Hi Jim,
Please see the attached. This is the draft protocol for collecting water samples at schools. This is
the process that was used this past weekend at Freeman elementary with a couple of tweaks that we
added. We met yesterday to discuss how the process went and there were some suggestions that
were incorporated into this version in an effort to smooth out a couple of minor bumps.
George
George L. Krisztian
Flint Action Plan Coordinator
Laboratory Director
Michigan Department of Environmental Quality
Desk ph (517) 284-6779
Cell ph |
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DRAFT — WORK IN PROGRESS
Protocol for Collecting Water Samples at Schools for Lead Analysis
The following is the procedure being used by the Michigan Department of
Environmental Quality to ensure samples from schools on city of Flint water are
collected in a systematic, consistent manner to provide meaningful results. By following
the below procedures school and health officials will have information to be able to
identify and correct sources that contribute lead into drinking water. The procedures
being used are:
e With the assistance from Department of Licensin
staff, conduct an on-site assessment of the buildi
components of concern and prioritize sample s
e DEQ and LARA staffs collect the sample
sequence recommended by LARA.
e Submit the samples and appropriate p:
Laboratory.
e Laboratory performs analysis and i
DEQ informs DHHS of test results, a
d Regulatory Affairs (LARA)
sumbing to identify plumbing
itized sites and in the
‘been added? If so, when were they
were lead-free plumbing and solder used?
located?
e What are the potable water pipes in the facility made of and what is their
location? Options include: lead, brass, copper, plastic, galvanized metal and
other materials. What materials were used to solder the potable water pipes in
the system? Are brass taps, fittings or valves used? Note the locations.
e How many of the following outlets provide water for consumption: Bubblers, ice
makers, water coolers and kitchen taps. Note their location. Include taps that
might be used for making coffee or preparing formula.
e What brands and models of water coolers (cooled drinking fountains) provide
DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA.
xxxEND_PAGE:deq16_b3_0014_0687_200
water in the facility and what is their location?
e Do faucets have accessible screens and have they been cleaned?
e Can you detect any signs of corrosion, such as leaks, rust-colored water or
stains?
e Is any electrical equipment grounded to water pipes?
e Are there any records of previous water testing?
Step 2 — LARA Arranges for On-site Plumbing Assessm
nd time for the assessment.
: id plumbing system should
LARA staff will contact school officials/staff and set a.
A school representative familiar with the buildin
accompany LARA staff as they conduct the ass
review should also available. If possible, a
assist LARA staff performing the on-site plu!
staff for drinking, co
locations include
or other sinks known to be or visibly
ffeemaker and/or cups are nearby).
C sampling location will be documented with
hould record any model number of faucets, valves, etc.
If potential brass devices are seen they should be
digital photos,
that are accessib
noted.
To determine the sampling sequence, LARA staff will identify the site closest to the
service line to be collected first. LARA staff will then determine the appropriate
sequence/order to sample each outlet beginning closest to the water main and
continuing out farther from the service line until the site the farthest away is sampled
last. This will minimize the chance that the piping may be flushed by a downstream or
other sample location prior to collecting the samples at that site.
LARA staff will also identify any water coolers that should have been removed under the
Lead Contamination Control Act (LCCA) in 1988. The LCCA mandated the repair,
replacement or recall and refund of drinking water coolers with lead-lined water tanks.
DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA.
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LARA staff will confirm that there are no recalled water coolers on-site. Any coolers that
should have been removed will be marked for removal or replacement.
Step 4 - Labeling the Sample Sites and Preparing Labels for the Bottles
Coding Scheme for Water Outlets
A drinking water bubbler (DW) on the 2nd floor (02) of the middle school (MID), the 15th
outlet counted, might be coded as follows.
MID- 02- DW-015
DW2= drinking water bubbler
WC = water cooler (chiller unit)
CF = classroom faucet
KC = kitchen faucet, cold
KH = kitchen faucet, hot
EC = home economics room, cold
EH = home economics room sink, h:
BF = bathroom faucet
NS = nurse's office sink
SC = service connector
ach outlet, school personnel should ensure that the
ter the initial sampling, it will be important to keep a
so that any future or follow-up sampling can be
Also, since drinking water has not been consumed from taps within the school buildings
for several weeks, it is important to flush the taps the day prior to the sampling. For
purposes of these sampling events, at the time of the on-site assessment LARA staff
will ensure that each sampling location is run for two minutes to clear the faucet. This
should be sufficient as long as the sampling teams are scheduled to arrive the next day
to collect samples.
Each outlet should be labeled and posted “DO NOT USE” so that no water is used
before sampling occurs. The sample sequence will be determined by LARA so that
sampling will occur closest to the water main/service line provided by the city.
DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA.
xxxEND_PAGE:deq16_b3_0014_0687_202
Step 6 — Collect the Samples
After the sites and order of collection have been determined by LARA staff, and the taps
flushed, samples will be collected the next day by DEQ and LARA staff. School
personnel will be notified to ensure water is not used in the building. (Scheduling for
sampling should confirm that there are no evening activities in the building or on-site the
night before sampling). In addition, no outlets or water should be used in the building
until sampling is completed. Use of bathrooms, etc. could draw fresh water through the
piping system and alter the effects of stagnation.
Sampling containers will be provided to by the DEQ Drinking Water Laboratory.
1. Four samples will be collected from each desi
four 125 milliliter (ml) samples collected at e2
evaluation/survey will be designated 32
sample site. There will be
let. Sample units for this
the pipes unused for at least 8 hou
is collected.
3. Notes should be taken at €
that may be present (e.g.,
cation (ID) number to each sample
ing the flush time) on the sample
ite are to e collected as follows: 2 — consecutive
cond flush, and a 2 minute flush as follows:
‘bottle and do not allow water to run down the drain in between
the first and second bottle).
b. Turn off tap. Cap, label the first and second bottles, and record sample
information on the request for water analysis form.
c. Mark the cap of the first bottle with a sharpie indicating #1.
d. Mark the cap of the second bottle with a sharpie indicating #2.
e. Turnon tap as before and after 30 seconds, fill the third bottle.
f. Turn off tap. Cap, label bottle, and record sample information on the
request for water analysis form. Mark the cap of the third bottle with a
sharpie indicating #3.
g. Turnon tap as before and after 2 minutes, fill the fourth bottle.
DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA.
xxxEND_PAGE:deq16_b3_0014_0687_203
h. Turn off tap. Cap, label bottle, and record sample information on the
request for water analysis form. Mark the cap of the fourth bottle with a
sharpie indicating #4.
7. Make sure to mark the bottles as “P1” first draw 1, P2 “first draw 2”, FO1 “30 sec
flush” or FO2 “2 min flush” and also indicate this information on the request for
water analysis form.
8. Secure the appropriate request for water analysis form to the appropriate bottle
(refer to the example bottle provided for “instructions”) with a rubber band.
9. Bundle the four samples collected at each individ
proper paperwork has been banded to each bo’
together with a single rubber band. ‘
mpling location (after the
nd secure the four samples
10. Collect the remainder of the samples
determined order as recommended
sites in the pre-
Complete th
Only use
Containe’
rinking Water Laboratory.
ady to collect the sample.
mpromised in any way, e.g., by being
surfaces, must not be used.
ple and its container.
e Deliver samples to the lab promptly.
How to Collect Flush Samples
Before the first flush sample is collected, allow the water to run down the drain for 30
seconds. Then collect a sample using the same protocol as above. Do not turn off
the tap or adjust the flow of water between the “flush” and collecting the sample.
DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA.
xxxEND_PAGE:deq16_b3_0014_0687_204
Before the second flush sample is collected, allow the water to run down the drain
for 2 minutes. Then collect a sample using the same protocol as above. Do not turn
off the tap or adjust the flow of water between the “flush” and collecting the sample.
Step 6 — Consecutive/Sequential Samples
Once all 125 ml samples have been obtained, sampling will begin to collect ten
consecutive/sequential 1 liter samples at three locations.
Depending on the number of sampling taps in the building, select three locations as
follows:
1. For a location close to the water main service: c
6 taps away from the water main. Do not use,
recommended to the water main.
2. For a mid-point location: choose an ou
the longest pipe run. This may or m
3. For an endpoint tap: select an outle
the plumbing pipe run. :
sé an outlet that is within 4 to
hat is closer than
sample. Label t 6 cap #1.
. Fill ten 1 liter bottles conse: i he water run down the drain.
of Metals in Enviror
Agency, Method 20
All Method Detection Limits shall be performed according to the Code of Federal
Regulations, Title 40, Part 136, Appendix B.
Analytical quality control will be in accordance with SOP #800 Revision #4.
Step 8 — Laboratory reports results to DEQ - ODWMA and DHHS staff
DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA.
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