Annex_B_FY2018_AFH_Initial_Sampling_Protocol.pdf

U.S. Arm y Publ ic Heal th Center

Protocol for Sampling Lead in Drinking Water at Army Family Housing Residences

General Medical: 500A

Approved for public release; distribution unlimited

September 2017

Annex B (Pro toco l fo r Sampl ing Lead in Dr ink ing Water a t Army Fami ly Hous ing Res idences) to OPORD 18-109 – Pro toco l fo r Sampl ing Lead in Dr ink ing Water a t Army Fami ly Hous ing Res idences

Use of trademarked name(s) does not imply endorsement by the U.S. Army but is intended only to assist in identification of a specific product.

PROTOCOL FOR SAMPLING LEAD IN DRINKING WATER

AT ARMY FAMILY HOUSING RESIDENCES

1. PURPOSE. To provide a standardized protocol for sampling drinking water from sinks primarily used for human consumption in Army family housing residences in order to characterize lead exposure from drinking water under normal use and water usage patterns.

2. SCOPE. This protocol supports U.S. Army Installation Management Command (IMCOM) Operations Order (OPORD) 16-080 and subsequent Fragmentary Orders (FRAGOs). This protocol explains, in a 6-step process, how to conduct sampling for lead in drinking water from sinks at Army family housing (AFH) residences. Proper sampling IAW this protocol requires sample collection at AFH residences as follows:

First, collect first draw, 30-second flushed, and 2-minute flushed samples (i.e., a 3-sample set) from the kitchen sink; and

Then, if sampling bathroom sinks, collect only a single first draw sample from each bathroom sink.

This protocol is largely based upon guidance contained in these documents:

3Ts for Reducing Lead in Drinking Water in Child Care Facilities: Revised Guidance, U.S. Environmental Protection Agency (EPA) 816-R-05-001, Dec

3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance, EPA 816-B-05-008, Oct 06.

Michigan Department of Environmental Quality Guidance on Drinking Water

Sampling for Lead and Copper at Schools and Daycares on Community Water Supplies, Michigan Department of Environmental Quality, Aug 16.

This sampling is not for regulatory or compliance purposes and is not related to the Lead and Copper Rule (LCR) sampling.

Protocol for Sampling Lead in Drinking Water at Army Family Housing FY 2018

3. BACKGROUND

Appendix A provides the history and reasoning for the sampling procedures in this protocol.

4. STEP 1: LABORATORY COORDINATION

Laboratories at U.S. Army Public Health Center (APHC), U.S Army Public Health Command-Europe (PHC-E), and U.S. Army Public Health Command–Pacific (PHC-P) will provide analytical support. The following is contact information for the laboratories:

Continental U.S. Installations contact the APHC Laboratory at:

APHC Client Services Division

Email: usarmy.apg.medcom-phc.list.org-ls-ls@mail.mil

Telephone: 410-436-2208

DSN: 584-2208

Overseas Installations contact Public Health Command Laboratories at:

PHC-P Division of Laboratory Sciences

Email: usarmy.zama.medcom-jpn.list.phcr-pacific-cmd@mail.mil

Telephone: 011-81-46-407-5615/8421

DSN: (315) 263-5615/8421

PHC-E Laboratory Sciences

Email: usarmy.landstuhl.medcom-ph-e.mbx.ls-hotline@mail.mil

Telephone:

06371-9464-9710 (within Germany) (+49) 6371-9464-9710 (from outside Germany)

DSN: (314) 590-9710

Samples must be collected in 250-mL plastic sample containers. Laboratories will provide “wide mouth” plastic sample containers. The sample container openings should be wide enough to allow collection of samples from a fully open sink faucet. This is representative sampling at a flow rate resembling the way someone would usually fill a glass of water or a pot for cooking. In addition, laboratories will provide any other supplies needed such as chain of custody forms and seals, and shipping containers.

Lead samples in drinking water require preservation with nitric acid (HNO3). Due to safety concerns and to help expedite sampling by installation personnel, sample preservation will be done by the laboratory immediately upon receipt of the samples.

The sample can be held up to 14 days prior to acidification without loss of lead through absorption, but EPA recommends sample preservation as soon as possible. To ensure preservation occurs within 14 days of collection, samples must be received by the laboratory within 8-10 days of collection to ensure accurate data.

5. STEP 2: DETERMINING WHEN TO SAMPLE.

Samples must be collected after water has sat in contact with plumbing for a period of time and before any water is used in the building. In AFH residences, outlets should sit unused for a typical overnight period in an occupied residence or for a minimum of 6-8 hours in a vacant AFH residence (which would be a typical overnight period of non-usage). The purpose of these minimum time periods is to be representative of typical overnight stagnation (i.e., normal water usage patterns).

For occupied AFH residences, request residents to refrain from using any water overnight. Samples must be collected the following morning before any water is used in the entire residence.

While not recommended, if vacant AFH residences must be sampled, water must sit unused for a minimum of 6- 8 hours. No water should be used in the residence during this time. It is acceptable to conduct sampling after longer periods of non-usage (for example over a weekend), but it is not recommended to conduct sampling after extended periods of non-usage (i.e., several weeks or months). If AFH residences have been vacant for such extended periods be sure to thoroughly flush residence plumbing prior to letting the water sit unused (see section 6; step 3: choosing and preparing outlets for sampling).

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6. STEP 3: CHOOSING AND PREPARING OUTLETS FOR SAMPLING.

All primary drinking water outlets must be sampled. Primary drinking water outlets are those sinks that typically and routinely provide water for consumption in AFH residences. Water for consumption includes water used for drinking and in food, beverage, and infant formula preparation.

Kitchen sinks must be sampled. If any bathroom sinks are routinely used for consumptive purposes (for example children frequently drink from a bathroom sink) then those sinks should be considered primary drinking water outlets and be sampled. It may be necessary to consult with residents prior to sampling to determine which sinks, in addition to the kitchen sink, should be sampled.

Preparing outlets for sampling may require them to be labeled or identified in such a way to prevent the drinking water outlet from being used or disturbed. This could be accomplished by placing a bag over the drinking water outlet and attaching a tag identifying the outlet as a sample site. Appendix B provides example tags.

Do not close any sink shut-off valves to prevent their use prior to sample collection.

Closing valves may produce minute scrapings from the valves that could cause inaccurate, non-representative results showing higher than actual lead levels in the water.

DO NOT flush sinks in occupied AFH residences or instruct residents to flush them in preparation for sampling because this would not be representative of normal usage patterns.

DO NOT remove or clean a sink faucet aerator or instruct residents to remove/clean aerators in preparation for sampling because this would also not be representative of normal usage patterns.

While sampling occupied AFH residences is the best approach for characterizing lead exposure from drinking water in these facilities, it may be necessary to sample vacant residences. In the event that sampling of vacant AFH residences must be conducted, the building plumbing must be flushed prior to allowing water to sit unused before sampling. The purpose of this flushing is to simulate typical water quality that would be provided to families and children if AFH residences were occupied. The quality of drinking water that has sat unused in building plumbing for several weeks or months will likely be significantly degraded and would not be representative of typical water quality provided. Therefore, it’s necessary to thoroughly flush building plumbing prior to sampling. The following guidance should be used for flushing. Note that flushing building plumbing any time after AFH residences have been vacant for extended periods is an excellent best management practice to employ prior to opening/occupying these facilities.

Flushing vacant AFH residences prior to letting water sit unused before sampling involves achieving a high flowrate and flushing all sinks (kitchen and bathroom sinks) that could be used as primary drinking water outlets.

First, run cold water at the highest flow in the bathtub using the bathtub faucet (not the showerhead) for 5 minutes.

Next, run cold water at the highest flow (cold water tap fully open) from the kitchen faucet for 5 minutes.

Then, flush each bathroom sink successively in the same manner as the kitchen faucet (5 minutes each with cold water tap fully open).

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7. STEP 4: LABELING SAMPLE CONTAINERS.

Prior to collecting samples from a sink, fill out the sample container labels using a permanent marker with a unique sample identifier (e.g., 1a) and the date and time the sample is collected.

Please use a unique sample identifier (ID) for each sample collected at an installation.

One option is to use a numbering system that identifies a unique outlet followed by alphabetical lowercase letters that identifies sample(s) collected from the outlet. As an example, the first sink (kitchen sink) sampled at an AFH residence on an installation is identified as “1”, and so the three samples collected from this sink will be identified as:

“1a” (first draw); “1b” (30-sec flush); and “1c” (2-min flush). No other outlets sampled for this effort at this installation should be identified as “1”. Subsequent samples collected at bathroom sinks in the same AFH residence as well as sinks in other AFH residences at the same installation will have their own unique sample IDs. For example, the second outlet sampled at this installation is a bathroom sink and will be identified as “2” and the first draw sample collected from this outlet will be identified as “2a”.

8. STEP 5: COLLECTING SAMPLES

First, three samples will be collected from the kitchen sink - a first draw sample; a 30-second flush sample; and a 2-minute flush sample (i.e., a 3-sample set) as shown in Figure 1. Then, if any bathroom sinks will be sampled, collect only a first draw sample from them.

Figure 1. Three-Sample Set Collected from the Kitchen Sink.

Ensure sample containers are kept sealed until collection of the samples.

For vacant AFH residences, collect samples after water has sat unused for a minimum of 6 -8 hours (or longer) and before any water is used.

For occupied AFH residences, if requesting residents to collect samples, instruct them to collect samples first thing in the morning after no water has been used overnight.

Provide residents with sample containers and directions for collecting samples (provided at the end of this section). Be sure to pre-fill the container labels with unique sample IDs that identify: 1) the residence location (e.g., address/bldg. number); 2) which sink (e.g., kitchen, kids bath); and 3) the type of sample (first draw, 30-second flush, or 2-minute flush).

Do not run any drinking water outlets or flush toilets elsewhere in residence before collecting samples.

Collect Samples from AFH Residences in the Following Manner:

Collect a 3-sample set from the kitchen sink first. Collect these samples without shutting off the water.

Use only the cold water tap.

Fill sample containers mostly full to allow room for addition of several milliliters of acid by the laboratory.

Kitchen sink sample collection:

o First draw sample collection. Place the first draw labeled sample container (e.g., the container with ‘a’ on the label) under the faucet. Do not allow the sample container to touch the faucet. Fully open the faucet’s cold water tap. Collect water immediately after opening the faucet without allowing any water to go to waste. With the water still running set the mostly full sample container aside and begin timing for collection of the 30-second and 2-minute flushed samples. Cap and seal the container after all samples are collected.

o 30-second flush-sample collection. After 30 seconds with the water still running, quickly place the 30-second flush-labeled sample container (e.g., labeled ‘b’) under the faucet and fill the container mostly full. Allow the water to continue running and set the sample container aside. Continue timing.

o 2-minute flush-sample collection. After the water has continued to flow for

2 minutes, quickly place the 2-minute flush-labeled sample container (e.g., labeled ‘c’) under the faucet and fill the container mostly full. Turn off the water and cap and seal all containers.

After completing sampling of the kitchen sink, move to any of the bathroom sinks to be sampled.

Bathroom sink sample collection: Place the labeled sample container corresponding to the specific bathroom sink (e.g., the container with ‘kids bath’ on the label) under the faucet. Do not allow the sample container to touch the faucet. Fully open the faucet’s cold water tap. Collect water immediately after opening the faucet without allowing any water to go to waste. Turn off the water and cap and seal the container.

RESIDENT DIRECTIONS FOR COLLECTING DRINKING WATER SAMPLES

[Note: If requesting residents to collect samples, provide sample containers and these directions for collecting samples. Be sure to pre-fill the container labels with unique sample IDs that identify: 1) the residence location (e.g., address/bldg. number); 2) which sink (e.g., kitchen, kids bath); and 3) the type of sample (first draw, 30-second flush, or 2-minute flush).]

1. Before Collecting Water Samples. The water will need to sit unused in your residence overnight before you collect samples. This means you shouldn’t use any water at all during this period of time (you shouldn’t flush a toilet or take a shower).

Please be sure to write down how long the water sat unused and provide this information to Garrison personnel who pick up the samples you collected. You can write this information down on the last page of these directions.

2. Collecting Water Samples. Collect water samples first thing in the morning. Start by collecting samples from the kitchen sink and then move to the bathroom sinks if they are to be sampled too. Arrange the sample containers next to the sink that matches the sample ID on the container labels (for example – place the 3 containers labeled ‘kitchen’ next to the kitchen sink).

First, collect water samples from the kitchen sink. You will collect 3 samples from the kitchen sink as shown in the figure:

Figure. 3-Sample Set for the Kitchen Sink o The first sample is called a first draw sample and will be collected in the corresponding labeled container (using the figure as an example, the first draw sample will be collected in the container labeled ‘Kitchen 1a’).

o The second sample is called a 30-second flush sample (in the figure, this sample will be collected in the container labeled ‘Kitchen 1b’).

o The third and last sample is called a 2-minute flush sample (in the figure, this sample will be collected in the container labeled ‘Kitchen 1c’).

o First draw sample collection. Place the first draw-labeled sample container under the kitchen faucet. Do not allow the sample container to touch the faucet. Fully open the faucet’s cold water tap (as though you were filling a glass or a pot for cooking). Collect water immediately after opening the faucet without allowing any water to go to waste. Fill the container mostly full and set aside. Continue to let the water run.

o 30-second flush-sample collection. Next, after the water has run for 30 seconds, quickly place the 30-second flush-labeled sample container under the faucet and fill the container mostly full. Set the container aside. Let the water continue to flow and keep track of the timing.

o 2-minute flush-sample collection. After the water has run for 2 minutes, quickly place the 2-minute flush-labeled sample container under the faucet and fill the container mostly full. Turn off the faucet. Cap and seal all containers.

If you are also collecting samples from any bathroom sinks, move to those sinks and collect only a first draw sample.

o Bathroom sink sample collection. Place the labeled sample container corresponding to the specific bathroom sink (e.g., the container with ‘kids bath’ on the label) under the faucet. Do not allow the sample container to touch the faucet. Fully open the faucet’s cold water tap. Collect water immediately after opening the faucet without allowing any water to go to waste. Turn off the water and cap and seal the container.

Be sure to write down at the end of these directions how long water sat unused before you collected samples and the date and times you collected samples.

3. Contact Garrison Personnel for Sample Pickup. You can leave the samples outside your front door if you won’t be home for pickup. Please be sure to include these directions with the samples.

4. Garrison Personnel Contact Information.

INSERT GARRISON POC NAME(S), PHONE NUMBERS, AND EMAILS.

5. Information to Write Down.

a. How long did the water sit unused before you collected the water samples?

Example: 8 ½ hours.

b. What were the date and times of the day when you collected the water samples?

Example: Kitchen – 7 June 2018 at 0530. Bathroom – 7 June 2018 at 0535.

9. STEP 5: SHIPPING SAMPLES

Ship or deliver samples to arrive at the laboratory as soon as practical but within 8-10 days of collection.

Samples must be acid-preserved by the laboratory within 14 days of collection.

To facilitate sample handling, processing, and preservation by acidification:

Confirm the proper shipping address for the laboratory.

Ship samples using the provided coolers and shipping return labels.

Fill out the chain-of-custody form, and include with the samples. Please fill out the chain of custody as completely and accurately as possible. Contact the laboratory if you have any questions about completing these forms.

Pack the samples in the cooler; ice is not necessary. Secure the samples in the cooler/shipping container so they don’t move around to avoid potential leaking from caps jarred loose. Packing material such as wadded paper or pieces of cardboard could be used. Bubble wrap is not necessary.

Seal the cooler using packing tape, and place a provided cooler seal on the cooler, applying the seal to both the cooler body, and cover of the cooler.

Notify the laboratory at least 1 day prior to shipping or delivering the samples.

If shipping via FedEx® drop the cooler at the nearest FedEx pickup site and ship via “Priority Overnight” service. Please do not ship via “First Overnight” service.

10. FACILITY AND SAMPLE FIELD DATA SHEETS.

Fill out the facility and sample field data sheets and provide electronic copies to the APHC point of contact listed in the most recent FRAGO to IMCOM OPORD 16-080.

These data sheets are located on HQ IMCOM’s sharepoint website for this sampling effort.

The Facility Field Data Sheet (Figure 2) is a fillable pdf document intended to obtain information on potential sources of lead in facility/building plumbing where samples are collected. It may be necessary to talk to plumbing personnel and personnel in the real property office to complete this sheet.

Figure 2. Facility Field Data Sheet, FFDS

The Sample Field Data Sheet, SFDS in Figure 3 is an Excel® file and is intended to document sample information from all facilities at an installation.

Figure 3. Sample Field Data Sheet, SFDS

Room # / Housing Unit

Address

Room/sample location description (classroom, cafeteria, kitchen)

4a 5 Apt. 1A Kitchen S = Sink 20-Mar-16 0530 O = Occupied 4b 5 Apt. 1A Kitchen S 20-Mar-16 0531 O

4c 5 Apt. 1A Kitchen S 20-Mar-16 0533 O

EXAMPLE

Is Facility Vacant or Occupied?

Sample Collection

Date

Sample Collection

Time

Sample ID (Number)

Facility/ Building #

Sample Location

Outlet type

11. POINT OF CONTACT. For questions about these procedures, please contact the APHC POC listed in the most recent FRAGO to IMCOM OPORD 16-080; or contact the Drinking Water Branch of the APHC at: DSN 584-3919, commercial (410) 436-3919, or email:

usarmy.apg.medcom-phc.mbx.dehe-water-supply@mail.mil..

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APPENDIX A

PROTOCOL BACKGROUND

A-2

A1. ORIGNIAL SAMPLING APPROACH. The sampling approach for Army family housing (AFH) was first introduced in the sample protocol developed in support of U.S.

Installation Management Command (IMCOM) Operations Order (OPORD) 16-080 in fiscal year (FY) 2016. The protocol contained sampling approaches for both high risk facilities (child development centers, elementary schools, and youth centers) and AFH.

The AFH sampling approach was based on recent research on lead corrosion in drinking water. Research suggested that sources of elevated lead may be found deeper in supply plumbing and/or service line, and higher flowrates may entrain lead-containing particulates which could result in higher lead levels at an outlet. The sampling procedure required collection of a set of three samples (a first draw sample, a 30-second flushed sample, and a 2-minute flushed sample) at the highest flowrate possible (e.g., fully open cold water tap) at each identified sink in an AFH residence.

The criteria for taking action at an individual sink in an AFH residence was 15 parts per billion (ppb).

A2. FISCAL YEAR 2017 UPDATE. In early FY 2017, the sampling approach for AFH was updated to include flushing guidance when sampling vacant AFH units (see section 6). While sampling occupied AFH residences is the best approach for characterizing lead exposure from drinking water, it may be necessary in some circumstances to sample vacant residences. In the event that sampling of vacant AFH residences must be conducted, the building plumbing must be flushed prior to allowing water to sit unused before sampling. The purpose of this flushing is an attempt to simulate typical water quality that would be provided to families if AFH residences were occupied. The quality of drinking water that has sat unused in building plumbing for several weeks or months will likely be significantly degraded and would not be representative of typical water quality provided. Therefore, it’s necessary to thoroughly flush building plumbing prior to sampling. Note that flushing building plumbing any time after AFH residences have been vacant for extended periods prior to opening/occupying these facilities.is an excellent best management practice to improve and/or maintain overall water quality

A3. FISCAL YEAR 2018 UPDATE. For FY2018 the AFH and high risk facility sampling approaches were separated into individual sampling protocols. The AFH sampling approach was modified to better balance the sampling burden and still maintain a rigorous approach that seeks to accurately characterize lead exposure from drinking water.

A review of the FY16 and FY17 sampling effort showed that most Garrisons were sampling the kitchen and all the bathroom sinks in AFH residences. This resulted in the collection of a very large number of samples. Based on available data, a total of 10,813 samples were collected from 3,584 sinks in 2,158 AFH residences. There were 734 sinks that had at least one sample result greater than 15 ppb lead. The figure shows which sample for those 734 sinks had elevated lead levels greater than 15 ppb. The

A-3 majority of sinks (82 percent) had only a first draw sample result greater than 15 ppb lead while approximately 20 percent had an elevated flushed sample result (30-second flush and/or 2-minute flush). These results suggest that the sample protocol could reduce, but not completely eliminate collection of flushed samples. Thus, the sample protocol was modified to require collection of a 3-sample set (first draw, 30-second flush, 2-minute flush) from the kitchen sink and, if sampling bathroom sinks, collection of only first draw samples from bathroom sinks. This modification should reduce overall sample burden and still be effective in characterizing lead exposure from drinking water in AFH (at the time of sampling).

Figure. Evaluation of FY16 & FY17 lead sample results > 15 ppb n = 734 outlets

B-1

APPENDIX B

EXAMPLE OUTLET SAMPLE TAGS

B-2

DO NOT USE. DO NOT DISTURB.

Drinking Water Sampling in Progress.

Point of Contact:

Name:

Phone Number:

DO NOT USE. DO NOT DISTURB.

Drinking Water Sampling in Progress.

Point of Contact:

Name:

Phone Number: