Questions about Lead?

Email us your questions: schoolwater@delaware.gov

Why hasn’t the state tested drinking water in schools before?

While school drinking water has been tested in the past, not every school has been tested, and not within a single initiative. EPA is in the process of revising the Lead and Copper Rule (LCR) which, while not finalized, proposes to require public water systems to test the drinking water that they supply in 20% of elementary schools and childcare facilities each year, complete an inventory of lead service lines, and review the current triggers for action when lead is detected in drinking water. Sampling conducted under the EPA WIIN Grant and the State’s initiative is more comprehensive and meant to identify specific sources and guide remediation.

The EPA offered grants specifically for sampling of consumable school water sources for the first time in 2019. The Delaware Department of Education proactively sought this EPA grant to test lead water levels in every school Statewide. During this ongoing project, public water systems have continued to sample schools in compliance with the Lead and Copper Rule requirements indicated above.

The State is working to implement the tenants of Senate Bill 270 (SB 270) which establishes an evaluation and assessment system created by the Department of Education to determine whether a school facility is in good repair to assure that school facilities are clean, safe, and functional for staff and students. SB 270 also mandates school testing beginning on or before 1/1/24.

Why was sampling conducted during COVID-19 a problem?

Schools sat empty and unused for approximately a year. Lead builds up when fixtures are unused and water is not circulating through a buildings plumbing system. EPA’s sampling protocol aims to collect samples that are representative of what the average person drinks every day, not water that has been sitting. EPA sampling protocols were not followed during our testing, resulting in artificially inflated lead measurements. Future sampling conducted under the EPA WIIN Grant and the State’s initiative will adhere to the EPA 3T sampling guidance.

What does “we are working with the EPA” mean?

This is an EPA grant designated to DOE and DPH to test consumable water sources in Delaware’s schools. It means that the EPA is providing technical and regulatory assistance to ensure DPH and DOE use best management practices for administration of the Lead in Schools grant guidance.

Why is lead-contaminated water bad?

Lead is toxic to children and adults. Young children are particularly vulnerable to lead because the physical and behavioral effects of lead occur at lower exposure levels in children than in adults. A dose of lead that would have little effect on an adult can have a significant effect on a child. In children, low levels of exposure have been linked to damage to the central and peripheral nervous system, learning disabilities, shorter stature, impaired hearing, and impaired formation and function of blood cells. The Environmental Protection Agency (EPA) estimates that drinking water can make up 20% or more of a person’s total exposure to lead.

Health Effects of Lead on Children:

  • Behavior and learning problems
  • Hyperactivity and lower IQ
  • Slowed growth
  • Hearing problems
  • Anemia (low levels of red blood cells)

How can lead get into school water?

A number of factors are involved in the extent to which lead enters the water, including the chemistry of the water, temperature of the water, amount of wear in the pipes, how long the water stays in pipes (i.e., if the building was closed for a while and no water was run), and the amount of lead the water comes into contact with. To determine the source of lead in drinking water, specific sampling methods and onsite observations are used by experts during their assessment. Once the source has been identified, short-term and long-term solutions to the facility can be recommended by DPH.

What is considered an Elevated Blood Lead Level?

The amount of lead in blood is referred to as the blood lead level, which is measured in micrograms of lead per deciliter of blood (µg/dL). CDC currently uses a blood lead reference value (BLRV) of 3.5 µg/dL) to identify children with blood lead levels that are higher than most children’s levels.

Why aren’t you going for lead levels of 0 in drinking water? The EPA says no level of lead is safe.

Historically, 15 ppb has been the EPA’s stated action level, and an enforceable standard, for lead in drinking water under the EPA’s Lead and Copper Rule regulations. It was also the stated level of action in the 2020 grant awarded to DPH and DOE. Delaware has lowered the initial action level from 15 ppb to 7.5 ppb.

The EPA also has a goal of 0, which unlike their action level of 15 ppb, is not enforceable. The State’s goal is also 0, and the State is working to get exposure levels as low as reasonably achievable. This has to be done with caution however, because sampling for lead in drinking water does have a lot of small nuances. Currently we have a limited picture of each system’s exposure, most of which was built upon sampling under a worst case scenario (in water that was stagnant and had not been used in over a year.)

As older piping and lead goosenecks are replaced over time, drinking water infrastructure/conveyance moves to less corrosive materials, and treatment techniques improve.

How do state and federal agencies determine the level of lead to test for in drinking water?

The Safe Drinking Water Act (SDWA) requires EPA to determine the level of contaminants in drinking water at which no adverse health effects are likely to occur with an adequate margin of safety. These non-enforceable health goals, based solely on possible health risks, are called maximum contaminant level goals (MCLGs). The SDWA has reduced the maximum allowable lead content in plumbing materials – content that is considered “lead free” – to be a weighted average calculated across a variety of those plumbing materials. Learn more.

Learn more about the maximum allowable content of lead in pipes, solder, fittings and fixtures

What is the timeline moving forward?

The EPA, DPH and DOE are involved in frequent conversations while the EPA reviews the history, timeline, sampling procedures and results which have occurred to date under the grant. There is no blanket resolution for all schools; some will require plumbing replacement or filter installation which are easy fixes. Others will require significant and costly repairs to water pipes leading from the drinking water mains. DPH awaits EPA guidance on next steps, and EPA has not yet determined a timeline. When the timeline is presented, resampling and follow-up actions will occur.

How are sources of water from public utility providers tested?

Public water systems are required to sample for lead and copper in accordance with EPA regulations. Any exceedances are reported on their Consumer Confidence Reports (can be obtained on Drinking Water Watch) which are distributed annually to consumers within public water systems’ jurisdictions.

Each drinking water system samples for lead and copper independently. The Division of Public Health monitors results and ensures compliance. Sampling schedules are based on a number of variables and sampling history, and can be viewed by locality on the Drinking Water Watch.

We have not found elevated levels of lead in the sources or water mains.

When DPH’s Lead Poisoning Prevention Program becomes aware that a child (or group of children) has tested with an elevated blood lead level (EBLL), what outreach measures to the family does it take in response?

Blood lead levels between 3.5 µg/dL and 6.9 µg/dL:

  • Follow up from the DPH Office of Lead Poisoning Prevention occurs:
    • Parents/guardians are mailed educational materials from the Lead Program’s Health Coordinator. The following topics are explained:
      • The meaning of an elevated blood lead level as it relates to the individual child
      • Information on common sources of lead hazards
      • Instructions to test the blood lead levels of all children aged 6 and younger living in the same house; Mothers of child-bearing age should also be tested
      • Prevention activities that can reduce lead poisoning
      • Guidance to the parent/guardian to contact the Health Coordinator to voice any concerns or questions

Blood lead levels between 7.0 µg/dL and above:

  • In addition to all the information above being mailed to the parents/guardians, the Health Coordinator will call the parent/guardian and conduct a telephone consultation with the parent/guardian. This now becomes an “Open Case” and follows CDC guidelines for Case Management Standards.
    • In addition to the telephone consultation and the home visit by a Health Coordinator, an investigation will be conducted by the Investigator.
      • If lead paint hazards in the home are the likely cause of the high lead levels in the child, then a lead risk assessment of the residence will be arranged by the Healthy Homes & Lead Poisoning Prevention Program and conducted by an environmental testing firm under contract with Office of Lead Poisoning Prevention.
      • If the investigation does not find that lead paint hazards in the home are the likely reason for the child having high lead levels, then a further investigation is conducted to try and determine the root cause of the lead exposure.
        • Examples of other sources may include:
            • Lead dust brought home from work (construction, manufacturing, steel fabricating, etc.)

           

            • Imported items like spices, ceramic pots, cosmetics, toys, home remedies

           

          • Drinking water

What is the length and duration of exposure to a single source that would be needed to return an elevated blood lead level?

According to the CDC, many sources can be involved leading to elevated blood lead levels including from paint, soil, and drinking water. If you think that you or your child have been exposed to lead, you should seek guidance from a medical provider. How long it takes to return an elevated blood lead level depends on weight of the person, amount of exposure from actually touching lead down to lead in dust, and other factors. In general, it takes repeated, ongoing exposure to create an elevated blood lead level.

Where can I find a list of public drinking water systems?

 

 

What funding is available to schools to address lead in drinking water?

School districts are eligible to apply for funding through the Division of Public Health’s Drinking Water State Revolving Fund program in accordance with EPA’s Lead Service Line Replacement requirements. Funds can be used to replace the lead service lines running from the water main to entry point (first shut off valve or 2 feet inside) of the building only. Interior plumbing and/or fixture replacement is not an eligible expense. Schools are strongly encouraged to partner with their water supply provider for the application of funding. In the event that the school is on an individual well, inquiries can be made to DPH for more information.

 

Questions about Lead?

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