Water Management
What’s Next After the Lead and Copper Rule Revisions? Meet LCRI
Water systems must comply with the LCRI starting in November 2027
With the initial inventory of the Lead and Copper Rule Revisions (LCRR) completed and customers notified, what’s next? The short answer is that water systems must now comply with the Lead and Copper Rule Improvements (LCRI) starting November 1, 2027.
As you may recall, the LCRR mandated that all water systems complete an initial inventory of their service lines and submit it by October 16, 2024. In addition to this requirement, the LCRR also mandated that all water systems with lead service lines (LSL), galvanized requiring replacement lines (GRR), or lines made of unknown materials (Unknowns) notify affected customers about the health risks associated with lead by November 15, 2024.
Any water system in Montana could receive free technical assistance for completing the inventory, and Morrison-Maierle assisted 12 of them.
What You Need to Know About LCRI
The LCRI requires water systems to update their inventories by adding connectors or goosenecks and submitting their baseline inventory by November 1, 2027. Many states included a column for lead connectors in their inventory templates, so most water systems will have this completed unless it was left blank. Water systems must submit the baseline inventory by the required date or provide a document stating that connectors were included in the initial inventory and no changes have been made since then.
Those systems with LSL, GRR, or Unknowns listed in the baseline inventory must submit a plan to replace the LSL and GRR and identify any Unknowns by November 1, 2027. This plan requires systems to lay out their 10-year process to ensure all LSL and GRR are replaced and Unknowns identified and replaced (if applicable) by December 2037. Identifying Unknowns earlier rather than later can streamline the replacement process and potentially eliminate the need for a plan if all materials are non-lead. Water systems must also submit an updated annual inventory throughout this 10-year period.
This snapshot is an example of the inventory from a small community in Montana. The LCRR mandated that all water systems complete an initial inventory of their service lines and submit it by October 16, 2024. In addition to this requirement, the LCRR also mandated that all water systems with lead service lines (LSL), galvanized requiring replacement lines (GRR), or lines made of unknown materials (Unknowns) notify affected customers about the health risks associated with lead by November 15, 2024.
What Kinds of Funding is Available?
Montana has funding to help water systems identify Unknowns and prepare replacement plans. Additional funding for service line replacements will also be made available in the future. Other states may offer similar assistance, so it’s advisable to contact your regulatory authority for further details.
What if My Inventory Shows No Signs of Lead?
The goal is to have an inventory comprised entirely of non-lead services. However, even if all lines are non-lead, some verification work remains. A percentage of non-lead services must be validated when specific criteria are met. The number of services requiring validation is based on the number within the validation pool, not the total number of services. For example, the validation pool does NOT include:
- Service lines installed after 1988.
- Service lines that underwent a two-point visual inspection (both street and building side) during installation or field inspection.
- Previously replaced LSL and GRR.
All remaining non-lead services will be included in the validation pool, and a randomized selection of 20% of this pool must undergo validation through a two-point visual inspection, which needs to be completed by December 31, 2034.
Starting November 2027, water systems must collect samples from 20% of elementary schools and 20% of childcare facilities each year, completing the first round of sampling within five years.
School and Daycare Requirements
The LCRI remains unchanged in its requirements for sampling in schools and daycare facilities. Starting November 2027, water systems must collect samples from 20% of elementary schools and 20% of childcare facilities each year, completing the first round of sampling within five years. Sampling in secondary schools is optional, although water systems must offer schools the opportunity to participate.
Five samples will be collected per school and two samples per childcare facility. After the initial round of sampling, further sampling will only be necessary if requested by the school or childcare facility. Annual public education about the health risks of lead in drinking water is required, regardless of whether the school is sampled.
Several states have school sampling programs. In Montana, water systems are only required to sample non-accredited (private) schools and all childcare facilities, while the Montana Department of Environmental Quality’s (DEQ) program samples accredited schools. Check with your regulatory authority to see if your state has a similar program.
What's Due in November 2027?
Site Plan Development
New sampling site plans must be developed by November 1, 2027. The new site plans must classify properties as one of the five Tiers listed on the right. Click through the list to learn more.
Tier 1
Single-family homes with lead service lines or lead plumbing.
Tier 2
Any building with a lead service line or lead plumbing.
Tier 3
Single-family homes with lead connectors or galvanized service lines.
Tier 4
Single-family homes with copper plumbing installed before 1988 that contains lead solder.
Tier 5
Any building that represents sites throughout the distribution system.
Sampling plans must include all Tier 1, 2, and 3 sites if applicable. Tier 4 and 5 sites can be used if no sites have lead service lines or plumbing.
Many water systems have been on a reduced monitoring schedule. This may change in January 2028 when sampling begins at the new locations. Water systems that show LSL or GRR on their November 1, 2027, inventory must resume the standard six-month monitoring schedule. This may be reduced after they show two consecutive six-month periods where they fall in the ninetieth percentile below for lead and copper action levels.
For systems with no LSL or GRR on their November 1, 2027, inventory, they can remain on a reduced monitoring schedule.
We’re Ready to Help
The inventory process can be difficult and time-consuming. Our team has significant experience as water system staff, administrators, and consultants who understand the LCRR and LCRI requirements.
Inventories can be complicated processes. Reach out so we can help!About The Author
Susan Fenhaus has centered her more than 30-year career on finding solutions that build better communities.
Learn more about SusanOffice Location: Helena
