*-/!•* ••  I*'- i

   v,          United States        Office of Water    EPA
   . ,          Environmental Protection    (4606)          October 2005
   |           Agency
                   **DRAFT 10-06-05**
              Getting the Lead Out -
   |           A Guide to Reducing Lead in
   !'           Drinking Water in Schools
               Revised Guidance for Schools
   /y>
                "Working draft for public review**
                 '
                    n

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                                     Contents
1.  Introduction	5
       1.1    Who Should Use This Manual	5
       1.2    Purpose of the Manual	'	5
       1.3    Approach 	5
       1.4    Health Effects of Lead	6
       1.5    Sources of Lead	6
       1.6    How Lead Gets into Drinking Water	7
       1.7    How Lead in Drinking Water is Regulated	12

2.  Planning Your Program and Establishing Partnerships  	14
       2.1    Assigning Roles	14
       2.2    School Records  	14
       2.3    Establishing Partnerships	15
             2.3.1  Assistance from Your Water Utility  	15
             2.3.2  Assistance from Your State Drinking Water Program  	16
             2.3.3  Assistance from Your Local Health Office	17
             2.3.4  Assistance from Certified Laboratories	17
             2.3.5  Assistance from Local Community Organizations 	17

3.  Assessment and Strategy: Plumbing Profile and Sampling Plan	19
       3.1    Development of a Plumbing Profile for Your Water Distribution System	19
       3.2    Who Should Create the Sampling Plan? - Leadership in Sampling	27
       3.3    Where Should 1 Sample? - Determining Sample Locations 	27
       3.4    Who Should Collect the Samples and Where Do Samples Go for Analysis? -
             Collection and Analysis of Samples 	28

4.  Conducting Sampling	32
       4.1    General Sampling Procedures  	32
       4.2    Collection Procedures 	32
       4.3    Laboratory Analysis and Handling of Sample Containers	33
       4.4    Overview of the Two-Step Sampling Process	33
             4.4.1  Step 1: Initial Sampling	34
             4.4.2  Step 2: Follow-Up Sampling	34
             4.4.3  Initial and Follow-Up Sampling Protocol  	35
             4.4.4  Sampling for Other Parameters 	39

5.  Remedies	61
       5.1    Routine Control Measures	61
       5.2    Interim (Short-Term) Control Measures 	61

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          Getting the Lead Out - A Guide to Reducing Lead in Drinking Water i
  6.  Informing the Public about Lead  	73
        6.1    Techniques for Disseminating Public  	73
        6.2    The Components of an Effective General Communication Strategy	74
        6.3    Participants	75
        6.4    Timing	75
        6.5    Content	76
        6.6    Methods and Manner of Communication 	76
        6.7    Sample Public Notice Materials	77

 Appendix A - Glossary of Terms 	82

 Appendix B - Publication List	!	84

 Appendix C - List of State Drinking Water Programs  	86

 Appendix D - Water Cooler Summary	94

 Appendix E - Sample Recordkeeping Form	98

 Appendix F - Preservation of Samples and Sample Containers	99

Appendix G - Example Scenarios for Water Sample Results ....:	100

Appendix H - Plumbing Profile Questionnaire	107

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                                     Exhibits
Exhibit 1.
Exhibitl.
Exhibits.
Exhibit 3.
Exhibit 3.
Exhibit 4.
Exhibit 4,
Exhibit 4.
Exhibit 4.
Exhibit 4.
Exhibit 4.
Exhibit 4,
Exhibit 4.
Exhibit 4,
Exhibit 4.
Exhibit 4.
Exhibits.
Exhibit 5.
Exhibit 5.
Exhibit 5,
Exhibits
Exhibit 5.
Exhibit 6
Exhibit 6
Exhibit 6
1: Potential Sources of Lead in Schools	10
2: Common Drinking Water Outlets	11
1: Sample Plumbing Profile Questionnaire and Answer  	20
2: Plumbing Configuration for a Single-Level Building  	30
3: Plumbing Configuration for a Multi-Level Building 	31
1: Pipe Volumes for Copper Pipe	37
2: Sample Strategy Flowchart	-	38
3: Service Connection Sampling	40
4: Drinking Water Fountains: Bubblers 	42
5: Drinking Water Fountains: Water Coolers  	44
6: Drinking Water Fountains: Bottled Water Dispensers  	48
7: Ice Making Machines	'	50
8: Water Faucets (Taps) 	52
9: Sampling Interior Plumbing	54
10: Sample Sites for a Single-Level Building	59
11: Sample Sites for a Multi-Level Building 	60
1: Flushing Directions by Outlet Type	62
2a: Remediation Flow Chart (part 1)  	66
2b: Remediation Flow Chart (part 2)  	67
2c: Remediation Flow Chart (part 3)	68
3: Case Study 1  	'.	69
4: Case Study 2   	72
1: Sample Public Notice Letter	78
   Sample Press Release for Local Media	79
   Sample Newsletter Article 	80

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                                   1.  Introduction
        The Environmental Protection Agency (EPA) is responsible for implementing the Safe
 Drinking Water Act (SDWA), which is the federal law intended to safeguard the nation's
 drinking water.  EPA is concerned about the potential for elevated lead levels in tap water
 provided for drinking in schools and child care facilities. Children are vulnerable to health risks
 associated with elevated lead levels in drinking water. The adverse health effects from lead
 include impaired mental development, IQ deficits, shorter attention spans, and lower birth
 weight. Exposure to lead is particularly a significant health concern in young children and
 infants because their bodies tend to absorb more lead than the average adult.

        In general, lead gets into drinking water by leaching from plumbing materials and
 fixtures as water moves through your school's distribution system. Because lead concentrations
 can change as water moves through the distribution system, the best way to know if a school or
 child care facility might have high levels of lead in its drinking water is by testing the water in
 that school or child care facility. Testing facilitates an evaluation of the plumbing and helps
 target remediation. It is a key first step in understanding the problem, if there is one, and
 designing an appropriate response.

        There is no federal law requiring sampling of drinking water in schools, except for
 schools that have their own water supply. The vast majority of public water systems do not
 include schools in their sampling plans, because the EPA rule governing lead in drinking water
 focused on the sampling of single family dwellings.  States and local jurisdictions may, however,
 establish programs for testing drinking water lead levels in schools.

       In December of 2004, the EPA held a national meeting to discuss the potential of lead
exposure in school and child care facilities. At the meeting, Assistant Administrator, Benjamin
H. Grumbles introduced the "3TV of minimizing lead exposure in school drinking water. The
3T's are:

       •  Training school officials to raise awareness of the potential occurrences, causes, and
          health effects of lead in drinking water, and to promote better monitoring of drinking
          water for lead.

       •  Testing of drinking water in schools to identify potential problems.

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

The 3T's, along with remediation, will help guide your school to provide safe drinking water to
its students and staff.

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

1.1    Who Should Use This Manual

       This manual is intended for use by officials responsible for the maintenance and/or safety
of school facilities, including the drinking water. The manual is specifically targeted at schools
that receive water from water utilities or water companies such as cities, towns, and water
districts.

1.2    Purpose of the Manual

       The purpose of this manual is to help schools minimize their students' and staffs
exposure to lead in drinking water. It 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 school drinking water systems; 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.

1.3    Approach

       EPA recommends that key staff, as well as school board members and administrators take
the following specific steps to reduce lead in the drinking water in schools:

(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.

(5)  Test the water. See Chapter 4.

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

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

(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.

1.4    Health Effects of Lead
       Lead is a toxic metal that can be harmful to human
health when ingested or inhaled. Even small doses of lead can
be harmful. Unlike most other contaminants, lead is stored in
our bones, and can be released later into the bloodstream.
Thus, even small doses can accumulate and become
significant. The groups most vulnerable to lead include
fetuses and young children.

       Exposure to lead is a significant health concern for
young children and infants whose growing bodies tend to
absorb more lead than the average adult.  Childhood lead
exposure can impair the development of the brain and central nervous system. Children under the
age of six are at the highest risk because of their rate of growth.  Even at low levels of lead
exposure, children may experience lower IQ levels, impaired hearing, reduced attention span, and
poor classroom performance.  At higher levels, lead can cause even more serious brain damage.
Testing drinking water in schools  and child care facilities is important because
children spend a significant portion of their day in these facilities and are likely to
consume water while they are there.

       Other groups that are vulnerable to lead are people who are immuno-compromised, as
well as pregnant women and fetuses. Accumulated lead stored in mothers' blood may damage a
child before it is born, causing a lower  birth weight and slowing down normal physical and
mental development.

       The degree of harm from lead exposure depends on a number of factors including the
frequency, duration, and dose of the exposures(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 or formula.
1.5    Sources of Lead

       Lead is distributed in the environment through both natural and human-made means.
Today, the greatest contributions of lead to the environment stem from past human activities.
Sources that produce excess lead exposure include the following:

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools  '

       •  Lead based paint (which can flake off onto soil, window sills, or floors and be
          ingested by children).

       *  Lead in the air (from industrial emissions).

       •  Dust and soil (lead deposits in soils around roadways and streets from past emissions
          by automobiles using leaded gas, together with paint chips and lead paint dust, find
          their way into the mouths of young children living in these environments).

       ป  Lead dust (brought home by industrial workers on their clothes and shoes).

       •  Lead in water (through corrosion of plumbing products containing lead).

       The U.S. government has taken steps over the past several decades to dramatically reduce
new sources of lead in the environment - by banning the manufacture and sale of leaded paint, by
phasing out lead additives in gasoline, 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 old lead paint covering millions of homes across the
United States, more stringent air control standards are being applied to industries emitting lead,
and more stringent regulations are in place to control lead in drinking water. Regulations
affecting lead in drinking water are described at the end of this chapter.

1.6    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.

 m 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 mineral 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

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 	  Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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, 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 remains in contact with lead in plumbing.  This
increase occurs up to a certain time limit, which can vary from facility to facility. As a result,
facilities with intermittent water use patterns, such as schools, may have elevated lead
concentrations. That is why testing water from your drinking water outlets for lead is so
important. Drinking water outlets are locations where water may be accessed 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 systems.

       The public water supplier is responsible for producing water that is not corrosive if
unacceptable levels of lead are found (see "How Lead in Drinking Water is Regulated" in section
1.7). However, centralized treatment by a utility does not guarantee that corrosion of lead from
plumbing will not occur within buildings served by the utility, i.e.,  your school.

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

       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. Pictures of some of the common
drinking water outlets are reflected 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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    Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                Exhibit 1.2:  Common Drinking Water Outlets

                  I
            Valve
Lateral
 Pipe
    Solder
    Joints

Connecting
   Pipe
         Solder
         Joint
                         •Wall
                      Valve
                        Cooling Element2

           Water Cooler
                                              Lateral
                                              Pipe
                                                      Wall
                                                                      Bubbler
                                                                      Valve
                                                          Bubbler
                                     Wall
                             Connectiri!
                                Pipe

                                Solder
                                Joint "^
                                Valve
                                \/
                               Solder
                                Joint
                                              Valve
                                                      Cold
                                                      Water
                                                     'Faucet
                                                           Screen
                                      Cold Water
                                     Faucet (Tap)
   Valve 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 D of this document.
                                        11

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

1.7    How Lead in Drinking Water is Regulated
       Lead is regulated in non-bottled drinking water 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 water utility are
generally not subject to the SDWA monitoring and treatment
requirements, because they are subject to an exclusion in the law.
However, some states may have monitoring and treatment
requirements for these schools.  Questions in this regard may be
directed to the appropriate state drinking water program office or the State Department of
Education or Public Instruction (see Appendix C 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 water utility.
                                         12

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                             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 connected to a public water system.  Solders and flux are considered to be lead-free when they
        contain less than 0.2 percent lead. Before this ban took effect 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: are banned
        from sale after August 6,1998.

        The 1988 Lead Contamination Control Act fLCCA).  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 D for a listing
        of these fixtures). These provision 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 (LCRY The LCR requires public water systems 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 public 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.
"EPA strongly recommends that all water outlets in all schools that provide water for drinking
          or cooking meet a lead standard of 20parts per billion (ppb) lead or less."
                            PUBLIC WATER SUPPLY TESTING vs. TESTING AT SCHOOLS

      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 1 5 parts
      per billion (ppb) is established for 1 liter samples taken by public water  systems at high-risk residences. Tlre-}5
      ppb ic?d--iy^otvi-trtaodatot)"ixCT;t-"tfoy.'Ojer\i iff more than 1 0 percent of the samples at residences exceeds 1 5
      ppb, system- wide corrosion control treatment may be necessary. The 1 5 ppb action level for public water
      systems is therefore a trigger for treatment rather than simply a health-based level.
                         ,radyth^
       ad bi.ikiJ.yu ufZO tjpb u. kvs. TUt; 20 ypl, iwet-e^afrjsired'-nyr^ytoo^^
        il]AC,-l.ifc COllOTKTrfjSiXilTrtTTtijSTMV'SCTT^I'i^iCifjTST^TITLTvTtitiA Wtiukl.! i%7.i xttwjTCTj^2ri^/T""Cx?wsTrtj;"RfCRtiT" AvisOO! ieiC*tj*v
      EPA rocoiimwnils that schools collect 250 siil first-draw samples from water fountains aaJ outlets Mid tlu:t the
      water fountains and/or outlets be taken out of ietvlce if she lead level exceeded 20 ppb. The sarnpie was
      designed so psnpoim specific fountain:; smd o-iUets that require*! reniediatior; (e.g. wa'.er cooker replacement). The
      school sampling protocol maximizes the likelihood -hat the highest concentrations of lead are found because the
      first 250inL are analyzed (or iead after over-light stagnation.
                                                   13

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

         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
water utility, 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.

       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 D 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
                                           14

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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 water utility were involved, which may mean that additional
records are available.

2.3   Establishing Partnerships

      2.3.1  Assistance from Your Water Utility

      Some water utilities 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 systems are 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 water utility tested
for lead  on its own, or had testing voluntarily conducted by the utility, neither the school nor the
utility is likely to have any  record of testing.  Although the utility 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 utility to determine whether information on previous
efforts or assistance is available. Although utilities are under no obligation to do so, assistance
may be available through technical guidance, sampling, or sharing of sampling costs. Some
utilities may be willing to help develop plumbing profiles and sampling plans (see Chapter 3).
The American Water Works Association (AWWA), a non-profit organization of water system
professionals, recently prepared a summary of information for utilities to assist them in Iheir
efforts 10 hd p schools.

      You should obtain from your utility the results of its required monitoring under the Lead
and Copper Rule to determine whether your utility is in compliance with the requirements of the
Lead and Copper Rule.  Your 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 utility 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.
                                           15

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                           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 utility about your water:

     Is the water system in compliance with Federal and State standards for lead monitoring and treatment?
     Does the utility have sample results from the school or from nearby locations?
     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 goosenecks at service
     connections) and does the system plan to remove these sources of lead?
     Would the utility provide assistance in your effort?
       2.3.2  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 water utility 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. A listing of state program
contacts is contained in Appendix C. Most state programs also have Web sites with contact
information. 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 water utility, 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 utilities 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 as to whether they have
knowledge of other state programs that are involved in reducing lead risks for children. There
may be an interest in a developing a cooperative effort between state programs or between state
and local  agencies.
                                              16

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

       2.3.3  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.

       You should be able to find a phone number for your local health office 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.
                                                                    | LABORATORY)
       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 mat 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.

       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 systems for compliance with the Lead and Copper Rule.

       2.3.5 Assistance from Local Community Organizations

       In your community there may be 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. Another useful resource is your region's Pediatric
Environmental Health Speciality Unit (PEHSU).  Your region's PESHU  may be able to provide
                                           17

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

risk communication and 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.
                                           18

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

   3.  Assessment and Strategy: Plumbing Profile and Sampling Plan

       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.

3.1    Development of a Plumbing Profile for Your Water Distribution System
       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. Conducting this survey of your facility's
plumbing will enable you to:

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

       •  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 sink, classroom sinks in special education
          classrooms, and any sink known to be or visibly used for consumption (e.g. coffee
          maker or cups are nearby).

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

       Exhibit 3.1 provides a plumbing profile questionnaire and provides a 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 H.
                                          19

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      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 mav be found among individual outlets in a facility because of differences in flow
rates and/or building materials.

      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 1
         year 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.

      •  Water coolers or other outlets have components that are not lead-free, especially if the
         water is corrosive.

      In general, you can expect localized presence of lead if:

      •  Some brass fittings, faucets, and valves have been installed in the last year (even though
         they may meet the SDWA lead content requirements).

      •  Drinking water outlets are in line with brass flush valves, such as drinking water
         fountains near rest room 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).

                                            26

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	


      •  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.

      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?

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 should 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. Generally, testing
should be conducted at those outlets that are most likely to have contamination since they would
represent the greatest hazards to human health.  However, every outlet used for drinking or
cooking should be sampled if possible. Priority 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.
                                           27

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      •   Areas containing brass fittings and fixtures.

      •   Water coolers identified by EPA (See Appendix D) as having lead-lined storage tanks
         or lead parts 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).

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.
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 C) or EPA's Safe Drinking Water Hotline (Appendix B) 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 protocols are different.
                                           28

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Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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 E contains a sample recordkeepingform
and identifies the type of information you should consider recording.

You should have a written agreement or contract with the laboratory for all of the
services to be provided.
                                   29

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                            4. Conducting Sampling
4.1   Recommended General Sampling Procedures

      This section outlines the general procedures EPA recommends
for 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 should modify them as appropriate.
See additional discussion in 4.4.3.

4.2   Collection Procedures
         All water samples collected should be 250 milliliters (mL) in volume.  School samples
         are smaller than the one-41iter 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 in a building.

         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.

         Make sure that no water is withdrawn from the taps or fountains from which the
         samples are to be collected prior to their sampling.

         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.

         Assign a unique sample identification number to each sample collected - use your
         sampling plan schematic with a numbering system. Record the identification number
         on the sample bottle and on your recordkeeping form (see Appendix E). 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
                                          32

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

         •    location of the sample site
         •    name of the manufacturer that produced the outlet, and the outlet's model number,
              if known.
         Consult the sample form in Appendix Efor additional recordkeeping items.

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, you should follow the instructions provided by the laboratory for
handling sample containers to ensure accurate results (also see Appendix F- 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), or
     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
          is essentially the same as parts per billion (ppb).

           Examples: 1 mg/L = 1000 pg/L = 1 ppm =1000 ppb; 0.020 mg/L = 20 pg/L = 20 ppb
4     Overview of the Two-Step Sampling Process

      EPA recommends that a two-step sampling process be followed for identifying lead
contamination. In Step  1, initial samples are collected to identify the location of outlets providing
water with high 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.
                                            33

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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.1

      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 drinking
water 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.

      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 H that is also discussed previously 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 4.2).  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.

      4.4.2   Step 2: Follow-Up Sampling

      If initial test results reveal lead concentrations greater than 20 ppb 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 that revealed lead
concentrations greater than 20 ppb in the initial test results. The purpose of Step 2 is to pinpoint
where (e.g., fixtures or interior plumbing) lead is getting into drinking water so that appropriate
        'Under the National Primary Drinking Water Regulations for public water supplies, a lead action level of
 15 ppb is established for 1-liter samples taken by public water suppliers in high-risk residences. If more than 10
 percent of the samples at residences exceed 15 ppb, system-wide corrosion control treatment may be necessary. It is
 important to note that the testing protocol used by public water suppliers is aimed at identifying system-wide
 problems rather than problems at outlets in individual buildings.  Moreover, the protocols for sample size and water
 retention time are different.
                                             34

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

corrective measures can be taken. EPA has established the 20 ppb trigger for follow-up testing to
ensure that the sources of lead contamination in drinking water outlets are identified.

      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. A comparison of initial and follow-up
samples will help to assess where the lead may be getting into the drinking water.  See Exhibits
4.2 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.

      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 types 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.

         ป .  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.2

      •  Ice making machines
        2 The Food and Dmg 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.

                                            35

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      *   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 own unique
numbers to every sample you collect.

      Following the instructions for the above water outlet locations are instructions for
conducting sampling of Ihe 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

      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.
below.
      Pipe volumes per foot of pipe length for various pipe sizes are shown in the Exhibit 4.1
                                          36

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Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
           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
21/2 '
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
                               37

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   Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                     Exhibit 4.2:  Sample Strategy Flowchart
        Collect and analyze
        initial samples from
        outlets (morning first
        draw) and from the
        service connection
            Is the lead
            in the screening
          sample below
             20 ppb?
•4  Outlet O.K. to use.  I
        Collect and analyze
         follow-up samples
        (interior plumbing).
             Is lead
         level in follow-up
        samples reduced to
            low 20 ppb
            lead levels i
      nterior plumbing follow-up
    samples close or equal to lead
     evels observed in screen!
            sample?
    Are lead levels
  In interior plumbing
 llow-up samples close or
    equal to 5 ppb?
jYes
The interior plumbing
is a source of lead.




The intend
sources
No
r plumbing
tlet are
of lead.

                                                                                       Select remedy.
             Are lead
          levels in service
 connection sample(s) close or equal to
lead levels observed in interior plumbing
            follow-up
            samples?
       Are lead
       Is in service
  connection samples
   close or equal to
       5 ppb?
The interior plumbing
 is a source of lead
                                          The interior plumbing
                                           and service line are
                                               38

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      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. Some of these are listed in the following
table:
  Contaminant
 Cadmium
 Color
 Copper
 Iron
 Turbidity
 Zinc
  Limit
  5ppb
 15 color
  units
1300 ppb
 300 ppb
1 turbidity
   unit
5000 ppb
                         Concern
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.
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.
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.
An aesthetic parameter that is indicative of corrosive
conditions at higher levels. See also color and turbidity.
(Galvanized pipe is typically made of iron.)
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.
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.
                                           39

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                      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:
      •   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 utility'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.
                                           40

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      •   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 1S. 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.

      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.  Usually, no significant amount of lead (above 5 ppb) comes from the
         public water system.

      •   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 j oints used in the installation or
         repair of cast iron pipes.

      •   If the lead level of Samples 1S and 1M are very low (close to 5 ppb), very little lead is
         being picked up from the service line or the distribution main.

      For example scenarios of different water sample results, please see Appendix G.
                                           41

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                   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
                                                                         /
                                                                          Bubbler
                                                                          Valve
                                                                    V
                                                                     Vatve

                                                                     ' Connecting
                                                                        Pipe
                                                                   1)
                                                   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.
Interpreting Test Results:
                                            42

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
To determine the source of lead in the water3 compare the test results of Samples 1A and 2 A.
     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 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 2 A 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 G.
Fountains Connected to
   a Central Chiller
                                          43

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                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 Dfor 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 D.
                   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 18 hours. This is acceptable if this
      is representative of the normal water
Lateral
 Pip*
        Connecting
          Pipe
2C
                        VVal1
                             -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.
                                             44

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   Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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 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 D.

Follow-Up Sample 2C

This water sample is representative of the water that is in contact
with the header or riser 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.
Floor-Mounted
    Cooler
                                     45

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      Interpreting Test Results:

      If the lead level in Sample 3C is higher than that in Sample 2C, the water cooler may be
      contributing lead to the water.

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

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

*     If the lead level in Sample 1C is higher than that in Sample 3C AND if the lead levels in
      Sample 2C and 3C are similar, the plumbing upstream from the cooler or the plumbing
      connection leading to the cooler, or both, is contributing lead to the water.

•     If the lead level in Sample 2C is in excess of 20 ppb and is equal to or greater than the lead
      levels in Samples  1C and 3C, the source of the lead may be sediments contained in the
      cooler storage tank, screens, or the plumbing upstream from the cooler.

To verify the source of lead, take the following steps:

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

      (2) If the flushed samples from the upstream outlets have lead levels in excess of 5 ppb,
        then the cooler and the upstream plumbing may both contribute lead to water.

•     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.
                                          46

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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

•     If the lead level in Sample 4C is significantly higher than 5 ppb, the source of lead is the
      plumbing upstream from the cooler or from debris in the cooler or screen.

•     If the lead level in Sample 4C is significantly higher than 5 ppb, but less than Sample 1C,
      the source of lead is the plumbing upstream from the cooler and/or  from debris in the cooler
      or screen.

For example scenarios of water sample results and possible  solutions, see Appendix G.
                                          47

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

         Exhibit 4.6: Drinking Water Fountains:  Bottled Water Dispensers
Note: 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.

Sample Collection Procedures:
      Initial Screening Sample ID

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

      Take this sample before the facility opens and before any
      water is used.  Collect the water immediately after opening
      the faucet without allowing any water to waste. Take follow-
      up samples from those bottled water dispensers where test -
      results indicate lead levels over 20 ppb.

      Follow-Up Sample 2D
      Collect this sample directly from the bottle that
      supplies the water to the unit.  This will enable
      you to determine the source of lead in the water.
Bottled Water
  Dispenser
Interpreting Test Results:

      If the sample contains lead, contact the water
      supplier and/or the manufacturer of the dispenser
      to ask 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.
   1D
      ^y>:
                                           48

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      •  Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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 G.
                                          49

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                          Exhibit 4.7: Ice Making Machines


Sample Collection Procedures:

•     Initial Screening Sample IE
                                                                      Ice Making Machine
                                                  Connecting
                                                   Plumbing
                                            Lateral
                                                                        Device Outlet
                                                Targeted Locations of Water in Plumbing
                                                         for Samples 1E&2E
      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 lead in the sediment

      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 9. 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.
                                           50

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   Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
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 G.
                                     51

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                          Exhibit 4.8:  Water Faucets (Taps)
Sample Collection Procedures:

•     Initial Screening Sample IF

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

      Take this sample before the facility opens
      and before any water is used. If the tap
      has an aerator, 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:
           Wall
ill
Connecting
  Pipe

  Solder
  Joint N
       Valve
Lateral
 Pipe
                  Valve
                   IT/
            Cold
            Water
            Faucet
                              1F

                              Screen
      Solder
       Joint
                \

           Cold Water
          Faucet (Tap)

Targeted Locations of Water in Plumbing
         for Samples 1F &2F.
      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
                                           52

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   Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
For example scenarios of water sample results and possible solutions, see Appendix G.
                                     53

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
        	  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 IGfor 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.)

                                           54

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

Interpreting Test Results:

*     If the lead level in Sample 1G exceeds 20 ppb, collect additional samples from the
      plumbing upstream where samples have not been previously taken (i.e., from header
      supplying water to the lateral, the riser pipe, or the service connection).

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

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

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

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

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.
Interpreting Test Results:
                                          55

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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

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

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

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

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

Riser Pipes

A riser is the vertical pipe that carries water from one floor to another.

Sample Collection Procedures:

*    Sample U

     Open the tap closest to the riser pipe. Let the water run for 30 seconds before collecting the
     sample. Fill the sample container with 250 mL of water.  The purpose of flushing is  to
     clear the faucet and plumbing between the sample site and the riser pipe.

Interpreting Test Results:

•    If the lead level in Sample 1J exceeds 20 ppb, collect additional samples from the plumbing
     upstream from the riser.  High lead levels in the riser pipes may also be caused by  recent
     repairs and additions using lead solder.

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

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
•     If the lead level in Sample U is close or equal to 5 ppb, the portion of the riser pipe and
      plumbing upstream from Sample Site 1J and the service connection are not contributing
      lead to the water. The source of the lead is downstream of the sample site.

*     If the lead level in Sample 1J significantly exceeds 5 ppb (for example, 10 ppb) and is less
      than the lead level in a sample taken downstream from Sample Site 1 J, a portion of the lead
      is contributed downstream from the sample site.
      For example scenarios of water sample results and possible solutions, see Appendix G.

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,
      Section 9.  If a sample tap or valve is available, collect
      the sample immediately after opening the tap or valve, without allowing any water to waste.
             Central Chiller Unit
      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.
           Lateral
                Connecting
                  Pipe
1K

                            Bubbler with
                            centra I chiller
 Targeted Locations of Water in Plumbing
        for Samples 1K&2K
      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
                                           57

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      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 9. If a sample tap or valve is
      available, collect the sample immediately after opening the tap or valve.

Interpreting Test Results - Central Chiller Unit:

•     If the lead level in Sample 2B is higher than that in Sample 4B, lead is contributed from the
      plumbing supplying the water from the chiller to the bubbler.

*     If the lead level in Sample 4B is higher than in Sample 3B, a portion of the lead may be
      coming from the chiller.  Note:  Sludge and sediments containing high levels of lead may
      accumulate in chiller tanks.  If the test results indicate that lead is contributed from the
      chiller unit, check for the presence of debris and sludge. Remove any of these materials
      from the chiller, flush the chiller unit, and resample the water.

*     If the lead level in Sample 3B exceeds 20 ppb, EPA recommends additional sampling from
      the distribution system supplying water to the chiller to locate the source of contamination.

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

      For example scenarios of water sample results and possible solutions, see Appendix G.
                                           58

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                                    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.

      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 avoid possible
exposures to lead:

      •   Clean debris from all accessible screens frequently. If you discover 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.

      ซ   Run the water before drinking, so you 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.

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 all
             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.
                   Exhibit 5.1:  Flushing Directions by Outlet Type

                                          61

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       Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
        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-minute 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 IS minutes. Because of the long time 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:

             ป•       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).

             ป•       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 disadvantage to flushing is the amount of time and staff needed to perform
             the task.
                                               62

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

       (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.
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.
       (3)    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.  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 $280) or expensive (ranging from $250 to $500, and up to
             $2,100 for a computerized reverse osmosis treatment unit), their effectiveness
             varies, and they 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.  Before purchasing any device, ask
             the manufacturer for proof of NSF approval or check by visiting the NSF Web site
             at http://www.nsf. org/business/search_listings/index/asp.

       (4)    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
                                           63

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  Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

       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.

(5)    If the sources of lead contamination are localized and limited to a few outlets,
       replacing these outlets 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 in a building used to measure
       or control the flow of water 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. These 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.

(6)    Lead pipes within the system and those portions of the lead service connections
       under the water supplier's jurisdiction can be replaced. Contact your public water
       supplier about this replacement  However, your facility may be responsible for
       replacing a portion of a lead service connection that is under its own administrative
       jurisdiction, rather than under the jurisdiction of the water supplier.

(7)    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.

(8)    Flushing individual problem outlets or all outlets may also represent a permanent,
       albeit ongoing, solution.  There are advantages and  disadvantages to flushing.

                                     64

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

             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.

       (9)    Time-operated solenoid valves can be installed and set to automatically flush the
             main pipes (headers) of the system.  It is important to note that solenoid valves  are
             not practical for flushing water coolers. These would need to be flushed manually
             by staff.  See the Interim Remedies section above for flushing instructions for
             water fountains.

       (10)   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 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.

       (11)   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
             i 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 Cfor a directory of State programs).

Three flow charts (Exhibits 5.2a through 5.2c) illustrating the remediation process are presented
below.
                                           65

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                              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 because of levy failures. 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 water utility, the county and state health
departments, and tbxicologists 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 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 utility 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.
                                           69

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in 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
district's 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-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 11 more schools will be replaced or rehabilitated so the
adopted water quality standards can be maintained.

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
                                           70

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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 had also  planned to replace plumbing in four schools, but the effort was
derailed by failed levy measures. 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.
                                            71

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                        Exhibit 5.4: Case Study 2 (Place Holder)

Place Bolder for Case Study 2: Philadelphia Schools
                                         72

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

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

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

      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.

      •   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
                                           73

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

         school employees.  Staffers would contain much the same information as that contained
         in a press release or letter/flier.

      •  Staff Newsletter: A notice contained in a staff newsletter is a further option for
         directly and effectively communicating information about the lead program to
         employees.

      •  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. Websites 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 safety.  As a result, you should not view communication and
outreach activities as stand-alone or final efforts, but rather as a part of an overall or general
communication strategy.
      The purpose of a general communication strategy is
to provide the means for addressing questions from
members of your facility's community and also to provide
ongoing, up-to-date information regarding your sampling
efforts.  Ideally, you should designate a single
spokesperson or special task force to interact with the
public since it is important that your message remain
consistent.
      The issues to be addressed as part of a communication strategy include:

      •   Participants

      •   Timing for delivery

      •   Content of the message

      •   Methods and manner of communication.

6.3   Participants

                                           74

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      Overall, there are six primary players or interests involved in the control of lead in drinking
water:

     (1) 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, parents,
      .   school boards, teachers, and other employees). Members of the local school community
         should be the primary targets of any general communication activities.

     (2) 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.

     (3) States and EPA Regions: State drinking water programs and EPA Regional offices are
         responsible for ensuring that public water systems 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.

     (4) Drinking Water Community:  Public water systems comprise the regulated drinking
         water community, and they are responsible for complying with all national and State
         drinking water standards for lead. This means that they must ensure that the water they
         deliver is non-corrosive, contains minimal amounts of lead, and will not result in
         significant lead-leaching from plumbing in individual homes and buildings.

     (5) 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.

     (6) 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.

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  mat 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.
                                          75

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      (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).

      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.
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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	

      (4) (For schools) encouraging classroom science activities that focus on drinking water
         quality. (Contact EPA's Safe Drinking Water Hotline - see Appendix B -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.
      (7) Be sure to have communication materials available in languages other than English or
         provide a contact name and number for non-English speakers to get information if your
         local community has a large portion of non-English speaking residents.

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.
                                           77

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                          Exhibit 6.1:  Sample Public Notice Letter
(Date)

Anytown School Department
Anytown, USA OQOOO-0000
Dear Members of the Anytown School Community:

The United States Environmental Protection Agency (EPA) has determined that Lead at certain levels in drinking water may be
a a health concern. Infants and young children are the most vulnerable to the effects of lead. Pregnant women are also
vulnerable to lead because it can lower birth weight and slow down normal physical and mental development of the baby. Lead
in young children, especially those under the age of six, can result in lower IQ levels, impaired hearing, reduced attention span,
and poor classroom performance. At high levels, lead can seriously damage the brain.

However, since lead usually enters water from certain plumbing in individual homes and businesses, EPA advises testing of
water in private buildings. EPA recommends that action be taken if lead levels exceed 20 parts per billion (ppb) at any tap
tested.

Following instructions given in an EPA guidance document designed for schools, we completed an evaluation of the plumbing
in each of the buildings within the Anytown School District. Through this effort, we identified and tested those drinking water
taps 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 tap that tested high for lead was a drinking water fountain at Kennedy High School. After follow-up testing was
conducted, it was determined that the faucet was the source of the lead contamination.  The faucet was replaced with a lead-free
faucet and retested. Follow-up test results revealed lead levels well below EPA's recommended level.

The second tap, located 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 sampling 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 viewing by the public, including students, teachers, other school
personnel, and parents and can be viewed between the hours of [	:_a.m, and _:	p.m] [and on our school website]. For more
information about drinking water quality in our schools, contact John Doe at the Anytown School Department, 555-2223. For
information about drinking water quality in your home or for questions about testing, contact your water supplier or state
drinking water agency.

Sincerely,

Fred Frank
Superintendent of Schools

NOTE:  If permanent remediation measures cannot be implemented immediately, you are encouraged to send this notice
without delay. In that case, you can describe the interim measures that are in place, and explain the reason, for the delay in
permanent remediation.
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     Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
              Exhibit 6.2: Sample Press Release for Local Media
Any town 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

      Any town, 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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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	
                       Exhibit 6.3:  Sample Newsletter Article


         Anvtown School District Conducts Sampling for Lead in Drinking Water

Why was Sampling Conducted?

Schools that receive water from a public water system, such as our district, are not required by
state or federal regulations to conduct sampling 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 Anvtown School District decided
that sampling 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 won't 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 mourns.

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
                                                            (Continued on next page)
                                           80

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	
(Continued from previous page)

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 Sampling

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.

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 sampling 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.
                                           81

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                        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: (I) 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 and Valves: Any of numerous mechanical devices by which the flow of water may be
started, stopped, or regulated by a movable part that opens, shuts, or partially obstructs one or
more ports of passageway.

Flux:  A substance applied during soldering to facilitate the flow of solder. Flux often contains
lead and can itself be a source of lead contamination in water. The lead-free requirements of the
1986 Safe Drinking Water  Act 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 1417(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 fitting and fixtures must meet
                                           82

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	
standards established under the lead leaching requirements of section 1417(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.

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 which 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 .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.

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.
                                           83

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	
                        Appendix B - Publication List

                              Web Site Publications*

(1)    *Actions You Can Take To Reduce Lead in Drinking Water. Web site publication, US
     EPA810-F-93-001. June 1993. http://www.epa.gov/safewater/leadAeadfactsheet.html

(2)   Commonly Asked Questions: Section 1417 of the Safe Drinking Water Act and the NSF
     Standard.  US EPA.  http://www. epa. gov/safewateT/standard/plurnbing.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-Sampttng (at Schools). Web site article.  US EPA.
     http://www.epa.gov/safewater/lead/safedecisiontree.htm

(5)   *Fact Sheet - Lead Reduction Plan - EPA Activities to Improve Implementation of the
     Lead and Copper Rule.  Web site publication.  US EPA810-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/pdis/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. USEPA812-B-94-002.  (April 1994 version of this document.)
     http://www.epa.gov/safewater/consumer/leadinschools.html

(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. NSF.
                                         84

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools	
     http://www.nsf.org/business/mechanical _plumbing/index.asp?program=MechanicalPIuSvs
     Com

(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, 9:00
                   am to 5:30 pm (EST), except Federal holidays.
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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
           Appendix C - 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. BOX997413
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

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
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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
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, DE 19901
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:
noltonjohnson@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. E-mail:
tarizumi@eha.health.state.hi.us
Room 300
Honolulu, HI 96814-4920
Phone: 808-586-4304
Fax: 808-586-4352
*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

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. Box19276
Springfield, IL 62794-9276
Phone: 217-785-8653
Fax:217-782-0075
E-mail: roger.selburg@epa.state.il.us
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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
Indiana
Mr. Patrick Carroll, Chief
Drinking Water Branch
Office of Water Quality
Dept. of Environmental Management
P.O. Box6015
Indianapolis, IN 46206-6015
Phone: 317-308-3281
Fax:317-308-3339
E-mail: pcarroll@idem.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. Martin, 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.martin@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

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

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
Michigan
Mr. James K. Cleland, P.E., Chief
Water Bureau
Michigan Dept. of Env. Quality
P. O. Box 30630
Lansing, Ml 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: 406-444-407.1
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

Nevada
Mr. Andrew Huray, Chief
Public Health Engineering Section
Nevada State Health Division
1179 Fairview Drive
Carson City, NV 89701
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
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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
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.hamil1@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:
femando_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. Box5520
Bismarck, ND 58506-5520
Phone: 701-328-5257
Fax: 701-328-5200
E-mail: lthelen@state.nd.us

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
                                        90

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
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

Oklahoma
Mr. Jon L. Craig, Director
Water Quality Division
Department of Environmental Quality
707 North Robinson
Suite 8100
P.O. Box1677
Oklahoma City, OK 73101-1677
Phone:405-702-8100
Fax:405-702-8101
E-mail: jon.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

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, PR 00917
Phone: 787-648-3903
Fax:787-758-6285
E-mail: orivera@salud.gov.pr

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, Rl 02908
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
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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
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, VI00820-5065
Phone: 340-773-0565
Fax: 340-773-9310

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. Box47828
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
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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
Wisconsin
Ms. Jill D. Jonas, Director
Bureau of Drinking Water and Groundwater
Wisconsin Department of Natural Resources
P.O. Box 7921
Madison, W! 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
                                        93

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         Getting the Lead Out • A Guide to Reducing Lead in Drinking Water in Schools
                     Appendix D - 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 D-2for 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 D-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..
        '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.

                                           94

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 	Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
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 D-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.

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
                                      Vemon Hills, IL 60061
                              PH: (800) SCOTSMAN or 800-726-8762
                                       PH: (847) 215-4500
SPECIAL NOTE:

       Experience indicates that newly installed brass
plumbing components containing 8 percent or less lead,
as allowed by the SD WA, 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.
                                            Table D-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

       The following models and serial numbers contain lead-lined tanks:
                      RWM13A
       WM14A Serial No. 843034     WM14A Serial No. 843006     WT11A Serial No. 222650

       WT21A Serial No. 64309550    WT21A Serial No. 64309542    LL14A Serial No. 64346908
         Based upon an analysis of 22 water coolers at alJS 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.
                                              95

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        Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                                             Table D-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     DPM8     7P           13P

DP16M    DP5S       C10E      PX-10        DP7S

WTC10    DP13M-60  DP14M    CP10-50      CP5

DP20-50   DP7SM     DP10X     DP13A       DP13A-50

CP3-50    DP13M     DP3RH    DP5F        CP3M

CP10      DP20       DP12N     DP7WM      DP14A-50/60
                                    DPM8H   DP15M    DP3R      DP8A

                                    DP13SM  DP7M     DP7MH    DP7WD

                                    CP5M    DP15MW  DP3R      DP14S

                                    EP10F    DP5M     DP10F     CP3H

                                    EP5F     13PL      DP8AH    DP13S
Halsey Taylor


•     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       S300/500/100D

•     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

HC14FL   HC14W

HC4FH    HC10F
HC6W     HWC7D     HC8WTH

HC2FH     HC14WTH   HC8FL

HC16WT   HCBF7HO   HC8F
HC14FH   HC8W

HC4F     HC5F

HC8FH    HC4W
HC2F      HC14WT

HC14WL   HCBF7D

HWC7
If you have one of the Halsey Taylor water coolers noted in Table D-2, contact Scotsman Ice Systems (address and
  phone noted above) to learn more about the requirements surrounding their replacement and rebate program.
                                             96

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Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
        Appendix E - Sample Recordkeeping Form
                        Record of Sampling
                 Name of Building
          Name of Sample Collector
      Contact Person for this Record
                  Sample ID Number
         Circle sample type:  Initial / 1st Follow-up / 2nd Follow-up
 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)
 NOTES:
                               97

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         Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
     Appendix F - 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).

Manualforthe 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, 20"1 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
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  Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
Appendix G - Example Scenarios for Water Sample Results
                 Service Connection Sampling (See Exhibit 4.3)
    Examples:
           Sample IS (20 ppb) exceeds Sample 1M (5 ppb) =15 ppb of lead is contributed
           from the service connection; the lead amount in the main (Sample 1M) does not
           exceed 5 ppb; therefore, you may want to check for a lead service connection or
           gooseneck depending upon results of lead testing at other outlets in the
           building; if you reduce lead at the connection, lead levels may be reduced
           throughout the remainder of the building.

           Sample 1M is 10 ppb and Sample IS is  10 ppb = very little lead is contributed
           from the service line; source of lead is most likely the water main.

           Sample IS (7 ppb) and Sample 1M (6 ppb) are close  to 5 ppb = very little lead
           (1 ppb) is being picked up in the water from the service line or the distribution
           main; very little lead is contributed from the source water; if other outlets show
           significantly higher lead levels, the source of the contamination is the interior
           plumbing and/or the outlets themselves.
      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
    (request results of lead leaching tests from distributors or manufacturers of any fixtures you
    intend to purchase); retest water for lead after new materials installed.
                                        99

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  Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

   Drinking Water Fountain with Central Chiller (See Exhibits 4.4 and 4.9)


Example 1:

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

•       Sample 2B (3 ppb) is close to 5 ppb = very little lead (2 ppb) is being picked up from the
        plumbing upstream from the bubbler; the majority or all of the lead is contributed from the
        bubbler.

Possible Solution:  Replace bubbler valve, fittings and/or fixture with lead-free materials (request
results of lead leaching studies from manufacturers  of brass products before purchasing to ensure
that harmful amounts of lead will not be leached); retest water once new materials installed.

Example 2:

•       Sample IB (38 ppb) exceeds Sample 2B (21 ppb) = 17 ppb of lead is contributed from the
        bubbler.

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

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

•       Sample IK (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 .
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       Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                  Drinking Water Fountain with Central Chiller (cont.)
     Example 4:

     ป        Sample 2B (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 IK (21 ppb) = 7 ppb of lead is contributed by the
             chiller.

     •        Sample IK (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.
Drinking Water Fountain with Self-Contained Chiller (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 far water
     coolers — see discussion of this issue in Sections 5.2 and 5.3 of this guidance document for further
                                               101

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     Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

   Drinking Water Fountain with Self-Contained Chiller (Water Coolers - cont.)
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 ID (23 ppb) exceeds Sample 2D (5 ppb) =18 ppb of lead is contributed from the
        dispenser unit.

Possible Solution:  Replace dispenser unit with one that is made of lead-free materials and retest

Example 2:

•       .Sample ID (24 ppb) and Sample 2D (23 ppb) are close = the source of lead is the bottled water.

Possible Solutions: Purchase another type of bottled water for which the distributor provides written
assurance that lead levels do not exceed Federal and State lead standards, or find other alternative lead-free
water source. Retest after any remedy has been employed.
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 Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools

                    Ice Making Machines (See Exhibit 4.7)


Example 1:

•       Sample IE is 22 ppb and Sample 2E (6 ppb) is close to 5 ppb = source of the lead (16
        ppb) is the ice maker.

Possible Solutions:  Replace plumbing components in ice maker with lead-free materials; clean
debris from plumbing and screen at inlet to ice maker; replace with lead-free ice maker; retest after
any remedy has been employed.

Example 2:
                                                                              /•
•       Sample IE = 22 ppb and Sample 2E (21 ppb) significantly exceeds 5 ppb = lead is
        contributed  from the plumbing upstream from the ice maker.

•       Sample 2E (21 ppb) exceeds 20 ppb = sampling from the distribution system supplying
        water to the ice maker is recommended (see Exhibit 4.9 for instructions).
                                       103

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    Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                            Faucets (Taps) (See Exhibit 4.8)
Example 1:

•       Sample IF (39 ppb) exceeds Sample 2F (6 ppb) = 33 ppb of lead is contributed from the water
        faucet.

•       Sample 2F (6 ppb) is close to 5 ppb = very little lead is coming from the plumbing upstream
        from the faucet; the majority of the lead is coming from the faucet and/or the plumbing
        connecting the faucet to the lateral.

Possible Solutions:  Replace faucet with lead-free device (request copies of lead leaching studies from
manufacturers of brass faucets and fixtures before purchasing); replace plumbing connecting the faucet to
the lateral with lead-free materials; flush outlet and connecting plumbing each day; apply point-of-use
device designed to remove lead; find alternative water source such as bottled water or other lead-free
location in the building; retest after any remedies are employed.

Example 2:

•       Sample IF (49 ppb) exceeds Sample 2F (25 ppb) = source of lead (24 ppb) is the water faucet
        and the plumbing upstream from the outlet (25 ppb).

•       Sample 2F (25 ppb) significantly exceeds 5 ppb = lead may be contributed from upstream from
        the faucet; evaluate lead test results conducted upstream from the faucet to ascertain potential
        contributions of lead from the upstream piping. To pinpoint location test interior plumbing (see
        instructions for sampling interior-plumbing in Exhibit 4.9).

Possible Solutions:  Replace faucet with lead-free device (request copies of lead leaching studies from
manufacturers of brass faucets and fixtures before purchasing); replace plumbing connecting faucet to the
lateral with lead-free materials;  replace suspected portion of interior plumbing with lead-free materials;
flush the outlet and interior plumbing each day; apply point-of-use device designed to remove lead; find
alternative water source such as bottled water or water from other lead-free location in the building; retest
after any remedies are employed.
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       Getting the Lead Out - A Guide to Reducing Lead in Drinking Water in Schools
                             Interior Plumbing (See Exhibit 4.9)
Example:

•       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:

•       Sample 1H or II (23 ppb) exceeds 20 ppb = collect additional samples from the plumbing upstream
        supplying water to the loop or header; compare the results with those taken from the service line or
        the riser pipe that supplies water to the loop and/or header.

•       Sample 1H or II (23 ppb) significantly exceeds 5 ppb and Sample 1H or II is less than downstream
        site (25 ppb) = a small portion of the lead (2 ppb) is contributed downstream of the sample site.

Possible Solution:  Following the collection of additional samples upstream from the header or loop to
pinpoint source of lead, replace affected plumbing with lead-free materials; retest water for lead.

Example:

•       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 1J (6 ppb) is not equal to downstream site (25 ppb) = source of lead is not the  riser pipe of
        the plumbing and service connection upstream from the riser pipe.

•       1J (6 ppb) is close to 5 ppb = the portion of the riser pipe and plumbing upstream from Sample Site
        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.
                                               105

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1 . When was the original building constructed?
Were any buildings or additions added to the
original facility? If so, complete a separate
plumbing profile for each building, addition, or
wing.



2. If built or repaired since 1 986, were lead-free
plumbing and solder used in accordance with the
lead-free requirements of the 1986 Safe Drinking
Water Act? What type of solder has been used?



3 . When were the most recent plumbing repaks
made (note locations)?



4. With what materials is the service connection
(the pipe that carries water to the school from the
utility's main in the street) made?
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listing of banned water coolers in Appendix :
Note the locations of any banned coolers.













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