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Water Sampling Plan 12 6 2004.xls

Howard University



In February, 2004, the District of Columbia Water and Sewer Authority (DCWASA) disclosed that high lead levels were found in drinking water of more than four thousand homes in the District of Columbia. DCWASA also reported that “… it is very unlikely that any buildings that are larger than a single family home (schools, other public buildings, for example) will have been built with these (lead) service lines because construction materials for larger facilities were different.”[1] Although, DCWASA attributed the high lead levels to single family homes with lead service lines, it raised concern about the lead levels in drinking water in Howard University (HU) buildings. To ensure that the lead levels in the University’s drinking water did not pose a potential hazard to students, faculty and staff, the Drinking Water Sampling Program was implemented as a precautionary measure.

 Sampling and Analysis Methods

HU retained a reputable environmental consulting contractor (MECX, LLC) to collect water samples for lead analysis from all university occupied facilities.  MECX followed the guidance developed by the U.S. Environmental Protection Agency (EPA) for all water samples collected.  Applicable guidance documents were, “Lead in Drinking Water in Schools and Non-Residential Buildings”, EPA 812-B-94-002, April, 1994, and “Sampling for Lead in Drinking Water in Nursery Schools and Day Care Facilities”, EPA 812-B-94-003, April, 1994.[2]  EPA guidance includes a two-step sampling process recommended for large buildings.  Step 1.  Preparation:  Each sample location is identified and isolated for a minimum of 8 hours and a maximum of 18 hours.  This time distinction is made to ensure that the water collected is representative of the building’s normal water use patterns.  Signs were posted at each location to ensure no water was withdrawn from the taps or fountains from which the samples were to be collected.  Step 2:  An initial Sample (250 ML) of water is collected and given a unique ID number.  Samples are then forwarded to an EPA certified laboratory for lead level analysis.  Test results indicating lead content of 20 parts per billion (ppb) or less is considered safe and requires no action.  If analysis indicate a lead level over 20 ppb a retest of that water source is required.  The water source must again be isolated as in Step #1, prior to retesting.  Retesting includes taking two additional water samples: the first sample is taken after a 30 second flush.  A second sample is taken after a 60 second flush.  Both samples are then forward to the EPA approved lab for analysis.  If the lead levels remain above 20 ppb the source is turned off until additional steps are taken (i.e. filtering, changing hardware, etc)  

 Testing Results

Since March, 2004, HU has collected 151 water samples to test for lead in drinking water from representative taps in 71 occupied campus buildings.  Only 13 of the 151 samples were above the EPA action level of 20 ppb.  Upon retesting all locations were below the EPA standard of 20 ppb.  A table showing the results of the complete sampling program, including those facilities that required retesting, is listed as Attachment A. 

 As we gathered information on items (water fountains, and other appliances) which may cause high lead readings prior to taking the water samples, we discovered that certain water fountains had been recalled by their manufacturer.  Attachment B contains the results of a campus wide survey of water fountains that were checked to determine whether they were listed on any manufacturer’s recall list containing internal lead parts.  Those fountains that are check-marked were found to be on recall lists and have been taken out of service and are scheduled to be replaced.

 As a result of a recent DCWASA public notification on high bacteria counts in the water distribution system, on October 14, 2004, MECX was also tasked to start sampling the remaining facilities on its schedule for coliform bacteria as part of the lead in drinking water sampling program.  All of the buildings sampled for coliform bacteria tested negative on final tests and analysis.

 The drinking water sampling program was completed on November 12, 2004.  Laboratory results were received on December 3, 2004.   From this point forward, the drinking water sampling program will be conducted annually and become a permanent part of the Office of Environmental Health and Safety’s environmental compliance program.

[1] “Lead Information Update,”

[2] “Lead in Drinking Water in Schools and Non-Residential Buildings,” EPA 812-B-94-002, April, 1994, p.28.



This page was last updated: December 9, 2004 eSystems Group