication and outreach activities as stand-alone or
final efforts, but rather as a part of an overall or general
communication strategy.
The purpose of a general communication strategy is to
provide the means for addressing questions from members of
your facility's community and also to provide ongoing, up-to-
date information regarding your sampling efforts. Ideally,
you should designate a single spokesperson or special task
force to interact with the public since it is important that your
message remain consistent.
The issues to be addressed as part of a communication
strategy include:
• Participants
• Timing for delivery
• Contents of the message
• Methods and manner of communication.
Participants
Overall, there are four primary players or interests
involved in the control of lead in drinking water:
States and EPA Regions: Both State drinking water
programs and EPA Regional offices are responsible for
ensuring that public water systems comply with the National
Primary Drinking Water Regulation for lead and any
additional or more stringent State standards. States are also
responsible for assisting schools in implementing lead-in-
drinking-water control programs.
Drinking Water Community: Public water systems comprise
the regulated drinking water community, and they are
responsible for complying with all national and State drinking
water standards for lead. This means that they must ensure that
the water they deliver is non-corrosive, contains minimal
amounts of lead, and will not result in significant lead-leaching
from plumbing in individual homes and buildings.
Local Community: The local community consists of those
users of the facility who would be most affected by lead-in-
drinking-water problems (i.e., business professionals,
students,-parents, school boards, teachers, and other
employees). Members of the local community should be the
primary targets of any general communication activities.
Larger Community: The local and regional media can
serve as a conduit for information reaching a larger local
community. It is important that you be prepared to generate
accurate news releases. Also, your spokesperson or task
force should be prepared to respond to interview requests
with accurate and consistent information.
Timing
The timing of your communication activities is very^
important. Whenever public health risks are involved, public
communication efforts are less complicated and generate less
conflict if those potentially affected are notified in advance of
important issues and events. At a minimum, you should
provide information to members of the building community
and the larger community (if deemed necessary) at the
following three times.
• Before your lead-in-drinking-water sampling program
begins.
• In response to periodic interest and/or pressure.
• After you obtain the results of testing and/or decide
upon corrective measures.
46
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Public Education
Contents
Your communication messages should consist of the'
following information:
• Details about the nature of your drinking water lead
control program.
• The results of your sampling program and your plans,
for correcting any identified problems.
• Information on the public health effects and risks
posed by lead in drinking water and the significance of
lead in drinking water versus other sources such as
food and air.
• The availability of general lead-in-drinking-water
information resources and the availability of the
detailed sampling results for your facility.
Methods
The communication methods that can be used for your
general communication strategy are largely the same as those
described earlier in regard to mandatory notification methods
and, thus, need not differ from communication activities
common to school or non-residential building operations
(i.e., meeting presentations, press releases, mailbox/paycheck
stuffers, and letters to staff and parents).
Additional methods unique to your lead control program may
include:
• Creating an information center located at a convenient
place in the facility such as a library or break room.
• Creating a task force with representatives from the
building community.
• Making available a list of laboratories that are State-
certified to test home water for lead and other
contaminants.
• (For schools) encouraging classroom science activities
that focus on drinking water quality. (Contact EPA's
Safe Drinking Water Hotline—see Appendix D—for
information on organizations that have such science
activities).
Helpful Hints for Communication
The following list contains some hints for effective
communication:
• Take the initiative in providing information to your
community (it is important to do so before the media
does it for you). When public health risks are
involved, especially with respect to children, vague or
incorrect information can be worse than no information
at all.
i
• Be a good and reliable source of information. That is,
provide honest, accurate, and comprehensive
information in every necessary area.
• Always speak with one voice (i.e., designate points of
contact—preferably one person—to respond to parents
and the media).
• Anticipate likely questions from members of the
building community (e.g., employees, parents,
teachers, students, members of civic organizations,
media representatives). Each member of the
community is likely to have a different concern and/or
viewpoint on the subject of lead testing.
• Be positive, proactive, and forthcoming when working
with the media. If you work together in a cordial
manner, your communication efforts are likely to be
less complex.
• Keep members of the building community up-to-date
as important events and information on your lead
testing program unfold.
Sample Public Notice Materials
Exhibit 14 contains a sample public notification letter
that could be used and adapted to communicate lead testing
information. Exhibit 15 is a sample press release for local
media that could also be used or adapted.
47
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Public Education
Exhibit 14 Sample Public Notice Letter
Spring 1994
An/town School Department
Anytown, USA 00000-0000
Dear Members of the Anytown School Community:
The United States Environmental Protection Agency (EPA) has determined that lead in
drinking water is a health concern at certain levels of exposure. The groups most
vulnerable to lead include fetuses and young children. Lead in pregnant women can damage
a child before it is born, by lowering birth weight and slowing down normal physical and
mental development. Lead in young children, especially those under the age of six, can
result in lower Id levels, impaired hearing, reduced attention span, and poor classroom
performance. At high levels, lead can seriously damage the brain.
As a result of these health effects, EPA has applied more stringent regulations to public
water systems. However, since lead is generally contributed to water via plumbing in
individual homes and businesses, EPA has also advocated testing of water in private
buildings. EPA recommends that action be taken if lead levels exceed 20 parts per
billion (ppb) at any outlet tested.
In October 1988, the U.S. Congress passed the Lead Contamination Control Act, which
specifically addressed the problem of lead in school drinking water. Following instruc-
tions given in an EPA guidance document especially designed for schools, we completed a
plumbing profile for each of the buildings within the Anytown School District. Through
this effort, we identified and tested those drinking water outlets most likely to have
high levels of lead. Of the samples taken, all but tested well below EPA's
recommended level of 20 ppb for lead.
The first contaminated outlet was a drinking water fountain (bubbler) at Kennedy High
School. After follow-up testing was conducted, it was determined that the faucet
(bubbler head) was the source of the lead contamination. The faucet was replaced with a
lead-free faucet and retested. Follow-up test results revealed lead levels well below
EPA's recommended level.
The second outlet, in the Lincoln Elementary School, was a faucet in the kitchen and
showed unacceptable lead levels in both initial and follow-up testing. We found the
source of the lead contamination to be the pipe providing water to the faucet. This pipe
was replaced with lead-free materials.
A copy of the test results is available in our central office for inspection by the
public, including teachers, other school personnel, and parents and can be viewed between
the hours of 8:30 a.m. and 4:00 p.m. For more information about water quality in our
schools, contact John Doe at the Anytown School Department, 555-2223. For information
about water quality in your home or for questions about testing, contact Jane Smith at
the Anytown Water Department, 555-1217.
Sincerely,
Fred Frank
Superintendent of Schools
48
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Public Education
Exhibit 15 Sample Press Release for Local Media
Anytown School Department
One School Street
Anytown, USA 00000-0000
Contact: Fred Frank, Superintendent
FOR IMMEDIATE RELEASE
News Release
Lead Levels in School Drinking Water Meet Federal Guidelines
Anytown, USA, April xx, 1994... The Anytown School Depart-
ment announced today that recent tests of drinking water in the
town's schools indicate that lead levels meet Federal guidelines.
Although the testing program detected lead at two drinking water
outlets at one elementary and one senior high school, lead levels
were reduced following replacement of these outlets.
In making the announcement, School Superintendent Fred Frank
stated, "We are pleased that the testing program has verified that
lead is not a problem in our school drinking water."
The School Department conducted the testing program to make
sure that drinking water in the school system is safe for children
and school staff. Water with high lead levels can contribute to
negative health effects, especially in young children.
The testing was conducted in January by school personnel
following Federal and State guidelines. Samples from various
locations in each of the schools were sent to a State-certified
laboratory for analysis. The laboratory results were received by
the School Department last week.
Information about the lead testing program, including the
laboratory results, can be found at the School Department office
at the above address, weekdays between 8:30 a.m. and 4:30 p.m.
STOP
49
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Part 2
Lead Testing Protocol
Section 1
General Procedures
This section outlines the general procedures involved -
in collecting drinking water samples for lead testing.
Specifically, the section discusses laboratory analysis and
collection, and handling procedures.
Laboratory Analysis and
Handling of Sample Containers
(1) As discussed in the previous section, the certified
drinking water lab you select to conduct your analyses
will provide sample collectors, or they will provide
you with materials and instructions if you plan to
collect your own samples. Do not attempt to prepare
your own sample containers unless you have qualified
personnel and an appropriate facility. Sample
containers should be prepared in a clean laboratory
environment by qualified laboratory personnel using
the appropriate purity chemicals.
If you collect your own samples, follow the
instructions provided by the lab for handling sample
containers to ensure accurate results. Do not rinse the
sample containers before filling. The lab has prepared
the containers to receive the samples you will take,
and the containers may contain a chemical needed to
preserve the samples properly until the samples reach
the laboratory. Avoid any contact with this chemical.
Be careful not to overfill the sampling containers with
water. For more information about the preparation of
sample containers and sample preservation, refer to
Appendix F. This information should also be shared
with the laboratory officials with whom you plan to
work.
Collection Procedures
(2) Collect all water samples before the facility 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 a sample is taken. This time
distinction is made to ensure that the water collected is
representative of the building's normal water use
patterns. At some infrequently used outlets, time gaps
may routinely be 18 hours. In such situations, the
sample will be representative of the building's normal
water consumption pattern for that particular outlet.
(3) Make sure that no water is withdrawn from the taps or
fountains from .which the samples are to be collected
prior to their sampling. Samples collected from the
designated sites after the taps have been used will indicate
lower lead levels. It is important that consistent
procedures be used in taking samples so that
generalizations about test results can be made.
(4) Unless specifically directed to do so, do not collect
samples in the morning after vacations, weekends, or
holidays. If lead is a problem in your facility, these
samples will cpntain higher lead levels than those
collected at other times. Such samples would not be
representative of the normal water use patterns within
your facility.
50
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General Procedures
(5) All water samples
collected should be
250 milliliters (ml)
in volume. Make
sure the sample
containers you plan
to use will
accommodate this
volume of water
and are
appropriately
marked.
(6) Assign a unique
sample ID number
to each sample
collected that is
reflective of the
type of outlet and
outlet location
being tested.
Record this ID
number on the
sample bottle and
on your
recordkeeping
form. On your recordkeeping form, also denote
such information as the type of sample taken, the
date and time of collection, name of the sample
collector, the location of the sample site, name of
the manufacturer that produced the outlet, and the
outlet's model number. Consult the sample form in
Appendix Efor additional recordkeeping items.
Response Actions
(7) Institute interim and permanent corrective measures
in your facility, as necessary, to minimize exposure
to lead contamination. See discussion of this topic in
Part 1, Section 4 of this document for details.
51
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Initial and Follow-Up Sampling by Outlet Type
Section 2
Initial and
Follow-Up
Sampling by
Outlet Type
The protocol for collecting initial and follow-up
samples is generally the same for various drinking water
outlets, with the exceptions of service connectors, ice
makers, and water coolers. The initial and follow-up testing
protocol, as well as the interpretation of test results, is
described in Exhibits 16 through 22 for the following types
of outlets:
• Service connections
• Drinking water fountains (four types)
Bubblers or drinking water fountains (without
central chillers): water is supplied to the bubbler
or fountain directly from the building's
plumbing.
Bubblers or drinking water fountains (with
central chillers): a central chiller unit cools water
for a number of drinking water fountains or
bubblers in the building.
Water coolers: devices are equipped with their
own cooling and storage systems; water is
supplied to the device from the building's
plumbing.
Bottled water dispensers: type of water fountain
whose water is supplied from bottled water.
• Ice making machines
• Water faucets.
Please note that sampling ID codes have been indicated in the
descriptions of the sampling protocol for each outlet type,
and they are denoted on the plumbing diagrams that follow in
Exhibits 25 and 26 (see pages 80 and 81). These sampling
ID codes have been included for illustrative purposes only.
When you conduct testing in your facility, you will assign
unique numbers for every sample you collect (see discussion
under the general requirements section above).
Following the instructions for collecting initial and follow-up*
samples and for interpreting test results are instructions for
conducting sampling t>f the interior plumbing of buildings
(Exhibit 23). Instructions are included for sampling l
loops and headers, and riser pipes. These types of samples
are necessary if follow-up outlet samples show lead levels
above 20 ppb.
Finally, Exhibit 28 gives an overview of the sampling
process presented in this guidance manual.
EPA's lead testing protocol for schools and non-
residential buildings emphasizes that first-draw or initial
samples should be taken from all drinking water outlets.
Follow-up samples should then be collected at only those
outlets where initial test results revealed lead levels
greater than 20 ppb.
52
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Initial and Follow-Up Sampling by Outlet Type
Exhibit 16 Service Connection Sampling
Service Connection Sampling
Until recently, lead pipes up to 2 1/2 inches in diameter were used for service connectors in
some locations. 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.
To test water in your service connector, locate the tap closest to the service connector. This is
especially important for larger facilities where more than one service connection is present.
Sample Collection Procedures:
Sample IS (Service Connection)
Take this sample before the facility 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 represents the water that has been
standing just outside of the building and in contact with the service connector.
Sample 1M (Water Main)
This sample is representative of the water that has been standing in the distribution main.
It will help pinpoint whether the service connector is the source of any lead. Take the
sample 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
an additional 3 minutes and then collect the sample.
Interpreting Test Results:
If the lead level of Sample IS (service connector) significantly exceeds 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 connector by scratching it with a knife
or key. Lead is soft and dull gray in appearance. When scratched, it will be shiny. In the
absence of a lead service connector, lead goosenecks or other materials containing lead in
line with the service connection may be the source of the contamination. Usually, no
significant amount of lead (above 5 ppb) comes from the distribution main (i.e., water
from the public water supplier or private water source).
53
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Initial and Follow-Up Sampling by Outlet Type
If the lead level of Sample 1M (water main} significantly exceeds 5 ppb (for example,
10 ppb), lead in the water may be attributed to the source water, sediments in the main, or
to lead in the distribution system such as from lead joints used in the installation or repair
of cast iron pipes. If the water supplied is from a well, lead may also be getting into the
water if the materials of construction of the well pump contain lead alloys.
If the lead level of Samples IS and 1M are very low (close to 5 ppb), very little lead is
being picked up from the service line or the distribution main. If any of your other initial
screening samples indicate a problem with lead contamination, the source of that contami-
nation is the interior plumbing and/or outlets themselves (or sediments containing lead
that are trapped in the plumbing or on screens). The problem is not the water supply or
the service connection.
Examples:
Sample IS (20 ppb) exceeds Sample 1M (5 ppb) = IS ppb of lead is contributed
from the service connector; the lead amount in the main (Sample 1M) does not
exceed 5 ppb; therefore, you may want to check for a lead service connector or
gooseneck depending upon results of lead testing at other outlets in the building; if
you reduce lead at the connection, lead levels may be reduced throughout the
remainder of the building.
Sample 1M is 10 ppb and Sample IS is 10 ppb — very little lead is contributed
from the service line; source of lead is most likely the water main.
Sample IS (7 ppb) and Sample 1M (6 ppb) are close to 5 ppb — very little lead
(1 ppb) is being picked up in the water from the service line or the distribution
main; very little lead is contributed from the source water; if other outlets show
significantly higher lead levels, the source of the contamination is the interior
plumbing and/or the outlets themselves.
For sample locations, see Exhibit 25: Plumbing Diagram for a Single-Level Building
and Exhibit 26: Plumbing Diagram for a Multilevel Building.
•
54
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Initial and Follow-Up Sampling by Outlet Type
Exhibit 17 Drinking Water Fountains: Bubblers Without Central Chiller
Drinking Water Fountains: Bubblers Without Central Chiller
Do not close the shut-off 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.
Sample Collection Procedures:
Initial Screening Sample 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 the facility opens and before any water is used. Collect the water
immediately after opening the valve without allowing any water to run into the drain. Take
follow-up samples from those bubblers where test results indicate lead levels over 20 ppb.
FoIlow-Up Sample 2A
•
This sample is representative of the water that is in the plumbing upstream from the bubbler
(from the bubbler back toward the service connector and the water main). Take this sample
before the facility opens and before any water is used. Let the water from the fountain run for 30
seconds before collecting the sample.
Interpreting Test 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 that hi 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.
55
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Initial and Follow-Up Sampling by Outlet Type
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.
(Sampling instructions for interior plumbing can be found in Exhibit 23.)
Example 1:
Sample 1A (31 ppb) exceeds Sample 2A (7 ppb) = 24 ppb of lead is contributed
from the bubbler.
Sample 2A (7 ppb) does not significantly exceed 5 ppb = very little lead (2 ppb) is
being picked up from the plumbing upstream from the bubbler; the majority of the
lead in the water is contributed from the bubbler.
Sample 2A (7 ppb) does not exceed 20 ppb = sampling from header or loop
supplying water to the lateral is not necessary.
Possible Solution: Replace fixture, valves, or fittings on bubbler with lead-free device
(request results of lead leaching tests from distributors or manufacturers of any fixtures
you intend to purchase); retest water for lead after new materials installed.
•
56
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Initial and Follow-Up Sampling by Outlet Type
Example 2:
•
Sample 1A (31 ppb) exceeds Sample 2A (25 ppb)
from the bubbler.
6 ppb of lead is contributed
Sample 2A (25 ppb) significantly exceeds 5 ppb = about 20 ppb of lead is being
contributed from the plumbing upstream from the bubbler.
Sample 2A (25 ppb) exceeds 20 ppb = sampling header or loop supplying water to
the lateral is necessary to locate the source of the contamination (consult Exhibit 23
for sampling instructions for interior plumbing—Samples 1 Hand II).
Possible Solution: Depending upon the results of testing of the header or loop
supplying water to the lateral, possible solutions could consist of replacing the
bubbler fixture, valves, or fittings with lead-free materials or replacing upstream
piping, piping joints, or both. Other alternatives might consist of removing the
bubbler from service and providing water in another lead-free area of the building,
providing bottled water, or flushing the outlet and/or interior plumbing on a daily
basis; retest water for lead after any remedy is employed.
For sample locations, see Exhibit 25: Plumbing Diagram for a Single-Level Building
and Exhibit 26: Plumbing Diagram for a Multilevel Building.
57
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Initial and Foliow-Up Sampling by Outlet Type
Exhibit 18 Drinking Water Fountains: Bubblers With Central Chiller
Drinking Water Fountains: Bubblers With Central Chiller
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.
Sample Collection Procedures:
Initial Screening Sample 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 the plumbing closest to the outlet of the unit.
Take this sample before the facility opens and before any water is used. Collect the water
immediately after opening the faucet without allowing any water to run into the drain.
Take follow-up samples from those water fountains where test results indicate lead levels
over 20 ppb.
Follow-Up Sample 2B
This sample is representative of the water that is in the plumbing upstream from the
bubbler. Take this sample before the facility opens and before any water is used. Let the
water from the fountain run for 30 seconds before collecting the sample.
Interpreting Test 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 that hi Sample 2B, a portion of lead in the
drinking water is contributed from the bubbler.
• If the lead level hi Sample 2B 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.
4
*
58
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Initial and Foliow-Up Sampling by Outlet Type
•
If the lead level in Sample 2B 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 2B exceeds 20 ppb, EPA recommends sampling from the chiller
unit supplying water to the lateral to locate the source of the contamination. (See Sample
Collection Procedures and Interpretation of Test Results for Central Chiller Unit below.)
Example 1:
Sample IB (25 ppb) exceeds Sample 2B (3 ppb) = 22 ppb of lead is contributed
from the bubbler.
Sample 2B (3 ppb) is close to 5 ppb = very little lead (2 ppb) is being picked up
from the plumbing upstream from the bubbler; the majority or all of the lead is
contributed from the bubbler.
Possible Solution: Replace bubbler valve, fittings and/or fixture with lead-free
materials (request results of lead leaching studies from manufacturers of brass
products before purchasing to ensure that harmful amounts of lead will not be
leached); retest water once new materials installed.
Example 2:
Sample IB (38 ppb) exceeds Sample 2B (21 ppb)
from the bubbler.
17 ppb of lead is contributed
Sample 2B (21 ppb) significantly exceeds 5 ppb = about 21 ppb of lead is being
contributed from the plumbing upstream from the bubbler.
• Sample 26 (21 ppb) exceeds 20 ppb = sampling from the chiller unit supplying the
water to the lateral is necessary to locate the source of the contamination (see
instructions and examples below for sampling chiller units).
For sample locations, see Exhibit 27: Vtoter Supply to Waer Fountains and Bubblers from
Central Chiller.
59
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Initial and Follow-Up Sampling by Outlet Type
Sample Collection Procedures—Central Chiller Unit:
Follow-Up Sample 3B
This sample is representative of water that has been in contact with the plumbing supply-
ing water to the chiller. Take this sample before the facility 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 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 supply-
ing 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 Test Results—Central Chiller Unit:
If the lead level in Sample 2B is higher than that hi Sample 4B, lead is contributed
from the plumbing supplying the water from the chiller to the bubbler.
• If the lead level hi Sample 4B is higher than hi 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 resample the water.
• If the lead level hi Sample 3B exceeds 20 ppb, EPA recommends additional sampling
from the distribution system supplying water to the chiller to locate the source of contami-
nation. (Refer to Exhibit 23 on Sampling Interior Plumbing for testing information.)
60
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Initial and Follow-Up Sampling by Outlet Type
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.
Example 1:
Sample 26 (21 ppb) exceeds Sample 3B (10 ppb) = 11 ppb of lead is contributed
from the plumbing supplying the water from the chiller to the bubbler.
Sample 36 (10 ppb) exceeds Sample 46 (4 ppb) = a portion of the lead (6 ppb) may
be coming from the chiller; check for and remove any debris and sludge in the
chiller unit; flush the unit, and resample the water.
Sample 46 (4 ppb) does not exceed 20 ppb = additional sampling from the distribu-
tion system supplying water to the chiller is not necessary.
Sample 46 (4 ppb) is very 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 can
be attributed to the chiller and the plumbing downstream from the chiller.
Possible Solutions: Flush the chiller unit and plumbing; if lead levels are still high,
replace plumbing supplying water from the chiller to the bubbler; replace the
bubbler fixture, fittings, and valves with lead-free materials; and/or clean sludge
and debris from chiller unit. Retest water for lead once changes have been made.
61
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Initial and Follow-Up Sampling by Outlet Type
Example 2:
Sample 26 (45 ppb) exceeds Sample 46 (28 ppb) = 17 ppb of lead is being contrib-
uted from the plumbing supplying water from the chiller to the bubbler.
Sample 4B (28 ppb) exceeds Sample 3B (21 ppb)
the chiller.
7 ppb of lead is contributed by
Sample 36 (21 ppb) exceeds 20 ppb = additional sampling from the distribution
system supplying water to the chiller is necessary to locate the source of the contami-
nation (see Exhibit 23 on Sampling Interior Plumbing for instructions).
Possible Solution: Flush the chiller unit and plumbing; retest the water. Depending
upon the results of testing of the distribution system supplying water to the chiller,
possible solutions include replacing upstream plumbing; replacing bubbler fixtures,
valves, or fittings with lead-free materials; and flushing the chiller unit outlet and
interior plumbing. Retest water for lead after changes have been made.
For sample locations, see Exhibit 27: Witter Supply to Vbter Fountains and Bubblers
from Central Chiller.
•
62
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Initial and Follow-Up Sampling by Outlet Type
Exhibit 19 Drinking Water Fountains: Water Coolers
Drinking Water Fountains: Water Coolers
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.
Sample Collection Procedures:
Two types of water coolers are used: the wall-mounted and the free-standing types. Water in
these coolers is stored in a pipe coil or in a reservoir. Refrigerant coils in contact with either of
these storage units cools 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 pipe; and/or the interior plumbing of the building.
Prior to testing, check the make and model numbers of your water coolers and compare them to
EPA's listing of coolers that have lead parts or lead-lined tanks (see Appendix Cfor a summary of
the water cooler issues and EPA's list of affected coolers). If you have a Halsey Taylor cooler
that is on EPA's list of coolers with lead-lined tanks, consult Halsey Taylor for information on
their replacement/refund program and associated testing directions. Contact information is
provided in Appendix C.
Regardless of whether your water cooler appears on EPA's listing, initial testing should be
conducted.
Initial Screening Sample 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.) The sample consists of water that has been in contact with
the interior plumbing, the valve and fittings, the storage unit, and the section of plumbing
closest to the outlet of the unit.
Take this sample before the facility opens and before any water is used. Collect the water
immediately after opening the faucet without allowing any water to waste, lake follow-up
samples from those water coolers whose test results indicate lead levels greater than 20 ppb.
63
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Initial and Follow-Up Sampling by Outlet Type
In conducting follow-up testing with water coolers be aware of the following:
Some water coolers manufactured before 1988 may 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 that
contain lead has been prepared by EPA and is summarized in Appendix C.
Sediments and debris containing lead on screens or in the plumbing frequently
produce significant lead levels (see Follow-Up Sample 4C).
Lead solder in the plumbing can also contribute to the problem.
Follow-Up Sample 2C
This water sample is representative of the water that is in contact with the plumbing
upstream of the cooler. Take this sample after the facility closes. 'Let the water from the
fountain run for 15 minutes before collecting the sample. You must flush the cooler for
15 minutes to ensure that no stagnant water is left in the storage unit.
Follow-Up Sample 3C
Take this sample before the faculty opens and before any water is used. This sample
must be taken the morning after you collect Follow-Up Sample 2C. Collect the water
immediately after opening the faucet without allowing any water to waste.
Because the water in the cooler was flushed the previous afternoon, this sample is repre-
sentative of the water that was in contact with the cooler overnight, not in extended contact
with the plumbing upstream. As such, it may differ from Initial Screening Sample 1C.
Interpreting Test Results:
• If the lead level in Sample 3C is higher than that in Sample 2C, the water cooler may
be contributing lead to the water.
If the lead level in Sample 3C is higher than that in Sample 2C AND the lead level in
Sample 1C is higher than that in Sample 3C, the plumbing upstream from the water
cooler may also be contributing lead to the water.
64
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Initial and Follow-Up Sampling by Outlet Type
• 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 that hi Sample 3C AND if the lead levels
in Sample 2C and 3C are similar, the plumbing upstream from the cooler or the plumb-
ing connection leading to the cooler, or both, is contributing lead to the water.
• If the lead level hi Sample 2C is in excess of 10 ppb and is equal to or greater than
the lead levels hi 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.
Sample Collection Procedures—Additional Water Cooler Testing
• 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 results 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
water.
• To confirm whether the cooler is the source of lead, take Follow-Up Sample 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 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.
65
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initial and Follow-Up Sampling by Outlet Type
Collect Sample 4C from the disconnected plumbing outlet in the same manner as you
collected Sample 1C. Compare the results from Sample 4C to the other sample results.
Interpreting Additional Water Cooler Test 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.
Example 1:
Sample 1C (54 ppb) = the plumbing upstream from the cooler and/or the water
cooler is contributing lead.
Sample 3C (40 ppb) exceeds Sample 2C (5 ppb) = the water cooler is contributing
35 ppb of lead.
Sample 3C (40 ppb) exceeds Sample 2C (5 ppb) and Sample 1C (54 ppb) exceeds
Sample 3C (40 ppb) = the plumbing upstream from the cooler is contributing 14
ppb of lead.
Sample 2C (5 ppb) is less than 10 ppb and Sample 2C is less than Sample 1C (54
ppb) and Sample 3C (40 ppb) = the source of lead is not sediments contained in the
cooler storage tank, screens, or plumbing upstream from the cooler.
Possible Solutions: Replace the cooler with one that contains lead-free components,
and retest the water or find an alternative lead-free drinking water source; locate
source of lead from plumbing and eliminate it (routine flushing is not applicable as
a potential remedy for water coolers—see discussion of this issue in Section 4 of
Pan 1 of this guidance document for further information).
1
66
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Initial and Follow-Up Sampling by Outlet Type
Example 2:
Sample 3C (42 ppb) exceeds Sample 2C (41 ppb) and Sample 1C (44 ppb) exceeds
Sample 3C (42 ppb) = the plumbing upstream from the cooler is contributing
2 ppb of lead to the water.
Sample 3C (42 ppb) is close to Sample 2C (41 ppb) = the water cooler probably is
not contributing lead to the water.
Sample 1C (44 ppb) exceeds Sample 3C (42 ppb) and Sample 3C and Sample 2C
(41 ppb) are close = the plumbing upstream from the cooler or the plumbing
connection to the cooler, or both, is contributing lead to the water.
Sample 2C (41 ppb) exceeds 10 ppb and Sample 2C is less than Sample 1C (44 ppb)
and Sample 3C (42 ppb) = source of lead is not likely sediments contained in the
cooler storage tank or screens.
Sample 4C (43 ppb) significantly exceeds 5 ppb = the source of lead is the plumb-
ing upstream from the cooler.
Possible Solutions: Move the cooler to an area in the building where plumbing is
free of lead, and retest the water; replace the plumbing upstream from the cooler
with lead-free materials, and retest the water; or provide an alternative lead-free
water source such as bottled water (flushing is not applicable as a potential remedy
for water coolers—see discussion of this issue in Section 4 of Pan 1 of this guidance
document for further information).
For sample locations, see Exhibit 25: Plumbing Diagram for a Single-Level Building
and Exhibit 26: Plumbing Diagram for a Multilevel Building.
67
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Initial and Follow-Up Sampling by Outlet Type
Exhibit 20 Drinking Water Fountains: Bottled Water Dispensers
Drinking Water Fountains: Bottled Water Dispensers
Sample Collection Procedures:
• Initial Screening Sample ID
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 dispenser
valve and fittings incorporated in the outlet of the unit.
Take this sample before the facility opens and before any water is used. Collect the water
immediately after opening the faucet without allowing any water to waste. Take follow-up
samples from those bottled water dispensers where test results indicate lead levels over 20
PPb.
Follow-Up Sample 2D
Collect this sample directly from the bottle that supplies the water to the unit. This will
enable you to determine the source of lead in the water.
Interpreting Test Results:
• If the lead level in Sample ID is higher than that hi Sample 2D, lead may be coming
from the dispenser unit.
• If the lead level hi Sample 2D is identical or dose to that hi Sample ID, the source of
lead is the bottled water.
Note: Public -water systems must ensure that water delivered to customers is minimally corrosive
to avoid lead being added to the water as a result of customer plumbing. The FDA, which
regulates the interstate sale of bottled water, has proposed a 5 ppb standard for lead in bottled
water. This standard is expected to go final in May 1994. EPA recommends that you contact
your distributor for written assurance that the bottled water does not exceed Federal and State
bottled water standards.
68
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Initial and Follow-Up Sampling by Outlet Type
Example 1:
Sample ID (23 ppb) exceeds Sample 2D (5 ppb) = 18 ppb of lead is contributed
from the dispenser unit.
Possible Solution: Replace dispenser unit with one that is made of lead-free
materials and retest.
Example 2:
Sample ID (24 ppb) and Sample 2D (23 ppb) are close — the source of lead is the
bottled water.
Possible Solutions: Purchase another type of bottled water for which the distributor
provides written assurance that lead levels do not exceed Federal and State lead
standards, or find other alternative lead-free water source. Retest after any remedy
has been employed.
69
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Initial and Follow-Up Sampling by Outlet Type
Exhibit 21 Ice Making Machines
Ice Making Machines
Sample Collection Procedures:
Initial Screening Sample IE
Fill a suitable container (2SO mL or larger, wide-mouthed bottle or Whirlpak 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 the lead level in Sample IE exceeds 20 ppb, collect a follow-up sample to determine if
the source of the lead is the plumbing or the ice making machine itself.
Follow-Up Sample 2E
Disconnect the ice maker 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 whether lead solder is present. If the debris
contains lead, the screen should be cleaned routinely.
Collect the sample from the disconnected plumbing as close to the ice maker as possible.
Fill the sample container with 250 mL of water.
Interpreting Test 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 Exhibit 23 on Sampling
Interior Plumbing for instructions.
•
70
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Initial and Follow-Up Sampling by Outlet Type
Example 1:
Sample IE is 22 ppb and Sample 2E (6 ppb) is close to 5 ppb = source of the lead
(16 ppb) is the ice maker.
Possible Solutions: Replace plumbing components in ice maker with lead-free
materials; clean debris from plumbing and screen at inlet to ice maker; replace with
lead-free ice maker; retest after any remedy has been employed.
Example 2:
Sample IE = 22 ppb and Sample 2E (21 ppb) significantly exceeds 5 ppb = lead is
contributed from the plumbing upstream from the ice maker.
Sample 2E (21 ppb) exceeds 20 ppb = sampling from the distribution system
supplying water to the ice maker is recommended (see Exhibit 23 for instructions).
71
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Initial and Follow-Up Sampling by Outlet Type
Exhibit 22 Water Faucets (Taps)
Water Faucets (Taps)
Sample Collection Procedures:
• Initial Screening Sample 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 pipes.
Take this sample before the facility opens and before any water is used. Collect the water
immediately after opening the faucet without allowing any water to go to waste. Follow-
up samples should be taken from those water faucets where test results indicate lead levels
over 20 ppb.
• Follow-Up Sample 2F
This sample is representative of the water that is in the plumbing system 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 Test Results:
• If the lead level in Sample IF is higher than that 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.
72
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Initial and Follow-Up Sampling by Outlet Type
Example 1:
Sample IF (39 ppb) exceeds Sample 2F (6 ppb) = 33 ppb of lead is contributed
from the water faucet.
Sample 2F (6 ppb) is close to 5 ppb = very little lead is coming from the plumbing
upstream from the faucet; the majority of the lead is coming from the faucet and/or
the plumbing connecting the faucet to the lateral.
Possible Solutions: Replace faucet with lead-free device (request copies of lead
leaching studies from manufacturers of brass faucets and fixtures before purchasing);
replace plumbing connecting the faucet to the lateral with lead-free materials; flush
outlet and connecting plumbing each day; apply point-of-use device designed to
remove lead; find alternative water source such as bottled water or other lead-free
location in the building; retest after any remedies are employed.
Example 2:
Sample IF (49 ppb) exceeds Sample 2F (25 ppb) = source of lead (24 ppb) is the
water faucet and the plumbing upstream from the outlet (25 ppb).
Sample 2F (25 ppb) significantly exceeds 5 ppb = lead may be contributed from
upstream from the faucet; evaluate lead test results conducted upstream from the
faucet to ascertain potential contributions of lead from the upstream piping. To
pinpoint location test interior plumbing (see instructions for sampling interior
plumbing in Exhibit 23).
Possible Solutions: Replace faucet with lead-free device (request copies of lead
leaching studies from manufacturers of brass faucets and fixtures before purchasing);
replace plumbing connecting faucet to the lateral with lead-free materials; replace
suspected portion of interior plumbing with lead-free materials; flush the outlet and
interior plumbing each day; apply point-of-use device designed to remove lead; find
alternative water source such as bottled water or water from other lead-free location
in the building; retest after any remedies are employed.
For sample locations, see Exhibit 25: Plumbing Diagram for a Single-Level Building
and Exhibit 26: Plumbing Diagram for a Multilevel Building.
73
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Initial and Follow-Up Sampling by Outlet Type
Exhibit 23 Sampling Interior Plumbing
Sampling Interior Plumbing
In general, if lead levels exceed 20 ppb in follow-up samples taken from drinking water outlets,
additional samples from designated sample sites in the interior plumbing should be collected.
Samples should be taken from laterals, loops and/or headers, and riser pipes. The configuration
of interior'plumbing will vary depending on the layout of a given building. See Exhibits 25 and
26 for sample diagrams of the interior plumbing in single-level and multilevel buildings.
Sampling should proceed systematically upstream from initial follow-up sample sites. The goal
of this type of sampling effort is to isolate those sections of the interior plumbing that contribute
lead to the water. This is achieved by comparing the results of interior plumbing samples with
the results of previously collected outlet samples.
LATERALS
Laterals are the plumbing branches between a fixture or group of fixtures (e.g., taps and water
fountains).
Sample Collection Procedures:
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. Collect a 250 mL sample. The purpose
of flushing the water is to clear the plumbing between the sample site and the lateral pipe.
This action will ensure 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 IGfor additional information on the source of the lead within the interior plumbing.
Interpreting Test Results:
• If the lead level in Sample 1G exceeds 20 ppb, collect additional samples from the
plumbing upstream (i.e., from the service line, the riser pipe, the loop, or header supply-
ing water to the lateral).
74
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Initial and Follow-Up Sampling by Outlet Type
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 down-
stream 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.
Example:
Sample 1G (22 ppb) exceeds 20 ppb = collect additional samples from the plumb-
ing upstream to further pinpoint the source of lead (i.e., from the service line, the
riser pipe, the loop, or the header supplying water to the lateral); see instructions
below for collecting these types of samples.
Sample 1G (22 ppb) significantly exceeds 5 ppb and is less than downstream site (35
ppb) = a portion of the lead (13 ppb) is contributed downstream from the sample site.
Sample 1G (22 ppb) is not similar to downstream site (35 ppb) but both exceed 20
ppb = 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; further sampling is necessary.
Possible Solution: Following the collection of additional samples from plumbing
upstream to pinpoint sources of lead, replace plumbing with lead-free materials;
retest water for lead.
For sample locations, see Exhibit 25: Plumbing Diagram for a Single-Level Building
and Exhibit 26: Plumbing Diagram for a Multilevel Building.
75
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Initial and Follow-Up Sampling by Outlet Type
LOOPS AND/OR HEADERS
A loop is a closed circuit of a plumbing branch that 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 buildings where additions and repairs have been made to the
original structure.
Sample Collection Procedures:
Sample 1H (header) or II (loop)
Locate the sampling point furthest from the service connection or riser pipe on the floor.
Open the faucet and let it run for 30 seconds before collecting this sample. Fill the
sample container with 250 mL of water. The purpose of flushing the water is to clear the
faucet and plumbing between the sample site and the loop and/or header pipe, thus
ensuring collection of a representative sample.
Interpreting Test 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 that 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. The laboratory will
provide instructions on how to package and handle the sediment.
If the lead level of Sample 1H or II is equal to the lead level hi a sample taken
downstream from Sample Site 1H or II, the lead is contributed from the head or the
loop and from interior plumbing upstream from the header or loop. Possible sources of
lead may be the loop, header, riser pipe, or service connection.
If the lead level hi 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
•
76
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Initial and Follow-Up Sampling by Outlet Type
the header or loop 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.
Example:
Sample 1H or II (23 ppb) exceeds 20 ppb = collect additional samples from the
plumbing upstream supplying water to the loop or header; compare the results with
those taken from the service line or the riser pipe that supplies water to the loop
and/or header.
Sample 1H or II (23 ppb) significantly exceeds 5 ppb and Sample 1H or II is less
than downstream site (25 ppb) = a small portion of the lead (2 ppb) is contributed
downstream of the sample site.
Possible Solution: Following the collection of additional samples upstream from
the header or loop to pinpoint source of lead, replace affected plumbing with lead-
free materials; retest water for lead.
For sample locations, see Exhibit 25: Plumbing Diagram for a Single-Level Building
and Exhibit 26: Plumbing Diagram for a Multilevel Building.
RISER PIPES
A riser is the vertical pipe that carries water from one floor to another.
Sample Collection Procedures:
Sample U
Open the tap closest to the riser pipe. Let the water run for 30 seconds before collecting
the sample. Fill the sample container with 250 mL of water. The purpose of flushing the
water is to clear the faucet and plumbing between the sample site and the riser pipe. This
approach will ensure collection of a representative sample.
77
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Initial and Follow-Up Sampling by Outlet Type
Interpreting Test Results:
• If the lead level in Sample U exceeds 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 of Sample U equals the lead level in a sample taken downstream
from Sample Site U, the source of the lead is the riser pipe or the plumbing and service
connection upstream from the riser pipe.
• If the lead level hi Sample 1J is close or equal to 5 ppb, the portion of the riser pipe
and plumbing upstream from Sample Site U and the service connection are not contribut-
ing lead to the water. The source of the lead is downstream of the sample site.
If the lead level hi Sample 1J significantly exceeds 5 ppb (for example, 10 ppb) and is
less than the lead level hi a sample taken downstream from Sample Site U, a portion
of the lead is contributed downstream from the sample site.
Example:
Downstream Site is 25 ppb, Service Connection Sample is 4 ppb, and Sample U (6
ppb) is less than 20 ppb = additional samples from upstream need not be collected;
21 ppb of lead is contributed from the downstream site.
Sample U (6 ppb) is not equal to downstream site (25 ppb) = source of lead is not
the riser pipe or the plumbing and service connection upstream from the riser pipe.
1J (6 ppb) is close to 5 ppb = the portion of the riser pipe and plumbing upstream
from Sample Site U and the service connection are not contributing lead to the
water; the source of lead is downstream of the sample site.
Possible Solution: Following the collection of samples from interior plumbing
downstream from the riser pipe and the affected outlet to pinpoint the source of
lead, replace affected plumbing with lead-free materials; retest water for lead.
For sample locations, see Exhibit 25: Plumbing Diagram for a Single-Level Build-
ing and Exhibit 26: Plumbing Diagram for a Multilevel Building.
•
78
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Initial and Follow-Up Sampling by Outlet Type
Exhibit 24 Summary of Samples
Initial Screening Follow-Up
Samples Samples
IS
1A
IB
1C
ID
IE
1M
2A
2B
3B, 4B
2C, 3C, 4C
2D
2E
2F
1G
1H
II
U
Summary of Samples
T^pe of Outlet or Plumbing
Service Connection to Distribution Main
Bubblers Without Central Chiller
Bubblers With Central Chiller
Central Chiller Unit
Water Coolers
Bottled Water Dispensers
Ice Making Machines
Water Faucets (Taps)
INTERIOR PLUMBING
Laterals
Headers
Loops
Risers
79
-------
Initial and Follow-Up Sampling by Outlet Type
Exhibit 25 Plumbing Diagram for a Single-Level Building
80
-------
Initial and Follow-Up Sampling by Outlet Type
Exhibit 26 Plumbing Diagram for a Multilevel Building
81
-------
Initial and Follow-Up Sampling by Outlet Type
82
Exhibit 27 Water Supply to Water Fountains and Bubblers from Central Chiller
-------
Initial and Follow-Up Sampling by Outlet Type
Collect and analyze
screening sample from
outlets (Morning First Draw).
Lead level In screening
sample is below 20 ppb.
Outlet O.K. to use.
Collect and analyze
follow-up samples (interior
plumbing). Lead levels are
reduced to below 20 ppb.
Lead level In Interior
plumbing follow-up samples
is close or equal to lead
levels observed In
screening sample.
-iI«J^
The interior plumbing
Is a source of lead.
-<^^>-
Collect and analyze
service connection
sample.
^mjr
Lead level service
connection sample Is close
or equal to lead levels
observed in interior
plumbing follow-up samples.
^nresj^
The service connection
is a source of lead.
nr
1
^ Lead levels In inter
n plumbing follow-up sa
are close or equal to E
1
^JNOL^
A—l The Interior plumbing
y— , outlet are sources ofk
_R Lead levels In servk
^o . connection sample is
r or equal to 5 ppb
-LN-U
The Interior plumbing
service line are sour
of lead.
£Li~v^ The outlet is a Lr\
""ppb'rV source of tead. ,-y
•
and
sod.
'? (shs The interior plumbing i-K
close v^ Is a source of lead. ^
and 1 r\
165 i J
i
K
,-„/
Select
remedy.
Exhibit 28 Overall Sampling Strategy
83
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Appendix A—Directory of EPA and State
Drinking Water Programs
Regional Contacts
Region I
Ms. Ellie Kwong
Groundwater Management and Water Supply Branch
U.S. Environmental Protection Agency Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3620
Region II
Mr. Taj Khan
Drinking Water/Ground Water Protection Branch
U.S. Environmental Protection Agency Region n
26 Federal Plaza, Room 853
New York, NY 10278
(212) 264-1358
Region III
Mr. George Rizzo
Drinking Water/Ground Water Protection Branch
U.S. Environmental Protection Agency Region DI
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-0609
Region IV
Mr. Tom DeGaetano
Municipal Facilities Branch
U.S. Environmental Protection Agency Region IV
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347:2913
Region V
Mr. John Delessandro
Technical Support Unit
U.S. Environmental Protection Agency Region V
77 West Jackson
Chicago, IL 60604
(312) 353-4914
Region VI
Mr. Len Pardee
Water Supply Branch
U.S. Environmental Protection Agency Region VI
First Interstate Bank Tower at Fountain Place
1445 Ross Avenue, 12th Floor, Suite 1200
Dallas, TX 75202
(214) 655-8086
Region VII
Ms. Elizabeth Murtagh-Yaw
Drinking Water Branch
U.S. Environmental Protection Agency Region VJJ
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7440
Region VIII
Ms. Marty Swickard-
PWSP Section - 8WM-DW
Drinking Water Branch
U.S. Environmental Protection Agency Region Vffl
999 18th Street, Suite 500
Denver, CO 80202
(303) 293-1629
Region IX
Ms. Cheryl Gustafson
Public Water Supply Section
U.S. Environmental Protection Agency Region DC
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1828
Region X
Ms. Wendy Marshall
Lead Contact WD-132
Ground Water and Drinking Water Branch
U.S. Environmental Protection Agency Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-1890
A-l
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Appendix A—Directory of EPA and State Drinking Water Programs
State LCCA Contacts
EPA REGION I
Connecticut
Mr. Bob Rivard, Supervising Sanitary Engineer
Water Supply Section
Connecticut Department of Health Services
150 Washington Street
Hartford, CT 06106
(203) 566-1253
Maine
Mr. Peter Moulton, Drinking Water Manager
Drinking Water Program
Maine Division of Health
State Station 10
Augusta, ME 04333
(207) 287-2070
Massachusetts
Mr. Chuck Larson, Environmental Engineer
Division of Water Supply
Massachusetts Department of Environmental Protection
One Winter Street
Boston, MA 02108
(617) 292-5857
New Hampshire
Mr. Richard Thayer, Sanitary Engineer
New Hampshire Department of Environmental Services
P.O. Box 95
6 Haven Drive
Concord, NH 03301
(603) 271-3139
Rhode Island
Ms. Donna Pytell, Sanitary Engineer
Division of Drinking Water Quality
Rhode Island Department of Health
3 Capitol Hill
Providence, RI 02908
(401) 277-6867
Vermont
Ms. Jean Nicolai/Benson Sargent
Drinking Water Program
Water Supply Division
Vermont Department of Health
Old Pantry Building
103 South Main Street
Waterbury, VT 05671-0403
(802) 241-3400
EPA REGION II
New Jersey
Mr. Sonny Saroya
Bureau of Safe Drinking Water
Division of Water Resources
New Jersey Department of Environmental Protection
P.O. Box CN-029
Trenton, NJ 08625
(609) 292-5550
New York
Mr. David Mead
New York Department of Health
2 University Plaza/Western Avenue
Room 406
Albany, NY 12203-3399
(518) 458-6706
Puerto Rico
Mrs. Olga I. Rivera, Acting Director
Puerto Rico Department of Health
Edificio A. Centra Medico
Call Box 70184
San Juan, PR 00936
(809) 763-4307
Virgin Islands (St. Thomas)
Mr. Ira Hobson, Supervisor, PWSS Program
Government of the Virgin IslandsDepartment of Planning and
Natural Resources
Nisky Center, Suite 231, Nisky 45A
St. Thomas, VI 00802
(809) 774-3320
A-2
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Appendix A—Directory of EPA and State Drinking Water Programs
EPA REGION III
Delaware
Mr. Ed Hallock
Environmental Health Specialist in
Public Water System Supervision Program
Division of Public Health
Delaware Department of Health and Social Services
P.O. Box 637
Dover, DE 19901
(302) 739-5410
[Both Lead and Drinking Water Contact]
District of Columbia
Preventive Health Services *
Commission of Public Health
Government of the District of Columbia
1660 L. Street, NW, Suite 815
Washington, DC 20036
(202) 673-6741
[Childhood Lead Poisoning Prevention Contact]
Maryland
Ms. Susan Guyaux
Center for Special Toxics
Lead Poisoning Prevention Program
Maryland Department of the Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3859
[Lead Contact]
Pennsylvania
Mr. Frederick A. Marrocco, Chief
Division of Water Supplies
Pennsylvania Department of Environmental Resources
P.O. Box 2357
Harrisburg, PA 17120
(717) 787-9037
[Both Lead and Drinking Water Contact]
Virginia
Mr. Robert B. Stroube, M.D., M.P.H.
State Health Commissioner
Virginia Department of Health
109 Governor Street
Richmond, VA 23219
(804) 786-3561
[Lead Contact]
West Virginia
Mr. Donald A. Kuntz, P.E. Director
Environmental Engineering Division
Office of Environmental Health Services
West Virginia Department of Health and Human Resources
815 Quarrier Street, Suite 418
Charleston, WV 25301
(304) 558-2981
[Both Lead and Drinking Water Contact]
EPA REGION IV
Alabama
Mr. Joe Alan Power, Director
Public Water Supply Branch
Alabama Department of Environmental Management
1751 Congressman W.L. Dickinson Drive
Montgomery, AL 36109-2698
(205) 271-7773
Florida
Mr. Van Hoofnagle, Administrator
Drinking Water Section
Florida Department of Environmental Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 487-1762
Georgia
Mr. Fred D. Lehman, Manager
Drinking Water Program
Georgia Department of Natural Resources
Floyd Towers East, Suite 1362
205 Butler Street, SE
Atlanta, GA 30334
(404) 651-2750
A-3
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Appendix A—Directory of EPA and State Drinking Water Programs
Kentucky
Mr. John T. Smither, Manager
Drinking Water Branch
Kentucky Natural Resources and
Environmental Protection Cabinet
14 Reilly Road
Frankfort, KY 40601
(502) 564-3410
Mississippi
Mr. David Mitchell, Director
Division of Water Supply
Mississippi State Department of Health
P.O. Box 1700
Jackson, MS 39205
(601) 960-7518
North Carolina
Mr. Wallace Venrick, Chief
Public Water Supply Section
North Carolina Department of Environmental Health
and Natural Resources
f Division of Environmental Health
P.O. Box 29536
Raleigh, NC 27626-0536
(919) 733-2321
South Carolina
Mr. Robert E. Malpass, Chief
Bureau of Drinking Water Protection
South Carolina Department of Health
and Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 733-5310
Tennessee
Mr. David Draughon, Director
Division of Water Supply
Tennessee Department of Environment and Conservation
401 Church Street
Sixth Floor, L & C Tower
Nashville, TN 37219-5404
(615) 532-0191
EPA REGION V
Illinois
Mr. Dean Thady
State Plumbing Consultant
Office of Health Protection
Illinois Department of Public Health
525 West Jefferson Street
Springfield, IL 62761
(217) 524-0799
[For questions on plumbing]
Mr. G. Michael Brant
Office of Health Protection
Division of Environmental Health
Illinois Department of Public Health
525 West Jefferson Street
Springfield, IL 62761
(217) 524-5830
[For questions on fountains in schools]
Indiana
Mr. Wayne Brattain ^
Drinking Water Branch
Indiana Department of Environmental Management
P.O. Box 6015
Indianapolis, IN 46206-6015
(317) 233-4179
Michigan
Division of Water Supply
Michigan Department of Public Health
3423 North Logan/Martin L. King Jr. Boulevard
P.O. Box 30195
Lansing, MI 48909
(517) 335-9215
Minnesota
Ms. Lih-In Rezania
Drinking Water Protection Section
Division of Environmental Health
Minnesota Department of Health
925 Delaware Street, SE
P.O. Box 59040
Minneapolis, MN 55459-0040
(612) 627-5488
A-4
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Appendix A—Directory of EPA and State Drinking Water Programs
Ohio
Mr. Dan Chatfield
Ohio Department of Health
246 North High Street
P.O. Box 118
Columbus, OH 43266-0118
(614) 466-1450
Wisconsin
Ms. Cindy Diedrich
Public Water Supply Section
Bureau of Water Supply
Wisconsin Department of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, WI 53707
(608) 267-2451
EPA REGION VI
Arkansas
Engineering Division
Arkansas Department of Health
4815 West Markham
Little Rock, AR 72203-3867
(501) 661-2623
Louisiana
Louisiana Department of Health and Hospitals
Office of Public Health
P.O. Box 60630, Room 403
New Orleans, LA 70160
(504) 568-5100
New Mexico
New Mexico Environmental Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
(505) 827-7536
Oklahoma
Oklahoma Department of Environmental Quality
Water Quality Service-0207
1000 NE 10th Street
P.O. Box 53551
Oklahoma City, OK 73117-1212
(405)271-5205 x!48
Texas
Texas National Resource Conservation Commission
P.O. Box 13087
Austin, TX 78711-3087
(512) 908-6020
EPA REGION VII
Iowa
Ms. Rita Gergely
Bureau of Health Engineering and Consumer Safety
Division of Disease Prevention
Iowa Department of Public Health
Lucas State Office Building
321 East 12th Street
Des Moines, IA 50319-0075
(512) 242-6340
Kansas
Contact school system for information
Missouri
Mr. Mike Carter
Bureau of Environmental Epidemiology
Missouri Department of Health
P.O. Box 570
Jefferson City, MO 65102
(314) 751-6102 or 1-800-392-7245
Nebraska
Mr. Jack Daniel, Director
Division of Drinking Water and Environmental Sanitation
Nebraska Department of Health
301 Centennial Mall South
P.O. Box 95007
Lincoln, NE 68509
(402) 471-2541
A-5
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Appendix A—Directory of EPA and State Drinking Water Programs
EPA REGION VIII
Colorado
Ms. Michelle Bolyard
Drinking Water Section
Water Quality Control Division
Colorado Department of Health
4300 Cherry Creek Dr. South
Denver, CO 80222
(303) 692-3539
Montana
Mr. Terry Campbell
Drinking Water Section, Water Quality Bureau
Montana Department of Health and Environmental Sciences
Cogswell Building
Helena, MT 59620
(406) 444-5256
North Dakota
Mr. Sherwin Wanner
North Dakota State Department of Health
and Consolidated Laboratories
Municipal Facilities Division
1200 Missouri Avenue, Box 5520
Bismarck, ND 58502-5520
(701) 221-5210
South Dakota
Mr. Michael Getty
South Dakota Department of Environmental
and Natural Resources
Office of Drinking Water
Joe Foss Building
Pierre, SD 57501-3181
(605) 773-3754
Utah
Ms. Patti Fauver
Utah Department of Environmental Quality
Division of Drinking Water
P.O. Box 144830
Salt Lake City, UT 84114-4830
(801) 538-6159
Wyoming
Ms. Maureen Doughtie
United States Environmental Protection Agency Region 8
PWSIE Section
999 18th Street, Suite 500
Denver, CO 80202
(303) 293-1629
EPA REGION IX
Arizona
Mr. Michael Kleminski
Compliance Officer
Drinking Water Compliance Unit
Arizona Office of Water Quality
3033 North Central Avenue
Phoenix, AZ 85012
(602) 207-4641
California
Technical Programs Branch
California Department of Health Services
Division of Drinking Water
2151 Berkeley Way, Room 113
Berkeley, CA 94704
(510) 540-2154
Hawaii
Hawaii Department of Health
Five Waterfront Plaza, Suite 250
500 Ala Moana Boulevard
Honolulu, HI 96813
(808) 586-4258
Nevada
Nevada Department of Human Resources
Bureau of Health Protection Services
505 East King Street
Carson City, NV 89710
(702) 687-4750
A-6
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Appendix A—Directory of EPA and State Drinking Water Programs
EPA REGION X
Alaska
Alaska Department of Environmental Conservation
Drinking Water Program Manager
410 Willoughby, Suite 105
Juneau, AK 99801
(907) 465-5300
Idaho
Mr. Eldon Nelson, Support Services Supervisor
Idaho Department of Education
650 West State
Boise, ID 83720
(208) 334-2203
Oregon
Mr. Dave Leland, Supervisor
Drinking Water Section
Oregon Health Division
P.O. Box 14450
Portland, OR 97214-0450
(503) 731-4010
Washington
Washington Department of Health
Division of Drinking Water
P.O. Box 47822
Olympia, WA 98504-7822
(206) 753-9674
A-7
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Appendix B—Glossary of Terms
Bubbler: A water fountain fixture connected to the water .
supply. A bubbler does not contain a refrigeration unit.
Some bubblers are attached to central chiller units, while
others are not.
Chiller: A central refrigeration unit providing cold water to
some types of bubblers.
Corrosion: A dissolving and wearing away of metal caused
by a chemical reaction (e.g., between water and the piping
that the water contacts).
Drinking Water Fountain: A fixture connected to the water
supply that provides water as needed. There are four types
of drinking water fountains: (1) bubblers without central
chillers, (2) bubblers with central chillers, (3) water coolers,
and (4) bottled water dispensers.
Faucet ("tap" and "fixture"): The device attached to a
water dispensing apparatus (i.e., bubbler, cooler, pipe, etc.)
from which the water flows. The term "faucet" is used
interchangeably with the terms "tap" and "fixture."
Fittings and Valves: Any of numerous mechanical devices
by which the flow of water may be started, stopped, or
regulated by a movable part that opens, shuts, or partially
obstructs one or more ports of passageway.
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. The lead-free
requirements of the 1986 Safe Drinking Water Act require
that solders and flux not contain more than 0.2 percent lead.
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 (e.g., 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.
Potable Water Pipes: The pipes in a distribution system and in
a building which carry water intended for human consumption.
Public Water System: Any system that has 15 or more
service connections and is in operation at least 60 days per
year or any system serving 25 or more persons daily at least
60 days per year.
Riser: The vertical pipe that carries water from one floor to
another.
Sediment: Matter from piping or other water conveyance
device that settles to the bottom of the water in the apparatus.
If lead components are used in plumbing materials, lead
sediments may form and result in elevated water lead levels.
Service Connector: The pipe that carries tap water from the
public water main to a building. In the past, these were
often comprised of lead materials.
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 that actively cools water for human
consumption. The reservoir can consist of a small tank or a
pipe coil.
B-l
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Appendix C—Water Cooler Summary
The Lead Contamination Control Act (LCCA), which .
amended the Safe Drinking Water Act, was signed into law on
October 31, 1988 (P.L. 100-572). The potential of water
coolers to supply lead to drinking water in schools and day care
centers was a principle focus of this legislation. Specifically, the
LCCA mandated that the Consumer Product Safety Commission
(CPSC) order the repair, replacement, or recall and refund of
drinking water coolers with lead-lined water tanks. In addition,
the LCCA called for a ban on the manufacture or sale in
interstate commerce of drinking water coolers that are not lead-
free. Civil and criminal penalties were established under the
law for violations of this ban. With respect to a water cooler
that may come in contact with drinking water, the LCCA '
defined the term "lead-free" to mean:
"not more than 8 percent lead, except that no drinking
water cooler which contains any solder, flux, or
storage tank interior surface which may come in
contact with drinking water shall be considered lead
free if the solder, flux, or storage tank interior surface
contains more than 0.2 percent lead."
Another component of the LCCA was the requirement that
EPA publish and make available to the states a list of
drinking water coolers, by brand and model, that are not
lead-free. In addition, EPA was to publish and make
available to the states a separate list of the brand and model
of water coolers with a lead-lined tank. EPA is required to
revise and republish these lists as new information or
analyses become available.
Based on responses to a Congressional survey in the winter
of 1988, three major manufacturers, the Halsey Taylor
Company, EBCO Manufacturing Corporation, and Sunroc
Corporation, indicated that lead solder had been used in at
least some models of their drinking water coolers. On April
10, 1988, EPA proposed in the Federal Register (at 54 FR
14320) lists of drinking water coolers with lead-lined tanks
and coolers that are not lead-free. Public comments were
received on the notice, and the list was revised and published
on January 18, 1990 (Part m, 55 FR 1772). See Table C-l
for a list of water coolers with lead components.
'Based on an analysis of 22 water coolers at a U.S. Navy facility and
subsequent data obtained by EPA, EPA believes the most serious cooler
contamination problems are associated with water coolers that have lead-
lined tanks.
Prior to publication of the January 1990 list, EPA determined
that Halsey Taylor was the only manufacturer of water
coolers with lead-lined tanks.' Table C-2 presents a listing
of model numbers of the Halsey Taylor drinking water
coolers with lead-lined tanks that had been identified by EPA
as of January 18, 1990.
Since the LCCA required the CPSC to order manufacturers
of coolers with lead-lined tanks to repair, replace or recall
and provide a refund of such coolers, the CPSC negotiated
such an agreement with Halsey Taylor through a consent
order published on June 1, 1990 (at 55 FR 22387). The
consent agreement calls on Halsey Taylor to provide a
replacement or refund program that addresses all the water
coolers listed in Table C-2 as well as "all tank-type models
of drinking water coolers manufactured by Halsey Taylor,
whether or not those models are included on the present or
on a future EPA list." Under the consent order, Halsey
Taylor agreed to notify the public of the replacement and
refund program for all tank type models.
If you have one of the Halsey Taylor water coolers noted i
Table C-2, contact Halsey Taylor (address and phone no
below) to learn more about the requirements surrounding
their replacement and refund program.
Halsey Taylor
2222 Camden Court
Oak Brook, IL 60520
(708) 574-3500
SPECIAL NOTE:
Experience indicates that newly installed brass
plumbing components containing 8 percent or less lead,
as allowed by the LCCA and the Lead Ban, can
contribute high lead levels to drinking water for a
considerable period after installation. U.S. water
cooler manufacturers have notified EPA that since
September 1993, the components of water coolers that
come in contact with drinking water have been made
with non-lead alloy materials. These materials include
stainless steel for fittings and water control devices,
brass made of 60 percent copper and 40 percent zinc,
terillium copper, and food grade plastic.
C-l
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Appendix C—Water Cooler Summary
Table C-1
Water Coolers With Other Lead Components
EBCO Manufacturing
All pressure bubbler water coolers with shipping dates from 1962 through 1977 have a bubbler valve containing
lead. The units contain a single, SO-SO tin-lead solder joint on the bubbler valve. Model numbers for coolers in this
category are not available.
The following models of pressure bubbler coolers produced from 1978 through 1981 contain one SO-SO tin-lead
solder joint each.
CP3 DP15W DPM8 7P
DP16M DP5S C10E PX-10
WTC10 DP13M-60 DP14M CP10-50
DP20-50 DP7SM DP10X DP13A
CP3-50 DP13M DP3RH DP5F
CP10 DP20 DP12N DP7WM
13P DPM8H
DP7S DP13SM
CP5 CP5M
DP13A-50 EP10F
CP3M EP5F
DP14A-50/60
DP15M DP3R DP8A
DP7M DP7MH DP7WD
DP15MW DP3R DP14S
DP5M DP10F CP3H
13PL DP8AH DP13S
Hakey Taylor
• Lead solder was used in these models of water coolers manufactured between 1978 and the last week of 1987:
WMA-1
S3/5/10D
SCWT/SCWT-A
BFC-4F/7F/4FS/7FS
SWA-1
S300/500/100D
DC/DHC-1
The following coolers manufactured for Haws Drinking Faucet Company (Haws) by Halsey Taylor from November
1984 through December 18, 1987 are not lead-free because they contain 2 tin-lead solder joints. The model
designations for these units are as follows:
HC8WT HC14F HC6W HWC7D HC8WTH HC14FH HC8W HC2F HC14WT
HC14FL HC14W HC2FH HC14WTH HC8FL HC4F HC5F HC14WL HCBF7D
HC4FH HC10F HC16WT HCBF7HO HC8F HC8FH HC4W HWC7
Table C-2
HaJsey Taylor Water Coolers With Lead-Lined Tanks
The following six model numbers have one or more units in the model series with lead-lined tanks:
WM8A WT8A GC10ACR GC10A GC5A RWM13A
The following models and serial numbers contain lead-lined tanks:
WM14A Serial No. 843034
WT21A Serial No. 64309550
WM14A Serial No. 843006
WT21A Serial No. 64309542
WT11A Serial No. 222650
LL14A Serial No. 64346908
C-2
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Appendix D —List of Lead Resources
Publications
Unless otherwise specified, these publications can be ordered
from the EPA National Safe Drinking Water Hotline listed
below.
Lead and Your Drinking Water (booklet), U.S. EPA Office
of Ground Water and Drinking Water, EPA 810/F-93-001,
April 1987.
Lead Contamination Control Act (P.L. 100-572) (Federal
statute) and supporting documents available through House
Document Room, House of Representatives, Washington, DC
20515 (202) 225-3456.
Lead Contamination Control Act (LCCA) (pamphlet), U.S.
EPA Office of Ground Water and Drinking Water, EPA
570/9-89-AAA, August 1989.
Lead in Drinking Water in Schools and Non-Residential
Buildings (manual), US EPA Office Of Ground Water and
Drinking Water, EPA 812-B-94-002, April 1994.
Sampling for Lead in Drinking Water in Nursery Schools
and Day Care Facilities (booklet), US EPA Office of Ground
Water and Drinking Water 812-B-94-003, April 1994.
The Lead Ban: Preventing the Use of Lead in Public Water
Systems and Plumbing Used for Drinking Water (pamphlet
on the Federal lead ban), U.S. EPA Office of Ground Water
and Drinking Water, EPA 570/9-89-BBB, August 1989.
Federal Register Notices on Water Coolers:
(1) April 10, 1989, Part n, 54 FR 14316
Explanation of the LCCA and availability of
guidance document.
(2) April 10, 1989, Part m, 54 FR 14320
Proposed list of water coolers that are not lead-free.
(3) January 18, 1990, Part ffl, 55 FR 1772
Final and proposed list of water coolers that are not
lead-free.
(4) June 1, 1990, 55 FR 22387
Notice of Haisey Taylor consent order agreement.
EPA National Safe Drinking Water Hotline
(800) 426-4791,
Hotline operates Monday through Friday, 9:00 am
to 5:30 pm (EST), except Federal holidays.
D-l
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Appendix E— Sample Recordkeeping Form
Record of Sampling
i
Name of Building
Name of Sample Collector
Contact Person for this Record
Sample ID Number
(circle sample type) Service Connection Initial 1st Follow-up 2nd Follow-up
Length of Flush
Type of Outlet
Mfg/Model
Serial #
Date of Installation
Location
Date of Collection
Time of Collection
Name of Laboratory Used
Lead Concentration (ppb)
NOTES:
am
pm
E-l
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Appendix F —Preservation of
Samples and Sample Containers
This appendix contains information pertaining to the preservation of samples and sample containers. If you plan to
use a certified drinking water laboratory to conduct analyses of your samples, they should be aware of these
requirements. In addition, they wilt provide you with actual samplers or sample containers and instructions. The sample
containers will have been prepared prior to your receipt. The lab will also specify how to handle the sample containers
and when to submit them after taking your samples.
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 results of analyses 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 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
adsoprtion onto the sample container wall, the sample will
need to be acidified 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 promptly ship it to the
laboratory. Upon receipt, the laboratory will acidify the
sample. The sample can be held up to 14 days prior to
acidification without loss of lead through absorption.
For more detailed information, refer to the following EPA
manuals:
Methods for Chemical Analysis of Water and Wastes, EPA-
600/4-79-020, revised edition, March 1983 (available from •
U.S. EPA, R&D Publications, 26 West Martin Luther King
Blvd., Cincinnati, OH 45268).
Methods for the Determination of Metals in Environmental
Samples, EPA/600/4-91/010, June 1991 (available from the
National Technical Information Service, Pub. No. PB91-
231498 (703) 487-4650).
Manual for the Certification of Laboratories Analyzing
Drinking Water, EPA-570/9-90/008, April 1990 (available from
the National Technical Information Service, (703) 487-4650).
F-l
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