F Flint Water Crisis Public Archive

Richard Kuhl

Assistant Attorney General at Environment, Natural Resources, and Agriculture Division / AG

Also known as Richard S. Kuhl

22

Emails

Oct 2015–Dec 2015

Archive range

22 emails found.

Flint Drinking Water Issues -

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New article by Dr. Hanna-Attisha in American Journal of Public Health attempting to draw a direct link between lead levels in drinking water and elevated blood lead levels. Richard S. Kuhl Assistant Attorney General Environment, Natural Resources, and Agriculture Division 6" Floor, G. Mennen Williams Building 525 West Ottawa Street P.O. Box 30755 Lansing, MI 48909 PH: (517) 335-0696 FX: (617) 373-1610 kublr@michigan gov xxxEND_PAGE:deq15_b821_2862_2862_1

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Fe eee ce Sem cc 9 Ee cc tc a ee . Attorney-Client Privilege xxxEND_PAGE:deq21_b044_0074_0076_2 Richard S. Kuhl Assistant Attorney General Environment, Natural Resources, and Agriculture Division 6 Floor, G. Mennen Williams Building 525 West Ottawa Street P.O. Box 80755 Lansing, MI 48909 PH: (517) 335-0696 FX: (517) 373-1610 xxxEND_PAGE:deq21_b044_0074_0076_3

DEQ's Outline of Flint Drinking Water Issues - Flint Water Task Force - Attorney Client

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Privilege Work Product -11-16-2015.pdf Apologies for the lateness of the hour. The final draft is attached © Thanks, Traty Jo Tracy Jo Devereaux Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality Constitution Hall, 4th Floor, South Tower, Pillar P8 525 W. Allegan Street Lansing, Michigan 48933 517-284-6544 xxxEND_PAGE:deq25_b050_0733_0733_1

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(DEQ); Busch, Stephen (DEQ); Philip, Kris (DEQ); Sygo, Jim (DEQ); Wyant, Dan (DEQ); Anderson, Madhu (DEQ); Jom Karen (DEQ); Wurfel, Brad (DEQ); Pallone, Maggie (DEQ); Krisztian, George (DEQ) Attorney-Client Privilege xxxEND_PAGE:deq24_b199_0510_0512_1 Richard S. Kobi Assistant Attorney General Errvirommnen tural Resources, and Agriculture Division 6 Floor, G. Mennen Willams Prudiding 825 West Ottawa Street PAD. Box 80755 Lansing, Mi 48909 as AV) 338-0686 SO GLT 323-1610 kublr@

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<THELENM? @imichizan.gov>, "Shaler, Karen (DEQ)" <[email protected]>, "Benzie, Richard (DEQ)" <BENZIERG@ michigan. goy>, "Prysby, Mike (DEQ)" <[email protected]>, "Busch, Stephen (DEQ)" <BUSCHS@ michizan.goy>, "Philip, Kris (DEQ)" <[email protected]>, "Sygo, Jim (DEQ)" <[email protected]>, "Wyant, Dan (DEQ)" <VWyantD @michigan.gov>, "Anderson, Madhu (DEQ)" "Tommasulo, Karen (DEQ)" "Wurfel, Brad (DEQ)" <[email protected]>, "Pallone, Maggie (DEQ)" <[email protected]>, "Krisztian, George (DEQ)" <krisztiang@m

FW: Lead Sampling Issues

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Thought folks might find these documents informative: Attached to this message are a couple of documents that were prepared over a decade ago that discuss excessive stagnation and sample invalidation under the LCR. They were prepared in response to questions from the Washington Post and other news media about invalidation of some samples collected in the Lansing Board of Water Light service area. The first document is an internal memo that identifies language in the federal preamble to and in EPA guidance for the LCR that discuss the need to collect samples from homes that have experienced “typical residential water use during the day before the compliance sample is collected.” The second document is a report prepared to explain why we “invalidated” samples for excessive stagnation in Lansing. It was in the aftermath of this event when EPA eliminated the ability of state programs to invalidate sample results based on excessive stagnation that ed the Michigan Public Water Supply Program to develop a recommendation that communities advise residents participating in their compliance monitoring to flush the designated sampling tap 6 to 8 hours before sample collection (the night before in most cases) to ensure that this tap was not experiencing excessive periods of stagnation. We did not want subsequent regulatory requirements to be imposed based on water quality information that did not accurately reflect the regulatory intent. This briefing report also xxxEND_PAGE:deq04_b214_3461_3462_1 discusses the fact that the regulatory monitoring scheme was not intended to represent human intake, but was based upon sampling a statistically significant number of residences containing leaded plumbing materials as a measure of successful water treatment efficacy. xxxEND_PAGE:deq04_b214_3461_3462_2

Flint Safe Drinking Water Act Issue

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All, Because of the potential for litigation being filed against the Department over the Safe Drinking Water Act issues involving the City of Flint’s use of water from the Flint River, we believe that a litigation hold should be put in place to ensure that documents and information relating to this matter are preserved. As stated in the memo, we recommend that the memo be circulated to any DEQ employees or contractors who have been involved in these issues. DTMB should also be alerted to ensure that electronic information is maintained. xxxEND_PAGE:deq04_b076_2599_2966_183 Please let us know if you have any questions regarding the attachment or if we provide you any assistance on this issue. Richard Richard S. Kuhl Assistant Attorney General Environment, Natural Resources, and Agriculture Division 6'» Floor, G. Mennen Williams Building 525 West Ottawa Street P.O. Box 30755 Lansing, MI 48909 PH: (517) 335-0696 FX: (617) 373-1610 [email protected] xxxEND_PAGE:deq04_b076_2599_2966_184 DEPARTMENT OF ATTORNEY GENERAL MEMORANDUM October 15, 2015 vo; Jim Sygo, Chief Deputy Director, Department of Environmental Quality (MDEQ) George Krisztian, Flint Action Plan Coordinator and Laboratory Director Liane Shekter Smith, Chief, Office of Drinking Water and Municipal Assistance (ODWMA) Steve Busch, District Supervisor, Lansing District Office, ODWMA