F Flint Water Crisis Public Archive

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Liane Shekter Smith Mike Prysby Richard Benzie

ATTORNEY-CLIENT PRIVILEGE WORK PRODUCT: Draft paragraph - needs review and

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additional data. Importance: High The Flint River — is it a safe source of drinking water? In Michigan, we are fortunate to have high quality drinking water sources. Seventy percent of Michigan’s population receives its drinking water from surface water sources, most with intakes in the Great Lakes. A handful of public water supplies in Michigan do treat water from inland sources such as rivers or groundwater under the influence of surface water. All surface water or groundwater under the influence of surface water requires significant treatment in order to be safe for consumption. Treatment of surface water is referred to under the SDWA as “complete treatment”. While all surface water sources must receive this higher level of treatment, river sources present a greater challenge than water withdrawn from one of the Great Lakes. Under most circumstances, rivers are prone to greater fluctuations in temperature, have higher amounts of organic material, greater turbidity (suspended solids), and more microbiological and viral contamination than Lakes Huron, Erie, Michigan or Superior. It should be noted, that while the water chemistry in the Flint River differs from that in Lake Huron, it can still be treated in accordance with the SDWA and Act 399. Many cities across the country rely on similar sources for drinking water. Also, it is not the source water that reacts with the homeowners plumbing out in the distribution system, but rather the finished water quality that is important. To begin with, neither the Flint River nor the treated water leaving the City of Flint’s water treatment plant contains lead. In addition, the treatment process employed by the City of Flint includes lime softening to reduce the hardness in the river water. Lime softening is not a process that would typically be thought to increase corrosivity of water. The City of Flint, however, does practice recarbonation to adjust pH at the end of the treatment process. pH levels of finished water leaving the City of Flint’s water treatment plant averaged 7.7. Water monitoring conducted quarterly at 25 sample sites located throughout the distribution system showed the following: July — September 2014 average pH = 7.71 range: 7.56 — 7.86 October — December 2014 average pH = 7.88 range: 7.62 —8.10 January — March 2015 average pH = 7.81 range: 7.60 — 7.99 April —June 2015 average pH = ??? range: ??? These numbers compare to the water delivered by DWSD. NEED TO INSERT HERE. xxxEND_PAGE:deq21_b219_0712_0712_1

DCDS coding for Flint

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Importance: High We have shifted gears on tracking time for Flint. Since some of the time is not recorded with hours (ie those who cannot record more than 80 hours in a pay period or are earning comp time), in order to capture it all, we are now going to use an Activity Code in DCDS instead of a project number. Below is guidance on how to do this in DCDS. Let me know if you have problems and I can walk you through it. We will still use a project number for all travel or other non-payroll costs. If I have missed anyone in this email, please forward on. Payroll is not certified so there is time to make changes as needed for this pay period. Thanks Kathy Tetzlaff Department Of Environmental Quality Resource Management Group Administration Section Chief for Office of Drinking Water & Municipal Assistance Office of Waste Management & Radiological Protection Office of Oil, Gas, & Minerals (517) 284-6500 Jeni RMG Sharepoint xxxEND_PAGE:deq04_b141_3323_3324_1 Act Cd Description FDWP Flint Drinking Water — No Pay Entering an Activity Code in DCDS The activity tab is accessed through the regular screen where employees enter their time. The path is as follows: Functions > Employee Data Collection. Right next to the TIME tab is an ACTIVITY tab. In the “Activity” tab complete the following steps: 1) Ensure that a check mark is selected for “No CB” which stands for No Coding Block. 2) Inthe drop down menu for “Activity” select code “FDWP” identified as Flint Drinking Water — No Pay. 3) Enter the appropriate time per day, for the two weeks in the pay period, where work was completed on the Flint Drinking Water project. 4) Select “Save” to save all information entered. xxxEND_PAGE:deq04_b141_3323_3324_2

RE: Project Number for City of Flint Drinking Water

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Here's my best guess fram a review of my calendar and my emails. e August 10-— 7 hour August 12 -~ 2 hours August 14 — 7 hour August 17 ~ 7 hour August 24 ~ 2 hours Asigust 28 ~ 2 hours August 31 ~ 4 hours Senternber 2 ~— 2 hours September 2 ~- | hour Genmtermber 4 ~~ ¢ hour Senternber 8 ~ 2 hours Sentermber 9 - 2 hours Senternber 10 ~— 5 hours Senternber 11-4 hours Senterber 15-3 hours Senternber 16 ~ 4 hours September 17 ~ 4 hours September 16— 7 hour Septernber 21-5 hours September 22 ~ 4 hours Septernber 23 ~ 4 hours September 24-9 hours September 25 —3 hours ® &® @ © © @ © © © © © & © © & © & SF 8 FB Total before last pay period: 64 hours

FW: TAC Team Summary 10_7_15

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Attached is VA Tech’s ppt discussion of the corrasion concerns in Flint and the comparison to Detroit water regarding corrosion. It would be more helpful to see the methodology of the study, actual data, and how samples were collected. Michael Prysby, P.E. District Engineer Office of Drinking Water and Municipal Assistance S17 290-8817

FW: Project Number for City of Flint Drinking Water

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Importance: High E wasn't sure whe all will need this so please forward as oppropriate. The department weuld like to capture our costs releted to the Flint situation. The below project number has been established. You ean use This with any account ceding The? you would normally be using for DCDS or travel expenses. As Eunderstand 4, we alse want to go back and camture ag much ag we can prior to This date, Tf you would process payroll corrections to acd this praject number, that would be helpful. Tf there is trevel, let us know so we con carrect We cari aise de the DCDS corrections far you Hf you pravide the dates and hours that should be charged, xxxEND_PAGE:deq16_b5_0892_4900_0005 With year-enc, the gooner the betrer. Thanks

Calhoun County Good to Grow School Program

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Date: Monday, October 05, 2015 2:22:45 PM The Good to Grow pilot program, funded by the W.K. Kellogg Foundation, was a partnership between the United States Environmental Protection Agency (EPA) and the Calhoun County Public Health Department (CCPHD) that had funding provided by the W.K. Kellogg Foundation for lead monitoring of potable water in schools and childcare facilities that are on municipal water. It is loosely based on the EPA’s 37s for Reducing Lead in Drinking Water in Schools. \n addition to the water sampling, the project was designed to also develop tools to identify and remediate identified lead hazards found in schools and childcare facilities. The lead sampling protocol for determining compliance of community public water supplies has a focus of identifying system-wide lead issues rather than issues in individual buildings. The Lead Copper Rule for public water systems has a lead action level of 15 ppb using 1 liter samples collected at high-risk residences. The action level of 15 ppb can be viewed as a trigger for treatment rather than an exposure level. On the other hand, the lead sampling protocol for schools and childcare facilities used in this study focused on pinpointing lead issues in specific fixtures. It recommends outlets with lead results over 20 ppb be taken out of service or go through remediation. The following link takes you to a summary of the “Good to Grow” program on the Calhoun County website. This website has other links including EPA’s “3Ts for Reducing Lead in Drinking Water in Schools” and “Drinking Water Best Management Practices — For Schools and Child Care Facilities Served by Municipal Water Systems.” There is also a link to AWWA’s “Assisting Schools and Child Care Facilities in Addressing Lead in Drinking Water” that | believe already has a lot of information that Pat and Mike may be able to incorporate into a strategy for other schools facing questions about lead exposure. | believe this pilot concluded earlier this year. | will be contacting Calhoun County to see if some additional information may be available. xxxEND_PAGE:deq04_b034_1886_1886_1

RE: june 24 memorandum

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Sorry this reply is so long. | dicin’t pian to de so, but | wanted to provide you with same information in case you feel the need to reply in part today. Brad, Mike Prysby is on annual leave for a counle of weeks, Steve Busch was in his Jackson office today and probably on his way home new, Liane tock this afterncon off to attend to personal business in Marshall, and Pat Cook is gone for the day. Do you need an answer today? Since this memo is based on the unofficial draft report, do we want to comment? We should probably meet to discuss before anyone responds. AS you know, we have agreed to disagree with EPA on a couple of the issues raised by this meme covering an unofficial EPA report. To begin, when the lead and copper rules (LOR) were first implemented, large oysterns were allowed to collect two sets of lead and copper samples in consecutive 6 month monitoring periods and if their 90" percentile lead level was within & milligrams per iter of the lead level in their source water, they did nat have to further “optirnize’ corrosion control treatment Vhen Flint changed water sources from the Great Lakes to an Inland river and employed water treaiment that was significantly different (orecipitative soffening vs. direct filtration} than that supplied by Detroit, we granted Flint as @ “new supply’ ihe same consideration to determine # their treatment already provided optimal corrosion control AS you know, their first @ month monitoring resulis complied with the Action Level for lead and were clase to demonstrating optimal corrosion control treaiment (OCCT), Since the city would be averaging resulfs from the two consecutive monitoring periods for the purnoses of OCCT determination, we awaited thelr second set of results fo see what they would reveal. After getting the second sei, it was determined that Flint was again in compliance with the iead and copper Action Level but they did net qualify as already practicing OCCT, Under the original requiatory schedule for implementing OCCT, a community serving more than 50,000 pecple was given a year to conduct treatment studies and submit them to DEQ. We then have 6 rnanths to review thelr stucies and designate thelr OCCT. They then have 2 years to install that treatment. During all that time, no monitoring is required, Our response to the concerns raised in thai memo bul siso more significantly, in formal discussions with Region & EPA Managers, was fo encourage Flint to not take the time we believe they were entitied to have for this process but to rave 2s quickly as possible to implement sarne OCCT. Second, we cantinue fo disagree with EPA on sampling protocols. We have attempted to ensure compllance with EPA guidance (| believe it was provided in the preamble to their lead and copper regulations} that said that household use should be “typical” for a rasicential customer on the day before sarnple collection for lead and copper. Early in the implementation of the LCR, we had encountered too many situations where compliance samples had been collected from kitchen and bethroom taps that had not been used in days and in SOMG CASES, even weeks, resulting in excessively stagnated water and correspondingly high lead levels that did not represent typical exposure expected afler overnight stagnation. Further complicating this issue was the media spectacie thet was arising over EPA's direct implemeniation of the LCR in Washington, D.C, where lead results were not always being included in compliance calculations and subsequenily, invalidation 1 xxxEND_PAGE:deq14_b0416_1610_1611_1 of samples was becorning more difficult. in order to avoid thet coriplicated process, we devised our currerit recornmendations for ensuring appropriate but net excessive stagnation for LCR monitoring. We continue to believe itis appropriate fo flush these taps the day before sample collection to simulate and/or ensure typical household use before ine tap is allowed to sit overnight to achieve the expected stagnation time the regulation stioulates (~8 hours} prior to collecting the first draw sample. The LCR does not say the result should represent the “absolute worst case” condition ~ it taiks about sampling the highest risk locations dead plurnbing, lead service lines, high lead content scider piping, etc.) after overnight stagnation and then collecting a first draw sample so as nol to flush elevaled lead from thal tap al that point in time. Unt EPA changes this rule, we are satisfied with our sampling protocol. larn leaving now, so you can use this information as you see fit, or walt until tornorrow fo discuss with Steve, Liane, Pat encime. We have an all-day ODWMA managers meeting starting at 9 AM Thursday, although Liane is also attending a meeting first thing In the morning with Jim Sygo, Bob Wagner and Jon Aden. Richard

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