ME Holvey Consulting, LLC

14-153

December 26, 2016

Mr. Jeffrey W. Rahn
Director of Environmental and Security Services
Health and Safety Committee Chairman
West Irondequoit Central School District
321 List Avenue
Rochester, New York 14617
Email: jeff_rahn@westiron.monroe.edu
Re:

Lead in Drinking Water Review and Summary October 2016

West Irondequoit Schools and Administrative Buildings
Rochester, New York

Dear Mr. Rahn:

ME Holvey Consulting, LLC (MEHC) was retained by the West Irondequoit School
District (WICSD) to review and summarize the Lead in Drinking Water Assessment
conducted by the District. WICSD staff sampled the pre-determined drinking water
outlets and ALS Environmental (ALS) analyzed the water for lead content in
accordance with NYSDOH regulations.
The sampling was conducted in accordance with the United States Environmental
Protection Agencys (USEPA) guidance as per the 3Ts for Reducing Lead in Drinking
Water in Schools and the NYS Department of Health Emergency Regulation, Lead
Testing in School Drinking Water (Subpart 67-4).
The newly established NYSDOH Regulation addresses lead in drinking water for Public
School Districts and BOCES. The NYSDOH Regulation states that schools are required to
take remedial measures when lead levels are shown to be above 15 micrograms per liter
(g/l) or 15 parts per billion (ppb); this is the NYSDOH Action Level for lead in drinking
water.
The objective of this assessment was to review the sampling and analytical data to
determine that the sampling protocols, test methodology, and quality control measures,
were completed in compliance with the NYSDOH Regulatory requirements.
WICSD staff sampled the drinking water on October 26 and 27, 2016. A total of 622
drinking water outlets were tested throughout WICSDs buildings. WICSD predetermined the drinking water sample locations for each building.
ALS is approved as an Environmental Laboratory in conformance with the National
Environmental Laboratory Accreditation Conference Standards for Potable Water by the
New York State Department of Health (NYSDOH).

P.O. Box 1252, Pittsford, New York 14534

Email: meholvey@gmail.com Phone: 585-690-3361

Mr. Jeffrey W. Rahn

Page 2
December 26, 2016

Lead Sampling Protocols and Analytical Methodology

The sampling and analytical testing was conducted in compliance with the NYSDOH
Regulation and USEPA Requirements for Lead Sampling and Testing Protocols. The
following USEPA Methodologies were used to prepare and analyze the drinking water
samples for Lead:
Drinking Water Sample Preparation
Lead by ICP-MS

USEPA Method 200.2

USEPA Method 200.8

Lead Sampling Protocol

As per NYSDOH Regulation and the USEPA 3Ts Guidance Document, schools are
required to collect 250 milliliters (mL) first-draw samples from water fountains and
other outlets used for drinking water consumption. First draw samples are defined as a
sample of tap water, collected in accordance with NYSDOH Regulations, that has been
standing in plumbing pipes at least 8 hours and not more than 18 hours and is collected
without prior flushing of the tap. Water fountains and/or outlets are to be taken out of
service if the NYSDOH Lead Action Level exceeds 15 ppb.
The sampling event was designed to pinpoint specific fountains and outlets that require
remediation (i.e. water cooler replacement and faucet replacement).
Samples were collected by WICSD Staff and received by ALS, on the following schedule:
Sample
Package
ID

No. of
Samples

R1611556

31

R1611558

30

R1611559

28

R1611561

40

R1611562

41

R1612043

24

R1612044

29

R1612045

25

R1612046

25

R1612047

30

R1612048

26

R1612049

32

ME Holvey Consulting, LLC

Date
Collected
Brookview
10/26/2016
Colebrook
10/26/2016
Seneca
10/26/2016
Rogers
10/26/2016
Rogers
10/26/2016
IHS
10/27/2016
IHS
10/27/2016
IHS
10/27/2016
IHS
10/27/2016
IHS
10/27/2016
IHS
10/27/2016
IHS
10/27/2016

Date
Received
by ALS

Sample Matrix

Requested
Analyses

Sample
Temperature
(C)

10/26/2016

Drinking Water

Lead

24.3

10/26/2016

Drinking Water

Lead

24.3

10/26/2016

Drinking Water

Lead

24.3

10/26/2016

Drinking Water

Lead

24.3

10/26/2016

Drinking Water

Lead

24.3

10/27/2016

Drinking Water

Lead

14.9

10/27/2016

Drinking Water

Lead

14.9

10/27/2016

Drinking Water

Lead

14.9

10/27/2016

Drinking Water

Lead

14.9

10/27/2016

Drinking Water

Lead

14.9

10/27/2016

Drinking Water

Lead

14.9

10/27/2016

Drinking Water

Lead

14.9

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Mr. Jeffrey W. Rahn

Page 3
December 26, 2016
Sample
Package
ID

No. of
Samples

R1612306

30

R1612307

29

R1612308

20

R1612309

33

R1612310

30

R1612311

30

R1612312

27

R1612313

15

R1612314

R1612315

40

Date
Collected
Iroquois
10/27/2016
Iroquois
10/27/2016
Lakeview
10/27/2016
Listwood
10/27/2016
Briarwood
10/27/2016
Dake
10/27/2016
Dake
10/27/2016
Oakview
10/27/2016
District Office
10/27/2016
Dake
10/27/2016

Date
Received
by ALS

Sample Matrix

Requested
Analyses

Sample
Temperature
(C)

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

10/27/2016

Drinking Water

Lead

14.4

Chain of Custody (COC) forms are used to document the history of sample possession
from the time the sample containers leave their point of origin to the time the samples are
received by the laboratory. COCs are considered legal documents. WICSD accurately
detailed the COC for each sampling event.
Each sample was preserved, at ALS, with nitric acid to reduce the pH to less than 2 as per
USEPA Method 200.2.
Lead Analytical Methodology
The WICSD drinking water samples for Lead were analyzed using USEPA Method 200.8:
Determination of Trace Elements in Waters and Wastes by Inductively Coupled Plasma Mass Spectrometry (ICP-MS). Quality Assurance and Quality Control (QA/QC)
measures were designed to achieve the data quality goals associated with this sampling
event, such as Method Blanks, Lab Control Samples, Duplicate Samples, and Matrix
Spike Samples.
The QA/QC samples were within established limits and the data quality objectives were
met for the WICSD drinking water samples. The analytical data is considered accurate.
Drinking Water Samples Results
There were 622 drinking water samples collected from the WICSD Schools and District
Office on October 26 and 27, 2016. There were 87 outlets identified above the NYSDOH
Action Level of 15 ppb.

ME Holvey Consulting, LLC

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Mr. Jeffrey W. Rahn

Page 4
December 26, 2016

The sample results were detailed in the laboratory reports from ALS. The sampling event
is summarized below:
!!

Brookview School (R1611556) Of the 31 samples collected, there was one (1)
sample identified above 15 ppb.

!!

Colebrook School (R1611558) Of the 30 samples collected, none were identified

above 15 ppb.

!!

Seneca School (R1611559) Of the 28 samples collected, none were identified above
15 ppb.

!!

Rogers School (R1611561, 1611562) Of the 81 samples collected, six (6) samples
were identified above 15 ppb.

!!

Irondequoit High School (R1612043, R1612044, R1612045, R1612046, R1612047,

R1612048, R1612049) Of the 191 samples collected, 53 samples were identified
above 15 ppb.

!!

Iroquois School (R1612306, R1612307) Of the 59 samples collected, twelve (12)

samples were identified above 15 ppb.

!!

Lakeview School (R1612308) Of the 20 samples collected, six (6) samples were
identified above 15 ppb.

!!

Listwood School (R1612309) Of the 33 samples collected, none were identified

above 15 ppb.

!!

Briarwood School (R1612310) Of the 30 sample collected, none were identified

above 15 ppb.

!!

Dake School (R1612311, R1612312, R1612315) Of the 97 samples collected, eight

(8) samples were identified above 15 ppb.

!!

Oakview School (R1612313) Of the 15 samples collected, one (1) sample was
identified above 15 ppb.

!!

District Office (R1612314) Of the 7 samples collected, none were identified above
15 ppb.

ME Holvey Consulting, LLC

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Mr. Jeffrey W. Rahn

Page 5
December 26, 2016

Table 1 identifies outlets with lead levels above 15 ppb.

Table 1
Outlets above NYSDOH Action Level
Sample ID

Room

Results
(ppb)

NYSDOH Action
Limit

82.7

15.0

Brookview School
Room 144 Sink

Room 144
Rogers School

RGSL Room 319

Room 319

49.7

15.0

RGSL Room 023 Sink #2

Room 023

15.2

15.0

RGSL Room 023 Sink #1

Room 023

32.5

15.0

RGSL Room 131 Sink #2

Room 131

25.3

15.0

RGSL Room 312 Sink #2

Room 312

19.4

15.0

RGSL Room 310 Sink

Room 310

15.2

15.0

Irondequoit High School

Mens Room by 1064 Sink #1

Mens Bathroom

36.4

15.0

Mens Room by 1064 Sink #2

Mens Bathroom

33.6

15.0

Mens Room by 1064 Sink #3

Mens Bathroom

29.0

15.0

Room 1064 Bathroom Sink #1

Room 1064

23.6

15.0

Room 1064 Bathroom Sink #2

Room 1064

19.0

15.0

Room 1064 Bathroom Sink #3

Room 1064

18.8

15.0

Room 1170 Sink #1

Room 1170

26.8

15.0

Room 2035 Sink #1

Room 2035

20.4

15.0

Room 2035 Sink #3

Room 2035

18.5

15.0

Room 2035 Sink #4

Room 2035

28.9

15.0

Room 2035 Sink #5

Room 2035

25.9

15.0

Room 2035 Sink #6

Room 2035

38.6

15.0

Room 2022 Sink #2

Room 2022

21.1

15.0

Room 2022 Sink #3

Room 2022

19.7

15.0

Room 2022 Sink #4

Room 2022

29.5

15.0

Room 2022 Sink #5

Room 2022

23.6

15.0

Room 2022 Sink #6

Room 2022

47.3

15.0

Room 2022 Sink #7

Room 2022

24.8

15.0

Room 2021 Sink #3

Room 2021

33.6

15.0

Room 2021 Sink #4

Room 2021

18.4

15.0

Room 2021 Sink #5

Room 2021

32.8

15.0

Room 2021 Sink #6

Room 2021

41.5

15.0

Room 2021 Sink #7

Room 2021

28.3

15.0

Room 2021 Sink #8

Room 2021

39.3

15.0

Room 2000 Sink #1

Room 2000

29.6

15.0

Room 2000 Sink #2

Room 2000

137

15.0

Room 2000 Sink #3

Room 2000

26.7

15.0

ME Holvey Consulting, LLC

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Mr. Jeffrey W. Rahn

Page 6
December 26, 2016
Sample ID

Room

Results
(ppb)

NYSDOH Action
Limit

Room 2000 Sink #4

Room 2000

37.2

15.0

Room 2000 Sink #5

Room 2000

54.3

15.0

Room 2000 Sink #6

Room 2000

19.2

15.0

Girls Team Locker Room Sink #1

Girls Team Locker Room

27.0

15.0

Girls Team Locker Room Sink #2

Girls Team Locker Room

52.5

15.0

Room 3011 Science Sink #1

Room 3011

22.1

15.0

Room 3011 Science Sink #2

Room 3011

22.7

15.0

Room 3011 Science Sink #4

Room 3011

18.3

15.0

Room 3011 Science Sink #5

Room 3011

42.3

15.0

Room 3000 Sink #3

Room 3000

22.6

15.0

Room 3000 Sink #4

Room 3000

17.3

15.0

Room 3000 Sink #5

Room 3000

17.8

15.0

Room 3000 Sink #6

Room 3000

30.5

15.0

Room 3044 Sink #1

Room 3044

50.1

15.0

Room 3044 Sink #2

Room 3044

36.3

15.0

Room 3031 Sink #1

Room 3031

34.4

15.0

Room 3025 Sink #2

Room 3025

23.2

15.0

Room 3025 Sink #3

Room 3025

34.1

15.0

Room 3025 Sink #4

Room 3025

45.6

15.0

Room 3025 Sink #6

Room 3025

45.1

15.0

Room 3025 Sink #7

Room 3025

47.7

15.0

Room 3010 Sink #2

Room 3010

24.6

15.0

Room 3010 Sink #3

Room 3010

28.4

15.0

Room 3010 Sink #5

Room 3010

21.7

15.0

Room 3010 Sink #6

Room 3010

43.3

15.0

Room 3010 Sink #7

Room 3010

67.9

15.0

Iroquois School
Room 319 Sink

Room 319

27.9

15.0

Room 324 Sink

Room 324

23.6

15.0

Room 324 Fountain

Room 324

87.6

15.0

Room 325 Fountain

Room 325

19.8

15.0

Room 115 Sink

Room 115

36.7

15.0

Room 145 Sink

Room 145

16.3

15.0

Room 137 Sink

Room 137

15.8

15.0

Room 145 Sink #1

Room 145

16.5

15.0

Door 8

19.7

15.0

Room 40 Fountain

Room 40

18.5

15.0

Room 41 Sink #1

Room 411

15.1

15.0

Room 30

15.1

15.0

Door 8 Hose

Room 30 Sink #1

Lakeview School
Room 17 Lav Sink

Room 17

15.5

15.0

Room 18 Lav Sink

Room 18

23.4

15.0

Room 47 Sink

Room 47

65.0

15.0

ME Holvey Consulting, LLC

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Mr. Jeffrey W. Rahn

Page 7
December 26, 2016
Sample ID

Room

Results
(ppb)

NYSDOH Action
Limit

Room 37 Sink

Room 37

48.9

15.0

Room 45 Lav Sink

Room 45

29.4

15.0

Room 41 Lav Sink

Room 41

19.6

15.0

Dake School
Room 353 Sink #1

Room 353

26.9

15.0

Room 133 Sink #3

Room 133

48.9

15.0

Room 157 Sink #1

Room 157

17.4

15.0

Room 357 Prep Room

Room 357

25.0

15.0

Room 357 Sink #1

Room 357

19.2

15.0

Room 355 Prep Room 1

Room 355

19.4

15.0

Room 365 Sink #1

Room 365

24.8

15.0

Room 365 Sink #4

Room 365

16.0

15.0

34.1

15.0

Oakview School
Room 37 Lav Sink

Room 37

Solutions to lead in drinking water need to be addressed on both a short-term and a

permanent basis. Short-term measures may include flushing the pipes to bring fresh water
to the source, removing the outlet from service or providing bottled water until the source
of contamination is resolved. Permanent remedies must be implemented in order to
eliminate the contaminant source.
The following recommendations and remedial options are identified for the above-listed
outlets:
1.! Take outlet out of service.
2.! Do not use for drinking water purposes adequate signage.
3.! Clean aerator, re-sample first draw and flush samples to identify if the
problem is at the faucet or interior plumbing; and/or,
4.! Replace outlet with NSF-approved devices and re-test.
Temporary control measures can be implemented by WICSD to properly address each
situation, such as:
1.! A flushing program until the outlets can be replaced. However, this is based
on flush samples meeting the NYSDOH Action Levels. Therefore, these
identified faucets must be sampled as a flush and tested.
2.! Placard sinks with notices that water should not be consumed, until appropriate
permanent actions can be implemented, such as removing/replacing a fixture.
These outlets can be used for hand washing and dish washing, not drinking or
food preparation.

ME Holvey Consulting, LLC

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Mr. Jeffrey W. Rahn

Page 8
December 26, 2016

Permanent remedies can be implemented in order to eliminate the contaminant source.

These options, outlined in the USEPA 3Ts guidance document include:
! Take outlet out of service.
! Replace outlets where there is localized contamination with new, certified
components. EPA recognizes NSF Standard 61, Section 9 as a performance
standard. It limits leaching of lead into the drinking water. The standard
regulates devices that dispense water for human ingestion.
! Install point-of-use devices that control lead at the tap.
The remedial options are based on the 3Ts guidance document as referenced in the
NYSDOH Emergency Regulation:
The Environmental Protection Agencys 3Ts for Reducing Lead in Drinking
Water in Schools, Revised Technical Guidance will be used as a technical
reference for implementation of the regulation.
NYSDOH Reporting Requirements
The NYSDOH requires that lead in drinking water results be reported as follows:
! When an action level is exceeded:
o! Schools must notify the local health department within one (1) business day
after receiving lab report.
o! School must notify the school community (staff, parents/guardians), IN
WRITING, within ten (10) business days of receiving lab reports.
! Posting lab results on school website: Schools must post their lab results on their
school website as soon as practical, but within 6 weeks of receiving the lab reports.
! Reporting result information in HERDS: Schools must report data relating to test
results in HERDS as soon as practical, but within 10 business days of receiving the
lab reports
Summary
The October 26 and 27, 2016 drinking water sampling events at West Irondequoit Central
School District was completed in compliance with the protocols set forth by the NYSDOH
Regulation and the USEPA 3Ts guidance.
There were no deviations from the lead sampling or analytical testing protocol.
Of the 622 water outlets sampled, 87 samples tested above the NYSDOH Action Level of
15 ppb. The 87 outlets account for 14% of tested fixtures.
Of the eighty-seven (87) outlets identified above the Action Level, it appears that fortyfive (45) of the samples were at laboratory sink faucets in Science Rooms. As per the
NYSDOH FAQs No. 7 (dated November 1, 2016), the school has the ability to make a
determination if the outlet is to be used for drinking water. If the Science Classroom is in
full control of the teacher, those lab sinks may be designated for non-potable use. A
Standard Operating Procedure (SOP) should be documented for the Science Rooms to
ME Holvey Consulting, LLC

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Mr. Jeffrey W. Rahn

Page 9
December 26, 2016

include the prohibition of using the sinks for drinking purposes as placarding alone is not
considered a permanent remedial measure. The concern is if the classroom is used in the
evenings or weekends for continuing education, etc. and the room is no longer in control
of the teacher, there is a potential for use of the sinks for drinking purpose (however
unlikely).
The identified outlets should be taken out of service until remedial measures have been
implemented. If the outlets will continue to operate for hand washing or dishwashing
purposes, they need to be adequately and securely placarded (See Attachment 1). Again,
this is a temporary measure. If the outlets are cleaned and/or replaced, the outlet must be
re-tested prior to being placed back into service for drinking purposes.
Priority for remedial measure should be conducted at outlets, identified above 15 ppb, that
are used for drinking water sources, such as the drinking fountains, kitchen sinks and
classroom sinks
Please call me at (585) 690-3361 if you have any questions or comments.
Respectfully Submitted,
ME Holvey Consulting, LLC by Mary Ellen Holvey, CIH
Senior Industrial Hygienist

ME Holvey Consulting, LLC

14-153

Attachment 1
NYSDOH Placarding Examples

Do not use for drinking

Do not use for drinking

!
Hand washing only

Not for drinking use

Do not use for drinking

!
Hand washing only

Not for drinking use