Lead and Copper

Helping public water systems to comply with the EPA Lead and Copper Rule and its 2024 revisions.

The Environmental Protection Agency (EPA) established the Lead and Copper Rule (LCR) in 1991 to protect public health and reduce exposure to lead in drinking water. That rule has been revised in 2021 and again in 2024 to include several new actions to better protect the public against the harmful effects of lead.

EPA’s 2021 Lead and Copper Rule Revisions (LCRR) introduced many new components (inventory, replacement plan, notification, corrosion control etc.) but the most pressing requirement was the development of a service line inventory. By October 16, 2024, all community (CWS) and non-transient, non-community (NTNC) water systems were required to create an inventory of their service lines throughout their distribution systems, paying special attention to any lead service lines that will need to be replaced, and submit an initial service line inventory to NHDES. 

In October 2024, EPA released the Lead and Copper Rule Improvements (LCRI) which improved upon the LCRR’s requirements to better protect the public. LCRI requires all lead/GRR service lines to be located and replaced, improve tap sampling, lower the lead action level, and strengthen public health protection through filter requirements and improved communication between the public water system and the water customer.

Funding is available for lead service line identification and replacement of lead/GRR service lines. For more information, please review the DWSRF LSLR Funding Flyer.

For more information on EPA's Lead and Copper Rule Revision visit the EPA Revised Lead and Copper Rule webpage.

Important Updates

Important updates related to LCRR/LCRI requirements will be posted here. Please check back periodically for new information.

  • LCRI changes the service line inventory validation requirements. NHDES will be updating our water systems with next steps in the coming months.
  • EPA is requiring a new version of the service line inventory, which will be called the baseline inventory. This version requires more information be added regarding lead connectors as well as a few other updates. NHDES will be releasing a new template in early 2025 that will be the required format for annual service line inventory updates moving forward. All water systems, regardless of service line material classification are required to submit a baseline inventory to NHDES.
  • Non-compliance sampling assistance is available through NHDES, please see the non-compliance sampling section of this webpage for additional details.

Lead Service Line Inventory

Water systems that have service lines comprised of lead, galvanized requiring replacement (GRR) or an unknown material are required to submit annual service line inventory updates to NHDES. The original NHDES assigned consultant (Arcadis, Hazen and Sawyer, Northeast GIS and Underwood) will be assisting their water systems in updating their inventory into NHDES’ newest template, reviewing additional records and creating a plan to help the systems identify unknowns in 2025. NHDES will be releasing an UPDATED INVENTORY template in February 2025, that will meet the requirements for the baseline Inventory and be the required form of submittal moving forward. Note that all service lines need to be included in the inventory. This includes fire lines, irrigation lines and all service lines after a master meter such as mobile home parks or private condos associations. Privately-owned redistribution systems (PORS) will be required to submit a service line inventory by the November 1, 2027, deadline for baseline inventories. Service line inventories are accessible to the public at any time. To get information on a service line material, please go to OneStop and search by the 7-digit PWS ID number or water system name to find the primary contact for that water system.

Replacement Plan and Replacement Rate

All water systems with a service line inventory that has lead, GRR or unknown service lines are required to submit a replacement plan using the NHDES template in 2027.

Water systems must replace service lines at a cumulative average annual rate of 10 percent, unless that system has a shortened or deferred deadline approved by NHDES. The cumulative average replacement rate includes the total number of lead, GRR and unknown service lines represented in the baseline inventory. The replacement rate is effective after the compliance date in 2027.

Customer Notification of Service Line Material

All systems with unknown, lead or GRR service lines must issue customer notices within 30 days of the service line inventory compliance date, and again annually thereafter. The following customer notification templates for lead, GRR and unknown service lines must be used:

You may use this suggested cover letter template in addition to the customer notification templates and edit it for your water system's use.

Non-Compliance Sampling Requirements

As required per EPA and as stated in the customer notification letter templates above, all systems are required to facilitate non-compliance sampling upon request to their water customers who received letters. NHDES is able to provide funding assistance to cover the non-compliance sampling and it is available using the guidance documents below.

Latest News

More Information

Lead Service Line Inventory Resources

illustration that includes multiple company logosSmall and Medium Systems

New Hampshire small and medium community (CWS) and non-transient non-community (NTNC) water systems with less than 1,700 service connections were paired with one of four consulting firms to assist them in complying with EPA’s LCRR by the federal deadline of October 16, 2024. There was no cost to the water systems for this assistance. Check your water system's assigned consultant. Please note newly activated or reclassified systems that are not included in the assigned consultants list are responsible for complying with LCRR/I as part of the design review process and will not be assigned a NHDES-hired consultant. Arcadis, Hazen and Sawyer, Northeast GIS and Underwood Engineers worked directly with each water system to create and submit their service line inventory by the federal deadline.

Consulting assistance for water systems will continue throughout 2025. The consultants will be assisting their assigned water systems in reviewing records and data, updating the service line inventory, assisting in creating a plan to identify unknown service lines and submitting the updated inventory to NHDES by the compliance date. 

Please be reminded that complying with LCRR is ultimately the responsibility of the CWS and NTNC water system owner. Water system staff should be communicating to determine which individual is tasked with submitting data to your assigned consultant (or NHDES if you are not assigned a consultant).

If you have any questions or need more information, please contact DWLead@des.nh.gov or call (603) 271-5927.

To assist public water systems to comply with the LSLI requirements, NHDES is providing financial assistance through 100% federal, no-match grants to large systems, as well as free consulting services for small and medium systems. In addition, work related to LSL investigation and service line replacements may be financed through the LEAD Drinking Water State Revolving Fund (DWSRF) with rolling, year-round applications and principal forgiveness. For more questions regarding lead in drinking water project funding, please review the DWSRF Lead Service Line Replacement (LSLR) Program Flyer or contact DWLead@des.nh.gov.

Learn More About Lead Funding

  • Large Public Water System Lead Service Line Inventory Grant – Large community public water systems serving ≥1700 service connections were eligible for this grant program in 2024. The 2024 grant application period has ended. NHDES will be posting more information about grant applications in 2025. 
  • Lead Drinking Water State Revolving Fund (DWSRF) Loan Application – Eligible expenses include work related to LSL investigations and full-service line replacements. Authority to borrow is required. Applications are open year-round and provide loan forgiveness for eligible applicants.
  • Small System Lead Service Line Inventory Consultants – New Hampshire small and medium water systems serving <1700 service connections have been paired with one of four consulting firms to develop and submit their service line inventories by the compliance date. Consulting services will continue throughout 2025. See the "Consulting Services - Small and Medium Systems" tab for more information.

a cut lead pipe rests on the groundNHDES may require that a water system undertake corrosion control activities if lead and/or copper are found at specific levels. The Lead and Copper Rule requires community and non-transient, non-community water systems to conduct tests to determine if lead and copper are present in high levels at the consumer's tap. The action levels are 0.015 milligrams per liter (mg/L) for lead and 1.3 mg/L for copper. Water systems are required to share the results of the lead samples with their consumers at the location where they were collected (known as Consumer Notification). The consumers need to be given information about the results, health effects, exposure routes and contact information. Water systems must also send a copy of the letter to NHDES and certify to this office that it was distributed in accordance with the rules. NHDES provides the following resources for public water systems:

Contact:
Bess Morrison
bess.a.morrison@des.nh.gov
(603) 271-0655

gooseneck pipe with corrosionSome water supplies require the use of corrosion control (CC) treatment to reduce water corrosivity to water mains and customer’s premise plumbing. Low pH or alkalinity and/or high chloride or conductivity are some of the characteristics of corrosive waters. Systems with CC treatment must monitor routine water quality (RWQ) parameters at least every two weeks at the distribution entry point and once per quarter at representative distribution sites. RWQ monitoring log sheets must be kept by the system and reported quarterly to NHDES upon trigger of either the lead (15 ppb) or copper (1.3 ppm) Action Level at the 90th percentile. Systems exceeding the Action Level must submit an Optimum Corrosion Control Treatment Report (OCCTR) within 6 months, implement the approved OCCTR within 1 year, and achieve two new compliant semi-annual LCR rounds within two years (system optimization) of the initial exceedance.

Corrosion Control Resources

Contact:
Doug Sayer
Small Systems Design Review
douglas.j.sayer@des.nh.gov
(603) 271-0893