MassDEP aide outlines LCRI deadlines: baseline inventory due Nov. 1, 2027; schools, replacement timelines explained

Hannah Parson, an assistance provider with UMass Amherst working with the Massachusetts Department of Environmental Protection27s (MassDEP) drinking water program, said the federal Lead and Copper Rule Improvements (LCRI) were finalized on Oct. 30, 2024 and become the compliant rule on Nov. 1, 2027. She told webinar participants that by that date most public water systems (PWS) must submit a baseline service line inventory and a lead service line replacement plan if they have lead service lines, galvanized requiring-replacement (GRR) lines, or unknowns.

The baseline inventory must go beyond the initial 2024 submissions, Parson said: it must include connector information (lead, non-lead, unknown, or "no connector") and street addresses where available, and it must be treated as a living document that is updated annually after the 2027 implementation date. She said MassDEP has published LCRI templates and an LCRI web page with forms and templates PWS can use to prepare their submissions.

Parson described the replacement timeline and related obligations. For most PWS the LCRI establishes a 10-year target (counting from the Nov. 1, 2027 compliance date) to identify unknowns and replace all lead and applicable GRR service lines, though systems may qualify for expedited, deferred, or alternative schedules under specified criteria. She emphasized that partial replacements are generally prohibited except for emergencies or unrelated major infrastructure work, and that systems must offer post-replacement water testing to customers and make a "reasonable effort" to obtain owner consent for private-side replacements (defined in the webinar as four outreach attempts using two different outreach methods).

On monitoring changes, Parson said the LCRI lowers the lead action level from 15 parts per billion to 10 parts per billion and adds school-and-child-care sampling obligations: PWS must offer sampling to 20% of the elementary schools and child-care facilities they serve each year for five years after the 2027 deadline until 100% of those sites have been sampled, declined sampling, or been nonresponsive. Secondary schools must be tested on request.

Parson also described required non-lead validations: systems must physically inspect a random subset of non-lead service lines at two points and submit those validations (the webinar included a stated validation due date for many systems; see Q&A and MassDEP guidance for precise schedules). She urged systems to begin resolving unknowns and preparing replacement plans now and to consider the MassDEP Water Smart pilot program to facilitate school sampling while public funding is being pursued.

The webinar host and presenters indicated MassDEP will post guidance and templates on its website and that unanswered questions from the session will be collected and published. Parson encouraged systems to use MassDEP27s templates for the baseline submission and to contact the drinking water program with case-by-case questions.