Correspondence between

Emails where every selected person appears as a sender, recipient, or copied participant.

FW: Michigan Radio interview request: pre-flushing recommendations

Hi, Ok, thanks - I'll be putting the feature together on Monday, so if you are able to line someone up Monday morning, that'd be great. Short of that - would you be able to answer a couple questions by email? *What's the reasoning behind DEQ recommending the pre-flush? EPA doesn't prohibit it, but EPA just told us they don't consider it a best practice, and others argue it can skew water tests for lead. *Do you know whether most cities in Michigan follow the DEQ's pre-flush recommendations for water testing? *Marc Edwards has pointed to a FOIAed document that notes the DEQ's recommendations for the length of pre-flushing have increased from about a minute and a half in 1997 up to 5 minutes now. Why is that the case? thanks! Rebecca Rebecca Williams Senior Reporter Michigan Radio (734) 647-3497 desk cell Havent got anyone readily available for an interview. We're reviewing the testing protocol as part of our internal review. When we've gat something to announce, Pi let you know. b xxxEND_PAGE:deq21_b351_1011_1012_1

FW: Lead Sampling Issues

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

FW: Response from EPA on using SRF for Private Line Replacement

10-6-2015 Response - Kildee.pdf 100615 SRF for Private Line Replacement (Hedman).pdf Follow up communication between Kildee and EPA on replacement of lead service lines and the use of SRF dollars. Nothing that hasn’t already been clarified to us by Susan and others at EPA, but sending so you have this in your files. Maggie

Freeman Elementary Report

Steve asked that I add the address to the school. ] have done so on the attached version. I also added page numbers. Heather Feuerstein Management Assistant to Maggie Pallone, Deputy Director and Brad Wurfel, Communications Director Department of Environmental Quality 517.284.6715 xxxEND_PAGE:deq14_b0801_2659_2659_1

Flint Home Owner's Lead data thru October 28, 2015

Attached is the latest data for Homeowner’s in Flint. The spreadsheet includes samples submitted to the DEQ Lab from September 3" thru October 26". - Of the 306 samples, 238 (77.7%) were at levels of 5ppb and lower for lead - The 90" percentile value is 10 ppb George George L. Krisztian Flint Action Plan Coordinator Laboratory Director Michigan Department of Environmental Quality Desk ph (517) 284-6719 xxxEND_PAGE:deq18_b209_1590_1590_1

More draft answers... DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA.

Before the switch — 1.b. The city of Flint hired consultants to evaluate the ability to treat water from the Flint River. Their consultants produced a report entitled “Analysis of the Flint River as a Permanent Water Supply for the City of Flint” dated July 2011. DEQ received a copy of this report in March 2013. DEQ staff did meet with city officials and their consultants during 2013 to discuss needed water treatment plant upgrades based on the report. 2. The city operated the water treatment plant as a backup/emergency plant for many years. During this time, the plant was operated in test mode quarterly to ensure that it would function in an emergency and to demonstrate that it could produce safe drinking water . During these test runs, raw water and treated water were sampled for many parameters. An evaluation for corrosion control, however, was not completed. After the switch — 6. On August 23, 2015 Dr. Edwards informed DEQ staff that he was initiating a study of Flint water quality issues to complement the sampling that was conducted by the city under the Lead and Copper Rule. Dr. Edwards’ study was performed after the notification by DEQ on August 17, 2015 to the City of Flint that the city is required to install corrosion control in accordance with the lead and copper rule requirements. The DEQ determination made following the regulatory protocol under the lead and copper rule and the study performed by Dr. Edwards reached similar conclusions. Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-284-6543 xxxEND_PAGE:deq14_b0720_2236_2236_1

More draft answers.... DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA.

Date: Thursday, October 15, 2015 4:23:00 PM Before the switch — 1.b. The city of Flint hired consultants to evaluate the ability to treat water from the Flint River. Their consultants produced a report entitled “Analysis of the Flint River as a Permanent Water Supply for the City of Flint” dated July 2011. DEQ received a copy of this report in March 2013. DEQ staff did meet with city officials and their consultants during 2013 to discuss needed water treatment plant upgrades based on the report. 2. The city operated the water treatment plant as a backup/emergency plant for many years. During this time, the plant was operated in test mode quarterly to ensure that it would function in an emergency and to demonstrate that it could produce safe drinking water . During these test runs, raw water and treated water were sampled for many parameters. An evaluation for corrosion control, however, was not completed. After the switch — 6. On August 23, 2015 Dr. Edwards informed DEQ staff that he was initiating a study of Flint water quality issues to complement the sampling that was conducted by the city under the Lead and Copper Rule. Dr. Edwards’ study was performed after the notification by DEQ on August 17, 2015 to the City of Flint that the city is required to install corrosion control in accordance with the lead and copper rule requirements. The DEQ determination made following the regulatory protocol under the lead and copper rule and the study performed by Dr. Edwards reached similar conclusions. Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-284-6543 xxxEND_PAGE:deq03_b289_1742_1742_1

DRAFT response. DRAFT DELIBERATIVE. NOT SUBJECT TO FOIA

Work in process, but we wanted you to have what we’ve completed/addressed. Before switch — 4. Staff believed that it was appropriate to monitor for two 6-month rounds of sampling to determine if additional measures were necessary. Based on the sampling performed, the city is required to install corrosion control treatment (see August 17, 2015 letter). Decisions regarding cost are made by the utility. 5. No. A pilot test was not required or conducted. Staff believed that it was appropriate to monitor for two 6-month rounds to determine if additional measures would be necessary. After switch — 1. We consulted with city staff regarding complaints. They reported that it was difficult to verify the complaints; i.e., when they tried to sample at locations that had problems they couldn’t reproduce the results. In addition, city crews were performing more hydrant flushing to improve water age in the system and flow patterns were altered as a result of valve repair and replacement; and both of these are expected to increase taste, odor and color concerns. In addition, there is no reason for staff to conclude that a TTHM problem would suggest there is a corrosion issue. 2. GM indicated that chloride concentrations no longer met their limit for manufacturing. DEQ staff evaluated chloride levels in the Flint treated water and determined that while they were higher in the Flint supply than previously when on DWSD water, they were well within acceptable ranges in accordance with EPA guidelines. 3. No. Staff believed that it was appropriate to monitor for two 6-month rounds of sampling to determine if additional measures were necessary. 4. No. This was believed to be a site specific/unique condition and staff considered it resolved once the lead service line was replaced. 5. It did. EPA and DEQ consulted. In addition, following the completion of the two 6-month rounds of monitoring the data indicated that additional measures are necessary and the city is required to install corrosion control treatment. Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-284-6543 xxxEND_PAGE:deq14_b0719_2235_2235_1

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