Correspondence between

Hi Ail, There’s a furry of new articles: brew mive. com/news/! http / Awww waet.corn/ rn sure there will be more. Thanks, Andrea Porter Environmental Engineer Ground Water & Drinking Water Branch ULS. EPA, Region 5 (WG-155} 77 .W. Jackson Blvd, Chicaga, (L 60604 Phone: 312-886-4427 Fax: 312-697-2656

Hi All, Looks like the Flint Pb water story is getting even more press: nite / noc? Snews.com/news/local /new-report-mistions quality-o Thanks, xxxEND_PAGE:deq21_b095_0285_0286_1 Andrea Porter Environmental Engineer Ground Water & Drinking Water Branch U.S. EPA, Region 5 (WG-15J) 77 W. Jackson Blvd. Chicago, IL 60604 Phone: 312-886-4427 Fax: 312-697-2656 xxxEND_PAGE:deq21_b095_0285_0286_2

I haven't spoken to her so I don't know, but information on the Flint Water Update website, which is recent, says that the Walters are still using bottled water for drinking/cooking. Miguel A. Del Toral Regulations Manager U.S. EPA RS GWDWB 77 West Jackson Blvd, (WG-15J) Chicago, IL 60604 Phone: (312) 886-5253 Sent: Tuesday, September 1, 2015 02:09 PM

Hi, Miguel. We had a call yesterday with MDEQ and were discussing Marc Edwards’ website. MDEQ thought that Ms Walters’ home has a whole house filter that would remove chlorine in addition to lead and other contaminants, such as a GAC filter. | said that when you and | were out there in late April/May, that there was no whole house GAC filter or other tap or under-sink filter; she had an iron filter at the entry point to her home—but an iron filter wouldn’t remove chlorine, though chlorine could oxidize the iron. Do you know if Ms Walters’ has installed a whole house GAC filter, or tap GAC filter or under-sink GAC filter since May? Jennifer xxxEND_PAGE:deq04_b578_6377_6764_175 Rennaker, Joanne (DEQ)

Here's Darren's Bio for MDEQ. Miguel A. Del Toral Regulations Manager U.S. EPA RS GWOWB | 77 West Jackson Blvd, (WG-155) Chicago, IL 60604 Phone: (312} 886-5253 xxxEND_PAGE:deq04_b577_6019_6376_239 DARREN A. LYTLE U.S. Environmental Protection Agency Cincinnati, OH 45268 (513) 569-7432 Phone (513) 487-2543 FAX [email protected] Education Ph.D., Environmental Engineering University of Illinois at Champaign-Urbana, Champaign, Illinois, December 19, 2005 Advisor: Prof. Vernon Snoeyink Dissertation: “The Effect of Water Chemistry on Iron Particles and Suspensions” Master of Science, MS, Environmental Engineering University of Cincinnati, Cincinnati, Ohio, 1991 Advisor: Prof. R. Scott Summers Thesis: “Removal of Beryllium from Drinking Water by Chemical Coagulation and Lime Softening” B.S., Civil Engineering University of Akron, Akron, Ohio, 1990 Registration Professional Engineer, Ohio, No. E-61725 Experience U.S. Environmental Protection Agency (EPA) Office of Research and Development (WSWRD) Treatment Technology Evaluation Branch (TTEB) Water Supply and Water Resources Division 26 W. Martin Luther King Dr. Cincinnati, Ohio 45268 Supervisory Environmental Engineer (Branch Chief, Acting) (May 2012 to present). See below for duties. Environmental Engineer (GS-14 National Expert) (March 2012 to May 2012). See below for duties. xxxEND_PAGE:deq04_b577_6019_6376_240 Supervisory Environmental Engineer (Branch Chief, Acting) (March 2010 to March 2012). Oversees and manages Branch within WSWRD’s Treatment, Technology and Evaluation Branch (TTEB). Branch consists as many as twenty- four federally-employed engineers, chemists, and technicians. The Branch conducts drinking research in support of the development of new and previously promulgated Federal drinking water standards. Serves as first line supervisor for a staff of engineers, scientist and technicians. Provides direction, guidance, advice and assistance to Branch staffing all administrative matters and in technical matters, as appropriate; sets priorities for Branch products within research plans; assigns staff, evaluated performance; resolves complaints and disputes within the Branch; handles appropriate personnel actions and issues, including recommending promotions, approving leave and interviewing and recommending candidates for positions within the Branch. Environmental Engineer (GS-14 National Expert) (June 2009 to March 2010). See below for duties. Supervisory Environmental Engineer (Branch Chief, Detail) (February 2009 to June 2009). Oversees and manages Branch within WSWRD’s Treatment, Technology and Evaluation Branch (TTEB). Branch consists of twenty-four federally-employed engineers, chemists, and technicians, and a number of contractors. The Branch conducts drinking research in support of the development of new and previously promulgated Federal drinking water standards. Environmental Engineer, National Expert (GS-14) (January 2005 to February 2009), Serves as a nationally and Agency recognized researcher on water treatment and distribution system issues including corrosion control, inorganic contaminant and pathogen control, and biological water treatment. Provides extensive research and technical assistance to EPA for the development and implementation of drinking water rules and regulations. Activities include addressing scientific peer panels like the Science Advisory Board with the results of my research, and participating on EPA workgroups and committees that develop guidelines and policies that the Agency issues to the water treatment utilities for achieving safe drinking water. Plans, directs, and participates in an in-house and extramural (grants/contracts) research program focused on corrosion control, inorganic contaminant and pathogen control, and biological water treatment. Research efforts are integrated into WSWRD, Regional and Program goals and needs. As the nationally recognized researcher, author authoritative scientific papers on research results in peer reviewed professional journals and writes chapters in technical manuals and books. Presents results of research at National Conferences, workshops, symposia and meetings. Organizes and moderates sessions at national B-2 xxxEND_PAGE:deq04_b577_6019_6376_241 conferences, etc., sponsored by various groups on topics of his special expertise. Called upon by other EPA programs, and organizations such as the Office of Water, various Regional Offices to participate in seminars and workshops. Environmental Engineer (1990 to November 7, 2008). Plan, design, and conduct in-house and field research on the removal and control of inorganic contaminants such as turbidity, metals and radionuclides, and microorganisms

Sorry, forgot the file... Miguel A. Del Toral Regulations Manager U.S. EPA RS GWDWB 77 West Jackson Blvd, (WG-15J) Chicago, IL 60604 Phone: (312) 886-5253

Morning Jen, Here's Mike's bio as requested by Flint. I haven't received anything from Darren yet. Miguel A. Del Toral Regulations Manager U.S. EPA RS GWDWB 77 West Jackson Blvd, (WG-15J) Chicago, IL 60604 Phone: (312) 886-5253 xxxEND_PAGE:deq04_b218_3468_3468_1

Slight correction...most old pipe from the home to the shut-off is galvanized, and the majority of lead they have seen is from the shut-off to the main. Apologies for not getting this report written up, but I keep getting sidetracked with NDWAC LCR and RTCR primacy packages. I will try to get that written up and out to you in the next week. If I get copies of the latest results 1 will forward them, but my understanding is that the DEQ lab runs the samples, so they should be available within DEQ as well. Miguel A. Del Toral xxxEND_PAGE:deq16_b5_0892_4900_0976 Regulations Manager U.S. EPA RS GWDWB 77 West Jackson Blvd, (WG-15J) Chicago, IL 60604 Phone: (312) 886-5253

Hi, Steve. | found that interesting that the Walters’ interior piping is all PVC, and they have an iron pre-filter at the service connection. | remember in a discussion with Miguel, and maybe he can explain further, that systems with iron removal treatment had higher levels of lead at the tap, especially if the bacteria had been allowed to overgrow the filter. Seems there was a higher amount of lead particulate in the system. Miguel said in his email to us on 2/27 at 4:58am, that: “Fe/Mn can transport lead from the lead service lines into the home. The lead sorbs onto the Fe/Mn particles. In SW systems, the Fe typically is released from the water mains.” Perhaps the iron pre-filter is contributing to the high lead levels? Jennifer

Miguel and Jennifer, Thank you for this information, we will take it under consideration. The City of Flint: - Has a90™ percentile lead level of 6.0 ppb based on 100 samples collected in its most recent monitoring period of 7/1/2014 ~ 12/31/2014, with 2 samples (23 & 37 ppb) over the Al, - Hasago™ percentile copper level of(110 ppb based an 100 samples collectegin its most recent monitoring period of 7/1/2014 — 12/31/2014, with no Samples over the Cu AL - Has an Optimized Corrosion Control Program ~ Conducts quarterly Water Quality Parameter monitoring at 25 sites and has not had any unusual results. - Has never had a 90" percentile lead AL exceedance ~ Continues to meet all applicable plant tap standards and treatment technique requirements at its WTP Has developed and implemented an Operational Evaluation of its treatment and distribution systems, and continues to adjust and update this OE based on updated quarterly resuits My understanding from Ben Grumbles and the LCR Short Term Revisions is that “EPA regulations require water systems to develop a targeted sampling pool, focused on those sites with the greatest risk of lead leaching. All compliance samples used to determine the 90" percentile must come from that sampling pool.” [40 CFR 141.80(c)(1}], 56 Fed Reg. 26518 (June, 7, 1991}, [AOCFR 141.90(a} iv}, and 40 CFR 141.90(h}(2)). Our office continues to wark with our cammunity water systems to follow these and ail other requirements of the current lead and copper regulations. 212 Browning, the site in question, is not part of the City’s established sample site pool. The residence consists of PVC plumbing materials, and has an iron pre-filter at the service connection. Regarding TTHM, the most recent quarter monitoring from February 2015 was issued today by the jab. While 2 of the 8 DBP compliance sites continue to have an LRAA that exceeds the standard, quarterly results at all 8 DBP compliance sites were below less than half the standard level of 80 ppb, the highest being 28.5 ppb. Only one site now has an QEL over 80 ppb, at 85 ppb. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

Date: Friday, February 27, 2015 1:48:06 PM Miguel and Jennifer, Thank you for this information, we will take it under consideration. The City of Flint: - Has agoth percentile lead level of 6.0 ppb based on 100 samples collected in its most recent monitoring period of 7/1/2014 — 12/31/2014, with 2 samples (23 & 37 ppb) over the AL. - Hasagoth percentile copper level of 110 ppb based on 100 samples collected in its most recent monitoring period of 7/1/2014 — 12/31/2014, with no samples over the Cu AL. - Has an Optimized Corrosion Control Program - Conducts quarterly Water Quality Parameter monitoring at 25 sites and has not had any unusual results. - Has never hada 90" percentile lead AL exceedance - Continues to meet all applicable plant tap standards and treatment technique requirements at its WTP - Has developed and implemented an Operational Evaluation of its treatment and distribution systems, and continues to adjust and update this OE based on updated quarterly results My understanding from Ben Grumbles and the LCR Short Term Revisions is that “EPA regulations require water systems to develop a targeted sampling pool, focused on those sites with the greatest risk of lead leaching. All compliance samples used to determine the got percentile must come from that sampling pool.” [40 CFR 141.80(c)(1)], 56 Fed Reg. 26518 (June, 7, 1991), [40CFR 141.90(a)(1) (v), and 40 CFR 141.90(h)(2)]. Our office continues to work with our community water systems to follow these and all other requirements of the current lead and copper regulations. 212 Browning, the site in question, is not part of the City’s established sample site pool. The residence consists of PVC plumbing materials, and has an iron pre-filter at the service connection. Regarding TTHM, the most recent quarter monitoring from February 2015 was issued today by the lab. While 2 of the 8 DBP compliance sites continue to have an LRAA that exceeds the standard, quarterly results at all 8 DBP compliance sites were below less than half the standard level of 80 ppb, the highest being 28.5 ppb. Only one site now has an OEL over 80 ppb, at 85 ppb. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314 xxxEND_PAGE:deq03_b475_2112_2118_1

Date: Friday, February 27, 2015 1:48:06 PM Miguel and Jennifer, Thank you for this information, we will take it under consideration. The City of Flint: - Has agoth percentile lead level of 6.0 ppb based on 100 samples collected in its most recent monitoring period of 7/1/2014 — 12/31/2014, with 2 samples (23 & 37 ppb) over the AL. - Hasagoth percentile copper level of 110 ppb based on 100 samples collected in its most recent monitoring period of 7/1/2014 — 12/31/2014, with no samples over the Cu AL. - Has an Optimized Corrosion Control Program - Conducts quarterly Water Quality Parameter monitoring at 25 sites and has not had any unusual results. - Has never hada 90" percentile lead AL exceedance - Continues to meet all applicable plant tap standards and treatment technique requirements at its WTP - Has developed and implemented an Operational Evaluation of its treatment and distribution systems, and continues to adjust and update this OE based on updated quarterly results My understanding from Ben Grumbles and the LCR Short Term Revisions is that “EPA regulations require water systems to develop a targeted sampling pool, focused on those sites with the greatest risk of lead leaching. All compliance samples used to determine the got percentile must come from that sampling pool.” [40 CFR 141.80(c)(1)], 56 Fed Reg. 26518 (June, 7, 1991), [40CFR 141.90(a)(1) (v), and 40 CFR 141.90(h)(2)]. Our office continues to work with our community water systems to follow these and all other requirements of the current lead and copper regulations. 212 Browning, the site in question, is not part of the City’s established sample site pool. The residence consists of PVC plumbing materials, and has an iron pre-filter at the service connection. Regarding TTHM, the most recent quarter monitoring from February 2015 was issued today by the lab. While 2 of the 8 DBP compliance sites continue to have an LRAA that exceeds the standard, quarterly results at all 8 DBP compliance sites were below less than half the standard level of 80 ppb, the highest being 28.5 ppb. Only one site now has an OEL over 80 ppb, at 85 ppb. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314 xxxEND_PAGE:deq01_b343_4124_4130_1 004125

Miguel and Jennifer, Thank you for this inforraation, we will take it under consideration. The City of Flint: - Has a 90" percentile lead fevel of 6.0 ppb based on 100 samples collected in its most recent monitoring period of 7/1/2014 ~ 12/31/2044, with 2 samples (23 & 37 pnb} over the AL. - Has a 90" percentile comper level of 110 ppb based an 100 samples collected in its mast recent monitoring period of 7/1/2014 - 12/31/2014, with no samples over the Cu AL. - Has an Cptimized Corrosion Control Program - Conducts quarterly Water Quality Pararneter manttoring at 25 sites and has not had any unusual results. - as never had a 90" percentile lead AL exceedance - Continues to meet all applicable plant tap standards and treatment technique requirements at its WTP - Has developed and implemented an Operational Evaluation of its treatrnent and distributian systems, and continues to aciiust and update this OF based on updated quarterly results My understanding fram Ben Grurnbles and the LCR Short Terra Revisions is that "EPA regulations require water systerns to develop a targeted sarnnling pool, focused on thase sites with the greatest risk of lead leaching. All compliance samples used ta determina the go” percentile must come fram that sarnpling pool.” [40 CFR 144. 80(cH4}] 56 Fed Reg. 26518 (June, 7, 1999), I40CFR 141. 90fa ivi, and 40 CFR 147. 90(hH2}) Gur office continues to work with our coramunity water systems to follow these and all other requirements of the current lead and conper regulations. xxxEND_PAGE:deq18_b054_0982_0987_1 212 Browning, the site in question, is not part of the City’s established sarnple site pool, The residence consists of PVC nlurnbing materials, and has an fron pre-filter at the service commection. Regarding TTHM, the most recent quarter monitoring fram February 2015 was issued today by the lab. While 2 of the & DBP compliance sites continue to have an LRAA that exceeds the standard, quarterly results at all 8 DAP corpliance sites were below less than half the standard level of 80 poh, the highest being 28.5 ppb. Only one site now has an OEL over 80 ppb, at 85 ppb. Stephen Busch, PE. Lansing and Jackson District Supervisor Office of Drinking Water and Municinal Assistance MDEQ SLY-643-2314

Jen/all - I think things got garbled in translation... What I was saying is that where you find Pb values that high, it is usually due to particulate lead. Not always, but generally. Particulate lead is released sporadically from lead service lines, leaded solder and leaded brass in a number of ways and folks tend to discount these values as anomalies, but particulate lead release is a normal part of the corrosion process and it is universal (common) in all systems. It’s just that it is not captured as often by the infrequent LCR sampling. If systems are pre-flushing the tap the night before collecting LCR compliance samples (MDEQ still provides these instructions to public water systems) this clears particulate lead out of the plumbing and biases the results low by eliminating the highest lead values. If systems are pre-flushing and still finding particulate lead, the amount of particulate lead in the system can be higher than what is being detected using these ‘pre-flushed’ first-draw samples. My point on that was that people are exposed to the particulate lead on a daily basis, but the particulate lead is being flushed away before collecting compliance samples which provides false assurance to residents about the true lead levels in the water. Some quick notes on particulate lead release: e Fe/Mn can transport lead from the lead service lines into the home. The lead sorbs onto the Fe/Mn particles. In GW systems, Fe/Mn can come from the source water and more Fe from the water mains. In SW systems, the Fe typically is released from the water mains. e Lead released from lead service lines can also 'seed' galvanized iron pipes inside the homes. Again, the lead sorbs onto the iron on the pipes and be released sporadically. Generally, the higher the flow, the more Fe and Fe+Pb particulate you will likely get. e Ifthere is a partial lead service line (lead connected to copper) you can get additional lead release due to galvanic corrosion. e Leaded brasses and solder can also release particulate lead under certain circumstances. e The particulate can contain very high concentrations of lead (hundreds to thousands of ppb Pb) which is a much higher concentration than lead paint, so even small particles can result in high lead values. e Ifthe lead service line was disturbed (water main repair/replacement, meter installation repair/replacement, service line leak repairs, etc.) you can have VERY high lead levels in the scale and sediment that is dislodged from the inside of lead service lines. Here in Chicago, during a partial lead service line replacement, we collected the scale and sediment that came into the home and we found 300,000+ ug/L lead in the scale; 125,000 ug/L Pb in the sediment. Very dangerous. e Higher levels of PO4 (3-4 mg/L Ortho) seem to reduce the amount of particulate Pb that is released in the absence of physical disturbances to the lead lines. Doesn’t stop it entirely, but should generally reduce the occurrence. Caveat — Other water quality issues can change the chemical complexes that form on the pipe, so cleaner sources with more consistent WQ form more predictable scale complexes. xxxEND_PAGE:deq18_b130_1247_1251_1 If remember correctly, Detroit is feeding PO4 for the LCR, but since Flint is no longer part of that interconnection, I was wondering what their OCCT was. They are required to have OCCT in place which is why I was asking what they were using. Mike Schock is our resident expert and may be able to help out with the simultaneous compliance (Pb & DBPs) so I would suggest that folks give him a call. Miguel A. Del Toral Regulations Manager U.S. EPA RS GWDWB 77 West Jackson Blvd, (WG-15J) Chicago, IL 60604 Phone: (312) 886-5253

Jen/all - I think things got garbled in translation... What I was saying is that where you find Pb values that high, it is usually due to particulate lead. Not always, but generally. Particulate lead is released sporadically from lead service lines, leaded solder and leaded brass in a number of ways and folks tend to discount these values as anomalies, but particulate lead release is a normal part of the corrosion process and it is universal (common) in all systems. It’s just that it is not captured as often by the infrequent LCR sampling. If systems are pre-flushing the tap the night before collec on thisting LCR compliance samples (MDEQ still provides these instructions to public water systems) this clears particulate lead out of the plumbing and biases the results low by eliminating the highest lead values. If systems are pre-flushing and still finding particulate lead, the amount of particulate lead in the system can be higher than what is being detected using these ‘pre-flushed’ first-draw samples. My point on that was that people are exposed to the particulate lead on a daily basis, but the particulate lead is being flushed away before collecting compliance samples which provides false assurance to residents about the true lead levels in the water. Some quick notes on particulate lead release: - Fe/Mn can transport lead from the lead service lines into the home. The lead sorbs onto the Fe/Mn particles. In GW systems, Fe/Mn can come from the source water and more Fe from the water mains. In SW systems, the Fe typically is released from the water mains. - Lead released from lead service lines can also 'seed' galvanized iron pipes inside the homes. Again, the lead sorbs onto the iron on the pipes and be released sporadically. Generally, the higher the flow, the more Fe and Fe+Pb particulate you will likely get. - If there is a partial lead service line (lead connected to copper) you can get additional lead release due to galvanic corrosion. - Leaded brasses and solder can also release particulate lead under certain circumstances. - The particulate can contain very high concentrations of lead (hundreds to thousands of ppb Pb) which is a much higher concentration than lead paint, so even small particles can result in high lead values. - If the lead service line was disturbed (water main repair/replacement, meter installation repair/replacement, service line leak repairs, etc.) you can have VERY high lead levels in the scale and sediment that is dislodged from the inside of lead service lines. Here in Chicago, during a partial lead service line replacement, we collected the scale and sediment that came into the home and we found 300,000+ ug/L lead in the scale; 125,000 ug/L Pb in the sediment. Very dangerous. e Higher levels of PO4 (3-4 mg/L Ortho) seem to reduce the amount of particulate Pb that is released in the absence of physical disturbances to the lead lines. Doesn’t stop it entirely, but should generally 2 xxxEND_PAGE:deq27_b157_0706_0711_2 reduce the occurrence. Caveat — Other water quality issues can change the chemical complexes that form on the pipe, so cleaner sources with more consistent WQ form more predictable scale complexes. If 1 remember correctly, Detroit is feeding PO4 for the LCR, but since Flint is no longer part of that interconnection, I was wondering what their OCCT was. They are required to have OCCT in place which is why I was asking what they were using. Mike Schock is our resident expert and may be able to help out with the simultaneous compliance (Pb & DBPs) so I would suggest that folks give him a call. Miguel A. Del Toral Regulations Manager U.S. EPA RS GWDWB 77 West Jackson Blvd, (WG-15J) Chicago, IL 60604 Phone: (312) 886-5253

Service Lines: A Field Study Good morning. Some of you mentioned that the State folks were interested in a presentation on the Chicago sampling study, so please forward the registration information to your States. Don't forget the LCR folks. I already sent this to IEPA (D. McMillan, R. Cobb, M. Crumly, J. Long), so no need to re-send. Registration is now open for the webinar on the EPA R5 sampling study conducted in Chicago (free to PWSs and general public) Detection and Evaluation of Elevated Lead Release from Service Lines: A Field Study February 3, 2014 12:00pm to 1:00pm Central Time Registration Link: _ 1 5# CEU TYPE: Technical WEBINAR TYPE: Technical IEPA#: 7932 Summary : Comparative stagnation sampling conducted in 32 homes in Chicago, Illinois with lead service lines demonstrated that the existing regulatory sampling protocol under the U.S. Lead and Copper Rule systematically misses the high lead levels and potential human exposure. Lead levels measured with sequential sampling were highest within the lead service lines, with maximum values more than four times higher than Chicago's regulatory compliance results using a first-draw sampling protocol. There was significant variability in lead values from different points within individual lead service lines and among different lead service line sites across the city. Although other factors could also influence lead levels, the highest lead results most often were associated with sites having known disturbances to the lead service lines. This study underscores the importance and interdependence of sample site selection, sampling protocol, and other factors in assessing lead levels in a public water system. INSTRUCTOR: Miguel A. Del Toral, Regulations Manager U.S. EPA Miguel A. Del Toral Regulations Manager U.S. EPA RS GWDWB 77 West Jackson Blvd, (WG-15J) Chicago, IL 60604 Phone: (312) 886-5253 xxxEND_PAGE:deq04_b319_4495_4495_1