Correspondence among

Please see Luke’s draft notes -- attached, and provide cornments to me by 1/8/16. | will finalize and place ori the Lansing drive, Thanks, Army Arny Lachance Grand Rapids District Coordinator and Grand Rapids and Kalamazoo District Supervisor Office of Brinking Water and Municipal Assistance Michigan Department of Emvronmental Cuallty Work Cell xxxEND_PAGE:deq18_b300_3141_3141_1

xxxEND_PAGE:deq21_b281_0870_0871_1 Yesterday, it was asked whether Lansing should be notified if you are involved with or working on a Pb/Cu issue. For now that will be a good idea. Please send me a brief e-mail (and cc Tracy Jo) that | can forward to Jim S. as a heads up. Please continue to do this for the near term as issues arise. Thanks. xxxEND_PAGE:deq21_b281_0870_0871_2

Date: Friday, October 09, 2015 1:45:00 PM Yesterday, it was asked whether Lansing should be notified if you are involved with or working ona Pb/Cu issue. For now that will be a good idea. Please send me a brief e-mail (and cc Tracy Jo) that | can forward to Jim S. as a heads up. Please continue to do this for the near term as issues arise. Thanks. xxxEND_PAGE:deq03_b094_0111_0111_1

Indicators Summary July 2015.doc All—Attached, please find the annual End-of-Year Evaluation of Michigan DEQ’s implementation of the PWSS in Michigan for FY 2014; and the Measures and Indicators page which is a compilation of the most recent data for all quantitative measures that Region 5 uses to regularly assess State program performance. Thank you for your comments and edits, which | have included. If you have any comments or questions regarding the Evaluation or the Measures and Indicators page, please let me know. Thank you for all your hard work! Jennifer Jennifer Kurtz Crooks Michigan Program Manager Ground Water and Drinking Water Branch U.S. EPA Region 5 77 West Jackson Bivd. Chicago, Illinois 60604 312.886.0244 [email protected] 312.582.5853 (fax) xxxEND_PAGE:deq04_b021_1427_1582_114 Michigan Department of Environmental Quality (Michigan DEQ), Office of Drinking Water and Municipal Assistance, Public Water System Supervision (PWSS) Program Work Plan Summary and FY 2014 End-of-Year Evaluation Contacts: Michigan DEQ Field Operations Section Chief: Richard Benzie, [email protected], (517) 284-6512; Michigan DEQ Environmental Health Section Chief: Carrie Monosmith, [email protected], (517) 290-2601. U.S. EPA Region 5 Michigan State Program Manager, Ground Water and Drinking Water Branch (GWDWB): Jennifer Kurtz Crooks, [email protected], (312) 886-0244 Federal funding used: PWSS grant; Drinking Water State Revolving Fund (DWSRF) Set-asides: 1) Small System Technical Assistance set-aside, 2) PWSS Program set-asides to supplement the PWSS program, and 3) Local Assistance set-asides that includes Wellhead Protection and Capacity Development. FY 2014 End-of-Year Evaluation Synopsis: Analysis of the various programs within Michigan’s drinking water program (below), and the data gleaned from implementation of these programs (see attached Measures and Indicators page), show many program improvements by Michigan DEQ. It is important to note that Michigan DEQ does not currently have adequate electronic reporting capabilities, due to competing priorities and resource limitations. Information Technology (IT) support from the Department of Technology, Management and Budget (DTMB) is now being provided to support WaterTrack until the noncommunity water system (NCWS) data moves to SDWIS/State or SDWIS-Prime. Financial/staff limitations within the Michigan PWSS program are an ongoing obstacle. For FY 2014, Region 5 commends Michigan DEQ for exceeding its targets for all National Drinking Water and Source Water Protection Measures, which include those from U.S. EPA’s Office of Ground Water and Drinking Water (OGWDW) and the Office of Enforcement and Compliance Assurance (OECA). During the most recent Drinking Water State Revolving Fund (DWSRF) Performance Evaluation in May 2015, the Region noted Michigan DEQ’s continued use of set-asides for innovative purposes and projects. The DWSRF set-aside workplans are very well written from a technical and financial perspective. Progress is noted in all activities funded with DWSRF set-asides. The FY 2014 Program Evaluation Report (PER) for the Michigan State Revolving Fund Programs, prepared by Region 5 State and Tribal Programs Branch and dated July 27, 2015, should be consulted for more information regarding the State’s DWSRF program. The most recent Regional Shared Goals, which represent CY 2014 (final data as of April 2015), show Michigan DEQ met 6 milestones of the 7 goals. The non-transient noncommunity water system (NTNCWS) goal not met indicated that more than 5% (5.2%) NTNCWSs have significant/major monitoring violations for acute-based standards; namely for total coliform and nitrate. | | | : Pere | xxxEND_PAGE:deq04_b021_1427_1582_115 Resources and Expertise: Michigan DEQ employs a highly trained staff with the technical expertise to carry out all mandatory components of the PWSS program (including engineering plan and specification review, sanitary surveys and emergency response. ) However, due to lack of adequate funding, the drinking water program cannot hire sufficient staff to accomplish all program activities. As a result, the PWSS program prioritizes activities, placing emphasis on those with direct impact on public health. Contracts with the Local Health Departments (LHD) to conduct the PWSS program at NCWSs, have been successful in ensuring public health is protected. However, the upcoming implementation of the Federal Revised Total Coliform Rule (RTCR) in FY 2016 with no additional Federal funding, may force the Michigan DEQ to prioritize LHD activities, and could increase the number of primacy activities the LHDs will be unable to complete. Michigan DEQ has indicated that if the Federal PWSS grant continues to be reduced or if the DWSRF set-asides are reduced, adequate staffing levels may be difficult to maintain and Michigan DEQ’s ability to meet federal PWSS primacy requirements could be jeopardized. The Region continues to offer assistance to the State, which includes compliance assistance and enforcement partnership. Rules and Primacy: Michigan DEQ has been granted primacy for all Federal drinking water regulations, and is implementing all drinking water rules. The State submitted its draft RTCR for Region 5 review, and the Region provided comments for public hearing in February 2015. The Region looks forward to receipt of the RTCR primacy package in FY 2016. For the past several years, Michigan DEQ disinvested in a number of program activities that were partially implemented in FY 2014. Partial implementation includes: 1. Lead Consumer Notification of tap results at NTNTCWSs:

Date: Friday, September 25, 2015 8:05:57 AM In general, I think this looks good. Was it shared with George Kristian at the lab for review? One other point, not sure how eDWR would reduce the number of samples that exceed the hold time. I didn't include Jennifer on this response. Make sure she knows I had a chance to look at her review. Thanks.

Date: Friday, September 11, 2015 5:43:00 PM While I’m gone next week, I’m requesting the following be available “acting” for signatures, if necessary: Monday and Tuesday — Carrie Monosmith Wednesday thru Friday - Sonya Butler I'll check e-mail periodically. The best way to reach me is by text (269-967-0681) and | can return a call. There are a number of personnel transactions in the works, but the biggest items are the log letters related to Flint and the FOIA requests. See you in a week. Liane 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_b279_0438_0438_1

All---Yes, | know, I’m a bit behind in documenting our evaluation of your program this year, for which | apologize. | summarized activities during FY 2014, but also included more up-to-date information to make this document more relevant to you. Please note that this is a final draft from the Region, but this is your opportunity to make changes to this document. Also, | included a sentence about Flint under Rules and Primacy, acknowledging the resources you all have provided Flint. Again, please feel free to edit/delete. If you could provide me with any revisions by Monday Sept 14, | can finalize. Also attached is our rather voluminous chart summary of Measures and Indicators used to assist with evaluating your program. Please note that the Logic Model Report Tool (LMRT) was not funded by HQ in 2015, so we did not receive any updated data this year. The LMRT data provided in this document was received in July 2014, for CY 2009-CY 2013. Not very relevant now, but FYI. We are currently looking for another national source of data that we can analyze that will give us trends, as did the LMRT data. Thank you! Jennifer xxxEND_PAGE:deq03_b372_1910_1911_2

Not sure if any of you might have seen this over the weekend. Should the outbreak continue to spread, this issue may gain traction nationwide. Stephen Busch, P.E. L MDEQ Lansing District Coordinator Office of Drinking Water and Municipal Assistance Lansing and Jackson District Supervisor 517-643-2314 [email protected] xxxEND_PAGE:deq26_b244_2025_2051_03 Olszewski, Rosemarie (DEQ)

All--Belaw are my draft notes from our call last week, June 10, 2015. Thank you all for participating. | apologize for the delay in getting these out in draft te you all for review—I was hoping to get a couple of items ironed out that were fuzzy during our discussions, but hasn’t happened yet. Several ACTION items below. So, please review to make sure | documented our discussion/agreements correctly, and feel free to edit as needed. { you could get back to me by July 13, that wouid be great. Thank you! Jennifer Attendees: MDEQ: Liane Shekter-Smith, Richard Benzie, Carrie Monasmith, Kris Philip, Dan Dettweiler, Marjorie Rodriguez (Student), Kevin Hoidwick, Mike Prysby, Dana DeBruyn, Steve Busch EPA Region 5: Tom Pay, Rita Bair, Nick Damato, Janet Kuefler, Michele Palmer, Tom Murphy, Heather Shoven, Cary McElhinney, Andrea Parter, Miguel Deltoral, Mostafa Noureldin i.Changes in Lead Disinvestments and Commitments for FY 2016 ARDP—for discussion: Due to our extreme focus on lead in drinking water, this is the consensus here. {Suggested wording} The NCWS pragram commits to full implementation of the lead consumer notification of tap results requirement, to begin in CY 2016. Region 5 will assist in a notification outreach effort in late FY 2015 to remaining 698 NTNCWSs that are not schools/daycares, to begin providing lead consumer notice in CY 2015. NCWS program commits 1 xxxEND_PAGE:deq27_b048_0234_0239_1 to include information on providing lead consumer notice in the annual monitoring letter sent to all NTNCW5s for CY 2016. STATE: The State faund this change in the wording acceptable. Callection of Lead samples at NINCWSs during June — September 2016 timeframe {Suggested wording) NCWS program cammits to including information in the applicable NTNCWS annual monitoring letters of the requirement to collect their annual/triennial lead sample between June and September only, during CY 2016, The MDEQ NCWS program currently does not have the capability to easily track lead sampling compliance within this specific timeframe. STATE: The State found this change in the wording acceptable.

See the note below regarding the “report” from Miguel at Region 5. Stephen Busch, PLL. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDBEQ SL7-643-2314 xxxEND_PAGE:deq21_b188_0646_0647_1

Date: Wednesday, July 08, 2015 2:53:58 PM Importance: High See the note below regarding the “report” from Miguel at Region 5. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

Date: Wednesday, July 08, 2015 2:53:59 PM Importance: High See the note below regarding the “report” from Miguel at Region 5. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

All—Below are my draft notes from our call last week, June 10, 2015, Thank you all for participating. | apologize for the delay in getting these out in draft to you all for review—I was hoping to get a couple of items ironed out that were fuzzy during our discussions, but hasn’t happened yet. Several ACTION items below. So, please review to make sure | documented our discussion/agreements correctly, and feel free to edit as needed. | you could get back to me by July 13, that would be great. Thank you! Jennifer Attendees; MDEQ:; Liane Shekter-Smith, Richard Benzie, Carrie Monosmith, Kris Philip, Dan Dettweiler, Marjorie Rodriguez (Student), Kevin Holdwick, Mike Prysby, Dana DeBruyn, Steve Busch EPA Region 5: Tom Poy, Rita Bair, Nick Damato, Janet Kuefler, Michele Palmer, Tom Murphy, Heather Shoven, Cary McElhinney, Andrea Porter, Miguel Deltoral, Mostafa Noureldin Summary: 1.Changes in Lead Disinvestments and Commitments for FY 2016 ARDP—for discussion: Due to our extreme focus on lead in drinking water, this is the consensus here. Consumer notification of tap results at NINCWSs: (Suggested wording) The NCWS program commits to full implementation of the lead consumer notification of tap results requirement, to begin in CY 2016. Region 5 will assist in a notification outreach effort in late FY 2015 to remaining 698 NTNCWSs that are not schools/daycares, to begin providing lead consumer notice in CY 2016, NCWS program commits to include information on providing lead consumer notice in the annual monitoring letter sent to all NTNCWSs for CY 2016. STATE: The State found this change in the wording acceptable. Collection of Lead samples at NINCWSs during June — September 2016 timeframe (Suggested wording) NCWS program commits to including information in the applicable NTNCWS annual monitoring letters of the requirement to collect their annual/triennial lead sample between June and September only, during CY 2016. The MDEQ NCWS program currently does not have the capability to easily track lead sampling compliance within this specific timeframe. xxxEND_PAGE:deq04_b300_3630_4070_398 STATE: The State found this change in the wording acceptable. Follow-up Actions for NINCWSs that sample outside of June-September 2015 timeframe

AH—Below ere my draft notes frorn our call last week, June LO, 2015. Thank you all for participating. | apologize far the datay in getting these out in craft to you all for review—I{ was honing to gat a couple of iterns ironed out thet wera fuzzy during our discussions, out hasn’t happened yet, Several ACTION iterns below, So, please review to make sure | documented our discussion/agreements correctly, and feel free to edit as needed. | you could get back to me by July 13, that would be great. Thank youl fennifer th, & Ber fran Dettweil 3 Marjorie Rodriguez Mike Prysby ar, Form Murphy, Heather Shoven, Cary i.Changes in Lead Disinvestments and Commitments for FY 2016 ARDP—for discussion: Due to our extreme focus on lead in drinking water, this is the consensus here. Consumer notification of tap results at NINCWSs: (Suggested wording) The NCWS program commits to full implementation of the lead consumer notification of tap results requirement, to begin in CY 2016. Region 5 will assist in a notification outreach effort in late FY 2015 to remaining 698 NTNCWSs that are not schools/daycares, to begin providing lead consumer notice in CY 2016. NCWS program commits xxxEND_PAGE:deq24_b016_0044_0049_1 to include information on providing lead consumer notice in the annual monitoring letter sent to all NTNCWSs for CY 2016. @ found this change inthe wording acc Collection of Lead samples at NINCWSs during June — September 2016 timeframe (Suggested wording) NCWS program commits to including information in the applicable NTNCWS annual monitoring letters of the requirement to collect their annual/triennial lead sample between June and September only, during CY 2016. The MDEQ NCWS program currently does not have the capability to easily track lead sampling compliance within this specific timeframe. ST :: The St found this change in the wording acceptable. Follow-up Actions for NINCWSs that sample outside of June-September 2015 timeframe

Greetings, Here is an agenda for the meeting on Monday morning to give DLARA participaris some notice of ihe topics to be discussed. itis my infention that this meeting not be overiy formal and we car ask questions and discuss isgues as they arise. Richard Benzie, PE. Chief Field Operations Section Office of Drinking Water and Municipal Assistance, MDEQ 547-284-6512

Today Richard asked me the rales thet the folks invited to Monday's rneeting are: Jira Scott is the section manager of the Health Facilities Engineering Section (plan review and physical plant inspections of hospitals and long term care facilities}. Teri Dyke is the section mariager that oversees federal certification of hospitals. Joe Madztar is the head of the plumbing division. As of today it looks Hke they are all with DLARA, i did not invite anyone from the apidermiclogical or disease sections, for the local health denartments.} since the goal was to discuss the physical prernise and permit and operational aspects. Dana xxxEND_PAGE:deq19_b03_0260_0305_01 DEQ/DLARA Meeting Agenda June 15, 2015 Edward-Hutchinson Conference Room Atrium South 1. Introductions — Liane Shekter Smith, Chief, ODWMA 2. Purpose — Liane Shekter Smith 3. Secondary Treatment and EPA — Richard Benzie, Chief, Field Operations a. b. c. d. e. PWS Definition Reasons for Secondary Treatment of premise plumbing/hot water systems Classification - Community vs. Noncommunity Veteran’s Administration Directive HACCP/Water Safety Plans 4. Approach to Secondary Treatment — Liane Shekter Smith a. b. Role and Responsibility of DLARA Programs Role and Responsibility of DEQ Programs — Richard Benzie and Steve Busch, Lansing/Jackson District Supervisor i. Act 399 construction permits ii. Engineered treatment systems with paced chemical feed ili. Coordination with plumbing permits iv. Initial state oversight/approval (in lieu of LHD) v. Certified Operator oversight vi. Disinfection Byproduct Monitoring, but not coliform sampling vii. Annual Fees Outreach and Education — Carrie Monosmith, Chief, Environmental Health Section 5. Conclusion/Action Items — Liane Shekter Smith xxxEND_PAGE:deq19_b03_0260_0305_02

Date: Thursday, March 19, 2015 8:59:06 AM The call is cancelled. We are going to try and reschedule in April.--Carrie

’ The call is cancelled. We are going to try and reschedule in April.--Carrie

Importance: High | have finally been able to set up a conference call with some of the members of the Michigan Hospital Association. However, | do believe they are more interested in what is happening in Flint rather than the regulatory aspects of secondary treatment. Unfortunately, this meeting can only be held at 3 PM this afternoon, or else it will wait at least 2 more weeks because one of their participants will be out of the country. | worked with Janice Jones, MHA, to get this set up. | did tell her that we would try to do it today, but it may have to be cancelled because the key people here all had meeting conflicts. (It conflicts with the Region 5 PWSS State call.) | don’t mind handling the call, but | don’t know the current Flint situation or enough of the particulars on the Legionella outbreak there to adequately answer their questions. Liane & Richard—if you can’t participate, perhaps Steve Busch and | could meet with them. Please let me know what you would like to do so that if this needs to be postponed | won't be doing it at the last minute, thanks-Carrie xxxEND_PAGE:deq28_b058_0218_0220_2 Benzie, Richard (DEQ .

: Importance: High 1 « | have finally been able to set up a conference call with some of the members of the Michigan Hospital Association. However, I do believe they are more interested in what is happening in Flint rather than the -regulatory aspects of secondary treatment. Unfortunately, this meeting can only be held at 3 PM this - : afternoon, or else it will wait at least 2 more weeks because one of their participants will be out of the country. f worked with Janice Jones, MHA, to-get this set up. | did tell her that we would try to do it today, but it may “have to be cancelled because the key people here all had meeting conflicts. (It conflicts with the Region 5 PWSS State call.) | don’t mind handling the call, but | don’t know the current Flint situation or enough of the particulars on the Legionella outbreak theré to adequately answer their questions.-Liane & Richard—if you can’t participate, perhaps Steve Busch and | could meet with them. Please Jet me know what you would like to do so that if this needs to be postponed | won’t be doing it at the last minute, thanks-Carrie ; xxxEND_PAGE:deq26_b240_1890_2019_070 . Devereaux, Tracy Jo (DEQ) . :

I’m not sure if anyone else receives these messages from ASDWA so | am sending it to those | think may want to contribute to the answers ASDWA is seeking about possible revisions to the Lead and Copper Rule. | also don’t know who has time to deal with this matter by the requested response date of March 13". | believe Pat and Jean were leads for Michigan on our contribution to the Region 5 workgroup that was providing Miguel Del Toro with advice for his participation in the national LCR workgroup. But Jean is out until April, Pat will only be in the office a few days between now and March ih. am out most of next week, and Kris leaves next Thursday for almost 2 weeks. | don’t think the answers to the questions are simple and they could take some collaboration. Anyone want to volunteer? Too bad we haven't filled that LCR/CCR Rule Manager position. But then they probably couldn’t answer these questions alone.

FY¥!— articles regarding Flint and KWA,

Date: Friday, March 21, 2014 10:06:21 AM FYI. The order between Flint and OWMRP regarding the Bray Road site was signed by all parties yesterday and is fully executed. If you would like a copy of the order, please let me know. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314 xxxEND_PAGE:deq01_b058_3602_3602_1

The language below in quotes is not what is included in the Order. in general, | chink what is provided below addresses our concern that we are not requiring thern to use KWA as their source, Ht acknowledges that either scenario will require changes which must be permitted under Act 399. Not sure what is provided is the only or best way to say it; but have ne oreblem with it as written. ido have a few other questians/comments on the Order in general that | will share with Rich.

Date: Wednesday, February 12, 2014 11:05:00 AM The language below in quotes is not what is included in the Order. In general, | think what is provided below addresses our concern that we are not requiring them to use KWA as their source. It acknowledges that either scenario will require changes which must be permitted under Act 399. Not sure what is provided is the only or best way to say it; but | have no problem with it as written. | do have a few other questions/comments on the Order in general that | will share with Rich.