March 29, 2018

VIA ELECTRONIC MAIL, theodorams@aol.com

Ms. Theodora Scarato

Re: Responses to Maryland Public Information Act Request regarding lead in PGCPS
water
Our File No.: 18-99-0037

Dear Ms. Scarato:

This letter is written in response to your Maryland Public Information Act request;
specifically requesting:

1. Where are the Fairmont Heights , the Ardmore, the Henry Wise,
the Bowie High Annex- lead in water 2018 PGCPS tests?

The document PGCPS placed online states that lead tests on these
schools and others were done in 2018 but I cannot find any
levels documented. The fields are blank. Can you update
that spreadsheet found on this page to include the lead
test numbers please http://www.pgcps.org/water-
quality-program/
Response: The results for Fairmont Heights, Ardmore, Henry
Wise and Bowie High Annex will be posted March 28, 2018.

2. Who made the decision for 10 ppb to be the PGCPS lead in water
threshold? What staff? What is their expertise in the issue of
children's health please? PGCPS is currently allowing 10ppb in the
water and I and others would like documentation of how you came
up with this number. What scientific documentation was used to
recommend 10 ppb as the lead in water threshold for the school?
Please share the medical documentation that supports the use of
this threshold as well so the community can understand why the
county is allowing this level of lead in the water.
Response: The Director of Building Services and the
Environmental Specialist made a recommendation to the Chief
Operating Officer. The decision to use 10ppb was based on EPA
recommendations for household action levels at 10ppb.

Prince George's County Public Schools | Office of General Counsel | Shauna Garlington Battle, Esquire | Direct: 301-952-6242
14201 SCHOOL LANE, UPPER MARLBORO, MD 20772 Website: www.PGCPS.org Follow Us: @PGCPS, Facebook, YouTube
Ms. Theodora Scarato
March 29, 2018
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3. There are many times where a water tap showed high levels and
then retests were done. Which test are you using for a cut off? Are
you using the first or second draw test? it is unclear from the
spreadsheets that you posted.
Response: If a first or second draw is higher than 10ppb, the
fixture is valved off and we schedule for mitigation. The steps we
follow are:

If a drinking source is above 10ppb, the source is valved off

The fixture is replaced
The water source is retested
If the second test is above 10ppb, the fixture is capped off

4. If a test shows a number over 10 ppb and then retests to a number

under the PGCPS threshold, what is your course of action? For
example if a tap reads at 12ppb at first draw and then retests at 20
ppb. what does pgcps do? Is the water turned off?
Response: See response detailed in question 3.

5. Are parents being informed of the lead tests in these schools? I

would like to share with you that in other states, parents are sent a
paper that looks like this-Barryingtom Elementary School lead
letter for parents
http://www.chsd.us/admin/reports/water_reports/Barryton%2
0Lead%20Copper%20Notification.pdf and they are told the exact
numbers of the exact taps. Why are PGCPS parents not
receiving such letters in their school? Please explain why PGCPS is
not informing parents of the same information as given to parents
in other school districts?
Response: Principals are notified by the Department of Building
Services and provided the results of the testing.

6. Send me the current list of ALL the schools with water shut offs
and specifically which fountains are being shut off in each school
AND the date of shut off. I think the best way to do this is to
integrate this information into the spreadsheet PDF of lead tests
you have online on your water quality page. Please add date of
water shut off or if the water source is left on please state "Water
left on"and have the date for each action right there next to the
lead level numbers. .
Response: The information requested is informally maintained in
Building Services as an internal reference document only.
Ms. Theodora Scarato
March 29, 2018
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7. Are bathroom and kitchen taps being tested? Please confirm this
because children often cup hands and drink from the sink. Some
school lead tests are only like 7 taps so Im sure there are more
water sources in the school. Where are these numbers?
Response: Water sources in kitchens are being tested. Water
sources in bathrooms are not being tested. Signs have been posted
above these water sources indicating non potable water.

8. Some taps are testing at very high levels on the first draw but then
going down on the second draw.

For example a tap at Fort Washington Elementary tested at 1390

ppb in 008A on the first draw in and then on the second draw it
tested at 20.8. So the lead number had an over 1000 times
variation just by virtue of timing.
For example at tap at Rose Valley Elementary tested at 2830
ppb on the first draw in and then on the second draw it tested at
32.7
For example a tap at Allen Wood Elementary tested at 60 ppb on
the first draw in and then on the second draw it tested at 10.9.
Forest Heights Elem had a tap that read at 9480 and then on the
second draw was 3260. These numbers are quite astounding.
Forest Heights Elem also had a tap that read at 11 800 and then
on the second draw was 20.2 These numbers are quite
astounding.
Indian Queen Elem had a tap that read at 192, 000 (yes, this is not
a typo) and then on the second draw was 615. That is a 312 times
decrease in lead in the water with the second draw. These numbers
are quite astounding.

The above information shows the variations in lead levels

depending on the time of the test. These variations are large.

Some taps are testing at lower levels on the first draw but then the
numbers went up the second draw.
For example Doswell E Brooks room 023A had a first reading of
25.1 ppb and t went up to 226 ppb on the second draw.
For example Kettering Middle room 134A had a first reading
of 44.5 and it went up to 309 on the second draw.
For example a tap at University Park Elementary had a first
reading of 94.5 and it went up to 159 on the second draw.
For example a tap at Pointer Ridge Elementary had a first reading
of 16.3 and it went up to 31.7 on the second draw.
Ms. Theodora Scarato
March 29, 2018
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Thus, it seems safe to say that if lead is found, the number can
vary widely depending on when the sample is taken. The
number can be double, triple or even almost ten times more on the
second draw- or less. 10 ppb as a threshold is not protective- even
for that limit- as the tap could read higher or lower at any time.
We do not know when a child or pregnant woman could drink it.

Can you respond this concern please.

Response: If a first or second draw is higher than 10ppb, the
fixture is valved off and we schedule for mitigation. The steps we
follow are:

If a drinking source is above 10ppb, the source is valved off

The fixture is replaced
The water source is retested
If the second test is above 10ppb, the fixture is capped off

9. I am asking PGCPS to immediately update their threshold to 0ppb

as the allowable amount of lead in the water. If a tap tests higher
and has lead- then the water should be not used for drinking, signs
should be placed at the source to inform children and staff. Taps
should be tested at least two times. Fresh lead free water should be
provided to the children and staff. Below is the documentation that
supports this. Please respond as to why you have not taken these
steps. We have been asking for over a year now. Thank you for
your immediate consideration of this issue.

The EPA, the American Academy of Pediatrics and the

CDC state there is no safe level and 0 ppb is the health
standard. This means only 0 ppt is safe. However current
regulations do not enforce this health based standard. Instead the
only law we have states that schools need to be under 20 ppt and
water to homes needs to be 15ppb and under . These 25 year old
regulations do not ensure safety for our school children.

0 ppb: EPA Health Limit- Maximum Contaminant Level

Goal- A Health Standard- for Lead in Water Limit
Read it here EPA DRINKING WATER STANDARDS AND
HEALTH ADVISORIES TABLE
https://www.epa.gov/sites/production/files/2015-
09/documents/dwstandards2012.pdf

below 1 ppb: American Academy of Pediatrics

Recommends below 1 ppb for Schools.
Ms. Theodora Scarato
March 29, 2018
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The American Academy of Pediatrics (AAP) Report on prevention
of Lead Toxicity states "state and local governments should take
steps to ensure water fountains in schools do not exceed water lead
concentrations of 1ppb." Please download the AAP report by
clicking here

0.2 ppt California's Office of Environmental Health

Hazard Assessment (COEHHA)
The COEHHA revised the state's public health goal for drinking
water to 0.2 parts per billion, a fraction of the threshold
established by the EPA.
“A revised Public Health Goal (PHG) of 0.2 ppb (or 0.2 µg/L) for
lead in drinking water is established, on the basis of new studies
relating neurobehavioral deficits to lower lead concentrations in
the blood than previously reported."
Read it
here https://oehha.ca.gov/media/downloads/water/chemicals/p
hg/leadfinalphg042409_0.pdf
Response: Prince George’s County Public Schools will continue
with the action level of 10 ppb.

10. The EPA states that 3Ts of adressing lead in schools are:

f Training school officials to raise awareness of the potential

occurrences, causes, and health effects of lead in drinking water;
assist school officials in identifying potential areas where elevated
lead may occur; and establishing a testing plan to identify and
prioritize testing sites.
f Testing drinking water in schools to identify potential problems
and take corrective actions as necessary.
f Telling students, parents, staff, and the larger community about
monitoring programs, potential risks, the results of testing, and
remediation actions.
"There is no safe level of lead exposure for children. Researchers
have found that children can have health effects when exposed to
even the lowest levels of lead, so it is critical to prevent exposure.
Infants, young children and pregnant women are at greatest risk.
Health effects can include damage to the brain and kidneys,
reduced IQ and other behavioral and neurological impairments.
The effects of lead have been linked to reduced performance in
schools which compounds the disadvantages for children.
Ensuring lead-free drinking water in schools helps not only the at-
risk child but the entire school community. "
Ms. Theodora Scarato
March 29, 2018
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Read the EPA letter to the State of New York here that
this quote is from
http://www.p12.nysed.gov/facplan/documents/Lead-
DrinkingWater-EPAlettertoNYSSuperintendentswAtt_05-26-
16.pdf

The letter states that the EPA has a voluntary program that guides
schools and districts through the process of sampling, and
communicating the results and remediating" Is PGCPS taking
advantage of this program?
Response: Prince George’s County Public Schools provides
extensive and ongoing training to our employees. Our testing
schedule is comprehensive and thorough. We meet with concerned
PTA groups as requested and principals are provided information to
guide conversations at the school house level.

11. Scientific research shows that lead in combination with

wireless radiation can exacerbate the effects of lead.

For example, Research investigating cell phone radiation in

combination with the lead- which is a known neurotoxin- has
found that children with blood lead levels had higher ADHD like
symptoms if they also had higher cell phone use. This finding has
lead the researchers to consider a potential synergetic effect
between lead and radio frequency (RF) fields, meaning the RF
exposure increased the effects from the lead exposure. In fact,
multiple research studies have found that electromagnetic fields
such as Wi-Fi and cell phone radiation can increase the effects of a
known toxic exposure. Researchers have repeatedly found a
tumor promotion effect from this type of radiation.

Radiofrequency wireless and cell phone radiation exposure has

also been shown to affect the permeability of the blood-brain
barrier (BBB), as well as altering the expression of microRNA
within the brain, which researchers state could lead to adverse
effects such as neurodegenerative disease. When the BBB is more
permeable, more toxins circulating in the blood can reach the
brain- this applies to lead of course.

In 2009, Dr. Leif Salford a neurosurgeon at Lund University

Hospital and Chairman of the Department of Neurosurgery
presented his published research studies that found blood-brain
barrier (BBB) leakage after very very low levels of exposure to
Ms. Theodora Scarato
March 29, 2018
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radiofrequency radiation. These studies have been confirmed and
expanded on by researchers from China who concluded, “these
results demonstrated that exposure to 900 MHz EMF radiation for
28 days can significantly impair spatial memory and damage
BBB permeability in rat by activating the mkp-1/ERK pathway.”

Therefore the combination of lead plus wireless could exacerbate

the effects of lead in children, even at low levels and cause more
damage to the brain. I have shared with you and the school board
that over 150 doctors recommend that wireless exposure be
reduced to pregnant women. Read more here
https://ehtrust.org/science/pregnancy-wireless-and-
electromagnetic-fields/
Currently many schools in internationally are removing the
wireless from schools and governments are issuing new directives
to remove wireless radio frequency from schools. For example
Cyprus has removed wireless from elementary schools. France has
turned the Wi-Fi off as well so that OFF is the default setting.
Many countries have banned Wi-Fi from kindergarten such as
France, Israel, Ghent Belgium etc. Read about that
here https://ehtrust.org/policy/international-policy-actions-on-
wireless/

12. I understand that some schools have ALL water off in an

abundance of caution even those taps that are lower than 10ppb.
Yet in other schools these taps are left on under 10 ppb. I think this
is not fair. All schools should be afforded this protection.

For example, Glenridge Elementary had all the water turned

off- even before they had the water tested! (And when it was
finally tested --many many faucets were found to be too high by
the way. As I understand it, the decision to turn the water off was
because a PG parks childcare was on site. There was concern that
any lead could be unsafe so they took action proactively. The fact
that ANY lead was found- be it at 7 or 8 was a potential problem
for staff and it made sense to turn it all off. I did a public
information request and found this out, as well as talk to staff. Is
this still the case? Why are Glenridge children treated differently
than other children in the PGCPS community? So please clarify
why some schoolchildren are being afforded this protection of a 0
ppb lead threshold and other school children have the 10 ppb
threshold for PGCPS action. Please also send me the list of schools
that are using the 0ppb as a threshold.
Ms. Theodora Scarato
March 29, 2018
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cc: Kevin M. Maxwell, Ph.D.
W. Wesley Watts, Jr., Ed.D.
Mr. Mark Fossett
Mr. Sam Stefanelli
Ms. Elizabeth Davis
Ms. Karen Bowlding
Mr. Alex Baylor
Demetria T. Tobias, Esquire