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.

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

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

Just one work of warning, the Saginaw-Midiand Municipal Water Sunnly Corporation had nurnerous private connections to their raw water transmission line from the late 40’s to the early 80’s. Eventually all the individuals were forced off the Hine anc were required ta cormect to a CWS providing finished water or install their own weil, Knowing the thought process of too many farmers, | would not put it past a few of them to use the KWA water service for ‘potable’ purposes. if adequate precautions are not taken, the COWMA will face the same headaches as the MBPH had with the ffarm owners and EPA,

I wasn't directly involved at the time but I believe Genesee County had initially including some possible nonpotable water uses when they were preparing their water withdrawal permit application. I believe they removed all mention of it in order to avoid some higher levels of scrutiny and possibly having additional requirements imposed to justify their request and receive a large quantity water withdrawal permit. I would think Brant may have the best knowledge on this complication and the implications. I believe the county obtained their withdrawal permit without using the public water supply option (by Act 399 construction permit) to avoid having to prepare construction plans. It costs a few thousand dollars but it also did not expire in 18 months as do PWS withdrawal permits if they haven't begun using the water. Therefore, WRD issued the permit and should be the lead in any discussion of a possible change in the intent of this permit. Interestingly, I don't know what restrictions or considerations the state would have if a public water system were to serve agricultural "customers" with finished water. But because this withdrawal permit application was contemplating providing nonpotable water for a separate sector, it came under review. I would include Brant and maybe you, me and/or Steve. Or have a pre-meeting and then decide who should represent the Office. Sent using OWA for iPhone

This is a little add since the Genesee County Drain Commissioner is the head of KWA. barn not currently aware of plans to shut down the DWSD pinetine, though no CWS use is anticipated West of Laneer. WA (Genesee County) has Water Withdrawal Permit 2009-001 through WRB and the water withdrawal program for 85 Sb. htto/ www michigan 200342 7 pdf he withdrawal permit application was not 1@ current plan for Genesee County’s WTF is to start at 30 MGD and expand to 45 MGD. Flint has a WTP capacity of 36 iG, though Hint has only purchased 18 MGD Annual Ave Day Demand in KWA. Lapeer has an option to connect into WA with a capacity of 4 MGB. 50 much of the 85 MGD ts already allocated. fie raw water Lake Huron Purnp station and intermediate booster station have a firm pumping capacity of 60 MGD with space for future pumps. WRE would nese to deal with the oermit any nermit limitations in regares to its decision process, htto://www. michigan. 290345 7 odf Was agricultural use inclucad as part of the application? Would any agricultural user be subject to water efficiency and conservation recndremants? if thase users are simply connecting te the Flint or Genesee County water distribution system then they would fall under the same requirements of any other water system customer. Stephen Busch, PLE. Lansing and Jackson District Supervisor Office of Drinking Water ancl Municipal Assis MDE 517-643-2514 Pag AACE

Your thoughts on whether and/or who should attend for ODWMA?

Importance: High FYI

FYI. Attached is what we have prepared for our OEL situation. As we don’t have 3 full quarters we had to modify the approach. Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance MDEQ 517-643-2314

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)

See the latest timeline for a specific contract. John O' Date: “Tue, Jun 10, 2014 at 3:01 PM Subject FW: Updated Rs Planning Calendar con rnailecom>

We were crovided the documents from the sanitarian for the intermediate pump station. As shown on the permit the minimiuan distance is 10 feat. We will have JH address the distance from the pump station as discussed in the review meeting,

Attached are MDEQ’s comments for the LHPS & IPS — 90% design for tomorrow’s meeting Also attached are MDEQ’s comments for the Flint Transmission main S-4007 — 60% design for tomorrow's meeting Given Saginaw Bay schedule, it would be best, if possible, to cover the pump station comments first followed by the Flint transmission main comments. See you all at 8:30am. Michael Prysby, P.E. District Engineer Office of Drinking Water and Municipal Assistance 517 290-8817 xxxEND_PAGE:deq11_b398_1839_1839_1

Attached are draft comments for the 90% submittal (IPS and LHPS) based upon our review and subsequent discussion. Feel free, as needed, to edit and/or provide any additional comments. As we discussed, | will contact Jon and Daryl tomorrow at 10am to further discuss our review comments pertaining to the LHPS. Following our discussion and receipt of any additional comments, | will prepare a final punch list for our meeting on Thurs. | will also forward a copy of the punch-list to Genesee County prior to COB tomorrow. | also attached my comments pertaining to the 60% submittal (S-4007 -Flint pipeline) if there is an opportunity for further review of this portion of the project. Michael Prysby, P.E. District Engineer Office of Drinking Water and Municipal Assistance 517 290-8817 xxxEND_PAGE:deq25_b213_3352_3352_1

60% plans for the KWA pipeline Contract S-4007 (Flint’s portion) has been received and loaded on the Lansing Central Drive (T). This also includes the 60% Design Report. T:\Drinking Water and Environmental Health\Community Drinking Water\District Offices\Lansing District\KWA-plans Given that this portion of the project is the Flint contract and in Genesee County, | plan to take the lead on the review and have comments on behalf of the MDEQ ready for the Jan 6" meeting. | will accept any additional comments from you if you’re available to review the plans. We will also be receiving the 90% plans for each pump station next Monday — Dec 23". | will review those plans on the Dec 30" and/or Jan 2". Michael Prysby, P.E. District Engineer Office of Drinking Water and Municipal Assistance 517 290-8817 xxxEND_PAGE:deq11_b397_1838_1838_1

DEQ-See the proposed schedule change with plan delivery as well. I am fine with the revised to allow you to review plans, in a timely manner, and then we meet at GCDC on Jan 6th at 10:00AM to review both PS'S, a pipeline and an update on KWA/GCDC, Flint City and status of DWSD. Wishing you all a Merry Christmas and Happy New Year. Go State. Any questions let me know. John O' John, A little change in plans. The alignment for $.4002, $.4003, S.4005 and $.4006 will be moving to the greenbelt. Therefore the 60% plans for this work will not be ready to share with MDEQ as scheduled. Below is what we believe the MDEQ will receive and when. Look this over and if you have any questions, give either Matt or | a call. 16. WaveTam Larry A. Osborn, PE, Professional Engineer 555 S. Saginaw Street, Suite 201, Flint, Michigan 48802 Sent: Tuesday, December 03, 2013 3:47 PM

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°.