• Water Quality Assurance Program
     Conclusions & Recommendations

    The WQAP was developed in accordance with and generally meets the recommendations contained in the 3Ts guide. There are a couple of areas where some enhancement to current practices might benefit the program.
    1. Provide additional training to teachers and school administration regarding areas where elevated levels of lead may occur and best practices to maintain water quality, i.e., the need and the benefits of flushing of drinking fountains. (This is based on the results of testing discussed in the following section. It does not mean that this information was not provided to teacher or school administration, but in at least one case, it does not appear that guidance was followed.)
    2. Consider additional methods of communication program results. The Water Quality website provides an extensive repository of lead-related information. Regular communication, e.g., at the beginning of the school year via a one-page letter or brochure regarding testing results and where additional information might be available would be way to assure nearly every student and parent was “told” of the information.

    Sampling
    Based on best practices and the lead testing results, the following actions are recommended:
    • LCS should continue to collect 250-mL first draw samples. Samples also continue to be collected after 8 hours of stagnation following regular water quality maintenance practices, but prior to use by students, faculty or administration.
    • Additional monitoring should be conducted at every elementary until every source of drinking water has been tested, including drinking fountains/bubblers, kitchen sinks, and washbasins/restroom sinks in classes for children in first grade or younger.
    • Enhanced monitoring (7 samples) should be conducted at every middle school and high school at least once.
    • Where remediation, either flushing or fixture replacement, occur testing following remediation should consist of a first-draw 250 mL sample, followed by a 30-second flush, and a second 250 mL sample.
    Water Quality Maintenance Practices
    Based on our understanding of the current water quality maintenance program, the following additional items are recommended:
    • Complete profiles at each school, beginning with an inventory of plumbing fixtures (i.e., bubblers make and model, drinking fountain make and model, etc.). This will help to identify fixtures that may routinely have higher lead concentrations and get them replaced sooner, if necessary.
    • Create an aerator maintenance schedule and clean debris from all accessible aerators frequently. It is recommended this be done annually.
    • Advise kitchen staff to only use cold water for food and beverage preparation.
    • ine flushing should continue on Mondays (or the first day of school in a given week) and Wednesdays at a minimum. Additional flushing by teachers in the morning prior to arrival of students is encouraged, but based on the results of the testing, may not provide any additional water quality benefits.
    • When high lead levels are detected, more rigorous (minimum of 10 minutes) should be practiced daily until follow-up monitoring results are available. If elevated levels persist in a drinking fountain or bubbler following the initial response, that fixture should be removed from service until the cause of the elevated lead concentrations can be identified and permanently resolved. If elevated levels persist is a bathroom sink or other source that should not be routinely used for drinking, then that fixture can be used but it should be very clearly identified as “not suitable for drinking.”
    • Long-term/permanent remedial actions, such as fixture replacement, should clearly be identified in the LCS WQAP. The 3Ts document provides guidance on the appropriateness of each alternative to a given situation.

    Program Statement

    The Water Quality Assurance Program is intended to:

    1. Find and correct any domestic water quality issues that may exist.
    2. Document the extent of facilities for which there are no water quality issues.
    3. Develop a plan for implementation of Best Management Water Quality Practices.
    4. Establish on-going monitoring and maintenance protocols.
    Outline of Overall Program

    Implementation of the Water Quality Assurance Program includes the following steps.
    LCS Action Items

    1. LCS initiated immediate water quality maintenance efforts
    2. Selection of Water Quality Engineering Team via RFQ process

    Water Quality Assurance Program - Professional Implementation

    1. An initial Planning Phase to establish testing scope and methods
    2. A water quality Testing & Evaluation Phase
    3. Implementation of water quality improvement measures where needed
    4. Institution of Best Management Water Quality Practices

    Construction Project Development

    1. Programming for Remediation Projects (if needed)

    Construction Project Implementation

    1. Construction Projects Design
    2. Remedial Construction
    3. Verification of water quality in non-suspect facilities
    Phasing Consideration

    It may be prudent to identify and commence with building s of ages which would be most suspect. The initial actions would be concentrated on the most suspect buildings, then as possible buildings having a lesser likelihood of issues would be included in the program.
    Phase 1a includes buildings of an age with suspect construction
    Phase 1b includes verification of water quality of remaining buildings unlikely to have issues due to recent construction, plus development of water quality BMP.

    LCS Water Quality Assurance Program

    LCS Action Items

    • LCS initiated immediate water quality maintenance efforts
    • identifies buildings constructed prior to the 1986 Safe Drinking Water Act.
    • undertakes an effort to flush piping during long periods of stagnant water use
    • Selection of Water Quality Engineering Team via RFQ process
    • commences a professional selection process for water quality experts
    Water Quality Assurance Program - Professional Implementation

    Plumbing Engineer

    • develops outline of building plumbing histories

    Water Quality Special / Industrial Hygienist

    • categorizes each building (or area) by initial suspected level of concern
    • defines testing protocols
    • develops maintainable records format

    Plumbing Engineer

    • develops plumbing system profiles for buildings

    Water Quality Special / Industrial Hygienist

    • develops testing plan for suspect buildings

    Testing Lab

    • Sample collection, analysis, and data compilation

    Water Quality Special / Industrial Hygienist

    • selects & quantifies specific buildings (areas) of concern
    • identifies & reports initial water quality improvements protocols
    • identifies extent of needed remediation

    Water Quality Special / Industrial Hygienist

    • defines long range “Best Management Water Quality Practices”
    • defines ongoing maintenance protocols
    • defines ongoing testing protocols
    Construction Project Development

    Plumbing Engineer

    • develops programs and budgets for plumbing systems’ remediation projects
    Construction Programing Implementation

    Mechanical and or Architectural / Mechanical Design Professionals

    • plumbing improvements projects design
    • plumbing improvements projects construction
    • water quality testing per Best Management Practices