Garden State Laboratories, Inc. Harvey Klein, M.S. Laboratory Director 410 Hillside Avenue Hillside, NJ 07205

School Drinking Water Testing for Lead On July 13, 2016 the State Board of Education promulgated by Special Adoption, Rules requiring immediate testing of drinking water for lead in all NJ Public Schools. N.J.A.C. 6A:26

Requirements School Requirements (j) All district boards of education are eligible to be reimbursed for the water supply testing and analysis conducted pursuant to (d) above after the effective date of these regulations. To receive reimbursement, the district board of education shall complete and submit to the Department a reimbursement application on a form or in a format supplied by the Department.

Requirements School Requirements (d) Includes details on sampling & analysis Includes a Sampling Plan (58 pages) and a Quality Assurance Project Plan – QAPP (23 pages) USEPA 3Ts for Reducing Lead in Drinking Water in Schools – Revised Guidance Doc. You need accurate, certified analytical results. Rules, Sampling Plan & QAPP available for download

Requirements School Requirements Critical points A plumbing survey for each facility that identifies how water enters and flows through each facility, the types of plumbing materials used in the facility, such as the service line, piping, solder, fixtures, drinking water outlets where a students or staff have or may have access

Requirements School Requirements Critical points The names and responsibilities of all individuals involved in sampling: School District Program Manager (Program Manager) Sampling Project Manager (Project Manager) Individual School Sampling Project Officers

Requirements School Requirements Critical points Samples shall be taken after water has sat, undisturbed in the school pipes for at least 8 hours but no more than 48 hours before the sample is taken. If building not in use (month of August)or outlets get little use Flushing is appropriate

Requirements School Requirements Critical points Flush start: Monday 9:00 AM till 12 noon Start at farthest outlet from POE Can start sampling Monday 8:00 PM Reality start Tuesday 8:00 AM till 6:00 PM Continue Wednesday 8:00 AM till 12 noon Now at end of 48 stagnation period. Flush remaining DW outlets and wait 8– 48 hours.

Requirements School Requirements Critical points Existing aerators, screens, and filters shall not be replaced or removed prior to or during sampling

Requirements School Requirements Critical points All samples shall be collected in pre- cleaned high-density polyethylene (HDPE) 250 milliliter (mL) wide-mouth single-use rigid sample containers that are properly labeled

Requirements School Requirements Critical points

Analysis shall be conducted by a NJDEP certified laboratory to analyze for lead in drinking water

Requirements School Requirements Critical points Sample analysis shall be conducted in accordance with a Quality Assurance Project Plan (QAPP), which shall be signed by the district board of education, the certified laboratory, and the individual responsible for conducting sampling.

Requirements School Requirements Critical points The QAPP shall include the identification of analytical methods, chain of custody procedures, data validation and reporting processes, detection limits (2 ppb), reporting to three significant figures, field blanks, and quality control measures required by the certified method

Requirements School Requirements Critical points The Department, in consultation with the Department of Environmental Pro- tection (DEP), has developed technical guidance manuals to assist district boards of education in complying with the sampling and analysis requirements lead-schools.html lead-schools.html

Requirements School Requirements Critical points Must do repeats every 6 years. This may change based upon proposed federal and state bills. If already done lead testing in last 5 years, results may be acceptable. Must apply to the DoE for approval. Reimbursements will NOT be made for testing done prior to 7/13/16.

Requirements School Requirements Critical points All district boards of education shall sample for lead after the replacement of any drinking water outlet or any other alteration to plumbing or service lines that may impact lead levels at the outlet.

Requirements School Requirements Critical points District boards of education may request an exemption from the testing requirements set forth in (d) above if they can demonstrate that they do not use any drinking water outlets for consumption or food preparation in any of their facilities

Requirements School Requirements Critical points District boards of education may apply to the Department for an extension of this deadline of up to one year, upon written demonstration that there is no certified laboratory available to conduct testing within the 365-day timeframe. The extension request shall include evidence that the district board of education requested testing from at least three certified laboratories and the responses from the laboratories showing that the testing could not be completed within the designated time period. Not Likely

Requirements School Requirements Critical points The Sampling Plan and QAPP are vital documents. Available, with appendices, as Word Docs so you can make them specific for your school district.

Requirements School Requirements Drinking Water Outlets 7.1 Sample Locations The following locations shall be identified and labeled for each school: Kitchen outlets Food Preparation outlets Teacher Lounge outlets Nurse’s Office outlets Home Economic Sink outlets Drinking Water Fountains – Bubblers and Water Coolers Outside drinking water fountains and food preparation areas Ice Machines Other drinking water outlets used for consumption Examples of outlets that do not need to be sampled include utility sinks, outside spigots, bathroom sinks and classroom sinks, unless any of these sinks are used routinely for consumption.

Requirements School Requirements Drinking Water Outlets

7.2 Sample Location Codes Each sampling location shall be identified by its location and type using the following coding system (Note additional codes as needed): KC = Kitchen Outlet, Cold CT= Cafeteria Outlet FP= Food Preparation Sink TL= Teacher Lounge Sink NS = Nurse’s Office Sink EC = Home Economics Outlet, Cold DW= Drinking Water Bubbler WC = Water Cooler (Chiller Unit) IM = Ice Machine

Requirements School Requirements Drinking Water Outlets 7.3 Sampling Location Inventory Attachment C shall be used to develop a detailed inventory of each drinking water outlet in the school to be sampled. The inventory must be completed and signed by the Project Officer. The Drinking Water Outlet Inventory shall include the following information: All drinking water outlets in the school The type, location, and sample location code of each drinking water outlet If the drinking water outlet has a chiller unit If the drinking water outlet has an aerator/screen If the drinking water outlet is motion activated, in which the hot water at the outlet must be turned off prior to sampling If the drinking water outlet is operational If the drinking water outlet has not been used frequently If the drinking water outlet is leaking If the drinking water outlet has a filter The make and model of all drinking water fountains and water coolers

Requirements School Requirements Drinking Water Outlets 8.1 Timeline Samples should be collected before the facility opens in the morning and before any water is used in the building. The water shall sit in the pipes unused for at least 8 hours, but no more than 48 hours, before a sample is collected. At no time should filters, aerators and screens be removed prior to or during the sampling event. Day of Sampling The Project Officer will use Attachment F to document when the water was last used and when sampling began.

Requirements School Requirements Drinking Water Outlets

Sample Collection Highlights All samples shall be collected in a pre-cleaned HDPE 250mL wide mouth single use rigid sample container. Identify on the Sampling Plan the outlet closest to the water service line(s) entry point to be collected first, then identify the next closest outlet as second, and move away from the water service line(s) entry point until the outlet farthest away is identified to be sampled last on the sampling plan. This will minimize the chance that a sampling location will be flushed by an upstream fixture. Sampling will begin at the outlet closest to the point of entry and continue to the furthest outlet to ensure the water remains motionless in the plumbing.

Requirements School Requirements Drinking Water Outlets Sampling can be done by school staff, lab staff or 3 rd party staff 2 sampling options: First Draw sample only, if result high take Flushed sample – 30 seconds or 15 mins First Draw and Flushed Most go with First Draw only. Non-acidified 250 ml HDPE bottles!

Requirements School Requirements Drinking Water Outlets Equipment and supplies that will be needed to perform the sampling survey are ASTM Type I reagent-grade water for the field reagent blank (FRB), non-colored latex or nitrile gloves, pre-cleaned HDPE wide- mouth 250 mL single use rigid sample containers (“sample container”) and chain of custody (COC forms-Appendix C or lab may use their own) and indelible ink/marker.

Requirements School Requirements Drinking Water Outlets Obtaining from the laboratory, prior to the sampling event, ASTM Type I reagent-grade water (RGW) to be used as Field Reagent Blanks (FRB). The sampler will transport this RGW to the school to be sampled. Before the first sample is collected the RGW collected at the Laboratory will be transferred to a sample container near the first sample location inside the school building. This FRB sample will be stored and transported in the same cooler, handled and preserved in the same manner as samples collected at that school.

Requirements School Requirements Critical points Within 24 hours after the district board of education has reviewed and verified the final laboratory results, the district board of education shall: Make the test results of all water samples publicly available at the school facility and on the district board of education’s website

Requirements School Requirements Drinking Water Outlets The Laboratory will immediately notify the Project Manager and Project Officer of the affected school(s) upon receipt of any validated laboratory results that exceed the action level for lead in drinking water that is greater than 15 µg/L (as defined as greater than or equal to 15.5 µg/L). For all results, the Laboratory will provide the result in micrograms per liter (µg/L) and to at least three (3) significant figures (i.e.19.6 µg/L or 20.4 µg/L).

Requirements School Requirements Critical points If any results exceed the permissible lead action level, 15 ppb, provide written notification to the parents/guardians of all students attending the facility, as well as to the Department.

Requirements School Requirements Critical points This notification shall include a description of the measures taken by the district board of education to immediately end use of each drinking water outlet where water quality exceeds the permissible lead action level, the measures taken to ensure that alternate drinking water has been made available to all students and staff members, and information regarding the health effects of lead.

Requirements School Requirements Drinking Water Outlets Upon receiving sample results, the District will turn off all outlets with results that exceed 15 µg/L (as defined as greater than or equal to 15.5 µg/L). If these locations must remain on for non-drinking purposes, a “DO NOT DRINK – SAFE FOR HANDWASHING ONLY” sign will be posted (Attachment H.v).

Cost of Services We view the services provided by Garden State Labs as professional services. Analytical costs vary dependent on turnaround time. Sampling & Analytical costs are reimbursable by the Dept. of Education

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