Lead Reduction

Lead Reduction in Schools Information for Administrators

This information has been taken from the DEQ website: http://deq.mt.gov/Water/DrinkingWater/LeadInSchools

For more information please refer to this web page or contact Greg Montgomery at the DEQ.

Montana Department of Public Health and Human Services (DPHHS) has rolled out a Lead Reduction in School Drinking Water Rule (Montana ARM 37.111.832(8)). This rule was enacted to protect school children by minimizing lead levels in drinking water provided at Montana’s schools.

DEQ (Department of Environmental Quality) has been awarded a grant from the EPA to help schools cover the costs of sampling for lead in their drinking water. DEQ has set up a reimbursement program to pay for the initial sample laboratory costs. The laboratories will be invoicing DEQ directly. The reimbursement program will only be available to public schools.

DEQ is also working with OPI to develop a grant program to assist schools with remediation costs if the lead is found above action levels. Please go to the Funding section on the Lead Reduction in School Drinking Water Program Webpage.

Children are the most susceptible to lead exposure and spend a large amount of their childhood in schools. It is extremely important that schools are providing safe drinking water.

Program Requirements:

DPHHS is partnering with DEQ to provide sampling and remediation technical assistance and guidance to schools. DEQ has developed guidance documents to help assist schools through the required lead sampling program.

The requirements for schools are as follows:

  1. Effective January 17, 2020, all schools accredited by the Montana Board of Public Education will be required to sample all drinking water fountains and kitchen fixtures that can be used for human consumption. All other potential human consumption fixtures (HCF) must be sampled, unless the school or district submits a testing plan to the DEQ to test representative samples of potential HCFs in the school. Schools will have until December 31, 2021, to complete the initial sampling.
  2. Create and maintain a simple schematic and inventory of plumbing materials, all fixtures and those that are used for human consumption. Schools are required to prepare a simple sketch or drawing (also could be aerial photo) showing the locations of all their water fixtures. Schools will also prepare a plumbing inventory including a list of all fixtures, plumbing types, maintenance or repair history, and general school information. The inventory information will be used to create a sampling plan. (After speaking with Mr. Montgomery: School evacuation maps may be used for the schematic. He realizes that some of the information will be difficult to find. He requests that the district do the best they can.)
  3. Create and implement a water flushing plan. Schools will be required to flush their water systems anytime a school has been inactive for greater than 3 days. Water flushing is an effective way for schools to improve their water quality. It removes stagnant water from pipes and fixtures that may contain higher concentrations of lead. A water flushing plan/procedure is required to be submitted to the DEQ by September 1, 2021.
  4. Follow-up actions will be required depending on the results of the sampling. The results will be placed in three bins (categories).
    • Bin 1 – Lead concentrations greater than 15.0 micrograms per Liter (ug/L) – fixture must be immediately removed from service.
    • Bin 2 – Lead concentrations greater than 5.0 ug/L and less than 15.0 ug/L – fixture must be fixed, replaced or removed from service.
    • Bin 3 – Lead concentrations less than 5.0 ug/L – no action is required.

Once remedial activities are completed, a follow-up sample is required from each fixture that had a remedial action. The follow-up sample is required before that fixture can be put back in service to confirm that lead concentrations are less than 5.0 ug/L. A second follow-up sample is required one year following completion of the remedial action.

  1. Routine sampling required following the initial sampling event. Once all fixtures are in Bin 3, the school must sample once every 3 calendar years to confirm HCFs continue to deliver water less than 5.0 ug/L. School may submit a waiver to DEQ in writing using a form approved by the department. The sample frequency may be adjusted by the DEQ based on test results and inventory.
  2. Schools are required to make test results publicly available. Schools are encouraged to inform parents and staff about your school’s lead sampling program. Templates are available for letters to parents, informational posters, and informational postcards. Schools will be required to make the results easily available and accessible to parents and staff. Sample results with remediation status will be publicly available on the DEQ website. (Area of the site still under construction).

DEQ is developing a web application that will allow schools to easily set up and maintain the required information. It will also allow schools to review their lead results and assign correction actions if needed. The web application is still under construction and should be available shortly.

Until the web application is ready, please follow the steps below in the Step by Step Flow Diagram. The forms and templates are available in the Guidance and Forms Section. Please follow the steps carefully. Samples cannot be collected until your school has completed the setup process (plumbing history and inventory).

The program is being rolled out in waves. Elementary schools and schools that contain elementary grades (K-8 and K-12) will start first. Middle and High School can start on November 1, 2020.

 

For a better copy of this diagram, please visit the DEQ webpage:

http://deq.mt.gov/Water/DrinkingWater/LeadInSchools/LISAdmin#Reg

 

For further information please refer to the DEQ webpage. Also, please contact:

Greg Montgomery

Reduction in School Drinking Water Rule Manager

Montana Department of Environmental Quality

1520 E 6th Ave

Helena, MT 59601

406-444-5312

gregory.montgomery@mt.gov

Schools can also contact their municipal water department for assistance. Municipal water systems are required to collect a variety of samples to maintain compliance with state and federal drinking water rules. They can be able to provide valuable information/assistance on how to coordinate with laboratories, properly collect and shop samples and understanding laboratory results.

Regional training sessions and webinars will be forthcoming to assist with this process.

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