Last Updated: March 13th, 2025
Welcome to the Drinking and Groundwater Protection Division’s website for the Lead and Copper Rule Improvements sampling requirements. If you’re looking for help understanding the new sampling requirements, you’ve found the right place. This page is broken down into several sections. If you’re just starting out, you’ll want to start at the beginning.
*DISCLAIMER: THE LCRI IS CURRENTLY UNDER A LEGAL HOLD ON IMPLEMENTATION. THIS WEBSITE WILL BE UPDATED PERIODICALLY AS INFORMATION BECOMES AVAILABLE.*
Who does this apply to?
The requirements in the Lead and Copper Rule Improvements apply to community water systems and non-transient non-community (NTNC) water systems.
What is happening and when?
RECOMMENDED: Submit an LCRI compliant Lead and Copper Sampling Plan – July 1, 2027.
With the Lead and Copper Rule Improvements, all water systems must develop a Baseline Lead Service Line Inventory (Baseline Inventory). Water systems must submit this Baseline Inventory no later than November 1, 2027. The inventory identifies leaded or potentially leaded service lines as well as lead connectors. This inventory and other local records must be used to develop a new LCRI compliant Lead and Copper Sampling Plan.
Water systems that have not completed their Baseline Inventory should develop their sample plan but understand that it may need to be re-developed. If the baseline inventory provides new information that would change the sample plan, a water system must update their sample plan accordingly.
As part of the new Lead and Copper Sampling Plan, all water systems will identify distribution system locations for water quality parameter sampling.
Water systems must provide one or more locations within the distribution system where water quality parameters will be sampled. The number of locations will be determined based on population served.
The Drinking Water and Groundwater Protection Division (Division) recommends submitting an LCRI compliant Lead and Copper Sampling Plan to your Lead and Copper Rule Manager no later than July 1, 2027. This will allow the Division to review your plan properly. Please keep in mind that the Division will be doing the same for hundreds of other water systems.
MANDATORY: Final Submittal Date for your LCRI Compliant Lead and Copper Sampling Plan – December 31, 2027.
The compliance deadline for submitting an LCRI compliant Lead and Copper Sampling Plan is December 31, 2027. Water systems that delay turning in their Lead and Copper Sampling Plan must delay sample collection until the sample plan has been approved. Don’t wait until the last minute! Acting quickly will give your water system the most flexibility when picking a date/time to sample.
MANDATORY: Many Systems reset to Standard Monitoring (every six months) – January 1, 2028.
The following systems will be reset to Standard Monitoring with the implementation of the LCRI, effective January 1, 2028:
If your water system will be reset to six-month sampling, it is even more important to get your LCRI compliant Lead and Copper Sampling Plan submitted by the July 1, 2027 recommended submittal date. This will give your water system ample time to correct any issues with the sampling plan, give the Division ample time to review it and the hundreds of other plans that will be submitted at the same time.
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Systems with Lead or Galvanized Requiring Replacement (GRR) service lines
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Any water system whose most recent 90th percentile calculation exceeds the Action Level of 10ppb as of November 1st, 2027
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Any water system that deviated from its designated optimized water quality parameters for more than 9 days during the July 1 through December 31, 2027, sample period.
How are sampling requirements changing?
Complete overhaul of sampling plan requirements.
With the implementation of the LCRI comes significant changes to sampling requirements. These changes are a dramatic departure from the past.
- Tiering for sample locations has expanded considerably. This is explained in detail within the LCRI Lead and Copper Sampling Plan Guidance.
- Distribution system sampling locations must be identified and collected throughout the tap sampling period when applicable.
- All water systems must submit a sample plan that includes locations where distribution system water quality parameters will be collected.
Systems must sample at the standard number of sites during annual monitoring
In previous years, water systems that had moved from six-month monitoring, also known as standard monitoring, to annual monitoring, saw the number of locations that needed to be collected, cut in half. This will no longer be true under the LCRI. Water systems will collect from the same number of locations when on annual monitoring, as they do on six-month monitoring.
Distribution water quality parameter sampling for all systems applying corrosion control treatment (CCT) or systems with a recent Lead or Copper action level exceedance (ALE)
To improve monitoring of CCT, all water systems with CCT will be required to collect water quality parameter samples at one or more locations throughout the distribution system. Field samples will be allowed, like the entry point sampling conducted and submitted with the Monthly Operating Reports. The required water quality parameters will depend on the corrosion control treatment used and may include:
- pH
- Alkalinity
- Orthophosphate
Water Systems will be required to begin sampling for distribution water quality parameters after a Lead or Copper Action Level Exceedance, even if the water system does not use corrosion control. The Division will alert the water system when this requirement has been activated and the water system must begin collecting and reporting water quality parameter data in the Monthly Operating Reports.
For each of the scenarios below, we have an example system with an identified population and monitoring type; standard or reduced. An example of a distribution system sampling schedule is presented for each system. These schedules are meant to highlight a sampling regime that captures the intent of the written rule by spreading sampling throughout each monitoring period.
1st and 5th Liter Lead Sampling
Water systems must collect 1st and 5th liter samples from all sample locations with Lead service lines or Lead premise plumbing. 1st and 5th liter sampling is when the first five(5) liters of water are collected from a faucet and the first and fifth liters are both analyzed. The highest result of the two is used when calculating the 90th percentile. For more information about 1st and 5th liter sampling, please read the instructions your lab will provide you with when you order these sample kits; instructions may vary from lab to lab.
Distribution System and Site Assessment for all locations that exceed the Lead Action Level of 10ppb
The water system must perform the distribution system and site assessment when a lead result from an individual tap sample site exceeds 0.010 mg/L (10ppb). The assessment consists of 9 steps that include corrosion control treatment assessment, follow-up lead sampling, and system modifications. Visit the Distribution System and Site Assessment website to learn more.
A Distribution System and Site Assessment flow chart is available in the resources section.
Resources
- New LCRI Sample Plan Form (PDF- coming soon!)
- New LCRI Sample Plan Form (ANRonline- coming soon!)
- New LCRI Sample Plan Guidance (PDF- coming soon!)
- Distribution System and Site Assessment Flow Chart
- Public Records Archive
- Lead and Copper Rule Improvements (eCFR link)
