Drinking Water

    Best Management Practices

For Schools and Child Care Facilities With Their Own
           Drinking Water Source

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                              Drinking Water
                   Best Management Practices

          For Schools and Child Care Facilities With Their Own
                             Drinking Water Source
This guide is intended for use by school officials and child care providers responsible for the maintenance and/or safety
of school and child care facilities including the drinking water. The purpose of this guide is to describe the importance
of implementing best management practices for drinking water in schools and child care facilities and how a school or
child care facility would go about implementing these practices. This guide is specifically designed for schools and child
care facilities that have their own well and, therefore, are classified as a public water system. This guide is not a regulation
itself, nor does it change or substitute for those provisions and regulations. Thus, it does not impose legally binding
requirements on EPA, states, public water systems, schools or child care facilities. This guide does not confer legal rights
or impose legal obligations upon any member of the public. While EPA has made every effort to ensure the accuracy
of the information in this guide the obligations of the regulated community are determined by statutes, regulations or
other legally binding requirements.  In the event of a conflict between the information in this guide and any statute or
regulation, this document would not be controlling.


Table of Contents
What Decision Makers Should Know	1

      Bacteria	6

      Lead	7

      Copper	9

Drinking Water Best Management Practices	10

      Bacteria	10

      Lead	11

      Additional Considerations	16

Resources	19

Glossary	20

 This document was prepared by the United States Environmental Protection Agency, Office
of Ground Water and Drinking Water, and is based on EPA New England's guide titled, "Are You
          Providing Safe Drinking Water at Your School? EPA-90 7 -F-0300 7, May 2003"

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What Decision Makers Should Know
 On any given day in America nearly 50 million
 public school students spend a significant
 portion of their day in school buildings.
 Exposure to environmental hazards in
 schools can negatively impact the health of
 children and school staff. Moreover, studies
 have shown that poor indoor environments
 in schools have negative impacts on teacher
 productivity and student performance.1'2'3
       Voluntarily testing for lead in addition
       to complying with the Lead and Copper
       Rule;
       Conducting routine measures for
       reducing lead exposure in drinking
       water; and
       Implementing additional measures such
       as water security, water conservation
       and educating students about drinking
       water.
Schools and child care facilities receive their
drinking water from either nearby municipal
water systems or their own on-site drinking
water source (i.e., wells).  Facilities that receive
their drinking water from their own water
source are operating a public water system
(PWS) and are required to comply with a series
of regulations. There are also best management
practices that schools  and child care facilities
should follow if they operate their own public
water system. This guide provides an overview
of public water systems and regulations that
apply to them. Additionally, this guide provides
best management practices for the following:
    •   Complying with regulations that apply
       to public water systems;
    •   Protecting sources of drinking water;
    •   Maintaining and sanitizing water
       fountains and faucet screens/aerators;
1 Vinciullo F. The relationship between multi-com-
ponent school health programs and school achieve-
ment. Paper presented at: Annual Conference of
the National Association of School Nurses, 2008;
Albuquerque, NM.
2 Stolz A, Knickelbein, A., Coburn, S. Linking
coordinated school health to student success. Paper
presented at: Annual Conference of the National
Association of School Nurses, 2008; Albuquerque,
NM.
3 NRC (National Research Council). Green Schools:
Attributes for Health and Learning. Washington
D.C.: The National Academies; 2006.
Public Water Systems

A public water supply system is one that
provides tap water for human consumption to
15 or more service connections or serves an
average of 25 people at least 60 days each year.
Water for human consumption includes water
for drinking and cooking, food preparation,
 Top Five Actions to Protect Drinking
 Water at Schools and Child Care
 Facilities
  1.  Clean drinking water fountains daily
     using procedures found in this guide.
  2.  Clean debris out of all outlet screens
     or aerators on a regular basis using the
     procedures found in this guide.
  3.  Test the facility's drinking water for lead.
     If lead is present,  follow the actions for
     addressing lead contamination outlined
     in this guide.
  4.  Ensure the source of your drinking water
     supply is free from contamination by
     using the recommendations found in this
     guide.
  5.  If elevated lead levels are found,
     regularly flush all water outlets used
     for drinking or food preparation and
     install point-of-use devices, to provide
     additional treatment of drinking water at
     the outlet.

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Table 1. Types of Public Water Systems
                                 Definition
                                               Examples
 Community water
      system
Deliver water to 15 or more service
connections OR at least 25 residents are
served by the system year-round
Subdivisions, mobile home
parks, water districts, cities
and towns
   Non- transient
  non-community
   water systems
Serve the same non-resident persons each
day for more than 6 months per year
Schools, child care facilities
and businesses
  Transient non-
 community water
      systems
A public water system that provides water
in a place where people do not remain for
long periods of time
Restaurants, rest stops,
summer camps and
campgrounds
hand washing and bathing. Most schools and
child care facilities that are PWSs are typically
non-transient, non-community water systems
(NTNCWS), as they serve the same non-
resident population  each day for more than six
months per year.  Other types of water systems
include community water systems (CWS)
and transient, non-community water systems
(TNCWS).  See Table 1 for a
list of public water systems,
definitions and examples.
                         Regulations That Apply to Your
                         Public Water System

                         As the number of drinking water regulations
                         grows, EPA, states and other organizations
                         continue to provide assistance to public water
                         systems to ensure compliance and help public
                         water systems provide safe, high-quality
                         drinking water (Table 2).  Compliance with
                         each regulation depends on what type of public
                         water system you are and the number of people
                         served. In addition, most schools and child
                         care facility PWSs are served by ground water,
                         and the drinking water regulations for these
                         well systems address chronic and acute impacts
                         from potential contaminants.

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Table 2.  Regulations that Apply to Non-Transient, Non-Community Water
Systems*
        Regulation
      Goal & Importance
       Applicability
   Total Coliform Rule
   (http://water.epa.gov/
  lawsregs/rulesregs/sdwa/
       tcr/index.cfm)
Seeks to limit bacteria, parasites
and viruses which can cause health
problems when humans ingest
them in drinking water by using
coliform bacteria as an indicator.
All public water systems
    Ground Water Rule
   (http://water.epa.gov/
  lawsregs/rulesregs/sdwa/
      gwr/index.cfm)
Provides for increased protection
(via monitoring) against microbial
pathogens in public water systems
that use ground water sources. It
establishes an approach to focus
on ground water systems that are
susceptible to contamination and
requires ground water systems that
are at risk to take corrective action.
All public water systems that
use ground water.
 Stage 1 Disinfectants and
 Disinfection Byproducts
   Rule (http://water.epa.
  gov/lawsregs/rulesregs/
   sdwa/stagel/factsheet.
           cfm)
Reduces exposure to disinfection
byproducts for customers,
strengthening public health by
decreasing potential cancer,
reproductive and developmental
health risks from DBFs.
Community water systems
and non-transient non-
community systems, including
those serving fewer than
10,000 people, that add a
disinfectant to the drinking
water during any part of the
treatment process.
 Stage 2 Disinfectants and
  Disinfection Byproduct
           Rule
   (http://water.epa.gov/
  lawsregs/rulesregs/sdwa/
     stage2/index.cfm)
Strengthen public health
protection by tightening
compliance monitoring
requirements for two groups of
disinfection byproducts (DBFs):
trihalomethanes (THMs) and
haloacetic acids (HAAs). This
rule is intended to reduce
potential cancer, reproductive and
development health risks from
DBFs.
Applies to community
and non-transient, non-
community water systems
that add and/or deliver water
that is treated with a primary
or residual disinfectant other
than ultraviolet light.

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        Regulation
      Goal & Importance
        Applicability
     Lead and Copper
   (http: / /water, epa.gov/
  lawsregs/rulesregs/sdwa/
       Icr/index.cfm)
Requires water systems to
control corrosivity and collect
tap samples from sites served
by the system that are more
likely to have plumbing materials
containing lead.  This rule
provides monitoring techniques
and response actions for lead and
copper, which may cause a variety
of health problems.
All community and non-
transient, non-community
water systems.
     Phase II/V Rules
   (http: / /water, epa.gov/
  lawsregs/rulesregs/sdwa/
 chemicalcontaminantrules/
   basicinformation.cfm)
Establishes monitoring and
reporting requirements and
allowable limits for inorganic,
volatile organic and synthetic
organic contaminants. This
provides important public health
protection through the reduction
of chronic risks from cancer,
organ damage and circulatory,
nervous and reproductive system
disorders.
All community and non-
community water supplies.
       Arsenic Rule
   (http: / /water, epa.gov/
  lawsregs/rulesregs/sdwa/
  arsenic/regulations.cfm)
Limits arsenic in water to 10 parts
per billion (ppb). This rule is
intended to reduce risks of cancer
and cardiovascular, pulmonary,
immunological, neurological and
endocrine effects that result from
exposure to arsenic.
All community and non-
transient, non-community
water systems.
 Public Notification Rule
   (http: / /water, epa.gov/
 lawsregs/rulesregs/sdwa/
  publicnotification/index.
            cfm)
Requires systems to notify the
public any time a water system
violates national primary drinking
water regulations or has other
situations posing a risk to public
health.  This rule ensures that
consumers will always know if
there is  a problem with their
drinking water.
All public water systems
violating national primary
drinking water regulations,
operating under a variance or
exemption or having other
situations posing a risk to
public health.
* Almost all school and child care facility water supplies rely on ground water so additional surface water
regulations are not highlighted here.

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Source Water Protection

One of the best ways to be sure you are
providing clean water is to ensure the source of
your supply is free from contamination.  State
drinking water agencies have identified wellhead
protection areas, land areas that provide
water to public supply wells and surface water
supplies. If your facility receives water from an
on-site well water system its protection area is
likely to include the school or child care facility
property and neighboring properties.

State drinking water programs are required
to complete a source water assessment for all
public drinking water systems, which include
information about the location of each drinking
water system's protection area and about
activities that could potentially contaminate  the
drinking water source, including ground water
wells (see Table 3). You can contact your state
or local drinking water program and ask if they
have a map showing your protection area.

You should also evaluate potential
contamination sources on your facility's
property that may impact water quality and
make plans to eliminate any risk they pose.
If the facility uses an on-site septic system,
evaluate the setback between it and your
well, and confirm it meets  state and local
requirements.  Some areas  to check within the
facility are sinks and floor drains  in facility
maintenance areas, cleaning supply areas,
science laboratories, vocational shops and art
classrooms.  It is a good idea to post signs over
sinks indicating chemicals cannot be disposed
of down the drain. Protecting the quality of
your water before it is contaminated is much
more cost-effective than trying to treat or
replace a supply that has been contaminated.

Additional information is available from EPA
at: http://water.epa.gov/infrastructure/
drinkingwater/sourcewater/protection/index.
cfm
Table 3. Potential Contamination Sources
Potential Contaminant
Bacteria/Pathogens
Nitrogen
Sodium, Chloride
Oils & Hydrocarbons
Chlorinated Solvents
Source
Septic systems, animal feedlots, manure storage
Septic systems, lawn fertilizers, agricultural
fertilizers, manure storage, animal feedlots
Road salt storage facilities, major roads when
road salt is applied
Gas stations, fuel oil distributors, underground
home heating oil tanks
Automotive services and repair facilities, dry
cleaners, industrial facilities

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Addressing Cross Contamination

It is important to be aware of cross
connections within your facility as
contamination can occur when there is a
connection between your building's drinking
water system  (pipes) and another liquid or
substance.  Cross contamination from backflow
of harmful substances may occur as a result
of reduced pressure in the drinking water
system or because of increased pressure in
the contaminating source.  Be aware, cross
contamination may not be immediately
apparent because a contaminant may not have a
strong taste, odor or color.
Cross contamination can happen at facilities
under a number of circumstances, including:
    •   When a tube or hose from a faucet is
       submerged in a solution, in a beaker or
       in a custodian's sink;
    •   A pipe is connected from a drinking
       water source to chemical lab equipment,
       a storage tank or cafeteria equipment; or
    •   A hose is dropped into a waste/floor
       drain in an automotive shop, boiler
       room or cafeteria.

Other sources of potential cross contamination
include cross connections between the drinking
water system and heating system boilers, water
coolers, lawn sprinkler systems, fire sprinkler
systems or soft drink machines.

Cross contamination can be prevented by
using backflow prevention devices that only
allow water to flow in one direction, from the
source to the tap, so liquid cannot flow back
A garden hose creates a dangerous cross connection between
potable and non-potable water.

down the tap and contaminate the water in
the distribution system. Devices should be
tested annually by a certified professional. If
you have questions about cross connections
and contamination, contact the local building/
plumbing inspector or for more information on
cross contamination please visit: http://wa.ter.
epa.gov/infrastructure/drinkingwater/pws/
crossconnectioncontrol/index.cfm
                                              Bacteria
Bacteria are present throughout our
environment. They have adapted to live
and reproduce in a variety of environments,
including inside animals and humans, and in
water, soil and food.  If bacteria are present
in drinking water sources, most are removed
during the disinfection process. However, some
may survive and enter the distribution system
(the building's pipes and plumbing). Bacteria
can also grow within  the plumbing system,
water fountains and faucets. Therefore, it is
important to regularly clean your facility's water
fountains, faucets and hot water tanks.

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 Lead
 Understanding Lead Exposure
Lime build-up on mouthpiece and protective guard of drinking
fountain.

As a public water system, your school or child
care facility is required to comply with the
Lead and Copper Rule (see page 2, Table 2.
Regulations that Apply to NTNCWSs). The
Lead and Copper Rule was developed to
protect public health by minimizing lead and
copper levels in drinking water. Public water
systems are required to collect a number of tap
samples based on the daily population served
(see Table 4).  However, EPA encourages
schools and child care facilities to conduct
additional voluntary lead testing at ALL water
outlets in their facility used for drinking or food
preparation. Because you cannot see, taste or
smell lead in your drinking water, testing the
facility's water is the only sure way to know if
there are elevated levels in the water.  School
officials and child care providers need to know
whether the drinking water that students,
teachers and staff consume contains  elevated
levels of lead because exposure to lead can
cause serious health problems, particularly for
young children.

The "Lead and Copper Rule:  Quick Reference
Guide for Schools and Child Care Facilities that
are Regulated Under the Safe Drinking Water
Act" provides an overview of the Lead and
Copper Rule and sampling requirements. The
guide is available at:
http://water.epa.gov/infrastructure/
drinkingwater/schools/upload/2006_l_ll_
schools_lead_qrg_lcr_schools.pdf
                                                In addition to complying with the Lead
                                                and Copper Rule, it is recommended that
                                                schools and child care facilities that are
                                                public water systems  conduct additional
                                                testing for lead as children are particularly
                                                susceptible to health  effects from lead.
Health Effects of Lead

Lead can cause serious health problems if too
much enters your body from drinking water or
other sources. Some facts about lead exposure
include:
    •  Infants, young children and pregnant
       women are at greatest risk to lead
       exposure;
    •  Increased lead levels have been shown
       to cause damage to the brain and
       kidneys;
    •  Increased lead levels interfere with the
       production of red blood cells that carry
       oxygen to all parts of your body;
    •  Scientists have linked the effects of lead
       on the brain with lowered intelligence
       quotient  (IQ) in children;
    •  Adults with kidney problems and high
       blood pressure can be affected by lower
       levels of  lead more than healthy adults;
    •  Lead is stored in the bones and it can be
       released later in life; and
    •  During pregnancy, the fetus receives
       lead from the mother's bones which
       may affect brain development.

In addition to protecting human health,
facilities that voluntarily test drinking water
and make information about their program
available to the public may increase the public's
confidence in the school or child care facility's
water quality.

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Table 4. Lead and Copper Tap Monitoring Requirements Under the Lead and
Copper Rule
School
or Child Care Facility Daily
Population Served
10,001 - 50,000
3,301-10,000
501 - 3,300
101-500
100 or less
Number of Lead and Copper Tap Sample
Locations
60
40
20
10
5
Source:  Lead and Capper Rule: Quick Reference Guide for Schools and Child Care Facilities that are Regulated Under the Safe
Drinking Water Act
How Lead Gets into Drinking Water

Soft water has a low pH, which is corrosive.
Other factors however also contribute to the
corrosion potential of the water and include
water velocity, temperature, alkalinity, type of
disinfectant, the age and condition of plumbing
and the amount of time water is in contact
with plumbing.  Of note, recent construction
work on your facility's plumbing system (e.g.,
pipe replacement and utility lead service line
replacement with copper components)  may
result in corrosion of remaining lead pipes or
disturbance of settled debris within larger pipes
in the system which may create new sources
of contamination.  The occurrence and rate of
corrosion depend on the complex interaction
between a number of these and other chemical,
physical and biological factors.
Example of lead pipes in a plumbing system.

According to the Lead and Copper Rule there
are steps that public water systems must take
to reduce the corrosiveness of the water if the
system has high levels of lead. However, if
the plumbing in the facility is made of lead or
contains lead parts, corrosion may occur simply
by water moving through  the plumbing.
  Reduction of Lead in Drinking Water Act
  A new requirement, signed into law by President Obama in January 2011, will further reduce
  lead in pipes, pipe fittings, plumbing fittings and fixtures to a weighted average of 0.25 percent.
  The Reduction of Lead in Drinking Water Act redefines "lead free" under the Safe Drinking
  Water Act to mean: not containing more than 0.2 percent lead when used with respect to
  solder and flux, the material used to join pipes and fixtures together (current law) and not
  more than a weighted average of 0.25 percent lead when used with respect to the wetted
  surfaces of pipes, pipe fittings, plumbing fittings and fixtures. The new requirements will
  become effective in January 2014.

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Potential Sources of Lead in Drinking
Water
    •   Lead pipes in plumbing:
       °   Dull gray in color and will appear
           shiny when scratched
       D   Banned since 1986 and not widely
           used since the 1930s
    •   Copper pipes joined by lead solder:
       °   Solder will be dull gray in color and
           will appear shiny when scratched
       D   Banned since 1986 and many
           communities banned prior to 1986
    •   Brass pipes, faucets, fittings and valves:
       °   May contain alloys of lead
    •   Sediments in screens on faucets may
       contain lead:
       °   Debris from plumbing can collect
           on  screens
    •   Water service line from the well to the
       facility  is made of lead:
       °   Pipes that carry water to the facility
           may contain lead
    •   Water fountains in the facility may
       contain lead parts:
       °   Specific brands of water fountains
           contain  lead parts or have lead lined
           water tanks
       °   Since 1988 it has been mandated
           that water fountains be lead free,
           but older facilities may have
           outdated models.
Copper
Copper is widely used in household plumbing,
sometimes without proper consideration of
water quality. Excess copper exposure can
cause stomach and intestinal distress, liver or
kidney damage and complications of Wilson's
disease. Children's bodies absorb more lead and
copper than the average adult because of their
rapid development.  Copper leaches into water
through corrosion of the plumbing system —
primarily from pipes, but fixtures, faucets and
fittings made of brass can also be a source.
The amount of copper in your water strongly
depends on the acidity and types and amounts
of minerals in the water, whether or not it is
oxygenated or disinfected, how long the water
stays in the pipes, the length of time the pipes
have been in use and the water's temperature.
When the water pH is below neutral (7) and
when the alkalinity of the water (bicarbonate
content) is high, very high concentrations of
copper can persist for many years in copper
pipes and fittings found in new construction
and remodeled or renovated buildings.  Blue
staining of water, sinks and fixtures can be
an indicator of extreme copper plumbing
corrosion.

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Drinking Water  Best Management
Practices
Bacteria
Drinking Water Fountains

Drinking water fountains should be cleaned
on a daily basis to reduce possible bacterial
contamination. Fountains should also be
included in the regular flushing of your
facility's plumbing system (as described in the
section, Routine Measures for Reducing Lead
Exposure).

Drinking Water Fountain Daily Cleaning
Procedures1
The following procedures should be considered
for daily cleaning:
   •  Gather necessary materials and
      suggested protective equipment;
   •  Obtain Material Safety Data Sheets
      (MSDS) for all chemicals being used
      and review manufacturer's instructions
      for use;
   •  Check the flow of the water to make
      sure there is a constant stream;
   •  Spray disinfectant cleaner solution on
      the inside surfaces of the mouthpiece
      and protective guard;
   •  Using a scrub brush, scrub the inside
      and outside of the mouthpiece and
      protective guard;
   •  Rinse the mouthpiece and protective
      guard with water; and
   •  Wipe drinking fountain surfaces with a
      clean cloth dampened with water.

It is also important to clean drinking water
fountains to remove lime and calcium build-up.
Lime and calcium build-up can begin to block
the water from coming through the mouthpiece
and going down the drain.
Removing Lime
Build-up on
Drinking Fountains
or Ice Machines
   •   Spray descaler onto the bowl and back
       of the drinking fountain;
   •   Use a clean, lint-free cloth saturated
       with the descaler. Apply to the surfaces
       with the lime build-up.  Let stand for
       the length of time recommended on the
       label;
   •   Wring out all excess solution from the
       cloth;
   •   Wipe the surface clean with  the cloth.
       If necessary, use a brush or  scrub pad
       to remove hard build-up. Be careful
       not to damage surfaces while scrubbing;
       and
   •   Thoroughly rinse the surfaces with
       clean water.

For a list of EPA-approved disinfectants to use
in your facility, please  visit: http://www.epa.
gov/oppadOOl /chemregindex.htm

Hot Water Tanks

Hot water tanks are susceptible to the
development of biofilm, which is a surface
deposit of bacteria that  accumulates creating
a slime layer. Similar to  the plaque that forms
on teeth biofilms accumulate over time. It
is recommended that you consult with an
experienced professional to have your  hot water
tank periodically cleaned to remove  existing
biofilms and sediments.2
1 Iowa State University Facilities Planning & Man-
agement - Custodial Task Procedures
2 National Environmental Services Center, Tech
Brief. Biofilm Control in Distribution Systems,
Summer 2008, Vol. 8, Issue 2.

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Lead

Voluntary Lead Testing

In addition to complying with the Lead and
Copper Rule, EPA recommends that schools
and child care facilities conduct additional
voluntary lead testing at ALL water outlets
used for drinking and food preparation. EPA
developed the 3Ts  (Training, Testing and
Telling) for Reducing Lead in Drinking Water
in Schools, Revised Technical Guidance to
help schools and child care facilities implement
simple strategies for managing the health risks
of lead in drinking water. Following the 3Ts
guidance does not replace requirements for
complying with the Lead and Copper Rule (see
page 2, Table 2. Regulations that Apply to Non-
transient, Non-community Water Systems).

The 3Ts include:
    •   Training school and child care facility
       officials to raise awareness of the
       potential occurrences, causes and health
       effects of lead in drinking water, assist
       facilities in  identifying potential areas
       where elevated lead may occur, and
       establish a testing plan to identify and
       prioritize testing sites;
    •   Testing drinking water in the facility
       to identify potential problems and take
       corrective actions as necessary; and
    •   Telling students, parents, staff and the
       larger community about monitoring
       programs, potential risks, the results of
       testing and remediation actions.

The 3Ts for Reducing Lead in Drinking
Water in Schools, Revised Technical Guidance
is available at: http://water.epa.gov/
infrasttucture/drinkingwater/schools/guidance.
cfm#3ts

The 3Ts for Reducing Lead in Drinking Water
in Child Care Facilities is available at: http://
water.epa.gov/infrastructure/drinkingwater/
schools/guidance.cfm#3ts

EPA also developed the, "What Your School or
Child Care Facility Should Know About Lead in
Drinking Water" DVD available for order from
the National Service Center for Environmental
Publications (NSCEP) at: http://water.epa.
gov/infrastructure/drinkingwater/schools/
guidance.cfm3

Test the Facility's Drinking Water for
Lead
It is important to test all of the drinking
water outlets in your facility, especially those
that provide water for drinking, cooking and
preparing juice and infant formula. Lead in
drinking water can be a localized problem and
can vary from tap to tap. Just because there
3 Also available by calling NSCEP at 1-800-490-
9198.  For International Orders: Call NSCEP at
(301) 519-6640 or e-mail NSCEP at nscep@bps-
lmit.com

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is lead getting into your water from one outlet
does not mean that all your taps are vulnerable.
At the same time, just because one tap sample is
free from lead does not mean that all your taps
are clear. It is a good idea to test ALL outlets
including drinking fountains and faucets where
water is used for drinking or cooking.  Unusual
sources of  drinking water, such as locker room
shower heads and other non-drinking water
taps used to fill water jugs  and carboys, should
also be included when testing for lead.

There are different sampling techniques used
to comply with the Lead and Copper Rule
and a voluntary lead testing program. The
3Ts for Reducing Lead in Drinking Water in
Schools, Revised Technical Guidance, provides
step-by-step instructions on how to properly
collect voluntary samples and test your facility's
drinking water outlets for lead.4 A list of
certified laboratories  for lead testing is available
from your state or local water authority. Testing
costs between $20.00 and $100.00 and the
laboratory will provide  instructions on proper
sampling procedures.

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 (ug/L), or as parts per
million (ppm) or parts per billion (ppb).  One
ppm is roughly equivalent  to one cup of a
substance in a swimming pool. One ppb  is
about one drop of a substance in a swimming
pool.

Under the Lead and Copper Rule, EPA
established an action level  of 15 ppb  for
lead in a one-liter sample, based on the 90th
percentile level of tap water samples (no more
than 10 percent of your samples can be above
the action level). If the 15 ppb threshold is
exceeded, the Lead and Copper Rule requires
corrosion control actions to be taken by
the water system operator to reduce lead
concentrations.

Under the 3Ts guidance, EPA recommends that
schools and child care facilities also take action
to correct issues with lead fixtures and piping
within the school if samples from any ONE
drinking water outlet shows lead levels greater
than 20 ppb.

If your sink has separate hot and cold water
knobs, samples should be collected from cold
water, as hot tap water is not recommended for
food preparation or direct consumption. If you
have one lever, be sure to turn it on to the cold
water side before collecting your sample.

Routine Measures for Reducing  Lead
Exposure

Whether you have tested your water or not, or
even if your water has shown low levels of lead,
there are basic practices that will further reduce
the potential for lead exposure at your facility as
well as reduce  sediment in your water.

Develop a flushing plan
   •   Determine how water enters and flows
       through your facility by developing a
       plumbing profile5. Consult with your
       maintenance personnel, a licensed
       plumber or a local water service to
       develop a plumbing profile;
   •   Locate all water outlets that are used for
       consumption;
   •   Identify the drinking water outlet(s)
       furthest from the main water service
       line  (Note: If your  facility has multiple
       wings there will be more than one outlet
       farthest from the main service line);
4 See Section II: Testing of the 3Ts for Reducing
Lead in Drinking Water in Schools, Revised Techni-
cal Guidance, available at:  http://water.epa.gov/
infrastructure/drinkingwater/schools/guidance.cfni
5 See Section II: Testing of the 3Ts for Reducing
Lead in Drinking Water in Schools, Revised Techni-
cal Guidance, available at:  http://water.epa.gov/
infrastructure/drinkingwater/schools/guidance.cfni

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   •   Determine the best order to open and
       flush drinking water outlets, starting
       with those farthest from the main
       service line;
   •   Identify options for  collection and non-
       potable re-use of flushed water (e.g.,
       plant watering); and
   •   Develop a system for accountability,
       including identifying one person who
       is in charge and developing a record
       keeping system.

Flush all water outlets used for drinking
or food preparation
   •   At the start of each  day, before using
       any water for drinking or cooking,
       flush the cold water  faucet by allowing
       the water to run for  a period of time.
       Contact your state or local drinking
       water program to find out what the
       recommended flushing time is for your
       facility based on system size and pipe
       diameter.  Flushing should be done for
       all water outlets used for drinking or
       food preparation.
   •   Flushing, or opening up a tap and
       letting the water run, replaces the
       stagnant water that may have been in
       contact with lead-containing plumbing
       fixtures overnight or over the weekend.
       The longer water is exposed to lead
       pipes or solder the greater the  likelihood
       of lead contamination.
   •   Flushing times vary  depending on your
       buildings pipes and outlets, refrigerated
       water fountains can  take as long as
       15 minutes to properly flush out the
       reservoir.
   •   If many taps need flushing,  the tap
       furthest from the main pipe should be
       opened for approximately 10 minutes
       to flush out the main pipe. Then,
       individual drinking water taps should
       be flushed to rid stagnant water from
       the pipes.6 Keep in mind that if your
       facility has more than one wing there
       may be more than one tap that is
       furthest from the main water line.

Use only cold water to prepare food and
drinks
    •   Hot water dissolves lead more quickly
       than cold water and is  therefore more
       likely to have greater amounts of lead.
    •   If hot water is needed, water should be
       drawn from the cold tap and heated.
    •   Use only thoroughly flushed water
       from the cold water tap for drinking
       and when making mixed baby formula,
       juices or foods.

Clean debris out of all water outlet
screens or aerators on a regular basis
    •   Small screens on the end of a faucet can
       trap sediments containing lead.  Note:
       Aerators are often used to regulate
       flow, reduce  splash and conserve water.
       Check to see if your faucets have
       aerators, since not all faucets have them.
                                              6 Lead in School Drinking Water Program (http://
                                              www.mass.gov/dep/water/drinking/sclcatlg.pdf).

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Faucet Aerators

Many taps that are used to provide water for
human consumption have an aerator as part
of the faucet assembly.  Aerators serve to
introduce air into the water flow which makes
it feel as if a larger water flow is coming out of
the tap.  The use of  aerators is a common water
conservation practice.  Screens are not intended
to remove contaminants in the water, but may
trap sediment or debris as water passes through
the faucet. Lead bearing sediment may end up
in drinking water from physical corrosion of
leaded solder and can build up in the aerator
over time.

Faucet Aerators Cleaning Procedures
   •   Remove the  aerator by twisting off with
       hands or pliers;
       One or more parts are contained
       within the aerator. Note the order and
       orientation of the parts as you remove
       them;
       Rinse the pieces with water and brush
       off the debris. For deposits that are
       difficult to remove, soak the parts in
       water for a few minutes and scrub with
       a toothbrush. Backwashing aerator
       components is also an effective cleaning
       method for many aerator types. Hold
       the removed aerator upside down under
       flowing water to backwash screens and
       mesh filters;
       If any parts are cracked or broken,
       replace them. If the washer has
       hardened it should be replaced; and
       Reassemble the aerator, screw it back
       onto the faucet and hand-tighten.
It is not recommended that aerators be
removed from faucets immediately before
sampling for lead as the sample will fail to
identify the typical available contribution
of particulate lead from that tap and thus
additional actions needed to reduce exposure to
lead in drinking water will fail to be taken.

However, if the results from the initial sample
are above the action level, you can consider
taking a second sample to determine whether

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particulate matter is the source of lead. For
this sample, the aerator would be cleaned or
removed prior to sampling so that the two
samples could be compared.7   It is advised that
a regular cleaning schedule be established for
aerators.

Respond to Elevated Lead Levels

If your system exceeds the lead action level
under the Lead and Copper Rule, specific
actions need to be taken.  These required
actions include public education, water quality
parameter monitoring, source water monitoring
and treatment and corrosion control treatment.8

Under the 3Ts guidance, EPA recommends
that schools and child care facilities take action
if samples from any ONE drinking water
outlet show lead levels greater than 20 ppb.
Any outlet with test results above this level
should not be used until the source of the
contamination is found and the lead levels are
reduced to 20 ppb or less.  If you are going
to stop using an outlet due to high lead levels
you should place a physical barrier such as tape
or an illustrative sign over the faucet so that
everyone knows it should not be used until it
is fixed. In addition, you should encourage
parents to have their children's blood tested
for lead if high lead levels are detected in
the water. It is recommended that facilities
develop Standard Operating Procedures
(SOPs) for responding to elevated lead levels
7 EPA, Oct 2006. Memorandum: Management
of Aerators during Collection of Tap Samples to
Comply with the Lead and Copper Rule. Available
at: http://water.epa.gov/lawsregs/rulesregs/sdwa/
lcr/upload/2006_10_27_lcrmr_memo_tapsamples-
aerators_10202006.pdf
8 The Lead and Copper Rule:  Quick Reference
Guide for Schools and Child Care Facilities that are
Regulated Under the Safe Drinking Water Act, avail-
able at: http://water.epa.gov/infrastructure/drink-
ingwater/schools/upload/2006_l_ll_schools_
lead_sqrg__lcr_schools.pdf
and administrators or directors should be
encouraged to communicate this information to
parents (or teachers)  so they can protect their
children. The following remedies can be used
to respond to elevated lead levels.

Provide an alternative lead-free drinking
water
    •   Bottled water can be used as a
       temporary measure; and
    •   Make sure the bottled water distributor
       meets federal and state bottled water
       quality standards (which are different
       than tap water) and that their filtration
       technology is National Sanitation
       Foundation International (NSF)
       certified for lead reduction  (http://
       www.nsf.org).
   Prior to replacing fixtures when elevated
   lead levels are determined, be sure to test
   the new fixtures to ensure the fixtures are
   "lead free." If you are purchasing a large
   volume of faucets ask the manufacturer
   or vender to test the faucets with your
   local tap water to make sure no lead is
   leached out of the faucets. If you are
   only purchasing a few faucets make sure
   the fixtures are  certified according to
   NSF/ANSI Standards 61 and 372 for
   lead reduction.  You can search for NSF
   drinking water components at: http://
   www.nsf.org/certified/pwscomponents/
Remove sources of lead in the plumbing
system
These remedies are most appropriate for
localized contamination problems and are best
handled by a licensed plumber:
    •   Replace solder joints with lead-free
       joints;
    •   Replace the outlet or fixture/faucet
       with "lead-free" materials (according
       to NSF/American National (ANSI)

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       Standards 61 and 372);
   •   Replace piping with "lead-free"
       materials; and
   •   Be sure to check product packaging to
       confirm item is NSF certified as lead
       free.

Install point-of-use/point-of-entry
treatment devices
   •   A point-of-use (POU) device is a
       filtration system, such as a carbon
       filter, that can be installed directly on a
       drinking water outlet. A point-of-entry
       (POE) device is a filtration system that
       is installed where the water main enters
       the facility and treats all the water in
       your building.
   •   Use a device that is certified by NSF
       International9 to remove lead.
       Maintaining POU and POE treatment
       devices is very important. Refer to
       the manufacturer's instructions for
       maintenance procedures.  If not
       maintained properly, some treatment
       devices may increase lead and other
       contaminant levels.
       If using a POU or POE device you
       should conduct follow up testing to
       make sure the water is still below the
       action level.
       With the use of a POU or POE device,
       flushing is not necessary.
       If using POU or POE devices on some
       faucets, but not all, make sure that
       faucets without a POU or POE device
       are clearly labeled that they are not for
       drinking or cooking water.
Communicate with your Community
about the Lead Testing Program
It is important to communicate early and often
about your testing plans, results and next steps.
Telling parents and staff about your voluntary
lead testing program will demonstrate your
proactive commitment to protecting the health
of your students and staff and build confidence
in your facility's ability to provide a safe and
healthy environment, whether or not elevated
lead levels are found in your facility.
9 NSF/ANSI Standard 61 explanation http://www.
nsf.org/business/water_distribution/faq.asp#lead
Additional

Considerations

Copper

Testing for copper may be appropriate if your
water is somewhat acidic (with a pH below 7)
and when it is disinfected.  Copper corrosion
decreases steadily over time under normal water
usage conditions, but elevated copper levels
can persist for many years in new copper pipes.
If you are experiencing blue staining of your
water, sinks, bathtubs or showers, or if there
is growing blue encrustation on the fixtures,
this may be an indicator of high copper levels,
and you should have your water tested for
both copper and lead. If you  are experiencing
elevated copper levels in the drinking water
system, the easiest method for reducing
exposure to copper is to flush the system to
avoid drinking or cooking with water that has

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been in contact with the plumbing system for
more than four hours. Particularly when first
drawing water in the morning, flush the system
by running the cold water faucet long enough
to get fresh water from the main, which could
vary from about two  minutes to five or ten
minutes, depending on the size and length
of the  pipes and the flow rate. Each faucet
where water is drawn for drinking or cooking
purposes should be flushed separately, starting
with the faucet or outlet farthest from where
the fresh water enters  the building.
                 10
Water Security
Work with your local emergency planning
committee to assess the vulnerability of your
facility's drinking water system and be sure
everyone working at your facility is involved in
this effort and understands their responsibilities.
    •   Prepare or update an emergency
       response plan.  Make sure all employees
       help develop the plan and receive
       training on it.
    •   Post updated emergency 24-hour
       numbers at your facilities in highly
       visible areas (e.g., pumphouse door,
       vehicles, office) and distribute them
       to key personnel and local response
       officials.
    •   Get to know your local police and
       fire departments and ask them to
       add your buildings to their routine
       rounds. Practice emergency response
       procedures with local police, emergency
       responders and public health officials.
    •   Fence and lock your drinking water
       facilities and vulnerable areas (e.g.,
       wellhead, hydrants, manholes,
       pumphouse and storage tanks).
    •   Lock all entry gates and doors, set
10 Adapted from EPA New England, Drinking Wa-
ter Security and Emergency Preparedness (http://
water.epa.gov/infrastructure/watersecurity/up-
load/2004_04_01_watersecurity_fs_security_small-
suppliers_top 10.pdf).
       alarms and post signs to indicate illegal
       entry.  Do not leave keys in equipment
       or vehicles at any time.
    •   Install good lighting around your
       pumphouse, treatment facility and
       parking lot.
    •   Identify existing and alternate
       water supplies and maximize use of
       backflow prevention devices and
       interconnections.
    •   Use your Source Water Assessment
       information (as described on page 5) to
       work with businesses and homeowners
       that are listed as potential sources of
       contamination in  order to lessen their
       impact on your water source.
    •   Lock monitoring wells to prevent
       vandalism or direct contamination by
       moving vent pipes inside the pump
       house  or fencing/screening them in.
    •   In case of an emergency, first call 911
       then follow your emergency response
       plan.

Additional water security resources
include:

Top 10 List for Drinking Water Security and
'Emergency Preparedness (EPA)
Provides tips to enhance security of small
ground water systems.
Website: http://water.epa.gov/infrastructure/
waters ecurity/upload/2004_04_01_
waters ecurity_fs_security_smallsuppliers_top 10.
pdf

Security Vulnerability Self Assessment Guide for
Small Drinking Water Systems (Association of State
Drinking Water Administrators in coordination with
National Rural Water Association)
Guidance is available for small systems, such
as schools and child care facilities, to complete
a security vulnerability assessment of their
drinking water system.
Contact: Association of State Drinking Water
Administrators at:  http://www.asdwa.org

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Water Conservation

Schools and child care facilities use large
amounts of water every day for heating and
cooling systems, restrooms, drinking water,
cooking, locker rooms, cafeterias, laboratories
and outdoor playing fields and lawns. Options
to reduce water use for these facilities include:
    •   Consider replacing old equipment such
       as dishwashers with energy and water
       saving devices;
    •   Repair water leaks and leaky toilets;
    •   Install aerators and automatic shut-off
       devices  on faucets;
    •   Use low-flow shower heads and timer
       shut-off devices to reduce water use
       during showers;
    •   Install timers  on outdoor sprinklers;
    •   Install toilet dams on older models;
    •   Replace plants and grasses that require
       a lot of  water with native sustainable
       vegetation; and
    •   Use rain barrels and teach the students
       about green roofs.

WaterSense
The WaterSense program promotes water
efficiency and enhancing the market for
water-efficient products, programs and
practices. Since the program's inception in
2006, WaterSense has helped consumers save a
cumulative 46 billion  gallons of water and $343
million in water and sewer bills.  For additional
information, visit:  http://www.epa.gov/
waters ens e/

Teaching Students about Drinking
Water

There are a variety of ways to teach students
about drinking water:

    •   Early science  classes demonstrating the
       water cycle;
    •   Mathematics  classes demonstrating
       supply and demand principles;
    •   History lessons discussing early
       settlement patterns near water sources
       and our nation's system of government,
       laws and regulations provide important
       knowledge for water resource decision-
       making;
    •   Involve students in the voluntary lead
       testing program to make it a teaching
       moment, ensuring that the students
       wear proper safety equipment and are
       not exposed to lead; and
    •   Engage high school science classes
       or local universities to conduct quick
       screening tests for devices identified as
       meeting the application needs and NSF
       International requirements to verify
       performance.

EPA has developed numerous resources and
activities for students and teachers, including:

Drinking Water in Schools and Child Care Facilities
(EPA)
Provides multiple resources regarding lead in
drinking water, including health information, an
overview of laws and regulations and guidance.
Website: http://water.epa.gov/infrastructure/
drinkingwater/schools/index.cfm

Kid's Stuff: Drinking Water and Ground Water
(EPA)
Provides activities and materials for students
and teachers for grades K-3, 4-8 and 9-12.
Website: http://water.epa.gov/learn/kids/
drinkingwater/index.cfm

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Water Science and Technology for Students and
Educators (EPA)
Water-related activities and resources for
students and teachers.
Website: http://water.epa.gov/learn/
resources/index.cfm

That Magnificent Ground Water Connection
(New England Interstate Water Pollution Control
Commission in coordination with EPA)
Classroom activities for students demonstrating
the many characteristics, uses and threats to
ground water resources in New England.
Available for grades K-6 and 7-12.
Selected activities are available at: http://www.
epa.gov/regionl/students/teacher/groundw.
html
Resources
3Ts for Reducine Lead in Drinkine Water in Schools
   J         o              o
Provides detailed guidance for schools that
receive their drinking water from municipal
water supplies regarding training and testing
for and communicating about lead in drinking
water.
Website:  http://water.epa.gov/infrastructure/
drinkingwater/schools/guidance.cfm#3ts

3Ts for Reducine Lead in Drinkine Water in Child
   J         o              o
Care Facilities
Provides detailed guidance for child care
facilities that  receive their drinking water from
municipal water supplies  regarding training and
testing for and communicating about lead in
drinking water.
Website:  http://water.epa.gov/infrastructure/
drinkingwater/schools/guidance.cfm#3ts

Lead and Copper Rule: A Quick Reference Guide for
Schools and Child Care Facilities that are Regulated
Under the Safe Drinking Water Act
Provides an overview of  the Lead and Copper
Rule requirements, including sampling,
compliance and public  education requirements.
Website: http://water.epa.gov/infrastructure/
drinkingwater/schools/upload/2006_l_ll_
schools_lead_sqrg_lcr_schools.pdf

EPA's Website on Lead
http://www.epa.gov/lead/

EPA's Website on Lead in Drinking Water
http://water.epa.gov/drink/info/lead/index.
cfm

EPA's Website on Reducing Lead in Drinkine Water
                     o              o
in Schools and Day Care Centers
http://water.epa.gov/drink/info/lead/
schools_index.cfm

Centers for Disease Control and Prevention's Website
on Lead
http://cdc.gov/lead/

National Lead Information Center Hotline: (800)
424-LEAD

EPA's Safe Drinking Water Hotline: (800) 426-
4791

Drinking Water Best Management Practices for Schools
and Childcare Facilities Served by Municipal Water
Systems (EPA)
Provides basic information for decision-makers
as well as best management practices.

State Drinking Water and  Lead
Prevention Information Sources

State drinking water programs can describe
state-specific requirements and provide
additional guidance materials for schools. For a
complete list of State Drinking Water program
contacts and lead prevention information
sources, see:

Implementing the Lead Public Education Provision of
the Lead and Copper Rule for Non Transient, Non
Community Water Systems, Appendix C:

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http://water.epa.gov/lawsregs/rulesregs/
sdwa/lcr/upload/Implementing-the-Lead-
Public-Education-Provisions-of-the-Lead-and-
Copper-Rule-A-Guide-for-Non-Transient-Non-
Community-Water-Systems.pdf

Implementing the Lead Public Education Provision
of the Lead and Copper Rule for Community Water
Systems, Appendix C:
http://water.epa.gov/lawsregs/rulesregs/
sdwa/lcr/upload/Implementing-the-Lead-
Public-Education-Provisions-of-the-Lead-and-
Copper-Rule-A-Guide-for-Community-Water-
Systems.pdf
Glossary
Acidic:
The condition of water or soil which contains a
sufficient amount of acidic substances to lower
the pH below 7.0.

Action Level:
The level of lead or copper which, if exceeded,
triggers treatment or other requirements that a
water system must follow.

Alkalinity:
The capacity of water to neutralize acids.
This capacity is caused by the water's content
of carbonate, bicarbonate, hydroxide and
occasionally borate,  silicate and phosphate.
Alkalinity is  expressed in milligrams per liter of
equivalent calcium carbonate.  Alkalinity is not
the same as pH because water does not have
to be strongly basic  (high pH)  to have a high
alkalinity. Alkalinity is a measure of how much
acid can be added to a liquid without causing a
significant change in pH.

Alloy:
A solution made of  two or more elements, at
least one of which is a metal.
Backflow:
A reverse flow condition created by a difference
in water pressures which causes water to flow
back into the distribution pipes of a potable
water supply from any source or sources other
than an intended source.

Backwashing:
The process of reversing the flow of water
back through the filter media to remove the
entrapped solids.

Bacteria:
Microscopic living organisms usually consisting
of a single cell. Bacteria can aid in pollution
control by consuming or breaking down
organic matter in sewage or by similarly acting
on oil spills or other water pollutants. Some
bacteria in soil, water or air may also cause
human, animal and plant health problems.

Compliance:
The act of meeting all state  and federal drinking
water regulations.

Contaminant:
Anything found in water (e.g., microorganisms,
minerals, chemicals, radionuclides, etc.) which
may be harmful to human health.

Corrosion:
The gradual decomposition  or destruction
of a material by chemical action often due to
an electrochemical reaction. Corrosion may
be caused by: 1) stray current electrolysis, 2)
galvanic corrosion caused by dissimilar metals
or 3) differential concentration cells. Corrosion
starts at the surface of a material and moves
inward.

Corrosivity:
A condition of water quality which will dissolve
metals at an excessive rate. The factors that
make water corrosive include an acidic pH,
low alkalinity, high dissolved solids and higher
temperature.

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Cross Connection:
Any actual or potential connection between
a drinking (potable) water system and an
unapproved water supply or other source of
contamination. For example, if you have a
pump moving non-potable water and hook
into the ground water system to supply water
for the pump seal a cross-connection or mixing
between the two water systems can occur.
This mixing may lead to contamination of the
drinking water.

Descaler:
A solution used to remove and/or prevent
limescale and fouling on water taps, kettles,
coffeemakers, toilets and water pipes.

Disinfectant:
A chemical (commonly chlorine, chloramine
or ozone) or physical process (e.g., ultraviolet
light) that kills microorganisms such as bacteria,
viruses and protozoa.

Distribution System:
A network of pipes leading from a treatment
plant to customers' plumbing systems or the
pipes and plumbing within a building that
distribute water to all of the water outlets.

Ground Water:
The water that systems pump and treat from
aquifers (natural reservoirs below the earth's
surface).

Lead Service Line:
A service line made of lead which connects
the water main to the building inlet and any
lead pigtail, gooseneck or other fitting which is
connected to such a lead line.

Monitoring  Program:
Testing that water systems must perform  to
detect and measure contaminants.  Specifically
measuring concentrations of certain substances
within environmental media (e.g., drinking
water) at regularly scheduled intervals.
Municipal Water System:
A network of pipes, pumps and storage and
treatment facilities designed to deliver potable
water to homes, schools, businesses and other
users in a city or town.

Non-Potable Water:
Water that may contain objectionable pollution,
contamination, minerals or infective agents and
is considered unsafe and/or unpalatable for
drinking.

Pathogen:
A disease-causing organism.

PH:
A measurement of how acidic or basic a
substance is. It ranges from 0 to 14. A pH of
7 is neutral.  A pH less than 7 is acidic, and a
pH greater than 7 is basic.

Point-of-Entry Device:
A treatment device applied to the drinking
water entering a house or building for the
purpose of reducing contaminants in the
drinking water distributed throughout the house
or building.

Point-of-Use Device:
A treatment device applied to a single tap used
for  the purpose of  reducing contaminants in
drinking water at that one tap.

Potable Water:
Water that is safe and satisfactory for drinking
and cooking.

Public Water System:
A system for the provision to the public of
water for human consumption through pipes or
other constructed conveyances, if such system
has  at least 15 service connections or regularly
serves at least 25 individuals.

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Remediation:
Removal of pollution or contaminants from
environmental media such as soil, ground
water, sediment or surface water for the
general protection of human health and the
environment.

Samples:
The water that is analyzed for the presence of
EPA-regulated drinking water contaminants.
Depending on the regulation, EPA requires
water systems and states to take samples from
source water, from water leaving the treatment
facility or from the taps of selected consumers.

Soft Water:
Water having a low concentration of polyvalent
cations,  such as calcium and magnesium
ions. According to U.S. Geological Survey
guidelines, soft water is water having a hardness
(concentration of polyvalent cations) of 60
milligrams per liter or less.

Solder:
A metallic compound used to seal the joints
between pipes.  Until recently, most solder
contained 50% lead. The use of lead solder
containing more than 0.2% lead is now
prohibited for pipes carrying potable water.

Source Water:
Water in its natural state prior to any treatment
for drinking.

Toilet Dam:
A water-conservation device that is placed
inside the tank portion of a toilet to reduce
the amount of water the tank will hold by
partitioning off part of the tank.

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