Correspondence among

Received. Thank you.

For reference, attached is the county health department’s FOIA request to the City of Flint from January. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

Importance: High Attached is a draft violation notice to the City of Flint regarding the exceedance of the drinking water standard for total trihalomethanes (TTHM) based on the latest round of samples collected in February 2015. As predicted, the levels from the latest round are all very low, but the annual average calculation for 2 sites remains above the maximum contaminant level standard. We plan to get the letter out on Thursday so please provide any by Wednesday 3/4. An electronic copy of the signed letter will be provided to Maggie/Sarah for forwarding to legislative members in the Flint area as was done with the last violation notice from December. Again, if you have any questions, please contact me directly. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314 xxxEND_PAGE:deq20_b01_001_057_46 STATE OF MICHIGAN <<" DEPARTMENT OF ENVIRONMENTAL QUALITY Bz LANSING DISTRICT OFFICE RICK SNYDER DAN WYANT GOVERNOR DIRECTOR March 5, 2015 - DRAFT Mr. Brent Wright, Operation Supervisor City Of Flint - DPW WSSN: 02310 Flint Water Plant 4500 North Dort Highway Flint, MI 48505 Dear Mr. Wright: SUBJECT: Violation Notice - Maximum Contaminant Level for Total Trinalomethanes Operational Evaluation — Total Trihalomethanes 1*' Quarter 2015 Monitoring Period The Department of Environmental Quality (DEQ), Office of Drinking Water and Municipal Assistance (ODWMA), records show that the City of Flint is in violation of the Safe Drinking Water Act,1976 PA 399, as amended (Act 399); R 325.10610, Maximum contaminant levels (MCL) for disinfection byproducts, of the 1979 Administrative Code. In accordance with R.325.10610, MCLs for disinfection byproducts, of the 1979 Administrative Code, the MCL for disinfection byproduct total trihalomethanes (TTHM) is 0.080 milligrams per liter (mg/L) as a Locational Running Annual Average (LRAA) at each monitoring location. As listed in the table below, our records show that the City of Flint’s hignest TTHM locational running annual average (LRAA), based on the last four quarters, ending February 28, 2015, is 0.105 mg/l which exceeds the standard, and that two of the eight sample site locations exceed the standard of 0.080 mg/L. Further, in accordance with R325.10719l, Disinfection byproducts: operational evaluation levels, of the 1979 Administrative Code, when an operational evaluation level (OEL) at a monitoring location for TTHM exceeds 0.080 mg/L, a supply shall conduct an operational evaluation and submit a written report of the evaluation to the department not later than 90 days after being notified of the analytical result that causes the supply to exceed the operational evaluation level. As listed in the table below, our records show that TTHM operational evaluation levels for the City of Flint exceed 0.080 mg/L at one of the City’s eight sample site locations. CONSTITUTION HALL * 525 WEST ALLEGAN STREET * P.O. BOX 30242 * LANSING, MICHIGAN 48909-7742 www. michigan.gov/deq * (617) 284-6651 xxxEND_PAGE:deq20_b01_001_057_47 TTHM Results (mg/L) 5/21/14 | 8/21/14 | 11/20/14 | 2/17/15 | LRAA OEL DBP1 McDonalds 0.162 0.145 0.059 0.0162 0.096 0.059 3719 Davison DBP2 Liquor Palace 0.112 0.127 0.033 0.0168 0.072 0.049 3302 S. Dort Highway DBP3 North Flint Auto 0.097 0.118 0.041 0.0149 0.068 0.047 6204 N. Saginaw St. DBP4 University Market 0.106 0.196 0.094 0.0245 0.105 0.085 2501 Flushing Road DBP5 Taco Bell 0.079 0.181 0.034 0.0151 0.078 0.063 3606 Corunna Road DBP6 Rite-Aid Pharmacy | 0.088 0.144 0.054 0.0192 0.076 0.059 5018 Clio Road DBP7 Salem Housing 0.082 0.112 0.050 0.0285 0.068 0.055 3216 MLK Boulevard DBP8 BP Gas Station 0.075 0.112 0.036 0.0199 0.061 0.047 822 S. Dort Highway Our investigation consisted of a review of ODWMA files for laboratory reports received for compliance monitoring. Our investigation is considered complete. This violation began on March 1, 2015, and will continue until TTHM LRAA is below the MCL at all sample sites. We are encouraged by the results from the most recent round of compliance samples collected on February 17, 2015, which now show individual TTHM levels at less than half of the 0.080 mg/L standard at all locations throughout the City’s system. Operational Evaluation Reports from December 2014 and February 2015 have identified possible causes and corrective measures for the previous elevated TTHM levels which we encourage the City continue implementing. These modifications have likely contributed in part to the reduction in TTHM levels reported in the most recent quarter, and suggest the City may be able to achieve compliance with the TTHM standard at all sites by continuing these efforts. Our office is currently reviewing the Operational Evaluation report dated February 27, 2015, and will provide the City and their consultant comments as needed to help address this MCL violation. Water systems that exceed the OEL must complete and submit an Operational Evaluation in accordance with Administrative Rule 7191 (R325.107191) within 90 days of being notified of the violation. An updated Operational Evaluation report, which incorporates the most recent sample results, must now be completed and received by our office by no later than Friday May 29, 2015. If you have any other factual information you would like us to consider regarding the violation identified in this Violation Notice (VN), please provide them in a written response by March 19, 2015. Administrative rule R 325.10403 of Act 399 requires that suppliers provide public notice (PN) as soon as practical, but no later than thirty (30) days after the supplier learns of this type of violation, by mail or direct delivery and by any other means reasonably xxxEND_PAGE:deq20_b01_001_057_48 calculated to reach customers not normally reached by mail. Enclosed is a sample PN which contains the minimum required language. The City is encouraged to include additional information regarding its response efforts to this violation. Please notify your consumers by April 1, 2015, and send us a signed and dated copy of the notice that you issued within ten (10) days of distributing the public notice. This violation must also be included in your 2015 Consumer Confidence Report (CCR), due by July 1, 2016. The PN must be repeated every quarter until you no longer exceed the TTHM standard. Failure to issue a PN for this violation will result in a fine of at least $1,000 per event, with a maximum of $5,000 per violation. We anticipate and appreciate your continued cooperation in resolving this matter. If you have any questions regarding this VN, please contact us at the numbers below. Sincerely, Michael F. Prysby, P.E., District Engineer Adam Rosenthal, EQA Lansing District Office Lansing District Office Office of Drinking Water & Municipal Office of Drinking Water & Municipal Assistance Assistance 517-290-8817 517-284-6644 mfp/ar/jlr Enclosure cc: Mr. Jerry Ambrose, Emergency Manager, City of Flint Mr. Daughtry Johnson, City of Flint Mr. Howard Croft, City of Flint Mr. Robert Bincsik, City of Flint Ms. Jennifer Crooks, U.S. Environmental Protection Agency, Region 5 Genesee County Health Department Ms. Liane Shekter Smith, P.E., DEQ Mr. Richard Benzie, P.E., DEQ Mr. Stephen Busch, P.E., DEQ xxxEND_PAGE:deq20_b01_001_057_49 IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER City of Flint Did Not Meet Treatment Requirements Our water system recently violated a drinking water standard. Although this incident was not an emergency, as our customers, you have a right to know what happened and what we are doing to correct this situation. We routinely monitor for the presence of drinking water contaminants. Samples were collected for total trinalomethanes (TTHM) analysis from eight locations on a quarterly basis (May 21, August 21, November 20 of 2014 and February 17, 2015). The average of the results at ANY of the eight locations must not exceed the maximum contaminant level (MCL) for TTHMs, otherwise our water system exceeds the Maximum Contaminant Level (MCL). The standard for TTHMs is 80 ug/L. The location reporting the highest TTHM level was 105 ug/L; thus, our water system exceeds the TTHM MCL. What should | do? e There is nothing you need to do unless you have a severely compromised immune system, have an infant, or are elderly. These people may be at increased risk and should seek advice about drinking water from their health care providers. e You do not need to boil your water or take other corrective actions. If a situation arises where the water is no longer safe to drink, you will be notified within 24 hours. What does this mean? This is not an emergency. If it had been an emergency, you would have been notified within 24 hours. People who drink water containing trihalomethanes in excess of the MCL over many years may experience problems with their liver, kidneys, or central nervous system, and may have an increased risk of getting cancer. What is being done? We are currently working on solutions to correct the problem. We anticipate resolving the problem in 2015. Our most recent individual sample results were all less than half the 80 yo/L_ standard, however since compliance is calculated using a locational running annual average (LRAA) of the most recent 4 quarters, we are still out of compliance with the MCL at 2 of 8 locations. For more information, please contact Mr. Brent Wright at 517-787-6537 or the Flint Water Plant at 4500 North Dort Highway, Flint, MI 48505. Please share this information with all the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this notice in a public place or distributing copies by hand or mail. This notice is being sent to you by the City of Flint. CERTIFICATION: WSSN: 02310 | certify that this water supply has fully complied with the public notification requirements in the Michigan Safe Drinking Water Act, 1976 PA 399, as amended, and the administrative rules. Signature Title Date Distributed Reminder to water supplier: This notice / certification must be sent to the DEQ. xxxEND_PAGE:deq20_b01_001_057_50

Date: Thursday, October 16, 2014 3:25:19 PM | was just contacted by Kate Wells, Michigan Radio NPR regarding the recent news about General otors concerns regarding chloride levels in Flint’s Drinking Water. explained that chloride does have a secondary level set by EPA which is not for health related issues but rather for taste and aesthetic concerns. Chloride which can generally come from salt, NaCl, sodium chloride, is a normal part of people’s diets, and the amounts in Flint’s drinking water would ikely be minor compared to normal dietary intakes. She asked about how chloride could be causing corrosion issues at GM. | indicated that | wasn’t sure how they were utilizing the water or what their process consisted of. | did indicate that we normally ook at other parameters in drinking water such as pH and alkalinity when considering its corrosivity. She asked about where water is analyzed. | indicated that most chemical analysis is performed at a certified laboratory, and that Flint has generally used the State Drinking Water Lab. She asked about how results are reported and | said that results go back to the system which then provides results to the DEQ, and that the State DW lab will report directly to the DEQ in addition to the City. She asked about consumer confidence reports (CCRs). | explained that these are federal requirements for all Community Water Systems. | informed her that detections for regulated contaminants would be reported but that with the exception of sodium, unregulated contaminants such as chloride are not required to be reported. That sodium is included so people with low sodium diets can determine their intake from water. | also clarified that the City’s current CCR which had to be issued by July 1 would reflect results from 2013 (when Flint was on DWSD) and that 2014 results would be in the CCR issued in 2015. She asked whether there would be similar health related issues from chloride as there are with sodium since they are both in salt, but | indicated that I’m not aware of any such issue and that if there were EPA would have asked it to be reported on the CCR and/or established a primary standard for it. She asked about salt entering water, it’s visibility, and | explained that when salt is present in water it will dissolve into sodium and chloride, that it would not be visible in the water, especially at the levels indicated. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314 xxxEND_PAGE:deq04_b291_3618_3619_1 xxxEND_PAGE:deq04_b291_3618_3619_2

Date: Thursday, October 16, 2014 3:25:18 PM | was just contacted by Kate Wells, Michigan Radio NPR regarding the recent news about General otors concerns regarding chloride levels in Flint’s Drinking Water. explained that chloride does have a secondary level set by EPA which is not for health related issues but rather for taste and aesthetic concerns. Chloride which can generally come from salt, NaCl, sodium chloride, is a normal part of people’s diets, and the amounts in Flint’s drinking water would ikely be minor compared to normal dietary intakes. She asked about how chloride could be causing corrosion issues at GM. | indicated that | wasn’t sure how they were utilizing the water or what their process consisted of. | did indicate that we normally ook at other parameters in drinking water such as pH and alkalinity when considering its corrosivity. She asked about where water is analyzed. | indicated that most chemical analysis is performed at a certified laboratory, and that Flint has generally used the State Drinking Water Lab. She asked about how results are reported and | said that results go back to the system which then provides results to the DEQ, and that the State DW lab will report directly to the DEQ in addition to the City. She asked about consumer confidence reports (CCRs). | explained that these are federal requirements for all Community Water Systems. | informed her that detections for regulated contaminants would be reported but that with the exception of sodium, unregulated contaminants such as chloride are not required to be reported. That sodium is included so people with low sodium diets can determine their intake from water. | also clarified that the City’s current CCR which had to be issued by July 1 would reflect results from 2013 (when Flint was on DWSD) and that 2014 results would be in the CCR issued in 2015. She asked whether there would be similar health related issues from chloride as there are with sodium since they are both in salt, but | indicated that I’m not aware of any such issue and that if there were EPA would have asked it to be reported on the CCR and/or established a primary standard for it. She asked about salt entering water, it’s visibility, and | explained that when salt is present in water it will dissolve into sodium and chloride, that it would not be visible in the water, especially at the levels indicated. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314 xxxEND_PAGE:deq01_b215_3881_3882_1 003882 xxxEND_PAGE:deq01_b215_3881_3882_2

I was just contacted by Kate Wells, Michigan Radio NPR regarding the recent news about General Motors concerns regarding chloride levels in Flint’s Drinking Water. I explained that chloride does have a secondary level set by EPA which is not for health related issues but rather for taste and aesthetic concerns. Chloride which can generally come from salt, NaCl, sodium chloride, is a normal part of people’s diets, and the amounts in Flint’s drinking water would likely be minor compared to normal dietary intakes. She asked about how chloride could be causing corrosion issues at GM. I indicated that I wasn’t sure how they were utilizing the water or what their process consisted of. I did indicate that we normally look at other parameters in drinking water such as pH and alkalinity when considering its corrosivity. She asked about where water is analyzed. I indicated that most chemical analysis is performed. at a certified laboratory, and that Flint has generally used the State Drinking Water Lab. She asked about how results are reported and I said that results go back to the system which then provides results to the DEQ, and that the State DW lab will report directly to the DEQ in addition to the City. ~ She asked about consumer confidence reports (CCRs): | explained that these are federal requirements for all Community Water Systems. I informed her that detections for regulated contaminants would be reported but that with the exception of sodium, unregulated contaminants such as chloride are not required to be reported. That sodium is included so people with low sodium diets can determine their intake from water. I also clarified that the City’s current CCR which had to be issued by July 1 would reflect results from 2013 (when Flint was on DWSD) and that 2014 results would be in the CCR issued in 2015. She asked whether there would be similar health related issues from chloride as there are with sodium since they are both in salt, but I indicated that I’m not aware of any such issue and that if there were EPA would have asked it to be reported on the CCR and/or established a primary standard for it. She asked about salt entering water, it’s visibility, and I explained that when salt is present in water it will dissolve into sodium and chloride, that it would not be visible-in the water, especially at the levels indicated. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

Utility Repairs Dort Hwy Oct 18 2014.pdf FYI. The City of Flint is doing some major repair work this weekend as indicated in the attached information. Customers in the affected area are being notified by the City that they may temporarily lose service and that when service is restored should boil their water until the City can verify that the line was properly disinfected through bacteria monitoring results. This protocol follows normal construction repair standards. To be clear this advisory is not based on any confirmed contamination, but a standard precautionary measure as part of normal construction and repair work. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314