ASTM E3366-23

This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: E3366 − 23
Standard Guide for
Using Publicly Available Data to Identify Schools and
Vulnerable Communities at High Risk for Elevated Lead in
1,2
Drinking Water
This standard is issued under the fixed designation E3366; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
INTRODUCTION
Sections 50105 and 50110 of the Infrastructure Investment and Jobs Act (1) direct the US EPA to
identify schools and housing in vulnerable communities at high risk to lead exposure from water
supply infrastructure. The Agency has responded with its Guidance for Developing and Maintaining
a Service Line Inventory EPA 816-B-22-001 (August 2022) and the January 2021 Lead and Copper
Rule Revision. The Lead and Copper Rule Revision establishes new limits for lead and copper in
drinking water. This guide describes a series of steps to effectively identify schools and vulnerable
communities at risk of high lead levels in drinking water using only publicly-available information and
robust geographic information systems software and is consistent with the Predictive Modeling
approach described in Section 5.5 of Guidance for Developing and Maintaining a Service Line
Inventory. This guide complements the records review activities described in EPA’s lead service line
replacement guidance. Stakeholders can use the procedures described in this guide to rapidly assess
the likelihood of lead in water exceeding the limits in federal regulations (40 CFR 141 et seq.) without
the costs associated with inspecting water service lines and water service line connections at schools
and in vulnerable communities.
According to EPA:
Service line inventories are the foundation from which water systems take action to address a
significant source of lead in drinking water - lead service lines (LSLs). Establishing an inventory of
service line materials and identifying the location of LSLs is a key step in getting them replaced and
protecting public health. Lead service line replacement (LSLR) is not dependent on knowing the
location of all LSLs; in fact, simultaneously developing an inventory while conducting LSLR can have
many benefits. For example, systems can save costs by replacing LSLs when crews find them onsite
during service line investigations. Systems can also leverage the opportunity for LSLR by seeking
customer consent and private property access during service line investigation. Replacing LSLs in a
safe and prompt manner while crews are in the field for inventory development provides an
opportunity for public health benefits for consumers by more quickly eliminating this potential source
of lead exposure from drinking water. (EPA August 2022)
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E3366 − 23
1. Scope of lead concentrations exceeding the maximum contaminant
level (MCL), using publicly available data. These steps aug-
1.1 As the General Accountability Office (GAO) reported in
ment and complement the records review activities that the US
2018 (2), the discovery of toxic levels of lead in drinking water
EPA encourages as part of the LSLR program.
in Flint, Michigan in 2015 renewed awareness about the risks
1.6 This standard does not purport to address all of the
that lead poses to public health. Exposure to lead can result in
safety concerns, if any, associated with its use. It is the
elevated blood lead levels and negative health effects. Children
responsibility of the user of this standard to establish appro-
are at particular risk, because their growing bodies absorb more
priate safety, health, and environmental practices and deter-
lead than adults, so protecting them from lead is important to
mine the applicability of regulatory limitations prior to use.
lifelong good health. According to the Centers for Disease
1.7 This international standard was developed in accor-
Control and Prevention (CDC), elevated blood lead levels have
dance with internationally recognized principles on standard-
been linked to anemia, kidney and brain damage, learning
ization established in the Decision on Principles for the
disabilities, and decreased growth. As a result of widespread
Development of International Standards, Guides and Recom-
human use, lead is prevalent in the environment; for example,
mendations issued by the World Trade Organization Technical
it can be found in paint (lead in paint was banned in the United
Barriers to Trade (TBT) Committee.
States in 1978) and soil, and can leach into drinking water
from lead-containing plumbing materials, such as faucets and
2. Referenced Documents
drinking fountains.
2.1 ASTM Standards:
1.2 Lead in school drinking water is a concern because it is
E3032 Guide for Climate Resiliency Planning and Strategy
a daily source of water for over 50 million children enrolled in
public schools. The pattern of school schedules—including
2.2 EPA References:
time off over weekends, holidays, and extended breaks—can
EPA 810-R-19-003 EPA. Strategies to Achieve Full Lead
contribute to standing water in the school’s plumbing system.
Service Line Replacement. October 2019
If there is lead in the plumbing system, the potential for it to
EPA 816-B-22-001 EPA Guidance for Developing and
leach into water can increase the longer the water remains in
Maintaining a Service Line Inventory. August 2022
contact with the plumbing. Estimating the risk of lead con-
tamination of schools’ drinking water at the State level is a
3. Terminology
complex and important challenge. Variable water quality
3.1 Definitions of Terms Specific to This Standard:
among water systems and changes in water chemistry during
3.1.1 community water system, CWS, n—as defined in the
distribution affect lead dissolution rates from pipes and fittings.
Safe Drinking Water Act, a water system that supplies water to
In addition, the locations of lead-bearing plumbing materials
the same population year-round.
are uncertain. EPA, 2002 (3), Triantafyllidou and Edwards,
3.1.1.1 Discussion—A community water system serves at
2012 (4).
least 25 people at their primary residences or at least 15
1.3 The US EPA is responsible for enforcement of the Safe
residences that are primary residences (for example,
Drinking Water Act (SDWA) on Tribal land; there is no
municipalities, mobile home park, subdivisions).
delegation of this authority to the States.
3.1.2 maximum contaminant level (MCL), n—The highest
1.4 Sections 50105 and 50110 of the Infrastructure Invest- level of a contaminant that is allowed in drinking water.
ment and Jobs Act (Public Law 117–58) (1) provides funding
3.1.2.1 Discussion—MCLs are set as close to MCLGs as
and directs the US EPA and the Department of Interior to feasible using the best available treatment technology and
address lead in drinking water systems that provide potable
taking cost into consideration. MCLs are enforceable stan-
water to schools and on Tribal land. EPA has announced that in dards.
accordance with this statute, the Agency discourages partial
3.1.3 maximum contaminant level goal (MCLG), n—The
lead service line replacements and encourages full replacement
level of a contaminant in drinking water below which there is
of deficient service lines. The legislation provided the US EPA
no known or expected risk to health.
with approximately $15 billion over a 5-year period to achieve
3.1.3.1 Discussion—MCLGs allow for a margin of safety
this goal.
and are non-enforceable public health goals.
1.5 This guide describes steps to rapidly identify commu-
3.1.4 national primary drinking water regulations
nity and public water systems, as defined in the SDWA, at risk
(NPDWRs), n—the National Primary Drinking Water Regula-
tions (NPDWR) are legally enforceable primary standards and
This guide is under the jurisdiction of ASTM Committee E50 on Environmental treatment techniques that apply to public water systems.
Assessment, Risk Management and Corrective Action and is the direct responsibil-
ity of Subcommittee E50.05 on Environmental Risk Management.
Current edition approved May 1, 2023. Published July 2023. DOI: 10.1520/
E3366–23 For referenced ASTM standards, visit the ASTM website, www.astm.org, or
Adapted from “Identifying Schools at High Risk for Elevated Lead in Drinking contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM
Water Using Only Publicly Available Data. Science of the Total Environment Standards volume information, refer to the standard’s Document Summary page on
The boldface numbers in parentheses refer to a list of references at the end of the ASTM website.
this standard. Available from United States Environmental Protection Agency (EPA), William
Lead in Paint. Centers for Disease Control and Prevention. https:// Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
www.cdc.gov/nceh/lead/prevention/sources/paint.htm http://www.epa.gov.
E3366 − 23
3.1.4.1 Discussion—Primary standards and treatment tech- 4.3 California’s State Water Resources Control Board’s
niques protect public health by limiting the levels of contami- Division of Drinking Water initiated an aggressive program of
nants in drinking water. sampling and public water systems supplying water to schools
in 2018. California Assembly Bill 746 published on October
3.1.5 public water system, n—As defined in the Safe Drink-
12, 2017, effective January 1, 2018, requires community water
ing Water Act, a public water system provides water for human
systems to test lead levels, by July 1, 2019, in drinking water
consumption through pipes or other constructed conveyances
at all California public, K-12 school sites that were constructed
to at least 15 service connections or serves an average of at
before January 1, 2010.
least 25 people for at least 60 days a year.
4.4 Lobo (2021) (6) reports that two factors predominantly
3.1.5.1 Discussion—A public water system may be publicly
or privately owned. control lead leaching into the drinking water: (1) the presence
or absence of lead-bearing plumbing materials, and (2) water
3.1.6 vulnerable communities, n—are groups and commu-
quality that promotes the formation of soluble or insoluble lead
nities at a higher risk for poor health as a result of the barriers
corrosion products. This guide provides a method of using
they experience to social, economic, political and environmen-
publicly-available information to determine if the water sup-
tal resources, as well as limitations due to illness or disability.
plied to schools presents an unacceptable lead exposure hazard.
3.2 Abbreviations and Acronyms:
4.5 The procedures described in the guide are consistent
3.2.1 CCR—Consumer Confidence Report
with Sections 4, 5, and 6 of Guide E3032.
3.2.2 CWS—Community Water System
5. Procedure
3.2.3 EPA—U.S. Environmental Protection Agency
5.1 Data Collection:
3.2.4 GAO—General Accountability Office
5.1.1 The data requirements for this guide include
3.2.5 GIS—Geographic Information System
demographics, water quality, age of the water supply pipes and
associated infrastructure, and school capture area (boundar-
3.2.6 LSL—Lead Service Line
ies) . The data requirements are based upon the research
3.2.7 LSLR—Lead Service Line Replacement
conducted at the University of California, Berkeley (Lobo,
3.2.8 MCL—Maximum Contaminant Level
2021 (7).
3.2.9 MCLG—Maximum Contaminant Level Goal
5.2 Demographic Data:
5.2.1 Use the US Census Bureau’s data portal ()to obtain the
3.2.10 NPDWR—National Primary Drinking Water Regula-
socioeconomic information for the students attending each
tions
school by assigning data from individual census tracts to
3.2.11 SDWA—Safe Drinking Water Act (42 USC 300f et
schools drawing students from those census tracts. Social data
seq. 1974; §612 as implemented by Public Law No: 114-322.
from American Community Survey (8) should be used to
2016)
estimate social conditions within census tracts. Select socio-
3.2.12 SDWIS —Safe Drinking Water Information System economic features that correspond to race, poverty levels and
unemployment. State annual school census reports, that include
4. Significance and Use information on race/ethnicity, by grade level, are another
source of demographic data that is publicly available.
4.1 Lead can enter drinking water when service lines or
5.2.1.1 Low-income minority groups have been reported to
plumbing fixtures that contain lead corrode, especially where
be at a disproportionately larger risk of lead exposure from old
the water has high acidity or low mineral content. According to
and poorly maintained water infrastructure in Flint, MI and the
the EPA, lead typically enters school d
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