Correspondence between

Attached are a few documents that the Saginaw Bay District just forwarded to the city of Saginaw regarding their LCR history. Paul Reinsch, the Water Superintendent in charge of both the plant and distribution system, is worried about being contacted by the news media about the lead issue. Yesterday, one of the local TV stations were interviewing some local residents about their thoughts. The day before, it was the local paper.

Jon, : tp Attached is a printout of lead and copper 90" percentile results since 2004. That’s as far back as they are entered in SDWIS. Rebecca offered to get you the 2000-2004 data if you want it, but our relevant actions began in about 2006. Here is a timeline of events: 1992 — DEQ notified City of lead/copper rule requirements (Dave Timm letter indicates agreement for a modified consecutive monitoring approach) 1992 — Lead action level was exceeded in first round of monitoring, appropriate follow-up activities took place 1993 — Letter from Bay City (will conduct corrosion study, want to switch to a single, consecutive system for compliance) 1996 — Desktop Corrosion Analysis recommends P04 addition, and DPH (now DEQ) concurs (deadline to install set at 12/31/97) 1996 — Letter from City requesting approval to pilot-test a switch to ferric sulfate as its primary coagulant fcarepstan control goal i is to have a finished water Chloride to Sulfate ratio of 0.6 or less based on AWWA paper and consultant’s recommendation). | cannot locate any correspondence from DEQ agreeing to this requested change, but it appears to have taken place. 1997 — March meeting notes/memo from consultant indicating that bench test results from the coagulant change were encouraging, and requesting a 6-month full scale test (which would be completed before the 12/31/97 deadline - above). I cannot locate any correspondence from DEQ agreeing to this, but the meeting notes.indicate DEQ attended the meeting, and as far as | know the City proceeded with this. 1998 — DEQ letter approves single, consecutive system for compliance monitoring 1998 — System meets action level for January-June, exceeds for July-December 1999 — System meets action level for January-June, exceeds for July-Decmeber 2000 — System meets action level for January-June, exceeds for July-December 2001 — System meets action level for both monitoring periods 2002 — System moves to reduced, annual monitoring, and meets action level 2003 — System remains on reduced, annual monitoring, and meets action level 2004 — System remains on reduced, annual monitoring, and exceeds action level 2005 — System reverts to 6-month monitoring and meets action level during both monitoring periods 2006 — System moves to reduced, annual monitoring, and exceeds action level 2006 — DEQ meets with City (11/29). City indicates that they have contacted their consulting engineer to review ’ corrosion control treatment practices. 2007 — DEQ Sanitary Survey requires City to reoptimize corrosion control due to periodic action level exceedances, with report due to DEQ 6/30/09 2009 — Corrosion control recommendations submitted to DEQ (part of the City’s Simultaneous Compliance Assessment report), DEQ met with City 12/4, consultant recommended PO4 addition and pH adjustment, DEQ concurs 2009 — December 17 letter establishes PO4 and pH adjustment as the official OCCT, set a 12/31/2011 deadline to install 2010 — December 20 Sanitary Survey confirms that the deadline to install OCCT is 12/31/2011, but gives the City two options — commit to a new raw water source (that has a stable pH) and install PO4, or commit to remain on the current. Saginaw Bay source (that has wide variations in pH and alkalinity) and install both PO4 and pH adjustment. The City ~ subsequently chose to switch to a pH-stable raw water source (per their October 25, 2010 letter to us). 2011 — PO4 treatment was installed by the deadline and was ready to begin operation; however, all parties involved agreed that hydrants should be flushed when PO4 treatment began. Due to concerns for cold weather/icing, the City xxxEND_PAGE:deq27_b170_0762_0763_1 BM 2008-1 AV EITY, CHY OF xxxEND_PAGE:deq27_b170_0762_0763_2

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

Just one work of warning, the Saginaw-Midiand Municipal Water Sunnly Corporation had nurnerous private connections to their raw water transmission line from the late 40’s to the early 80’s. Eventually all the individuals were forced off the Hine anc were required ta cormect to a CWS providing finished water or install their own weil, Knowing the thought process of too many farmers, | would not put it past a few of them to use the KWA water service for ‘potable’ purposes. if adequate precautions are not taken, the COWMA will face the same headaches as the MBPH had with the ffarm owners and EPA,

I wasn't directly involved at the time but I believe Genesee County had initially including some possible nonpotable water uses when they were preparing their water withdrawal permit application. I believe they removed all mention of it in order to avoid some higher levels of scrutiny and possibly having additional requirements imposed to justify their request and receive a large quantity water withdrawal permit. I would think Brant may have the best knowledge on this complication and the implications. I believe the county obtained their withdrawal permit without using the public water supply option (by Act 399 construction permit) to avoid having to prepare construction plans. It costs a few thousand dollars but it also did not expire in 18 months as do PWS withdrawal permits if they haven't begun using the water. Therefore, WRD issued the permit and should be the lead in any discussion of a possible change in the intent of this permit. Interestingly, I don't know what restrictions or considerations the state would have if a public water system were to serve agricultural "customers" with finished water. But because this withdrawal permit application was contemplating providing nonpotable water for a separate sector, it came under review. I would include Brant and maybe you, me and/or Steve. Or have a pre-meeting and then decide who should represent the Office. Sent using OWA for iPhone

This is a little add since the Genesee County Drain Commissioner is the head of KWA. barn not currently aware of plans to shut down the DWSD pinetine, though no CWS use is anticipated West of Laneer. WA (Genesee County) has Water Withdrawal Permit 2009-001 through WRB and the water withdrawal program for 85 Sb. htto/ www michigan 200342 7 pdf he withdrawal permit application was not 1@ current plan for Genesee County’s WTF is to start at 30 MGD and expand to 45 MGD. Flint has a WTP capacity of 36 iG, though Hint has only purchased 18 MGD Annual Ave Day Demand in KWA. Lapeer has an option to connect into WA with a capacity of 4 MGB. 50 much of the 85 MGD ts already allocated. fie raw water Lake Huron Purnp station and intermediate booster station have a firm pumping capacity of 60 MGD with space for future pumps. WRE would nese to deal with the oermit any nermit limitations in regares to its decision process, htto://www. michigan. 290345 7 odf Was agricultural use inclucad as part of the application? Would any agricultural user be subject to water efficiency and conservation recndremants? if thase users are simply connecting te the Flint or Genesee County water distribution system then they would fall under the same requirements of any other water system customer. Stephen Busch, PLE. Lansing and Jackson District Supervisor Office of Drinking Water ancl Municipal Assis MDE 517-643-2514 Pag AACE

Your thoughts on whether and/or who should attend for ODWMA?

Date: Thursday, February 05, 2015 2:45:34 PM The Bay City wholesale customers are expected to come into compliance later this year. The new Bay County plant, which will be using Lake Huron versus Saginaw Bay water, is expected to start operations about mid to late July. The current DBPR compliance issue is somewhat associated by an emergency last summer, when Bay City increased the chlorine residuals to deal with a major main break. There are several other wholesale customers for other systems that are approaching but expected to remain below the TTHM MCL. Bad Axe, which is a customer of Huron Shores Regional Water Authority (Pt. Austin), and Scottville, a customer of Ludington, are proactively researching potential solutions in the event their numbers creep a little higher. Both communites are at the end of long transmission lines. Consequently both systems are examining the same potential solution by adding aeration to reservoirs and/or elevated tanks. My calculations indicate that the air stripping option, even strictly using it during the seasonal high formation period, would keep both communities significantly below the MCL.

The good news is thet this is the best time of year as far as distribution system TTHMs go.

Jon, WMEN may be planning to sample as a follow-up to the Flint media coverage, and it may be just from Flint, but since the station requested 3 TTHM sampling units, you may want to provide a heads-up to Saginaw, Bay City and Midland if you haven’t already done so. | would suggest these water systems even consider issuing some sort of proactive statement or press release that updates their customers and those of their consecutive systems on the status of their DBP monitoring and compliance activities in light of the media coverage that Flint has received. They could mention their sampling regimens, their current LRAAs, their ongoing public notifications as needed, any other compliance activities such as the construction of a new plant with an improved source in Bay City’s case, all in an effort to head off any negative news that could be created by someone sampling somewhere in their system and getting high results. They should also alert their consecutive systems so that they may provide a consistent message. | also want to thank George for the heads up. Richard Richard Benzie, P.E., Chief Field Operations Section Office of Drinking Water and Municipal Assistance, MDEQ 517-284-6512

Date: Tuesday, January 20, 2015 9:45:00 AM Jon, WMEN may be planning to sample as a follow-up to the Flint media coverage, and it may be just from Flint, but since the station requested 3 TTHM sampling units, you may want to provide a heads-up to Saginaw, Bay City and Midland if you haven't already done so. | would suggest these water systems even consider issuing some sort of proactive statement or press release that updates their customers and those of their consecutive systems on the status of their DBP monitoring and compliance activities in light of the media coverage that Flint has received. They could mention their sampling regimens, their current LRAAs, their ongoing public notifications as needed, any other compliance activities such as the construction of a new plant with an improved source in Bay City’s case, all in an effort to head off any negative news that could be created by someone sampling somewhere in their system and getting high results. They should also alert their consecutive systems so that they may provide a consistent message. | also want to thank George for the heads up. Richard Richard Benzie, P.E., Chief Field Operations Section Office of Drinking Water and Municipal Assistance, MDEQ 517-284-6512

Importance: High FYI

Liane: Ht appears that the director will be coming to the Bay City office in June and/or September. Last couple of times, he did not want to see anything related to drinking water. Hfhe has changed his mind, we will have the new Bay County plant under construction. Also, we should have the KWA raw water sump station, located Hist south of the village of Lexington, under construction.

Under GASB 34 old infrastructure (pre-1980) was not included in the required valuation of infrastructure assets. However, GASB 34 does provide two methods (Depreciation and Modified) for calculating the value of an infrastructure asset, Despite the 72 line being installed in 1965, perhaps one of these methods could be used to value the asset. In addition, to estimate historical cost of infrastructure, the government has to calculate the current replacement cost of the infrastructure asset, including the costs of materials, equipment and labor used for construction, It then must apply historical consumer price index values, deflating the current value and estimating the cost of the asset at the time it was placed in service. The only issue with an older asset such as this is what to do when the benchmark average lifecycle for that asset type is less than the actual age of the asset. Still trying to follow this approach would at least provide something in line with current accounting and asset management standards. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

Date: Thursday, August 08, 2013 12:16:26 PM Under GASB 34 old infrastructure (pre-1980) was not included in the required valuation of infrastructure assets. However, GASB 34 does provide two methods (Depreciation and Modified) for calculating the value of an infrastructure asset. Despite the 72 line being installed in 1965, perhaps one of these methods could be used to value the asset. In addition, to estimate historical cost of infrastructure, the government has to calculate the current replacement cost of the infrastructure asset, including the costs of materials, equipment and labor used for construction. It then must apply historical consumer price index values, deflating the current value and estimating the cost of the asset at the time it was placed in service. The only issue with an older asset such as this is what to do when the benchmark average lifecycle for that asset type is less than the actual age of the asset. Still trying to follow this approach would at least provide something in line with current accounting and asset management standards. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

Date: Monday, August 05, 2013 3:58:36 PM All — | recently spoke with Randall Byrne (Treasury) and agreed to try to help them with a couple of items. (Randy — sorry it’s taken me so long to get this note out). 1. Flint is considering selling the 72-inch pipeline. It was constructed in 1965 for $6.5M. How would you determine fair market price for such an item? | suggested getting quotes from a couple of contractors for what it would cost to install today and figure some kind of depreciation for a 50 year old pipeline. Other ideas? 2. Treasury is looking for contractors that could possibly operate a distribution system. Could you please provide a list of names/companies that are already doing this kind of work around the state? United Water and Earth Tech were the ones that came to mind. There must be others. Thanks much. Liane Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-373-9523 ** Effective August 12, 2013 my new number will be (517) 284-6543 xxxEND_PAGE:deq01_b026_1836_1836_1

All- | recently spoke with Randall Byrne (Treasury) and agreed to try to help them with a couple of items. (Randy — sorry it’s taken me so long to get this note out). 1. Flint is considering selling the 72-inch pipeline. It was constructed in 1965 for $6.5M. How would you determine fair market price for such an item? | suggested getting quotes from a couple of contractors for what it would cost to install today and figure some kind of depreciation for a 50 year old pipeline. Other ideas? 2. Treasury is looking for contractors that could possibly operate a distribution system. Could you please provide a list of names/companies that are already doing this kind of work around the state? United Water and Earth Tech were the ones that came to mind. There must be others. Thanks much. Liane Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-373-9523 ** Effective August 12, 2013 my new number will be (517) 284-6543 xxxEND_PAGE:deq17_b072_0871_0871_1

Date: Monday, August 05, 2013 3:58:00 PM All — | recently spoke with Randall Byrne (Treasury) and agreed to try to help them with a couple of items. (Randy — sorry it’s taken me so long to get this note out). 1. Flint is considering selling the 72-inch pipeline. It was constructed in 1965 for $6.5M. How would you determine fair market price for such an item? | suggested getting quotes from a couple of contractors for what it would cost to install today and figure some kind of depreciation for a 50 year old pipeline. Other ideas? 2. Treasury is looking for contractors that could possibly operate a distribution system. Could you please provide a list of names/companies that are already doing this kind of work around the state? United Water and Earth Tech were the ones that came to mind. There must be others. Thanks much. Liane Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-373-9523 ** Effective August 12, 2013 my new number will be (517) 284-6543 xxxEND_PAGE:deq03_b017_0020_0020_1

All- | recently spoke with Randall Byrne (Treasury) and agreed to try to help them with a couple of items. (Randy — sorry it’s taken me so long to get this note out). 1, Flint is considering selling the 72-inch pipeline. It was constructed in 1965 for $6.5M. How would you determine fair market price for such an item? | suggested getting quotes from a couple of contractors for what it would cost to install today and figure some kind of depreciation for a 50 year old pipeline. Other ideas? 2. Highland Park is looking at contracting out their water department for the near future. At this point, they would need a company that could manage their distribution system. Could you please provide a list of names/companies that are already doing this kind of work around the state? United Water and Earth Tech were the ones that came to mind. There must be others. Thanks much. Liane Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-373-9523 ** Effective August 12, 2013 my new number will be (517) 284-6543 xxxEND_PAGE:deq04_b575_5314_5665_260 Rennaker, Joanne (DEQ)

Date: Monday, August 05, 2013 3:43:15 PM All — | recently spoke with Randall Byrne (Treasury) and agreed to try to help them with a couple of items. (Randy — sorry it’s taken me so long to get this note out). 1. Flint is considering selling the 72-inch pipeline. It was constructed in 1965 for $6.5M. How would you determine fair market price for such an item? | suggested getting quotes from a couple of contractors for what it would cost to install today and figure some kind of depreciation for a 50 year old pipeline. Other ideas? 2. Highland Park is looking at contracting out their water department for the near future. At this point, they would need a company that could manage their distribution system. Could you please provide a list of names/companies that are already doing this kind of work around the state? United Water and Earth Tech were the ones that came to mind. There must be others. Thanks much. Liane Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-373-9523 ** Effective August 12, 2013 my new number will be (517) 284-6543 xxxEND_PAGE:deq01_b025_1835_1835_1

Date: Monday, August 05, 2013 3:43:00 PM All — | recently spoke with Randall Byrne (Treasury) and agreed to try to help them with a couple of items. (Randy — sorry it’s taken me so long to get this note out). 1. Flint is considering selling the 72-inch pipeline. It was constructed in 1965 for $6.5M. How would you determine fair market price for such an item? | suggested getting quotes from a couple of contractors for what it would cost to install today and figure some kind of depreciation for a 50 year old pipeline. Other ideas? 2. Highland Park is looking at contracting out their water department for the near future. At this point, they would need a company that could manage their distribution system. Could you please provide a list of names/companies that are already doing this kind of work around the state? United Water and Earth Tech were the ones that came to mind. There must be others. Thanks much. Liane Liane J. Shekter Smith, P.E., Chief Office of Drinking Water and Municipal Assistance Michigan Department of Environmental Quality 517-373-9523 ** Effective August 12, 2013 my new number will be (517) 284-6543 xxxEND_PAGE:deq03_b016_0019_0019_1

FYI. Published article linked below. spend 171000 for engi.html Stephen Busch, P.E, Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

Date: Tuesday, July 09, 2013 9:00:48 AM FYI. Published article linked below. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

! received a call this morning (July 8) from Dominic Adams, Flint Journal/Mlive. | called him back with Mike Prysby, District Engineer sitting in on the call. Mr. Adams had obtained information that the City of Flint was contracting some engineering work for the Flint WTP, and the work was in part to potentially use the Flint River as a primary drinking water source. | informed Mr. Adams that the City of Flint receives treated water from DWSD and has been since the 1960’s, but has had the WTP available for reliability should the single transmission line system from DWSD fail. In an emergency the Flint WTP is already approved to use the Flint River for source water and is designed to meet all drinking water standards and public health requirements. : : | also informed Mr. Adams that the engineering work in question would be to primarily enhance treatment capabilities beyond minimum requirements for the purpose of softening to provide customers with water quality consistent with what they already receive from DWSD. Some equipment for softening is already in place, but under emergency operation would not normally be used due to the time required for startup and fine tuning. Mr. Adams asked whether the DEQ has approved or signed off on the proposed engineering work and on allowing the City of Flint to use the River as its source water. | explained that the ODWMA has not received a construction permit application for such work at this time, and that one would be required. | also indicated to Mr. Adams, that regardless of the source water, the City of Flint would be required to meet ail applicable Drinking Water Standards and public health requirements and again that the WTP is already approved as a redundant supply to use the Flint River as a source water _ meeting all drinking water standands and that the WTP undergoes test runs on a quarterly basis to maintain the WTP. Mr. Adams asked for more specifics regarding the treatment process and | explained that the removal of hardness for aesthetic water quality : at this WTP is called lime spiteniniy : Mr. Adams also inquired about the City being able to use the Flint River after the contract with DWSD terminates, and | indicated that may be one option, but they could also continue to purchase treated water from DWSD. In Mr. Adams voicemail he mentioned a variance to use the Flint River, and | reiterated that there is no “Variance”, but that the WTP has been constructed and approved te to treat water from the Flint River to appropriate standards as needed. Let me know if you have any questions. _Stephen Busch, P.E. Lansing and Jackson District Supervisor .- Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314 xxxEND_PAGE:deq27_b325_1544_1743_011 Mr. Howard Kroft . 27 May 7, 2012 | e The fluoride concentration in Flint’s finished water must remain comparable to | the fluoride concentration in DWSD’s water. : e Suggested Practices recommends, and we fully endorse, monitoring WTP filters and plant tap for total colifom bacteria on a daily basis. In addition to plant tap monitoring, a protocol should be Sstablsied for monitoring both treated water components prior to blending. . e Finished water must meet all ‘other applicable Maximum Contaminant Levels for ° ciganle and inorganic parameters. ; . . Based upon the 2007 Water Treatment Plant Sanitary Survey and the results of the most recent WTP test runs, we are confident that the WTP can meet the operational — parameters: discussed above. Given the installation of intermediate chlorination and improved ozone residuals, Flint’s‘CT calculation will need to be “updated. Since Flint was not required to conduct the initial round of source water monitoring for cryptosporidium, treatment classification as part of the Long Term 2 Enhanced Surface Waiter Treatment Rule requirements has not been determined for the WTP. The next - round of cryptosporidium monitoring begins in 2015 and subsequent bin treatment classification for Flint will be determined by 2017 (after completing 24 months of monitoring). Additional treatment for Siypeceperslam may be required depending on. the mentary results. Also, since DWSD would no longer be Flint’s sole source of water, various water distribution system programs including Flint's Bacteriological Monitoring, Lead and Copper, and the Stage 2 Disinfectants and Disinfection Byproducts monitoring - ‘programs will change. ‘Specific changes to these monitoring programs will be discussed - in more detail after the city identifies the future operation of the Flint WTP. The-DEQ has no objection to blending Flint River water with water purchased either