Follow Up Flag: Follow up
Flag Status: Flagged
Jim,
On behalf of the Task Force, thank you for sending us the corrosion control plan letter this morning for our
review. Attached please find EPA’s edits to that letter. We also understand that MDEQ will issue an amended permit
shortly to take account of the Task Force’s comments sent to you today.
EPA encourages the City to take advantage of our offer for analytical support as our laboratory can analyze for a more
robust set of parameters. The presence or absence of these additional parameters has provided valuable information
and insights in past efforts on identifying potential sources of lead.
The Task Force believes Flint should implement the additional corrosion control treatment as soon as possible. The
letter and amended permit are an important step in making sure additional corrosion control takes place quickly and
appropriately.
- Bob
Robert Kaplan
Deputy Regional Administrator
U.S. EPA Region 5
Phone: (312) 886-1499
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STATE OF MICHIGAN —_
<_
DEPARTMENT OF ENVIRONMENTAL QUALITY DEéss.
LANSING DISTRICT OFFICE
RICK SNYDER DAN WYANT.
GOVERNOR DIRECTOR
October 30, 2015
Mr. Mike Glasgow
Utilities Administrator
City of Flint
4500 North Dort Highway
Flint, Michigan 48505
Dear Mr. Glasgow:
The purpose of this letter is to outli
the additional corrosion control trea
and Sewerage Department
6, 2015. DWSD/GLWA
in in the City water distribution system, customer service
ity shall dose additional orthophosphate to increase
distribution syst
The City has obtained:
(Act 399), water syste!
Control Station 2 and Pum}
October 28, 2015.
tion permit for the installation of this treatment equipment at
ion 4, construction permit number WW151104, issued on
The City should also maintain a minimum pH level of 7.0 throughout the City’s water distribution
system. If pH levels of 7.0 or less are detected, the City shall immediately notify the MDEQ.
As part of the City water system operations, the City shall conduct:
- Daily monitoring of incoming DWSD/GLWA water for pH and for orthophosphate
residual, as PO,
- Daily monitoring of additional orthophosphate dosage, as PO,
- Daily monitoring of water entering the City distribution system for pH and for
orthophosphate residual, as PO,
CONSTITUTION HALL * 525 WEST ALLEGAN STREET + P.O. BOX 30242 + LANSING, MICHIGAN 48909-7742
www. michigan.gov/deq * (517) 335-6010
xxxEND_PAGE:deq20_b02_058_173_056
Mr. Mike Glasgow 2 October 30, 2015
This information shall be included in the City’s monthly operation report and shall be reported to
the MDEQ as required under Administrative Rule 1502 (R 325.11502) of the administrative rules
promulgated pursuant to Act 399.
Enhanced Water Quality Parameter Monitoring
The City’s revised monitoring schedule dated October 22, 2015, requires quarterly Water
Quality Parameter Monitoring at 25 sites throughout the City’s water distribution system for
temperature (Celcius), Conductivity (mS), pH, Total Alkalinity (mg/L as CaCO), Calcium (mg/L
as Ca’*), and orthophosphate (mg/L PO,). Ten of these 25 sites are also used by the City to
conduct required total coliform bacteria and chlorine residual monitoring (location numbers 1, 2,
3, 4, 5, 6, 7, 8, CS, and WS). At these ten locations the City shall also conduct weekly
monitoring for the following parameters at the same time that total coliform bacteria and
chlorine residual monitoring is conducted to further assess water stability:
- Turbidity (NTU) - Calcium (mg/L as Ca”)
- tron (mg/L) - Chloride (mg/L as CI)
- Orthophosphate (mg/L PO,) - Temperature (Celcius)
- pH - Conductivity (mS)
- Total Alkalinity (mg/L as CaCO,;)
If orthophosphate residual levels less than 3.1 mg/L as PO, (1.0 mg/L as P) are detected at any
of these locations, then orthophosphate dosage shall be increased to achieve the minimum
phosphate residual of 3.1 mg/L as PO, (1.0 mg/L as P) at all locations. In addition, if pH levels
of 7.0 or less are detected at any of these locations, the City shall immediately notify the MDEQ.
Corrosion Control Treatment Test Loops
To further confirm the effectiveness of corrosion control treatment and the City’s operations, it is
recommended that the City construct, install, and monitor test loops of service line and plumbing
materials. Instructions for construction, installation, and monitoring of these test loops can be
obtained from the United States Environmental Protection Agency's (U.S. EPA) Office of
Research and Development. The U.S. EPA has also offered to provide analytical services to
support this investigative effort. Please contact Mr. Darren Lytle, Acting Branch Chief, at
512-569-7432 or
[email protected].
Lead Service Line Verification Sampling
The City has been reviewing customer service connection records in order to confirm customer
service line materials at each connection. The U.S. EPA has developed a sampling procedure
that can be used to help verify the presence of lead service lines and it is recommended that the
City conduct this sampling at a selection of customer locations for this purpose. Information
regarding this erent sampling can also) be onanies ner Mr. mie Any water analysis for
compliance At is expected to be completed by a certified ee The Ci ‘of Flint may wish to
conduct this lead service line investigative sampling in cooperation with the U.S. EPA, which
has offered to provide analytical services.
Customer Household Exposure Assessment
DRAFT
xxxEND_PAGE:deq20_b02_058_173_057
Mr. Mike Glasgow 3 October 30, 2015
The Michigan Department of Health and Human Services (MDHHS) is continuing to conduct
blood lead level testing for children in the City. Families with children found to have elevated
blood lead levels will be asked to have an elevated blood lead level investigation conducted at
their residence that will include a lead exposure assessment, including the contribution of lead