METROPOLITAN NASHVILLE PUBLIC SCHOOLS
Nashville, Tennessee

LEAD IN DRINKING WATER SAMPLING
AND ANALYSIS REPORT
Prepared for:

Metropolitan Nashville Public Schools
1417 Murfreesboro Road
Nashville, Tennessee 37219

Prepared by:

220 Athens Way, Suite 410
Nashville, Tennessee 37228
615.255.9300/1.800.588.7962
www.ensafe.com

EnSafe Project Number: 0888819011

November 8, 2016

 Table of Contents
1.0

INTRODUCTION ............................................................................................................ 1

2.0

OBJECTIVE ................................................................................................................... 1

3.0

SCOPE OF WORK .......................................................................................................... 1

4.0

SCHOOL SAMPLING PRIORITIZATION............................................................................. 2

5.0

PLANNING .................................................................................................................... 2

6.0

SAMPLING PROCEDURES ............................................................................................... 3
6.1
Preparation for Sampling ..................................................................................... 3
6.2
Sample Collection ............................................................................................... 3

7.0

LABORATORY ANALYICAL RESULTS SUMMARY ................................................................ 4
7.1
Laboratory Analytical Results for Initial Sampling Event ......................................... 5
7.2
Laboratory Analytical Results for Second Sampling Event (Resampling) ................... 5

8.0

IMPLEMENTED CORECTIVE MEASURES ........................................................................... 6

9.0

CONCLUSIONS AND RECOMMENDATIONS....................................................................... 7
9.1
Conclusions ........................................................................................................ 7
9.2
Recommendations .............................................................................................. 8

10.0

LIMITATIONS ............................................................................................................... 9
Tables

Table 1

Summary of Corrective Measures for Screening Limit Exceedances Associated
with Flush Samples Collected During Resampling .................................................. 6
Appendices

Appendix A
Appendix B

Summary of Water Sampling and Exceedance Results
Excerpt from 3Ts for Reducing Lead in Drinking Water in Schools: Revised
U.S. EPA Technical Guidance, October 2006

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 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

1.0

INTRODUCTION

EnSafe Inc. is pleased to provide this report to Metropolitan Nashville Public Schools (MNPS) for
recently completed sampling and laboratory analysis of drinking water collected from 49 MNPS
schools and administrative buildings identified by MNPS. These services were performed to develop
a baseline of lead concentrations detected in drinking water collected from taps at select MNPS
schools; specifically, taps from which water is obtained and potentially consumed or used for food
preparation. The baseline data developed through the execution of these sampling and analysis
activities is intended to help MNPS determine if future testing of water for lead concentrations or
corrective measures are needed to help mitigate the consumption of lead-impacted water.
2.0

OBJECTIVE

The objective of the sampling and laboratory analysis activities is to provide insight into lead
concentrations in drinking water samples from taps within 49 schools identified by MNPS. EnSafe
coordinated with MNPS to collect water samples from taps considered representative within
schools. These samples were then analyzed to determine if samples contained lead concentrations
of 15 micrograms per liter (ug/l) or higher. Based on the results of the sampling events, baseline
data is available such that MNPS can institute additional sampling and/or corrective measures,
if warranted. For the purpose of determining if additional sampling or corrective measures actions
are warranted, 15 ug/l was used as the action level. This concentration is the Maximum Contaminant
Level per the United States Environmental Protection Agency (U.S. EPA) National Primary
Drinking Water Regulations, and is more stringent than an action level of 20 ug/l referenced in
United States Environmental Protection Agency (U.S. EPA) Lead in Schools Guidance.
3.0

SCOPE OF WORK

The scope of work was based on meetings and correspondence with MNPS, project objectives,
familiarity with drinking water programs, and regulatory guidance.

The scope of work

was performed in general accordance with the MNPS Lead in Drinking Water Sampling Plan, dated
May 27, 2016, and included prioritization of the schools to be sampled and related planning,
collection of drinking water samples from 49 MNPS identified locations, laboratory analyses of water
samples for lead concentrations, and preparation of letter reports summarizing findings and
recommendations for each school sampled.

Per requests by MNPS, additional sampling and

analysis were performed for most drinking water taps where exceedances of the 15 ug/l action
level were detected during the initial sampling and analysis. Details regarding the scope of work
are discussed in the following sections.

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 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

4.0

SCHOOL SAMPLING PRIORITIZATION

MNPS developed an anticipated sampling plan order that proposed the anticipated order of public
schools to be sampled. This anticipated order is shown in Appendix A and was based largely on the
age of the schools. Older schools were generally favored to be sampled earlier than newer schools.
The actual order of schools being sampled varied slightly from the anticipated order. Elementary
and junior high schools were sometimes favored in priority over high schools. Other factors that
affected the order included ongoing construction, location, resources, or other facility-specific
factors. Actual sampling dates for initial sampling at each location are also shown in Appendix A.
5.0
PLANNING
Typical planning activities included preparation of a floor plan by MNPS for each school to be
sampled. An inspection (walkthrough) of the schools was conducted by Mr. Louis Burnett
(MNPS Sampling Program Manager) and/or Melissa Risch (MNPS Sampling Assistant). During the
walkthrough sampling locations (taps) were identified on the floor plan and assigned
an identification number. In addition to placing tap locations on the floor plans, a tap inventory
was prepared and provided information about each fixture (tap) such as the coinciding
identification number from the floor plan, fixture type, and location. This information was then
provided to EnSafe.
Following receipt of the floor plan and tap inventory for each school, sampling locations
were further identified (coded) by its location and type such that individual sample identifications
would indicate the type of fixture where the sample was collected. The coding system included
the following:
POE
KT
CT
FP
TL
NS
EC

Point of Entry
Kitchen Taps
Cafeteria Tap
Food Preparation Sink
Teacher Lounge Sink
Nurse's Office Sink
Home Economics Room

OW
SOW
WE
LT
AR
CF
BF

Drinking Water Bubbler
Sink with Bubbler
Water Cooler (chiller unit)
Library Tap
Art Room Tap
Classroom Faucet
Bathroom Faucet

As discussed in Section 6.2, these codes and tap locations from the floor plan were used to label
and identify each sample collected.

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 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

6.0

SAMPLING PROCEDURES

6.1

Preparation for Sampling

As part of preparation for sampling, sample containers, coolers, labels and chains of custody were
obtained from ESC Lab Sciences, a state-certified laboratory. Deionized water was also obtained from
the laboratory for use in preparation of field blank samples for quality assurance during sampling
activities at each school.

Labels for sample containers were pre-printed to include pertinent

information such as school name and parameter to be analyzed (lead). The sample identification,
date and time of collection were subsequently placed on labels during sample collection.
Identified taps were flushed for a minimum of 30 seconds by MNPS personnel approximately
6 to 18 hours prior to collection of first draw water samples. School personnel were notified of
pending sampling activities and efforts were made by MNPS to prevent use of water during the
period between flushing and sample collection. Sampling was usually performed in early morning
hours to further ensure taps were not used during the 6 to 18 hour period.
Prior to sampling, efforts were made to note if water at taps appeared to have been used during
the previous 6 hours. Water leaks at a tap or other similar observations were also documented.
6.2

Sample Collection

Initial sampling at individual schools was performed from June 1, 2016 to October 5, 2016 and
included collection of “first draw” samples from each tap identified by MNPS for sampling.
A "first draw sample" is the water initially discharged from a tap after the period of inactivity.
To minimize movement or disturbance of water within the plumbing infrastructure, sampling
activities were typically initiated at the tap believed closest to the water supply line point of entry
(POE) into the school as determined by MNPS, and continued in a general manner in which taps
believed to be furthest downstream from the water supply POE were sampled last.

Identified

bathroom taps were sampled unless a bathroom contained multiple taps which appeared to use the
same plumbing and/or equipped with similar fixtures, in which case only one representative tap
was typically sampled. For sinks where there was an operational bubbler, efforts were made to
collect a water sample from the bubbler instead of the sink faucet.

First draw water samples

(undisturbed within piping for a minimum of 6 hours, if possible) were collected by placing a
laboratory-supplied sample container under the tap before turning on the cold water allowing water
to flow into the container. Each sample container was properly identified/labeled and submitted to
the laboratory for analysis under appropriate chain of custody procedures.

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 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

Following their receipt, laboratory analytical results for first draw samples were reviewed and
compared to the action level of 15 ug/l for lead in drinking water, and MNPS was notified of the
results for each school. As requested by MNPS, a second set of samples were collected at taps
where concentrations equal to or greater than the action level were reported by the laboratory,
and in some cases samples from adjacent taps were also collected. Similar to the initial sampling
process, taps identified to be resampled were flushed for a minimum of 30 seconds by MNPS
personnel approximately 6 to 18 hours prior to collection of the second set of samples.
The samples collected during this resampling included a first draw sample and a flush sample from
the tap.

First draw samples during this resampling were collected using the same procedure

as described for initial sampling activities. Flush samples were also collected using a method similar
to the first draw sampling method with the exception of flushing the respective tap for a minimum
of approximately 30 seconds prior to collecting the sample.
Each sample collected was properly identified on the laboratory supplied sample container and
chain of custody. The sample identification (sample number) included the type of tap feature, as
discussed in Section 5.0 (i.e., CF, BF, KT, SOW, etc.), and the tap location number identified on the
school floor plan. In addition, the sample identification for first draw samples included a “FD” suffix
and flush samples were identified utilizing a “FL” suffix. An example of a sample identification is
BF-3-FD, which indicates a first draw sample collected from bathroom faucet number 3. Another
example is TL-1-FL, which indicates a flush sample collected from teacher lounge sink number 1.
For first draw samples collected during a resampling event, a “-2” was placed at the end of the
sample identification.
Quality assurance samples were also collected as part of the sampling effort, and included
collection of duplicate and field blank samples. One duplicate sample was typically collected per
10 drinking water samples (10%) at each school, and one field blank sample was prepared/collected
per school.
Water samples were transported under chain-of-custody control to ESC Lab Sciences, a state-certified
laboratory and analyzed for dissolved lead concentrations using U.S. Environmental Protection
Agency Method 200.8.
7.0

LABORATORY ANALYICAL RESULTS SUMMARY

Details for each individual school regarding the taps sampled and laboratory analytical results
reported for each sample are presented in individual letter reports submitted in conjunction with
this document.
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 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

7.1

Laboratory Analytical Results for Initial Sampling Event

Following receipt of laboratory analytical results for initial first draw samples collected at each
school, results were reviewed and compared to the action level, and MNPS was notified of the
results for each school. Of particular concern were reported lead concentrations of the action level
(15 ug/l) or higher.

These are identified as “exceedances.”

One or more exceedances were

reported in 32 of the 49 schools where samples were collected with a total of 81 exceedances
reported for the 49 schools sampled. The number of taps in schools where exceedances were
reported ranged from 1 to 10 per school. Taps where exceedances were reported in samples
included bathroom faucets, classroom faucets, kitchen and cafeteria taps, and sinks with bubblers,
as well as other tap types. Exceedances ranged from 15.0 ug/l detected in a sample from a sink
with a bubbler in the Baxter Alternative Learning Center School, to 1,190 ug/l detected in a sample
collected from a bathroom faucet in Hillwood High School. A summary of the schools, numbers of
samples and exceedances, sample identifications where exceedances were reported, and reported
exceeding concentrations is shown in Appendix A.
7.2

Laboratory Analytical Results for Second Sampling Event (Resampling)

As requested by MNPS, a second set of samples were collected from taps where exceedances were
reported, and in some cases samples from adjacent taps were also collected and submitted for
analysis.

An exception was Hume Fogg Magnet School where an exceedance was reported;

however, due to ongoing construction and replacement of plumbing systems at this location, MNPS
requested the tap not be resampled. Water samples collected during resampling of the 31 schools
in which an exceedance was reported, included a first draw sample and a flush sample from
the identified tap(s). One or more exceedances were reported in first draw samples from 17 of
the 31 schools where resampling was performed. The number of taps in schools where
exceedances were reported ranged from 1 to 4 per school. Taps where exceedances were reported
in samples included bathroom faucets, classroom faucets, kitchen and cafeteria taps, and sinks with
bubblers, as well as other tap types. Exceedances ranged from 15.0 ug/l detected in a sample
from a kitchen tap in Eakin Elementary School, to 260 ug/l detected in a sample from a bathroom
faucet in Hillwood High School.

A summary of the schools, samples and exceedances, sample

identifications and exceeding concentrations is shown in Appendix A.
Regarding flush sample results, either 1 or 2 exceedances were reported in flush samples from 4 of
the 31 schools where resampling was performed. Taps where flush samples were reported with
exceedances included an office faucet, classroom faucet, teacher lounge sink, water cooler, and
sink with bubbler. Exceedances ranged from 18.2 ug/l reported in a sample from an office sink in
Cameron College Prep School, to 738 ug/l reported in a sample collected from a teachers lounge
sink in the Cohn School.
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 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

8.0

IMPLEMENTED CORECTIVE MEASURES

Upon receipt of laboratory analytical results for samples collected at each school, the results were
reviewed by EnSafe and MNPS was notified of the results. Of particular concern were reported lead
concentrations exceeding the action level.

One notable concentration was 294 ug/l reported in a

sample from a drinking water bubbler (identified as location 30) at Dupont Elementary School (Dupont).
This bubbler shared a sink and plumbing with an adjacent bubbler (identified as location 29).
As a corrective measure, MNPS quickly responded and removed these taps.

Another corrective

measure resulted from a screening limit exceedance reported for a sample collected from a sink in
an administrative office at Cameron College Prep School (Cameron). This tap was also taken offline
as a corrective measure.
As previously discussed, resampling of taps was completed where exceedances were reported
during initial sampling. Resampling activities included collection of both first draw samples and
flush samples.

Based on a review of the laboratory analytical results, flushing appears to

significantly reduce reported lead concentrations in most taps.

Specifically, exceedances were

reported in only 5 of 78 flush samples collected and analyzed from taps where exceedances had
previously been detected in initial first draw samples.

In response to the 5 flush sample

exceedances, which suggested flushing may not effectively reduce lead concentrations to
acceptable levels in these particular taps,

MNPS implemented corrective measures.

Corrective

measures implemented at these locations, as well as the Dupont and Cameron locations (described
above), are summarized in Table 1.
Table 1
Summary of Corrective Measures for Screening Limit Exceedances
Associated with Flush Samples Collected During Resampling
Tap Location
School
Tap Location
Number
Tap Type
Head Middle Magnet School

Classroom

9

Classroom faucet

The Cohn School

Alumni area
Teachers’ lounge

26
36

Water fountain
Bathroom faucet

Academy at Old Cockrill

First floor hallway

12

Water fountain

Outside of kitchen
Outside of kitchen
Coaches office
Main office

29
30
22
39

Water fountain
Water fountain
Office faucet
Office faucet

Dupont Elementary School
Cameron College Prep School

6

Corrective
Measure
Tap taken
offline
Taps taken
offline
Replaced
corroded filter
Taps taken
offline
Taps taken
offline

 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

9.0

CONCLUSIONS AND RECOMMENDATIONS

9.1

Conclusions

As discussed herein, the objective of sampling and laboratory analysis activities is to provide insight
into lead concentrations in drinking water samples from taps within the 49 schools identified by
MNPS. These services were performed to develop a baseline of lead concentrations detected in
drinking water collected from taps within MNPS schools and administrative buildings; specifically,
taps from which water is potentially consumed or used for food preparation. The baseline data
obtained through the execution of these sampling and analysis activities is intended to help MNPS
determine if future testing of water for lead concentrations or corrective measures are needed to
mitigate the consumption of lead-impacted water.
Based on a review of laboratory analytical results, and as shown in Appendix A, a total of
81 exceedances were reported in approximately 2,841 first draw samples collected during the initial
sampling. Most initial sampling was performed in the first half of MNPS summer vacation when water
use in the schools was reportedly less than other times of the year. Most resampling of taps where
exceedances were identified during initial sampling events was performed later in the summer when
water use reportedly increased.

Only 28 exceedances were reported in the first draw samples

collected during resampling, suggesting increased water use reduces the water’s contact time within
plumbing infrastructure, and therefore reduces lead concentrations at these taps. A total of only
5 exceedances were reported for flush samples collected during resampling, further suggesting
increased water use reduces lead concentrations at these taps.

Specifics regarding sampling,

analysis, and results for each school are presented in individual reports submitted in conjunction with
this document.
U.S. EPA and other regulatory literature indicate interior plumbing, soldered joints, leaded brass
fittings, and various drinking water taps containing lead materials are primary contributors of lead
in drinking water. Sediments containing lead may also collect in the low-lying sections of pipe or
behind sediment screens and also serve as a source of lead. Lead-containing sediments may result
from minute particles of pipe, mineral deposits (scales), valves, fixtures, solder, or flux that
accumulate in the plumbing. The potential for lead to leach into water can increase with longer
contact time between water and lead containing materials in the plumbing system. As such, U.S.
EPA and other regulatory literature indicates increased water use reduces lead concentrations in
drinking water, which appears to be in agreement with the subject MNPS sampling and reported
analytical results.

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 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

9.2

Recommendations

Numerous corrective measure alternatives were discussed with MNPS to address reported
exceedances and prevent future exposure to elevated lead concentrations.

These alternatives

included, in-part:


Flushing programs



Point-of-use devices (e.g., aerators, screens, filters) programs



Removal and/or replacement of problematic taps



Use only cold water for food and beverage preparation



Placard problematic taps with notices that water should not be consumed.



Alternate grounding for electrical wires grounded to water pipes to reduce the likelihood
of corrosion.



Replace lead service lines and other lead pipes.

Baseline findings reported herein and review of U.S. EPA guidance, as well as other regulatory
guidance, indicate flushing is an effective interim control measure in reducing lead concentrations.
Based on these factors and correspondence with MNPS, consideration of a flushing program is
recommended. As part of the flushing program, flushing of suspect taps immediately before and
periodically during occupancy should be performed at a minimum. Should these taps be used as a
water source for consumption, flushing for a minimum of 30 seconds immediately before use, is
also recommended. Details regarding flushing, such as frequency and duration, should be noted
and recorded during this activity to document the activities and provide insight into program
effectiveness should additional samples be collected for laboratory analysis.
Baseline findings reported herein, field observations, and review of regulatory guidance also
indicate maintaining point of use devices such as aerators, screens, and filters appears to be an
effective routine control measure in reducing lead concentrations.

Based on these factors and

correspondence with MNPS, consideration of a point of use device maintenance program is also
recommended for consideration.

Fouled filters, aerators, screens can result in elevated lead

concentrations; therefore, it is recommended such devices be regularly inspected and replaced or
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 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

maintained as needed. The condition of the devices and any debris or fouling should be noted and
recorded during this activity to provide insight into frequency of fouling and the need for cleaning
or replacement.
Where sources of lead contamination are localized and limited to a select taps, replacing these taps
or upstream components may be considered as an alternative corrective measure.

U.S. EPA

worked with the plumbing industry and National Sanitation Foundation (NSF) International,
a public health and safety company, to develop an industry standard designed to minimize amounts
of lead leaching from various taps and plumbing components. This standard is NSF Standard 61
(Sections 4, 8 and 9). Before replacing plumbing products, it is recommended that inquiries be
made regarding compliance with this standard relative to the potential for the leaching of lead from
existing plumbing components and/or infrastructure.
U.S. EPA literature indicates hot water can dissolve lead more readily than cold water. As such, it is
recommended only cold water taps be used as a drinking water source.
Additional control measures for reducing lead concentrations in drinking water are presented in the
U.S. EPA document 3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance,

October 2006. Excerpts from this document showing additional control measures are included in
Appendix B, and should also be considered as alternatives when selecting remedies, if needed.
Should a flushing program, point of use device maintenance program, or other aforementioned
alternative(s) be selected and implemented as a corrective measure, additional sampling and
analysis of the water should be discussed and performed to ensure effectiveness of the program(s).
It is considered likely these control measures will prove effective in reducing lead concentrations.
However, if laboratory results analytical indicate these measures are insufficient or ineffective in
reducing lead concentrations to acceptable levels, alternative control measures should be
implemented accordingly.
10.0

LIMITATIONS

Information presented in this report, as well as individual letter reports prepared for each
respective school, was obtained through performance of a scope of work outlined in EnSafe’s

Proposal for Drinking Water Testing Services, dated April 7, 2016, and subsequent correspondence
with MNPS. Report users should recognize sampling or testing activities are inherently limited, in
that conditions at sampling locations and related concentrations and chemistry may vary from those
when samples were obtained.

EnSafe’s ability to interpret results and draw conclusions and
9

 Lead in Drinking Water Sampling and Analysis Report
Metropolitan Nashville Public Schools
Nashville, Tennessee
November 8, 2016

recommendations is similarly limited. EnSafe has conducted the professional assessment services
with a level of care and skill consistent with generally accepted environmental consulting industry
standards.

Report results and findings apply solely to conditions existing at the time EnSafe

obtained samples or conducted tests.
Only the party for whom this report was originally prepared and/or other parties specifically named
in our proposal have the right to make use of and rely upon this report. Reuse of this report, or
any portion thereof, for other than its intended purpose shall be at the user’s sole risk. Except as
specifically described in our proposal, EnSafe makes no representation as to the accuracy or
completeness of information prepared by other parties. Conditions in other parts of the MNPS
locations and water supply systems may vary from those at the locations where data
were collected.

As such, EnSafe does not provide any guarantees, certifications, or

warranties regarding the extent of environmental contamination, contaminant sources, or corrective
measures on the MNPS sites. These limitations apply to this report, and the individual letter reports
prepared for each MNPS school and administration building. These individual reports are part of
this deliverable package.

10

 Appendix A
Summary of Water Sampling and Exceedance Results

SUMMARY OF DRINKING WATER SAMPLING AND EXCEEDANCE RESULTS
Inital Sampling Event

Anticipated
Sampling Order
1
2
3
4

School/Location
Warner Elementary E.O.
Eakin Elementary
Buena Vista Elementary E.O.
Sylvan Park Elem. Paideia Design Ctr

ORIGINAL
CONST. DATE
1919
1928
1931
1935

Second Sampling Event (Resampling)

TOTAL SAMPLES
FIRST DRAW AT
OR ABOVE 15
INITIAL
TOTAL FIRST
EXCEEDANCE SAMPLE IDENTIFICATION
ug/l
SAMPLING DATE DRAW SAMPLES*
AND CONCENTRATION (ug/l)
6/1/2016
50
0
6/2/2016
110
1
KT-32-FD (17.0 ug/l)
6/3/2016
50
1
BF-38-FD (48.7 ug/l)
6/7//2016
75
1
CF-69-FD (17.3)
CF-02-FD (135 ug/l)
CF-04-FD (150 ug/l)
CF-04-FD-D (196 ug/l)
6/8/2016
104
3
6/9/2016
66
0

5
6

Waverly-Belmont ES
Jones Elem. Paideia Magnet

1935
1936

7

Martin Professional Development Ctr

1936

6/10/2016

25

2

8
9
10

Caldwell Elementary E.O.
Lockeland Elem. Design Center
Green, Julia Elementary

1937
1939
1948

6/14/2016
6/10//2016
6/16/2016

79
43
82

2
0
0

11
12

DuPont Elementary
Kirkpatrick Elementary E.O.

1951
1952

6/16/2016
6/14/2016

55
54

2
0

13

Tusculum Elementary

1952

6/17/2016

52

2

14
15
16

Glendale Elem. Spanish Immersion
Neely's Bend Elementary
Crieve Hall Elementary

1953
1953
1954

6/15/2016
6/17/2016
6/15/2016

58
65
74

2
1
0

17

Goodlettsville Elem.

1954

6/21/2016

65

4

18

Rosebank Elementary

1954

7/20/2016

38

2

19
20

Bordeaux Early Learning Center
McGavock Elementary

1955
1955

6/21/2016
6/22/2016

55
49

2
0

21
22
23
24
25
26

Baxter ALC (Liberty Collegiate Acad.)
Hume-Fogg High Magnet
Bailey STEM Magnet Middle
Robertson Academy (G/T)
McCann (Nashville Preparatory)
Litton, Isaac Middle

1910
1912
1929
1936
1936
1938

6/22/2016
10/5/2016
6/23/2016
6/23/2016
6/24/2016
6/24/2016

34
60
64
19
17
59

2
1
1
0
1
0

OF-28-FD (22.1 ug/l)
CF-31-FD (15.1 ug/l)
SOW-13-FD (44.2 ug/l)
SOW-26-FD (33.7 ug/l)
KT-32-FD (15.6 ug/l)
OW-30-FD (294 ug/l)
SOW-41-FD (21.8 ug/l)
SOW-42-FD (23.8 ug/ll)
KT-01-FD (15.3 ug/l)
SOW-47-FD (25.8 ug/l)
KT-44-FD (15.2 ug/l)
AR-44-FD (29 ug/l)
CF-39-FD (24.8 ug/l)
BF-05-FD (23.9 ug/l)
BF-12-FD (27.8 ug/l)
SOW-30-FD (60.1 ug/l)
SOW-01-FD (41.9 ug/l)
KT-04-FD (19.9 ug/l)
KT-48-FD (18.9 ug/l)
SOW-09-FD (15.0 ug/l)
BF-18-FD (31.6 ug/l)
AR-15-FD (15.7 ug/l)
CF-08-FD (16.2 ug/l)
CT-19-FD (64 ug/l)

BF-86-FD
BF-76-FD
BF-71-FD
BF-06-FD
CF-51-FD
27

DuPont Hadley Middle

1939

6/29/2016

83

5

28

West End Middle

1939

6/29/2016

83

3

29
30
31
32

Cameron (Cameron College Prep)
McGruder Family Res. Ctr (Old J. Early)
Dalewood (currently has Goodlettsville MS)
Antioch MS Alumni Bldg (a)

1939
1940
1949
1949

6/30/2016
6/30/2016
7/1/2016
7/12/2016

52
18
64
4

2
0
0
0

33
34
35
36
37

Brick Church (old ) Middle
Antioch Middle (a)
Joelton Middle (a)
Central Alumni Bldg (a)
Madison Middle (a)

1949
1950
1950
1950
1951

7/12/2016
7/13/2016
7/14/2016
9/16/2016
7/14/2016

31
86
46
5
86

2
1
1
0
1

38

Head Middle Magnet

1952

7/15/2016

50

3

May 16, 2016

SECOND
SAMPLING DATE
NA
6/10/2016
6/10/2016
6/16/2016

TOTAL RESAMPLE
FIRST DRAW &
FLUSH
2
4
2

TOTAL RESAMPLE
FIRST DRAW AT OR
ABOVE 15 ug/l
1
0
0

6/23/2016
NA

4
-

2
-

6/24/2016

4

1

8/19/2016
NA
NA

4
-

0
-

8/17/2016
NA

2
-

0
-

7/29/2016

4

2

7/28/2016
8/16/2016
NA

4
2
-

0
1
-

8/16/2016
9/14/2016
8

1

8/19/2016

4

0

7/29/2016
NA

4
-

0
-

9/9/2016

4

0

8/19/2016
NA
8/16/2016
NA

2
2
-

0
0

(22.9 ug/l)
(23.7 ug/l)
(16.6 ug/l)
(101 ug/l)
(137 ug/l)

KT-20-FD (29.9 ug/l)
BF-49-FD (30.3 ug/l)
CF-54-FD (21.7 ug/l)
OF-22-FD (39.3 ug/l)
BF-36-FD (18.7 ug/l)

KT-16-FD (17.6 ug/l)
KT-17-FD (22.4 ug/l)
CF-40-FD (22.7 ug/l)
CT-38-FD (21.9 ug/l)
AR-62-FD (26.5)
CF-09-FD (103 ug/l)
KT-21-FD (64.8 ug/l)
CF-47-FD (17.6 ug/l)

RESAMPLE FIRST DRAW
IDENTIFICATION AND
CONCENTRATION (ug/l)
KT-32-FD-2 (15.0 ug/l)
BF-38-FD-2 (0.58 ug/l)
CF-69-FD (3.31)
CF-02-FD-2 (88.2 ug/l)
CF-04-FD-2 (144 ug/l)
OF-28-FD-2 (13.4 ug/l)
CF-31-FD-2 (15.3 ug/l)
SOW-13-FD-2 (14.5 ug/l)
SOW-26-FD-2 (6.23 ug/l)

KT-32-FD-2 (13 ug/l)
SOW-41-FD-2 (16.8 ug/l)
SOW-42-FD-2 (23.2 ug/l)
KT-01-FD-2 (2.08 ug/l)
SOW-47-FD-2 (1.55 ug/l)
KT-44-FD-2 (20.7 ug/l)
AR-44-FD-2 (3.25 ug/l)
BF-05-FD-2 (3.39 ug/l)
BF-12-FD-2 (13.4 ug/l)
CF-39-FD-2 (28.5 ug/l)
SOW-30-FD-2 (1.71 ug/l)
SOW-01-FD-2 (2.01 ug/l)
KT-04-FD-2 (7.4 ug/l)
KT-48-FD-2 (2.34 ug/l)
SOW-09-FD-2 (2.55 ug/l)
BF-18-FD-2 (4.25 ug/l)
CF-08-FD-2 (12.6 ug/l)
CT-19-FD-2 (1.32 ug/l)

8/17/2016

10

2

7/28/2016

6

2

8/19/2016
9/16/2016
NA
NA
NA

4
-

1

BF-86-FD-2 (0.538 ug/l)
BF-76-FD-2 (0.423 ug/l)
BF-71-FD-2 (33.9 ug/l)
BF-06-FD-2 (33.1 ug/l)
CF-51-FD-2 (0.404 ug/l)
KT-20-FD-2 (23.1 ug/l)
BF-49-FD-2 (6.81 ug/l)
CF-54-FD-2 (18.5 ug/l)
OF-22-FD-2 (5.65 ug/l)
BF-36-FD-2 (4.11 ug/l)
OF-39-FD-2 (28.4 ug/l)

9/14/2016
9/9/2016
9/14/2016
NA
8/16/2016

4
2
2

0
0
1

KT-16-FD-2 (1.37 ug/l)
KT-17-FD-2 (1.81 ug/l)
CF-40-FD-2 (0.308 ug/l)
CT-38-FD-2 (19.7 ug/l)

2

1

8/16/2016

6

1

AR-62-FD-2 (26.5 ug/l)
CF-09-FD-2 (214 ug/l)
KT-21-FD-2 (1.15 ug/l)
CF-47-FD-2 (11.9 ug/l)

TOTAL RESAMPLE FLUSH AT OR
ABOVE 15 ug/l
0
0
0

0
0
0
0
0
0
0
-

0

0
0
0
0
0

RESAMPLE FLUSH IDENTIFICATION
AND CONCENTRATION (ug/l)
KT-32-FL (3.99 ug/l)
BF-38-FL (ND)
CF-69-FL (0.614)
CF-02-FL (3.56 ug/l)
CF-04-FL (4.29 ug/l)
OF-28-FL (6.13 ug/l)
CF-31-FL (10.5 ug/l)
SOW-13-FL (4.91 ug/l)
SOW-26-FL (0.832 ug/l)

KT-32-FL (7.96 ug/l)
SOW-41-FL (9.96 ug/l)
SOW-42-FL (1.98 ug/l)
KT-01-FL (0.372 ug/l)
SOW-47-FL (0.271 ug/l)
KT-44-FL (3.34 ug/l)
AR-44-FL (0.149 ug/l)
BF-05-FL (0.331 ug/l)
BF-12-FL (0.526 ug/l)
CF-39-FL (1.05 ug/l)
SOW-30-FL (3.82 ug/l)
SOW-01-FL (1.86 ug/l)
KT-04-FL (0.455 ug/l)
KT-48-FL (1.08 ug/l)
SOW-09-FL (0.487 ug/l)
BF-18-FL (0.752 ug/l)
CF-08-FL (1.03 ug/l)
CT-19-FL (0.337 ug/l)

BF-86-FL (0.298 ug/l)
BF-76-FL (ND)
BF-71-FL (2 ug/l)
BF-06-FL (1.49 ug/l)
CF-51-FL (0.287 ug/l)
0

1

KT-20-FL (0.903 ug/l)
BF-49-FL (0.33 ug/l)
CF-54-FL (0.862 ug/l)
OF-22-FL (18.2 ug/l)
BF-36-FL (2.81 ug/l)
OF-39-FL (0.266 ug/l)

0
0
0

KT-16-FL (ND)
KT-17-FL (0.276 ug/l)
CF-40-FL (ND)
CT-38-FL (1.74 ug/l)

0

0

1

AR-62-FL (1.03 ug/l)
CF-09-FL (85.8 ug/l)
KT-21-FL (ND)
CF-47-FL (1.97 ug/l)

1

 SUMMARY OF DRINKING WATER SAMPLING AND EXCEEDANCE RESULTS
Inital Sampling Event

Anticipated
Sampling Order

School/Location

ORIGINAL
CONST. DATE

Second Sampling Event (Resampling)

TOTAL SAMPLES
FIRST DRAW AT
OR ABOVE 15
INITIAL
TOTAL FIRST
ug/l
SAMPLING DATE DRAW SAMPLES*

EXCEEDANCE SAMPLE IDENTIFICATION
AND CONCENTRATION (ug/l)
BF-18-FD (75.4 ug/l)
CF-05-FD (18.5 ug/l)
KT-38-FD (28.5 ug/l)

39

Donelson Middle (a)

1953

7/13/2016

78

3

40

Johnson ALC & MNPS Middle ALC

1954

7/15/2016

36

2

KT-04-FD (105 ug/l)
SOW-35-FD (37.1 ug/l)

3

BF-10-FD (51.9 ug/l)
CF-108-FD (30.9 ug/l)
CF-112-FD (19.7 ug/l)

41

McKissack Middle

1954

7/20/2016

96

SECOND
SAMPLING DATE

TOTAL RESAMPLE
FIRST DRAW &
FLUSH

TOTAL RESAMPLE
FIRST DRAW AT OR
ABOVE 15 ug/l

RESAMPLE FIRST DRAW
IDENTIFICATION AND
CONCENTRATION (ug/l)

9/9/2016

6

1

9/9/2016

4

0

BF-18-FD-2 (11.5 ug/l)
CF-05-FD-2 (7.24 ug/l)
KT-38-FD-2 (16.1 ug/l)
KT-04-FD-2 (4.11 ug/l)
SOW-35-FD-2 (14.1 ug/l)

1

BF-10-FD-2 (2.32 ug/l)
CF-108-FD-2 (21.1 ug/l)
CF-112-FD-2 (0.479 ug/l)

8/16/2016

6

The Cohn School
East Nashville Magnet (a)
King, Martin Luther Jr. Magnet

1928
1932
1936

7/26/2016
7/27/2016
7/21/2016

71
94
85

10
0
0

CF-04-FD (198 ug/l)
BF-03-FD (41.3 ug/l)
BF-03-FD-D (57 ug/l)
WE-12-FD (32.6 ug/l)
OW-21-FD (75.3 ug/l)
BF-18-FD (24.9 ug/l)

45
46

The Academy at Old Cockrill (a)
Administration Bldg (Central Office)

1939
1942

7/21/2016
10/7/2016

19
52

6
0

8/16/2016
9/9/2016
NA
-

8/17/2016
9/16/2016
NA

20

Hillwood High
Operations Bldg (Central Office)

1953
1953

7/28/2016

115

7

49

Hillsboro High

1955

7/29/2016

85

2

TOTALS OF ALL SCHOOLS SAMPLED

81

AR-56-FD (43.5 ug/l)
CF-106-FD(15.9 ug/l)

0
0

BF-18-FL (3.48 ug/l)
CF-05-FL (0.800 ug/l)
KT-38-FL (0.598 ug/l)
KT-04-FL (0.605 ug/l)
SOW-35-FL (3.02 ug/l)

0

BF-10-FL (0.309 ug/l)
CF-108-FL (2.11 ug/l)
CF-112-FL (ND)

BF-02-FL (1.38 ug/l)
BF-26-FL (1.17 ug/l)
BF-28-FL (9.62 ug/l)
SOW-29-FL (21.9 ug/l)
OF-83-FL (4.93 ug/l)
TL-36-FL (738 ug/l)
BF-48-FL (9.9 ug/l)
BF-52-FL (2.08 ug/l)
BF-53-FL (0.728 ug/l)
BF-72-FL (2.6 ug/l)
2

4

CF-04-FL (12.1 ug/l)
BF-03-FL (10.1 ug/l)
WE-12-FL (19.3 ug/l)
OW-21-FL (12.4 ug/l)
BF-18-FL (5.23 ug/l)
WE-12-FL (0.772 ug/l)

CF-04-FD-2 (55.2 ug/l)
BF-03-FD-2 (7.09 ug/l)
WE-12-FD-2 (23.8 ug/l)
OW-21-FD-2 (64.8 ug/l)
BF-18-FD-2 (100 ug/l)
WE-12-FD-2 (0.917 ug/l)
12

1

4

AR-21-FD (30.9 ug/l)
WE-110-FD (20.6 ug/l)
BF-125-FD (15.8 ug/l)
WE-101-FD (83.1 ug/l)
BF-102-FD (1190 ug/l)
BF-142-FD (30.8 ug/l)
BF-142-FD-D (16.8 ug/l)
47
48

RESAMPLE FLUSH IDENTIFICATION
AND CONCENTRATION (ug/l)

BF-02-FD-2 (21.3 ug/l)
BF-26-FD-2 (16.7 ug/l)
BF-28-FD-2 (35.4 ug/l)
SOW-29-FD-2 (6.41 ug/l)
OF-83-FD-2 (4.74 ug/l)
TL-36-FD-2 (1.44 ug/l)
BF-48-FD-2 (15.8 ug/l)
BF-52-FD-2 (13.6 ug/l)
BF-53-FD-2 (6.67 ug/l)
BF-72-FD-2 (14.5 ug/l)

BF-02-FD (29 ug/l)
BF-26-FD (28.3 ug/l)
BF-28-FD (51.3 ug/l)
SOW-29-FD (101 ug/l)
OF-83-FD (107 ug/l)
TL-36-FD (16.7 ug/l)
BF-48-FD (34.6 ug/l)
BF-52-FD (31.2 ug/l)
BF-53-FD (15.3 ug/l)
BF-72-FD (15.8 ug/l)
42
43
44

TOTAL RESAMPLE FLUSH AT OR
ABOVE 15 ug/l

AR-21-FL (1.11 ug/l)
WE-110-FL (3.59 ug/l)
BF-125-FL (0.35 ug/l)
WE-101-FL (0.385 ug/l)
BF-102-FL (0.361 ug/l)
BF-142-FL (2.44 ug/l)

AR-21-FD-2 (0.554 ug/l)
WE-110-FD-2 (44.8 ug/l)
BF-125-FD-2 (1.61 ug/l)
WE-101-FD-2 (6.52 ug/l)
BF-102-FD-2 (3.74 ug/l)
BF-142-FD-2 (260 ug/l)
8/17/2016

12

2

8/17/2016

4

0
28

0
AR-56-FD-2 (1.02 ug/l)
CF-106-FD-2 (9.19 ug/l)

0

AR-56-FL (0.289 ug/l)
CF-106-FL (10.3 ug/l)

5

*One duplicate sample was collected for every approximate 10 samples
ug/l = micrograms per liter
Exceedances of action level are highlighted in red.
Sample identifications indicate typre of tap sampled, location number, and if a first draw or flush sample.

May 16, 2016

2

 Appendix B
Excerpt from 3Ts for Reducing Lead in Drinking Water in Schools:
Revised U.S. EPA Technical Guidance, October 2006

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

5. Remedies
Solutions to lead problems typically need to be made on an interim (short-term) and on a permanent basis.
Interim measures can be taken while you wait for your test results or until a permanent solution has been put
in place. In addition, there are routine measures that should be taken. You should work closely with
maintenance staff and any plumbers who may make repairs. Make sure that users are familiar with the use of
new fixtures you install.
Outlined below are various routine, interim and permanent remedies. To aid you in the process of selecting
remedies, a case study has been included as Exhibit 5.3.
5.1 Routine Control Measures
Below are examples of routine activities that should be conducted to prevent exposure to elevated levels of
lead:
• 

Create aerator (screen) cleaning maintenance schedule and clean debris from all accessible aerators
frequently.

• 

Use only cold water for food and beverage preparation. Hot water will dissolve lead more quickly
than cold water and is likely to contain increased lead levels. If hot water is needed, it should be taken
from the cold water tap and heated on a stove or in a microwave oven.

• 

Instruct the users (students and staff ) to run the water before drinking or staff could run the water
before students arrive, so they are drinking water that has not been in contact with the faucet interior
since faucets are often a major source of lead in drinking water.

• 

Placard bathroom sinks with notices that water should not be consumed. You should use pictures if
there are small children using bathrooms.

5.2 Interim (Short-Term) Control Measures
Some examples of interim control measures include:
(1)  “Flush” the piping system in your building. “Flushing” involves opening suspect taps every morning
before the facility opens and letting the water run to remove water that has been standing in the
interior pipes and/or the outlets. The flushing time varies by the type of outlet being cleared. The
degree to which flushing helps reduce lead levels can also vary depending upon the age and condition
of the plumbing and the corrosiveness of the water. Flushing instructions are presented in Exhibit 5.1.

55

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

Exhibit 5.1: Flushing Directions by Outlet Type
Remember that each drinking water outlet should be flushed individually; flushing a toilet will not flush your water
fountains. All flushing should be recorded in a log submitted daily to the office, or person, in charge of this program.
•  Locate the faucet furthest away from the service line on each wing and floor of the building, open the faucets
wide, and let the water run for 10 minutes. For best results, calculate the volume of the plumbing and the flow
rate at the tap and adjust the flushing time accordingly. This 10-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 15 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:
f

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).

f

Thoroughly flush several designated drinking water outlets daily while taking all others
temporarily out of service.

f

Use bottled water.


f

Collect water being flushed and use for non-consumptive purposes.


• 

Another obvious disadvantage to flushing is the amount of time and staff needed to perform the task.

• 

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

HINT: Be careful not to flush too many taps at once. This could dislodge sediments that might create further
lead problems, or it could reduce pressure in the system below safe levels. If the flow from outlets is reduced
noticeably during flushing, you have probably turned on too many taps at once.

56

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

(2) Provide bottled water. This can be an expensive alternative but might be warranted if you expect or
are aware of widespread contamination and flushing is not an option. If you use bottled water, be
aware that it is not regulated by EPA but rather by the Food and Drug Administration (FDA). Your
state may also regulate bottled water, and, in some instances, these standards may be more stringent
than the federal requirements. EPA recommends that you require a written statement from the
bottled water distributor guaranteeing that the bottled water meets FDA and state standards.
(3)  Shut off problem outlets. If initial sample results from an outlet exceed 20 ppb, the outlet can be
shut off or disconnected until the problem is resolved. If the outlet had been frequently used, bottled
water could be provided as a temporary replacement as suggested in item 2 above.
5.3 Permanent Remedies
You can take a number of actions to permanently reduce or eliminate the sources of lead that originate in your
building’s plumbing. Some of these actions may allow the elimination or reduction of routine flushing or
other interim measures. After obtaining an understanding of your water supply and the lead conditions in
your facility (as a result of testing), you should examine the permanent treatment options and select those
most appropriate to your situation. Obviously, your decision will be based on such factors as cost, likelihood
of success, availability of water, and staffing requirements.
(1) Replacement. If the sources of lead contamination are
localized and limited to a few outlets, replacing these
outlets or upstream components may be the most
practical solution. EPA worked with the plumbing
industry and NSF International to develop an industry
standard that is designed to minimize the amounts of
lead being leached from these products. This standard is
NSF Standard 61 (Sections 4, 8 and 9). Before you
purchase any brass plumbing products, request
information regarding compliance with this standard.

Tip: If multiple components (for
example, bubbler valves) are in need of
replacement, you may wish to purchase
only one or two initially. You could
then take follow-up water samples after
installing the new component(s) to see
if that particular product leaches
unacceptable levels of lead. If followup testing is satisfactory, you could be
reasonably certain that the product will
perform well at other locations in your
facility.

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

NSF Standard 61, Section 8 covers inline mechanical devices that are used to measure or control the
flow of water. Inline devices used to measure or control the flow of water in a building include water
meters, building valves, check valves, meter stops, valves and fittings, backflow preventers, etc. An
inline device is any device installed on a service line or building distribution system downstream of the
water main and before endpoint devices.
NSF Standard 61, Section 9 covers endpoint devices. The devices include kitchen and bar faucets,
lavatory faucets, water dispensers, drinking fountains, water coolers, glass fillers, residential refrigerator
ice makers, supply stops, and endpoint control valves. Under the Lead Ban, these devices must meet
the requirements of this standard. Be sure to check for compliance with NSF Standard 61, Section 9
before purchasing or installing an endpoint device.
57

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

(2)  Lead levels can be reduced at the tap. Reverse osmosis units are commercially available and can be
effective in removing lead. Since these devices also tend to make the water corrosive, they should only
be used when placed at water outlets. Such devices are termed point-of-use (POU) devices. POU
devices can be used to treat faucets or taps, but would not be used on drinking water fountains. There
are a number of POU cartridge filter units on the market that effectively remove lead.
POU devices can be either purchased or leased. They can be relatively inexpensive ($65 to $250) or
expensive (ranging from $250 to $500), their effectiveness varies, and they may be vulnerable to
vandalism. They also require a maintenance program for regular upkeep to ensure effectiveness.
Cartridge filter units need to be replaced periodically to remain effective. NSF International, an
independent, third-party certification organization, has a testing program to evaluate the performance
of POU devices for lead removal (NSF Standard 53). Before purchasing any device, ask the
manufacturer for proof of NSF approval and the Performance Data Sheet, or check by visiting the
NSF Web site at http://www.nsf.org/business/search_listings/index/asp.
(3)  Check grounding wires. Electrical current may accelerate the corrosion of lead in piping materials.
Existing wires already grounded to the water pipes can possibly be removed by a qualified electrician,
and replaced by an alternative grounding system. If your local or state building codes allow, consider
finding an alternative grounding system and have a qualified electrician make the change. Be aware
that the removal of grounding from water pipes may create a shock hazard unless an acceptable,
alternative ground is provided.
(4)  Lead pipe replacement. Lead pipes within the school and those portions of the lead service lines
under the water supplier’s jurisdiction can be replaced. Contact your public water supplier regarding
their jurisdiction. However, your facility may be responsible for replacing a portion of a lead sevice
line that is under its own administrative jurisdiction, rather than under the jurisdiction of the water
supplier.
(5)  Reconfigure plumbing. In some facilities, the plumbing system might be modified so that water
supplied for drinking or cooking is redirected to bypass sources of lead contamination. Before
undertaking such an alternative, be certain of the sources of lead contamination. Follow-up testing
would also be necessary, as with the other remedies, to ensure that the efforts result in reduced lead
levels at the tap.
(6)  Manual flushing. Flushing individual problem outlets or all outlets may also represent a permanent,
albeit ongoing, solution. There are advantages and disadvantages to flushing. Flushing is often the
quickest and easiest solution to high lead levels, especially when contamination is localized in a small
area or in a small building. See the Interim Remedies section above for a discussion of the advantages/
disadvantages of this remedy in addition to outlet flushing instructions. You should review this
information before deciding whether flushing is appropriate as a permanent remedy in your facility.
(7)  Automatic flushing. Time-operated solenoid valves can be installed and set to automatically flush the
main pipes (headers) of the system. It is important to note that solenoid valves are not practical for
flushing water coolers. They would have to be flushed manually by staff. See the Interim Remedies
section above for flushing instructions for water fountains.
(8)  Bottled water. If other treatment fails or is impractical, bottled water can be purchased for
consumption by the building community. As noted under the interim remedies section above, make
sure that the bottled water you select meets federal and/or state standards for lead and other drinking
58

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

water contaminants. EPA recommends that you require a written statement from the bottled water
distributor guaranteeing that the lead levels in the water do not exceed 5 ppb.
(9)  Use lead-free materials. Make sure that any plumber who does repair or replacement work on the
facility’s plumbing system uses only “lead-free” solders and other materials. The 1986 Safe Drinking
Water Act Amendments require that only “lead-free” materials be used in new plumbing and
plumbing repairs. Make sure all plumbers and other workers adhere to these requirements. These
actions will ensure that new lead is not introduced into the facility’s plumbing system. Report any
violations of the “lead-free” requirements to your local plumbing inspector, the state drinking water
program or EPA (see Appendix D for a directory of state programs).
(10)Shut off problem outlets. If initial sample results from an outlet exceed 20 ppb, the outlet can be
shut off or disconnected permanently. If the outlet had not been used regularly, this may be a viable
option. However, if the outlet had been frequently used, this is probably not a practical solution.
Three flow charts (Exhibits 5.2a through 5.2c) illustrating a basic remediation process are presented below.
Please note that these flow charts provide a basic process for developing permanent solutions to lead problems.
Interim measures are therefore not specifically addressed on the charts. Also, for simplicity, not all of the
possible permanent remedies listed in the above discussion are shown on the charts. However, these options
provide additional flexibility and should be considered when using the flow charts. For example, a school
might decide to provide a point-of-use reverse osmosis treatment unit at a kitchen sink tap in lieu of replacing
high lead plumbing because a treatment unit would provide better overall water quality for cooking and it
would remove lead from the water.

59

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

Exhibit 5.2a: Remediation Flow Chart (part 1)

60

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

Exhibit 5.2b: Remediation Flow Chart (part 2)

61

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

Exhibit 5.2c: Remediation Flow Chart (part 3)

62