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Stage 2 DBPR, Operational Evaluation Level Exceedances (OEL)

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)