FW: Privileged Attorney-Client Communication - Outline of Flint Drinking Water Issues
- From
- Madhu Anderson
Wayne — | have attached the documents we pulled together for the Governor's Flint Water Task Force. There is a Q&A document as
well as a timeline of events (we have documents associated with each of the events). If you have a timeline too, it would be good to
see as well. Let me know if you have any questions. Thanks,
Na hha
Madhu R. Anderson
Deputy Director, Economic & Strategic Initiatives
@ 517 284 6702 | 517 290 9653
f=] [email protected]
DEQ
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FLINT DRINKING WATER EVENTS TIMELINE
ATTORNEY CLIENT PRIVILEGE — DRAFT 11/6/2015
Date
Event
Attachment
Pre-1967
Flint Water Treatment Plant in operation
using Flint River for drinking water
1
Post-1967
Flint switched to DWSD for drinking water
None
Jan 2006
Discussions regarding Karegnondi Water
Authority, Preliminary Long-Term Water
Supply for Genesee County
2
June/Sept
2009
Lake Huron Water Supply Study
Karegnondi Water Authority
Executive Summary and
Preliminary Engineering Report
March 2013
Analysis of the Flint River as a Permanent
Water Supply for the City of Flint; Prepared
for: City of Flint dated July 2011
April 2013
April 2013
June 2013
Flint notifies DWSD of contract
discontinuation and joins the
Karegnondi Water Authori
DWSD sets termination of Flint water
service contract to April 17, 2014
Flint notifies DEQ of intent to operate Flint
Water Treatment Plant full time using Flint
River for drinking water
April 2014
DEQ issues Flint WTP construction permits
for full time operation enhancements
W141025 and W141026
May 2014
Flint stops purchasing DWSD water. Starts
using the City of Flint WTP and Flint River
for drinking water
10
Aug 2014
Flint E.Coli Bacteria violation, Localized
System Boil Water Advisory
11
Sept 2014
Disinfection Byproducts (TTHM), DEQ
requests preemptive Operational Evaluation
12
Sept 2014 Flint Total Coliform Bacteria violation,
Localized System Boil Water Advisory
13
Oct 2014
General Motors announces decision to stop
using Flint River as source for production
water
14
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FLINT DRINKING WATER EVENTS TIMELINE
ATTORNEY CLIENT PRIVILEGE — DRAFT 11/6/2015
Date Event Attachment
Dec 2014 Disinfection Byproducts quarterly violation 15
begins
Dec 31, 2015 | 1* 6-month round of lead and copper 16
monitoring ends, 100 samples
90" percentile lead level, 6 parts per billion.
Results due from Flint to DEQ on January
—_ 10, 2015
Jan 21, 2015 | City of Flint Public Meeting regarding 17
disinfection byproducts and bacteria
Feb 26, 2015 | E-mail from EPA to DEQ regarding elevated 18
lead sample
Feb 27, 2015 | E-mail from EPA to DEQ inquiring about 19
Optimized Corrosion Control Treatment
Feb 27, 2015 | DEQ response to EPA email with statement | 20
regarding optimized corrosion control
| program
March 5, 2"4 Disinfection Byproducts quarterly 21
2015 violation notice
April 3, 2015 | LT2 Surface Water Treatment Rule Letter 22
April 6, 2015 | Flint proposes installation of Granular 23
Activated Carbon Filter media to reduce
disinfection byproducts
April 23, EPA e-mail to DEQ regarding corrosion 24
2015 control treatment
April 24. and | DEQ responds to EPA regarding corrosion 25
May 1, 2015 | control treatment
April 27, EPA provided bottles to 212 Browning for 26
2015 lead/copper analyses
May 6, 2015 | Lead service line replaced at 212 Browning. 27
EPA on-site
May 28, 2015 | Internal EPA e-mail regarding results at 212 29
Browning
June 9, 2015 | 3 Disinfection Byproducts quarterly 30
violation notice
June 10, Semi-Annual Conference call with EPA 31
2015 |
June 30, E-mail from EPA scheduling conference call 32
2015 on July 21, 2015 regarding elevated lead
result and concerns regarding corrosion
control
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FLINT DRINKING WATER EVENTS TIMELINE
ATTORNEY CLIENT PRIVILEGE — DRAFT 11/6/2015
Date Event Attachment
June 30, 2nd 6-month round of lead and copper None
2015 monitoring ends. Results due from Flint to
DEQ on July10, 2015
July 9, 2015 | DEQ informed that EPA draft internal memo 33
is on ACLU website
July 14, DEQ issues construction permit to Flint for 34
2015 Granular Activated Carbon filter media
W151055
July 21, Conference call with EPA (LCR 35
2015 implementation and Flint) during which it
informs DEQ its interpretation of LCR
July 24, DEQ e-mail and draft letter 90° percentile 36
2015 lead determination = 11 parts per billion
and City of Flint requirement to add
corrosion control treatment
July 28, DEQ received blood lead level information 37
2015 from DHHS indicating that results since the
switch to the Flint River are consistent with
ast years seasonal variations
Aug 4, 2015 | Meeting with city representatives at 38
Governor's office
Aug 17, 2015 | DEQ notifies Flint of lead/copper 39
monitoring results and requires City to
install corrosion control treatment
Aug 23, 2015 | DEQ notified by an external party that a 40
water quality study was about to begin in
Flint
Sept 2, 2015 | Disinfection Byproducts return to 43
compliance
Sept 11, EPA e-mail confirming that DEQ was never 44
2015 sent the draft June 24, 2015 memo
Sept 21, Meeting with Congressional 45
2015 representatives, legislators, EPA and DEQ
to discuss issues with water quality in Flint
Sept 22, Meeting/Conference call with DHHS, GCHD, 46
2015 and DEQ to discuss lead
education/outreach
Sept 24, Hurley Children’s Hospital data reveals 47 “|
2015 elevated blood lead levels in Flint children
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FLINT DRINKING WATER EVENTS TIMELINE
ATTORNEY CLIENT PRIVILEGE — DRAFT 11/6/2015
[ Date Event Attachment |
Sept 24, DHHS response affirms State blood lead None
2015 level data is more comprehensive than
Hurley Hospital data
Sept 25, Flint issues Lead Advisory regarding 48
2015 drinking water
Oct 1, 2015 | State Chief Medical Officer confirms Hurley None
blood lead level data
Oct 1,2015 | GCHD issues “Do Not Drink” Advisory 49
Oct 2, 2015 DEQ and DHHS press conference. 50
Governor's Flint Action Plan announced.
Oct 2,2015 | GCHD school screening water samples 51
| collected for lead analysis
Oct 8, 2015 | Governor Press Conference: Flint to 52
reconnect to Great Lakes Water
Authority/Detroit Water and Sewerage
Department
Oct 15, 2015 | State Legislature authorizes a $9 million to None
assist the City of Flint to pay for the return
to the Detroit water system and to fund staff
at schools to gauge lead exposure
Oct 16, 2015 | First weekly coordination meeting held None
between the City of Flint and state agencies
Oct 16, 2015 | DEQ meets with Flint Schools None
Superintendent and Genesee County Health
Department
Oct 16, 2015 | Flint switches back to DWSD for water 53
Oct 21, 2015 | Governor Snyder announces formation of None
Flint Water Task Force to complete an
After-Action Review
Oct 28, 2015 | DEQ issues construction permit for 54
additional corrosion control treatment
W151104
Oct 30, 2015 | DEQ letter to Flint regarding corrosion 55
control treatment operation
| Mid-Late Planned connection to Karegnondi Water | None
2016 Authority (Lake Huron water to Flint WTP)
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Privileged Attorney-Client Communication November 16, 2015
Clty of Flint Drinking Water
Outline prepared by the
Michigan Department of Environmental Quality for the
Flint Water Task Force
INTRODUCTION
This document is intended to provide an overview of Michigan’s implementation of
the Safe Drinking Water Act, 1976 PA 399, as amended (Act 399), with respect to
events in the city of Flint (City), Michigan.
BACKGROUND
. How has Flint historically obtained its drinking water?
The water system in the City was organized and built under private ownership in
1883 as the Flint Water Works Company to pump raw water from the Flint River to
their consumers. In 1903, the system was converted to a municipally-owned
corporation which supplied drinking water to the City. In 1967, the City became a
customer of the Detroit Water and Sewerage Department (DWSD) system.
After the switch to DWSD, the City operated its water treatment plant as a standby
plant for purposes of reliability in the event of an emergency, such as an interruption
in service of the single pipeline from DWSD. In the last ten years, the water
treatment plant was used as an emergency backup during two weeks in 2009:
June 18 through June 20 and September 10 through September 13.
As a backup emergency water treatment plant, the City was required to operate the
water treatment plant quarterly to demonstrate the capability to produce drinking
water in accordance with Act 399 and to keep mechanical equipment (such as
valves, rubber seals, etc.) in good working order. Each quarter, the water treatment
plant was test run and samples were taken of both raw water and finished water
(post-filters). Since the water treatment plant was upgraded in the early 2000s,
monitoring showed that the water treatment plant was performing as designed.
Contractual obligations with DWSD did not allow treated water to be put into the
City's distribution system during these test runs. Treated water was discharged to
the Flint River in accordance with a National Pollutant Discharge Elimination System
(NPDES) Permit. The test runs were for demonstration purposes, to keep the water
treatment plant operational. and staff familiar with operation in the event it was
needed in an emergency.
. What State and Federal laws or rules exist to ensure safe drinking water Is
provided to City residents?
The federal Safe Drinking Water Act (federal SDWA) is the primary law that ensures
the quality of Americans’ drinking water. Under the federal SDWA, the United States
Environmental Protection Agency (USEPA) sets standards for drinking water quality
and oversees the states, localities, and water suppliers who implement those
standards.
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Privileged Attorney-Client Communication November 16, 2015
The federal SDWA was originally passed by Congress in 1974 to protect public
health by regulating the nation's public drinking water supply. The law was amended
in 1986 and 1996 and requires many actions to protect drinking water and its
sources: rivers, lakes, reservoirs, springs, and ground water wells. (The federal
SDWA does not regulate private wells which serve fewer than 25 individuals.)
Originally, the federal SDWA focused primarily on treatment as the means of
providing safe drinking water at the tap. The 1996 amendments greatly enhanced
the existing law by recognizing source water protection, operator training, funding for
water system improvements, and public information as important components of safe
drinking water. This approach ensures the quality of drinking water by protecting it