Steps to Create and Implement a LCCA Sampling Program

  • Develop a sampling plan: a written sampling plan is highly recommended.  It clarifies procedures for any personnel involved with the Program.
  • Code each fixture using a system that will allow you to identify each unique fixture.  Coding should be identified on a site map.
  • In addition to the unique fixture code, a unique sample identifier is necessary if more than one sample will be taken from a fixture.
  • Prioritize sampling sites based on potential use and risk.  Also, consider that actual use can change over time.
  • Bathroom fixtures should be included as children may drink or brush their teeth at these fixtures.
  • EPA recommends that wide-mouth bottles be used to collect lead and copper samples.  It has become apparent that wide-mouth bottles offer advantages over narrow-necked bottles because wide-mouth bottles allow for a higher flow rate during sample collection which is more representative of the flow that a consumer may use to fill up a glass of water.  Instruct your testing lab to provide you with wide-mouth bottles for testing of lead and copper.
  • Do not collect samples in the morning after vacations, weekends, or holidays because the water will have remained stagnant for too long and would not represent the water used for drinking during most of the days of the week.

 

 Lead and Copper Sample Collection Procedures

A. How to Collect an Initial (First Draw) Sample

The protocol described below differs from the 1-liter sample required by the Lead and Copper Rule for PWSs.  Because the protocol differs, these tests neither replace nor interfere with sampling requirements under the Lead and Copper Rule.

Collect the sample before any water has been used. Water should not be used for 6-18 hours before sampling.

  1. Make sure you have clean hands.
  2. Complete the sample collection form.
  3. Only use containers (250 milliliter/wide mouth) supplied by your certified lab.
  4. Containers should not be opened until you are ready to collect the sample.
  5. Sampling containers that have been compromised in any way, e.g., by being touched on the threads or the interior surfaces, must not be used.
  6. Keep food and drink away from the sample and its container.
  7. If the fixture/faucet has an aerator at the end of the fixture, it should not be removed before taking samples.  The person taking the sample should not remove or clean any aerators prior to or during the collection of tap samples (see EPA Note #1). Make sure no water has been withdrawn from the tap or water fountain, as well as from any adjacent taps, before you collect the sample.  Outlets must be inactive for at least 6 to 8 hours before testing.  Overnight is best.  Do not flush (known as pre-stagnation flushing) the tap for a specified period of time prior to starting the minimum 6-hour stagnation time required for samples collected.
  8. Place the container under the faucet or drinking water fountain that is being tested and collect 250 milliliters of water.  When turning on the water for a faucet, open the cold water tap as you would when filling a glass of water.
  9. If a faucet is being tested make sure you turn on the cold water tap.
  10. Turn on the water and fill the container without allowing any water to run down the drain.
  11. Close the container according to the instructions from your certified lab.  Tightly cap the sample bottle and place in the sample (shipping) kit provided.
  12. Make sure the container is labeled with the same information from your sample collection form.
  13. Prepare the container for shipping according to the certified lab's instructions.  Ship containers according to the certified lab's instructions.
  14. Samples must be delivered to the lab within 14 days of collection for proper testing.

 

B. How to Collect a Second First Draw Sample

If the result of your initial first draw sample result was higher than 15ppb, particulate lead that can get trapped in the aerator or screen of the outlet can be contributing to the elevated levels of lead.  The protocol below consists of an established sample size/volume and water retention time.  It is designed to identify lead problems at outlets/fixtures and upstream plumbing within school facilities and in the water entering the facilities.

  1. Collect the sample before any water has been used.  Water should not be used for 6-18 hours before sampling.  Outlets must be inactive for at least 6 to 8 hours before testing. Overnight is best.  Do not flush (known as pre-stagnation flushing) the tap for a specified period of time prior to starting the minimum 6-hour stagnation time required for samples collected.
  2. Make sure you have clean hands.
  3. Complete the sample collection form.
  4. Only use containers (250 milliliter/wide-mouth) supplied by your certified lab.
  5. Containers should not be opened until you are ready to collect the sample.
  6. Sampling containers that have been compromised in any way, e.g., by being touched on the threads or the interior surfaces, must not be used.
  7. Keep food and drink away from the sample and its container.
  8. If the fixture/faucet has an aerator at the end of the fixture, it should not be removed before taking samples.  The person taking the sample should not remove or clean any aerators prior to, or during, the collection of tap samples. (see EPA Note #1)
  9. Make sure no water has been withdrawn from the tap or water fountain, as well as from any adjacent taps, before you collect the sample.  Outlets must be inactive for at least 6 to 8 hours before testing (overnight is best).  Do not flush (known as pre-stagnation flushing) the tap for a specified period of time prior to starting the minimum 6-hour stagnation time required for samples collected.
  10. Place the container under the faucet or drinking water fountain that is being tested and collect 250 milliliters of water.  When collecting from a faucet open the cold water tap as you would when filling a glass of water.  
  11. If a faucet is being tested make sure you turn on the cold water tap.
  12. Turn on the water and fill the container without allowing any water to run down the drain.
  13. Close the container according to the instructions from your certified lab.  Tightly cap the sample bottle and place in the sample kit provided.
  14. If the faucet has an aerator on the end of the fixture, after taking the First Draw Sample remove or clean the aerator/stainer and then take a second First Draw-Aerator sample. (see EPA Note #2)
  15. Make sure the container is labeled with the same information from your sample recording form.
  16. Prepare the container for shipping according to the certified lab's instructions.
  17. Ship containers according to the certified lab's instructions.
  18. Samples must be delivered to the lab within 14 days of collection for proper testing.

 

C. How to Collect a Flush (Follow-Up) Sample

Collect the sample first thing in the morning before any water has been used.  Water should not be used for 6-18 hours before sampling.

  1. Make sure you have clean hands.
  2. Complete the sample collection form.
  3. Only use containers (250 milliliter/wide-mouth) supplied by your certified lab.
  4. Containers should not be opened until you are ready to collect the sample.
  5. Sampling containers that have been compromised in any way, e.g., by being touched on the threads or the interior surfaces, must not be used.
  6. Keep food and drink away from the sample and its container.
  7. Remove any aerators attached to the faucet/fixture prior to the collection of the Flush samples.
  8. Make sure no water has been withdrawn from the tap or water fountain before you collect the sample.
  9. If a faucet is being tested make sure you turn on the cold water tap.  Turn on the cold water for the faucet or drinking water fountain and let it run down the drain for 30 seconds or the amount of time instructed.  When turning on the water for a faucet, open the cold water tap as you would do when filling a glass of water.
  10. Place the container under the faucet or drinking water fountain that is being tested and collect 250 milliliters of water.
  11. Close the container per instructions from your certified lab.  Tightly cap the sample bottle and place in the sample kit provided.
  12. Make sure the container is labeled with the same information from your sample collection form.
  13. Prepare the container for shipping per the certified lab's instructions.
  14. Ship containers per the certified lab's instructions.
  15. Samples must be delivered to the lab within 14 days of collection for proper testing.

 

EPA Note #1

Some schools may opt to clean the aerators prior to collecting initial first draw samples.  However, EPA recommends that the collection of first draw samples without aerators should only be permissible if the outlet does not normally have an aerator, or if your school has a documented routine maintenance program for removing, cleaning, and replacing aerators on drinking water outlets.  If your school does not have an aerator maintenance program in place, removing, cleaning, and replacing the aerators prior to sampling for diagnostic purposes will  provide sampling results that cannot be assured to represent the water that the children and staff are routinely drinking from the outlet.

 

 

 

EPA Note #2

Eliminating Particulate Lead, a Source of Lead in Drinking Water

Alternative Step 2:

If initial first draw sampling results reveal concentrations higher than 20 ppb in the 250 mL sample for a given outlet, a contributing source of the elevated lead levels could be the debris in the aerator or screen of the outlet.  By cleaning the aerator or screen and retesting the water following the initial first draw sampling procedures you can identify whether or not the debris is a contributing source to elevated levels in your facility.

Determining aerator/screen debris contribution:

Scenario 1:  Your initial first draw sampling result was higher than 20 ppb. You decide to see if the aerator is a contributing source of lead in the water.  After cleaning our your aerator you take another first draw sample.*  The results come back less than or close to 5 ppb or the detection level.  This result tells you that the debris in the aerator was contributing to elevated levels in your school.  Continue to clean out the aerator on a regular basis and this outlet is O.K. to use.  However, please note that without regular maintenance this tap may serve water with elevated lead levels.

Scenario 2: Your initial first draw sampling result is 25 ppb. You decide to see if the aerator is a contributing source of lead in the water.  After cleaning out your aerator you take another first draw sample.*  The second sample result is very close or equivalent to the 25 ppb sample.  Since your initial first draw sample and alternative second first draw sample results are similar, the problem is upstream from the aerator.  Continue to follow the sampling protocol and do your follow-up flush sampling.

Scenario 3:  Your initial first draw sampling result is 60 ppb. You decide to see if the aerator is a contributing source of lead in the water.  After cleaning out your aerator you take another first draw sample.*  The second sample result is 25 ppb.  While your results are lower, but still above 20 ppb, this tells you that the aerator or screen is a contributing source and that the plumbing upstream of the aerator is contributing as well.  If this situation occurs, you should continue with follow-up flush sampling to target the additional contributing sources.

*When taking your second first draw sample, please remember to follow the same sampling procedures as your initial first draw sample.

 

How to Collect Samples:

  • Make sure you have clean hands.
  • Complete the sample collection form.
  • Only use containers (250 milliliter) supplied by your certified lab.
  • Containers should not be opened until you are ready to collect the sample.
  • Sampling containers that have been compromised in any way, e.g., by being touched on the threads or the interior surfaces, must not be used.
  • Keep food and drink away from the sample and its container.
  • Collect one sample per ice maker.

Initial Screening Sample (A)

Fill a suitable container (250 ml [or larger with a line denoting 250 ml], wide-mouthed bottle or other container) provided by the laboratory at least three-quarters full of ice.

  • Do not touch the ice with your hands
  • Use a non-metal scoop or disposable plastic gloves (provided by the laboratory) to place the ice in the container

If the lead level in Sample A exceeds 15 ppb (MassDEP Action Level), collect a follow-up sample to determine if the source of the lead is the plumbing or the ice making machine itself.

 

Follow-Up Sample (B)

Disconnect the ice maker from the plumbing and look for a screen at the inlet.  Remove the screen.  If debris is present on the screen, forward a sample (Sample C) of the debris in a "new/unused" zip-lock bag to the laboratory for analysis and clean out the remaining debris (on the screen or behind the screen in the pipe).

Collect a sample (B) from the disconnected plumbing as close to the ice maker as possible.  If a sample tap or valve is available the sample can be obtained from the sample tap. Collect the sample immediately after opening the tap or valve (B).  Fill the sample container with 250 ml of water.  After taking Sample B, flush the piping for thirty seconds and then fill a second sample container with 250 ml of water (Sample D - Instruct the lab to test Sample D only if Sample B is greater than 15 ppb).

If no tap is available, contact the ice maker manufacturer for recommendations that will minimize disruption of existing plumbing.  Adding taps or valves could add new sources of lead to the plumbing, even if the new devices are "lead-free" and meet NSF Standard 61, section 8 standards.

 

Interpreting Test Results

  • If the lead level in Sample B is ≤ (less than or equal to) 5 ppb and the level of lead in Sample A is ≥ (greater than or equal to) 15 mg/l, the source of the lead in the ice maker is the ice maker.
  • If the lead level in Sample B significantly exceeds 5 ppb (10-15 ppb), the plumbing upstream from the ice maker is also contributing to the lead in the ice.
  • If the lead level in Sample B exceeds 15 ppb, MassDEP recommends collecting follow-up flush samples from the distribution system supplying water to the ice maker (at Sample point B unless already collected).  Refer to Exhibit below.
  • If the flush sample (D) is less than or equal to 5 ppb, then a flushing program should be instituted.
  • If the lead level in Sample C determines that lead solder is present which is contributing to the results found in Sample A then:
    • If debris is found on the screen, clean the screen routinely to avoid accumulations of debris.
    • If debris is not found on the screen, it should be checked at least twice a year for debris.

How to Collect Samples:

  • Make sure you have clean hands.
  • Complete the sample collection form.
  • Only use containers (250 milliliter) supplied by your certified lab.
  • Containers should not be opened until your are ready to collect the sample.
  • Sampling containers that have been compromised in any way, e.g., by being touched on the threads or the interior surfaces, must not be used.
  • Keep food and drink away from the sample and its container.
  • Collect one sample per kettle.

Initial Screening Samples (Sample A)

If you can collect a sample from a spout filling the kettle, fill a suitable container (250 ml [or larger with a line denoting 250 ml], wide-mouthed bottle or other container) provided by the certified laboratory.  This is Sample A.

Fill the kettle 2/3 full with water (assume 1/3 is used for food).  Mix the water with the kettle's mixer.  If the kettle does not have a mixer or it is not operable then use a non-metal utensil to stir the water in the kettle to ensure a homogenous mixture.  Collect one thoroughly mixed sample for the kettle.  Fill a suitable container (250 ml [or larger with a line denoting 250 ml], wide-mouthed bottle or other container) provided by the certified laboratory.  This is Sample B.

If the lead level in Sample A or B exceeds 15 ppb (MassDEP Action Level), collect follow-up samples to determine if the source of the lead is the plumbing.

Follow-Up Sample (Sample C)

Disconnect the kettle from the plumbing and look for a screen at the inlet.  Remove the screen.  If debris is present on the screen, forward a sample of the debris (Sample C) in a "new/unused" zip lock bag to the laboratory for analysis and clean out the remaining debris (on the screen or behind the screen in the pipe).

Collect a sample from the disconnected plumbing as close to the kettle as possible.  This is Sample D.  Sample D should only be collected if you are unable to collect Sample A as described above.  If a sample tap or valve is available the sample can be obtained from the sample tap.  Collect the sample immediately after opening the tap or valve.  Fill the sample container with 250 ml of water.  After taking Sample D flush the piping for thirty seconds and then fill a second sample container with 250 ml of water.  This is Sample E.  Instruct the lab to test Sample E only if Sample A or Sample D is greater than 15 ppb.

If no tap is available, contact the kettle manufacturer for recommendations that will minimize disruption of existing plumbing.  Adding taps or valves could add new sources of lead to the plumbing even if the new devices are "lead-free" and meet NSF standard 61, section 8 standards.

 

Interpreting Test Results

  • If the lead level in Sample B is greater than or equal to 15 ppb and the level of lead in Sample A is less than or equal to 5 mg/l, the source of the lead is the kettle.
  • If the lead level in Sample A significantly exceeds 5 ppb (10-15 ppb or greater), the plumbing upstream from the kettle is also contributing lead.
  • If the lead level in Sample D significantly exceeds 5 ppb (10-15 ppb or greater), the plumbing upstream from the kettle is also contributing to the lead.
  • If the lead level in Sample A exceeds 15 ppb, MassDEP recommends collecting follow-up samples from the distribution system supplying water to the kettle (Sample point D/E). Refer to the Exhibit below.
  • If the flush sample (Sample E) is less than or equal to 5 ppb, then a flushing program should be instituted.
  • If the lead level in Sample C determines that lead solder is present which is contributing to the results found in Sample A then:
    • If debris is found on the screen, clean the screen routinely to avoid accumulations of debris.
    • If debris is not found on the screen, it should be checked at least twice per year for debris.