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Lead Sampling Issues

Linda, Steve Busch asked me to provide you with any information that explains how and why the ODWMA arrived at our recommendations for sampling for lead at consumer taps as required by the Lead, Copper, Corrosion Control regulations (LCR). 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 led 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 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:deq18_b146_1281_1282_1 If you have any questions, please contact me. Richard Richard Benzie, P.E., Chief Field Operations Section Office of Drinking Water and Municipal Assistance, MDEQ 517-284-6512 xxxEND_PAGE:deq18_b146_1281_1282_2

Lead Sampling Issues

Lansing BWL briefing on invalidation for excessive staqnation.pdf Linda, Steve Busch asked me to provide you with any information that explains how and why the ODWMA arrived at our recommendations for sampling for lead at consumer taps as required by the Lead, Copper, Corrosion Control regulations (LCR). 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 led 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 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. If you have any questions, please contact me. Richard Richard Benzie, P.E., Chief Field Operations Section Office of Drinking Water and Municipal Assistance, MDEQ 517-284-6512 xxxEND_PAGE:deq02_b213_2366_2367_1 xxxEND_PAGE:deq02_b213_2366_2367_2

Flint Pb Health Education Conference Call Summary

Hello All, Below is a summary from our call. Please note the action items. In addition, Karen Lishinski pointed out this EPA website as a good resource: htto://water.epa SUMMARY: A conference call with the attendees listed below occurred on 9/22/2015 discussing lead (Pb) outreach in the city of Flint. The purpose of the call was to facilitate introductions, and identify Pb health education materials, current Pb outreach efforts in Flint and existing resources. DEQ provided a brief background of the drinking water compliance process in relation to efforts being conducted in Flint. Information sharing occurred between attendees about the Pb in drinking water sampling efforts in Flint. Each agency/department listed their current health education efforts and available resources that could be made available relative to Pb outreach in Flint. The CLPPP provides some limited funding to prosperity region 6 to conduct Pb outreach. CLPPP is building a Pb Tool Kit for providers. Information about Pb in drinking water does not currently exist in these materials, but they are interested to build that information into the tool kit. DEQ has contacts with the Flint’s drinking water program. GCHD has been getting many phone calls and they have had to create factsheets about water hardness and trihalomethanes. Action Items from the Call: 1. Participants will e-mail their Pb outreach materials and presentations that are in current use to Michelle Bruneau (Bruneau @michigan.gov). 2. GCHD will send Michelle a list of concerns they have been getting from the Flint community. 3. Michelle will to look over the materials to assess what messages are covered, what messages are not covered, and provide suggestions on what work may need to be done to address gaps. 4. Follow-up is needed on the water sampling directions being provided by the city to homeowners that request a Pb in tap water analysis. (There are two sampling procedures depending on the purpose of the water sample.) 5. Karen Lishinski will provide a contact at WIC, so they can be invited to our follow-up conference call. 2 xxxEND_PAGE:dhhs02_b0680_2390_2392_2 002392 6. MDHHS-DEH will arrange a follow-up conference call in approximately two weeks. Attendees: Dawn Hallwood (Genesse Co HD) James Henry (GCHD) Mark Valacak (GCHD) Brad Wurfel (DEQ) Liane Shekter-Smith (DEQ) Richard Benzie (DEQ) Stephen Busch (DEQ) Nancy Peeler (DHHS) Karen Lishinski (DHHS) Linda Dykema (DHHS) Kory Groetsch (DHHS) Michelle Bruneau (DHHS) Current plan is to schedule another conference call in two weeks. Clearly, this is a dynamic and evolving situation. S Best Regards, Kory Groetsch, MS , Manager Toxicology and Response Section Michigan Dept of Health and Human Services (MDHHS) 201 Townsend St. Lansing, MI 48913 517-335-9935 [email protected] Confidentiality Notice: This message, including any attachments, is intended solely for the use of the above named recipient(s) and may contain confidential and/or privileged information. Any unauthorized review, use, disclosure, or distribution of any confidential and/or privileged information contained in this e-mail is expressly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy any and all copies of the original message. xxxEND_PAGE:dhhs02_b0680_2390_2392_3