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MassDEP urges water systems to meet Oct. 16 lead service‑line inventory deadline; outlines 24‑hour public‑notice and Nov. 15 consumer‑notice requirements
Summary
At a MassDEP Drinking Water Program webinar, staff told public water systems to submit initial Service Line Inventories by Oct. 16, 2024, distribute Service Line Inventory consumer notices within 30 days (practically Nov. 15) and prepare for 24‑hour Tier‑1 public notices when a system's 90th‑percentile lead result exceeds the current action level of 15 µg/L.
The Massachusetts Department of Environmental Protection (MassDEP) told public water systems Wednesday that they must submit an initial Service Line Inventory (SLI) by Oct. 16, 2024, and distribute Service Line Inventory consumer notices 30 days after submission — effectively by Nov. 15 for systems that submit on Oct. 16.
"By October 16th, you will submit the initial Service Line inventory and the required forms," said Jasmine Stranges, an environmental analyst in MassDEP’s Drinking Water Program, describing the immediate compliance steps systems must take.
Why it matters: the federal Lead and Copper Rule Improvements (LCRI) announced by EPA will introduce additional requirements for inventories and sampling; MassDEP emphasized that several LCRI elements will not change until states adopt implementing rules and that the current action level of 15 µg/L (15 parts per billion) remains in effect until the LCRI takes effect for states (MassDEP said the federal process gives states up to two years to promulgate rules).
Key requirements and timing - Service Line Inventory (SLI): initial inventories must be submitted as a CSV file to the MassDEP Drinking Water Program email by Oct. 16, 2024. Required fields include a locational identifier, service line material classification, and the verification method used. MassDEP will return inventories with missing required fields for correction; significantly incomplete inventories can be referred to EPA for enforcement.
- Consumer notices: Systems must send consumer notices to any building with a lead, galvanized‑requiring‑replacement (GRR), or unknown service line within 30 days of submitting the inventory. MassDEP staff said systems using MassDEP templates that already sent GRR notices will not have the 30‑day clock start early if the template matched the required content.
- Tier‑1 public notices: Under the current LCR, systems that exceed the 90th‑percentile lead action level (15 µg/L) must issue a Tier‑1 public notice to customers within 24 hours of calculating the exceedance, consult the state as soon as practical, and submit a copy of the Tier‑1 notice to MassDEP and EPA. "Within 24 hours after you learn about the lead action level exceedance, you have to...issue that public notice to customers," said Kathy Wanett, a presenter in the webinar.
What counts as public availability MassDEP explained options for making inventories publicly available. Large systems may post a line‑by‑line CSV or an interactive map; systems under 50,000 people may instead post a “no lead” statement or make the inventory available upon request. For multiunit buildings, MassDEP said notifying the property owner or manager with instructions to post the notice and obtaining written confirmation is sufficient evidence a system has met its obligation to notify occupants.
Format, submission, and support MassDEP requires the inventory file itself be sent as a CSV attachment (not a link to a server or URL). The agency will provide an error file for minor problems and a deadline to resubmit corrected inventories. MassDEP staff said regional offices and technical‑assistance providers (including a UMass contract) are available to help systems complete submissions.
Funding and planning requirements Systems using State Revolving Fund (SRF) money to prepare inventories must also submit a Lead Service Line Replacement Plan Summary; MassDEP said SRF‑related eligibility and finer funding details will be clarified with the SRF program and potentially by federal guidance. MassDEP staff noted EPA had announced additional federal funding opportunities the previous day and said they would follow up with details.
Enforcement MassDEP warned that failure to submit an SLI by Oct. 16, submission of a blank or substantially incomplete inventory, or failure to make an inventory publicly available on Oct. 16 may lead to enforcement referral to EPA. "Not submitting your SLI to MassDEP by October 16, 2024" can result in referral for enforcement, MassDEP said during the webinar.
Outstanding questions and DEP follow‑up Attendees asked whether proactive two‑point visual verifications performed before 2027 will count in the LCRI validation pool; MassDEP said it will review the federal document and coordinate with EPA Region 1 to clarify whether early verifications can be credited. Staff also agreed to clarify timelines for notifying new customers and whether certain SRF activities are eligible for funding.
What happens next MassDEP will post the webinar recording, slides, and a compiled Q&A on its website; staff said they will contact systems most likely to exceed the 90th percentile to pre‑approve Tier‑1 notices. MassDEP urged systems to submit what they have by Oct. 16 rather than seeking extensions — "there are no extensions," staff said, citing EPA guidance — and offered technical assistance through regional offices and contracted consultants.
The MassDEP Drinking Water Program provided the webinar slides and Q&A to be posted on its website and invited systems to use the program director email for follow‑up questions.
