DATA REPORT: SUMMARY OF LEAD WATER RESULTS IN FILTER AND SEQUENTIAL STUDIES
EXECUTIVE SUMMARY

The EPA Office of Water (OW) requested the EPA Office of Research and Development (ORD) conduct a
filter effectiveness study in Benton Harbor, Michigan in response to a Safe Drinking Water Act petition
filed on behalf of the residents of Benton Harbor. ORD designed a study to evaluate filter effectiveness,
identify lead (Pb) sources, and characterize particles within residences in Benton Harbor. This study was
carried out in collaboration between EPA Region 5 and ORD from November 9 - December 17, 2021.
Approximately 2,000 field samples were collected and analyzed, sampling 215 homes for the filter
effectiveness study (resulting in 199 properly installed and operated filter study homes) and 26 homes for
the sequential sampling study to evaluate premise plumbing and service line lead release. This data report
provides an initial overview of the findings from the studies; a comprehensive final report will be provided
in summer 2022. The results here show that all properly operating filter water samples were found to be
below the NSF/ANSI 53 and bottled water certification (21 C.F.R. § 165.110) requirements of 5 ppb lead
(FDA).

BACKGROUND

The City of Benton Harbor, Ml, initially exceeded EPA's Lead and Copper Rule (LCR) lead action
level (AL) in 2018, after which the State required the City to conduct monitoring every 6 months according
to Michigan's new Lead and Copper Provisions of the Michigan Safe Drinking Water Act (1976 PA 399).
The system continued to exceed the lead AL during five additional monitoring periods from January 2019
to June 2021; in the most recent monitoring round ending in December 2021 (EGLE, 2019, 2021a), the
90th percentile was equal to the lead AL. In response to the AL exceedances, the Michigan Department of
Health and Human Services (MDHHS) through the Berrien County Health Department (BCHD) began
providing the community with faucet-mounted point-of-use (POU) and pitcher filters certified by
NSF/ANSI 53 for lead reduction to reduce the level of lead in tap water (News, 2019). In March 2019, the
City began adding an 70% orthophosphate and 30% polyphosphate blended corrosion-control inhibitor at
a target dose of 1.5 mg P04/L (EGLE, 2019, 2020). Based on the State of Michigan Department of
Environment, Great Lakes and Energy (EGLE) evaluation of subsequent monitoring results, in its February
2020 designation of optimal corrosion control treatment (OCCT) (EGLE, 2020), EGLE directed the City to
change to a minimum of 90% orthophosphate and 10% polyphosphate blend to achieve a 3 mg P04/L
orthophosphate residual in the distribution system, with the system making the switch in March 2020
(EGLE, 2021c).

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Concerns were raised over filter effectiveness as well as public education on proper filter use
(uncertainty on how to properly install and maintain the filters) (Petitioners, 2021). A petition outlining
the history of Benton Harbor's lead contamination issues and proposed actions was submitted to the EPA
on September 9, 2021, and included a specific request that a filter lead removal study be conducted in
Benton Harbor by EPA's Office of Research and Development (ORD). On September 30, 2021, a joint press
release was issued by BCHD, MDHHS, and EGLE stating that bottled water would be made available to the
residents of Benton Harbor (EGLE, 2021b).

At OW's request, ORD designed, and with the assistance of R5 and MDHHS, implemented a
statistically sound filter effectiveness study. Sampling began on November 9, 2021, and concluded on
December 17, 2021, after water from properly installed and operated filters had been collected in 199
Benton Harbor homes. In addition to the filter effectiveness study, ORD designed two additional studies:
(1) to assess lead source contributions in premise plumbing, and (2) to characterize lead particles. A
sequential profile sampling study was designed and performed that included 26 Benton Harbor homes to
understand drinking water lead sources. A complementary lead particle and characterization study was
performed that consisted of particle size fractionation and particle composition characterization. These
studies are important considerations for corrosion control effectiveness and for characteristics of lead-
containing particles that could jeopardize filter effectiveness.

The objective of this data report is to provide an initial overview of the findings from the (1) filter
effectiveness, (2) sequential profile, and (3) particle size fractionation studies. This initial report is focused
on the lead in water results given the prioritization of lead analyses, completeness of the lead dataset,
and importance of the results. Chlorine data is also included here. Other water quality data, field
observations, and additional study findings are still under analysis and review and will be reported in a
follow-on report in summer 2022.

METHODS IN BRIEF

Table 1: Study team and roles

Responsibility	Personnel

Project Lead	Darren Lytle

Study Design	Darren Lytle, Mike Schock, JenniferTully, Val Bosscher

Field Sampling Team	EPA: Peg Donnelly, Jonathan Burian, Joan Rogers, Mari Nord,

Daniel Williams, Christy Muhlen, Steve Harmon, Andrew
Maguire, Claire Scheib-Feeley, Michelle Kerr, Cheryl Burdett,
Mostafa Noureldin, Kevin Gaughan, Jodie Opie, Alexandria
Flevarakis, Rob Thompson, Colin Geisenhoffer, Casey Formal
(EPA contractor)

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Quality Assurance Review
Report Preparation

Data Team

Water Analysis Team

MDHHS support to EPA sampling teams: Kevin Kasischke, Frank
Schenkhuizen; Mannik Smith Group (MDHHS contractor) Mike
DeLong, Jessica Bankey, Kevin Larr, Rabia Azam
HeatherShoven, Amanda Wroble, Rob Snyder, Colin Breslin,
Christina Rice, Colin Kramer, Ellie Hagen, Luis Antonio Flores,
Kathleen Swan, Francis Awanya, and Edgar Santiago
EPA: Val Bosscher, Jennifer Tully, Janice Huang, Jonathan
Burian, Matthew Blaser, Lucy Stanfield, Eric Holbus, Jason
Sewell, Samuel Blazey; EPA contractors: Scott Shilling, Matthew
Pinelli, Megan Urbanic, Adam Peterca, Randy Dorian
Maily Pham, Jackie Adams

Darren Lytle, JenniferTully, Mike Schock, Val Bosscher

Sampling site selection. Single-family residences served by the Benton Harbor Water Plant that
were provided with PUR or Brita POU faucet filters or ZeroWater™ pitcher filters from BCHD were targeted
for this sampling effort. The distribution of filter types sampled in homes (Figure 1) reflected the
distribution of filter types provided to residents by the BCHD (89% faucet filters, 11% pitcher filters).
Residences sampled for the filter effectiveness study were confirmed to not have whole-house filters,
water softeners, or reverse osmosis units under the kitchen sink. Furthermore, schedulers targeted single-
family residences with known lead service lines (LSLs), or with Benton Harbor documentation of being
likely (assumed) to have an LSL. EPA completed best efforts to schedule sampling at the approximately
200 homes identified by Benton Harbor as known LSLs as of early December, including homes on Smith
Court; and, as of documentation available in mid-January 2022, at least 55 of the 215 filter effectiveness
sample sites had known LSLs at the time of sampling. Based on a preliminary statistical assessment
performed by an EPA contracted statistician, 200 homes were targeted in the sampling pool to answer
the question of whether properly certified POU faucet filters and pitcher filters reduce lead to 5 ng/L (5
ppb) (the NSF/ANSI 53 certification standard) or less (estimated number of samples needed to reach a
95% lower confidence bound at 95% confidence).

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¦ Faucet Filter Samples ¦ Pitcher Filter Samples
Figure 1. Distribution of faucet POU and pitcher filters sampled in filter effectiveness study.

The filter effectiveness study sampling in Benton Harbor began on November 9, 2021. Seasonality
often impacts lead release, and colder temperatures can reduce the amount and rate of lead release, so
the study was designed, organized, and started as rapidly as was logistically possible to minimize the
effects of the increasingly cold weather.

During the home visit, the sampling team collected information from the residents and observation
of the home, including but not limited to details about the service line material, type of filter, operating
status of the filter, use of whole house filters/softeners, and water stagnation time. Initially, no special
instructions regarding water stagnation time were provided to residents in advance of filter effectiveness
sampling. Water samples were collected at random stagnation times (random daytime [RDT] samples) as
reported by the residents. After reviewing samples collected in November, it was noted that most of the
reported stagnation times were 1 hour or less. Beginning with samples collected on 11/29/21, schedulers
encouraged residents to stagnate their water prior to the sampling visit, and all residences scheduled for
sampling after 11/29/21 were requested to stagnate their water for 6+ hours prior to the sampling visit
to try to increase the challenge of the influent lead level to the filters.

Filter Study Sampling Protocol. The filter effectiveness study was designed to evaluate whether

properly certified and operated faucet mounted POU and pitcher filters reduced lead to at or below 5

ppb. For this study, properly operated faucet filters included those that had a green or yellow indicator

light when the samples were taken (or were within the total dissolved solids, TDS, operating bounds for

the ZeroWater™ filters) and only had cold water run through them. While properly operated filters were

only considered in this report, the sampling team tracked inadequately maintained filters (i.e., red or
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malfunctioning light, hot water was used through the filter, or TDS reading outside of the operating limit),
and the water was still sampled through these filters. When compromised filters were used by residents,
the EPA sampling team provided filter education to the resident and replaced the filter (following
manufacturer instructions). If the faucet POU filter (or pitcher) filter was compromised, the replacement
filter was sampled if the newly installed filter cartridge did not require a conditioning step. If a conditioning
step was necessary, EPA attempted to schedule a follow-up sampling visit for a later date. All samples
were collected without altering the aerators on the faucet.

Faucet Mounted POU Filter Sampling Procedure. First, with the filter in the on position, the cold-water
tap was turned on and the first 5 seconds of filtered water was collected in a 500 mL or 250 mL wide-
mouth HDPE bottle. This (-5FF##) sample is not considered proper use as, according to the POU filter
operation instructions, the first 5 seconds of use is to be wasted; however, this water sample was analyzed
for lead (data forthcoming). Immediately following the 5 second flush sample, without turning the water
off and taking care not to spill, a 1 L sample of filtered water was collected in a wide-mouth HDPE bottle
(-FF##). Next, the filter was switched to bypass mode without turning the water off, and a 1 L sample of
unfiltered water was collected (-UF##).

Pitcher Filters Sampling Procedure. Any water that was found to be in the pitcher on sampler arrival
was transferred to another container so that the pitcher was completely empty to start. The cold-water
tap was turned on, and a first draw 1 L sample (-PF##) was collected in a 1 L HDPE bottle. Immediately
following without turning off the water, a second 1 L sample (-UF##) was collected without allowing any
water to spill. The first liter of water that was collected (-PF##) was turned "end over end" five times to
mix and then poured into the empty pitcher filter. Once the sample passed completely through the filter
the filtered water was poured into a new sample bottle for laboratory analysis. Some water poured into
the pitcher filter has the potential to be retained within the filter (when the filter is new), so that the
volume of pitcher filtered water was slightly less than the influent volume. If the filtered water sample did
not have enough volume to reach the 1 L mark on the sample bottle, an additional sample of water was
collected and filtered in the pitcher until there was enough effluent to fill the bottle.

Service Line Filter Study Samples. After a review of preliminary data, beginning with samples collected
on and after 12/2/21, an additional pair of samples were collected during filter sampling visits. These
samples targeted water in contact with the service line that was approximated to be at the 7th liter based
on review of past MDHHS sequential profile lead data. The intent was to find higher lead concentrations
to challenge the filter by targeting water that had a greater chance to capture the lead contribution
directly from known or assumed LSLs (if present). Once the first unfiltered sample (-UF##) was collected,

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the cold water was allowed to run (if a faucet filter, the filter was in bypass mode) while filling and wasting
1 L sample bottles until 4 L of water had been flushed after the initial two 1 L samples (-FF## or -PF## and
then -UF##). Then filtered service line and unfiltered service line samples were collected as described
below.

•	Faucet Mounted POU Sites: The filter was switched to the on position and the first 5 seconds of
filtered water was wasted, then a 1 L service line sample of filtered water was collected (-FFL##).
Immediately following the service line (-FFL##) sample, without turning off the water, the filter
was switched to bypass mode and a 1 L sample of unfiltered water was collected (-UFL##).

•	Pitcher Filter Sites: AIL service line sample was collected (-PFL##). Immediately following the
service line sample without turning off the water, a second 1 L sample (-UFL##) was collected. The
-PFL## sample was then filtered through the pitcher filter as previously described.

Sequential Sampling Protocol. Residents were instructed to flush cold water through the faucet in the
intended sampling location for 5 minutes at least 6 hours prior to their scheduled sampling. After the 5-
minute flush, residents were instructed to turn off the faucet and not use any water in the house for at
least 6 hours prior to sampling. Sequential samples were collected only after the resident verified that
water in the entire home had been stagnant for 6+ hours.

The first two sequential samples in the profile were collected in 125 mL HDPE bottles to identify
smaller lead containing premise plumbing components near the tap (i.e., faucet and connected plumbing).
The rest of the sequential samples were collected in 500 mL HDPE bottles. AIL HDPE bottle was included
in each set of sequential samples targeting the anticipated highest lead concentration for lead
fractionation (particulate). The location of the 1 L sample bottle within the sequential set was
predetermined by identifying the location of the peak lead level observed in sequential samples that were
previously collected from the homes by MDHHS. The number of sequential sample bottles equated to
approximately 16 L per site, unless previous sequential sample results from the residence suggested that
a larger or smaller number of samples were necessary to collect water to beyond the service line (fully
flushed water from the main).

Bottles were prelabeled and arranged in order on a nearby surface. The cold-water tap was turned
on (bypass mode if a faucet POU device was present) so that the first volume of water out of the tap was
carefully collected (lower flow rate) in the first sequential sample bottle (125 mL). Immediately following
the first sequential sample, without turning the water off and taking care not to spill, the second sample
was collected. After the first two 125 mL bottles the flow rate was increased and sampling continued until
all bottles allocated for the sampling site were filled.

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Once sequential sampling was complete, the cold water was allowed to continue flushing at the
maximum flow rate for an additional 5 minutes. After 5 minutes of flushing, three 500 mL HDPE sample
bottles were sequentially collected, and temperature was measured (data forthcoming in summer 2022
report). The first flushed sample was analyzed for metals (reported here for lead), the second and third
samples were analyzed for background water quality including alkalinity and total organic carbon [TOC]
(data forthcoming). Water was also collected and analyzed on-site, if possible, for free chlorine, total
chlorine, and alkalinity (alkalinity to be reported later in the summer 2022 report). If field equipment was
unavailable, total chlorine, free chlorine and alkalinity were measured at the field office within two hours
of sample receipt. Free chlorine levels less than 0.2 mg Cl2/L were resampled after an additional 5 minutes
of flushing. If the sample still contained less than 0.2 mg Cl2/L free chlorine, the MDHHS member of the
sampling team collected a water sample for bacteriologic analysis. (MDHHS was responsible for
microbiological analyses (i.e., total coliform and E. coli) and reporting results to residents.) Then flow rate
was reduced to the width of a pencil and four flasks of water were collected with no headspace; these
samples were analyzed for pH in the field laboratory (data to be reported later in the summer 2022
report). Water samples for metals analyses were field preserved with nitric acid to a pH of <2.

Particle Size Fractionation. Sample filtrations and solid sample collection occurred on the 1 L peak-
targeted sequential sample as soon as possible (within 2 hours) to reduce the likelihood that metal
particulate could continue to change overtime. Once back at the field laboratory, the 1 L bottle was turned
"end over end" five times to mix before water was used for each of the various filtrations detailed below.
For the syringe filtrations, each syringe was rinsed with 5 mL of sample water (rinsed and wasted) before
drawing up sample water. Then 50 mL of water from the 1 L sample bottle was filtered through a 0.45 pim
syringe filter into a 60 mL sample bottle, to identify the fraction of colloidal Pb (particle size <0.45 pim).
This step was repeated from the 1 L bottle with a 0.2 pim syringe filter into a separate 60 mL sample bottle,
to determine the nanoparticulate Pb fraction (particle size <0.2 pim). For ultrafiltration the stirred cell has
been observed to adsorb some soluble Pb. For this reason, a pre-conditioning step was developed for the
stirred cell by filling it with 250 mL of sample water for at least 5 minutes to saturate the stirred cell with
Pb. This conditioning water was then wasted, and the cell was refilled with 250 mL of sample water that
underwent filtration. This sample water was filtered through a 30 kDa ultrafilter into a 125 mL bottle for
laboratory analysis, to determine the soluble fraction of Pb. 30 kDa was determined to correlate with pore
sizes smaller than 10 nm. The remaining sample in the 1 L bottle was retained for total metals analysis.

Water analysis. Water samples were analyzed at USEPA Region 5's Chicago Regional Laboratory
(CRL). Samples were analyzed for lead using EPA method 200.8 (CRL Standard Operating Procedure for
the analysis of metals by Inductively Coupled Plasma-Mass Spectrometry, EPA method 200.8/SW-846
Benton Harbor Data Report	7	February 26, 2022


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6020B using the Agilent 7700x, Metals 001 version 11). The reporting limit for Pb from CRL is 0.5 ppb. In
accordance with the target minimum of one per 20 samples, over 100 field blanks were collected,
associated with the approximately 1,800 field samples for metals analysis. Field blanks were filled with
Milli-Q® water (lab distilled water that is passed through a mixed bed resin column before use) at the field
laboratory, capped and taken out to sampling sites. During the sampling visit, the field blank bottle was
uncapped and left open in the sampling location during sampling. Once all samples had been collected
the bottle was capped and placed in the cooler and subsequently field-preserved with the rest of the
samples. The data was validated against the laboratory and field performance requirements, before data
analysis was performed. Free and total chlorine were measured using a Hach (Hach Company, Loveland,
CO) SL1000 portable parallel analyzer according to Hach Method 10260 (EPA approved DPD (N, N-diethyl-
p-phenylenediamine) method).

QUALITY ASSURANCE SUMMARY

This study adhered to the following Quality Assurance Project Plans (QAPP), prepared, and approved prior
to sampling and updated as necessary over the course of the study:

Benton Harbor, Ml Filter Performance Screening and Assessment Study (CESER QA Tracking ID: K-WID-
0033382-QP-1-0)

SAMPLING PROTOCOL

This study followed the sampling procedures outlined in:

Drinking Water Sampling Protocols for Benton Harbor Water Study, Version 2.5 12/10/21

Multiple edits were made to the sampling protocol to address matters in the field and are captured in the

version history at the beginning of the document.

SUMMARY OF RESULTS

Filter Effectiveness Study. The filter effectiveness study consisted of water samples
collected from 199 homes with properly operated filters in Benton Harbor. In total, 306 pairs of
filtered and unfiltered water samples and 1 unpaired filtered water sample (corresponding
unfiltered sample was accidently discarded) were collected (Appendix A).

Lead concentrations in unfiltered water samples at properly operated filter study homes

ranged from below the laboratory lead reporting limit (< 0.5 ppb) to a maximum level of 77 ppb.

Twenty-one percent (63 water samples) of the unfiltered water samples contained lead between

5 ppb and 77 ppb and 46% (141) of the unfiltered samples were between 0.5 ppb and 4.99 ppb.
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Thirty-three percent (102) of the unfiltered samples were below the reporting limit for lead
(Figure 2).

The lead concentrations in all filtered water samples were below the NSF/ANSI 53
certification standard of 5 ppb, and no filtered water lead concentration was greater than 2.5
ppb. Most filtered water samples (90%, 277 samples) were below the reporting limit for lead
(<0.5 ppb). Furthermore, 95% of the samples (291) were below 1 ppb, and 5% of the samples (16)
were between 1 ppb and 2.5 ppb (Figures 2 and 3).

Unfiltered Lead Level

Unfiltered Percentile

Figure 2. Unfiltered lead levels in water from properly operated filter study homes in Benton Harbor.

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Properly Operated Unfiltered and Filtered Samples

•	Unfiltered

•	Filtered

		5 ppb

		0.5 ppb

Unfiltered
N = 306

Filtered
N = 307

Figure 3. Summary of lead levels in filtered and unfiltered
water samples collected at properly operated filter study
Benton Harbor homes.

Sequential Profile Study. Sequential profile datasets were collected from 26 Benton

Harbor homes (see Appendix B). Profiles varied widely and reflected the unique plumbing

configurations and make-up of materials within the home plumbing and service lines. The

maximum peak (many profiles had more than one peak) lead concentration in the profiles ranged

between about 3 to 391 ppb, and the median maximum concentration was 15 ppb (Figure 4).

Three of the profiles had maximum lead concentrations below 5 ppb. Maximum lead profile

concentrations clustered around 1 to 3 L and 6 to 11 L (Figure 5). The minimum lead profile

concentrations ranged between below the reporting limit (0.5 ppb) and 10.5 ppb. The weighted

average lead concentration was determined by dividing the sum of the lead mass of all samples

in a profile by the sum of water sample volume of all samples collected in the profile. The

weighted average lead concentrations across the entire profile ranged between 0.6 ppb and 31
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ppb and the median weighted average value was 6.3 ppb (Figure 4) reflecting the location of
different lead sources in the drinking water in the lead-containing premise plumbing material and
through the service lines. The first draw 1L equivalent is calculated from the profile as follows:
SS01/0.125+SS02/0.125+SS03/0.5+SS04/0.25. First draw 1L equivalent concentrations ranged
between 1.9 ppb and 188 ppb, and the median was 5.6 ppb.

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Fuly Flushed First Draw Equivalent Weighted Average Maximum

(1st L) (FromProfile) (FromProfile)	(FromProfile)

Water Sample Type

Figure 4. Summary of profile data (26 profiles). Boxes represent the median, and 25th and
75th percentiles. Error bars (whiskers) are displayed at the 10th and 90th percentiles.

Dots are data that fall outside of the 10th and 90th percentiles.

BH Sequential Volume Containing Maximum Pb Observed

5 -i	

4 —


a>

E 3-		 	

0	0

1
**—
o

= 2" -1 n	-1	n

o
O

0 I I I1! I I I I1! I I I I1! I I I I I I I I I I I I I I I I I I I1! I I I I1! t I I I1! I I II1! I I I I1! I I I I I I I I I I I M l'l ' I 'I I I I I l'l I I I I I I I I I I I I I I I I I I I I I I I I1! I

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

Cumulative Volume (L)

Figure 5. Location (Liter, L) where maximum lead concentration appears in profile.

Lead Particle Size Fractionation Study. Lead size fractionations by filtration (0.45 [im and
0.2 urn filtrations, and ultrafiltration) were performed on water samples that targeted volumes

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of water with previous high lead concentrations in 16 of the sequential profile sets (homes). Early
in the study, a lead field analyzer test kit was used to screen these targeted volumes and
filtrations were not performed unless a sample tested >9.5 ppb lead. While the field analyzer
remained in use, the trigger level for filtrations was removed for samples collected on and after
11/23/21 (after review of preliminary ICP-MS lead data that indicated the field analyzer was
reading some sample concentrations low). Lead concentrations in the unfiltered targeted
samples ranged between 5 and 133 ppb (median concentration was 14 ppb), and there was no
apparent difference between the amount of lead passing different filter sizes (0.45 |am, 0.2 |am,
ultrafilter) in any of the samples. The fraction of lead in the particulate form based on ultrafiltered
lead results ranged between 15 and 95% (median 37%). Lead particle size fractions indicated by
filter fractionization analyses are not necessarily reflective of individual lead particle sizes.
Particle-particle interactions, particle interactions with filter surfaces and other factors can
impact filter fractionization observations. Additional complementary electron microscopy lead
particle analysis will be reported later in the summer 2022 report.

Chlorine Analyses. Free and total chlorine water analyses were performed at 236 Benton
Harbor homes (two locations had no recorded measurements). Free and total chorine results
ranged between 0.03 and 3.3 mg Ch/L and 0.1 and 3.6 mg Ch/L, respectively (see Appendix C).
Ten homes had free chlorine levels <0.2 mg Ch/L in the first 5-minute flushed sample and 8 of
those homes still contained <0.2 mg Ch/L after an additional 5-minute flush.

CONCLUSIONS

All properly operating filter water samples were found to be below the NSF/ANSI 53 and

bottled water certification (21 C.F.R. § 165.110) requirements of 5 ppb lead (FDA). Despite EPA

efforts to challenge water filters by targeting LSL homes and efforts in the latter portion of the

study to increase stagnation time, lead concentrations in associated unfiltered water samples

were also often found to be low in the homes sampled, with 79% of unfiltered water samples

containing <5 ppb lead. Higher lead levels were observed in stagnated samples at many

sequential sampling locations. Multiple peaks of lead were noted in many of the homes profiled,

indicating more than one significant source of lead to household drinking water. There appeared

to be two relative clusters where the highest lead levels in the profile samples appeared. One

cluster was in the premise plumbing near the tap (lst-3rd liter) and another appeared in the
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volumes likely representing the service line in the range of the 6th to 11th liter. Additional analyses
and other information collected will be reported in a more comprehensive report in summer
2022 which will allow for a more complete analysis and development of broader conclusions.

APPENDIX A

BH_Data_Package_2_7
_22_V2.xls x

Excel Sheet Containing Properly Operating Filter Study Data

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APPENDIX B

2312 Profile

	Pb 	Fully Flushed







Ma
8.9

x Pb
ppb













































































































J ^

r

r











_i—1 L

r

















^	



i—"



0	2	4	6	8	10	12	14	16

Cumulative Volume (L)

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2710 Profile

20
18
16
14

—. 12

-Q
Q_

Q_

10

"a
re
a)

-1 8

Max Pb

¦Pb

•Fully Flushed





1

8.9 ppb









1 ^





























PI



—1

h



n_



1—1—,





LPi

		 j









		 r1





n_





















10	15

Cumulative Volume (L)

20

25

30

25

20

-O

Q_
Q.

"O
TO

Q)

15

10

2715 Profile

¦Pb 	Fully Flushed

Max Pb
26.3 ppb

6	8	10	12

Cumulative Volume (L)

14

16

18

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2753 Profile

-Q

a.

Q.

T3
tc
(L)

20
18
16
14
12
10

¦Pb	Fully Flushed









Max Pb
18.0 ppb

















n



















—































nf







-











-



















r

r













~L



JL/







h







r~







































6	8	10	12	14	16	18

Cumulative Volume (L)

20

2765 Profile

	Pb 	Fully Flushed







Max Pb
24.4 ppb





































U1

















































"1









































0	2	4	6	8	10	12	14	16	18

Cumulative Volume (L)

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16

14

12

10

2?

Q.

Q_

" 8
~a

ro

Q)

3057 Profile

¦Pb

•Fully Flushed

Max Pb
13.4 ppb



10	15

Cumulative Volume (L)

20

25

12

10

-O

Q_
Q.

"O
TO

Q)

3108 Profile

¦Pb

•Fully Flushed

Max Pb

n 11.0 ppb





























































r-i





































6	8

Cumulative Volume (L}

10

12

14

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35

30

25

-Q 20

Q.

Q_

"a
re

a> 15

10

3119 Profile

¦Pb

•Fully Flushed

Max
29.7

Pb
ppb

1

10	15

Cumulative Volume (L)

20

25

3.5

2.5

2

Q.

~D
TO

OJ 1.5

J

0.5

Max Pb
3.13 ppb

3150 Profile

¦Pb 	Fully Flushed

II

4	6	8

Cumulative Volume (L}

10

12

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12

10

_Q
Q_

Q_

— 6
~a

CD

cu

3174 Profile

¦ Pb 	Ful ly Fl ushed







Max Pb
9.75 ppb











Pi







































10	15

Cumulative Volume (L)

20

25

25

20

—. 15

-Q
Q_

Q.

"a

TO
O)

10

3184 Profile

¦Pb 	Fully Flushed













Ma

23[

x Pb
3 ppb



















—





nj































r







h







































6	8	10	12

Cumulative Volume (L)

14	16

18

Benton Harbor Data Report

20

February 26, 2022


-------
16 Max Pb
14.4 ppb

3225 Profile

•Pb 	Fully Flushed

14

12

10

2?

Q.

Q_

" 8
~a

TO
Q)



6	8	10	12

Cumulative Volume (L)

14	16

18

25

20

-O

Q_
Q.

"O
TO

Q)

15

10

3275 Profile

¦Pb 	Fully Flushed









Max Pt
20.3 pp

b

















JL









J	



















1

/I





|—













1







I



















6	8	10	12

Cumulative Volume (L)

14	16

18

Benton Harbor Data Report

21

February 26, 2022


-------
3276 Profile

	Pb 	Fully Flushed

Ma
9.9

x Pb
ppb















rT



























































-1









~|















¦-i	





















0	2	4	6	8	10	12	14	16

Cumulative Volume (L)

-O

Q_
Q.

"O

TO

0)

20
18
16
14
12
10
8
6
4
2
0

3395 Profile

Max Pb

¦Pb

•Fully Flushed







1J

5.9 p

T

pb









































































































J























Lu_r





h_



























6	8	10	12

Cumulative Volume (L)

14

16

18

Benton Harbor Data Report

22

February 26, 2022


-------
25

20

_ 15

_Q

Q.

Q_

~a

TO
Q)

10

3407 Profile



¦Pb

•Fully Flushed

Max Pb

19.6

ppb

6	8	10	12

Cumulative Volume (L)

14

16

18

450

400

350

300

o. 250

Q.

8 200

150

100

50

3446 Profile

¦Pb

•Fully Flushed

Max Pb
391.0 ppb















































































































6	8

Cumulative Volume (L}

10

12

14

Benton Harbor Data Report

23

February 26, 2022


-------
3492 Profile

4.5

3.5

q. 2.5

Q.

tc 9
CD z

1.5

0.5

Max Pb

•Pb

¦Fully Flushed

4.2 p

>pb

























































i—



—

















































H

















n_n

















10

12

14

Cumulative Volume (L)

4348 Profile

	Pb 	Fully Flushed







Max Pb
8.61 ppb

n































































































































































0	2	4	6	8	10	12	14

Cumulative Volume (L)

Benton Harbor Data Report

24

February 26, 2022


-------
4.5

3.5

o. 2.5

Q_

"a

CU T

n k *-

1.5

0.5

4518 Profile

¦Pb

•Fully Flushed

Max Pb
3.98 ppb







































































































































































6	8	10	12

Cumulative Volume (L)

14

16

18

18

16

14

12

o. 10

Q.

-o

03 Q
nt °

4579 Profile

¦Pb

•Fully Flushed

Max Pb
15.5 ppb

	I

6	8

Cumulative Volume (L}

10

12

14

Benton Harbor Data Report

25

February 26, 2022


-------
4613 Profile

	Pb 	Fully Flushed









Max
12.2

Pb
ppb

















—

—







































—







































































0	2	4	6	8	10	12	14	16	18

Cumulative Volume (L)

4615 Profile

	Pb 	Fully Flushed

|—1

Max Pb
19.0 ppb



































































































































































r

























k

























0	2	4	6	8	10	12	14	16	18	20

Cumulative Volume (L)

Benton Harbor Data Report

26

February 26, 2022


-------
4645 Profile

	Pb 	Fully Flushed

Max Pb















.U \J\

JU





























































































"1—





































0	2	4	6	8	10	12	14	16

Cumulative Volume (L)

250

200

-O

Q_
Q.

"O

TO

0)

150

100

50

Max Pb
191 ppb

4730 Profile

¦Pb 	Fully Flushed

6	8	10	12

Cumulative Volume (L}

14	16

18

Benton Harbor Data Report

27

February 26, 2022


-------
_Q
Q_
Q_

"a

TO
O)

10
9
8
7
6
5
4
3
2
1
0

4827 Profile

Max Pb

¦Pb

•Fully Flushed





9.35 ppb































































































































-H























4	6	8

Cumulative Volume (L)

10

12

Appendix C

BH_ChlorineResults.xl

sx

Excel Sheet Containing Free and Total Chlorine Data

REFERENCES

EGLE. (2019). Permit Application for Water Supply Systems. Phosphate Corrosion Inhibitor Installation.

EGLE. (2020). Letter, Water System Corrosion Treatment.

EGLE. (2021a). Benton Harbor Drinking Water Lead Testing, 2018-Present. Retrieved from

https://www.michigan.gov/documents/egle/Benton-Harbor-Water-Status 737420 7.pdf

EGLE. (2021b). Bottled water available in City of Benton Harbor; filters and educational visits to homes
planned. Retrieved from https://www.michigan.gOv/egle/0.9429.7-135-3308 3323-569429-
.OO.html

EGLE. (2021c). City of Benton Harbor Water System, Water System History and Compliance and
Enforcement Update. Briefing to EPA, September 2

FDA. Requirements for Specific Standardized Beverages- Bottled water, 21 C.F.R. § 165.110.

Benton Harbor Data Report	28	February 26, 2022


-------
News, F. (2019). Benton Harbor residents to get free water filters. Retrieved from

https://www.foxl7online.com/2019/01/25/benton-harbor-residents-to-get-free-water-filters
Petitioners. (2021). Petition for Emergency Action under the Safe Drinking Water Act, 42 U.S.C. § 300i
and 42 U.S.C. § 300j-l(b), to Abate the Imminent and Substantial Endangerment to Benton
Harbor, Michigan Residents from Lead Contamination in Drinking Water.

Benton Harbor Data Report

29

February 26, 2022


-------