Correspondence among

Attached are revised sampling instructions. This document would be our new recommendations for supplies to provide to homeowners. We've incorporated EPA's most recent comments. Please review and provide any comments/suggestions by 11am. Thanks.

ATTOOO01.htm FY¥i— we'll need to address thase commiants in the document that we were reviewing this morning.

ATTO00001.htm FYI — we'll need to address these comments in the document that we were reviewing this morning.

Updated with Jean/Kris comments incorporated. xxxEND_PAGE:deq16_b4_0688_0891_047 | DRINKING WATER LEAD AND COPPER SAMPLING INSTRUCTIONS ~~~ -{ Formatted: Left: 0.8", Right: 0.8" Dear Resident: Thank you for helping to monitor for lead and copper in your drinking water. This sampling | effortis required by the U.S. Environmental Protection Agency and the Michigan Department of Environmental Quality, and is being accomplished through the cooperation of homeowners and residents. It is important that you follow these instructions so thatwe may-collect an accurate measurement of the lead and copper in your drinking water. This sample is-suppesed teshould represent the water you would typically drink and the faucet from where you weuld drink the water. Call your water supply if you have anyquestions. is to-be-colleciec after water has been sitting in the pipes for an extended-perioc oftime (-e,-he-wateruse-during this period}. Therefore, do not use any water for at least 6 hours before sampling. We do not recommend sampling if the water fas Sat sale fot more ethan formorethantZheus. If the faucet has been idle more than 18 hours, the sample maymight not be analyzed because it does not represent typical daily use. of ri ay ‘1. The best times to sample are early morning or after returning from work. Dueto-this “a Fonnatted: Uist aragraph Indent: [ef 0", jumbered + Level: 1 + Numbering Style: 1, 2, requiremeni_eilhereany mornings or evenings upon returning from work are the best 3, ... + Start at: 1 + Alignment: Left + Aligned times-for-collecting- samples. described. in-more-deiail- below. at 0106) x Indentatagea ue 2. Select a faucet in the KITCHEN or BATHROOM that is commonly used for drinking. DO_ NOT sample from a laundry sink or a hose spigot as these samples cannot be used by your-watersupplyfor compliance. 3. If you have a single handle faucet, turn it to the COLD side. Place the open sample bottle (open) below the faucet and gently open the cold water tap. Fill the sample bottle to the neck of the-bottie with the “first draw” of COLD water. 4..Water must sit idle in the pipes for an extended lenath of time before sampling. A-sample 4. Tightly cap the sample bottle and place in the sample kit provided. Please+Review the sample kit label at-this-thme-to ensure that-all information contained on the label is correct. | 5. Answer the questions on the back of this form and-remerrberte sign the form. 6. Attach this form to the bottle and leave it outside your front door for pick-up. 7. Thank you again for your help. We will send you the results within 30 days of receiving them. Information on this year’s lead and copper monitoring will be printed in the | Water Quality Report that will be made available to you by July 1 of next year. Contact your water supply if you have anyquestions. Water Supply: If you have arnyquestions call: xxxEND_PAGE:deq16_b4_0688_0891_048 Manager or Michigan Department of Environmental Quality Water Operator: DEQ Contact: Phone: Phone: Or Contact: xxxEND_PAGE:deq16_b4_0688_0891_049 — A. Which faucet did you use to fill the bottle? Ui Kitchen (Main bathroom — LJ Other If OTHER, please describe: B. When was the faucet last used before sampling? Date TIME AM/PM Cc. When did you fill the bottle? DATE TIME AM/PM D. Is this faucet connected to a home treatment device such as a water softener, a reverse osmosis unit, an iron removal device OR is any kind of additive used in the home? YES NO If YES, please describe: Note: If you have a home treatment device OR any kind of additive is used-inthe-home,, it is possible we might not analyze your sample or be able to use your sample for compliance purposes. E. If any plumbing repairs or replacement has been done in the home since the previous sampling event, please note this information here: If YES, please describe: | have read the Drinking Water Lead and Copper Sampling Instructions and have taken a tap sample in accordance with these directions. Signature Date xxxEND_PAGE:deq16_b4_0688_0891_050

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.

| read it today and had a few comments but wanted to discuss them with Kris Philip before | replied. | hope to have that conversation tomorrow. Liane is out until October 7.

All--Richard pointed out you all have busy working on issues with our favorite City, and also you all were out last week for the Section meeting. In light of the possibility that we will be shut-down next Thursday, | would like to finalize this on Wednesday COB. If you can get me any comments by say Wednesday early afternoon, | can finalize at the end of the day. If we have a continuing resolution, ’d like to get comments by Friday, Oct 2 COB and | will finalize on Monday Oct 5. Dan said he had a few comments on my NCWS write-up for data management, etc. Liane, I’m hoping you can read my resources comments, and Flint comments, and make sure these are OK with you. Thank you all for your time. ennifer

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

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

Flint-Site5-BWA.pdf FYI

Date: Monday, October 03, 2011 3:15:19 PM Kris, please weigh in before Adam calls them back. Pat suggested they resample, but he forgot it was already October (Can't fault Pat - | can’t remember what YEAR this is!) | believe the samples are improper and should not be used to calculate the 90". The supply cannot resample because we are outside the June-Sept monitoring period. Calculate the 90" on the available proper sample results. The supply is short the minimum number of samples, so an M/R violation applies as does admin fine and PN. | could be persuaded on the admin fine.

Date: Monday, October 03, 2011 2:42:26 PM can they since it's October?

Date: Monday, October 03, 2011 2:40:35 PM | hate to say it, but since they did not meet the minimum 6 hour stagnation time, | don’t think we can accept the results of those 2 samples. They will have to resample. Pat

| was notified by Jeff Antil that Detroit received samples from Flint, and they were 2 samples short. Actually they had all samples, but according to the last use and collection times for 2 samples, equaled 5 hrs and 5.5 hrs stagnation time. Input please. thanks, Adam 1 xxxEND_PAGE:deq04_b075_2261_2598_138 Rennaker, Joanne (DEQ)

Date: Monday, October 03, 2011 2:20:13 PM | was notified by Jeff Antil that Detroit received samples from Flint, and they were 2 samples short. Actually they had all samples, but according to the last use and collection times for 2 samples, equaled 5 hrs and 5.5 hrs stagnation time. Input please. thanks, Adam xxxEND_PAGE:deq01_b207_3873_3873_1

(11-2-10).pptx Please try to accommodate this request. | can’t do much by next Thursday, and Patis oul as well. Atleast get some data on the number of violations we have experienced and make an effort to answer the questions at the end of this message. Thanks.

Summary The EPA does not give specific guidance on standing times, but mentions it in the preamble of the 1991 rule and in their 1991 guidance manual, The PREAMBLE discusses a proposed 8-18 hour standing time and the controversy surrounding the 8 hours. The EPA settled on 6 hours, but did not discuss the upper limit further. The GUIDANCE MANUAL states that water use during the previous day should be typical of daily use when occupied. It also mentions 12 hours as excessively long in @ parenthetical statement. Details below, Details Preamble: The preamble of the original lead and copper rule (56 FR 26460 dated June 7, 1991) states, “The 1988 proposal would have required systems to collect ...sample at a consumer's tap that has been standing in the interior plumbing for 8 to 18 hours and was collected without prior flushing” (page 26518, column 3, under 2, Sample Collection). However, “numerous commenters were critical of the 8 to 18 hour standing time requirement” (page 26520, column 1 under ii. Standing Time). The EPA responded with reducing the minimum standing time to 6 hours, but no longer addressed the maximum standing time. Later in the preamble, under the public notification and system reporting and recordkeeping requirements section, the EPA notes that the final rule settled on requiring systems to certify that the first draw sample stood motionless for least 6 hours with no further mention of the 18 hours {page 26531, column 1, under a. Tap Monitoring.) Guidance Manual: The EPA mentions excessive standing times in their guidance manual. “First Draw Tap Samples: Samples can be collected any time as long as the water has stood undisturbed in the pipes for at least 6 hours. Water use during the day before sample collection should have been typical of its daily use when occupied. PWSs should request home owners to indicate when water had iast been used in the house prior to sampling and the time that the sample was collected. Estimating the stagnation period may assist PWSs in data interpretation, especially when excessively long stagnation periods are encountered (more than 12 hours).” There is no further mention of excessively long stagnation period (page 4-14 of the Lead and Copper Rule Guidance Manual, Volume I: Monitoring, dated September 1991, Drinking Water Technology Branch, Drinking Water Standards Division, Office of Ground Water and Drinking Water.) xxxEND_PAGE:deq18_b145_1280_1280_1