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Dear Mr. Busch, | apprectate your response. Would you be able to send me a copy of the modified consecutive system approach to lead.and copper monitoring that EPA approved? Lam sorry I cannot route my question through the NDWAC or my WG. | am not a NDWAC member, and my WG disbanded when our final report was completed back in August. | apologize if | have caused any confusion. The questions fam posing come solely from me because | am in the process of writing a dissenting opinion about the NDWAC LCR WG recommendations that is due fo EPA In a couple of weeks. One of the main reasons [ am writing this opinion is because of concerns | have about the LCR's CCT requirement. Your experience with and implementation of the LCR in Flintis extremely helpful to me in deepening my understanding about the LCR's CCT requirement and will undoubtedly allow me to write a more informed discussion. | thank you in advance for your help on this matter and your support of ongoing efforts to assess the LCR carefully and thoroughly. ‘ Kindly, - Yanna Lambrinidou Yanna Lambrinidou PhD Parents for Nontoxic Alternatives PO Box 6283 Washington DC 20015 : | P 202.997.1834 . B www. dewasawatch. blogspot: com :

Dr, Lamibrinidou, Yen sarry for the delay in my respanse. As some of your questions relate more to statewide program iraplementation | have requested assistance with the response from staff within aur central program office. However, these staff were attending and participating in an offsite (American Water Works Association Conference Michigan Section} canference last week. G Michigan has implemented an EPA approved modified consecutive system annraach to lead and copper monitoring where a wholesale water supply sells water to other cormmunity water systems. in addition, while water quality parameter (WGP) monitoring occurs at both the water treatrnent plant and in the cornbined distribution system, a WOQP range is only required to be established at the water treatment plant tap after the systern has demonstrated optimized corrosion control treatment (OCCT). Thus when the City of Flint was a customer of the Detroit Water and Sewerage Department (DW5B}, the City of Flint participated in WOP monitoring of its distribution system, but ranges ware established only for the OCCT at DWSD reatmert plants. The attached letter from our Department established the minimurn levels for pH and phosphate dosage in 2000. As the City of Flint water treatrnent plant has not yet installed such treatment or been given the designation of OCCT hese plant tap values have not been established. However, the City of Flint WTP has continued to maintain the minimurn pH value requirement previously established for DWSD As noted in your Working Group Report to the NDWAC, “Corrosion Control Treatment (CCT) involves the addition of chemicals (e.g. orthophosphates or silicate} to create a barrier between the pipes and the drinking water, or to modify drinking water chemistry {such as pH and hardness} to inhibit the potential for corrosion.” Should you consider the Flint WTP softening process te be OCCT, then the City already continues to comply with the OCCT requirements as the City of Hint has never hac 10% or more of compliance tap samples exceed the 15 ppb action level. Even prior to DWSD’s established OCCT the City of Flint lead compliance monitoring has never exceeded the 15 ppb action level, f you have additional questions we would appreciate having therm routed through the NDWAC and your Working Group. Thanks. Stephen Busch, PLE. MIDEQ Lansing Mstrict Coordinator Office of Drinking Water and Municipal Assistance Lansing and Jackson District Supervisor xxxEND_PAGE:deq17_b048_0717_0719_1 SL7-643-2314 [email protected]

Dear Mr. Busch, lam writing to confirm that you received my email below. | would appreciate your thoughts. Kindly, Yanna Lambrinidou Yanna Lambrinidou PhD Parents for Nontoxic Alternatives PO Box 6283 Washington DC 20015 P 202.997.1834 B www. dowasawaich blogspot.com

Dear Mr. Busch, Thank you for your quick response. | appreciate the information at, | am sure, a very busy time for you and MDEQ. Could you please help me understand the following? When you say that all previous optimal water quality parameter ranges would have been established for the Detroit water utility (not for the City of Flint), do you mean that MDEQ never set optimal water quality parameter ranges specifically for Flint before Flint's switch to Flint River water? It is my impression, please correct me if I'm wrong, that under the LCR, all large systems -- whether they are consecutive or not -- must have optimal water quality parameter ranges designated by states specifically for them (at the time when these systems are deemed to have optimized their treatment). Is there language in the LCR | am missing that allows a utility not to have optimal quality parameter ranges established specifically for it? My second question is this: If the City of Flint had no optimal water quality parameter ranges established specifically for it in the past, how did it achieve LCR compliance? Isn't it the case that utility-specific optimal water quality parameter ranges (and maintenance of these ranges) are required for all large systems to avoid an LCR violation? | would appreciate your assistance on this matter, as it will shed light on an issue that seems to be very important for EPA's assessment of and upcoming revisions to the LCR. Kindly, Yanna Lambrinidou Yanna Lambrinidou PhD Parents for Nontoxic Alternatives PO Box 6283 Washington DC 20015 P 202.997.1834 B

Dr. Lambrinidau, AU previous water quality pararneter ranges would have been established for the City af Filnt’s wholesale finished water supplier, the Detroit Water and Sewerage Departmant, not the City of Flint tisalf, As the City of Fint has nat yet established optimized corrosion control treatment, the MDEOQ ts not yet at the point of ragulatory requiremanis where the range of water quality parameters would be set. Stephen Busch, PLL. MDEO Lansing [istrict Coordinatar Office of Drinking Water and Municinal Assistance Lansing and Jackson District Supervisor SEL? -643-2344 xxxEND_PAGE:deq21_b504_1400_1401_1 [email protected]

Date: Monday, September 14, 2015 11:05:31 AM Dr. Lambrinidou, All previous water quality parameter ranges would have been established for the City of Flint’s wholesale finished water supplier, the Detroit Water and Sewerage Department, not the City of Flint itself. As the City of Flint has not yet established optimized corrosion control treatment, the MDEQ is not yet at the point of regulatory requirements where the range of water quality parameters would be set. Stephen Busch, P.E. MDEQ Lansing District Coordinator Office of Drinking Water and Municipal Assistance Lansing and Jackson District Supervisor 517-643-2314 [email protected]

Good morning Mr. Wurfel and Mr. Busch, As a member of the EPA National Drinking Water Advisory Council (NDWAC) Lead and Copper Rule (LCR) workgroup that just completed its recommendations to EPA about the agency's upcoming revisions to the LCR, | am watching with great interest and concern the developments in Flint in relation to lead. | am looking for information on the optimal water quality parameter (WQP) ranges that MDEQ has set for Flint's water. Are those posted online? If so, could you send me the link? If not, could you let me know what they are? Thank you kindly, Yanna Lambrinidou PhD Parents for Nontoxic Alternatives PO Box 6283 Washington DC 20015 P 202.997.1834 B www.dowesawatch bloaspol.com xxxEND_PAGE:deq21_b504_1400_1401_2

Good morning Mr. Wurfel and Mr. Busch, xxxEND_PAGE:deq15_b267_0983_1021_38 . As a swenker of the EPA National Drinking Water Advisory Council (NoWAc) Lead and Copper Rule (LCR) sworkareues that just completed its recommendations to EPA about the agency's upcoming revisions to the LCR, | am watching with ° great interést and concern the developments in Flint in relation to lead. 1 am looking for information on the optimal water - quality parameter (WOP) ranges that MDEQ has set for Flint's water. Are those posted online? If so, could yo send me the link? If not, could you let me know What they are? Thank you kindly, Yanna Lambrinidou PhD Parents for Nontoxic Alternatives PO Box 6283 Washington DC 20015 P 202.997.1834 B xxxEND_PAGE:deq15_b267_0983_1021_39