STATE OF MICHTGAN a DEPARTMENT OF ENVIRONMENTAL QUALITY Sale LANSING DISTRICT OFFICE DAN WYANT RICK SNYDER aRECTOR ‘GOVERNOR August 17, 2015 Mr. Brent Wright City of Flint - DPW Flint Water Plant 4500 North Dort Highway Flint, Michigan 48505 Dear Mr. Wright: Flint, City of WSSN: 02310 SUBJECT: Lead and Copper Monitoring of Drinking Water Taps The Department of Environmental Quality (DEQ), Office of Drinking Water and Municipal Assistance (ODWMA), received your report for the monitoring period January 1, 2015, through June 30, 2015. Resulls ils monitoring period Action Levels. Doth] FofSamples Above | #ofSamples | #of Samples Percentile Action Level Required Collected Tead 15 parts per bition (pb) 14 ppb 6 so 69 ‘Copper 1.3 parts par milion (ppm) _ mala : boa 8 Ninety percent or more of the sites you tested are within action fevels under the administrative rules promulgated under the Michigan Safe Drinking Water Act, 1976 PA 399, as amended (Act 399). These results must be reported on your 2015 Consumer Confidence Report (CCR) due to our office, your customers, and the local health department, by July 1, 2016. Also include the following statement in the CCR, regardiess of the lead and copper levels: If present, elevated levels of lead can cause serious health problems, especially for pregnant women and young children. Lead in drinking water is primarily from materials land components associated with sorvice lines and home plumbing. The City of Flint is rosponsible for providing high quality drinking water, but cannot control the variety of materials used in plumbing components, When your water has been sitting for several hours, you can minimize the potential for lead exposure by flushing your tap for 30 seconds to 2 minutes before using water for drinking or cooking. if you are concerned ‘about lead in your water, you may wish to have your water tested. Information on lead in drinking water, testing methods, and steps you can take to minimize exposure is available from the Safe Drinking Water Hotline at 1-600-426-4791 or at hittp://www.water.epa.gov/drinkdinfolead. “CONSTITUTION HALL +825 WEST ALLEGAN STREET *P.0, BOX 90242 * LANSING, MICHIGAN 48800-7742 ‘ww mietigan gowteg (517) 95-8010 |Mr, Brent Wright 2 August 17, 2015 Recent changes to the Lead and Copper Rule (LCR) require the water supply 10 provide vidual lead tap results to people who receive water from sites that were ‘sampled, even if ad wae not detected, within 20 days of learning of results. You must also send vs & te at gn that you mot al the delivery requirements along with a sample copy of You Castomer notice by three months after the end of the monitoring period. To download the Lead fand Copper Report and Consumer Notice of Lead Result Certificate Microsoft Word or PDF format, visit hitp-iwww michigan govldeq, Click on Water, Drinking Water, ‘Community Water ‘Supply, and Reporting Forms under the Manuals, Forms and Brochures, heading. Water supplies that fll to distribute the Consumer Notice of Lead Results ‘must include the following Seitoment in their CCR, “During the year, we falled to provide lead results to persons served at the sites that were tested as required by the Lead and Copper Rule.” While the City’s LR compliance monitoring has continued to meet action level requirements, seer atco requires all large systems (those serving over 50,000 people) to optimize ane Oslon control regardless of thelr 90th percentile lead concentration. One way to SRinonstrate fully optimized corrosion control treatment is through two consecttive ‘six month conde of LCR compliance moritoring in which the difference between the oth percentile level TM the highest source water lead concentration is less than the Practical ‘Quantitative Level for ibaa (0.008 miligrams per liter). Since the City did not meet these criteria it ‘both the July — December 2014, and January — June 2018, sampling periods, the City must now, recommend a Peer to fully optimize corrosion control treatment within six months in accordance with requirements under Act 399, Administrative Rule 604f (R 325.10604), This recommendation aust be provided to our office as soon.as possible, but no later than January 4, 2016. However, given the past use of phosphate treatment by the Detroit Water and Sewerage Department (DWSD) to fully optimize corrosion control treatment when the City was a wholesale buctomer of DWSD, the ODWMA recommends the City soloct this as its recommended {aiment option, and begin implementation as soon as possible to address ongoing ConParTs by customers regarding lead levels within their premise plumbing systems Under the second slep of this Rule, the DEQ can specify optimal corrosion control treatment, ur ofice wil inform you when monitoring needs to be conducted as pat of the optimization of the implemented corrosion control treatment. Customer requested samples for lead shall continue to be collected and analyzed. Please ‘make every attempt to sele the same sites catia the previous monitoring period, giving Tier 1 sites frst prionty, Woriginal sites are unavailable, select replacement sites based on the Tier 1, 2, and 3 criteria. Please contact me at 517-284-6644 or rosenthala@michigan.gov at your earliest convenience fo discuss how the City will be complying with the above requirements. Sincerely, Za se fs teal Adam Ro: thal, Environmental Quality ‘Analyst Lansing District Office Office of Drinking Water and Municipal Assistance cc: Mr. Michael Glasgow, City of FlintRennaker, Joanne (DEQ) From: prysby, Mike (DEQ) Sent: ‘Thursday, September 03, 2015 9:05 AM To: Benzie, Richard (DEQ) Ce: Shekter Smith, Liane (DEQ); Busch, ‘Stephen (DEQ) ‘Subject: RE: Flint Meeting Richard, | spoke this morning with Mike Glasgow (Utility Administrator) and Brent Wight (WTP Supt) to see what came out of their meeting with LAN and the city. The meeting's main focus was over the lawsuit and financial issues; however, corrosion control treatment was also discussed. City administration told Mike and Brent that there will be no funding restrictions to install corrosion control. The capital cost to install treatment (P04 feed system) is not expected to be high since the WTP has existing feed lines and equip in place; however, new properly sized pumps will be needed. Mike expects LAN to have a proposal for us to review and approve for issuance of an Act 399 construction permit within the next one to ‘two months. Michael Prysby, P.E. District Engineer Office of Drinking Water and Municipal Assistance 517 290-8817 From: Benzie, Richard (DEQ) fednesday, September 02, 2015 5:13 PM Prysby, Mike (DEQ) shekter Smith, Liane (DEQ); Busch, Stephen (DEQ) Subject: FW: Flint Meeting Do we know how this meeting concluded? From: Poy, Thomas {mailto:poy.thomas@epa,cov] Sent: Wednesday, September 02, 2015 4:23 PM Tor Shekter Smith, Liane (DEQ); Benzie, Richard (DEQ) Subject: Flint Meeting Liane/Richare! How did Flint’s meeting with their consultant go? Did they decide to implement treatment? Tom ES eee eee Tom Poy Chief, Ground Water and Drinking Water Branch USEPA - Region 5 (312) 886-5991Rennaker, Joanne (DEQ) From: Prysby, Mike (0&Q) Sent: “Thursday, September 03, 2015 1:22 PM To: Bonvie, Richard (DEQ); Shekter Smith, Liane (OEQ); Busch, Stephen (DEQ) Subject: FW: Flint Water Below is a note from Howard Croft to our TAC team concerning the return to compliance for TTHMs. Howard also briefly discusses the lead issue and the city’s plans to install optimal corrosion control. Michael Prysby, P.E. District Engineer Office of Drinking Water and Municipal Assistance 517 290-8817 Fronis Howard Croft (mailtorhcroft@citvint.cort] Sent: Thursday, September 03, 2015 12:28 PM To: Brent Wright; Dayne Walling; ‘donna. cole; Gerald (Jed) Natzke; Gerald Ambrose; Howard Croft; James Henry; Jason Lorenz; jmikewright; JoAnne Herman; ‘John O'Brien; Kirk Smith; larry. koehier@mec.edu; Laura Sullivan; Michael Glasgow; Michael Wright; Mike Lane; Prysby, Mike (DEQ); Natasha Henderson; ‘Norb Birchmeier; Pete Levine; Robert Bincsik; ‘tos isy,edu; Russell Hudson; Samir Matta; Warren Green: Subject: Flint Water Technical Advisory Team, 1 am pleased to report that the City of Flint has officially retumed to compliance with the Michigan Safe Drinking Water Act and we have received confirming documentation from the DEQ today. The GAC filtering ‘was installed on time and was instrumental in our ability to maintain an average evel under the MCL. We “anticipate that we wil have no further notices going out. Recent testing has raised questions regarding the amount of lead that is being found in the water and I wanted to report to you our current status. [xt the onset of our plant design, optimization for lead was addressed and discussed with the engineering firm ae ith the DEQ. It was determined that having more data was advisable prior 0 the commitment of a specific Gptimization method. Most chemicals used inthis process are Phosphate based and phosphate can be “food” doesmoteta, We have performed over onc hundred and sixty Jed fests throughout the city since switching over to the Flint River and remain within the EPA standards. ‘We ate curently designing an optimization plan with the engineering firm that vill be presented to the DEQ and upon approval we expect to have it implemented by Janusty 2016. 1 is worthwhile to note that the DEQ has reported that other cities have taken years to complete an optimization plan and we anticipate having a plan in place over the next four months, 4It is also worth noting to this group that there are different Jead testing methods used within industry and the city remains consistent with the most recent EPA approved testing method which can produce different results than other methods. We hope to schedule anothet TAC team meeting for late September or early October I will attempt to keep everyone informed and 100k for the best dates. We are inviting additional EPA experts to become a part of this committee, ‘Thank you, Howard Croft Public Works Director City of Flint 1101 8, Saginaw Street Flint, MI 48502 PH 810.766.7135 Ext.2043 herof@cityofflint.comRennaker, Joanne (DEQ) zi From: Shekter Smith, Liane (DEQ) Sent: Monday, August 03, 2015 3:34 PM To: Cook, Pat (DEQ); Busch, Stephen (DEQ) Subject: FW: FOR REVIEW: MDEQ - Flint Call Notes Attachments: MDEQ Call on July 21call notes v4.docx Just réceived the attached. Haven't reviewed it yet. From: Hyde, Tinka [malito:hyd Sent: Monday, August 03, 2015 3:31 PM To: Shekter Smith, Liane (DEQ) Ce: Poy, Thomas; Bair, Rita ‘Subject: FOR REVIEW: MDEQ - Flint Call Notes ti ane — Attached are our notes from our call on 7/21 regarding Flint Drinking Water System. Please take a jook and let me know if you have any questions or comments. ThanksNotes on Call with MDEQ on July 21, 2015 DEQ Implementation of LCR Rule and Flint Issues Issue ft: Is there a public health concern regarding lead in Flint or other regulatory requirements? The 90" percentile resuits of the 2" round of monitoring was 12 ppb. ‘The population has dropped to under 100,000 and therefore the 1° round of month monitoring was done for 100 samples, but the 2™ round only needed 60 samples. Customer-requested samples were included, but MDEQ did notthave specifics on how many there were, aa raed about the timeline for Flint to swith overt tha Huron water source, MDEQ said the pipeline is under construction and scheduled to be coogi LY 2016. MDEQ expects some delays and thinks a more realistic timeframe is October 20, : MDEQ explained that Flint would have 18 monthsifaseomplete the wefZesion control study and the complicating factor of switching over to Lake, Should the corrosiaizcontrol study be based on the take Huron source? MDEQ.also explained thatiance Flint is using Lake Hureiyater that they would corrosion control treatment was needed. = Se ing them they aig to complete a corrosion contro study = based on results they are not optim nthe timing Réempleting a corrosion control study and the anticipated switch to Lake Huron Waler, jill have diselissions with Flint and request that they start corrosion control.tceatment as sootas possibles is. MDEQasked for eee thesfegulations allow to be waived if MBEGrhas Hint Sait pH adjustmghsnd adding:Bhosphates. Region 5 will look into this and get back to MDEGEBjth an anser. All ckr@liledged that flit Initiated corrosion control treatment and continuedatb-evaltal systern toiensure optimization that these efforts would ERR 2 con ~_—! jut fooking strvent more comprehensively to ensure problems -SDEQ statetizhat Flint ison the brink of DBP compliance and that ce last year. Any adjustments for corrosion control treatment 8 her issu@siveren’t exacerbated. Region 5 agall = of ORD staff, Darren Lytie and Mike Schock which MEQ said they Issue #2: Discuss optimal corrosion control requirements Discussion Items: MEQ.explained that they did not treat the switch to Flint River water as a "new system’, but as a new Source. ttis their understanding that 2 rounds of 6-month monitoring is still needed to characterize the water quality. They don’t know what is optimized until those 2 rounds of 6-month monitoring are completed.Issue #3: Discuss Pre-flus hegion 5 noted that under 142.81(6)(3(i) that any system that has been deemed optimized must notify the State of any long-term change in treatment or the addition of a new source. The State must review and approve the change and may require any such system to conduct adelitional monitoring Or other sation to ensure that the system maintains minimal levels of corrosion inthe distribution system. The State's requirement for 2 additional rounds of 6-month monitoring would fall under the “additional monitoring” prescribed by the State and not the initial 2 rounds of 6-month monitoring for new systems Region 5 explained that they have talked to HO about the interpretation of regulations and believes that systems that have been deemed optimized need to “maintain” corrosion control. The Region agreed to provide supporting regulatory citations for the language about maintaining corrosion control, Ed Moriarty in OGWOW is also consulting OGC on this topic and th#9SC opinion wil also be shared. MDEQ mentioned that there are other communities that jgave the Detroit system or connect to the new Lake Huron pipeline, but many of those either don‘tebete.treat for corrosion control or will be building new treatment plants. Requirements for maging cakfasion control for addtional ‘communities connecting to the Lake Huron pipeligig-will be discussed:further after receipt of the HQ/OGC opinion. Lead compliance sampling procedUagialistate of Michigan comply with Federal SDWA requirements wich calls for @ minimipief agus during wiigh,there is no water used from the tap the sample is taken from. = = = = MEGS not interest sng ts pollan on ang uriipew regultins come ou. They also pointed out sh the pre-Teghing instrucianfate not feauitgments, bt suggestions ‘The Michigan pre-fi@@hing instrusilons were devgfoped as a way to ensure that sampled faucets were the targeted 6 hour (i.e., rarely used faucets or MDEG wil Seid. a letter to Flintregerding the 2 rounds of 6-month monitoring results that exceed § ppb and the néGafor a corcosia control study. They will have discussions with Fit to request ‘that ‘ontrol tZatment as soon as possible rather than walting for the completion ofa ny study that can take MADEQ and the Region Wain agreement that it is important to get phosphate addition going In Flint ‘as soon as possible, MDEQ mentioned tapping Mike Shock for help with this n th Region 5 commented that we now have a path forward for Flint despite 2 difference of opinion on whether the regulations required Flint to “maintain” corrosion control treatment when they started serving treated water from the Flint River. MMDEQ and Region 5 agreed that after Flint implements corrosion control treatment, when they switch pack to take Huron water, they will need to continue the corrosion control treatment while ‘conducting monitoring to determine this treatment Is optimized with the new Lake Huron water quality.Region 5 will et back to MDEQ once it gets H0/OGC's opinion on the need to “maintain” corrosion control treatment once a system is deemed optimized. MME and Region 5 agreed that other communities currently implementing corrosion control roatment and change sources wll need to continue to provide corrosion control treatment and conduct monitoring to determine whether the treatment is optimized with the new source water quality. Region 5 will research ccT study. and get back to MDEQ on the 144.81 {3)(b)(5) citation and the ability to waiveRennaker, Joanne (DEQ) From: Busch, Stephen (DEQ) Sent: Monday, August 10, 2015 2:17 PM To! Shekter Smith, Liane (DEQ) Cc: Benzie, Richard (DEQ) Subject: RE: Flint, | called Tom Poy and left a voicemall stephen Busch, PE MDEQ Lansing District Coordinator arp Drinking Water and Municipal Assistance Lansing and Jackson District Supervisor 517-643-2314 bbuschs@michigan.gov Original Message: From: Shekter Smith, Liane (DEQ) Sent: Monday, August 10, 2015 10:53 AM To: Busch, Stephen (DEQ) Ce: Benzie, Richard (DEQ) Subject: RE: Flint Steve - can you provide a response/update for EPA? {also have a voicemail message from Tom asking basically the same questions. Original Message~ From: Poy, Thomas [mailto:poy.thomas@epa.tov] Sent: Monday, August 10, 2015 8:05 AM ‘or shekter Smith, Liane (DEQ); Benzie, Richard (DEQ); Busch, Stephen (080) Ce: Crooks, Jennifer Subject: Flint Liane: Any news on Flint since our calla couple of weeks ago? Has the letter been sent to inform them that they are not optifnized for lead based on their monitoring? Have they been approached about starting corrosion contro! sooner rather than later? Tom SEA EPEeLeeeneeeeCe tte Tom Poy Chief, Ground and Drinking Water Branch USEPA Region 5 (312) 886-5991Rennaker, Joanne (DEQ) Fror Shekter Smith, Liane (DEQ) Sent: Tuesday, August 25, 2015 1:56 PM To: Iwalters313@gmailcom ce: Busch, Stephen (DEQ); Devereaux, Tracy Jo (DEQ) Subject: Follow Up from our Aug. 4th meeting Dear Ms. Walters, | wanted to update you regarding our Department's findings related to questions raised! during our meeting at the Governor's office on August 4. | apologize for the delay in getting back to you. Lead and Copper Monitoring regarding Flint lead and copper compliance monitoring forthe January = June 2025 period, he City has confirmed that aiteed and copper samples collected throughout the City, whether routine sites or customer request sent to the aeaeeof michigan lab for analysis. Individual sample results ae provided to the property owner within 20 days of receiving the lab results in accordance with the Michigan Safe Drinking Water Act (Public Act 399, 1976 Administrative Rule 10(5). Results from the State of Michigan lab are provided directly to our Office staff ave confirmed that the lead 90® percentile compliance calculation of 13 parts per bilion is based on 69 samples that met the appropriate sampling location ste criteria, and met the sample collection site and collection protocol requirements ofthe Safe Drinking Water Act for this monitoring period A minimure of 60 samples were required for aeaaritering period. As indicated during the meeting, the City’s sampling for lead complies with the Acted Level aoe ried of 15 parts per billion, but based on the population served by the City and these results, the Clty willed to sas recommendation to the MDEQon how they wil fully optimize thelr corrosion control treatment. These next steps continue to follow the requirements of the Lead and Copper Rule. samples collected at your residence of 212 Browning Avenue were not included this compliance determination as you aarrnts hole home fiter, As stated inthe Michigan Safe Drinking Water Act (Public Act 399, 2976 Administrative Rule ioe, Lead and Copper in tap water, monitoring requirements) “Sampling stes may not include faucets that have point ance or point of entry treatment devices designed ta rereve inorganic contaminants.” Such treatment alters the oie chemintyy and water quality such that itis no longer representative of public water from the CVs distribution Sater, Therefore, the City cannot use samples collected at your residence as part of is determination for public water system compliance with the lead or copper action level standard. Sample Summary (samples taken at your residence) For your information, we are providing the information that we've gathered regarding samples collected at your home, Ourrecords indicate between February and June of this year there were six samples collected by either you or ar Mike Glasgow with the City of Flint, and submitted to the State Laboratory for analysis as follows: February 11, Bathroom tap, collected at 10:20 AM by Mike Glasgow. This sample was analyzed for aesthetic metals (copper, iron, manganese, and zinc) which does not include lead analysis. February 28, Kitchen tap, collected at 7:15 AM by you. This sample was analyzed for lead (104 parts per billion) and copper (non-detect).ebruary 25, Kitchen tap, collected at 10:26 AM by Mike Glasgow. This sample was analyzed for metals including jead. All results (including lead) were non-detect except for Barium 0.01 parts per million. The result for Barium wes well below its maximum contaminant level of 2 parts per milion. March 3, Kitchen tap, collected at 6:00 AM by you. This sample was analyzed for lead (397 parts per billion) and copper {non-detect). March 48, Kitchen tap, collected at 11:10 AM by Mike Glasgow. This sample was analyzed for lead (4 parts per billion) and copper (non-detect). April 2, Pre-point of service, collected at 8:00 AM by you. This sample was analyzed for lead (707 parts per billion) and copper (110 parts per bition). Lead Education/Outreach ‘As we discussed during the meeting, we support efforts to educate homeqwns!S about the sources of lead in their private residence, provide guidance measures to reduce the potential for lead exposure, and provide information on resources for lead abatement, Along those lines, our Office has been in contact ‘with the Department of Health and treman Services, Environmental Health Division, Healthy Homes Section and had some preliminary discussions about a public education and assistance campaign regarding household lead Issues, guidance and abatement, ead monitoring by public water systems serves 2 dual purpose. The first purpose [sto ens Te the public water supply is adequately treating its water to address corrosion potential and help limit lead exposure, The second purpose is to a vroem homeowners about lead levels within their individual residence so that they can make educated choices regarding their own exposure risk. pH Results During the meeting concerns were also expressed regarding pH levels within customet plumbing systems. As you may now, pli has no associated contaminant level as itis simply a numeric scale used to specify the acidity or alkalinity of a aoe ne elty of Flint conducts daly monitoring of pH values on both its raw and finished (treated) water at the City's water treatment plantas part of its operations. The City is also required to conduct water quality parameter Sent: Thursday, September 24, 2015 1:17 PM To: Howard Croft; Brent Wright; Dayne Walling: donna, cole; edwardsm; Gerald (Jed) Nota James Henry Jason Lorenz; mikewright, Anne Herman; John O'Brien Kirk Smith, larry.koehler@mecedu; Laure Sulvan; yte darrin@epa gov: Michael Glasgow Wight Michael: Mike Lane; Prysby, Mike (DEQ) Natasha Henderson; Notb Birchmeier pete Levine; Robert Bincsik;rosejo@msu.edu; Russell Hudson; Samir Matta; Sean Kammer, Warren Green; Busch, Stephen (DEQ) ce {ytle, Darren Subject: RE: Technical Advisory Meeting Howard; ‘Thank you for the meeting invitation. However, | am not available to attend the mest that week. | wish there had Pane citotion wth Dr Lytle and myself about our other commitments and our travel avalabits before scheduling the meeting, | till wll be available to participate overall the advisory process. | noticed also that the email address fr Dr. Lytle appears to have a typographical eror int but you may have spoken to tim on the phone about the meeting. The correct email address is; Iyiledarren@epa.gov. ‘Thank you, again, for the opportunity to participate. Regards, Mike: Michael R. Schock US, Environmental Protection Agency ORD, NRMRL, WSWRD, ‘TTEB 26 West Martin Luther King Drive Gincinnati, OH 45220 Phone: 513-569-7412 schock michael @epa.gov From: Howard Croft [mailto: ‘heroft@citvofflint.com] Sent: Wednesday, September 23, 2015 3:52 PM To: Brent Wright; Dayne Walling; ‘donna, cole; edwardsm; Gerald (Jed) Natzke; Howard Croft; James Henry; Jason Lorenz; jmikewright; JoAnne Herman; John O'Brien; Kick Smith; larry. koehler@mec.edu; Laura Sullivan; i lytle.darrin@epa.gov; Michael Glasgow; Wright, Michael; Mike Lane; Mike Prysby (DEQ); Natasha Henderson; Norb Birchmeier; Pete Levine; Robert Bincsik; rosejo@msu.edu; Russell Hudson; Samir Matta; Schock, Michael; Sean Kammer; Warren Green; Busch, Stephen (DEQ) Subject: Technical Advisory Meeting ‘Technical Advisory Team,+ am waiting to inform everyone that we have scheduled the next Technica! Advisory Committee meeting to be ‘Warhesday Cotober 72015 from 2:00 — 4:30 pm. We are extending invitation’ Mare Edwards of Virginia ‘Teoh along with two lead experts ffom the BPA (Datten Lytle & Michae! Schock) to become a part of the trhnfeal team and we are hopeful that they wil all be present atthe upcoming meeting, ‘At the meeting we will discuss an overview of the City water system, compliance with the Safe Drinking Water ‘Ket lead eoncems, corrosion control, water testing, public education, capital improvement plans, the KWA pipeline, and next steps. { will forward a specific location and agenda in the near future but we are firmly committing to the time and date, As with previous meetings we look forward to this group having positive dialogue that will benefit the community. “Thank you, Howard Croft Public Works Director City of Flint 1101 S. Saginaw Street Flint, MI 48502 PH 810.766.7135 Bxt.2043 herof u@eityofflint. com,Rennaker, Joanne (DEQ) From: Rosenthal, Adam (DEQ) Sent: Thursday, April 30, 2015 2:14 PM To: Cook, Pat (DEQ) ce: Busch, Stephen (DEQ) Subject: RE: Flint Corrosion Control? ‘According to the lab report, itis 0.001 mg/t. From: Cook, Pat (DEQ) Sent: Thursday, April 30, 2015 12:15 PM Tor Rosenthal, Adam (DEQ) Ce: Busch, Stephen (DEQ) ‘Subject: FW: Flint Corrosion Control? LI Adam ~ what is the reporting/detection limit for lead on the CMET2 scan? From: Cook, Pat (DEQ) Sent: Friday, April 24, 2015 12:45 PM To: Deltoral, Miguel ‘Subject: RE: Flint Corrosion Control? ‘Total Lead collected from the plant tap on 8/22/14 was zero. From: Deltoral, Miguel ‘Sent: Friday, April 24, 2015 11:59 AM To: Cook, Pat (DEQ) Ce: Poy, Thomas; Porter, Andrea ‘Subject: Re: Flint Corrosion Control? “What was the source water lead level? Miguel A. De! Tora Regulations Manager U.S. EPA RS GWOWS 77 West Jackson Blvd, (WG-15) Chicago, IL 60608 Phone: (312) 886-5253 From: Cook, Pat (DEQ) ‘sent: Friday, April 24, 2015 10:43 AM To: Deltoral, MiguelCe: Poy, Thomas; Porter, Andrea Subject: RE: Flint Corrosion Control? Hi Miguel - Flint is currently not practicing corrosion control treatment at the WTP. When they started treating a tovat their WTP last spring, we placed them on full chart (100 ‘ites) Pb/Cu monitoring for two consecutive 8 month periods. WO monitoring is also being conducted “The first round of samples after switch-over from BWSD (ly 1, 2014 ~ Dec 31, 2014) had 90th percentiles of 6 ppb for Lead and 110 ppb for Copper. The eucond round of samples (Jan 1, 2016 ~ June 30, 2015) is unde wy with approximately 20 of the 100 sample see sults in, The highest lead result out ofthe 20 receWved thus far is 13 ppb. gased on the matrix of recommended corrosion control study components for Large PWS's for both Lead and Copper, there are no additional requirements for the Oly ‘of Plint based on the levels of lead and copper in the Cope source water and the results of the lead and copper distributer monitoring, The only provision of the rtd & Copper Rule which classifies the existing treatment of far9e PWSs as optimized for corrosion control is ea ihe difference between the 90% Pb-TAP and Pb-POE is less than the lead practical quantitative level (PQL) for each six-month period ofthe intial monitoring progr ‘By definition, the PQL for lead is 0.005 mg/L, ira the lead value for the source water used in this determination the highest source water lead ae ontration, I this condition is met, then no study of testing is required. We believe this condition has been met for Flint, However, we will re-evaluate this after the 2” round of 6 month sampling is completed. if you have any further questions, please contact the Lansing District Supervisor, Steve Busch at (517) 643- 2344 or at buschs@michiaan.gov. Have a good (and hopefully warm) weekend! Patrick Cook, P.E. ‘Community Drinking Water Unit Office of Drinking Water & Municipal Assistance Michigan Department of Environmental Quality Phone: (517) 284-6514 cookp@michigan.cov From: Deltora, Miguel [maito:deltoralmisusl@epa.cov] ‘Sent: Thursday, April 23, 2015 12:33 PM To: Cook, Pat (DEQ) Ce: Poy, Thomas; Porter, Andrea ‘Subject: Flint Corrosion ‘Control? Hi Pat, ‘What's Flint doing now (post Detroit) for corrosion control treatment? Miguel A. Del Toral Regulations Manager Ground Water and Drinking Water Branch 7 West Jackson Bivd (WG-15)} Chicago, IL 60604 Phone: (312) 886-5253Rennaker, Joanne (DEQ) From: Prysby, Mike (OEQ) Sent: Friday, April 24, 2015 11:56 AM Cook, Pat (DEQ) Busch, Stephen (DEQ); Rosenthal, Adam (DEQ) Re: Flint Corrosion Contro!? Pat, Vat are correct, | received call from Miguel regarding his concerns with the renices and how he believes its skewing down the lead level results from s the call and we can discuss in more detail next Tues, . lead/copper sampling procedure from lead jtes with lead services. | briefed Steve on Sent from my iPhone on Apr 24, 2015, at 11:16 AM, Cook, Pat (DEQ) Sent: ‘Thursday, February 26, 2015 5:15 PM To: Prysby, Mike (DEQ) ce: Busch, Stephen (DEQ); Rosenthal, Adam (DEQ); Deltoral, Miguel; Poy, Thomas Subject: HIGH LEAD: FLINT Water testing Results Attachments: Flint lean level results Feb 2015 212 Browning (Pb Cu) pdf ‘Thank you, Mike, These results are dated 2/18/35, 50 they're probably diferent results than the results Adam had, but they still have to be included in with compliance Calculation of the 90" percentile. What dates are the earlier compliance samples? Yes, the stagnation of the water would increase the lead levels, and 'm glad you're following uP with the City to get the toad levels reduced for Mrs. Walters’ home—which will hopefully be effective for her neighbors Because they are also ost likely being exposed to these high lead levels. Miguel reminded me this morning, there are 09 safe levels of lead in drinking water. «talked with Miguel DelToral about his knowledge on research on lead. He sald that high evel of ron, usually bring high levels of lead. The large amount of black sediment at Mrs. Walters’ home, is most ihely particulate lead, Miguel aid, where the lead actually bonds to the iron sediment. While the particulates of lead/iron are small, they're very highly concentrated with lead—up to 95% lead. gue! was wonderin if Fit is feeding Phosphates. Flint must have Optimal Corrosion Contal Treatment—is it Phosphates? Ori it pH/Alkainty Adjustment? The reason he asks, is because systems using the pH/Alkalinity adjustment have problems with ead levels in the 100's or higher—and they have problems with random lead particulate aaoeerrinthe estibution system, Miguel said that we all know that flushing tegularly helps reduce the lead aaa rations, But not immediately, The City can’t just fish in advance of taking the compliance samples, they have to flush the lines on a regular schedule. ‘The problem with high lead issues, i thatthe water has so many different variables, that its hard to pinpoint what is causing what problem where, From a pubic health perspective, can we assume that the high lend fevels in Mrs. Walters’ neighborhood are isolated to just her area? Or are they more widespread? Please feel free to contact Miguel directly—312-886-5253; Deltoral.miguel@epa gov. Jennifer From: Prysby, Mike (DEQ) [mailto:PRYSBYM@michigan.gov] Sent: Thursday, February 26, 2015 10:25 AM ‘To: Crooks, Jennifer Ce: Busch, Stephen (DEQ); Rosenthal, Adam (EQ) Subject: RE: HIGH LEAD: FLINT Water testing Results Jennifer, | recall Adam showing me a high lead/copper sample result (perhaps it was this one)...as part of the city’s routine lead-copper monitoring. If so, it was a stagnated sample as part of the sampling protocol. Adam mentioned that all other samples were below the AL...and the citywill not exceed the lead AL. Iwill confirm this. The city; however, needs to take further ction to help address Ms. Walter's concern. The type of plumbing needs to be identified and sample tap location within the premise plumbing. They should offer to re-sample for PB after flushing the tap to demonstrate that flushing the tap will reduce the lead concentration. The city also needs to provide other lead-reduction strategies to Mrs. Walters. Michael Prysby, P.E- District Engineer Office of Drinking Water and Municipal Assistance 517 290-8817 From: Crooks, Jennifer {mailto:crooks jennifer@ena.gov] Sent: Thursday, February 26, 2015 10:53 AM To: Busch, Stephen (DEQ); Prysby, Mike (DEQ) Cc: Poy, Thomas; Deltoral, Miguel ‘Subject: HIGH LEAD: FLINT Water testing Results Hi, Steve and Mike. Thanks for talking with me yesterday, Steven about the most recent TTHM results, We'll jook forward tevraseiving them whenever you get them back from the lab. However, the main purpose of my emails to alert you to the Fgh lead levels reported to a citizen yesterday by Flint (Water Dept, [have been discussing the water situation with LeeAnn Walters since January, and she has been talking vith Mike Glasgow at the plant about the black sediment in her water {HUGE KUDOs to MIKEII) He dic test it to find want the iron levels were greater than his test would go; GT 3.3. But Decals the iron levels were so high, he suggested testing for lead and copper, WOW!!! Did he Find the LEAD! 208 ‘ppb. She has 2 children under the age of 3. Big worries here. so, Steve, this goes back to what you and | were talking about yesterday, That the different chemistry water Is feaching aoa taminants from the insides ofthe biofilms inside the pipes. | chink ead is a good indication that other contaminants are also present inthe tap water, that obviously were NOt present in the compliance samples taken et the plant, VOC/SOC and inorganies/metals would be good sammoles tart with to take at the tap. And since Ms, Walters! ern water fs showing the high lead levels, her tap water would bea good place to start, | think We also talked about Dr. Joan Rose from Michigan State being on the Flint Tech Advisory Committee—you also ventioned that someone from the Dept of Community Health was on the Committee. I'm thinking that Dr. Rose woulel vrent to dive further Into this, since there's actual evidence that the Water leaching contaminants from the biofilms; or Dept of Community Health would want to get involved and look at this from an epidemiological perspective. (She and her family are also exhibiting the rashes when exposed to the water, ‘and her daughter's hair i falling out in clumps.) Maybe MSU could authorize the payment ofthe analyses for these samples? Or Dept of Community Health? The citizen’s name I LeeAnn Walters 212 Browning Ave lint, Mi 48507 616-212-6233, Lwalters313@gmail.com JenniferFrom: Lea Moste [mailto:iwalters313@zmail.com] Sent: Thursday, February 26, 2015 9:08 AM To: Crooks, Jennifer Subject: Fwd: Re: Water testing Results - - Forwarded message From: "Michael Glasgow" Date: Feb 26, 2015 7:55 AM. ‘Subject: Re: Water testing Results To: "Lea Moste" Ce: Lee, Here are your Lead & Copper Results. ‘This number is very high, 104 ppb of lead, In the last few months over 100 samples have been tested and only 2 were over the 15 ppb regulatory Jimit, and the highest level I have seen i837 ppb. I wll pass this info to Mr, Croft soe is aware, I wil! send the sample I collected from your kitchen fave today for a complete metals test (12 different metals), to see what the level is without letting the water Stapnate over night. Im hoping that value will be much, but we will have fo 5° Sorry for this news, but I wanted to let you know right away. Mike On Tue, Feb 24, 2015 at 1:50 PM, Michael Glasgow wrote: Lee, { will bring a copy of last years annual report when [stop by tomorrow. The annual report from 2014 must be delivered tg residents by Jaly 1st of this year. Timagine we may have it complete by June. | Mike On Fri, Feb 20, 2015 at 1:00 AM, Lea Moste <{walters313@gmail.com> wrote Mike, ‘Thank you forthe water reports and we already planed fo see you on the 25th at 10:00am, I was wondering, iF you know who [need to talk to inthe water plant to obtain the “Annual Drinking Water Report from last | year. According to the EPA website there is ink to access but when you click on it, it cannot be accessed. | Was also curious if there is an expected time frame for this years report due to the switch. Ifyou can be of any | assistance I would appreciate it, ‘Thank You LeeAnne Walters On Thu, Feb 19, 2015 at 12:47 PM, Michael Glasgow wrote: | Lee & Dennis, Here is a list of test results from water sampled at yout home over the last 2 weeks, [have sent in your lead and copper sample, and also a sample from the toilet tank for manganese T should hopefully have results|| stom this esting erly next wee Iiplan on stopping over on Wednesday (the 25th) around 10 am again to | sive you these results & sample again. | MikeRennaker, Joanne (DEQ) Fro Deltoral, Miguel Sent Friday, February 27, 2015 5:59 AM To: Crooks, Jennifer; Prysby, Mike (DEQ) ce: Busch Stephen {0EQ); Rosenthal, Adam (DEQ Poy, Thomas; Schock, Michael Porter, Andrea Subject: Re: HIGH LEAD: FLINT Water testing Results Jen/all - I think things got garbled in translation... What 1 was saying is that where you find Pb values that high itis usually due 9 particulate lead. Not always, put generally. Particulate lead is released sporadically from lead ‘service lines, leaded solder and leaded brass in a number of ways and folks tend to discount these values as anomalies, but particulate lead release is a normal part of the corrosion process and itis universal (common) in all systems It’s just that itis not captured as often by the infrequent LCR sampling. Iesystems ave pre-lashing the tap the night before collecting LCR compliance samples (MDEQ still provides these instructions to public watet systems) this clears particulate lead out of the pltmbing and biases the results Jow by climinating the highest ead values. If systoms are pre-flushing and still Tjnding particulate lead, the amount of particulate lead inthe system can be higher than what is being detected tusing these “pre-lushe? first-dra samples. My point on that was ‘hat people are exposed to the particulate aaa daly basis, but the particulate lead is being flushed away before collesing compliance samples which provides false assurance to residents about the tre lead Levels in the water Some quick notes on particulate lead release: «| Fe/Mn can transport lead from the lead service lines into the home. The lead sorbs on the Fe/Mn paticles, In GW systems, Fe/Min can come fiom the source water and mote Fe from the water mains. In SW systems, the Fe typically is released ftom the water mains «ec celeased from lead service lies can also 'seed’ galvanized iron pipes inside the homes. Again, the eat corbs onto the iron on the pipes and be released sporadically. Generally, the higher the flow, the more Fe and FetPb particulate you will likely get. If there is a partial Jead service ine (lead connected to copper) you can get additional Lead release due to galvanic corrosion. «Pa beesses and solder ean also release particulate lead under certain circumstance. «The particulate ean contain very high concentrations of lead (hundreds to ‘thousands of ppb Pb) which is a higher concentration than lead paint, so even stall particles can result in high lead values. «If the lead serviee line was disturbed (water main repais/replacement, metce installation repair/replacement, service line leak repair, etc.) you can have ‘VERY high lead levels in the seale and 7eErment that is dislodged from the inside of lead service lines. Here in Chicago, during a partial lead sess ine replacement, we collected the scale and sediment that came into the bome and we found 300,000 ug/l. lead in the scale; 125,000 ug/L Pb inthe sediment. Very deneoro «Higher levels of PO4 (3-4 mg/L Ortho) seem to reduce the amount of particulate Pb that is released in tre abtence of physical disturbances tothe ead lines. Doosn't stop it entirely, but should generally rtjuce the occurrence. Caveat ~ Other water quality issues can change the ‘chemical complexes that form Gon the pipe, so cleaner sources with more consistent WQ form more ‘predictable scale complexes.If Tsemember correctly, Detroit is feeding POM forthe LCR, but since Flint js no longey Pat of that Interconnection, T was wondering what their OCCT was. They are required to have OCCT in place which is why Iwas asking what they were using. Mike Schock is our resident expert and may be able to help out with the simultaneous compliance (Pb & DBPs) so I would suggest that folks give him a call, ‘Miguel A. Del Toral Regulations Manager U.S. EPA RS GWDWB: 7 West Jackson Blvd, (WG-15!) Chicago, 60608 Phone: (312) 886-5253, From: Crooks, Jennifer Sent: Thursday, February 26, 2015 04:15 PM To: Prysby, Mike (DEQ) Co: Bueehy Stephen (DEQ); Rosenthal, Adam (DEQ); Deltoral, Miguel; Poy, Thomas Subject: KIGH LEAD: FLINT Water testing Results ‘Thank you, Mike, These results are dated 2/18/15, 50 they're probably different results than the results Adam had, but they still have to be included in with compliance calculation of the ‘20 percentile, What dates are the earlier compliance samples? ‘os, the stagnation of the water would increase the lead levels, and fm glad you're following up with the City to get the read levels reduced for Mrs. Walters’ home—which will hopefully be effective for her neighbors because they are also most likely being exposed to these high lead levels. Miguel reminded me this morning, there are no safe levels of lead in drinking water. + talked with Miguel Del Toral about his knowledge on research on lead. He sald that hh levels of iron, usually bring high levels f lead, The large amount of black sediment at Mis, Walters’ howe most likely particulate lead, Miguel we where the lead actually bonds tothe Iron sediment. While the particulates of lead/iron are small, they're very highly concentrated with lead—up to 95% lead. Miguel was wondering if Flint is feeding Phosphates. Flint must have Optimal Correeieh Control Treatment—Is it Phosphates? Oris it pr/Alkalinity Adjustment? The reason he asks is because systerns Ne the pl/Alkalinity adjustment have problems with lead levels in the 100's or higher—and hey have problems with random lead particulate aca inthe alstribution system, Miguel said that we al know that flushing regularly helps reduce the lead eecentrations, but not immediately. The City cant ust fush in advance of taking the ‘compliance samples, they have to fiush the lines on a regular schedule. ‘The problem with high lead issues, i that the water has so many different variables, that it’s hard to pinpoint what is Causing what problem where. From a public health petspective, can we assume what the high lead levels in Mrs. Walters’ neighborhood are isolated to just her area? Or are they more widespread? please feel free to contact Miguel directly 312-886-5253; Deltoral miguel@epa.gov. Jennifer From: Prysby, Mike (DEQ) [mailto:?PRYSBYM@michigan.gov] Sent: Thursday, February 26, 2025 10:25 AM To: Crooks, JenniferCc: Busch, Stephen (DEQ); Rosenthal, Adam (DEQ) Subject: RE: HIGH (EAD: FLINT Water testing Results Jennifer, | recall Adam showing me a high lead/copper sample result (perhaps it was this one)....as part of the city’s routine lead-copper monitoring. If so, it was a stagnated sample as part of the sampling protocol. Adam mentioned that all other samples were below the AL...and the city will not exceed the lead AL. | will confirm this. The city; however, needs to take further action to help address Ms. Walter's concern. The type of plumbing needs to be identified and sample tap location within the premise plumbing. They should offer to re-sample for PB after flushing the tap to demonstrate that flushing the tap will reduce the lead concentration. The city also needs to provide other lead-reduction strategies to Mrs. Walters. Michael Prysby, P.E- District Engineer Office of Drinking Water and Municipal Assistance 517 290-8817 From Gack Jennie (mato;caotsJennie@ena.o0”) ‘Sent: Thursday, February 26, 2015 10:53 AM To: Busch, Stephen (DEQ); Prysby, Mike (DEQ) Ce: Poy, Thomas; Deltoral, Miguel ‘Subject: HIGH LEAD: FLINT Water testing Results Hi, Steve and Mike, Thanks for talking with me yesterday, Steve, about the most recent TTHM results. We'll look forward to receiving them whenever you get them back from the lab, However, the maln purpose of my emails to alert you tothe high lead levels reported fo a cite yesterday by Fint aeaea tpt have been dlscussing the water situation with LeeAnn Walters since January, an he hes been talking ea eee Giagow at the plant about the back sediment in her water. (HUGE KUDOs to MIKE] He dla it itto find ian the ron levels were greater than his test would go; GT 3.2. But, because the iron levels Wor high, he suggested trating for lead and copper. WOWIII Did he find the LEAD! 108 ppb. She has children under the ag of 3.. Big worries here so, Steve, this goes back to what you and | were talking about yesterday. That che different chemistry water is leaching aos tuminants from the insides of the biofilms inside the pipes. think Lead isa good indloaon that other contaminants are also present inthe tap water, that obviously were not present in the compliance samples taken at the plant. VOC/SOC and inorganics/metals would be good samples to start with to take at the tap. And since Ms, Walters! vrinking water fs showing the high lea levels, her tap water would be a good place start, | think, We also talked about Or. Joan Rose from Michigan State being on the Flint Tech Advisory Committee—you also mentioned that someone from the Dept of Community Health was on the Committee I'm thinking that Dr. Rose would rere e further into this, since there's actual evidence that the water I leaching con ara from the biofilms; oF Dept of Community Health would want to get involved and look at this from a) epidemiological perspective. (She and her family are also exhibiting the rashes when exposed to the water, and her ‘daughter's hair is falling out in clumps.) Maybe MSU could authorize the payment of the analyses for these samples? Or Dept of Community Health? 3‘The citizen’s name Is: LeeAnn Walters 212 Browning Ave Flint, MI 48507 616-212-6233 Lwalters313@gmail.com Jennifer From: Lea Moste [mailto-walters313@gmail.com) hursday, February 26, 2015 9:08 AM rooks, Jennifer ‘Subject: Fwd: Re: Water testing Results Forwarded message - From: "Michael Glasgow" Date: Feb 26, 2015 7:55.AM Subject: Re: Water testing Results To: "Lea Moste" Ce: Lee, Here are your Lead & Copper Results, This number is very high, 104 ppb of lead. In the last few months over 100 samples have been tested and only 2 were over the 15 ppb regulatory limit, and the highest level I have seen is37 ppb. Till pas this ato to Mr. Croft so he is aware. Twill send the sample collected from your kitchen ‘ances today for a complete metals test (12 different metals), t0 see what the level is without letting the water stagnate over night. I'm hoping that value will be much, but we wil have fo see, Sorry for this news, but I wanted to let you know right away. Mike On Tue, Feb 24, 2015 at 1:50 PM, Michael Glasgow wrote: Lee, { will bringa copy of last years annual report when T stop by tomorow. The annnal report from 2014 must be delivered to residents by July Ist ofthis year. T imagine we may have it complete by Tune Mike Oia Fri, Feb 20, 2015 at 1:00 AM, Lea Moste wrote: | Mike, | ‘Thank you for the water reports and we lready planned fo see you on the 25th at 10;00am. I was wondering | ifyou know who I need to talc to in the water plant to obtain the Annual Drinking ‘Water Report from last year, According o the EPA website there is link to aesess but when you chi of Ns it cannot be accessed year do curious if there is an expected time frame for this years report due tothe switeh, I you can be of any assistance I would appreciate it. ‘Thank You LeeAnne Walters‘On Thu, Feb 19, 2015 at 12:47 PM, Michael Glasgow wrote: Lee & Dennis, from water sampled at your home over the last 2. weeks. I have sent in your lead oa sample from the toilet tank for manganese. T should hopefully have results Here is a list of test results ‘Wednesday (the 25th) around 10 am again to and copper sample, and als‘ rom this testing early next week. I'l plan on stopping over on ive you these results & sample again. MikeRennaker, Joanne (DEQ) Cook, Pat (DEQ) Friday, May 01, 2015 11:38 AM Deltoral, Miguel ce: anor ea, Crooks, Jenifer Poy, Thomas; Benz, Richard (DEQ) Busch Stephen (DEQ) Subject: RE: Flint Corroston Control? Hi Miguel - sory, | should have been more specific in My previous email, The rules you stated below allow large systems to be considered having optimal coos on central if they have data from two consecutive 6 month monitoring periods that meet specific criteria. DEG.ODWMA has not made a formal decision a to Wihether or not the City of Flint meets the exemption criter CF ‘wil be required to do a corrosion control study arent has only completed one round of 6 month monitor ‘The City of Flint’s second round of monitoring Siirbe completed by June 30, 2015, and we will make @ formal decision at that time. If my memory is correct, this is consistent with the process followed in the early * 90's for large systems when the Pb/Cu rule was first implemented. The Department waits untl large systems ‘complete both rounds of full seale, 6 month renting before making a decision about optimal corso) vontral. Ifit is determined that Flint has to install morosion control treatment, the rule allows up to 2 years fo ‘complete a study and 2 additional years to instal {he treatment unless we set a shorter time frame, ‘As Flint willbe switching raw water sources in a just over one Yer from now, raw water quality will be completely different than what they currently use. Requiring a study at the current time will be of litle t0 no carne in the long term control of these chronic contaminants Finally, the City of Flin’s sampling protocols for lead and copper monitoring comply will all current state and federal requirements, Any required modifications will be implemented at the time when such future regulatory requirements take effect. Patrick Cook, P.E. Community Drinking Water Unit Office of Drinking Water & Municipal Assistance Michigan Department ‘of Environmental Quality Phone. (517) 284-6514 cookp@michigan aov From: Dekora, Miguel (mailtodetoral:miguel@epa.gov] ‘Sent: Saturday, April 25, 2015 10:11 AM To: Cook, Pat (DEQ) Cet Porter, Andrea; Crooks, Jennifer; Poy, Thomas ‘Subject: Re: Flint Corrosion Control? Hi Pat, 1 be heading out to MI for RTCR tomorrow and won't see ‘email until next Tuesday, but I wanted to follow up aes because Flint has essentially not been using any corrosion control treatment since April 30, 2014 and they have LSLs, Given the very high lead levels found at one home and the pre-fhushing happening at Flint, I'm tae that the whole town may have much higher lead levels ‘han the compliance results indicated, since they re using precflushing ahead oftheir compliance sampling,If the source water lead is non-detect (zero), then according to 141.89(@)(3) they should use 22#0 for that source water value: “All lead and copper levels measured between the PQ. and MDL must ‘be either reported as measured or they can be reported as one-half the POL speci ied and copper in paragraph (#)(1)Gi) of this section. All las Oppel sbe reported as.zero." ‘Ag far as the treatment determination, theze are only two scenarios fora large system 10 be deemed to have optimized corrosion control without treatment and Flint does not appear fo mest either: The first is at 141,81(6)(3) Any water aystem is deemed to have optimized corrosion control if t submits results of tap water monitoring itoring conduoted in accordance with § 141.88 ¢ i riod that the difference between the 90th puted under §141.80(6)(3), and th jghest source waier lead concentration is sn Level for lead specified in § 141.89@)(1)@) If Flint’ highest source water lead was zero, and their 90th percentile was 0.006, then Flint does not meet this criteria, because the difference must be LESS THAN the PQL (i.< 0.004 or less). 0.006 - 0 = 0.006. low the WMeiiéd Detéotion Limit may also be denied ihe 908 percentile tap water lead level is less ‘than oF ‘or two consecutive 6-month monitoring periods. “Although Flint's source water lead was non-detect (zor0), the 90th percentile lead level is 0.006 which is above ‘the POL of 0.005, so Flint would not meet this criteria either. ‘Am I missing something? (Miguel A. Del Toral Regulations Manager US. EPA RS GWOWE 77 West Jackson Blvd, (WG-15)) Chicago, tL 60604 Phone: (312) 886:5253, From: Cook, Pat (DEQ) Sent: Friday, Apri! 24, 2015 12:45 PM To: Deltoral, Miguel Subject: RE: Flint Corrosion Control?Total Lead collected from the plant tap on 6/22/14 was 220 pat From: Dettoral, Miguel [mailtordeltoral miguel@epe.gov) Sent: Friday, April 24, 2015 11:59 AM ok, Pat (DEQ) y, Thomas; Porter, Andrea Subject: Re: Flint Corrosion Control? “What was the source water lead level? Miguel A. Del Toral Regulations Manager US. EPA RS GWOWB: 77 West Jackson Blvd, (6-158) Chicago, 160604 Phone: (312) 886-5253 From: Cook, Pat (DEQ) Sent: Friday, April 24, 2015 10:43 AM To: Deltoral, Miguel Ce: Poy, Thomas; Porter, Andrea Subject: RE: Flint Corrosion Control? Hi Miguel - Flint is currently not practicing corrosion control treatment at the WTP. When they started treating water at their WTP last spring, we placed them on full chart (100 sites) Pb/Cu monitoring for two consecutive 6 month periods. Wa monitoring Is also being conducted. The first round of samples after switch-over from Devs uly 1.2044 - Dec 31, 2074) had 0th percentiles Of 6 ppb for Lead and 110 ppb for Copper. The eevond ound of samples (Jan 1, 2015 ~ June 30, 2015) 's Cinderway with approximately 20 of the 100 sample site results in. The highest lead result out of the 20 received thus far is 13 ppb. pased on the matrix of recommended corresion control study components for Large PWS's for both Lead and Copper, there are no additional requirements for "he ‘City of Flint based on the levels of lead and copper th the cePent source water and the results of the lead and copper vietribution monitoring. The only provision of the {aaa & Copper Rule which classifies the existing Treatment of large PWSs as optimized for corrosion control is iron the difference between the 90% Pb-TAP and SBOE is (03s than the lead practical quantitative level (POL) for each six-month period of the Inia Trontoring program. By definition, the PAL for lead is (005 mg/L; (ri the lead value forthe source water used inthis tievermination is the highest source water lead arn centration. I this condition is met, then no study of testing s required, We believe this condition has been met for Flint, However, we will re-evaluate this after the 2 round of 6 month sampling 's completed. it you have any further questions, please contact the Lansing District Supervisor, Steve Busch at (517) 643- 2914 or at buschs@michigan.dov. Have a good (and hopefully warm) weekend! Patrick Cook, P.E. ‘Community Drinking Water Unit Office of Drinking Water & Municipal Assistance Michigan Department of Environmental Quality Phone: (517) 284-6514From; Deltoral, Miguel [mailto:deltoral.migue!@ep2.c0v} Sent: Thursday, April 23, 2015 12:33 PM To: Cook, Pat (DEQ) Ce: Poy, Thomas; Porter, Andrea ‘Subject: Flint Corrosion Control? Hi Pat, What’s Flint doing now (post Detroit) for corrosion control treatment? ‘Miguel A. Del Toral Regulations Manager Ground Water and Drinking Water Branch 77 West Jackson Blvd (WG-15!) Chicago, iL 60604 Phone: (312) 886-5253Rennaker, Joanne (DEQ) From: Dykema, Linda D. (OCH) Sent: ‘Thursday, July 23, 2025 1008 AM To: Busch, Stephen (DEQ); Philip kris (EQ; Shekter Smith, Uane (DEQ) Subject: FW: Director's Office Assignment Flint -need update asap ¥i- this is what I sent up to my front office. Thanks for your help Steves Original Message~ From: Dykema, Linda O. (DCH) ‘Sent: Thursday, July 23, 2015 10:07 AM wer aller, Corinne (OCH); Peeler, Nancy {DCH}; Anderson, Paula (DCH); Travis, Rashmi (DCI ‘Moran, Susan (DCH) Cebricm, Wesley F. (DCH); Bouters, Janese (DCH); Bar, Jaccut (0c); Fink, Brenda (OCH); Groetsch, Kory (DCH) Subject: RE: Director's Office Assignment ~ Flint - need update 252 rijalva, Nancy (DCH); { spoke with Steve Busch, Lansing District Office manager, DEQ Office of Drinking Water & Municipal Assistance. “The city of Flint recently conducted drinking water testing throughout the city with special attention to those areas Known to have old service ines. The ity water supply i in compiane ‘with the lead rule, which means that 90% of the water samples were ess than the lead action level of 15 ppb, DEQ wil, however, recommend that Flint further “optimize” their corrosion control methods. The DEQ has not seen 9 change in the city's compliance with the lead rule since switching to the Flint River source, Some water samples had lead levels above 15 ppb. Homeowners recente their sampling results and those with elevated porn are provided with information regarding how to minerize thel xO including replacement of water supply lines, the ety pays for line replacement from the main tothe Proper'y boundary. The property owner is responsible for some portion ofthe cost ithe line replaced ison thelr proper ‘To Steve's knowledge, there is no program in Flint to ‘sist homeowners with timited financial means. regarding the home with high drinking water lead levels some YoATY ago the supply line that serves the neighborhood vine replaced, but somehow this house was not connected ko fhe Net fine, such that the family's drinking water supply eae rerming from the old corroded lead pipe, None ofthe neighbors wate, hhad elevated lead levels, which was likely why she was temporarily connected by garden hose to a tap supplied by the new fine, She has since been permanently connected to the new line, Regarding the EPA drinking water official quoted In the press articles: the report that he Issued was a result of his own reccarch and was not reviewed or approved by EPA management. He has essentially acted outside his authorityRennaker, Joanne (DE From: Crooks, Jennifer Sent: Tuesday, July 28, 2015 9:47 AM To: ‘Shekter Smith, Liane (DEQ); Benzie, Richard (DEQ); Philip, Kris (EQ); Monosmith, Carvie {DEQ); DeBruyn, Dana (DEQ); Dettweiler, Dan (DEQ); Busch, Stephen (DEQ Prysby. Mike (DEQ); Cook, Pat (DEQ); Holdwick, Kevin (DEQ) ce Poy, Thomas; Bair, Rta; Damato, Nicholas; Shoven, Heather; Kuefier, Janet, Murphy, Thomas; Porter, Andrea; Deltoral, Miguel Subject: Final Notes from Michigan semi-annual call on 6/10 | was supposed to finalize these in mid-July, but! didn’t receive any changes from anyone, so these notes are final now. Thank you all again for participating, Jennifer Se From: Crooks, Jennifer Sent: Wednesday, July 01, 2015 5:31 PM seechekter Smith, Liane (ONRE); Richard Benze; kris philip; Monosmith, Carrie (DNRE); DeBruyn, Dana (OE), rel enailer Dan (BEGI; Busch, Stephen (DEQ); Prysby, Mike (DEQ)' ‘cookp@michigan.gov' Holdwick, Kevin (DEQ) Cer Thomas Poy Bar, Rita; Damato, Nicholas; Shoven, Heather; Kuefler, Janet; Murphy, Thomas; Porter, Andrea; Deltoral, Miguel Subject: Draft Notes from Michigan semi-annual call on 6/10 ‘All~Below are my draft notes from our cal last week, une 10, 2025. Thank you al for participating. | apologize for the olay in getting these out in drat to you all for review—! was hoping to get a couple of items ironed out that ware fuzzy luring our deeussions, ut hasn't happened yet. Several ACTION items below. So, please review to make sure i Sarre ened our dlacussion/agreements correctly, and feel free to edit as needed. | you could get back to me by July 13, ‘that would be great. Thank you! Jennifer Attendees: MDEO: Liane Shekter-Smith, Richard Benzie, Carrie Monosmith, Kris Philip, Dan Dettweller, Marjorie Rodriguez (Student, Kevin Holdwick, Mike Prysby, Dana DeBruyn, Steve Busch [Pm Region 5: Tom Poy, Rita Bai, Nick Damato, Janet Kuefer, Michele Palmer, Tom Murphy, Heather Sheven, Cary Mecélhinney, Andrea Porter, Miguel Deltoral, Mostafa Noureldin Summary: ‘changes in Lead Disinvestments and Commitments for FY 2016 ARDP—for discussion: Due to our extreme focus on lead in drinking water, this is the consensus here. Consumer notification of tap results at NTNCWS: (suggested wording) The NCWS program commits to full implementation ofthe lead consumer notification of tap results Fequlrement, to begin in CY 2016, Region 5 will asist ina notification outreach effort in ate F¥ 2048 to remaining 698 NTNCWSs that are not schools/daycares, to begin providing lead consumer natice in CY 2026. NCWS program ‘commits 1to include information on providing lead consumer notice n the annual monitoring letter sent to all NTNCWSS for CY 2016. “STATE: The State found this change in the wording acceptable. collection of Lead samples at NINCWSs during une ~ September 2016 timeframe {suggested wording) NCWS program coramits to including information in the applicable NTNCWS annual monitoring Hae of the requirement to collect theit annual/triennial lead sample betwee ‘June and September only, during CY BOLE, The MDEQ. NOWS program currently does not have the capabllty {0 ‘easily track lead sampling compliance within this specific timeframe. STATE: The State found this change in the wording acceptable. stember 2015 timefrarn Follow-up Actions for NTNCWSs that sample outside of Jun (From 5/5/35 call notes w/EPA) MOEA, commits to providing Region 5 with all CY 2015 lead (and copper?) sample date yrotl NTNCWSs by March 2016 so that EPA can analyze how many PWSs monitored outside the June through October timeframe, EPA commits to follow-up with MDEQ to discuss follow-up actions STATE: The State agreed to providing EPA RS the raw lead and copper data for all CY 2015 for all NTNCWSS. The a yntortrack database does have data, but it can’t generate violations. MDEQ doesn't commit to enforcing against 2016 ralstors in FY 2016. The State sad, i fs planning on dislwesting In enforcg ‘against these violators due to limited capability of Watertrack; however, ifthe State's noncommunity date ‘management capabilities improve during FY 2016, imaptementation ofthis disinvestment may become a realty. The State has not designated an alternate timeframe, oF dene systom specific documentation as to why the system qualifies for @ different timeframe. ‘Submittal of the lead and copper reporting form {suggested wording) MDEQ, commits to requiring CWSs and NTNCWSs to submit the lead and copper reporting Form via ceeeerial monitoring letters to each system, tracking CWSs and NTNOWSS submittal of the lead and copper reporting form, and commits to issuing violations for failure to submit the ead ‘and copper reporting form. The reporting form provides the address ofthe sample site, designates sampling site selection criteria, and explanation(s) for any changes in sampling sites. STATE: Dan Dettweiler stated that the NCW program was not in a postion to do this for the NINCWSs at this time. Tom Murphy azked how does WaterTrack hancle/track high lead results? 197) ‘M said there is a truncation issue on the tample location name field. Dan acknowledged that this problem as been identified, and the Department of se hnology Management and Budget (DTMB) has been trying te Fx this problem, but itis@ challenging problem. Dan rete that sample sites for NTNCWSs are actually identified by LHDs during ‘the sanitary survey and are documented in tha conitary survey. The LHDs check the pdf of the laboratory results shat Clearly states where the sample was taken, and calcolates the 90" percentile, However, Dan stated thatthe requirement © ‘end in the lead and copper reporting form daa nvrenty inthe LHD anal monitoring fetter sent to each system The NTNCWSs do not couple this form to the sae consumer Notice, as does the CWSs. Kes Philip pointed out thatthe HiDs select the sample sites, thus when they ithe 90" percentile, they are actually double checking the ses ‘with the results. are calcul rom our discussion, the Region concluded that at this time, the LHDs are actively reviewing the lead and copper results ererthe sample locations when they calculate the 90" percentiles to ensure PATE {LCR monitoring is conducted by ALL riewss atthe proper sample sites, After out call, asked for verification of this statement, and Dan Dettweiler 2responded, “Just as with an exceeding value ofan MCL, WaterTrack alerts the LHD when at least one sample for a water system exceeds the AL, A 90* percentile calculation is made only when an exceeding result alerts the LHD. For cases Sinere there are no exceeding results, private lab samples are reviewed atthe time (HDs hand-enter ther into eeese track, State lab samples, which flow electronically via nightiy downloads from the state fab database, are veiemed when pds of the analysis reports are, routinely, emailed by the state ab to Hs Beyond that, MDEQs annual ae vtuation ofthe LHDs provides another opportunity for us to oversee the proper assigning and use of designated sampling locations.” ACTION: The Region wil discuss Dan’s response internally, and get back to the State with any issues/concers, «is Philip said that the CWS program is requiring thatthe systems submmi the form, but they are not enforcing whether sr not the system submits the form. Often, the CWS will submit the Lead Consumer Note ‘and the Lead and Copper aporting form fogether, Kris sid if 90% are already submiting the forms, then (he State will agree to follow-up and arco this requirement, Sut, if les than that, will probably be too much ofa burden, Kris said they may change the way DEQis tracking in SDWIS duting FY 2026, But, the Region sald SDWIS-Prime probably won't be available until 2017 at the earliest. |ACTION: kis Philip wil research with the District Office to determine the current submittal rate of the lead and copper ‘reporting form from CWSs; and report back to the Region. Enforcement Update with Heather [NTNCWSs under Bottled Water agreements due to Arsenic MCL violations: ta ivcuscions with Region 5 and the February 2014 EPA/OECA memo, MDEG has closed the old Arsenic open-ended tact violations; however, no further quarterly monitoring is being conducted atthe (2 27) systems that are still under aetieg water agreements. Thus, ne more arsenic MCL violations will be reported for these sys and these systems pn not become priority systems (ETT score of 11 or more) since only one arsenie MC violation will be reported (5 points) even though they have a longstanding isue with arsenic noncompliance ‘The Region would like to discuss the pros and cons of placing these PWSS with arsenfe MCL violations on quarterly monitoring as required under 40 CFR Section 141.23(c}(7); and brainstorm possible solutions. eather provided an update on how the State is ding in returning ETT systems to compares; the State is doing very retin achioving its commitment for FY 2015. Heather said the Region is glad to ee the State ‘and LHD prioritization of implementation ofthe drinking water program and NTNCWS schools and dayeares Referring to the NTNCWSs under BW agreements that are in violation ofthe Arsenic Mf, Heather said that since there aerery more open-ended MCL violations in SDWIS, that no MCL violations can be reported fo SDWIS unless there is are itoring to shovr the system isin non-compliance. Even though the LHD has indicated 2k these systems are drinking treed water for public health protection, the use of bottled water cannot be a permanent solution to the fact that the system's drinking water atthe tap continues to exceed the MCL for arsenie Dan said there are 22 systems, where 8 are aires that should be conducting quarterly monitoring. Dana sai that letters have been sent (OR drafted?) to these 22 systems to require quarterly sampling for arsenic; these 22 systems are in 10 different counties so the message from the aera r consistent, A secondary effect ofthis new requlrement for the systems, may be thot they transition to another ‘water source or install treatment sooner. ‘The State voiced a concern that multiple quarterly violations could potentially affect the State's relationship with the ibs tmancially, Genesee and Oakland Counties have quite @ number of roncommunity wate’ systems. Multiple tquorterly violations could affect the Dept of Community Health's determination as (6 ‘whether the LHDs are meeting aarntmum program requirements; thus recelve full funding for their work with the roncormmunity systems for the tiinking water program. The LHOs cannot have more than 20% of their systems with violations. The Region wonders ow mach funding would be cut from a LHD contract fit exceeds the 20% noncompliance level set in the contract?Status of Flint “TTHM levels for May-—Due to MDEQ district engineer lune 20-RECEIVED; soe link to results jts-show-al-locations-are-within-acceptable-fimits-fo hnttps://anw.cityoffint.com/2015/06/01/may-water-testing-res fthm/ All samples below the TTHM NCL; one site still has an LRAA above the MC Put decreased from 105 ppb in Feb to 93.5 ppb in May. Mike rysby said he is getting ready to issue the construction permit to the Cty of Flint to install a GAC filter in July, that witeeerove more TOC to further reduce the potential of developing TTHMSs, Mike said he has already issued @ vonstruction permit fora transmission line within the City that will help reduce water a88- ead in Flint ur discussions with MEQ indicate that no phosphates/corrosion control has been added to the system since April coud when the source of drinking water changed tothe lint River. We understand that ‘the City is just finishing up its sosand set of &-month intial monitoring fr lead; where the results will probably warrant Corrosion Control Study to be conducted, Since Flint has lead service lines, we understand some citizen-requested lead sampling is exceeding the ation Level and the source of drinking water will be changing again in 2026, soto stat 8 Corrosion Control Study now doesn't make sense. The idea to ask Flint to simply add phosphate may be premature there are many other issues and tone that must be taken into account which would require a comprehensive look 2° he water quality and the system hefore any treatment recommendations car/should be made. Miguel is recommending MDEQ and EPA? approach Flint aout formally requesting EPA's Office of Research and Development in Cncinnat| suppor ‘the lead in Flint drinking synter issue, and request that Mike Schock, ORD, and possibly Darren Lytle, ORD, to participate in Flint’s drinking water vrdvisory committee so that @ comprehensive evaluation on how to proceed can De discussed. miguel provided a brief summary of the high lead results found atthe residence of Ms. Lecanne Walters in Flint, Miguel aaron up with a written summary of the work conducted, sample results, nc conclusion’ Iaigue! belfeves that lead fevels in Fin are being affected by the lack of Corrosion Control being conducted by the City, ayn che LCR requires 2 6 month initial monitoring for anew source. Steve Busch stated that in the Lead sampling pool, seat allof the lead sample sites are lead service lines, and the State isnot seeing large In SOS in lead levels at the tap. Miguel suggested that EPA experts in Lead, Mike Schock; and in distriputiot systems, Darren Lytle, be added to the raesvirnking water advisory committee to assist the City/State In determining the best wit proceed to minimize lead Fr the city’s drinking water during the interim use ofthe Fint River, and subsequent use of Lake Huron water, Miguel sad he will send Mike Schock and Darren Lyte's contact information te Steve and Mike. Steve pointed out that the city i following the LCR requirements, and completing the requirements i & timely manner. Miguel's point is that Since the LCR was promulgated 20+ years ago, that research and cifferent situation’, like Washington D.C., have aavcated scentists, experts, and regulators thatthe existing requirements In the LCR my not be as protective as previously thought. Thus he can only make recommendations a5 to how 19 Yeu sampling protocols. And Miguel i ymowledges that t may be another year before these regulation changes are promulgated in the Long-Term Lead and Copper Rule. in December 2015, the NDWAC recommendation Is expected. “The Region asked the State ifthe Flint River willbe a permanent supplemental sours of drinking water, once the City of qt sonnocts with the Karegdodt pipeline from Lake Huron. Mike Prysby said that she CY & currently pumping 22MD, put the City has 40-50 MG of storage. The Citys currently working on reducing its ‘unaccounted for water losses, and tance water losses are dropping. The State, through the Governor's office, provided disadvantaged system funding, $2M which includes $900k for lead detection, and pipe inspection.A Update on WaterTrack to SDWIS-State: The migration of WaterTrack data to SDWIS-State was number 39 on the Dept of rechnology Management and Budget's (OTM®) project list ast Years this year itis number 20, It doesn’t appear this project has a high prfority. Does the State have any new information on the progress of this project? ban said thatthe migration of WaterTrack data to SDWIS-State has moved © priority of 26 with DTMB so far this year aa aa cad they are going to take this project out of the que, since Ronda Mee has returned to the drinking water program from DTMB. Ronda said she re-estiated DTMB's iol) 9 ‘this project to be far less than originally rrouht so there ism need for any program developers or the ech team ‘This project will only need the Data Team and ue signers ony, Ronda said they can setspon anew server and Migr the data fram WaterTrack to SDWIS- cre themselves in-house. Kes Pip remembers migrating the CWS dof 10 ‘sDWiS-State, 50 she can be a resource for this project The parts that are needed to be completed by DTM cove te contracted out. Cary McElhinney said that a ee yess of withholding PWSS grant funds and reaiecting the Funds 1° HQ contract with SAIC. Richard Benzle caer he process worked well last year when Mi used PWSS funds to contract ‘with a HO. contractor to conduct NEEDS survey training. ACTION: Jen wil follow up with State and Tribal Programs Branch about the process and timing of holding back funds from the WSS grant for the purpose of contracting with SAIC consequences of cutting the State drinking water program to.2 "ft inimal program” Jennifer hada discussion with Richard Benale regarding the possbity of the Michigan State Legislature looking to have just a minimal drinking water program, meariing only 2 ProBsam ‘with activities that are required by the Federal SDWA. seanifer ultimately discussed this internally with Tom Poy. The ‘minimal program suggested would cut out Operator Certification, Capacity Development, Plan Review, Cross Connection ‘Control, Source Water Protection, among other programs that are State required. Operator Certification chad Capacity Development, while not required by the Federal regulations, do have financial strings attached. And Plan feview/construction permits are required by the SRF programm poeesjoar Any fecent communication with the State Legislature that ‘they might proceed and make this possibility 2 reality? richard and tiane said there is no current threat from the State Lesislavure cut the State-funded PWSS program sities, But there is State-wide impetus to delete old programs and regulations, so this could lead to questioning the purpose of State-funded PWS program activities, Richar is ust being proactive in preparing a justification, Aichard remembers a discussion many years ago about what constitutes 3 comprehensive drinking water program’. Tom Poy a scnnifer commented in a previous communication with Richard ‘that the EPA PWSS primacy program and the State- aoe aed notvtes Inthe drinking water program were meant to comBlemon ‘each other, To support this statement, Jarnifer sent Richard some PWSS Priority guidance from the 90's, some preamble language from the 1976 SDWA found by our attorney, and language from Section 142 ofthe SOWA regulations from 1976 that might assist hl in his justification. EPA's Resource Message at the LHD Workshop in Apri From the 2014 analysis of Shared Goals 2013 data, which is compliance data, for noncommunity systems, there are oreting trends of irate M/R violations for both NTNCWSS and TNC\SS, ‘We discussed this on the last sem-annuat call. Analysis of the 2015 Shared Goals 2014 data {April 2015) shows an improvement—that of decreasing numbers of pacti/nitrate M/R violations. However, in ight ofthe upcotring implementation of RTCR in 2016, the question raised here in the Region is:oes the State have a plan with the LHDs as to what activites must be prioritized, and what wil fll off the plate? Not all mass wil need to isinvest based upon each LHD's resources, but some poorly funded LHDs may have to disinvest in some activties/drop activities that have no risk to public health. carrie Monosmith said that she met with the RTCR workgroup, comprised of LHD Directors/sanitarians, ast fall to identify activities that the state can disinvest in during the next Several years as the LHDs begin implementation of RTCR. ‘They could not identify any activity that could be dropped. The ‘main thing that will help the LHDs save time is to get the aaa ic DW {eDWWA) going, of the CMD porta, which wil drastically reduce the LHDs time in inputting laboratory data into WaterTrack/SOWIS-State, From there, they can develop electronic data forms (CROMEER compliant) that the systems can submit. Thank you! Jennifer shekterl@michigan.gov; ‘Richard Benzle' ; 'Monosmith, cate (ONRE) ; ‘DeBruyn, Dana (DEO) ‘2DebruynD@michigan.gov>; Dettweller, Dan (DEQ) ; Poy, Thomas ; Kuefler, Janet ; Shoven, Heather ; Murphy, Thomas Cmurphi.thomas@epa,Z0v>; Bait Rita ; Pniak, cGward Busch, Stephen (DEQ) Rennaker, Joanne (DEQ From: Poy, Thomas Sent: Thursday, September 03; 2015 1:02 PM Te: Borie, Richard (OEQ); Shekter Smith tiane (OE); Busch, Stephen (DEQ: Pysby, Mike (DEQ) ce yee, Tinka; Henry, Timothy; Bar, Rit; Oamato, Nicholas; Crooks, Jenifer Subject: RE: Flint Meeting Thanks for the email | hope that Flint will utilize the expertise of MDE field staff and ORD distribution system staff to help them. identy water quality and pipe conditions that need to be considered in the fective implementation of phosphate treatment. _ Tom Poy Chief, Ground Water and Drinking Water Branch USEPA - Region 5 (312) 886-5991 From: Benzie, Richard (DEQ) {mailto:BENZIER@michigan.g0v) Sent: Thursday, September 03, 2015 9:21 AM To: Poy, Thomas Ce: shekterl@michigan.gov Subject: FW: Flint Meeting ey From: Prysby, Mike (DEQ) Sent: Thursday, September 03, 2015 9:06 AM To: Benzie, Richard (DEQ) Ce: Shekter Smith, Liane (DEQ); Busch, Stephen (DEQ) ‘Subject: RE: Flint Meeting Richard, { spoke this morning with Mike Glasgow (Utility Administrator) and Brent Wight (WTP Supt) to see what came out of their meeting with LAN and the city. The meeting's main focus was over the lawsuit and financial issues; however, corrosion control treatment was also discussed. City administration ‘told Mike and Brent that there will be no funding restrictions to install corrosion control. The capital cost to install treatment (P04 feed system) is not expected to be high since the WTP has existing feed lines and equip in place; however, new properly sized pumps will be needed. Mike expects LAN to have a proposal for us to review and approve for issuance of an Act 399 construction permit within the next one to two months.Michael Prysby, P.E. District Engineer Office of Drinking Water and Municipal Assistance 517 290-8817 From: Bervle, Richard (DEQ) jednesday, September 02, 2015 5:13 PM Tos Prysby, Mike (DEQ) Cel shakter Smith, Liane (DEQ); Busch, Stephen (DEQ) ‘Subject: FW: Flint Meeting Do we know how this meeting concluded? From: Poy, Thomas [malto:poy.thomas@epa.gov} Sent: Wednesday, September 02, 2015 4:23 PM per pekter Smith, Liane (DEQ); Benzie, Richard (DEQ) Subject: Fint Meeting Liane/Richard: How did lint’s meeting with their consultant go? Did they decide Tom fee tee eee ese eer Tom Poy ‘Chief, Ground Water and Drinking Water Branch USEPA Region S (312) 886-5991 to implement treatment?Rennaker, Joanne (DE From: Crooks, Jennifer Sent Thursday, September 10, 2015 5:58 PM To: Shekter Smith, Liane (EQ) ce: Benvie, Richard (OEQ) Busch, Stephen (OE); Pysby, Mike (DEQ) Poy ‘Thomas; Porter, andrea; Devereaux, Tracy Jo (OEQY Kuefler, Janet, Shoven, Heathen Deltoral, Miguel Subject: Final Notes from call Tuesday 8/31/15 with MI DEQ RE: Flint ‘Thank you, Liane, for our edits—t incorporated al of your edits, and further clarified who said what. Jennifer Date: ‘August 31, 2015 Present: tiane Shekter Smith, Richard Benzle, Steve Busch, (2 other MDEQ staff2), Tom Poy, Andrea Porter, Janet Kuefler, Jennifer Crooks ‘STRATEGIC NEXT STEPS FOR ELINT TO ADDRESS LEAD CORROSION CONCERNS ‘Tom Poy discussed Marc Edwards’ website, “Flint, Mi Water ‘study Updates” (atps:/inewaterstudyupdates. wordpress.com), The viscussion focused on the lead sampling and analytical results dois dwards’ tear posted to their website, Tom emphasized that EPA is not involved with Marc Edwards’ workin nt Tom mentioned thatthe Edwards team's samples may not have been analyzed by a certified fab (which is only Fequired for compliance samples) nor taken from sites that qualify as Ter 2 for UCR compliance sampling but the results five further evidence that lead levels in Flint are tending upward. (The conclusion that there is an increasing trend of at concentrations at consumer taps builds upon earlier compliance sampling taken by Flint in 2024 and 2025 that showed the 90" percentile of the ‘1 é-month sampling period at Spb, then the 90" percentile of the 2" 6-month cremplng period at 11ppb.) Everyone at the meeting agreed that flint in compliance with the Safe Drinking water Act ction level for lead. However, because the city’s population ‘exceeds 50,000 persons, MDEQ stated that Flint needs to ataltionally optimize thelr treatment process to reduce lead levels further, if possible. ‘the “Flint, Mi Water Study Updates” website is putting added pressive MDEQ and EPA to ensure that Flint addresses Trai tack of optimized corrasion contol treatment in an expedited manviel order to protect the residents from texposure to high lead levels. Richard noted that there are umyelOny systems across the country that have installed corrosion control treatment, have optimized their corrosion ‘Control, but did not necessarily reduce their lead levels. We tional benefit of corrosion conteol is prolonged life for water distribution pipes and home plumbing, This results in lower costs for water utilities and their customers. Im March 1992, the DWSD contracted with Tucker, Young, Jackson, Tull, in. (TYAN, in association with CH2M HILL, INC, and Beonomic and Engineering Services, Inc. (BES), to perform a lend and copper corrosion control ste. The purpose ofthe study was to determine the aptimal approach fr reducing lead and copper concentrations in DWSP deinking water without adversely affecting other water quality characteristics. Major tasks inthis study were to: « Bvaluate existing water quality data, existing distribution system pipe ‘materials and the results of lead and ‘copper sampling + Identity and analyze feasible and practical treatment methods to reduce Jead and copper corrosion {desktop analysis) «Design and construct a pipe-loop testing apparatus to evaluate treatment alternatives identified in the desktop analysis,evaluate selected corrosion control treatments on different pipe materials + Byaluate the effectiveness and feasibility ofthe tested treatment alternatives in reducing lead and copper concentrations “+ Recommend an optimum lead corrosion contol treatment + Develop an implementation plan for full-scale corrosion control fcilities ‘This eport presents the results of the DWSD Lead and Copper Corrosion Control Optimization Study. Figure ES-1 ‘WSU Water System «Operate the pipe loops ford year & Existing Contitions “The DWSD obtains water from thee intakes. Two of thes, the Balle Isle and the igh Iskne Ttakes, ake water fom the Detroit River. The third intakes 00 “Lake Huron, Water is treated at five water treatment plants (WTPs) including the ‘Water Works Park Southwest Springwells, Northeast, and Lake Haron ‘WyiPs. The water system is shown in Figure BS-1, Treated water fom the 9 ‘woes distributed to the City of Detroit ‘and 119 wholesale water customer tems, The DWSD water system serves bout 4 million people ‘Water leaving the WTPs is of good . quality and considered moderately (ase eo agent 1 Wator Pst © te, Water Pant Sriie Area Under Ctra (we ake Hon fa byture Lake Haron & lorteast Sorte tt. “ Mivtre syringe it 8 Soumwest 1 Water Wars Pork 1 soctest racutve Summarycorrosive. For example, pH from the five WPs averages 7.4, alkalinity averages 76 ng/L. (CaCO), and harciness averages 100 sng/L (CaCO). Nevertheless, some increase in lead and copper is resulting from the corrosive action of the water primarily on sevice pipe and household plumbing, The main sources of endl are 50:30 lead /tin solder, brass containing Toad used in faucets, and lead service lines and plumbing. “The regulation lead AL is 0015 mg/ atthe 90th percentile in home water tps: Daring the LCR Compliance Monitoring conducted in 1992, DWSD's 90th percen- tie lead concentration was 0.017 mg/1. in the first round and 0.023 mg/-in the second round of sampling (Figure E52). ‘Looking at the data in aslightiy diferent imannet, 35 t0 37 percentof the 119 pur: vyeyor water systems exceeded the AL forlend. Figure E82 {GR Complance Monitoring Results for Lead For coppes the 9th percentile concentrations were 034 and 0.19 mg/L fortwo rounds of sampting-wel below the copper ALof 1.3 mg/L Figure £5) Lead uptake, therefore, isthe major ‘concern within the DWSD water system. ‘Determining the optimal lead control treatment is essential tis the objective of conducting this corrosion control study. Further, there ate an estimated 200,000 lead secvice lines (LSE) in DWSD's direct service arva and possibly more in areas served by wholesale customers, After corrosion treatment is optimized, the possibilty exists that lead ALs may stil be over 0.015 mg/Lat the 90th percentile. ‘Shoufd this occur, the DWSD would need to embark on aremoval program for LSLS, ‘which could cost between $300 and 00 milion. 4 Desktop Anatysis ‘To reduce the number of chemicals for long-term testing, a screening analysis was performed using desktop techniques recommended by US. BPA. Lead corro- son control treatment methods examined fortheie applicability to DWSD are as follows: + Polyphosphates + Orthophosphates + Zinc orthophosphate « Polyphosphate/orthophosphate biends. + silicates + pi adjustment «+ Altainity adjustment «+ Calcium adjustment “The main criteria forselecting a lead corrosion control method is performance for lead uptake reduction. Lead corrosion control methods were also evaluntedFigure €8-3, ‘LOR Compliance Monitoring Results for Comper FA Aion tovel= 1. 018 ona ond based on effects on other drinking water regulations, industial waler users, ‘wastewater treatment, waier quality, water treatment operations, consecutive water systems, and multiple sources of supply and treatment ‘Based on this evaluation, the fallow- ing chemical treatments were eliminated from consideration for pipe-loop testing, «+ Polyphosphates, These products are primarily used to sequester iron, calcium, and manganese and may actually do more to promote lead corrosion than to preventit, «+ Polyphosphate/Orthophosphate Blends. These products have fot been proven to be more effective than orthophosphates alone for lead reduction, and theis proprietary ‘chemical composition makes selection ofthe optimum product difficult. + Silicate. Sodium silicate inhibitors require a high dosage for lead control and, based on a survey of major industries, would have significant adverse effects on industrial water users. « Alkalinity Adjustment. This technique would have marginal performance for lead reduction based on DWSD water quality and would be impractical fora system the size of DWSD. + Calcium Adjustment to Deposit a Caleiusn Carbonate Layer. This technique is not a proven method forlend reduction, and would be difficult to produce a uniform layer throughout a distribution system the size of DWSD. Calcium carbonate deposition, however, can cer when pH is raised for lead reduction. This situation is addressed under the pH adjustment alternative, Lead corrosion control treatment methods applicable for DWSD water are as follows: + Orthophosphates. These products have been shown to be an effective means of lead reduction for water similar to that of the DWSD. + Zine Orthophosphate, These products are also a proven method of lead reduction, ahough there is ‘concer about 2ine in industrial water and wastewater «+ pH adjustment. This technique is. also a proven method of reducing, Jead solubility although higher pHs affect some industrial users and can increase calcium carbonate deposition. erooutve Summary‘Acgurvey of 16 Great Lakes area water utilities using water of similar quality to that of DWSD demonstrated the effectiveness of orthophosphate, zine orthophosphate, and pH adjustment in reducing lead concentrations at the consumers’ taps. Those treatment meth ods, therefore, were retained for farther testing in the pipeloop apparatus & Pine-Loop Testing Based on the desktop analysis, it was concluded that the following treatments would be tested in the pipe loops: «+ Adjusting pH to 8.1 using sodium hydroxide «+ Adjusting pH to 87 using sodium hydroxide «Adding zinc orthophosphate at doses of 04 mg/L for zine and phosphorous (as P) + Adding osthophosphate using phos: phoric acid ata dose of A mg/T-as P Seeescietseeessraeeeeteeeee eee Pipe-toop testing produces information onthe corrosion control treatment most ikely to effectively reduce lead levels. _ {tis important to understand that pipe-loop testing is conducted to provide information on the relative ‘effectiveness ofeorrosion control treatments. The results ‘cannot be used to predict actual lead Iovels that may occur at customers’ taps in the water system. Pipe-loop testing, however, produces information on the corrosion control treatment snost likely to effectively reduce lead Jevels and is an approved optimization techniques Executive Sumer ‘Appilotsscale testing apparatus was designed and constructed to test each of the treatment techniques on different pipe materials. Five pipe-loop racks were constructed: one foreach of the four trethiods and another for control (no treatment provided). Each pipe-loop rack included one new lead pipe loop, tivo identical copper pipe loops with ead soldered joints, one brass tester, and one section of old lead pipe. Three weight loss testers were also inclucied for mensuring corrosion rates of steel, galvanized steel, and copper. A typical testing apparatus s shown in Figure E54. “The pipe-loop facility was installed dn the lower level of the Water Works Park ‘High Service Pump Station and operated from January to Novernber, 1993, After an initial period of passivation, water samples were collected on a weekly basis and analyzed for lead, copper ad zine. ‘The liter water samples were taken after the water had been in contact with the pipe loop materials fo 8 hours. This wes done to represent the fist-draw sampling, required by the LCR. Additional sampling included daily monitoring for pH, chem cal doses, and temperature. Disinfectiontoss were done quarterly. Favor profile analyses to assess any changes i ast of odors were run monthly Results of pilot testing indicated: «+ The inhibitor treatments, zine orthophosphate, and phosphoric acid are statistically better than the ‘untreated control for both old and new lead piping (Figure ES). + For lead solder and copper Piping the median lead levels were lowest in the water with inhibitors (zine Figure ES-5 Relative Lead Levels trom Lead Pine BH newtenu rhe by-products (DBP) and pipe insert weight orthophosphate and phosphoric sci), but only the phosphoric acid results were statistically better thant the other loops (Figure ES-6). «+ Forbrass, the results indicated that the treatments were no better than the control; however, lead levels ‘were near the detection iit in the ‘as testers (Figure ES) + Zine orthophosphate and ‘phosphoric acid were also found to hoe the most effective treatments in reducing copper (Figure ES-7) Figure E58, Relative Lead Levels trom Soldered Copper and Brass @ sutras cope Piet pveFigure E57 &, Evaluating Corrosion Relative Copper Levels trom Copper Pipe Control Treatment “The four corrosion contro! treatments tested i the pipe loops were evaluated based on the following criteria: «+ Performance for lead uptake reduction « Beasbility of implementation within regulatory and functional constain's « Reliability in terms of operational ' consistency and continuous | corrosion contsol protection + Cost | Pipe-loop data analyses indicted | onthophosphate and zinc orthophosphate ace rast likey to yield the best results OF jead reduction. pH adjustment was not as tfective fr lad control, Oxthophosphate and zinc orthophosphate were elective at reducing copper levels ‘A feasibility analysis indicated that industrial water users would be affected adversely by zinc or ahigher water PH Wastewater operations would be ad- versely affected by zinc and orthophos- phates loadings. There were no major vifects of corrosion control treatment on drinking water regulations. pH adjust ment could, however, decrease disinfec . tion effectiveness and increase DBP «+ DPBs were increased for the pl! acjustment treatments as expected "The DBPs formed asa result of this increase, however, did not exceed BPA-proposed limits, The = orthophosphate and zine formation. : ‘orthophosphate did nat increase ‘The reliability of zinc orthophos- DBPs. hate and sodium hydroxide chemicals is fess than would be expected for ortho- phosphates, Zine orthophosphate is & proprietary chemical wth prize and supply constraints. Sodium hydroxide availability end price depend on market conditions. Orthophosphate (phosphoric ‘cid) is available as a generic chemical and is commonly tse inthe food and bev=r + None of the cozrosion control treatments had an adverse effect on the taste and odor of the water produced.age industry; therefore, price and avail ability are more stable. From a WTP operations standpoint, pH adjustment is tess reliable because pI¥ can change with raw water quality and treatment conditions, “The chemical cost of each treatment alternative is shown in Figure E58. Phosphoric acid addition is Tess than half the cast of pH adjustment to 8.1, the next owest chemical cost. This represents a1 Figure 68-8 Troatment Alternatives Costs Note, henicl Cast Suan Poy ise Tama PO, wodgH st) 43m! Heo $0.24 Nae aon gt) 7.207 Heo $0.24 0, 123m PO) SIT PD lst HPO (ores Canta Trestnent { average cost savings of about $2400 per day. Phosphoric acid could save the DWSD about $10 million in present worth inthe next 20 years compared to the next lowest cost altemative. 4 Selecting Corrosion Control Treatment “The elative ranking of alternatives for the four criteria (performance, feasibi- ity reliability, cost is summarized in Figure BS-9. Values of 1 through # were assigned for each treatment alternative in each criteria category (L was best; 4 worst). ‘Because performance for lead reduction ‘was the main criteria it was given @ weight of 2 Each ofthe other criteria was given a weight of COrthophosphates were ranked highest overall. Zinc orthophosphate wes second, mainly because ofits adverse effects on industry, wastewater plant operations, and higher costs. pH adjust- nent was ranked lowest because itis les effective for lead reduction, less reliable, and demonstrates more adverse effects on industry and drinking water regulatory compliance. ——— Onthophosphates were selected a8 the optimal treatment alternative for full-scale lead corrosion control. —_—_ ‘Based on corrosion control theory, ‘comparison with analogous water $s~ tems, and the extensive pilot plant studies, osthophosphates were selected as the optimal treatment alternative for Ful seale {ead corrosion control. Brooitve SummaryEvaluation Criteria Phosphoric Acid Phosphoric acd is the recommended form of adding orthophosphate. tis @ generic chemical and can be bid compet tively. Tt does not add sodium tothe water and costs less than any other form of orthophosphate In addition, the Snshed water pH is already i the optimal range for ead solubility reduction by phos: phates, 6 pF adjustment isnot required “The recommended dose of phosphor rieacid is 12 mg/Las P for initial passiva- tion and a sustained dose of 4 mg/L a5 P formaintaining control of lead ptake, Values may be adjusted based on full-scale results. , Full-Scale Implementation “The LCR requires optimal corrosion control treatment installation by Jansary 1, 1997, To meet this deadline, the implemen tation scheclule in Figute BS-10 is pro- posed. The frst element of implements: tion is to conduct full-scale demonstration testing in the distribution system served 10 ocative Summary Tlaity wie! by one of the WTPs before installing chemical feed facilities in the other four plants. Operation of lead corrosion contro! facilises at all plants is planned for May 1996, This will provide additional time to optimize the system before [ead monitor ing is required in 1997. “The chemical equipment cequired for ‘each WTP is summarized in Table ES-1. A ‘schematic of a typical liquid chemical system is shown in Figure £5-11 _ The cost of lead corrosion control chemicals is estimated to be about $0.87 per year per household. oo “The estimated capital cost for cortosion control facilites atthe five WIP is $3,740,000. The estimated cost of chemicals is $868,000 per year. The cost of {ead corrosion control chemicals is est rated to be about $0.87 per year per household.Figure ES-10 Implementation Schedule 4. emanation Test 2. Predesion 2. Design 4.60 8, Award 6. coustrotion es Teves 8, startan 6. intial Song 10, rat ond Sonn reset ‘ a WL ian ‘A monitoring program will be fend reduction, such as removing lend established before and after corrosion. ‘service lines, will not be required. control treatment is implemented {0 {fthe lead AL is still exceeded after determine performance for lead reduction optimization and stabilization, & propre crc effects on other water quality pare fF ead service line removal should be vners, If lad is reduced to below the BPA developed in addition to an ongoing public ‘ALof0.015 mp/L for two consecutive edu program. raonth monitoring periods, other methods ease eee Gperation of lead corrosion contral facilities at all pants is planned for May 1988. oo roa 18 petal aso} am] [08 3-0Table E51 ‘chemical Equipment Summary ‘inten of fuk tanks Bulk tank capacity, each (gal) Naaher of day tanks Day tank capacity (gal) ‘Number of feeders Feeder capacity, each (ont) Lo Number of transfer pumps Yeansfer pump capacity each (gpm) ter Wo sommuost | Park water | N Water Plant | Pant TT ey 00 00 Figure ES-11 quid Chemical System Schematic ‘oouk Tok fvtboast. | Sprinqwets | Lake aro iota Pant | Water Plat | Vinton Plant Pe TysuRUOW 9! ef ee + odd St Teel sung - uel siquowg ee |e € aed yo Z661 306-A uaunesaL 30 pue Apmas ASMA syjuow 9] SE Ga Fe gad sy ‘Leer aung- “ver sinowa[ ee | te t adds Z66r 780i syuow gs] €E ee t add ve ‘goer 290 - Aint] aeah Tt ee, fe oO qdd ¢ ‘666r aun - ‘ues weakt, ee |e z oad Z Goae Wdas- 20 aeakt| ee ee 0 add py TooZ was - auny| ‘sean ¢| ee Ca t ‘gddy ‘Zo0e Was = sunt ‘sieak ¢| ee ee. oO qdd yt “S007 Yas - BUC seake|_€6 _| ee 0 ado gooz 3495- 9um| sueak€| &% G4 0 gddo THoe Was - sunt| an TR Pu TAH is WHRATEAIL PE SEIROS MON] ia Trae 20 apuyoun - camera \o})| peumnbeu | qd st anoge 1134 SUUONUOW| ponnbass_| sojduies | soyduns | sajdwes jo 104unN “Kreis Basouwo ainw Jadoo pue peor wi 30 AD]( STATE OF MICHIGAN. JOHN ENGLER, GOVERNOR DEPARTMENT OF PUBLIC HEALTH as N, LOGANIMARTIN [KING J BL JK 90105, LANSING, MICHIGAN 48902 Versioe Davie Aiton. DYEEtOF March 15, 1993 / city of Flint wSsN: 2310 Stol South Saginaw street Flint, Michigen 46502 * nbtention: Mr- Charles smith, Utilities superintendent 295 10991 subject: ead/Copper Monitoring Gentlemen: we nave reviewed the cemults of the second round of the Lead ang BGpper monitoring completed fon your water supply for the period of Soly 1, 1992, through od ford 31,1992. TRE Samp were JULY ced and analyzed to, comply ‘uth the U.S. Environmenta} corte ction agency's Lead and Copp. Rogulation. “The action Levels Bpecified in the regulation Require that the 90th percentile Speqits from the distribution Eyatem samples for lead and copper ret exceed 15 and 1300 ug/l, ‘respectively- since the 90th percentile Lead devel for your water system is 744 Ug/l, the lead action. evel of 15 ug/l has not been exceeded. 3905" the goth percentile copper’ Te Mas significantly below the Zopper action level of 1300 g/l. This means that your water System as met both action jevels for the first two monitoring periods. although many of the Detroit water end Sewerage Department (DwsD) aittomers have met the action Styels, DWSD is required to conduct custegy co decerine whether thot’ 1s rereatment processes can BS fmproved to further reduce y nGsion. The study is to be, ‘completed by duly 2, 2994, and any > Conmmenged treatment modifications must BY de piace by January 1, 1997.city of Flint Page 2 march 15, 1993 purther monitoring of Your, water system for Lead and copper will Burthe required until the gp sendy as complete, and Ay additional Eorresion control, iment has begun. We will inform you when fonitoring is again required. This may be a5 Tate as January 1997+ “rg you have any questions, please call me at (527) 335-8309. sincer! / oe ‘timothy A. Benton, pistrict Engineer Preision of Water SUPPIY piveau of Bnvironmentat and ‘oceupational Health AB? im TAD?ST on weisenberger Wate plant supervisor Sci Geneseo County Health DepartmentRennaker, Joanne (DE From: Busch, Stephen (DEQ) Sent: ‘Monday, August 17, 2015 2:36 PM To: Wurfel, Brad (DEQ) ce $yg0, im (EQ), Benzie Richard (DEQ cook, Pat (DEQ): Prysby, Mike (DEQ Rosenthal pine (DEQ) Palone, Maggie (DEQ Shekter ‘smith, Liane (CEQ) Subject: flint Lead Monitoring Letter ‘Attachments: City of Flint PPCULS 8.17.15 pdf Brad, ‘as there has been much interest regarding Jead related to Flint drinking water, | have attached our latest letter which overs the most recent January ~sune 2045 vnonitoring period. The City isin compliance with the 15 part per billion coton level for lead. Yet based on these results, he treatment cannot be deemed to provide fully optimized corrosion control treatment, and the city will need (© nent additonal treatment to achieve this ‘optimization under the Lead and Copper Rule requirements, wees ihiched under the Michigan Safe Drinking Water ‘Act, This is all spelled out in the attached letter. ityou have any questions or would ike any adaitional information you may contact me at the number below. Stephen Busch, P.E. MDEQ Lansing District Coordinator Difice of Drinking Water and Municipal Assistance tansing and Jackson District Supervisor 517-643-2314 buschs@michigan.2ov[LANSING DISTRICT OFFICE rare oF MICHIGAN Se DEPARTMENT OF ENVIRONMENTAL QUALITY ck SNYDER DAN WYANT ‘GovErNaR RECTOR August 17, 2015 Mr, Brent Wright City of Flint - DPW Flint Water Plant ‘4500 North Dort Highway Flint, Michigan 48505 Dear Mr. Wright: SUBJECT: Flint, City of ssn: 02310 Lead and Copper Monitoring of ‘Drinking Water Taps (DEQ), Office of Drinking Water and Municipal -The Department of Environmental Quality ‘od January 4, 2018, through asistance (ODWMA), recelved Your report for the monitoring Perl ‘June 30, 2015. Feaulls this monitoring period. Fal Samples Above ” # of Samples ation Level Required Toad 15 parts per billion (op) Copper 1.3 paris Per Ninety percent or more of the sites you tested are within action Jovels under the administrative Mies promulgated under the Michige® sorte inking Watar Act, 1976 PA 390, 6 amended {Act 389). These results must Ibe reported on your-2015 Consume Confidence Report (CCR) ue to our office, your customers, rep the local health department, BY ‘July 1, 2016. Also tude the following statement inthe ‘GOR, regerdiess of the lead anc copP! levels: In present, olovatodlavels of fad can 5 serious health probloms, especielly For ent women ard young CGror asd in drinking water is primarily from materials progremponents associated wit Sonne a and home plumbing. me City OF Flint is aesponsfle for providing high quali minking water, but cannot control tra variety of rotate used in plumbing components Giieen your water fas beer siting for ‘several meter you can minimizo te potently Or eee aposuro by fushing you tp for our Je to 2 minutes before using Weter for arinking or cooking. If you are concerned se00tt pad in your water, you may Wan ‘rave yourwater tested. information °” lead in ating water, testing methods, and She you ean take (0 minimize exposure is grape trom the Safe Drinking Water ‘Peitine al 1-800-426-4791 or at http:/urwc water. ep “arinkdinfofioad. const Ts ONHAL +426 WEST ALEGANSTRESE ‘pox sda LANSING, MOHGAN 48606°7742 wanegan govhleg “(81775986070Mr. Brent Wright 2 August 17, 2015 recent changes to the Lead and GOPPE ufo (LGR) require the water SUBPY to provide | Reeidual lead tap resulls to peore Per Tecalve water from sites that Were ‘sampled, even if indi was not detected, within 20 days re Foaming of results. You must eo, send us leat Jeaton that you metal the deers requirements along with a ‘sample copy of You certfomer notice by three martns at road ofthe monitoring period. To ‘download the Lead format, visit hitpsinww.michigan.govided “Click on Water, Drinking Water, ‘Gommunity Water Supply, and Reporting Fons, ager the Manuals, Forms and Brochures heading. Water ‘supplies that fall to di ti Recalls must include the folowing Statement in their CCR, “During the year, We ‘sons served at the sites that were tested 8s Touired by the Lead and Copper Rule.” White the City's LOR compliance monitoring has continued to mary action level requirements, Wea GR also requires all large Syston ithase serving over $0,000 people) to optimize corrosion control regardless “Sr trelr 90th percentile lead ‘congentration. One way t0 Gemonstrate fully optimized Corrosion control treatment Is through two consecutive ht month TOR compliance monitoring in Mvaich the difference between the ‘goth percentile level | 2 tr iead concentration 18 loss thar’ et racical Quantitative Level for $254 (0.008 mailigrams perlite. ‘Since the City aid not meet hess criteria in both the July — Bebember 2074, and January = June S016, sampling periods, the City ‘must now recommend @ Pestient to fully optimize corrosich © Zniral treatment within sie months in accordance with fequirements under Act 399, ‘administrative Rule GO4t (R i SH opodi). This recommendation reilst be provided to our office a8 Srer.as possible, but no later than ‘January 1, 2016. | However, given the past use of phosphate treatment by the Detroit Water and Sewerage | Department (DWSO) t0 fully ‘optimize corrosion control ‘reatment when the City Was ‘wholesale Satiomer of DWSD, the OWN. vee ommonds the City seleat this 2 its recornmended treatment option, and begin implementation a8 S000 AS possible to address ongoing ‘concerns by customers rogarting lea eels within thelr premise Pluribhg Systems. Under the seoond step of this Rule, the DEG 69h specify optimal corrosion control treatment. our office wil inform you when monitoring needs to be conducted as part of the optimization of | the implemented corrosion ‘control treatment. Customer Tequested samples for lead shall ! Continue to be caliected and ‘analyzed. Please make every iempt to select the same sit°s ' teed in the previous monitoring partied, giving Tier t ses tet priority. tf original ses a> Lee alable, select roplacement stss ‘hed on the Tier 4, 2, and 3 cnteray Please contact me at 517-284-6844 oF rosenthala@michigan.gev at your earliest convenience reget ase how the City wil be comping Sth the above requirements Sincerely, LE Mojo Lt aad ‘Rosenthal, Environmental Quality Analyst ‘Lansing District Office Office of Drinking Water and ‘Municipal Assistance cq; Mr, Michael Glasgow, Clty of Flint