Lead Testing in Schools Training Workshop -

“Testing”

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY WATER SUPPLY DIVISION

Testing

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Module 4:Developing a Sample Plan

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Developing a Sampling Plan

• Conduct a “Walkthrough” of the facility.• Determine Sampling Locations.• Select a Laboratory for Drinking Water Sample

Analysis.• Determine your Sampling Frequency.• Understand the Sampling Procedures.

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Conduct a Walkthrough

• Understand how the drinking water enters and flows through the facilities.

• Identify the building’s plumbing products.• Identify common drinking water outlets.• Map building with all drinking water outlets and

plumbing materials.• Quick Tip – Try and utilize a customer service

inspector or a local plumber to assist in identifying plumbing materials and create a plumbing profile.

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Common Drinking Water Outlets

• Water Coolers• Drinking Water Fountains

• Other term: Water Bubblers• Cold water taps

• Kitchen, breakroom, etc.• Ice makers

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Pre-Sampling Inspection

• Inventory all Drinking Water Sinks and Fountains.• Inspect the visible plumbing of these fixtures by

looking inside cabinets and under sinks.• Document if faucets have screens/aerators.

•Do not remove them for lead sampling.

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Pre-Sampling Inspection

• Inventory all Drinking Water Sinks and Fountains.• Check all water coolers to ensure they do not

have a lead lined tank.•Lead Contamination Control Act (LCCA)•3Ts, Appendix B

Guidance as to which model fountains contain lead and should be removed.

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Plumbing Profile

• Questionnaire:• Date of construction.• Identify building water

lines.• Determine the layout

and route cold water takes after it leaves the entry point and the direction cold water travels through the building.

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Plumbing Profile (cont.)

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Determine Sampling Locations

• To create a sampling plan you will have to take all the information gathered in the plumbing survey.• Including the different types of water outlets to decide where you are going to sample.

• Determine how to prioritize sample sites based on considerations such as:•Plumbing materials.•Use of the outlet.

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Identify Sample Locations

• Select drinking water fixtures for sampling.• Every outlet regularly used for drinking or

cooking should be sampled.• Priority is given to drinking fountains that are

primarily accessed by children.

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Priority Sampling Outlets

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Water Cooler Drinking Water Bubbler Classroom Sink

Kitchen Sinks Teacher’s Lounge Sinks Nurse’s Office Sink

Additional Locations

• The following sink types should be noted, but are not generally used for drinking water.

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Art/Science Room sinks Bathroom Sinks

Label Sample Locations

• Develop a code system:•Assign a unique sample site identification (ID) number that states the type of fixture and location.

•Example: Water Cooler in classroom 110 could be labeled as “Room 110 WC”.

• Label each site on a map of the facility.

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Selecting a Laboratory

• Select an accredited laboratory approved to conduct lead in drinking water analysis.• https://www.tceq.texas.gov/assets/public/complian

ce/compliance_support/qa/txnelap_lab_list.pdf• Verify the matrix is “Drinking Water” and that

“Lead” analysis is available.

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Selecting a Laboratory

• Questions to ask:• Is the laboratory accredited for analyzing lead

in drinking water?• Can the laboratory conduct sampling as well as

analysis?• Is there an increase in price if sampling occurs

on weekends or other times outside of normal business hours?

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Selecting a Laboratory

• Questions to ask (cont.)• What is the laboratory’s time frame for

providing sample results?• What is the cost of the laboratory services and

what is included?

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Selecting a Laboratory

• Other Considerations:• Contact other laboratories to compare prices

and services.• Recommend establishing a written agreement

or contract for all the services to be provided.• Potentially work with other schools/districts to

coordinate sample events for a bulk price.

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Determine Sampling Frequency

• Document the sampling frequency chosen, based on:• Plumbing materials• Water quality• Lead results• Remediation efforts• Budget

• EPA recommends sampling on an annual basis.

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Understanding the Sampling Procedures

• Who should collect the 3Ts samples?• Individuals that have been trained on proper

sample collection procedures, such as:•Laboratory personnel.•Public water system operators.•School employees after training.

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Understanding the Sampling Procedures (Cont.)

• What is the recommended sample volume?• EPA recommends the use of small samples.• 250 milliliters (mL)• Represents a smaller section of plumbing

which can help identify the source of lead in the outlet.

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Understanding the Sampling Procedures (Cont.)

• What are the recommended types of samples:• First-draw samples (Step 1 sample).• Flush samples (Step 2 sample).• Sequential samples.

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“First-draw” Samples

• Collected in the morning at outlets that are used for drinking or cooking.

• Water must have been siting still in the pipes all night • At least 8 hours, but not more than 18 hours.

• EPA strongly recommends that schools collect a first-draw sample for all fixtures used for consumption.

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“Flush” Samples

• Collecting water after the water has been running from the fixture for a pre-determined length of time.• Generally 30 seconds.

• Helps to determine if lead is coming from the fixture or from the interior plumbing.

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“Sequential” Samples

• Collecting multiple water samples at a single fixture, without flushing beforehand or running water between samples.• A series of samples collected at the same time.

• Helps to determine if lead is from the fixture or from the interior plumbing.• Sampling method used in a “Detailed Fixture

Evaluation” to pinpoint potential source of lead. • Appendix D of the 3Ts.

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Understanding the Sampling Procedures (Cont.)

• When should samples be collected?• Before the facility opens and before any water

is used.• Unused for at least 8 hours but not more than

18 hours old.• EPA does not recommend collecting samples

after a long break or after the water has been stagnate for too long.

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Understanding the Sampling Procedures (Cont.)

• When should I take action?• There is no safe level of lead for children.• EPA encourages schools to prioritize

remediation efforts based on sample results.• Develop a plan of action to respond to levels of

lead above a school set action level.•Remediation requirements.•Removing outlet from use.•Communication to stakeholders.

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Understanding the Sampling Procedures (Cont.)

• When should I take action?• EPA recommends that schools prioritize

remediation of drinking water outlets with the highest levels of lead.

• Quick Tip – EPA under the Lead and Copper Rule designated a level of 15 parts per billion of lead based on the 90th percentile for public water systems to take additional actions.

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Module 5:Conducting Sampling & Interpreting Results

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Conducting Sampling and Interpreting Results

• 2-Step Sampling at the Tap• Step 1: Initial First-Draw Samples• Step 2: Follow-up Flush Samples

• Sampling Dos and Don’ts

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2-Step Sampling at the Tap

• The EPA 3Ts recommends a 2-step sampling process to identify whether lead is an issue and to pinpoint potential lead sources (i.e., the fixture or interior plumbing).• Step 1 - 250-mL “First-draw” sample• Step 2 - 250- mL “Flush” sample

• Both samples can be collected during the same event but not be analyzed unless lead is found in the first-draw sample.

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Step 1 – First-draw Sample

• Procedures• Collect before facility opens and before fixture is

used (8-18 hours stagnation period)• One 250 –mL sample bottle that is prelabeled

should be collected at each location• Sample from cold water tap• Make note of any fixtures that are leaking.

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Step 1 – First-draw Sample

• Procedures• Compare all sample results to prioritize follow-

up sampling and remediation. • Outlets with elevated lead levels should not be

made available for consumption.

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Step 1 – First-draw Sample

• After the water has sat for 8-18 hours, collect 250 mL first draw samples from water outlets to determine lead occurrence.•This type of sample focuses on the fixture itself.

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Step 1 – First-draw Sample (cont.)

• Fill the bottle to the line marked “250 mL” and then turn the water off. Cap the bottle tightly.

• Fill out laboratory chain of custody form.• Send samples to accredited laboratory chosen.

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Step 2- Flush Sample

• If the initial test shows lead levels over the school’s designated action level, a flush test can determine if the lead contamination results are from the interior plumbing components.

• You may collect this flush sample at the same time as the first-draw sample (simultaneous samples).

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Step 2 – Flush Sample (Simultaneous Samples)

• After collecting the 250 mL first draw (initial) sample from the water outlet.

• Collect a second 250 mL sample immediately after the first one is filled.

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Step 2 – Flush Sample(Single Sample)

• After the water has sat for 8-18 hours, let the water run for 30 seconds to flush the fixture.

• Collect a 250 mL sample after the water has run for 30 seconds.

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Step 2 – Flush Sample (cont.)

• Fill the bottle to the line marked “250 mL” and then turn the water off. Cap the bottle tightly.

• Fill out laboratory chain of custody form.• Send samples to an accredited laboratory.

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Sampling Dos and Don’ts

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Sampling Dos and Don’ts

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Sampling Dos and Don’ts

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Sampling Dos and Don’ts

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Sampling Dos and Don’ts

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Sampling Dos and Don’ts

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Recordkeeping

• Recordkeeping is very important before, during, and following any testing that is conducted. Some suggestions for you include:• Documenting methodologies, procedures, and

best practices that were used to plan for testing.• Maintaining information about the laboratories

and/or professionals and their procedures used.• Documents any plans instituted in the process.

(i.e., flushing plans, maintenance plans, sampling schedules, etc.)

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Questions?

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