Correspondence between

Date: Monday, November 30, 2015 4:17:01 PM

The attached e-rnall is referenced and is part of a link to several different websites. in shart, tt is naw puble information. i don't know ifany of you have sean the merno in its entirety.

Mr. VanDeventer called me this afternoon and indicated they are looking for LCR related information, so the first bulleted item in their FOIA requests can be considered to be with respect to LCR documents just like the second and third bullet. He also indicated that his use of the phrase, “water testing standards and protocols used to test the community water supply...” was referring to the analytical procedures. | suggested he contact the state laboratory to get the information about the analytical procedures they use for analyzing lead. | said that some of these large systems may also use another certified laboratory, and he would have to contact those laboratories should he want that information. He mentioned that some district staff had informed him there may be a central repository for this information. 90" percentile calculations since 2011 are stored in SDWIS, but individual lead results are not. As the Grand Rapids district first noted, these requests do not specifically ask for actual results, but seem to be more aimed at the implementation of the LCR. | would assume any compliance determination correspondence since January of 2011 would be included. If actual results have been included with correspondence that fits the request, so be it. Please proceed to fill these FOIA requests. Richard Richard Benzie, P.E., Chief xxxEND_PAGE:deq04_b190_3412_3416_1 Field Operations Section Office of Drinking Water and Municipal Assistance, MDEQ 517-284-6512

FYI. If | don’t here from the requestor by Monday, we will fill this request on the assumption that they are interested in the lead and copper monitoring program. Richard Benzie, P.E., Chief Field Operations Section Office of Drinking Water and Municipal Assistance, MDEQ 517-284-6512

| left another voicemail message earlier today and have just now sent this email hoping to get a response by the end of the week.

FYI. We can discuss this matter further at our upcoming FOS Managers meeting. Richard Benzie, P.E., Chief Field Operations Section Office of Drinking Water and Municipal Assistance, MDEQ 517-284-6512

FYI —| left a voicemail message and am awaiting a return call.

After discussing this matter with Kris Philip and others here in Lansing, | am planning to call Farough & Associates tomorrow to see if they will clarify their request. For those of you that have received this request for a water system in your district, we want to respond consistently. We need to know if they are primarily interested in LCR information, or are they requesting additional compliance data. A broad interpretation of their first bullet could imply they are looking for all correspondence related to compliance with the public water supply program and Act 399. We would also like to know what they mean by “water testing standards and protocols.” Is it just water testing protocols, or is it protocols for the PWSS program in general? | will let you know as soon as | get a response.

Just a quick heads up that we are arranging a brown bag session for ODWMA employees in an attempt to explain what is happening with Flint. | know it is short notice, but we have reserved the ConCon Room for Thursday at 11:00 AM. We will provide a call-in option for district offices. Hopefully, at least some staff from each district will participate and fill in those who cannot alter their schedules on short notice. More details about the call-in number will follow as we confirm arrangements and/or they become available. | wanted you to know as soon as we were able to reserve a room. Richard xxxEND_PAGE:deq26_b044_0520_0520_1

Date: Thursday, October 01, 2015 6:57:00 PM FY| —This is where we will be Friday afternoon.

FYI This is where we will be Friday afternoon.

Attached is some additional information regarding what plumbing appurtenances, fixtures, appliances, etc. would pose potential risk for harboring legionella. Stephen Busch, P.E. ‘ Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance © MDEQ 517-643-2314 1 :

Premise plumning.msq > tached is some additional information regarding what plumbing appurtenances, fixtures, [5 ppliances, etc. would pose potential risk for harboring legionella. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance DEQ 7-643-2314 wm

Here are the two separate emails that Steve sent to the hospitals in Flint that Mike and he visited recently.to discuss’ . premise plumbing issues. . Each of the émails has the 3. attachments that were mentioned in the managers meeting today. The email messages outline an approach we should-all follow for now when dealing with these facilities on this issue.

Water Safety PlanHACCP Information.msq Here are the two separate emails that Steve sent to the hospitals in Flint that Mike and he visited recently to discuss premise plumbing issues. Each of the emails has the 3 attachments that were mentioned in the managers meeting today. The email messages outline an approach we should all follow for now when dealing with these facilities on this issue.

This synthesis of state PWSS program activities can be lengthy but often has interesting tidbits. In this edition, | noted a few: e Some interesting things in both the Resources and DWSRF summary paragraphs. * Under implementation, some states noting problems arising with Stage 2 DBP monitoring results, especially in consecutive systems. « in Data Management, lots of complaining as usual. | also noted that a couple of states were moving away from EPA developed electronic sanitary survey software to a GEC developed SWIFT application. e Under Security and Data Management, one state is voicing concerns about giving any locational data to EPA that they cannot keep secure. Most states are going in the other direction — making the data more readily accessible. e Lots of Source Water stuff, including one state requiring above ground (chemical) storage tanks in Source Water Protection Areas to be registered. e Under “Hot Topics:” © Both Alabama and Florida are dealing with premise plumbing and secondary treatment system issues — Alabama issued their first construction permit to a hospital to install treatment to deter Legionella. o Severe and/or worsening drought issues in several states (you know what | tell them - come on back for a long, cool drink of water when you-all get thirsty!). o New York is developing a template for the “Value of Water” Brochure that would allow for the input of state or water system specific information. | am hoping we can utilize that brochure and/or that function in the upcoming drinking water week. o Washington state has returned to producing hard copies of their newsletter based on stakeholder feedback. Apparently, not everyone wants to use a smartphone to read their newsletters. © Wisconsin initiated a requirement for a HEAT EXCHANGE DRILLER’S LICENSE today — April 1%. No Joke. 1 xxxEND_PAGE:deq04_b077_2967_3228_001

Shown below is the short blurb about the pH shift and coagulant studies being conducted by the frozen northern lower peninsula. Feel free to edit or request more detail info. A gradual increase in the pH over the past decade in the northern portions of Lake Michigan has resulted in the coagulant of choice, alum, being less effective for three community water systems. The ODWMA field staff has been working with the communities developing dosage rates to meet minimum solubility requirements based on the water quality change. Also, the field staff has worked with the most impacted community, Traverse City, by giving detail suggestions on conducting a coagulant study. With the average pH of around 8.3 anda maximum of 8.6 in the East Grand Traverse Bay, the city of Traverse City has hired a nationally recognized expert to assist them with selecting another coagulant. (By the way, the consultant told the city the DEQ was right.) Preliminary bench study results indicate that the city should explore the use of ferric chloride or ferric sulfate as their replacement coagulant. The cities of Ludington and Charlevoix may be following suit based on the final results from Traverse City. Following a tour of several communities using ferric based coagulants on the east side of the northern lower peninsula, Traverse City will be proposing a schedule for hiring a consultant to design the new chemical feed system this spring. It is possible the new coagulant feed system will be running in the spring of 2016. xxxEND_PAGE:deq04_b156_3348_3349_2

Saginaw Bay District has dealt with a few systems that have exceeded the OEL during their Stage 2 monitoring. | have been asked by Steve Busch to share a copy of the correspondence we sent. | have created a new folder named “OEL Exceedance Info” on the Lansing server under Community Drinking Water Unit, Standard Documents and Forms, DDBP Rules. In that folder are three documents, one related to Kochville Township and two related to Tittabawassee Township: 1) KochvilleOELMeeting6-13 — Kochville Township exceeded the OEL last year. When a water system exceeds an OEL, they must (within 90 days) submit a report to us identifying possible causes and potential corrective measures. They must evaluate the following factors, if applicable: Source, Treatment, Distribution, and Storage. Kochville purchases water and does not have storage; therefore, only the Distribution category directly applies to them. When this occurs, we ask the wholesale supplier to provide some supplementary information. There does not appear to be a SDWA requirement that the water system meet with us to discuss an OEL exceedance — they can just proceed with the report if they wish; however, | offer to meet with each system that exceeds the OEL to explain what is expected of them, and to go through the EPA’s guidance manual for completing an OEL report. Kochville Township wanted to have a meeting. After the meeting, | wrote the follow-up letter that | placed on the server. You are welcome to share it with your staff. Note —| have, on other occasions, provided the equivalent information to water systems via email rather than a formal letter such as Kochville’s (since there does not appear to be a SDWA requirement that we notify them of the OEL). 2) OELReport02470 — A copy of Tittabawassee Township’s completed OEL report (except for one part that didn’t scan correctly). | chose to include Tittabawassee’s report because they purchase water but have storage and distribution facilities, so their report contained more information than Kochville’s. 3) OELReport02470Pt2 — The remainder of Tittabawassee’s completed report. Bob London Office of Drinking Water and Municipal Assistance xxxEND_PAGE:deq03_b607_4179_4696_406 Saginaw Bay District Office 989-450-7834 xxxEND_PAGE:deq03_b607_4179_4696_407 STATE OF MICHIGAN i" DEPARTMENT OF ENVIRONMENTAL QUALITY 1 A LANSING DISTRICT OFFICE Boa RICK SNYDER DAN WYANT GOVERNOR DIRECTOR September 10, 2044 Mr. Brent Wright City of Flint Water Treatment Plant 4500 North Dort Highway Flint, Michigan 48505 SUBJECT: Compliance Communication Total Trihalomethane Operational Evaluation Requested Under the Stage 2 Disinfectants and Disinfection Byproduct Rule, the City of Flint has been required to collect samples for the analysis of Total Trihalomethane (TTHM) and Haloacetic Acids (HAAS) at eight sites within the City’s water distribution system. The City has completed two quarterly monitoring periods since changing its source water to the Filnt River effective April 25, 2014. ' Normally an Operational Evaluation Level (OEL) would be calculated in accordance with the Michigan Safe Drinking Water Act, Public Act 399, 1976, as amended, Administrative Rule 7196 (R 325.107196), each quarter once three quarters of results have been obtained and compared with the respective maximum contaminant level (MCL) for TTHM. Normally the caiculation would be made as follows: : (2 x current quarter + sum of 2 previous quarters) divided by 4 As the City of Flint currently has only two quarters of data, the calculation has been modified as follows: (2 x current quarter + previous quarter) divided by 4 The resulting OEL for each site is listed in the table below, All results are in parts per billion (ppb): TTHM HAAS | | ~ [ead | 6/21/14 | Mod, OEL be 5/21/44 | 8/21/14 | Mod, OEL 2/90avean il a ; = | 822.8. DortHighway | 1% . = | 3302 8. Dot Highway 96.6 | 127.2 31 | 28 | otra Market) 496.4 | 481.3 24 26 Set aia seen 75.4 | 196.2 38 | 47 48 ec hed d 88.2 | 144.4 49 30 27 toon | 792 | 1183 so | 37 | at CONSTITUTION HALL + 525 WEST ALLEGAN STREET » P.O. BOX 30242 * LANSING, MICHIGAN 48909-7742 wav. michigan.gov/deg * (617) 284-6651 xxxEND_PAGE:deq03_b607_4179_4696_408 Mr. Brent Wright 2 September 10, 2014 As shown in the table above, even with this less restrictive modified method, six of the City's eight sites already exceed the OEL limit of 80 ppb for TTHM. in addition, the City's two other sites are both more than 95% of the TTHM OEL limit. The MCL for TTHM and HAAS is based on a locational running annual average for each site, essentially the average at each site over the four previous quarterly monitoring periods. However, with TTHM levels of this magnitude, it is likely the MCL will be exceeded for at least one of these eight sites from just three quarters of monitoring results. For TTHM, four quarters at the MCL of 80 ppb (4 x 80) would provide 320 ppb allowable. As an example, site DBP1 through just two quarterly monitoring periods has a total of 307 ppb (162+145), leaving only 13 ppb over two more quarterly monitoring periods to maintain compliance with the MCL. Therefore, this office is requesting the City of Flint complete an Operational Evaluation in accordance with Administrative Rule 7191 (R325.101791), The Operational Evaluation Report shall be submitted to this office no later than November 28, 2014. The report shall not be limited in scope and shall include thé following: Examination of Treatment Operational Practices ~ Changes in source water quality - Treatment changes - Storage tank operations - Excess storage capacity » Treatment problems that contribute to TTHM formation Examination of Distribution Operational Practices - Storage tank operations - Excess storage capacity - Distribution system flushing The report shall also include steps the City could consider to minimize future exceedances. Additional guidance on completing the Operational Evaluation Report, including a number of forms that can be used to gather and evaluate water system information is provided in the United States Environmental Protection Agency's (U.S, EPA) Operational Evaluation Guidance Manual. This document is available on the U.S. EPA's website at the following link: http://www, Be advised, failure to submit an Operational Evaluation Report by this deadline is a reporting violation subject to Tier 3 Public Notification. The OEL is an indicator of operational performance. The water system must take proactive steps to be able to comply with the MCL.’s for TTHM and HAAS. While it is recognized that removal of Total Organic Carbon disinfection byproduct precursors as part of the treatment process has performed above minimum removal requirements under the treatment technique, around 4 parts per million of organic carbon are still present in the treated water and may be leading to additional TTHM formation in the City’s distribution system. While health effects associated with disinfection byproducts contaminants are based on chronic exposure, the Cily has available alternatives that must be considered to achieve compliance with this drinking water public health standard. xxxEND_PAGE:deq03_b607_4179_4696_409 Mr, Brent Wright 3) September 10, 2014 If you have any questions regarding this information, please contact me at the number below. cc: Mr. Darnell Early, City of Flint Mr, Daugherty Johnson III, City of FLint Mr. Howard Croft, City of Flint Mr. Robert Bincsik, City of Flint Ms. Llane Shekter Smith, P.E., DEQ Mr, Richard Benzie, P.E., DEQ Mr, Stephen Busch, P.E., DEQ Genesee Co. Health Dept. Sincerely, Wele.O ge Gy Michael Prysby, P.E. District Engineer Office of Drinking Water and Municipal Assistance Lansing District Office (517) 290-8817 xxxEND_PAGE:deq03_b607_4179_4696_410 Rennaker, Joanne (DEQ)

Importance: High You grobably will get this request frorn the multl media coordinator as weil, but | think of district accomplishments as programmatic successes that should be included in the overall ODWIMA accomplishments. Sometimes these projects involve mare than district staff, Hhe aur involvement with Hint, DWSD, thelr emergency managers, the State Treasurer and the Gavernor on the KWA pipeline. Another example is the approval of and financing for the Bay Metro plant that that gets Bay City and customers out of the vulnerable lower Saginaw Bay. It was accomplished with district and Revolving Loan Section staff. 1 xxxEND_PAGE:deq21_b533_1519_1521_1 So ff you could each come up with 2 or 3 exarnples, | expect we would get half of them included for ODWMA. Mote the deadline ~ Decernber 4°.

Attached are the draft rninutes frorn the past meeting. Let me know If you have any commients/changes, also if someone has notes from the second half of the meeting I can add those in if you send them to me. I plan to post the final in the S Drive, RMD_All folder. Kelli Hoffman. West Unit Chief RLS-ODWMA DEQ 517-241-4668 xxxEND_PAGE:deq19_b02_0037_0259_211 ODWMA Managers Meeting 4/12/2013 9:30am SMT Update - Liane SMT Good job getting minutes out Budget SRF -20 percent cut DWRF — 5 percent cut Looking at set asides for balancing House proposal- Does not fund debt service on SAW now Training Share with other staff what training is available and what training is good/useful Ways to better share info? DIT fixed Database — training reports now available Share training reports quarterly Liane shared email on supervisory training thru Civil Service Plan for an in-service? When/Where — RAM Center Needs to be successful/crossover training Need to have concurrent sessions — RLS would need wastewater info Need a — Liane suggested July/Aug 2014? Committee nominations, survey of staff? Wendy spearheading Mentoring New Employee — built in support system Pair up new staff with experienced employee outside of new staff’s unit Better if pairs are physically located near each other Quality of Life mentoring — not well advertised, nobody knew about it Mentoring/Experienced folks should be volunteers not assigned Training for mentors? Level of commitment? Someone from ODWMA needed for communications point person for DEQ social media — keep in mind Restacking Updates RLS was dropped in the original plan, new plan in works % cage in Filley St. dedicated to ODWMA for equipment Get to keep library in place — atrium level Should be able to get collaborative space on 4" floor Note sent to Rhonda about 2 drawer lateral files (specifically style E) — no response yet New phone system Now is the time, with restack Pilot program going to cell phones — Bill Creal All new phone numbers possible QAPPs RLS — need to have for SRF? — When there is a need EPA wants to transfer burden to states for contractors Drinking water lab has QAPP if sample taken to environmental lab than might not have QAPP Liane- we should be covered since we take to certified drinking water lab Metrics Scorecard/Metrics stuff due next week EPA Office of Water program measures xxxEND_PAGE:deq19_b02_0037_0259_212 Metrics needed on more of a program basis — Kathy uses for program budgets Needed to be set up in folders so they are easier to find Will be set up on S: drive, set up by program Carrie — add one in for enforcement RLS new EA distribution system New postcard distribution system EA published online Carrie suggested publishing in DEQ calendar Flex Schedules/Telecommuting SMT - reaffirmed 7am-6pm schedules and telecommuting 64hrs in office per pay period Telecommuting — Formal process — approval process remains the same, must be accessible Informal process — not been ‘legally’ allowed but now will be, old policy to change, discretion up to supervisor. Must be infrequent requests, many liability issues. Okay to say no. Official telecommuting has stringent requirements Four 10’s schedule — up to supervisor. Managers/Clericals need to work five days a week (in general). Liane out Mon-Wed in Chicago next week, EPA PWSS R5 meeting Liane attended MALPH legislative reception this week Liane AWWA board meeting next Friday Liane attending non-community water supply training in Bay City for local Health Depts. 4/22-4/23 Multiple small system training — Deb, Mark Joseph UP Institute same week (May) as stakeholder meeting — Liane and Carrie to discuss Flint Water— —_ waiting for Treasurer to make a decision meeting was held with DEQ, Treasury, Flint, Genesee Co — most onboard with KWA option, more alternatives from DWSD? Highland Park — Letter signed addressing distribution problems and DWSD current situation is temp RLS gets monthly calls from legislative staff about project Liane, Kris visited Waterworks Park, DWSD Liane discussed Director attending RLS staff meeting She met with Director after regarding WRD and RLS — no change. 12:07 end time. xxxEND_PAGE:deq19_b02_0037_0259_213