Lead Service Line Inventory Progress and other Lead and Copper Rule News

June 14, 2024

The federal Lead and Copper Rule Revisions (LCRR) and proposed Lead and Copper Rule Improvements (LCRI) require public water systems (PWS) to inventory all lead service lines (LSL) and galvanized requiring replacement (GRR) downstream of lead by October 16, 2024. NHDES has hired four consultants and issued 30 grants to assist our 1,200 non-transient PWS to complete their inventories.

The proposed LCRI is currently being finalized but the expected requirements for PWS include:

By October 16, 2024:

Complete and upload service line materials inventories using the NHDES Inventory Template including identification of all lead, galvanized, copper, brass, high-density polyethylene (HDPE) and any other non-lead or unknown materials.
Begin Public Notices to all LSL, GRR and unknown services.
Perform Acute Public Notice within 24 hours for Lead Action Level Exceedances of 15 parts per billion (ppb) at the 90th percentile.

By 2027 (three years of final rule promulgation):

Develop a Replacement Plan for all lead and GRR services, and a plan for identifying all unknown service line materials.
New Lead Action Level of 10 ppb requiring 24-hour Acute Public Notice at the 90th percentile and new Distribution System Site Assessment (DSSA) for all individual samples above 10 ppb.
Submit new sampling plans and reset to semi-annual LCR sampling in accordance with new Sampling Tiers starting January 2028.
Start first- and fifth-liter stagnant LCR samples.
Provide Consumer Notice letter within three days of receipt from the certified laboratory for every LCR sample collected, even if non-detect.
Start replacement of all LSL and GRR services to achieve 100% replacement in 10 years (2037).

Current Status of New Hampshire’s Lead Service Line Inventories

NHDES is making great progress with assisting PWS on their service line inventories. Of the 1,200 systems assigned to a consultant, all systems have been contacted and are working on submitting information to their assigned consultant. Please be reminded that inventory information must be submitted using the NHDES Lead Service Line Inventory Template. If a PWS is working with a consultant, the consultant will submit the inventory information on the PWS’ behalf. Please visit the NHDES LCRR webpage to look up whether a consultant is assisting your water system.

To assist with completing service line inventories, NHDES has developed guidance to provide clarification on acceptable methods of service line identification. Visit the NHDES LCRR webpage for more information.

The proposed LCRI requirements also include sampling of schools and child care centers which New Hampshire is completing through our Get the Lead Out of New Hampshire Drinking Water program. NHDES anticipates completing the three rounds of lead testing at all fixtures where children can drink the water at all schools and licensed child care facilities by 2025. This program will provide assistance with laboratory costs, database management and outreach and will be funded by the federal Water Infrastructure Improvements for the Nation (WIIN) Lead grants. Information about this program, including how to enroll for the free sample testing, all sample results to date, and an interactive dashboard map are available at www.gettheleadoutnh.org.

Following the classification of service line materials in the required inventory, eligible water systems can apply for funding for full lead service line replacements through the Drinking Water State Revolving Fund (DWSRF) Lead Service Line Replacement (LSLR) program. Examples of eligible projects include the complete removal of lead and GRR service lines, removal and replacement of lead goosenecks, pigtails and connectors, and site restoration (landscaping, sidewalks, driveways, etc.) and more. Principal forgiveness ranges from 50 to 100% depending on the PWS affordability index. Submit a final application any time.

NHDES is determining the next steps to continue providing assistance to PWS in completing service line inventories. NHDES will distribute more information and guidance as it becomes available. If you have any questions, please visit the NHDES Lead and Copper webpage or contact Heather Baron at heather.l.baron@des.nh.gov or (603) 271-5927.