Revised Technical Guidance

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Disclaimer
This manual contains recommendations on how to address lead in school drinking water systems; these are suggestions
only and are not requirements. This manual does, however, also contain an overview of requirements concerning lead
in drinking water. The statutory provisions and regulations described in this document contain binding requirements.
The general description here does not substitute for those laws or regulations; nor is this document a regulation itself.
As a result, you will need to be familiar with the details of the rules that are relevant to your school drinking water; you
cannot rely solely on this guidance for compliance information. Also, many states (or tribes) and localities have
different, more stringent requirements than EPA's, so you will need to find out what other laws and regulations apply to
school drinking water in addition to the ones described here.

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 3Ts for Reducing Lead in Drinking Water in Schools:
                                             Revised Technical Guidance


Contents


Introduction	4

I.  Training	6
1.  What You Should Know about Lead in Drinking Water	 6
      1.1 Health Effects of Lead	 6
      1.2 Sources of Lead	 6
      1.3 How Lead Gets into Drinking Water	7
      1.4 How Lead in Drinking Water is Regulated	 11
2.  Planning Your Program and Establishing Partnerships	 13
      2.1 Assigning Roles	 13
      2.2 School Records	 13
      2.3 Establishing Partnerships	 13
         2.3.1 Assistance from Your Public Water Supplier	 13
         2.3.2 Assistance from Your Local Health Office	 15
         2.3.3 Assistance from Your State Drinking Water Program	 15
         2.3.4 Assistance from Certified Laboratories	 15
         2.3.5 Assistance from Local Community Organizations	 16

II. Testing	 17
3.  Assessment and Strategy: Plumbing Profile and Sampling Plan	 17
      3.1 Development of a Plumbing Profile for Your Facility's Plumbing	 17
      3.2 Who Should Create the  Sampling Plan? - Leadership in Sampling	 24
      3.3 Where Should I Sample? - Determining Sample Locations	 24
      3.4 Who Should Collect the Samples and Where Do Samples Go for Analysis?
         Collection and Analysis  of Samples	 25
4.  Conducting Sampling	 28
      4.1 General Sampling Procedures	 28
      4.2 Collection Procedures	 28
      4.3 Laboratory Analysis and Handling of Sample Containers	 29
      4.4 Overview of the Two-Step Sampling Process	 29
         4.4.1 Step 1: Initial Sampling	 29
         4.4.2 Step 2: Follow-Up  Sampling	 30
         4.4.3 Initial and Follow- Up Sampling Protocol	 32
         4.4.4 Sampling for Other Parameters	 35

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3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
5.  Remedies    	 54
      5.1 Routine Control Measures	 54
      5.2 Interim (Short-Term) Control Measures	 54
      5.3 Permanent Remedies 	 56

III. Telling	64
6.  Informing the Public about Lead	 64
      6.1 Techniques for Disseminating Public Information	64
      6.2 The Components of an Effective General Communication Strategy	65
      6.3 Participants	 65
      6.4 Timing	66
      6.5 Content	66
      6.6 Methods and Manner of Communication	66
      6.7 Sample Public Notice Materials	67

Appendix A - Glossary of Terms	72

Appendix B - Publication List	74

Appendix C - Resources	76

Appendix D - List of State Drinking Water Programs	77

Appendix E - Water Cooler Summary	85

Appendix F - Sample Recordkeeping Form	88

Appendix G - Preservation of Samples and Sample Containers	89

Appendix H - Example Scenarios for Water Sample Results	90

Appendix I - Plumbing Profile Questionnaire	95

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                                                         3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Exhibits
Exhibit 1.1:  Potential Sources of Lead in Schools 	9
Exhibit 1.2:  Common Drinking Water Outlets	 10
Exhibit 3.1:  Sample Plumbing Profile Questionnaire	 18
Exhibit 3.2:  Plumbing Configuration for a Single-Level Building	26
Exhibit 3.3:  Plumbing Configuration for a Multi-Level Building	27
Exhibit 4.1:  Pipe Volumes for Copper Pipe	33
Exhibit 4.2:  Sample Strategy Flowchart	34
Exhibit 4.3:  Service Connection Sampling	36
Exhibit 4.4:  Drinking Water Fountains: Bubblers	38
Exhibit 4.5:  Drinking Water Fountains: Water Coolers	40
Exhibit 4.6:  Drinking Water Fountains: Bottled Water Dispensers	44
Exhibit 4.7:  Ice Making Machines	45
Exhibit 4.8:  Water Faucets (Taps)	46
Exhibit 4.9:  Sampling Interior Plumbing	47
Exhibit 4.10: Sample Sites for a Single-Level Building	52
Exhibit 4.11: Sample Sites for a Multi-Level Building	53
Exhibit 5.1:  Flushing Directions by Outlet Type	55
Exhibit 5.2a: Remediation Flow Chart (part 1)	59
Exhibit 5.2b: Remediation Flow Chart (part 2)	60
Exhibit 5.2c: Remediation Flow Chart (part 3)	61
Exhibit 5.3:  Case Study 1	62
Exhibit 6.1:  Sample Public Notice Letter	68
Exhibit 6.2:  Sample Press Release for Local Media	69
Exhibit 6.3:  Sample Newsletter Article	70

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3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Introduction

The Environmental Protection Agency (EPA) developed this guidance manual because the Agency is concerned
about the potential for elevated lead levels in drinking water in schools. Children are most susceptible to the
effects of lead, because their bodies are still undergoing development. The adverse health effects from lead
include reduced IQ and attention span, learning disabilities, poor classroom performance, hyperactivity,
behavioral problems, impaired growth, and hearing loss.

There is no federal law requiring testing of drinking water in schools, except for schools that have their own
water supply and are thus regulated under the Safe Drinking Water Act (SDWA). The vast majority of public
water suppliers do not include schools in their sampling plans because regulations (specifically the Lead and
Copper Rule)  require sampling of single family dwellings. States and local jurisdictions may, however,
establish their own programs for testing drinking water lead levels in schools. EPA suggests that schools
implement programs for reducing lead in drinking water as part of the school's overall plan for reducing
environmental threats. Safe and healthy school environments foster healthy children, and may improve
students' general performance.

Lead most frequently gets into drinking water by leaching from plumbing materials and fixtures as water
moves through your school's distribution system. Even though the drinking water you receive from your
water supplier meets federal and state standards for lead, your facility may have elevated lead levels due to
plumbing materials and water use patterns. Because lead concentrations can change as water moves through
the distribution system, the best way to know if a school might have elevated levels of lead in its drinking
water is by testing the water in that school. Testing facilitates an evaluation of the plumbing and helps target
remediation. It is a key step in understanding the problem, if there is one, and designing an appropriate
response.

This guidance manual is intended for use by school officials responsible for the maintenance and/or safety of
school facilities including the drinking water. The guidance introduces the 3Ts for reducing lead in drinking
water. The 3Ts are:

        >•      Training school officials to raise awareness of the potential occurrences, causes, and health
              effects of lead in drinking water; assist school officials in identifying potential areas where
              elevated lead may occur; and establishing a testing plan to identify and prioritize testing sites.

        *      Testing drinking water in schools to identify potential problems and take corrective actions as
              necessary.

        *•      Telling students, parents, staff, and the larger community about monitoring programs,
              potential risks, the results of testing, and remediation actions.

The purpose of this manual is to help schools minimize their students' and staff's exposure to lead in drinking
water. This manual is specifically targeted at schools that receive water from water utilities or water suppliers
such as cities, towns and water districts.  This guidance manual replaces the 1994 EPA guidance document
Lead in Drinking Water in Schools and Non-Residential Buildings.  By following the steps below, you will be
assured your facility does not have elevated levels of lead in the drinking water.

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                                                         3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance
Training
(1) Conduct a thorough review of this guidance document. Other reference documents are available. See
    Appendix B.

(2) Review available resources to find out what may already have been done and what assistance may be
    available to you. See Chapter 2.

(3) Develop a plumbing profile to assess the factors that contribute to lead contamination. See Chapter 3.

(4) Develop a drinking water sampling plan. See Chapter 3.


Testing	

(5) Test the water.  See Chapter 4.

(6) Correct any problems that are identified. See Chapter 5.


Telling	

(7) Communicate to students, parents, staff, and the larger community about what you are doing to protect
    them from possible exposure to lead in drinking water.  See Chapter 6.

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3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
I.  Training


1. What You Should Know about Lead in Drinking Water


1.1  Health Effects of Lead
Lead is a toxic metal that is harmful to human health. Lead has no known value to the human body.  The
human body cannot tell the difference between lead and calcium, which is a mineral that strengthens the
bones. Like calcium, lead remains in the bloodstream and body organs like muscle or brain for a few months.
What is not excreted is absorbed into the bones, where it can collect for a lifetime.

Young children, those 6 years and younger, are at particular risk for lead exposure because they have frequent
hand-to-mouth activity and absorb lead more easily than do adults. Children's nervous systems are still
undergoing development and thus are more susceptible to the effects of toxic agents. Lead is also harmful to
the developing fetuses of pregnant women.

No safe blood lead level in children has been determined. Lead can affect almost every organ and system in
your body. The most sensitive is the central nervous system (brain), particularly in children. Lead also
damages kidneys and the reproductive system. The effects are the same whether it is breathed or swallowed.
Low blood levels of lead (those below 10 ng/dL) have been associated with reduced IQand attention span,
learning disabilities, poor classroom performance, hyperactivity, behavioral problems, impaired growth, and
hearing loss. Very high lead level (blood lead levels above 70 ng/dL) can cause severe neurological problems
such as coma, convulsions, and even death.  The only method to determine a child's lead level is for them to
have a blood lead test done by a health provider.

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, juice, or formula.
1.2 Sources 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. Sources of lead exposure include
the following:

    (1) Lead based paint. The most common sources of lead exposure for children are chips and particles of
       deteriorated lead paint. Although children may be exposed to lead from paint directly by swallowing
       paint chips, they are more often exposed by house dust or soil contaminated by leaded paint. Lead
       paint chips become ground into tiny bits that become part of the dust and soil in and around homes.
       This usually occurs when leaded paint deteriorates or is subject to friction or abrasion (as on doors and
       windowsills and window wells). In addition, lead can be dispersed when paint is disturbed during
       demolition, remodeling, paint removal, or preparation of painted surfaces for repainting.

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                                                         3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
    (2) Lead in the air. Lead in the air comes from industrial emissions.
    (3) Lead in 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.

    (4) Lead industry. Byproducts brought home by industrial workers on their clothes and shoes.

    (5) Lead in consumer products and food. Lead may be found in some imported candies, medicines,
       dishes, toys, jewelry, and plastics.

    (6) Lead in water. Lead in water occurs 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: by banning the manufacture and sale of leaded paint; by phasing out lead additives in
gasoline, and by encouraging the phase-out of lead seams in food cans; by banning the sale of pipes and
plumbing for drinking water that are not "lead-free"; and by banning lead-lined water coolers, among other
activities.  More recently,  the government has begun to address persistent sources of lead in the environment.
For example, programs have been instituted to minimize the hazards posed by 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. Regulations affecting lead in
drinking water are described at the end of this chapter.
1.3 How Lead Gets into Drinking Water
Lead can get into drinking water in two ways:

    (1) by being present in the source water, such as coming from contaminated runoff or water pollution.

    (2) through an interaction between the water and plumbing materials containing lead, such as through
       corrosion.

(1) 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 is a naturally occurring metal and in some instances can get into well water. Lead can enter
    surface waters (waters from rivers, lakes, or 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, or waterways, which may enter the water supply. Lead
    from these sources can be easily removed by existing treatment plant technologies.

(2) Through Corrosion
    Most lead gets into drinking water after the water leaves the local well or treatment plant and comes into
    contact with plumbing materials containing lead. These include lead pipe and lead solder (commonly
    used until 1986) as well as faucets, valves, and other components made of brass. 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 released into the drinking water.

The critical issue is that even though your public water supplier may deliver 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.  The potential for lead to leach into water can increase the longer the water

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3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
remains in contact with lead in plumbing. As a result, facilities with intermittent water use patterns, such
as schools, may have elevated lead concentrations.  Testing drinking water in schools is important
because children spend a significant portion of their day in these facilities and are likely to consume
water while they are there. That is why testing water from your drinking water outlets for lead is so
important. Drinking water outlets are locations where water may be used for consumption, such as a drinking
fountain, water faucet, or tap.

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.

As illustrated in Exhibit 1.1, once the water leaves the public water supply system or treatment plant, drinking
water comes into contact with plumbing materials that may contain lead. 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, such as lead  joints in
cast iron mains, service connections, pigtails, and goosenecks. These components may or may not be owned
by your water supplier.

Sediments containing lead may also collect in the low-lying sections of pipe or behind sediment screens. Lead-
containing sediments may result from minute particles of pipe, mineral deposits (scales), valves, fixtures,
solder, or flux that accumulate in the plumbing. This may happen during the initial construction of the
plumbing system, during repairs, when connecting new fixtures, when plumbing is otherwise disturbed, or
during normal use (e.g., turning of faucet handles, movement of valves, etc.). Sediment can also originate
from the public water systems water mains and service taps.

If the public water supplier finds unacceptable levels of lead at customers' homes, the system may have to
provide centralized treatment to minimize the corrosion of lead  into the water (see "How Lead in Drinking
Water is Regulated" in section 1.4). However, centralized treatment by a public water system does not
guarantee that corrosion of lead from plumbing will not occur within buildings served by the public water
system, i.e., your school.

Interior plumbing, soldered joints, leaded brass fittings, and various drinking water outlets that contain lead
materials are the primary contributors of lead in drinking water. It is also important to note that brass
plumbing components contain lead.  Examples of some of the common drinking water outlets are shown in
Exhibit 1.2. (The glossary in Appendix A provides definitions of the various drinking water outlets discussed
in this document.) Although there is an increased probability that a given plumbing component installed
prior to the 1990s could contain more lead than the newer components, the occurrence of lead in drinking
water can not be predicted based upon the age of the component or the school facility.

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                                                                    3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                      Exhibit 1.1:  Potential Sources  of Lead in Schools
                   Water from Public Water Supply
 Potential Sources of Lead
     In Drinking Water

Common sources of lead in
school drinking water include

•   Lead solder
   Lead fluxes
   Lead pipe and lead pipe
   fittings
   Fixtures, valves, meters, and
   other system components
   containing brass
•   Sediments
                                                                                     Soldered Joint
                                                                                                           Bubbler
School Building
I I


I
I
JUUL

                                                                            School Property

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                            Exhibit 1.2:  Common Drinking Water Outlets
                                          Wall
                                        Cooling Element2

                          Water Cooler
                                                                       Wall
                                                                                           Bubbler
                                                                                            Valve
    Bubbler
                                                      Wall
                                             Connecting
                                                Pipe
                                                Solder
                                                 Joint
 Cdd
Water
Faucet
                                                                             Screen
                                                      Cold Water
                                                     Faucet  (Tap)
                  1Valve locations are approximate and will vary, depending upon installation.
                  2Old cooling elements may be lead-lined.  For more information on replacement of lead-lined cooling
                  elements, see Appendix E of this document.
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                                                        3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
1.4 How Lead in Drinking Water is Regulated
Lead is regulated in public drinking water supplies under a federal 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 requirements developed by EPA apply to public water systems. Schools that are served by a public water
system (i.e., a drinking water system that they do not own or operate) are not subject to the SDWA
monitoring and treatment requirements, because those schools do not meet the definition of a public water
system.  However, some states may have monitoring and treatment requirements for these schools. Nearly all
states have a drinking water office that implements the SDWA on behalf of EPA.  Questions regarding the
regulation of your drinking water may be directed to the appropriate state drinking water program office (see
Appendix D for a directory of state programs).

Additional requirements under the Safe Drinking Water Act include specific provisions for controlling lead in
drinking water:

    ^  THE LEAD BAN (1986): A requirement that only lead-free materials be used in new plumbing and
       in plumbing repairs.

    *  THE LEAD CONTAMINATION CONTROL ACT (LCCA) (1988):  The LCCA further
       amended the SDWA. The LCCA is aimed at the identification and reduction of lead in drinking
       water at schools and child care facilities. However, implementation and enforcement of the LCCA has
       been at each state's discretion. School monitoring and compliance has varied widely.

    ^  THE LEAD AND COPPER RULE (1991): A regulation by EPA to minimize the corrosivity and
       amount of lead and copper in water supplied by public water systems.

The table below summarizes the significant elements of the SDWA with respect to lead in drinking water.
Note that the 1991 Lead and Copper Rule does not apply to schools that receive water from a public water
system.
                                                                                                     11

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       3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                                  REQUIREMENTS UNDER THE SAFE DRINKING WATER ACT


               The 1986 SDWA 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
               providing water for human consumption. Solders and flux are considered to be lead-free when they contain less
               than 0.2 percent lead. Before this ban took effect on June 19,1986, solders used to join water pipes typically
               contained about 50 percent lead.  Pipes and pipe fittings are considered "lead-free" under the Lead Ban when
               they contain less than 8 percent lead. Plumbing fixtures that are not "lead-free" were banned from sale after
               August 6,1998.  Plumbing fixtures are subject to the NSF International standard.

               NOTE: "Lead-free" pipe is allowed to contain up to 8 percent lead and "lead-free" solder and flux may
               contain up to 0.2 percent lead.  Lead-free plumbing components are not necessarily "free" of lead.

               The 1988 Lead Contamination Control Act (LCCA).  The purpose of the LCCA is to reduce lead exposure
               and the health risks associated with it by reducing lead levels in drinking water at schools and child care centers.
               The LCCA created lead monitoring and  reporting requirements for all schools, and required the replacement of
               drinking water fixtures that contained excessive levels of lead (see Appendix E for a listing of these fixtures). The
               provisions are not enforceable. As a result, states have the option to voluntarily enforce the provisions of the Act
               (or alternate provisions) through their own authority.

               The 1991 Lead and Copper Rule (LCR).  The LCR requires public water suppliers to monitor for lead in
               drinking water and to provide treatment for corrosive water if lead or copper are found at unacceptable levels.
               EPA strongly recommends that schools test their facilities for lead. However, unless a school owns its water
               system, testing for lead and copper within the school is not specifically required. Therefore, many schools served
               by water systems owned by cities, towns, or other entities may have never been tested for lead under the LCR.
                                 PUBLIC WATER SUPPLY TESTING vs. TESTING AT SCHOOLS
                                                      (15 ppb vs 20 ppb)


               It is important to note that the lead testing protocol used by public water systems is aimed at identifying
               system-wide problems rather than problems at outlets in individual buildings.  Moreover, the protocols for
               sample size and sampling procedures are different. Under the LCR for public water systems, a lead action level
               of 15 parts per billion (ppb) is established for 1 liter samples taken by public water systems at high-risk
               residences.  If more than 10 percent of the samples at residences exceed 15 ppb, system-wide corrosion control
               treatment may be necessary. The 15 ppb action level for public water systems is therefore a trigger for
               treatment rather than an exposure level.

               EPA recommends that schools collect 250 mL first-draw samples from water fountains and outlets, and that the
               water fountains and/or outlets be taken out of service if the lead level exceeded 20 ppb. The sample was designed
               to pinpoint specific fountains and outlets that require remediation (e.g. water cooler replacement). The school
               sampling protocol maximizes the likelihood that the highest concentrations of lead are found because the first
               250 mL are analyzed for lead after overnight stagnation.
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                                                        3Ts for Reducing Lead in Drinking Water m Schools Revised Technical Guidance
2. Planning Your Program and Establishing Partnerships	

Monitoring for lead in your school's drinking water is extremely important.  If you have never or have not
recently monitored for lead in your school's drinking water, you are encouraged to begin the process by
identifying any lead problems that you may have in your drinking water.  You should start by identifying your
existing resources, which include school records, available finances, and personnel. You should also research
opportunities for assistance from your local public water supplier, state and local health agencies, and certified
water testing laboratories.
2.1  Assigning  Roles
Your school should assign responsibility to a key individual(s) to ensure that testing and follow-up actions are
completed. A person should also be appointed to serve as the contact person for communication with
interested parties (civic groups, the media, etc.).  One person or more may be involved in these activities, but it
is important to clearly define responsibilities and to support those people in their roles. An effective program
will require a team effort.

If your school decides to use consultants or lab personnel, their roles should be defined with respect to the
responsible person(s) at the school. Contact your state drinking water program or local health department if
you need advice on how to identify a qualified consultant.
2.2 School Records
To determine if previous monitoring efforts have been made at your school, you should review your school
records. Some schools conducted voluntary monitoring in cooperation with state or local officials in response
to the 1988 Lead Contamination Control Act (LCCA).  Other schools may have sampled for lead in response
to state requirements. This information will be useful in filling out your Plumbing Profile Questionnaire (see
Chapter 3), a tool that may be used to help determine whether lead is likely to be a problem in your facility.
Records should also be reviewed to determine whether remediation actions have been taken. For example,
have water coolers that contain lead been replaced (see Appendix E for a listing of banned water coolers)?
While these records may not make additional testing or remediation unnecessary, they will help to prioritize
your efforts and make them more efficient.

If testing or remediation was conducted in response to the 1988 Lead Contamination Control Act, it may
have taken place 10 years ago or more.  If you are not familiar with what activities may have taken place at
your school and your records are incomplete or absent, you are encouraged to contact individuals that may
have been  involved in the past.  Personnel that were involved may remember activities that were not well-
documented. They may also remember whether other agencies or the local public water supplier were
involved, which may mean that additional records are available.
2.3 Establishing  Partnerships

2.3.1  Assistance from Your Public Water Supplier
Some public water suppliers have devoted resources to helping schools conduct testing for lead even though
they may not be legally required to do so.  As discussed in the previous chapter, public water suppliers are
                                                                                                      13

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      required by the Lead and Copper Rule to monitor for lead at customers' taps. However, testing at schools
      was not specifically required unless the public water system was owned and operated by the school.
      Therefore, unless a school served by a public water system tested for lead on its own, or had testing
      voluntarily conducted by the public water system, neither the school nor the public water system is likely to
      have any record of testing. Although the public water system may treat the water to minimize corrosion, it is
      very important that you test to determine to what extent lead is leaching from plumbing within the school.

      You are encouraged to contact your public water supplier to determine whether assistance or information on
      previous efforts is available. Although utilities are under no obligation to do so, assistance may be available
      through technical guidance, sampling, or sharing in sampling costs. Some utilities may be willing to help
      develop sampling plans (see Chapter 3) and plumbing profiles (see Chapter 3). The American Water Works
      Association (AWWA), a non-profit organization of water system professionals, recently prepared a summary
      of information for water suppliers on options for providing assistance to schools.

      You should obtain the results of your water supplier's required monitoring under the Lead and Copper Rule
      to determine whether they are in compliance with the requirements of the Lead and Copper Rule. Your
      water utility should be able to tell you whether lead monitoring is current, whether the monitoring results are
      below the lead action level, and whether corrosion control treatment is provided. Your water supplier should
      also be able to tell you whether they have conducted lead monitoring at your school, and they may be able to
      give you some indication of whether lead could be a problem within your building(s).

      You may wish to begin by contacting your local director of public works, water superintendent, or water
      department, depending upon how your utility is organized. Some utilities have Web sites with contact
      information. All public water suppliers are required to produce and distribute an annual Consumer
      Confidence Report (CCR).  You may want to get in the habit of thoroughly reviewing your utility's CCR for
      important information about the water chemistry and overall water quality. Changes in water chemistry or
      quality may affect your school's long-term sampling plan. The CCR also provides the name(s) and contact
      information for those at your utility who may be able to answer any questions you have.
                            Questions to Ask Your Drinking Water Supplier

          It is important to know who supplies your facility's drinking water, and whether and how the water entering your
          facility is treated. Some kinds of treatment can make the water more corrosive, while others will reduce the problem.
          If the water is corrosive, treatment can reduce lead levels throughout the system and can save you and the supplier
          money by reducing damage to plumbing. The following are some questions you may want to ask your public water
          supplier:
           •  Ask for a copy of the most recent annual water quality report (CCR).
           •  Is the water system in compliance with federal and state standards for lead monitoring and treatment?
           •  What steps have been taken to maintain compliance with the Lead and Copper Rule?
           •  Does the utility have sample results from the school?
           •  Is the water corrosive? If so, what is the system doing to minimize corrosion?
           •  If a corrosion control chemical is used, does the chemical form a protective coating inside the piping?
           •  Does the water distribution system have any lead piping (for example, lead gooseneck at service connections),
              and does the system plan to remove these sources of lead?
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                                                          3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
2.3.2  Assistance from Your Local Health Office
Many local governments have established programs that are responsible for a wide variety of public health
protection activities, such as a Lead Poisoning Prevention Program. These programs are often the first line of
defense when public health risks arise. Lead programs for children are often a high priority for local health
offices.

You may wish to contact the local health office to discuss your needs. Although resources may be limited, the
office may be willing to provide assistance in a variety of ways. For example, a representative may be able to
attend Parent and Teacher Association meetings to discuss potential health effects, as well as to act as a contact
with state programs to obtain information and assistance. A representative may even be able to assist in
developing the plumbing profile, conducting sampling, or in taking follow-up action.

The phone number for your local health office should be in the listings under your county or city
government. Many offices also have a Web site. The following Web site contains information about many
local health departments listed by state http://www.healthguideusa.org/local health departments.htm.

2.3.3  Assistance from Your State Drinking Water Program
As discussed in Chapter 1, the only federal requirement that applies uniformly to  schools that receive water
from a public water system is  the ban on the installation of water system components that are not lead-free
(the Lead Ban).

You are encouraged to contact your state program to determine whether any other requirements apply, or
whether technical assistance is available.  The drinking water program may be housed in the department of
health or the department of the environment.  A listing of state program contacts is contained in Appendix D.
Most state programs also have Web sites with contact information. The following Web site contains
information about many state health departments
http://www.healthguideusa.org/state  health departments.htm. When discussing the issue with your state
program, you may wish to request assistance with voluntary compliance with the  Lead Contamination
Control Act. Since most state programs are familiar with the Act, this should help to clarify your request.

If you have not been able to make contact with your local public water supplier, you may also wish to ask
whether the state program can provide information  on monitoring compliance, results, and treatment. Your
state program regulates all such water suppliers for compliance with the Lead and  Copper Rule, and therefore
should have this information readily available.

You may also wish to ask the state drinking water program staff about other state  programs that are involved
in reducing lead risks for children. There may be an interest in developing a cooperative effort between state
programs or between state and local agencies.

2.3.4  Assistance from Certified  Laboratories
Your state drinking water office should be able to provide a list of certified laboratories in your area. You
should only use a laboratory that is certified by the state or EPA for testing lead in drinking water for public
water systems.

Some laboratories will provide assistance in addressing the activities described in this manual. For example,
some laboratories will collect samples for clients to ensure proper sampling technique and sample preservation.
However, costs for services will vary and you may wish to contact several certified labs.
                                                                                                         15

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      3Ts for Reducing Lead in Drinking Water m Schools Revised Technical Guidance
      If outside laboratory personnel are used, you should ensure that they understand the testing procedures
      described in this manual because these procedures differ from those used by public water suppliers for
      compliance with the Lead and Copper Rule.

      2.3.5  Assistance from Local Community Organizations
      Your community has a variety of local organizations that can help; for example community volunteer groups,
      senior citizens groups, the Parent and Teacher Associations, and local environmental groups. Tap into the
      expertise of people in your community who may be able to help with all aspects of your lead in drinking water
      reduction program. Another useful resource is your region's Pediatric Environmental Health Speciality Unit
      (PEHSU). Your region's PEHSU may be able to provide risk communication support to school districts; for
      more information please visit http://www.aoec.org/PEHSU.org.

      Contacting these groups is another way for your school to foster support. These groups might be willing to
      volunteer time to collect samples and train others to collect samples.
16

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                                                        3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
II.  Testing


3. Assessment and Strategy: Plumbing Profile and Sampling Plan	


3.1  Development of a Plumbing  Profile for Your Facility's Plumbing
Before testing and correcting lead problems, it is important to target potential problems and 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 facility. If your
facility has additions, wings, or multiple buildings built during different years, a separate plumbing profile
may be recommended for each. A plumbing profile can be created by answering a series of questions about
your facility's plumbing.  Every school is unique and a plumbing profile will help you understand the
potential sources of lead in your facility. Conducting this survey of your facility's plumbing will enable you
to:

   •   Understand how water enters and flows  through your building(s).

   •   Identify and prioritize sample sites. EPA recommends the following sites as priority sample sites:
       drinking fountains (both bubbler and water cooler style), kitchen sinks, classroom combination sinks
       and drinking fountains, home economics room sinks, teachers' lounge sinks, nurse's office sinks, sinks
       in special education classrooms, and any other sink known to be or visibly used for consumption (e.g.,
       coffeemaker or cups are nearby).

   •   Understand whether you may have a widespread contamination problem or only localized concerns.

   •   Plan, establish, and prioritize remedial actions, as necessary.

Exhibit 3.1 provides a plumbing profile questionnaire discussion and interpretations of possible answers
designed to help you plan your testing strategy and develop your sampling plan. Planning your strategy will
enable you to conduct testing in a cost-efficient  manner.  For a blank copy of the plumbing profile
questionnaire, see Appendix I.
                                                                                                     17

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       3Ts for Reducing Lead m Drinking Water in Schools Revised Technical Guidance
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localities actually required the use of lead service connections up until the lead-fi
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Survey your building for exposed pipes, preferably accompanied by an experienc
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• Lead pipes are dull gray in color and may be easily scratched by an object st
Lead pipes are a major source of lead contamination in drinking water.
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joints. In some instances, compounds containing lead have been used to se
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joints were typically joined together with lead solders until the lead-free rec
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• Plastic pipes, especially those manufactured abroad, may contain lead. If pi
sure they meet NSF International standards. (Note: NSF International is an
testing organization. Product listings can be obtained by visiting their Web site t
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3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      Now that you understand the potential dangers of lead contamination in drinking water and the laws and
      programs in place to address this problem, it is time to begin development of a plumbing profile and a
      sampling plan.
      3.2 Who Should  Create the Sampling  Plan? - Leadership in Sampling
      As discussed in Chapter 2, it is important to designate a school employee(s) to take responsibility of the
      sampling program and follow-up activities, even if someone else is hired to conduct testing. If laboratory
      representatives or consultants are used to conduct testing, you should ensure that they have experience in
      conducting lead testing at schools. You may wish to ask the laboratory or consultant for references. Contact
      your state or local health department or drinking water program if you need advice on how to identify a
      qualified consultant.
      3.3 Where  Should I  Sample? - Determining  Sample Locations
      You must decide where to take samples and how to prioritize the sample sites based on your responses to the
      plumbing profile and your knowledge of the facility.  If possible, every outlet used for drinking or cooking
      should be sampled. At a minimum, every outlet that is regularly used for cooking and drinking should be
      sampled. Sample sites that are most likely to have lead contamination include:

          •   Areas containing lead pipes or lead solder.

          •   Areas of recent construction and repair in which materials containing lead were used.

          •   Areas where the plumbing is used to ground electrical circuits.

          •   Areas of low flow and/or infrequent use.
          •   Areas containing brass fittings and fixtures.
          •   Water  coolers identified by EPA (See Appendix E) as having lead-lined storage tanks or lead parts.
             These  should be removed.

      It may be helpful to diagram the plumbing in your facility and the outlets that will require testing. Examples
      of plumbing configurations for a single-level building and a multi-level building are illustrated in Exhibits 3.2
      and 3.3, respectively.  Locate service connections, headers, laterals, loops, drinking water fountains (bubblers
      and coolers), riser pipes and different drinking water loops (see Appendix A for a glossary of these plumbing
      terms), and decide in  what order you wish to take samples.

      As shown in the above-mentioned Exhibits, water is carried to the different floors in a multi-level building 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).
24

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                                                         3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
3.4 Who Should Collect the  Samples  and Where Do Samples Go for Analysis? -
Collection and Analysis of Samples
Deciding who will collect samples will be based, in part, on who will analyze the samples.  Choosing an
individual who is adequately trained to collect samples may help avoid sampling errors. Some state drinking
water programs or public water suppliers may provide both services, although there is no federal requirement
that they do so.  Regardless of who collects the samples, you should employ a certified laboratory to conduct
sample analyses. Contact your state drinking water program (Appendix D) or EPA's Safe Drinking Water
Hotline (Appendix B and C) for a list of certified laboratories in your area. Consider the following issues prior
to making a selection:

   •   Will the laboratory take samples for you or will they provide training and sample containers for
       collectors designated by you?  (Testing activities can  be useless if sample collectors do not follow
       proper sampling procedures.)

   •   If it is determined that a laboratory or other consultant will take your samples, make sure they
       understand the sample protocol. This protocol is described in the next section. Make sure that
       laboratories or consultants thoroughly understand this protocol and do not confuse it with the lead testing
       protocol used by public water suppliers. The  two protocol are different.

   •   What is the cost of the laboratory's services? Costs will vary, 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 laboratories to compare prices and services, and you may
       wish to combine your sampling with another school to obtain a cheaper analysis rate.

   •   What is the laboratory's time frame for providing sample results?

   •   Recordkeeping is a crucial activity. Appendix F contains a sample recordkeepingform and identifies the
       type of information you should consider recording.

   •   Establish a written agreement or contract with  the laboratory for all of the services to be provided.
                                                                                                       25

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       3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                  Exhibit 3.2:   Plumbing Configuration for a  Single-Level Building
                                                            Header-
                                             Latera!
             Note: amplified lateral and
                 header configurations
                 are shown for clarity.
         VteterMain
                                Street
                                                                                                          Lateral
                                                                                                             Faucet
26

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                                                         3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
        Exhibit 3.3:  Plumbing Configuration for a Multi-Level Building
Note: Simplified header and
     lateral configurations
     are shown for clarity
     Water Main
                                                            School Building
                                                                                                           27

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      4. Conducting Sampling
      4.1  General Sampling Procedures
      This section outlines the general procedures involved in collecting drinking water samples for lead testing, and
      the two-step sampling process for sampling at your school.  Please note that the general two-step sampling
      process in this chapter contains recommendations for sampling that were created for typical plumbing
      configurations. If you believe that the recommendations do not fit your specific site conditions, you may
      wish to modify them as appropriate.  See additional discussion in 4.4.3. EPA strongly recommends that all
      water outlets in all schools that provide water for drinking or cooking meet a standard of 20 parts per
      billion (ppb) lead or less.
      4.2 Collection  Procedures

         (1)  All water samples collected should be 250 milliliters (mL) in volume. School samples are smaller than
             the one liter sample collected by public water suppliers for compliance with the Lead and Copper
             Rule. A smaller sample is more effective at identifying the sources of lead at an outlet because a
             smaller sample represents a smaller section of plumbing. A smaller sample is also more representative
             of water per serving consumed by a child. A 250 mL sample from a faucet would not include
             portions of the plumbing behind the wall that the faucet is mounted on, for example, compared to a
             1000 mL (1 liter) sample, which would include a longer line of plumbing with its valves and tees and
             elbows and soldered joints.

         (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.
             However, water may be more than 18 hours old at some outlets that are infrequently used. If this is
             typical of normal use patterns, then these outlets should still be sampled.

         (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.
         (4)  Unless specifically directed to do so, do not collect samples in the morning after vacations,  weekends,
             or holidays because the water will have remained stagnant for too long and would not represent the
             water used for drinking during most of the days of the week.
         (5)  Assign a unique sample identification number to each sample collected - use your sampling plan
             schematic or numbering system. Record the identification number on the sample bottle and on your
             recordkeeping form (see Appendix F). On your recordkeeping form include information on:

                •   Type of sample taken, e.g., initial, first follow-up, etc.

                •   Date and time of collection.

                •   Name of the sample collector.

                •   Location of the sample site.

                •   Name of the manufacturer that produced the outlet, and the outlets model number, if
                    known.

             Consult the sample form in Appendix F for additional recordkeeping items.

28

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                                                          3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
4.3 Laboratory Analysis and Handling  of Sample Containers
As discussed in the previous chapter, the certified drinking water lab that you select will either collect the
samples for you or they will provide you with materials and instructions if you plan to collect your own
samples.

If you collect your own samples, follow the instructions provided by the laboratory for handling sample
containers to ensure accurate results (also see Appendix G — Preservation of Samples and Sample Containers).
Make sure the containers are kept sealed between the time of their preparation by the lab and the collection of
the sample. Be sure to carefully follow the laboratory's instructions for preservation of the samples. Icing or
refrigeration of the samples will likely be necessary.  Most laboratories will provide shipping containers and ice
packs if shipping is necessary.
    When the laboratory returns your test results, the concentrations of lead in your drinking water samples will be
    reported in metric form such as milligrams per liter (mg/L) or micrograms per liter (ng/L), QL they will be reported as a
    concentration such as parts per million (ppm) or parts per billion (ppb), respectively.

    Milligrams per liter (mg/L) is essentially the same as parts per million (ppm).  Micrograms per liter (|ig/L) is essentially
    the same as parts per billion (ppb).

    Examples: 1 mg/L = 1000 ng/L = 1ppm =1000ppb;  0.020 mg/L = 20  ng/L = 0.02ppm = 20ppb
4.4 Overview of the Two-Step Sampling Process
EPA recommends that a two-step sampling process be followed for identifying lead contamination. Lead in a
water sample taken from an outlet can originate from the outlet fixture (the faucet, bubbler etc.), or plumbing
upstream of the outlet fixture (pipe, joints, valves, fittings etc.). The two-step sampling process helps to
identify the actual source(s) of lead.

In Step 1, initial samples are collected to identify the location of outlets providing water with elevated lead
levels.  In Step 2, follow-up water samples are taken only from problem locations to determine the lead level
of water that has been stagnant in upstream plumbing, but not in the outlet fixture. The results of initial and
follow-up samples are then compared to determine the sources of lead contamination and to determine
appropriate corrective measures.

The protocol, which consists of an established sample size volume and water retention time, is designed to
identify lead problems at outlets and upstream plumbing within school facilities.

This section provides a brief definition and overview of the purpose of each of the two steps in EPA's lead
testing process.

4.4.1   Step 1:  Initial Sampling
In Step 1, initial screening samples are taken from the service connection and the prioritized outlets in the
facility. These initial samples determine: a) the lead content of water from your facility's service connection
and b) the lead content of water sitting in water outlets that are used for drinking or cooking within your
building(s). The goal of Step  1 is to compare the lead level of water from your facility's service connection to
water that has remained stagnant in the outlet or fixture.
                                                                                                         29

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      To determine the lead content in water from your facility's service connection, first contact your public water
      supplier to identify what lead levels you might expect. (Ifyou completed the plumbing profile questionnaire in
      Appendix I that is also discussed in Exhibit 3.1, you will already have this information.) Second, test water that
      is representative of your service connection and the mains in your public water system. Compare the results to
      determine what contribution your service connection is making to lead concentrations in your building (see
      Exhibit 4.3). Then, compare this finding to the results from outlets in the facility. For sampling instructions
      for initial samples from service connections, mains, and different types of water outlets, see Exhibits 4.3
      through 4.9.

      Before beginning sampling, you should repair any leaking outlets to ensure that you collect representative
      samples.

      4.4.2   Step 2: Follow-Up Sampling
      If initial test results reveal lead concentrations greater than 20 ppb in a 250 mL sample for a given outlet,
      follow-up testing described in Step 2 is recommended to determine if the lead contamination results are from
      the fixture or from interior plumbing.  EPA has established this trigger for follow-up testing to ensure that the
      sources of lead contamination in drinking water outlets are identified.

      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 (e.g., fixtures or interior
      plumbing) lead is getting into drinking water so that appropriate corrective measures can be taken.

      As with initial samples, follow-up samples are to be taken before a facility opens and before any water is used.
      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. The sampler should induce a small (e.g., pencil-sized) steady flow of water from the outlet or other
      sample location. The sampler should be careful not to begin with a high rate of flow, and then reduce the
      flow just prior to sampling. Sudden changes in flow could stir up sediments or cause sloughing of pipe films
      that would not be characteristic of typical water use patterns.

      A comparison of initial and follow-up samples will help to assess where the lead may be getting into the
      drinking water. See Exhibits 4.3 through 4.8 for follow-up sampling instructions for various types of outlets.

      After follow-up sampling, additional samples from the interior plumbing within the building are also often
      necessary to further pinpoint the sources of lead contamination. See Exhibit 4.9 for instructions for additional
      sampling.

      After reviewing the plumbing profile questionnaire and background regarding what your answers to the profile
      could mean (Exhibit 3.1), you have learned that lead contamination may not occur uniformly throughout a
      building. You should have 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. When planning your strategy, it is important to
      note that large variations in lead concentrations may be found among individual outlets in a facility because of
      differences in flow rates and/or building materials.
30

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                                                           3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
In general, you may find widespread presence of lead in your drinking water when:
    •    Lead pipes are used throughout the facility.
    •    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 Amendments took effect). This situation is
        rare.

    •    The water is corrosive.

    •    Sediment or scale in the plumbing and faucet screens contain lead.

    •    Brass fittings, faucets, and valves were installed throughout the building less than five years ago (even
        though they may contain less than the "lead-free" requirements of the Safe Drinking Water Act).

    •    The service connection (i.e., the pipe that carries water from the public water system main to the
        building) is made of lead.

In general, you may find localized presence of lead if:
    •    Some brass  fittings, faucets, and valves have been installed in the last five years (even though they may
        meet the SDWA "lead-free" requirement).

    •    Drinking water outlets are in line with brass flush valves, such as drinking water fountains near
        restroom supply piping.
    •    Lead pipes are used in some locations.

    •    The water is non-corrosive.

    •    Lead solder joints were installed in short sections of pipe before 1986 or were illegally installed after
        1988 (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 frequently contains lead.
    •    Some water coolers or other outlets have components that are not lead-free, especially if the water is
        corrosive.

After identifying potential problem areas in your facility through completion of a plumbing profile, the next
step is to have the water tested.  A sampling plan should be developed before testing begins. 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?
                                                                                                          31

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      4.4.3  Initial and Follow-Up Sampling Protocol
      The protocol for collecting initial and follow-up samples varies by type of drinking water outlet.  The initial
      and follow-up testing protocol and the interpretation of test results is described in Exhibits 4.3 thorough 4.9
      for the following locations and type of outlets:

          •   Service connections and water mains

          •   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.
                     Note: The Food and Drug Administration (FDA) regulates bottled water. EPA recommends
                     testing the dispenser to ensure that the dispenser is not contributing lead to the water.
          •   Ice making machines

          •   Water faucets

          •   Interior plumbing
      Please note that sampling ID codes have been
      indicated in the descriptions of the sampling
      protocol for each outlet type.  These sampling ID
      codes have been included for illustrative purposes
      only.  When you conduct testing in your facility, you
      should assign your unique numbers for every sample
      you collect.

      Following the instructions for the above water outlet
      locations are instructions for conducting sampling of
      the interior plumbing of buildings (Exhibit 4.9).
      Instructions are included for sampling laterals, loops
      and headers, and riser pipes. These types of samples
      are necessary if follow-up outlet samples show lead
      levels above 20 ppb.
      Exhibit 4.2 provides an overview of the sampling process in a flow chart format.
TIP: Schools may wish to collect both initial and
follow-up samples at the same time. This is more
convenient and may save time and money if a
contractor has been hired to collect the samples.
However, using this  approach creates a trade-off
between convenience and confidence. The
confidence in the sample results will decrease since
flushing water through an outlet after taking the
initial sample could  compromise  the flushed
samples taken at subsequent outlets, depending
upon the plumbing configuration. As succeeding
outlets are flushed, the chances of compromising
the remaining flushed samples would increase.
32

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                                                        3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
As discussed in section 4.1, you may wish to modify sampling recommendations to suit your site conditions.
For example, if you believe that flushing an outlet for 30 seconds prior to taking a follow-up sample is
excessive, you may wish to calculate a more accurate time estimate.  This could be done by:

   •   Calculating the pipe volume in gallons between the outlet and the location in the plumbing that you
       want to sample.

   •   Measuring the outlet flow in gallons per minute.

   •   The length of time for flushing can be determined by dividing the pipe volume in gallons by the
       outlet flow in gallons per minute.

Pipe volumes per foot of pipe length for various pipe sizes are shown in Exhibit 4.1 below.
                        Exhibit 4.1:  Pipe Volumes for Copper Pipe
Nominal
Pipe Diameter
(inches)
3/8
1/2
3/4
1
1 1/4
1 1/2
2
2 1/2
3
Approximate Capacity
(gallons per foot of length)
Type K Copper
(soft)
0.0066
0.0113
0.0226
0.0404
0.0632
0.0895
0.1566
0.2412
0.3448
Type L Copper
(rigid)
0.0075
0.0121
0.0251
0.0429
0.0653
0.0924
0.1607
0.2479
0.3538
                                                                                                      33

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        3Ts for Reducing Lead in Drinking Water in Schools  Revised Technical Guidance
                                        Exhibit 4.2:   Sample Strategy Flowchart
                      Collect and analyze initial
                        samples from outlets
                       (morning first draw) and
                          from the service
                            connection
                             Is the lead
                          level in the initial
                         sample at or below
                              20 ppb?
  Outlet O.K. to use
                         Collect and analyze
                         follow-up samples
                         (interior plumbing).
                              Is lead
                          level in follow-up
                         samples less than
                              20 ppb?
    Are lead levels
  in interior plumbing    "\Yes
follow-up samples dose ^
      to 5 ppb?    /
       The outlet is a
       source of lead.
                          Are lead levels in
                  interior plumbing follow-up samples
                   reater than or equal to lead levels
                     -observed in intial sampled'
                        The interior plumbing
                         is a source of lead.
                                                               The interior plumbing
                                                                  and outlet are
                                                                 sources of lead.
                             Are lead
                     levels in service connection
                sample(s) greater than or equal to lead
                  levels observed in interior plumbing
                         follow-up samples?
       Are lead
    levels in service
  connection samples
       close to
        5 ppb?
The interior plumbing
 is a source of lead.
                                                               The interior plumbing
                                                                and service line are
                                                                 sources of lead.
                            The service
                           connection is a
                           source of lead.
34

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                                                         3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
4.4.4  Sampling for Other Parameters
In addition to monitoring for lead, you may wish to monitor for other parameters that may provide an
indication of problems in your plumbing. However, note that analysis costs will increase as the number of
parameters increases. Some other parameters are listed in the following table:
     Contaminant
  Limit
                          Concern
    Cadmium
  5ppb
A regulated toxic metal found in low levels in galvanized pipe.
The maximum allowable level is 5 ppb. However, the presence of
cadmium at any level indicates that corrosive conditions may exist
in the plumbing.
    Color
 15 color
   units
An aesthetic parameter that may indicate the presence of iron
oxides.  Iron oxides are often present in iron or steel pipe as a
result of corrosive conditions.
    Copper
1300 ppb
A regulated toxic metal used to make copper piping. The
presence of copper in water samples taken from copper piping is
not unusual, but higher levels indicate that corrosive conditions
may be a concern.
    Iron
 300 ppb
An aesthetic parameter that is indicative of corrosive conditions at
higher levels. See also color and turbidity. (Galvanized pipe is
typically made of iron.)
    Turbidity
1 turbidity
   unit
A measurement of the clarity of water.  Higher turbidity values
may indicate the presence of iron oxides.  Iron oxides are often
present in iron or steel pipe as a result of corrosive conditions.
    Zinc
5000 ppb
An aesthetic parameter that is indicative of corrosive conditions at
higher levels. Zinc is used in making galvanized piping products.
The presence of zinc in water samples taken from galvanized
piping is not unusual, but higher levels indicate that corrosive
conditions may be a concern.

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                              Exhibit 4.3:  Service Connection Sampling
      Lead pipes are still used for service connections in some locations. Other materials used for service connections
      include copper, galvanized steel, plastic, and iron. Lead service connections can produce significant lead levels
      in your drinking water.

      To test water in your service connection, locate the tap closest to the service connection. This is especially
      important for larger facilities where more than one service connection is present.
                                       Sample Collection  Procedures:
                                                                   School Building
                           City Water Main
                             (in street)
                                Collects water representative
                                of the mam
Collects water representative of the service connection
                                     Targeted Locations of Water in Plumbing
                                               for Samples 1S& 1M
      Sample IS (Service Connection)
      Take this sample before the facility opens. Note that this is not an initial first-draw sample.  Open the cold
      water tap closest to the service connection.  Let the water run, and feel the temperature of the water.
      Depending upon the temperature of your public water system's water and the temperature of the room, you
      may feel the water temperature change as the water from the service connection enters the building. However,
      it is possible that the water in the service connection and the building are close to the same temperature.
      Therefore, you should collect the sample immediately after a temperature change is detected, or after 30
      seconds. Flushing removes the water that was in the facility's interior plumbing and allows sampling of the
      water that was in the service connection. You may wish to calculate a more accurate flush time for your
      building by using the method described in section 4.4.3.

      Sample 1M (Water Main)
      This sample is representative of the water that is provided by the distribution main. Take the sample from the
      same location as sample IS. Let the water run, and feel the temperature of the water. If you can feel a change
      in water temperature,  allow the water to run an additional 3 minutes  after the temperature changes and then
      collect the sample. If you cannot feel a change in temperature, allow the water to run for 3 minutes and 30
      seconds.
36

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                                                          3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
If possible, you should take this sample from a faucet rather than a drinking fountain because of the limited
flow that is normally provided by a drinking fountain. Also, a change in temperature may be difficult to
detect if the sample is taken from a water cooler (see the discussions for Samples IS and 1M below).
Interpreting Test Results:

   •   If the lead level of Sample IS (service connection) significantly exceeds 5 ppb (for example, 10 ppb)
       and is higher than in sample 1M, lead is contributed from the service connection. Check for the
       presence of a lead service connection by scratching it with a knife or key. (Lead test kits are available
       from water testing and laboratory supply companies and are relatively inexpensive.) Lead is soft and
       dull gray in appearance. When scratched, it will be shiny. In the absence of a lead service connection,
       lead goosenecks or other materials containing lead may be the source of the contamination.
   •   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 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. Usually, no significant amount of lead (above 5 ppb)
       comes from the public water system.

For example scenarios of different water sample results, please see Appendix H.
                                                                                                          37

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                           Exhibit 4.4:  Drinking Water Fountains:  Bubblers
          Do not close the shut-off valves to the water fountains to prevent their use prior to sample collection. 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.
          •    Follow-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 connection 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. If several bubblers are served by a central
              chiller, samples should be taken from different
              bubblers on different days.
One Style of Drinking
   Water Fountain

Wall — 	 	

Solder
Joint
Lateral Valve 1
PiP\ 1 1*^
2A^M/
S Solder
Joint

1
^
\
6
//

\
\
X
^
1

Bubbler
/Valve
j^ 1A
( I ^
6H )
\
Valve
^ Connecting
Pipe



Targeted Locations of Water in Plumbing
for Samples 1A & 2A
Note: All the samples are collected at the
outlet. The sample numbers indicate
what water is being targeted for testing.
38

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                                                          3Ts for Reducing Lead in Drinking Water m Schools Revised Technical Guidance
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 in
       Sample 2A, a portion of lead in the drinking water is
       contributed from the bubbler.
   •   If the lead level in Sample 2A is very low (close to 5
       ppb), very little lead is picked up from the plumbing
       upstream from the outlet. The majority or all of the
       lead in the water is contributed from the bubbler.

   •   If the lead level in Sample 2A significantly exceeds 5     Fountains Connected to a Central Chiller
       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 4.9.)

For example scenarios of water sample results and possible solutions, see Appendix H.
                                                                                                        39

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                        Exhibit 4.5: Drinking Water Fountains:  Water Coolers
          Do not close the valves to the water fountains to prevent their use prior to sample collection. 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 Efor 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
E.
                                                                            Wall-Mounted Cooler
      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. (In areas of infrequent use, the
              water may not have been used in more than 1 8
              hours. This is acceptable if this is 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 water to waste.  Take follow-up
              samples from water coolers whose test results
              indicate lead levels greater than 20 ppb.

              When conducting follow-up testing with water
              coolers you should be aware that some water
                                                                 Lateral
                                                                 Pipe
                                                                       Valve
                                                         Header
                                                         i
                                                         2C
                                                                 Connecting
                                                                   Pipe
-Water
 Cooler
                                                                                         Cooling Element
                                                                                         (old ones may be
                                                                                          lead-lined)
                                                             Targeted Locations of Water in Plumbing
                                                                    for Samples 1C -4C
                                                            Note  The valve shown upstream of the water cooler may be
                                                                      located inside the cooler
40

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                                                  3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
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 the unit is lead-free. A list of makes and model numbers of coolers
that contain lead has been prepared by EPA and is summarized in Appendix E.

Follow-Up Sample 2C
This water sample is representative of the water that is in contact with the header or rising piping
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 facility 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 representative 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.
                                                                                                41

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         3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Interpreting Test Results:
• IF
• IF
• IE
• IE
Follow-up
Sample 3C
-*
Follow-up
Sample 3C

Initial
Sample 1C
-*
Follow-up
Sample 2C
— ป
Follow-up
Sample 1C

Follow-up
Sample 2C
IS GREATER THAN
The water cooler may be contributing
lead.
IS GREATER THAN
IS GREATER THAN
The upstream plumbing may also be
contributing lead.
IS CLOSE OR
EQUAL TO
The water cooler is probably not
contributing lead.
IS GREATER THAN
IS CLOSE OR
EQUAL TO
Follow-up
Sample 2C

Follow-up
Sample 2C

Follow-up
Sample 3C

Follow-up
Sample 3C

Follow-up
Sample 3C

Follow-up
Sample 3C
THEN
AND
THEN
THEN
AND
THEN
The water cooler and/or upstream
^ plumbing are probably contributing
lead.
• IF
Follow-up Sample
2C > 20 ppb, AND
IS GREATER THAN
OR EQUAL TO
Initial Sample 1C &
Follow-up Sample
3C
THEN
                                                     The source of the lead may be sediments
                                                    contained in the cooler storage tank,
                                                    screens, or the plumbing upstream from
                                                    the cooler.
42

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                                                           3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
       Follow-Up Sample 4C
       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.

       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
Follow-up
Sample 4C
 IS LESS THAN 5 ppb,
        THEN
The lead is coming from debris in
the cooler or in the screen.
       IF
Follow-up
Sample 4C
  IS MUCH GREATER
  THAN 5 ppb, THEN
The lead is coming from debris in
the cooler or in the screen.
       IF
Follow-up
Sample 4C
 IS MUCH GREATER
THAN 5 ppb, AND LESS
        THAN
          THEN
                               The source of lead may be sediments contained in the cooler, screens, and/or the
                               upstream plumbing.
For example scenarios of water sample results and possible solutions, see Appendix H.
                                                                                                          43

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                 Exhibit 4.6: Drinking Water Fountains: Bottled Water Dispensers

      Sample Collection Procedures:
      This testing will identify if lead is being contributed to the water from the dispenser.

      Notes:  The Food and Drug Administration (FDA), regulates the interstate sale of bottled water and has
      established a 5 ppb standard for lead in bottled water. EPA recommends that you contact your distributor for
      written assurance that the bottled water does not exceed federal or state bottled water standards, and a copy of
      recent test results.
          •   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.  See
             the Note below for an alternative to follow-up sampling.
Bottled Water
  Dispenser
      Interpreting Test Results:

          •    If the sample contains lead, contact the water supplier and/or
              the manufacturer of the dispenser to ask for their
              recommendations.

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

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

      Note:   Many dispensers have a hot and cold tap. Water from both taps
      is meant to be directly consumed, therefore, both taps should be sampled.
      However, you may wish to sample the hot water tap  on a separate day.

      For example scenarios of water sample results and possible solutions,
      see Appendix H.
Bot
Targeted Loc
for
tied Water Dispenser

V J
f-^io
d7
•^20
:ations of Water in Plumbing
Samples 10 &2D
44

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                           3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance
Exhibit 4.7: Ice Making Machines
                                                     Ice Making Machine
                                Connecting
                                 Plumbing
                         Lateral
                                                       Device Outlet
                                                                 ME
                             Targeted Locations of Water in Plumbing
                                      for Samples 1E & 2E
Sample Collection Procedures:

   •   Initial Screening Sample IE
       Fill a suitable container (250 mL or larger,
       wide-mouthed bottle or other container)
       provided 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
       laboratory to place the ice in the container.

       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 and clean out the remaining debris. The laboratory will
       determine whether lead solder is present. Clean the screen routinely to avoid accumulations of debris.

       Collect the sample from the disconnected plumbing as close to the ice maker as possible. Fill the
       sample container with 250 mL of water. If no tap is available, contact the ice machine manufacturer
       for recommendations that will minimize disruption of existing plumbing. Adding taps or valves
       could add new sources of lead to the plumbing, even if the new devices are lead-free and meet NSF
       Standard 61,  section 8. If a sample tap or valve is available, collect the sample immediately after
       opening the tap or valve.

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 4.9 on Sampling Interior Plumbing for
       instructions.

For example scenarios of water sample results, please see Appendix H.
                                                                          45

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                                     Exhibit 4.8: Water Faucets (Taps)
                                                                      Connecting
                                                                         Pipe

                                                                         Solder
                                                                         Jointx
                                                                         Valve
                                                                   Lateral
                                                                   Pipe
                                                                         \/
                                                                         Solder
                                                                         Joint
                                                                                      Valve
 Cold
Water
Faucet
                                                                                                  1F

                                                                                                  Screen
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       j              wail
       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. If the tap has an aerator (screen),
       remove, clean, and replace it prior to collecting the
       sample. Using the cold water tap, 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 initial screening test results indicate lead levels
       over 20 ppb.

   •   Follow-Up Sample 2F
       This sample is representative of the water that is in
       the plumbing upstream from the faucet.  Take this
       sample before school opens and before any water is
       used. Let the water from the faucet run for 30
       seconds before collecting the sample.

Interpreting  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.

For example scenarios of water sample results and possible solutions, see Appendix H.
                                                                              Cold Water
                                                                              Faucet (Tap)
                                                                  Targeted Locations of Water in Plumbing
                                                                           for Samples 1F& 2F.
46

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                                                           3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance
                          Exhibit 4.9: Sampling Interior Plumbing
In general, if lead levels exceed 20 ppb in follow-up samples taken from drinking water outlets, additional
samples from upstream sample sites in the interior plumbing should be collected. EPA recommends that
water samples from each lateral, header and riser (where applicable) be collected because use patterns may vary
among locations within a building.  The configuration of interior plumbing will vary depending on the layout
of a given building. Construction materials may also vary, especially in larger buildings where additions and
repairs have been made to the original structure. See Exhibits 4.10 and 4.11 for simplified diagrams of the
interior plumbing in single-level and multi-level buildings.

Sampling should proceed systematically upstream from follow-up sample sites that exceed 20 ppb.  (However,
you do not have to sample at upstream sites  where follow-up samples have already been taken.) The goal  of this
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 each other, and with the results of
previously collected follow-up samples.

Developing procedures from upstream sampling from laterals, headers and risers can be difficult because of the
wide variation in plumbing configurations among facilities. As discussed in 4.4.3, the sampling procedures in
this manual were developed for typical configurations that may not be similar to your facility. You may wish
to either develop your own sampling procedures using the guidance provided in 4.4.3, or retain a consultant
for guidance in this process.

Laterals
A lateral is a plumbing branch between a fixture or group of fixtures  (e.g., taps, water fountains, etc.) and a
header.

Sample Collection Procedures:
    •   Sample 1G (lateral)
       Open the outlet 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 1G for additional information on the
source of the lead within the interior plumbing.  (As noted above, you do not have to take sample 1G at sites
where follow-up samples have already been taken.   The previous results are adequate.)
                                                                                                          47

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       3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
       Interpreting Test Results:
              IF
              IF
            •  IF
              IF
Follow-up
Sample 1G
Follow-up
Sample 1G
Follow-up
Sample 1G
Follow-up
Sample 1G
           IS GREATER THAN 20 ppb
                      THEN
                                          Collect additional samples from the plumbing upstream where samples have
                                          note been previously taken; i.e., from the header that feeds the lateral, the riser
                                          pipe (if applicable), or the service connection.

                                          Note: High lead levels may be caused by recent repairs or by sediment in the
                                          plumbing. Sediment should be sent to a laboratory for analysis.
      IS CLOSE OR
        EQUAL TO
Initial results from a
 downstream outlet
THEN
                                          The lead is contributed from the lateral and!or from interior plumbing
                                          upstream from the lateral. Possible sources include the lateral, header, riser
                                          pipe, or service connection.
         IS CLOSE OR EQUAL TO 5 ppb
                      THEN
                                          The portion of the lateral upstream from Sample Site 1G and the interior
                                          plumbing supplying water to the lateral are probably not contributing lead.
                                          The source is downstream from Sample Site IG.
IS APPROXIMATELY 10 ppb
      OR GREATER
   AND IS LESS THAN
Initial results from a
 downstream outlet
THEN
                                          A portion of the lead is contributed from the plumbing downstream from
                                          Sample Site IG.
       Headers
       A header is the main water supply pipe on a given floor of a building. A header supplies water to laterals.  In
       smaller buildings, a header may be very short and/or have a relatively small diameter.

       Sample Collection Procedures:

          •   Sample 1H (header)
              Locate the sampling point furthest from the service connection or riser pipe (see discussion of riser
              pipes on the next page) on the floor. You should try to take this sample from a faucet to provide
              adequate flushing through the tap. 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 header pipe.
48

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                                                                    3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Interpreting Test  Results:
     IF
     IF
     IF
     IF
Follow-up
Sample 1 H
 Follow-up
Sample 1H
 Follow-up
Sample 1H
Follow-up
Sample 1H
             IS GREATER THAN 20 ppb
                         THEN
                                     Collect additional samples from the plumbing upstream that supplies water to
                                     the header (if not already done); i.e., the riser pipe (if applicable), or the service
                                     connection.

                                     Note: High lead levels may be caused by recent repairs or by sediment in the
                                     plumbing. Sediment should be sent to a laboratory for analysis.
       IS CLOSE OR
        EQUAL TO
Initial results from a
 downstream outlet
THEN
                                     The lead is contributed from the header andlot from interior plumbing
                                     upstream from the header.  Possible sources include the header, riser pipe, or
                                     service connection.
          IS CLOSE OR EQUAL TO 5 ppb
                         THEN
                                     The portion of the header upstream from Sample Site 1H and the interior
                                    plumbing supplying water to the header are probably not contributing lead.
                                     rhe source is downstream from Sample Site 1H.
IS APPROXIMATELY 10 ppb
       OR GREATER
    AND IS LESS THAN
Initial results from a
 downstream outlet
THEN
                                    A portion of the lead is contributed from the plumbing doitmstream from
                                    Sample Site 1H.
                                                                                                                           49

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       3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
       Riser Pipes
       A riser is the vertical pipe that carries water from one floor to another.

       Sample Collection Procedures:
           •    Sample 1J
               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 is to clear the faucet and
               plumbing between the sample site and the riser pipe.

       Interpreting Test Results:
                              Follow-up
                              Sample 1J
                      IS GREATER THAN
                                      20 ppb.
                       THEN
                                               Collect additional samples front the plumbing upstream that supplies water to
                                               the riser (if not already done); i.e., a riser from another floor, or the service
                                               connection.

                                               Note: High lead levels may he caused by recent repairs.
                 IF
                 IF
Follow-up
Sample 1J
Follow-up
Sample 1J
       IS CLOSE OR
        EQUAL TO
Initial results from a
 downstream outlet
THEN
                                               I he lead is contributed from the riser and/or from interior plumbing upstream
                                               from the sample site.  Possible sources include the riser pipes on other floors or
                                               the service connection.
       IS CLOSE OR
        EQUAL TO
      5 ppb
THEN
                                               I he portion of the riser upstream from Sample Site IJ and the service
                                               connection are probably not contributing lead. The source is downstream from
                                               Sample Site 1 /
                 IF
Follow-up
Sample IJ
IS APPROXIMATELY 10 ppb
OR GREATER AND IS LESS
          THAN
Initial results from a
 downstream outlet
THEN
                                               A portion of the lead is contributed from the plumbing downstream from
                                               Sample Site IJ.
       For example scenarios of water sample results and possible solutions, see Appendix H.
50

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                                                           3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance
Sample Collection Procedures - Central Chiller Unit:
   •    Follow-Up Sample IK
        This sample is representative of water that has
        been in contact with the plumbing supplying
        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. If no tap is available,
        contact the chiller manufacturer for
        recommendations that will minimize disruption
        of existing plumbing. Adding taps or valves could
        add new sources of lead to the plumbing, even if
        the new devices are lead-free and meet NSF
        Standard 61. If a sample tap or valve is available,
        collect the sample immediately after opening the
        tap or valve, without allowing any water to waste.
Targeted Locations of Water in Plumbing
        for Samples 1K&2K
   •   Follow-Up Sample 2K
       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 2K consists of a mixture of water from the water supply and
       any water that may be recirculated from the plumbing supplying water to the bubblers.
       Take the sample from a tap or valve as close to the outlet of the chiller as possible. If no tap is
       available, contact the chiller manufacturer for recommendations that will minimize disruption of
       existing plumbing. Adding taps or valves could add new sources of lead to the plumbing, even if the
       new devices are lead-free and meet NSF Standard 61.  If a sample tap or valve is available, collect the
       sample immediately after opening the tap or valve.

Interpreting Test Results - Central Chiller Unit:
Note: You will need the results from samples collected at the bubblers per instructions in exhibit 4.4.
   •   If the lead level in Sample 2A is higher than that in Sample 2K, lead is contributed from the plumbing
       supplying the water from the chiller to the bubbler.
   •   If the lead level in Sample 2K is higher than in Sample IK, 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 in Sample IK exceeds 20 ppb,  EPA recommends  additional sampling from the
       distribution system supplying water to the chiller to locate the source of contamination.
   •   If the lead level in Sample IK 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.

For example scenarios of water sample results and possible solutions, see Appendix H.
                                                                                                          51

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       3Ts for Reducing Lead m Drinking Water in Schools Revised Technical Guidance
                            Exhibit 4.10:   Sample Sites for a  Single-Level Building
             Morning first-draw samples from coolers,
          1   faucets, bubblers, etc.  (Initial Screening
             Samples 1A, 1C, 1D, 1E, 1F.)

             Samples from lateral after 30-second
          2   flush from designated outlets. (Follow-up
             Samples 2A, 2E, 2F, 1G.)

          ,,   Samples from coolers after 15-minute
          6   flush  (Follow-up Sample 2C.)

          .   Samples from coolers morning first-
             draw  (Follow-up Sample 3C)
                                                 Lateral
            Note:  Simplified header and lateral
                  configurations are shown for
                  clarity
j-   Morning first-draw from coolers at disconnected
    plumbing outlet.  (Follow-up Sample 4C.)

..,   Sample from header pipe taken from faucet
    farthest from service line. (Sample 1H )

7   Sample from service line and distribution main taken
    from faucet closest to service line. (Samples 1M, 1S.)
        Header •
                   V
                                                                                      - Lateral
                                                                          Cooler
                                                                                                                       Lateral
                                  "'4

                                   3
                                                                                                  Faucet
             Water Mam
                                               Service Connection
                                                      Note all of these samples should not be collected on the same day
52

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                                                                           3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                      Exhibit 4.11:   Sample Sites for a Multi-Level Building
^~  Morning first-draw samples from coolers, faucets,
(1) bubblers, etc. (Initial Screening Samples 1A, 1C,
     1D, 1E, 1F.)
 s^ Samples from laterals after 30-second flush from
\^) designated outlets. (Follow-up Samples 2A, 2E,
     2F, 1G.)

(Q\ Sample from header taken from faucet farthest from
^— ^ riser pipe. (Sample 1H.)

(4\ Sample from riser pipe taken from faucet closest to
^-^ riser pipe. (Sample 1J.)

/•g\ Samples from service line and  distribution main
^-/ taken from tap closest to service connection.
     (Sample 1H.)

/X\ Sample from inlet to chiller unit. (Follow-
VV up sample 1K.)
ฎ     Sample from outlet of chiller unit.
     (Follow-up sample 2K.)
 Note: Simplified header and
      lateral configurations
      are shown for clarity.
                 Water Main
                                       Service Connection                            School Building
                                             Note: all of these samples should not be collected on the same day.
                                                                                                                                         53

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      5.   Remedies
      Solutions to lead problems typically need to be made on an interim (short-term) and on a permanent basis.
      Interim measures can be taken while you wait for your test results or until a permanent solution has been put
      in place. In addition, there are routine measures that should be taken. You should work closely with
      maintenance staff and any plumbers who may make repairs. Make sure that users are familiar with the use of
      new fixtures you install.

      Outlined below are various routine, interim and permanent remedies. To aid you in the process of selecting
      remedies, a case study has been included as Exhibit 5.3.
      5.1  Routine Control Measures
      Below are examples of routine activities that should be conducted to prevent exposure to elevated levels of
      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, even if the analysis finds no
             lead.
         •   Use only cold water for food and beverage preparation. 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.

         •   Instruct the users (students and staff) to run the water before drinking or staff could run the water
             before students arrive, so they are drinking water that has not been in contact with the faucet interior
             since faucets are often a major source of lead in drinking water.
         •   Placard bathroom sinks with notices that water should not be consumed.  You should use pictures if
             there are small children using bathrooms.
      5.2 Interim  (Short-Term)  Control Measures
      Some examples of interim control measures include:
          (1) "Flush" the piping system in your building. "Flushing" involves opening suspect taps every morning
             before the facility opens and letting the water run to remove water that has been 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. Flushing instructions are presented in Exhibit 5.1.
54

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                                                            3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                      Exhibit 5.1:  Flushing Directions by Outlet Type
    Remember that each drinking water outlet should 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, or person, in charge of this program.

     •   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-mmute time frame is considered adequate for
        most buildings.

     •   Open valves at all drinking water fountains without refrigeration units and let the water run for roughly 30
        seconds to one minute, or until cold.

     •   Let the water run on all refrigerated water fountains for 15 minutes. Because of the longtime period required,
        routinely flushing refrigerated fountains may not be feasible. It may therefore be necessary, and more
        economical, to replace these outlets with lead-free, NSF-approved devices.

     •   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 to one minute, or until cold.
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. To minimize this disadvantage, consider the following:

           ^   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.

    •    Flushing is not recommended as a practical remedy for water coolers.


HINT: Be careful not to flush too many taps at once. This could dislodge sediments  that might create further
lead problems, or it could reduce pressure in the system below safe levels.  If the flow  from outlets is reduced
noticeably during flushing, you have probably turned on too many taps at once.
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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
          (2) 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). 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.

         (3) Shut off problem outlets. If initial sample results from an outlet exceed 20 ppb, the outlet can be
             shut off or disconnected until the problem is resolved.  If the outlet had been frequently used, bottled
             water could be provided as a temporary replacement as suggested in item 2 above.
      5.3 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 should 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.
                                                                    Tip: If multiple components (for
                                                                    example, bubbler valves) are in need of
                                                                    replacement, you may wish to purchase
                                                                    only one or two initially. You could
                                                                    then take follow-up water samples after
                                                                    installing the new component(s) to see
                                                                    if that particular product leaches
                                                                    unacceptable levels of lead. If follow-
                                                                    up testing is satisfactory, you could be
                                                                    reasonably certain that the product will
                                                                    perform well at other locations in your
                                                                    facility.
(1)  Replacement. If the sources of lead contamination are
    localized and limited to a few outlets, replacing these
    outlets or upstream components may be the most
    practical solution.  EPA worked with the plumbing
    industry and NSF International to develop an industry
    standard that is designed to minimize the amounts of
    lead being leached from these products. This standard is
    NSF Standard 61 (Sections 4, 8 and 9). Before you
    purchase any brass plumbing products, request
    information regarding compliance with this standard.

    NSF Standard 61, Section 4 covers pipes, fittings and
    small drinking water storage devices having domestic or
    residential applications, including the products or water
    contact materials of pipes, fittings, tubing, hoses, well casing, drop pipes and screens, etc.

    NSF Standard 61, Section 8 covers inline mechanical devices that are used to measure or control the
    flow of water. Inline devices used to measure or control the flow of water in a building include water
    meters, building valves, check valves, meter stops, valves and fittings, backflow preventers, etc. An
    inline device is any device installed on a service line or building distribution system downstream of the
    water main and before endpoint devices.

    NSF Standard 61, Section 9 covers endpoint devices. The devices include kitchen and bar faucets,
    lavatory faucets, water dispensers, drinking fountains, water coolers, glass fillers, residential refrigerator
    ice makers, supply stops, and endpoint control valves. Under the Lead Ban, these devices must meet
    the requirements  of this standard.  Be sure to check for compliance with NSF Standard 61, Section 9
    before purchasing or installing an endpoint device.
56

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                                                       3Ts for Reducing Lead in Drinking Water m Schools. Revised Technical Guidance
(2) Lead levels can be reduced at the tap. Reverse osmosis units are commercially available and can be
    effective in removing lead.  Since these devices also tend to make the water corrosive, they should only
    be used when placed at water outlets. Such devices are termed point-of-use (POU) devices. POU
    devices can be used to treat faucets or taps, but would not be used on drinking water fountains. 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 relatively inexpensive ($65 to $250) or
    expensive (ranging from $250 to $500), their effectiveness varies, and they may be vulnerable to
    vandalism. They also require a maintenance program 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 for lead removal (NSF Standard 53). Before purchasing any device, ask the
    manufacturer for proof of NSF approval and the Performance Data Sheet, or check by visiting the
    NSF Web site at http://www.nsf.org/business/search_listings/index/asp.

(3) Check grounding wires.  Electrical current may accelerate the corrosion of lead in piping materials.
    Existing wires already grounded to the water pipes can possibly be removed by a qualified electrician,
    and replaced by an alternative grounding system. 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.
(4) Lead pipe replacement. Lead pipes within the school and those portions of the lead service lines
    under the water supplier's jurisdiction can be replaced. Contact your public water supplier regarding
    their jurisdiction. However, your facility may be responsible for replacing a portion of a lead sevice
    line that is under its own administrative jurisdiction, rather than under the jurisdiction of the water
    supplier.
(5) Reconfigure plumbing. 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 efforts result in reduced lead
    levels at the tap.
(6) Manual flushing. Flushing individual problem outlets or all outlets may also represent a permanent,
    albeit ongoing, 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 Interim Remedies section above for a discussion of the advantages/
    disadvantages of this remedy in addition to outlet flushing instructions. You should review this
    information before deciding whether flushing is appropriate as a permanent remedy in your facility.

(7) Automatic flushing.  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. They would have to be flushed manually by staff. See the Interim Remedies
    section above for flushing instructions for water fountains.

(8) Bottled water. If other treatment fails or is impractical, bottled water can be purchased for
    consumption by the building community.  As noted under the interim remedies section above, make
    sure that the bottled water you select meets federal and/or state standards for lead and other drinking
                                                                                                      57

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
             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.

          (9) Use lead-free materials. Make sure that any plumber who does repair or replacement work on the
             facility's plumbing system uses only "lead-free" solders and other materials. The 1986 Safe Drinking
             Water Act Amendments require 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, the state drinking water
             program or EPA (see Appendix D for a directory of state programs).
          (10) Shut off problem outlets. If initial sample results from an outlet exceed 20 ppb, the outlet can be
             shut off or disconnected permanently.  If the outlet had not been used regularly, this may be a viable
             option. However, if the outlet had been frequently used, this is probably not a practical solution.

      Three flow charts (Exhibits 5.2a through 5.2c) illustrating a basic remediation process are presented below.
      Please note that these flow charts provide a basic process for developing permanent solutions to lead problems.
      Interim measures are therefore not specifically addressed on the charts. Also, for simplicity, not all of the
      possible permanent remedies listed in the above discussion are shown on the charts. However, these options
      provide additional flexibility and should be considered when using the flow charts. For example, a school
      might decide to provide a point-of-use reverse osmosis treatment unit at a kitchen sink tap in lieu of replacing
      high lead plumbing because a treatment unit would provide better overall water quality for cooking and it
      would remove lead from the water.
58

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                                                            3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance
                   Exhibit 5.2a:   Remediation Flow Chart (part 1)
                        Was outlet \  YES
                        sampled?
Remediation
  Process
          Go to C on
         Exhibit 5.2.b
                                         What was
                                       result of follow
                                         up sample?
            Outlet    \   >20ppb
         replacement?1/^
                         Replace fixture and
                     associated pipes and fittings
            Cut, cap and remove
          associated pipes and other
           elements as necessary
   ^at,warXl20ppb       J No Remediation A
result of initial >       	w      .,
  sample?/               V   Necessary   J
                                                                                     NOTE
                                                                           Initial and follow-up samples refer
                                                                           to samples taken in accordance
                                                                           with procedures described in this
                                                                           document for each outlet type.
                                                                                    Outlet   \ NO
                                                                            ^^replacement?1,
                                 YES
Replace outlet1
i
r
                                                                                 Cut and cap
1 Point-of-use treatment devices or routine flushing measures may serve as
alternatives to outlet replacement (see Section 5.3). Continue on with the flow chart.
                                                                                                                 59

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        3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                                   Exhibit  5.2b:  Remediation Flow  Chart (part 2)
                                                                                             NOTE

                                                                                 Initial and follow-up samples refer
                                                                                 to samples taken in accordance
                                                                                 with procedures described in this
                                                                                 document for each outlet type.
                              Go to the
                           [ Beginning of I
                           \Exhibit 5.2a/
                                                                                                                    Find lead using
                                                                                                                    procedures in
                                                                                                                      manual2
                                                              Normal service with daily flush
                                                                    (see Exhibit 5.1)
         Wait no
       longer than
         90 days
                                           Conduct post-remediation
                                                initial sampling
                                      20ppb
                          < 20 ppb
                                                                           Return to normal
                                                                              service
)
                     1  Point-of-use treatment devices or routine flushing measures may serve as alternatives
                     to outlet replacement (see Section 5.3). Continue on with the flow chart
                    2 Procedures include follow-up sampling and development of a plumbing profile (see Sections 3.1 and 4.4).
60

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                                                             3Ts for Reducing Lead in Drinking Water in Schools  Revised Technical Guidance
                 Exhibit 5.2c:  Remediation  Flow Chart (part 3)
Take follow-up samples from
 upstream and downstream
         outlets
                                                      lion   j
confidence level that
 lead contamination
   Is localized?
             UNKNOWN or
                 LOW
         Were
      other follow-up
      samples taken
     from nearby sites
      after cutting &
        capping?
                                      /Were all samplesX NO
          NOTE
Follow-up samples refer to samples
taken in accordance with procedures
described in this document for each
outlet type.
                                                                                    Go to the
                                                                                  Beginning of
                                                                                  Exhibit 5.2a
    2 Procedures include follow-up sampling and development of a plumbing profile (see Sections 3.1 and 4.4).
                                                                                                                      61

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                                        Exhibit 5.3: Case Study 1
       This case study illustrates how one large school district addressed a long-standing lead problem. A variety of
      solutions were used to address lead problems at 50 schools in the district.
      Background
      Schools were sampled in 1991 and 1992 in response to the Lead Contamination Control Act.  Drinking
      fountains with lead levels over 20 ppb were replaced. However, subsequent testing showed that levels at some
      outlets continued to be above 20 ppb. Internal recommendations to replace plumbing at four schools were
      not implemented due to many complex factors. A flushing program was implemented, but was not
      consistently applied.

      In 2003, a concerned parent conducted testing at one school because of iron staining problems.  The testing
      showed that there were also lead problems at the school. Recognizing that the problem was likely widespread,
      the district put all schools over 7 years old on bottled water and sent a letter of notification to every parent.

      A consultant was hired to create a comprehensive testing program for almost 100 schools. A working group
      consisting of the school's local public water supplier, the county and state health departments, and
      toxicologists was formed to develop a comprehensive approach.

      A comprehensive water quality policy was adopted that includes standards for lead and 5 other contaminants.
      The standard for lead (10 ppb) is more stringent than EPA's recommended Action Level for schools and
      public buildings. The policy includes procedures for short-term and long-term testing, and for remediation.

      Testing
      In cooperation with the working group, the district's consultant developed plumbing profiles and a testing
      program, and the district began comprehensive lead testing in 2004 at 2400 sample locations. All drinking
      water fountains and cold water taps in classrooms, nurse's offices, and kitchens were sampled.  Other locations
      were sampled if they were deemed to be a potential health risk because of possible human consumption. Lead
      levels over 20 ppb were found at 25% of the locations. One location was 1600 ppb. Fifty schools were
      found to have at least one outlet with a problem. The water supplied by the local public water system was
      found to have typically less than 1 ppb lead and was ruled out as a source of lead.

      Testing also showed that flushing of the outlets for 30 seconds reduced the lead levels to below 20 ppb at all
      but 3% of the locations. Additionally, cadmium was found at 3% of the sample locations, and coliform-
      positive samples were found at 6 schools.

      Remediation
      The district adopted a policy for mitigation that included a target level of 10 ppb for lead.  Additionally, the
      EPA public water supply standards for cadmium, copper, iron and coliform bacteria were adopted.  (The EPA
      standard for iron is a secondary standard, which means that the standard is primarily an aesthetic standard
      rather than health-based. Under federal law, public water supplies are not required to comply with secondary
      standards.) Compliance with the districts adopted standards will be maintained through fixture replacement,
      filtration, replacement/rehabilitation of lines, or disabling of outlets.

       Fountains and other outlets that produce lead analysis results higher than 10 ppb will be fixed or disabled.
       Fixtures with confirmed levels of iron over 0.5 ppm will be fixed or removed from service.  If more than one-
62

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                                                         3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
half of the drinking water sources in a school or in a wing of a school exceed 0.3 ppm iron, further
remediation for iron will be addressed by the district.

The plumbing in the four schools originally targeted for replacement was fixed in the Summer of 2004.
Eventually, the plumbing in all schools will be replaced or rehabilitated so the adopted water quality standards
can be maintained. The approach used will range from complete piping replacement in just a few schools (no
more than 7 total, including the 4 already done), to partial piping replacement in a number of schools
(perhaps 15 total), to fixture replacement in many schools.

Bottled water is provided at all schools or locations within a school which have lead problems until problems
are addressed.  Drinking water is easily available to all students and all staff throughout the school day. After
compliance with the adopted water quality standards is achieved, periodic testing will continue every three
years until it is demonstrated that less frequent testing is necessary.

Public Education
The district understands the importance of informing parents, students, and staff of water quality policy and
testing results.

Additionally, the district adopted the following steps:

   •    Qualified experts were retained to obtain the best advice.

   •    A public oversight committee was created to ensure awareness and involvement of the public.

   •    Community meetings are held as necessary to keep the public updated.

   •    School board briefing sessions related to lead are open to the public.

   •    A comprehensive Web site has been developed that includes health effects information, FAQs, contact
        information, and testing results for each school in the district.

Lessons  Learned
The district had attempted to  address the Lead Contamination Control Act in 1991  and 1992 through
testing,  replacement of drinking water fountains and flushing. Fountains that tested over 20 ppb were
replaced until subsequent testing revealed that problems with lead persisted. Flushing efforts that were initially
instituted were not uniformly implemented at all district schools. The district considered replacing plumbing
in four schools, but no action was taken until 2004. The reasons for the work not being done are complex
and no one reason can be cited. Additionally, there were no clear legal mandates for lead testing and
compliance at schools served by public water utilities. Lead problems therefore continued at the schools
without school officials' awareness.

Because remedial measures were not instituted as originally planned, the public was not aware that lead
problems existed until 2003. The public response to the problems was very strong and clear. The public
wanted  to be aware of the problems and wanted them fixed. The school district had also lost credibility
because of the amount of time, the inactivity, and the lack of communication since problems were initially
discovered in the early 1990s.

The district has learned that clear, open, and timely communication is mandatory in order to restore public
confidence. An aggressive policy of testing, remediation and disclosure has helped to bridge the gap between
the district and the public and to restore confidence.
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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      •II.  Telling
      6.  Informing the Public about Lead
       In addition to testing for lead and solving any contamination problems, a lead control program should also
      include a public information component. This section discusses public information techniques and the
      importance of developing an overall communication strategy. Helpful communication hints are provided
      along with sample public notice materials.
      6.1  Techniques for Disseminating Public Information
      EPA recommends that schools conducting a lead-in-drinking-water sampling program comply with the public
      information components of the Lead Contamination Control Act. There are two components:

         (1) Notify relevant parent, teacher, student, and employee organizations of the availability of your
             sampling program results.

         (2) Make copies of the sampling results available in your administrative offices "for inspection by the
             public, including teachers, other school personnel, and parents."

      Given the health effects of lead, EPA advocates that any school conducting sampling for lead make public
      any test results. In addition, such schools should identify activities they are pursuing to correct any lead
      problems found.

      There are six basic public notification methods that can be applied alone or in combination to communicate
      lead-in-drinking-water issues and the meaning of your sampling program results.

      You should choose the method(s) 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. All materials should be culturally and linguistically appropriate.
         •   Press Release: A press release in the local newspaper can potentially inform a broad range of the
             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.

         •   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.

         •   Mailbox or Paycheck Staffers: Mailbox and paycheck stuffers represent the most direct and effective
             method of communicating lead in drinking water activities to school employees. 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 another option for directly and effectively
             communicating information about the lead program to employees.
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                                                         3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
       Presentations:  Providing presentations at facility-related meetings is another effective means of
       communication. Relevant events for schools include meetings of parent-teacher organizations, faculty,
       and the school board.
       Email and Web sites: Electronic communications are convenient for many parents, especially those
       who work during the school day. Web sites can be updated frequently to quickly convey new
       information. Email provides a quick, easy method for parents to ask questions, but responses must be
       timely to be effective.
6.2 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 health. 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
   •   Content of the message
   •   Methods and manner of communication.
6.3 Participants
Overall, there are six primary players or interests involved in the control of lead in drinking water:
   (1) Your School Community: School employees, students, and parents should be informed and involved
       from the beginning of the process. Interested employees, students, and parent volunteers can help
       address the issue and ensure safe drinking water at your school.
   (2) Building Community: The building community consists of those users of the facility who would be
       most affected by lead in drinking water problems (i.e., students, teachers and other employees, school
       boards and community groups who use the facility).  Members of the school and building community
       should be the primary targets of any general communication activities.

   (3) Local Health Community: Local health officials, such as health officers, sanitarians, and nurses, can
       help you understand potential health risks associated with elevated lead levels in drinking water.

   (4) 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.
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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
          (5) States and EPA Regions: State drinking water programs and EPA Regional offices are responsible for
             ensuring that public water suppliers comply with the state and federal regulations regarding lead in
             drinking water. States or EPA may be able to provide guidance or technical assistance in
             communication strategies, health risks, and other sources of lead.

          (6) Drinking Water Community: Public water suppliers 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.
      6.4 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, EPA recommends that you provide
      information to members of the local school community and the larger community (if deemed necessary) at
      the following three times.
          (1) Before your lead in drinking water sampling program begins.
          (2) In response to periodic interest.
          (3) After you obtain the results of testing, when/if you decide upon corrective measures, or if no corrective
             measure are required because the lead levels are low.
      6.5 Content
      Your communication messages should consist of the following information:
          (1)  Details about the nature of your drinking water lead control program.
          (2)  The results of your sampling program and your plans for correcting any identified problems.
          (3)  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, air, dust, and soil.
          (4)  The availability of general lead in drinking water information resources and the availability of the
              detailed sampling results for your facility.

          (5)  How and where individuals may seek blood-lead level testing if they are concerned.

          (6)  Recommend consultation with a physician if further assistance is needed.

          (7)  How families can increase their awareness of exposure in their home and elsewhere.
       6.6 Methods and  Manner of Communication
       The communication methods that can be used for your general communication strategy are largely the same as
       those described earlier and, thus, need not differ from communication activities common to school operations
       (i.e., meeting presentations, press releases, mailbox/paycheck stuffers, and letters to staff and parents). If your
       school has a large community of non-English speakers you should provide information in other languages, as
       appropriate, or provide a contact name for non-English speakers to get more information.
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                                                          3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Additional methods unique to your lead control program may include:
   (1) Creating an information center located at a convenient place in the facility such as a library or break
       room.

   (2) Creating a task force with representatives from the community.

   (3) Making available a list of laboratories that are state-certified to test home water for lead and other
       contaminants.
   (4) (For schools) encouraging classroom science activities that focus on drinking water quality. (Contact
       EPA's Safe Drinking Water Hotline 1-800-426-4791- see Appendix B and C-for information on
       organizations that have such science activities).

The following list contains some hints for effective communication:

   (1) 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.

   (2) Be a good and reliable source of information. That is, provide honest, accurate, and comprehensive
       information in every necessary area.

   (3) Always speak with one voice (i.e., designate points of contact - preferably one person — to respond to
       parents and the media).

   (4) Anticipate likely questions from members of the local community, including civic organizations and
       the media, and prepare answers. Each member of the community may have a different concern or
       viewpoint on the subject of lead testing.

   (5) 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.
   (6) Keep members of the building community up-to-date as important events and information on your
       lead testing program unfold.
6.7 Sample Public Notice Materials
Exhibit 6. 1 contains a sample public notification letter that could be used and adapted to communicate lead
testing information. Exhibit 6.2 is a sample press release for local media that could also be used or adapted.
Exhibit 6.3 is a sample article that could be published in a school newsletter.
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       3Ts for Reducing Lead in Drinking Water m Schools Revised Technical Guidance
                                   Exhibit  6.1:  Sample Public Notice Letter
           (Date)

           Anytown School Department
           Anytown, USA 00000-0000

           Dear Anytown School Community:

           Our school system is committed to protecting student, teacher, and staff health. To protect our community, (Anytown
           School District) tests our schools' drinking water for lead.

           Why Test School Drinking Water for Lead?
           High levels of lead in drinking water can cause health problems. Lead is most dangerous for pregnant women, infants,
           and children under 6 years old. Exposure to high levels of lead during pregnancy contributes to low birth weight and
           developmental delays in infants. In young children, lead exposure can lower IQ levels, affect hearing, reduce attention
           span, and hurt school  performance. At very high levels, lead can even cause brain damage.

           To protect public health, the U.S. Environmental Protection Agency (EPA) suggests that schools and day care facilities
           test their drinking water for lead. If lead is found at any water outlet at levels above 20 parts per billion (ppb), EPA
           recommends taking action to reduce the lead.

           Is Our School's Drinking Water Safe?
           Yes, our schools' water is safe. Anytown School District tested our drinking water for lead. Of the (number) water
           samples we tested, only (number) showed lead levels above the 20 ppb mark. In other words, (percentage) of the
           water outlets tested did not have any lead problems.

           The first outlet with high lead levels was a drinking water fountain/bubbler at (Anytown High School). We identified
           the source of the lead  so we could fix the problem. The faucet for this drinking water fountain/bubbler was made of
           lead parts. (Lead was often used in plumbing materials until it was banned in 1986). We replaced the part with a lead-
           free faucet. Then we tested the water again and found the problem was fixed.

           The second outlet with high lead levels was a faucet in the kitchen of (Anvtown Elementary School). We found the
           source of the lead was a  pipe that brings water to the faucet. We replaced the pipe with lead-free pipe. Then we tested
           the water again and found the problem was fixed.

           While we sampled the schools' water, we provided bottled water for all students and staff. When we found high lead
           levels at (two) water outlets, we made sure no one used those outlets until we had fixed the lead problems.

           How Can I Learn More?
           You can  see a copy of all of our water testing results at the school district's central office, which is open Monday to
           Friday from (9:00 am to  5:00 pm) and on our Web site at (www.anytownschools.k12.us). For more information about
           water quality in our schools, please contact (John Doe) at (Anytown School District. 555-2233). For information about
           water quality and sampling for lead at home, contact your local water supplier or state drinking water agency.

           Sincerely,

           (Fred Frank)
           Superintendent of Schools

           Note: If your school district cannot immediately fix elevated lead levels, we encourage you to send this notice without
           delay. In that case, describe the interim measures you will take to provide safe drinking water until the problem can be
           addressed and the reason for the delay in a implementing a permanent solution.
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                                                           3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                 Exhibit 6.2:  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, 2005... The Anytown School Department announced today that recent tests of drinking
water in the town's schools indicate that lead levels meet federal guidelines. Although lead was initially detected
above the recommended level at one drinking water outlet in an elementary school and at one outlet in a senior high
school, lead levels were reduced to acceptable levels following replacement of these outlets.

    In making the announcement. School Superintendent Fred Frank stated, "We are pleased that the testing program
identified only two drinking water outlets with elevated lead levels.  Both outlets have since been replaced."

    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
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       3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
                                    Exhibit 6.3:   Sample  Newsletter Article


           Anytown  School District Conducts Sampling for Lead in Drinking Water

           Why was Testing Conducted?

           Schools that receive water from a public water system, such as our district, are not required by state or federal
           regulations to conduct testing for lead in their drinking water. The Environmental Protection Agency (EPA) requires
           our public water system to provide water to our school that is minimally corrosive. However, some school districts in
           other locations have found that water samples from their drinking water fixtures have contained relatively high levels
           of lead. The lead was found to come from the plumbing inside the schools, including fittings, solder, water coolers or
           water faucets.  Because of this information, the Anytown School District decided that testing would be in the best
           interests of the children, parents, faculty and other citizens served by our district.

           Health Effects of Lead

           The EPA has determined that lead in drinking water is a health concern at certain levels of exposure. Lead is found
           throughout the environment in lead-based paint, air, soil, household dust, food, certain types of pottery porcelain and
           pewter, and water. Lead can pose a significant risk to your health if too much of it enters your body.  Lead builds up in
           the body over many years and can cause damage to the brain, red blood cells and kidneys. The greatest risk is to
           young children and pregnant women. Amounts of lead that will not hurt adults can  slow down normal mental and
           physical  development of growing bodies. In addition, a child at play often comes into contact with sources of lead
           contamination - like dirt and dust - that rarely affect an adult. It is important to wash children's hands and toys often,
           and to try to make sure they only put food in their mouths.

           How Lead Enters our Water

           Lead is unusual among drinking water contaminants in that it seldom occurs naturally in water supplies like
           groundwater, rivers and lakes. Lead enters drinking water primarily as a result of the corrosion, or wearing away, of
           materials containing lead in the water distribution system and in building plumbing.  These materials include lead-
           based solder used to join copper pipe, brass, and chrome-plated brass faucets. In 1986, Congress banned the use of
           lead solder containing greater than 0.2% lead, and restricted the lead content of faucets, pipes and other plumbing
           materials.  However, even the lead in plumbing materials meeting these new requirements is subject to corrosion.
           When water stands in lead pipes or plumbing systems containing lead for several hours or more, the lead may dissolve
           into the drinking water. This means the first water drawn from the tap in the morning may contain fairly high levels of
           lead.

           Lead in Drinking Water

           Lead in drinking water, although rarely the sole cause of lead poisoning, can significantly increase a person's total lead
           exposure, particularly the exposure of children under the age of 6. EPA estimates that drinking water can make up 20%
           or more of a person's total exposure to lead.

           Results of our Testing

           Following instructions 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 outlet that tested high for lead 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.
           (Continued on next page)
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                                                             3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
(Continued from previous page)

The second outlet, in the Lincoln Elementary School, was a faucet in the kitchen that 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.

During the testing period, bottled water was provided to all students at all schools to minimize the potential for lead
exposure. Upon receiving the test results, the two outlets that tested high for lead were disconnected until they were
replaced.

A copy of the test results is available in our central office for inspection by the public, including students, 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 your water supplier or drinking
water agency.
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      3Ts for Reducing Lead m Drinking Water in Schools Revised Technical Guidance
      Appendix A - Glossary of Terms

      Bubbler: An outlet fixture that consists of the bubbler valve, the bubbler receptacle and all associated piping,
      valves and mounting appurtenances for attaching the fixture to a wall or mounting surface. A bubbler does
      not contain a refrigeration unit. Some bubblers are attached to central chiller units, while others are not.

      Bubbler Valve: The valve and discharge device that mounts on top of the bubbler fixture and discharges water
      for consumption.

      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"): A valved outlet device attached to a pipe that normally serves a sink or tub fixture. A faucet
      discharges hot and/or cold water for a variety of consumptive uses, including drinking, cooking, and washing.
      The term "faucet" is used interchangeably with the term "tap."

      Fittings: Fittings  are generally static parts that are used to join sections of pipe, or to join pipe to outlet
      fixtures.

      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 Amendments 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 header or riser pipe and a fixture or group of fixtures. A lateral may or
      may not be looped.  Where more than one fixture is served by a lateral, connecting pipes are provided between
      the fixtures and the lateral.

      Lead-free: Taken from Section I4l7(d) of the Safe Drinking Water Act, this term means that solders and
      flux may not contain more than 0.2 percent lead; pipes, pipe fittings, and well pumps may not contain more
      than 8.0 percent lead; and outlet plumbing fittings and fixtures must meet standards established under the lead
      leaching requirements of section I4l7(e) of the Safe Drinking Water Act.

      Outlet: A location where water may be accessed for consumption such as a drinking fountain, water faucet, or
      tap.

      Passivation: A corrosion control technique that causes the pipe materials to create metal-hydroxide-carbonate
      compounds that form a film on the pipe wall to protect the pipe.
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                                                          3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Potable Water Pipes: The pipes in a distribution system and in a building which carry water intended for
human consumption.

Public Water System: Any water system that has 15 or more service connections and is in operation at least
60 days per year or any water 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 Connection: The pipe that carries tap water from the public water main to a building.  In the past,
these were often comprised of lead materials.

Source Water: Untreated water from streams, rivers, lakes, or underground aquifers that is used to supply
private wells and public drinking water.

Solder: A metallic compound used to seal the joints between pipes. Until 1988, solder containing up to 50%
lead was legally used in potable water plumbing. Lead-free solders, which can contain up to 0.2% lead, 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.

Valves: Valves are 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.

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.
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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      Appendix B - Publication List

      Web Site Publications*
      (1)   *Actions You Can Take To Reduce Lead in Drinking Water.  Web site publication. US EPA 810-F-93-
          001. June 1993. http://www.epa.gov/safewater/lead/leadfactsheet.html
      (2)  Commonly Asked Questions: Section 1417 of the Safe Drinking Water Act and the NSF Standard.  US
          EPA. http://www.epa.gov/safewater/standard/plumbing.html
      (3)  Consumer Fact Sheet on: Lead. Web site article.  US EPA. http://www.epa.gov/safewater/dwh/c-ioc/
          lead.html
      (4)  Decision Tree for Pre-Sampling (at Schools). Web site article. US EPA, http://www.epa.gov/safewater/
          schools
      (5)  *Fact Sheet - Lead Reduction Plan - EPA Activities to Improve Implementation of the Lead and Copper
          Rule. Web site publication.  US EPA 810-F-05-001.  March 2005. http://www.epa.gov/safewater/lcrmr/
          reductionplan  fs.html
      (6)  Frequently Asked Questions. Web site article. National Sanitation Foundation (NSF). http://
          www.nsf.org/business/water distribution/dwa usepa.asp
      (7)  *Is There Lead in the Drinking Water? Web site publication. US EPA 903-F-01-002. April 2002.
          http://www.epa.gov/safewater/lead/pdfs/v2final.pdf
      (8)  *Lead Contamination Control Act (pamphlet). Web site article. Web site publication.  US EPA 570/9-
          89-AAA. July 1989. http://www.epa.gov/safewater/lead/pdfs/epalccapamphletl989.pdf
      (9) Lead Contamination Control Act (statute). Web site article. Government Printing Office. January 2004.
          http://www.access.gpo.gov/uscode/title42/chapter6a subchapterxii  partf .html
      (10) *Lead in Drinking Water in Schools and Non-Residential Buildings. Web site publication. US EPA
          812-B-94-002.  (April 1994 version of this document.)
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                                                        3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
(11) Lead in Schools and Day Care Centers. Web site article.  US EPA.) http://www.epa.gov/safewater/lead/
    schoolanddccs.htm
(12) Mechanical Plumbing System Components. Web site article. Listing of approved components. NSE
    http://www.nsf.org/business/mechanical plumbing/index.asp?program=MechanicalPluSysCom
(13) National Lead Information Center - Document Request Site. US EPA. http://www.epa.gov/lead/
    nlicdocs.htm
(14) Post-Remediation Sampling. Web site article, (after replacement of fixtures, pipe, fittings, etc.). US EPA.
    http://www.epa.gov/safewater/lead/passivation.htm
(15) Testing Schools and Day Care Centers for Lead in Drinking Water. Web site article. US EPA. http://
    www.epa.gov/safewater/lead/testing.htm
(16) *Lead Contamination Control Act (P.L. 100-572 - federal statute) and supporting documents. House
    Document Room, House of Representatives. Washington, DC 20515. (202) 225-3456.
(17) *Samplingfor Lead in Drinking Water in Nursery Schools and Day Care Facilities (booklet).  US EPA
    812-B-94-003.  April 1994.
(18) *The Lead Ban: Preventing the Use of Lead in Public Water Systems and Plumbing Used for Drinking
    Water (pamphlet on the federal lead ban).  US EPA 570/9-89-BBB. August 1989.

* Also available in hard copy through the National Drinking Water Hotline. See below.

                                   Hard Copy  Publications
                              EPA National Safe Drinking Water Hotline
                                          (800)426-4791

                              Hotline operates Monday through Friday,
                                       except federal holidays.

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      Appendix C - Resources

      Safe Drinking Water Hotline 1-800-426-4791

      Healthy School Environments
      Healthy School Environments
      This web site is designed to provide one-stop access to the many programs and resources available to help
      prevent and resolve environmental issues in schools,  http://www.epa.gov/schools/

      Department of Education Safe and Drug Free Schools
      This Department of Education web site offers a collection of links and resources on various school health and
      safety topics. http://www.ed.gov/admins/lead/safety/edpicks.jhtml?src=qc

      Lead Poisoning Prevention
      Lead Poison Prevention
      EPA's Lead Awareness Program designs outreach activities and educational materials, awards grants, and manages
      a toll-free hotline to help parents, home owners, and lead professionals learn what they can do to protect their
      families, and themselves, from the dangers of lead, http: //www. epa.gov/lead/

      The Centers for Disease Control Childhood Lead Poisoning Prevention Program
      The Lead Contamination Control Act of 1988 authorized the Centers for Disease Control and Prevention
      (CDC) to initiate program efforts to eliminate childhood lead poisoning in the United States. Visit this web site
      for information on partnerships, publications, and various other materials addressing lead poison prevention.
      http://www.cdc.gov/nceh/lead/lead.htm

      National Lead Information Center (NLIC)
      The National Lead Information Center (NLIC) provides the general public and professionals with information
      about lead hazards and their prevention. NLIC operates under a contract with the U.S. Environmental
      Protection Agency (EPA), with funding from EPA, the Centers for Disease Control and Prevention, and the
      Department of Housing and Urban Development. (1-800-424-LEAD [5323]).  http: //www. epa.gov/lead/
      nlic.htm

      Accredited  Certification Programs:
      American National Standards Institute: list of accredited plumbing and other product certification programs.
      www.ansi.org/public/ca/ansi  cp.html

      The current companies/organizations with NSF 61 plumbing component certification programs accredited by
      ANSI:
             National Sanitation Foundation: Also provides information on the standards that it has issued.
             www.nsf.org
             Underwriters Laboratories,  www.ul.com
             International Association of Plumbing & Mechanical Officials, Research & Testing, Inc.
             www.iapmo.org/rnt/index.html
             Canadian Standards Association International, www.csa.ca
             Truesdail Laboratories,  www.truesdail.com
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                                                   3Ts for Reducing Lead m Drinking Water in Schools Revised Technical Guidance
Appendix D - List of State Drinking Water Programs
Alabama
Mr. Ed Hughes, Chief
Drinking Water Branch
Dept. of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
Phone: 334-271-7774
Fax:334-279-3051
E-mail: ekh@adem.state.al.us

Alaska
Dr. James Weise, Manager
Drinking Water Program
Division of Environmental Health
Alaska Dept. of Environmental Conservation
555 Cordova St.
Anchorage, AK 99501
Phone: 907-269-7647
Fax: 907-269-7655
E-mail: james_weise@dec.state.ak.us

American Samoa
Ms. Sheila Wiegman, Environmental
Coordinator
American Samoa
Environmental Protection Agency
Office of the Governor
Pago Pago, AS 96799
Phone: 684-633-2304
Fax:684-633-5801

Arizona
Mr. John Calkins
Drinking Water Section
Arizona Dept. of Environmental Quality
1110W. Washington St.
Phoenix, AZ 85007
Phone:602-771-4617
Fax: 602-771-4634
E-mail: calkins.john@azdeq.gov
Arkansas
Mr. Harold R. Seifert, P.E., Director
Division of Engineering
Arkansas Department of Health
4815 West Markham Street
Mail Slot 37
Little Rock, AR 72205-3867
Phone: 501-661-2623
Fax: 501-661-2032
E-mail: hseifert@HealthyArkansas.com

California
Dr.  David P. Spath, Chief
Division of Drinking Water
and Environmental Management
California Dept. of Health Services
P.O. Box 997413
Sacramento, CA 95899-7413
Phone:916-449-5582
Fax: 916-449-5575
E-mail: DSpath@dhs.ca.gov

Colorado
Mr. Chet Pauls, Manager
Drinking Water Program
Water Quality Control Division
Colorado Dept. of Public Health and
Environment
WQCD-DW-B2
4300 Cherry Creek Drive, South
Denver, CO 80246-1530
Phone: 303-692-3610
Fax: 303-782-0390
E-mail: chester.pauls@state.co.us
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      3Ts for Reducing Lead in Drinking Water in Schools; Revised Technical Guidance
      Connecticut
      Dr. Gerald R. Iwan, Director
      Drinking Water Division
      Connecticut Dept. of Public Health
      410 Capitol Ave. MS-51WAT
      P.O. Box 340308
      Hartford, CT 06134-0308
      Phone: 860-509-7333
      Fax: 860-509-7359
      E-mail: gerald.iwan@po.state.ct.us

      Delaware
      Mr. Edward G. Hallock, Program
      Administrator
      Office of Drinking Water
      Division of Public Health
      Delaware Health and Social Services
      Blue Hen Corporate Center, Suite 203
      655 Bay Road
      Dover, DEI 9901
      Phone:302-741-8590
      Fax:302-741-8631
      E-mail: edward.hallock@state.de.us

      District of Columbia
      Ms. Jerusalem Bekele, Chief
      Water Quality Division
      Department of Health
      51 N Street,  NE
      Washington, DC 20002
      Phone:202-535-1603
      E-mail: jerusalem.bekele@dc.gov

      Florida
      Mr. Van R. Hoofnagle, Administrator
      Drinking Water Section
      Florida Dept. of Environmental Protection
      Twin Towers Office Building
      2600 Blair Stone Road
      Tallahassee, FL 32399-2400
      Phone:850-245-8631
      Fax: 850-245-8669
      E-mail: van.hoofnagle@dep.state.fl.us
Georgia
Mr. Nolton G. Johnson, Chief
Water Resources Branch
Environmental Protection Div., Georgia DNR
2 Martin Luther King, Jr. Drive, S.E.
East Tower - Suite 1362
Atlanta, GA 30334
Phone:404-651-5168
Fax:404-651-9590
E-mail:
nolton_johnson@mail.dnr.state.ga.us
*Mr. Brad Addison is Manager
of the Drinking Water Program
(see address above)
Phone:404-651-5155
Fax:404-651-9590
E-mail: brad_addison@dnr.state.ga.us

Guam
Mr. Jesus T. Salas, Administrator
Guam Environmental Protection Agency
Government of Guam
P.O. Box 22439 GMF
Barrigada, GU 96921
Phone:671-472-8863
Fax: 671-477-9402

Hawaii
Mr. Thomas E. Arizumi, Chief
Environmental Management Division
Hawaii Department of Health
919 Ala Moana Blvd.
Room 300
Honolulu, HI 96814-4920
Phone: 808-586-4304
Fax: 808-586-4352
 E-mail:
tarizumi@eha.health.state.hi.us

*Mr. Bill Wong is the Chief of
the Safe Drinking Water Branch
(see address above, except Room 308)
Phone: 808-586-4258
Fax:808-586-4351
E-mail: waterbill@aol.com
78

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                                                      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Idaho
Mr. Lance E. Nielsen, Manager
Drinking Water Program
Idaho Dept. of Environmental Quality
1410 North Hilton
Boise, ID 83706
Phone:208-373-0291
Fax: 208-373-0576
E-mail: lance.nielsen@deq.idaho.gov

Illinois
Mr. Roger D. Selburg, P.E., Manager
Division of Public Water Supplies
Illinois EPA
P.O. Box 19276
Springfield, IL 62794-9276
Phone:217-785-8653
Fax: 217-782-0075
E-mail: roger.selburg@epa.state.il.us

Indiana
Mr. Patrick Carroll, Chief
Drinking Water Branch
Office of Water Quality
Dept. of Environmental Management
P.O. Box 6015
Indianapolis, IN 46206-6015
Phone:317-308-3281
Fax:317-308-3339
E-mail: pcarroll@idern.in.gov

Iowa
Mr. Dennis J. Alt, Environmental Program
Supervisor
Water Supply Section
Iowa Department of Natural Resources
401 SW 7th Street, Suite  M
Des Moines,  IA 50309-4611
Phone:515-725-0275
Fax: 515-725-0348
E-mail: dennis.alt@dnr.state.ia.us
*Mr. Steve Hopkins is Supervisor of
the Water Supply Operations
(see address above)
Phone:515-725-0295
Fax:515-725-0348
E-mail: stephen.hopkins@dnr.state.ia.us
Kansas
Mr. David F. Waldo, Chief
Public Water Supply Section
Bureau of Water
Kansas Dept of Health & Environment
1000 SW Jackson St. - Suite 420
Topeka, KS 66612-1367
Phone: 785-296-5503
Fax: 785-296-5509
E-mail: dwaldo@kdhe.state.ks.us

Kentucky
Ms. Donna S. Marlin, Manager
Division of Water - Drinking Water Branch
Kentucky Dept. for Environmental Protection
14 Reilly Road, Frankfort Ofc. Park
Frankfort, KY 40601
Phone: 502-564-3410
Fax:502-564-5105
E-mail: donna.marlin@ky.gov

Louisiana
Ms. Karen Irion, Administrator
Safe Drinking Water Program
Center for Environmental and Health
Services
Office of Public Health
Louisiana Dept. of Health and Hospitals
6867 Blue Bonnet Blvd.
Baton Rouge, LA 70810
Phone: 225-765-5046
Fax: 225-765-5040
E-mail: Kirion@dhh.la.gov

Maine
Ms. Nancy Beardsley, Director
Drinking Water Program
Maine Department of Health and Human
Services
Division of Health Engineering
11 State House Station
Augusta, ME 04333
Phone: 207-287-5674
Fax: 207-287-4172
E-mail: nancy.beardsley@maine.gov
                                                                                                  79

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      3Ts for Reducing Lead m Drinking Water in Schools Revised Technical Guidance
      Maryland
      Mr. Saeid Kasraei, Manager
      Water Supply Program
      Maryland Dept. of the Environment
      Montgomery Park Business Center
      1800 Washington Blvd. - Suite 450
      Baltimore, MD 21230-1708
      Phone:410-537-3702
      Fax:410-537-3157
      E-mail: skasraei@mde.state.md.us

      Massachusetts
      Mr. David Terry, Director
      Drinking Water Program
      Massachusetts Department of
      Environmental
      Protection
      One Winter Street, 6th Floor
      Boston, MA 02108
      Phone:617-292-5529
      Fax: 617-292-5696
      E-mail: david.terry@state.ma.us

      Michigan
      Mr. James K. Cleland, P.E., Chief
      Water Bureau
      Michigan Dept. of Env. Quality
      P. O. Box 30630
      Lansing, MI 48909-8130
      Phone:517-241-1287
      Fax:517-335-0889
      E-mail: clelandj@michigan.gov

      Minnesota
      Mr. Doug Mandy, Manager
      Drinking Water Protection Section
      Minnesota Department of Health
      Metro Square Building, Suite 220
      P.O. Box 64975
      St. Paul, MN 55164-0975
      Phone:651-215-0757
      Fax:651-215-0775
      E-mail: douglas.mandy@health.state.mn.us
Mississippi
Mr. Keith Allen, Director
Division of Water Supply
Mississippi State Department of Health
P.O. Box 1700
570 E. Woodrow Wilson Dr.
Jackson, MS 39215-1700
Phone:601-576-7518
Fax: 601-576-7822
E-mail: kallen@msdh.state.ms.us

Missouri
Mr. Ed Galbraith, Director
Water Protection Program
Missouri Dept of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
Phone:573-751-6721
Fax:573-751-1146
E-mail: ed.galbraith@dnr.mo.gov

Montana
Mr. Jon Dillard, Bureau Chief
Public Water and Subdivisions Bureau
Montana Dept. of Environmental Quality
Box 200901
1520 East  Sixth Ave.
Helena, MT 59620-0901
Phone: 406-444-4071
Fax:406-444-1374
E-mail: jdillard@mt.gov

Nebraska
Mr. Jack L. Daniel, Administrator
Environmental Health Services Section
Nebraska Health and Human Services
System
301 Centennial Mall South, 3rd Floor
P.O. Box 95007
Lincoln, NE 68509-5007
Phone:402-471-0510
Fax:402-471-6436
E-mail: jack.daniel@hhss.ne.gov
80

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                                                      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Nevada
Mr. Andrew Huray, Chief
Public Health Engineering Section
Nevada State Health Division
1179 Fairview Drive
Carson City, NV 8 9701
Phone: 775-687-6353
Fax: 775-687-5699
E-mail: ahuray@nvhd.state.nv.us

New Hampshire
Mr. Rene Pelletier, Program Manager
Water Supply Engineering Bureau
Dept. of Environmental Services
Post Office Box 95
6 Hazen Drive
Concord, NH 03302-0095
Phone: 603-271-3434
Fax:603-271-5171
E-mail: rpelletier@des.state.nh.us
* Ms. Sarah Pillsbury is Drinking Water
Administrator
(see address above)
Phone:603-271-1168
Fax:603-271-2181
E-mail: spillsbury@des.state.nh.us

New Jersey
Mr. Barker Hamill, Chief
Bureau of Safe Drinking Water
New Jersey Department of Environmental
Protection
P.O. Box  426
Trenton, NJ 08625
Phone: 609-292-5550
Fax: 609-292-1654
E-mail: barker.hamill@dep.state.nj.us
New Mexico
Mr. Fernando Martinez, Chief
Drinking Water Bureau
New Mexico Environment Department
525 Camino De Los Marquez
Suite 4
Santa Fe, NM 87505
Phone: 505-827-1400
Fax: 505-827-7545
E-mail:
fernando_martinez@nmenv.state.nm.us

New York
Mr. Jack Dunn, Director
Bureau of Public Water Supply Protection
New York Department of Health
Flanigan Square, Rm. 400
547 River Street
Troy, NY 12180-2216
Phone:518-402-7650
Fax:518-402-7659
E-mail: jmd02@health.state.ny.us

North Carolina
Ms. Jessica G. Miles, P.E., Chief
Public Water Supply Section
North Carolina Dept. of Env. and Natural
Resources
1634 Mail Service Center
Raleigh, NC 27699-1634
Phone:919-715-3232
Fax:919-715-4374
E-mail: jessica.miles@ncmail.net

North Dakota
Mr. Larry J. Thelen, Program Manager
Drinking Water Program
ND Dept. of Health
1200 Missouri Avenue, Room 203
P.O. Box 5520
Bismarck, ND 58506-5520
Phone: 701-328-5257
Fax: 701-328-5200
E-mail: lthelen@state.nd.us
                                                                                                 81

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      Northern Mariana Islands
      Mr. John I. Castro, Director
      Division of Environmental Quality
      Commonwealth of the Northern Mariana Islands
      Post Office Box 501304
      Saipan, MP 96950-1304
      Phone: 670-664-8500
      Fax: 670-664-8540
      E-mail: deq.director@saipan.com
      *Mr. Joe M. Kaipat is the Manager of
      the Safe Drinking Water Branch
      (see address above)
      Phone: 670-664-8500
      Fax: 670-664-8540
      E-mail: joe.kaipat@saipan.com

      Ohio
      Mr. Mike G. Baker, Chief
      Division of Drinking and Ground Waters
      Ohio EPA
      Lazarus Gov't Center
      P.O. Box 1049
      Columbus, OH 43216-1049
      Phone:614-644-2752
      Fax: 614-644-2909
      E-mail: mike.baker@epa.state.oh.us
      *Mr. Kirk Leifheit is Assistant Chief of
      Drinking Water in the
      Division of Drinking and Ground Waters
      (see address above)
      Phone:614-644-2769
      Fax: 614-644-2909
      E-mail: kirk.leifheit@epa.state.oh.us

      Oklahoma
      Mr. Jon L. Craig, Director
      Water Quality Division
      Department of Environmental Quality
      707 North Robinson
      Suite 8100
      P.O. Box 1677
      Oklahoma City, OK 73101-1677
      Phone:405-702-8100
      Fax:405-702-8101
      E-mail: j on. craig@deq. state, ok. us
*Mr. Mike S. Harrell is Administrator of
the Public Water Supply Program
(see address above)
Phone:405-702-8158
Fax:405-702-8101
E-mail: mike.harrell@deq.state.ok.us

Oregon
Mr. David E. Leland, Manager
Drinking Water Program
Office of Public Health Systems
Oregon Department of Human Services
800 NE Oregon St. - Rm. 611
Portland, OR 97232
Phone:503-731-4010
Fax: 503-731-4077
E-mail: david.e.leland@state.or.us

Pennsylvania
Mr. Jeffrey A. Gordon, Chief
Division of Operations Management and Training
Bureau of Water Standards and Facility
Regulation
Department of Environmental Protection
P.O.  Box 8467
Harrisburg, PA 17105-8467
Phone:717-772-4018
Fax: 717-772-3249
E-mail: jegordon@state.pa.us

Puerto Rico
Ms. Olga Rivera, Director
Public Water Supply Supervision Program
Puerto Rico Department of Health
Office of the Secretary
Nacional Plaza Building
431 Ponce De Leon Ave.
9th Floor - Suite 903
HatoRey, PR00917
Phone: 787-648-3903
Fax: 787-758-6285
E-mail: orivera@salud.gov.pr
82

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                                                     3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Rhode  Island
Ms. June A. Swallow, P.E., Chief
Office of Drinking Water Quality
Rhode Island Department of Health
3 Capitol Hill, Room 209
Providence, RI02908
Phone:401-222-6867
Fax:401-222-6953
E-mail: junes@doh.state.ri.us

South Carolina
Mr. Alton C. Boozer, Chief
Bureau of Water
South Carolina Dept. of Health &
Environmental Control
2600 Bull Street
Columbia, SC 29201
Phone: 803-898-4259
Fax: 803-898-3795
E-mail: boozerac@dhec.sc.gov

South Dakota
Mr. Rob Kittay, Administrator
Drinking Water Program
Division of Environmental Regulation
SD Dept. of Env. and Natural Resources
523 East Capital Ave, Joe Foss Bldg
Pierre, SD 57501-3181
Phone: 605-773-4208
Fax: 605-773-5286
E-mail: rob.kittay@state.sd.us

Tennessee
Mr. W. David Draughon, Jr., Director
Division of Water Supply
Tennessee Dept. of Environment &
Conservation
401 Church Street
L & C Tower, 6th Floor
Nashville, TN 37243-1549
Phone:615-532-0152
Fax:615-532-0503
E-mail: david.draughon@state.tn.us
Texas
Mr. E. Buck Henderson, Manager
Public Drinking Water Section
Water Supply Division
Texas Commission on
Environmental Quality
P.O. Box 13087 (MC-155)
Austin, TX 78711-3087
Phone:512-239-0990
Fax:512-239-0030
E-mail: ehenders@tceq.state.tx.us

Utah
Mr. Kevin W. Brown, Director
Division of Drinking Water
Utah Dept. of Environmental Quality
P.O. Box 144830
Salt Lake City, UT 84114-4830
Phone:801-536-4188
Fax:801-536-4211
E-mail: kwbrown@utah.gov

Vermont
Mr. Jay L. Rutherford, P.E., Director
Water Supply Division
Vermont Dept. of Env. Conservation
Old Pantry Building
103 South Main Street
Waterbury, VT 05671-0403
Phone:802-241-3434
Fax:802-241-3284
E-mail: jay.rutherford@state.vt.us

Virgin Islands
Mr. Leonard Reed, Assistant Director
Division of Environmental Protection
Dept. of Planning & Natural Resources
Wheatley Center 2
St. Thomas, VI 00802
Phone: 340-777-4577
Fax: 340-774-5416
* Mrs. Christine M. Lottes is Supervisor of Public
Water System Supervision (PWSS)
Dept. of Planning & Natural Resources
Water Gut Homes 1118
Christiansted, St. Croix, VI 00820-5065
Phone: 340-773-0565
Fax:340-773-9310
                                                                                                 83

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      Virginia
      Mr. Jerry Peaks, Director
      Office of Drinking Water
      Virginia Department of Health
      109 Governor St.
      Richmond, VA 23219
      Phone: 804-864-7488
      Fax: 804-864-7520
      E-mail: jerry.peaks@vdh.viginia.gov

      Washington
      Ms. Denise Addotta Clifford, Director
      Office of Drinking Water
      WA Department of Health
      7211 Cleanwater Lane, Bldg. 9
      P.O. Box 47828
      Olympia, WA 98504-7828
      Phone:360-236-3110
      Fax: 360-236-2253
      E-mail: denise.clifford@doh.wa.gov

      West Virginia
      Mr. Walter Ivey, Director
      Environmental Engineering Div.
      Office of Environmental Health Services
      West Virginia Dept. of Health and Human
      Services
      815 Quarrier Street, Suite 418
      Charleston, WV 25301
      Phone:304-558-6715
      Fax: 304-558-0289
      E-mail: walterivey@wvdhhr.org

      Wisconsin
      Ms. Jill D. Jonas, Director
      Bureau of Drinking Water and Groundwater
      Wisconsin Department of Natural Resources
      P.O. Box 7921
      Madison, WI 53707
      Phone: 608-267-7545
      Fax: 608-267-7650
      E-mail: jill.jonas@dnr.state.wi.us
Wyoming
Mr. John Wagner, Administrator
Water Quality
Dept. of Environmental Quality
Herschler Building
4th Floor West
Cheyenne, WY 82002
Phone: 307-777-7055
Fax: 307-777-5973
E-mail: jwagne@state.wy.us
*Wyoming's Drinking Water Program is managed by
EPA Region VIII
84

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                                                        3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Appendix E - 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 child care centers was a principal 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 III, 55 FR 1772).  See  Table E-2 for a list of water coolers and lead components.

Prior to publication of the January 1990 list, EPA determined that Halsey Taylor was the only manufacturer
of water coolers with lead-lined tanks.1 Table E-l 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.
   1 Based upon an analysis of 22 water coolers at a US 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.
                                                                                                     85

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      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 E-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.
              SPECIAL NOTE:
              Experience indicates that newly installed brass
              plumbing components containing 8 percent or less
              lead, as allowed by the SDWA, 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.
      Currently, a company formerly associated with Halsey Taylor, Scotsman Ice Systems, has assumed
      responsibility for replacement of lead-line coolers previously marketed by Halsey Taylor. See below for the
      address of Scotsman Ice Systems.

                                              Scotsman Ice Systems
                                          775 Corporate Woods Parkway
                                             Vernon Hills, IL 60061
                                    PH: (800) SCOTSMAN or 800-726-8762
                                              PH: (847)215-4500
                                                   Table E-l
                               Halsey Taylor Water Coolers With Lead-Lined Tanks2

               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
               WT2lASerialNo.
               64309550
WM14A Serial No.
843006
WT21A Serial No.
64309542
WT11A Serial No. 222650

LL14A Serial No. 64346908
          2Based upon an analysis of 22 water coolers at a US 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.
86

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                                                          3Ts for Reducing Lead m Drinking Water in Schools Revised Technical Guidance
                                              Table E-2
                             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, 50-50 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 50-50
 tin-lead solder joint each.
 CP3      DP15W

 DP16M   DP5S
                      DPM8
13P

DP7S

CP5

DP13A-50

CP3M

DP14A-50/6Q
DPM8H   DP15M     DP3R      DP8A

DP13SM   DP7M      DP7MH    DP7WMD

CP5M     DP15MW   DP3R      DP14S

EP10F     DP5M      DPI OF     CP3H

EP5F      13PL       DP8AH     DP13S
	   	       C10E

WTC10   DP13M-60   DP14M

DP20-50   DP7SM      DP IPX

CP3-50    DP13M      DP3RH

CP10     DP20       DP12N     	      	


Halsey Taylor


1. Lead solder was used in these models of water coolers manufactured between 1978 and the last week of 1987:

WMA-1                SCWT/SCWT-A          SWA-1                 DC/DHC-1

S3/5/10D              BFC-4F/7F/4FS/7FS        S300/300/100D
 2. 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     HC14F    HC8W     HC2F       HC14WT
                                                            H
 HC14FL   HC14W     HC2FH    HC14WTH   HC8FL
 HC4FH   HC10F      HC16WT   HCBF7HO    HC8F
                                                          HC4F     HC5F      HC14WL   HCBF7D

                                                          HC8FH   HC4W     HWC7
If you have one of the Halsey Taylor water coolers noted in Table E-2, contact Scotsman Ice Systems (address and phone
noted above) to learn more about the requirements surrounding their replacement and rebate program.
                                                                                                         87

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    3Ts for Reducing Lead in Drinking Water in Schools, Revised Technical Guidance
    Appendix F - Sample Recordkeeping Form
Appendix F - Sample
Record of
Name of Building
Name of Sample Collector
Contact Person for this Record
Sample ID Number
Circle sample type: Initial / 1
Length of Flush (for flushed samples)
Type of Outlet (faucet, cooler etc.)
Mfg/Model
Serial #
Date of Installation
Location
Date of Collection
Time of Collection
Name of Laboratory Used
Lead, Concentration (ppb)
Recordkeeping Form
Sampling



st Follow-up / 2nd Follow-up




Illllll MINI






NOTES:

88

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                                                        3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
Appendix G  -
Preservation of Samples and  Sample  Containers
    This appendix contains information pertaining to the preservation of samples and sample containers. A certified
    drinking water laboratory should be aware of these requirements. In addition, they will provide you with actual
    samplers or sample containers and instructions. The sample containers may have been prepared prior to your receipt.
    The laboratory will also specify how to handle the sample containers and when to submit them after taking your
    samples.
In order to avoid analytical errors, pay particular attention to proper collection and handling of the sample
before analysis.  Sample containers (250 mL) should be obtained from a certified laboratory. You should not
use other containers such as used jars or water bottles.

Make sure the containers are kept sealed between the time of their preparation by the lab and the collection of
the sample. This will assure that no contaminants from the outside are introduced. Preserve the sample by
icing and promptly ship or deliver it to the laboratory.  Most laboratories will provide the necessary shipping
containers and cold packs. 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, but EPA recommends that the
laboratories receive the samples as soon as possible.

For more detailed information, refer to the following documents:

Methods for the Determination of Metals in Environmental Samples. EPA/600/4-94/111. May 1994
(available from the National Technical Information Service, Pub. No. PB95-125472 (703)  487-4650).

Manual for the  Certification of Laboratories Analyzing Drinking Water.  US EPA 815-B-97-001. March
1997 (available from the National Technical Information Service (703) 487-4650).

Standard Methods for the Examination of Water and Wastewater, 20th Edition. Co-published by the
American Public Health Association, the Water Environment Federation, and the American Water Works
Association.  1998 (available from the American Water Works Association, ISBN # 0-87553-235-7, Catalog
#10079).
                                                                                                    89

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      3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
      Appendix H -
      Example Scenarios for Water  Sample Results
                            Service Connection Sampling  (See Exhibit 4.3)
          Examples:
           •  Sample 1S (20 ppb) exceeds Sample 1M (5 ppb) =15 ppb of lead is contributed from the service connection; the
             lead amount in the main (Sample 1 M) does not exceed 5 ppb; therefore, you may want to check for a lead sevice
             line 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 1S is  10 ppb = very little lead is contributed from the service line; source of lead
             is most likely the water main.

           •  Sample 1S (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.
                Drinking Water  Fountain without Central Chiller  (See Exhibit 4.4)

          Example:

           •   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 (ensure compliance with the
          NSF standards for any fixtures you intend to purchase); retest water for lead after new materials installed.
90

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                                                           3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
   Drinking  Water Fountain with  Central Chiller (See Exhibits 4.4 and  4.9)

Example 1:

 •  Sample 1A (25 ppb) exceeds Sample 2A (3 ppb) = 22 ppb of lead is contributed from the bubbler.

 •  Sample 2A (3 ppb) is close to 5 ppb = very little lead 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 1A (38 ppb) exceeds Sample 2A (21 ppb) = 17 ppb of lead is contributed from the bubbler.

 •  Sample 2A (21 ppb) significantly exceeds 5 ppb = about 21 ppb of lead is being contributed from the plumbing
    upstream from the bubbler.

 •  Sample 2A (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).

Example 3:

 •  Sample 2A (21 ppb) exceeds Sample 2K (10 ppb) = 11 ppb of lead is contributed from the plumbing supplying
    the water from the chiller to the bubbler.

 •  Sample 2K (10 ppb) exceeds Sample 1K (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 1K (4 ppb) does not exceed 20 ppb = additional sampling from the distribution system supplying water
    to the chiller  is not necessary.

 •  Sample 1K (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 clean
sediment and debris from chiller unit. Retest water for lead once changes have been made. If the lead levels after
initial flushing are low, clean any sediment and debris from the chiller, and resample the chiller monthly for 3 months.
If the lead levels increase, the additional remediation measures listed immediately above are probably necessary to
reduce lead risks.  If the levels remain low, routine annual cleaning of sediment and debris and routine monitoring at
the same frequency as other sites is recommended  .

Example 4:

 •  Sample 2A (45 ppb) exceeds Sample 2K (28 ppb) = 17 ppb of lead is being contributed from the plumbing
    supplying water from the chiller to the bubbler.

 •  Sample 2K(28 ppb) exceeds Sample 1K(21 ppb) = 7 ppb of lead is contributed by the chiller.

 •  Sample 1K (21 ppb) exceeds 20 ppb = additional sampling from the distribution system supplying  water to the
    chiller is necessary to locate the source of the contamination (see Exhibit 4.9 on Sampling Interior Plumbing for
    instructions).

Possible Solution: Lead levels are clearly elevated at all sample sites.  It appears that multiple sources of lead are
contributing to the problem. Retesting may help locate sources of lead, but it appears that the solution  includes
replacement of upstream plumbing; the bubbler fixture, valves, and fittings with lead-free materials; and cleaning the
sediment and debris from the chiller. Retest water for lead after changes have been made.  If levels are still elevated,
replacement of the chiller may be necessary.
                                                                                                              91

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       3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance
                      Drinking Water Fountain (Water Coolers)  (See Exhibit 4.5)

           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 directly 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 Sections 5.2 and 5.3 of this
           guidance document for further information).

           Example 2:

            •  Samples 1C (44 ppb), 3C (42 ppb) and 2C (41 ppb) are approximately equal = the cooler is not the likely source
              of lead.

            •  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 is contributing lead to the water.

            •  Samples 1C (44 ppb), 3C (42 ppb) and 2C (41 ppb) are approximately equal = the 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 plumbing upstream from the cooler.

           Possible Solutions: Replace the plumbing upstream between the header and cooler with lead-free materials and retest
           the water. If the water continues to test high, the header, service connection and/or public water supply may be the
           problem. An evaluation should be made as soon as possible to determine the source of the lead, and other outlets
           should be tested immediately if not already done. Remember that flushing  is not recommended as a practical remedy
           for water coolers.
                                 Bottled Water Dispensers (See Exhibit 4.6)

           Example 1:

            •   Sample 1D (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 1D (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.
92

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                                                           3Ts for Reducing Lead m Drinking Water in Schools Revised Technical Guidance
                          Ice Making Machines (See  Exhibit 4.7)

Example 1:

 •  Sample 1E 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 1E = 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 4.9 for instructions).
                              Faucets (Taps) (See Exhibit 4.8)

Example 1:

 •  Sample 1F (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 (ensure compliance with the NSF standards for any fixtures
you intend to purchase); 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 1F (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 4.9).

Possible Solutions: Replace faucet with lead-free device (ensure compliance with the NSF standards for any fixtures
you intend to purchase); 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.
                                                                                                              93

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       3Ts for Reducing Lead m Drinking Water in Schools Revised Technical Guidance
                                      Interior  Plumbing (See Exhibit 4.9)
           Example 1:
            •   Sample 1G (22 ppb) exceeds 20 ppb = collect additional samples from the plumbing 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).

            •   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.

           Example 2:

            •   Sample 1H or 1J (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 1Hor 1J (23 ppb) significantly exceeds 5 ppb and Sample 1Hor 1J 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.

           Example 3:

            •   Downstream Site is 25 ppb. Service Connection Sample is 4 ppb, and Sample 1J (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.

            •   U (6 ppb) is close to 5 ppb = the portion of the riser pipe and plumbing upstream from Sample Site 1J and the
               service connection are not contributing lead to the water; the source of 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.
94

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                                                                    3Ts for Reducing Lead in Drinking Water in Schools Revised Technical Guidance
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Bubblers
Ice Makers
1 Kitchen Taps
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^ote the locations.

                                                                            97

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          3Ts for Reducing Lead in Drinking Water in Schools  Revised Technical Guidance
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