Flint Water: A Political Football. Part 14

Let's look at the Veolia report a bit closer.

In a previous post, I indicated that this date was important:

• February 18, 2015  The City of Flint tests the drinking water at the Walters residence. Tests reveal high lead in the drinking water (104 ug/L)
• February 18, 2015 Rob Nicholas, vice president for Veolia, states in a news conference that "(The problems) are less about the water itself and more about the (transmission pipes)." [source]

How unfortunate. Violia is there in Flint and was hired by Flint for their expertise:

Veolia appreciates the City’s decision to seek independent third parties to review current treatment processes, maintenance procedures and actions taken to date, and provide ideas for improvement. We are pleased to present this final report to the City of Flint following our experts’ 160-hour assessment of the water treatment plant, distribution system, customer service and communications programs, and capital plans and annual budget

One of those "ideas for improvement" was this:

Increase of Ferric Chloride – Four coagulants were tested by Veolia -ferric chloride, ferric sulfate, polyaluminum chloride (PACI) and aluminum chlorohydrate (ACH). Ferric chloride and ACH were found to be the best choice of product for effectiveness in removing TOC, a precursor to TTHM formation. 

I wrote about the addition of Ferric Chloride causing problems in this post.

March 2015: The City of Flint increases the Ferric Chloride dosage used in the filtration process to improve the removal of disinfection byproduct precursor material, in an effort to lower the TTHM levels.

...my research found this:

In practical case studies, coagulation with a chloride-based coagulant (e.g., ferric chloride) tended to increase lead leaching from simulated copper joints... 

...which is probably why on:

March 03, 2015: The City of Flint re-tests lead levels in drinking water at Walters’ residence. The lead level measured is 397 ug/L (ppb).

But that's not really the issue I want to point out. Remember why Veolia was hired, and remember what they said. They (Veolia) recommended using Ferric Chloride, which the city did. Veolia also provide warm fuzzy pats on the behind for everyone:

From our review, these numerous efforts demonstrate how the city is trying to be transparent and responsive beyond what many other communities might do in similar circumstances. 

Remember what was known about lead in two samples on Feb 18th and March 3rd. Remember who took those samples (the City of Flint).

Now read this from Veolia's report:

The City should be congratulated on its efforts to keep the public informed. It is posting its monthly reports on the web page to provide transparency, though these reports are highly technical – and may be too technical for the customer base at large

No one would have known about those lead results had it not been for the Del Toral EPA memo.

Those lead results were known by the city at the same time Veolia was there. In Veolia's own words we are told this:

It is our desire to help Flint residents and public officials better understand the current situation so that informed decisions can be made to ensure safe drinking water for the city’s customers.

Now go back and read their March 12th report. I'll wait.

Notice what's missing? Now go back and do a search for the word "lead." I'll wait.

Did you find what's missing?

Now go back to February 18th's news conference when Rob Nicholas, vice president for Veolia, says this:

"It's less about the water itself and more about the pipes," he said. "You're just getting debris flushed out of the pipes ... You don't want to drink it because it looks bad."

In my view, you cannot point the finger at one person and say; 'that's him! that's the culprit!'

This is a collective failure of those in the know and those with decision making responsibility.

It's not the using of Flint River water that was a bad decision, it was the failure to have in place what would be needed to treat that water. This was, in my opinion, ground zero for what I consider a failure that cannot be spun away with hindsight.

Once the spigot was opened it was doomed to fail because they had not put in place what was needed to properly treat the water. I have shown that in these last posts so my SPECULATION is supported.

Once it was found to be failing, the spin train started and the failures started piling up:

1. Veolia failed the City of Flint by not addressing the lead that was detected in the Willams' home.
2. Veolia failed the City of Flint by not addressing corrosion control as it relates to the issue of lead. The only recommendation for corrosion control was that "the water system could add a polyphosphate to the water as a way to minimize the amount of discolored water."
3. The City of Flint failed by not reporting the two lead results from the Williams home. This did not keep the "public informed" and this did not "provide transparency." 
4. The EPA failed when it failed to address the lead found at the Williams' home and addressed by the EPA's Del Toral, telling those wanting an answer on safety that “it would be premature to draw any conclusions” 
5. The MDEQ failed by issuing all sorts of statements telling the public everything was okay and those that said there was a problem were out for some agenda. For example: "The connection between water and blood is there's other sources of lead getting into kids' blood. Historically lead has represented approximately less than 20 percent on the average of lead found in kids' blood as the source...it's not the big source historically.
6. The Mayor of Flint failed when he drank the water to prove it was safe.
7. The MDHHS failed when it did not look at the blood-lead levels in children by zip code and then criticized the work of a doctor who did trying to discredit her.

I'm sure you can come up with a whole bunch more. So I guess to put an end to these 14 posts I need to kind of end with a summary.

Here is the lesson I take away from all of this.

When there is a change from the norm, you need to be observant to ensure that the change has not created any problems.  Just like organic kitty-litter is kitty-litter, it is fundamentally different from clay kitty-litter.

Same goes for water. In the case of Flint all eyes should have focused on lead leaching out once the corosivity of the Flint River water was known to be an issue due to the age and condition of the water system and the homes it fed. At that point, the MDHHS should have been looking closely at blood-lead levels in children under 5 years of age and the MDEQ should have been out there testing for lead.

Lead was a real hazard to the public if it was leaching out due to the corosivity of the water.

So the takeaway from all of this is that when treating water to be used for drinking, its all about the water chemistry.

Flint is a casebook study of what not to do with drinking water.  But in case you have forgotten:

Thanks for reading!

Jeff

Flint Water: A Political Football. Part 13

Lucky number post 13!

If we take out hindsight, what are we left with?  Incompetence? Willful disregard? Apathy?

Those words really don't fit well here, although they do - pardon the pun - contaminate what went on.

As I see it, and this is after a week of looking at all the stuff I could find (so take that into consideration regarding how much stock to put into my opinion), what took place in Flint was a snowball that got bigger and bigger as it rolled down the hill.

So if we look at it like a snowball, the question to ask is who - or what - started it down that hill?

I SPECULATE that it was the result of a decision to use Flint River water with the knowledge that it would be difficult to treat but with the assurance that it could be treated.

The problem is, as I pointed out in my last post, is that thinking was folly.

The City of Flint, as was documented in Veolia's March 12, 2015 report clearly identifies the lack of treatment capability and knowledge on the part of the city. They did not have the monitoring equipment to confirm the water chemistry was correct and they did not have the trained operators that understood how to treat this particular water.

They knew, before they made the switch to the Flint River, that the water would be a challenge. They knew this but did it anyway. They were told it was a bad idea, but went forward anyway. Why?

SPECULATION It was money that made them ignore the negatives. If you look at the projections of cost savings to use the Flint River in place of continuing to use Detroit water during this gap in time, you can see how it most likely became 'damn the torpedoes! Full steam ahead!' by those in charge.

Was it the Governor who made this call? Does it matter? If one person can overrule all the others who have responsibility; the health department; the environmental department; the engineering firms; the water operators; the mayor, the city council, the people...then we have a serious problem with how we govern.

If it wasn't the Governor and it was that unelected emergency manager assigned by the Governor, we still have the same issue. Someone overruled the technical people telling them what it would take and that it was a bad idea.

...or all those technical people were incompetent, or on the take, or wanted to promote genocide, or wanted the Republicans/Democrats to look bad.

You see where this goes?

SPECULATION It was the cost savings that put the Flint River as the gap water source in play, and everyone who opposed it got on-board because of who was on-board. Groupthink took over because of the players at the table.  Each one said their concern, and then gave their approval with the understanding that those concerns would be taken care of.

If everything went as they planed it, it would work.  Its water afterall, we treat water all the time from many different sources and make it into drinking water. We knew it would be hard going in, but golly we can do it!

On June 29th 2013, following many preliminary discussions on how the City would fill the interim gap, a formal, all day meeting was held at the Flint Water Plant with all interested parties including City of Flint Officials (COF), representatives from the Genesee County Drain Commissioners Office (GCDC), the Michigan Department of Environmental Quality (DEQ), and the design engineers from the previous plant upgrade Lockwood, Andrews, and Newnam (LAN).

Everyone was there. See! Look at what we discussed!

Source

It all sounds good when in an air conditioned room. This ship done sailed and it was going to be up to the Flint Water System employees to make it work. Go for it guys!

SPECULATION Somebody done messed up! Who? All of them.  Groupthink took over because the guy in charge said we are going to use Flint River water, make it work. And they did...on paper.

These facts were balanced against a licensed staff, LAN engineering’s extensive experience in this field, advanced equipment that Flint has for treatment, and support from the DEQ.

Snap back to reality. Oh, there goes gravity...

...the same diligence was given in determining what source water to use while waiting for the community supported KWA water to arrive. The City concluded from this work that the Flint River presented a safe and financially responsible alternative water source.

Yes, but you did not finish it.  You opened up that spigot and you did not put in place the operators, monitoring, and sampling protocol needed to do what you wanted to do. You claim you had it all figured out, but reality says differently.

It was a safe alternative only if you made it a safe alternative. That did not happen.  That's not a hindsight problem, that's a failure to follow through problem. Who's fault is it then when the response is:

The decision to use the Flint River as an intermediate water source was approved by state regulatory officials in 2014...

LAN engineering’s extensive experience in this field...

The DEQ requires...an F-I state licensed operator in charge that oversees the operation of the treatment process. This license is the highest classification in the state that specializes in “complete treatment” The City of Flint has such a person on staff at the water plant and that person’s responsibility is to determine the correct levels of chemical treatment, monitor the system, submit official test results to the state regulatory agency, and make necessary adjustments when contaminant levels are breached. All of these steps were followed and acknowledged by the DEQ.

See, everything is in order.  That's January 13th, 2015.  Now look at what Veolia tells us in their report dated March 12th, 2015:

The February 2015 report from LAN...indicated apparent reasons for the elevated levels of TTHM in the distribution system. Obtain a THM Analyzer and Carry Out Jar Testing.

That should have been in place on day one.  In March, 2015 Veolia recommends:

The staff understands the basic treatment process but needs further practice and training to become proficient in the use of routine process control to adjust for water quality.

The amount of testing and resulting changes in chemical dosages, along with monitoring the impact on the water, will require a well-documented process that all operators follow. An example of this is jar testing, which is used by the operators to identify the most effective chemicals and dosages to optimize treatment.

Standard operating procedure needs to be set and lab technicians trained in that process.

 ...should also consider a TOC analyzer that can be an online continuous device to provide immediate information on influent and effluent levels of TOC. 

Do I need to say it again? This should have been in place when the Flint River spigot was turned on.

Reading the Veolia report does bring up some interesting questions as to how much was said and how little was done.

Next post: Flint Water: A Political Football.  Part 14

Flint Water: A Political Football. Part 12

Speculation: The Flint Water System was not set up to treat drinking water, especially the type of water, with its wacky water chemistry. They lacked the knowledge, the chemistry, and treatment prowess necessary to get this done in 10 months when the Flint River spigot was turned on.

Can that be supported?

Let's look at this.

• April 25, 2014: Pipes carrying Flint River water are opened; the Detroit supply is shut off.

• February 18, 2015  The City of Flint tests the drinking water at the Walters residence. Tests reveal high lead in the drinking water (104 ug/L)

That Feb 18th date is critical on what was known by whom and when.  Look what also happened on February 18th:

"The city has reduced levels of TTHM, and now all (testing) sites are in compliance," said Rob Nicholas, vice president for Veolia, the consultant that city officials introduced during a news conference just last week. "(The problems) are less about the water itself and more about the (transmission pipes)." [source]

Who or what is Veolia?

Veolia is the world's largest water services and technology company. Its team started work in Flint last week and is being paid $40,000 to assess how city water is tested and distributed, including water treatment processes and operations, laboratory testing and analysis. [source]

"Last week" would have been around February 11th. The Flint River water has been flowing into the Flint Water pipes now for around nine months.  The City of Flint now brings in Veolia to report on whats going on. Here is what we are told on March 12, 2015:

The City of Flint has made a number of good decisions regarding treatment changes that have improved water quality. However, this is a very complex water quality issue and the City is seeking additional advice on what to do to ensure healthful drinking water for the community.

Let's look at this change described in Del Toral's EPA memo:

• March 2015: The City of Flint increases the Ferric Chloride dosage used in the filtration process to improve the removal of disinfection byproduct precursor material, in an effort to lower the TTHM levels.

• March 03, 2015: The City of Flint re-tests lead levels in drinking water at Walters’ residence. The lead level measured is 397 ug/L

You do see the dates, and you do see the findings, correct?

The review of the water quality records during the time of Veolia’s study shows the water to be in compliance with State and Federal regulations, and, based on those standards, the water is considered to meet drinking water requirements. [source]

Consultant speak for 'WE never said it was safe...'

But I digress. Can I support my speculation that the City of Flint, a purchaser of treated water for many years, was in no way, shape, or form to treat water being pulled from the Flint River. All of these issues can be blamed on the decision to use Flint River water without an adequate understanding of not just how to treat it, but having the ability, know-how, and understanding of how to treat that water.

Let me show you exhibit one from the Veolia report:

The amount of testing and resulting changes in chemical dosages, along with monitoring the impact on the water, will require a well-documented process that all operators follow. An example of this is jar testing, which is used by the operators to identify the most effective chemicals and dosages to optimize treatment.

No jar testing kind of means ya aint ready for water treatment.  Its kind of like not having a pipe wrench when you call yourself a plumber.

The staff understands the basic treatment process but needs further practice and training to become proficient in the use of routine process control to adjust for water quality.

Flint River water was way beyond 'basic' treatment.

...that a desired water treatment quality is defined and variations from it signal alarms and that the staff knows what to do when the water quality setpoints begin to drift away from its desired quality levels. 

Figuring this out 10 months into the use of the water is...well...a sign that you ignored the folks telling you not to go this route.  Flint was not ready to treat Flint River water. I think if you ask enough people that were present during this discussion, you will find this was known at the time but ignored by a higher up. Once that happened everyone falls in line, gives their tacit approval while holding up their proof that they tried to let them know.

But the engineers agreed to it! Yeah...just like they did with the Challenger disaster.

Okay...so file this one under my pipe wrench analogy as well:

The City has already purchased a TTHM analyzer but should also consider a TOC analyzer that can be an online continuous device to provide immediate information on influent and effluent levels of TOC. 

Really...and you call yourself a drinking water producer?

And now, exhibit two!

A good demonstration of skill level is for the staff to become certified by the State as a licensed water plant operator. Many utilities now require all operators to hold at least the minimum certification level as a starting point and offer incentives to increase their certification level.

So...they had no certified staff responsible for treating this water?  They did not understand this skill level when they decided to treat the Flint River water?

How we got to today is a decision to treat Flint River water without the capability and knowledge required to treat it.

SPECULATION: Someone brought this up to the folks in charge at the appropriate time. I guarantee it! Someone told them it was going to be a problem and what those problems would be. Someone - or a bunch of them - understood the water chemistry issues.

Next post: Flint Water: A Political Football.  Part 13

Flint Water: A Political Football. Part 11

So what's it all about Alfie?

Ready for some speculating? Because that's where this here post is going to go.

How did this happen, not how as in they used Flint River water, duh! Or its because they were run by Democrats, or because of genocide.  All of those are put out there as theories, but they really can't explain the "how."

Let's start with this document:

...in particular Question 5's answer.  The question is not important, nor is the contaminant.  What is notable is this part of the response:

What we discovered is that as water travels through the 600 miles of the City’s distribution mains it will, at times, reside in the system for up to 3 or 4 weeks. Water purchased from [Detroit Water and Sewerage Department] DWSD is drawn from Lake Huron, chlorinated, and then travels over 80 miles to reach the City. By the time the water reaches Flint it is stable and capable of withstanding this type of residency time within the system. Water drawn from the Flint River, specifically in summer months when the temperature is fluctuating, is more susceptible to being impacted by variables such as high residency times and increased chemical reaction.

It's all about water chemistry and they were unprepared to handle it. Now let's go back to the decision to use the Flint River as their water source.

On March 25th 2013, after evaluating cost comparisons for a permanent water source approv[ed] a resolution to purchase water from the Karegnondi Water Authority (KWA).

This is important to understand,  Before the Flint River was used as the water source, the city of Flint purchased water from the DWSD.  The resolution passed was to start purchasing the water from KWA.

The word to focus on is purchase.

On April 17th, 2013 DWSD sent a letter terminating the existing water service contract between the City of Flint and Detroit.  With the termination set to take effect 12 months later on April 17th 2014, a gap was created between the end of the DWSD contract and the start of the KWA.

This "gap" is where the problem began.  Their answer, to use the Flint River, was the wrong decision to make.  Not wrong in hindsight, but wrong because of that word "purchase" used previously.

On June 29th 2013, following many preliminary discussions on how the City would fill the interim gap, a formal, all day meeting was held at the Flint Water Plant with all interested parties including City of Flint Officials (COF), representatives from the Genesee County Drain Commissioners Office (GCDC), the Michigan Department of Environmental Quality (DEQ), and the design engineers from the previous plant upgrade Lockwood, Andrews, and Newnam (LAN).

We learn this from a deposition on an unrelated issue:

Ambrose [Flint's financial manager] testified under oath in 2014 that Kurtz [Flint Emergency Manager at the time] considered using water from the Flint River for the city’s drinking water, but rejected it after consulting the Michigan Department of Environmental Quality. The plan was found “not to be feasible,”

That took place in December of 2012.  Here is where it gets good...

“Who determined it wasn’t feasible?” the attorney asked. 

“It was a collective decision of the emergency management team based on conversations with the MDEQ that indicated they would not be supportive of the use of the Flint River on a long-term basis as a primary source of water,” replied Ambrose.

“What was the reason they gave?” asked the attorney

“You’ll have to ask them,” Ambrose replied.

On June 29th 2013 to April 25th, Flint needed to switch from a purchaser of water to a treater of drinking water. That's 10 months to build the capacity - both in capability and structure -to treat drinking water.

Why is this problematic?  Let's look at this May 2013 report from their neighbor, the City of Cleo, who is also a purchaser of drinking water.

Water systems who purchase drinking water don't treat water.  They pass it on, make sure they monitor it, and, for the most part, set it and forget it.  The job to treat and make sure it is safe is the producer of the drinking water, which was Detroit for many years..

Speculation: The Flint Water System was not set up to treat drinking water, especially the type of water, with its wacky water chemistry. They lacked the knowledge, the chemistry, and treatment prowess necessary to get this done in 10 months when the Flint River spigot was turned on.

They were aware of the need to do so, it appears:

It was understood that the Flint River would be subject to temperature variations, rain events, and have higher organic carbon than Lake Huron water and would be more difficult to treat. These facts were balanced against a licensed staff, LAN engineering’s extensive experience in this field, advanced equipment that Flint has for treatment, and support from the DEQ.

 In hindsight that was underestimated and in my opinion folly to think they could.


Next post: Flint Water: A Political Football.  Part 12

Flint Water: A Political Football. Part 10

I looked at Marc Edwards' numbers and did some calculatin'

Source

Here is what the Virginia Tech Research Team tell us:

Over the weekend, we analyzed all samples shipped to Virginia Tech from Flint to date. Flint residents have already returned an astonishing 84% of the sample kits we sent out (252 out of 300 samples). 

The protocol they used can be found here:

Students and scientists (see About Us) at Virginia Tech assembled and shipped 300 kits for Flint residents to sample their water and get it analyzed for lead. The kits comprise of three bottles (1L, 500 mL and 250 mL ones) and an instruction sheet for sampling tap water. All 300 kits were sent out August 14th (Friday) and reached Flint on August 19th (Wednesday). 

The Excel file I downloaded,  Flint-Samples-FINAL.xlsx, contains 300 sample points (I am kind of confused as to why this number does not match with the statement above) from which three samples were collected at each point:

• Pb Bottle 1 (ppb) - First Draw
• Pb Bottle 2 (ppb) - 45 secs flushing
• Pb Bottle 3 (ppb) - 2 mins flushing

The average lead concentration reported on the sheet for the first draw is 10.646 ppb.  I took all these sample results and recalculated using Excel's statistical function and I got the same number.

I then looked to see what the largest number reported was for each of the three sample columns. With this many sample points you can see a trend.  Since these samples were collected by the homeowners, the possibility of human error in sampling bottle identification is high.

That being the case, I felt that three samples were incorrectly identified, so I removed them from the rest of the data points.  This left 297 sample points from which to run some calculations.

What I wanted to see was if there was a difference between the first draw and a flush.  The problem with this data as presented was that sample 97 reported results in this order:

1. 7.244
2. 1051
3. 1.328

It is possible that 1051 ppb is a legit number, but it appears doubtful that the 45 second flush would produce such a high number when the first draw was only 7.2. Additionally, this one numbers skews the results for the 45 second draw too much to make a comparison between first draw and flushes appropriate.

Removing samples from the data is a judgement call, and I think I can justify removing them in an effort to get a truer picture of what is going on.  I also removed samples 258 and 24 because I think they are in the wrong order - their removal changes the average but still shows a drop in lead when a flush was used.

So here are my results.  For 297 sample points:

As you can see, there is a reduction in the amount of lead found in the 45 second sample and even less in the 2 minute flush sample.  This supports the contention that the flushing requirement Flint was having the homeowners perform to meet the Lead and Copper Rule was most likely under reporting the lead.

What's important here is to not get caught up in the averages. This data came from a mix of homes in Flint.

Flint’s non-profit group Water You Fighting For? is helping coordinate distribution of these kits to volunteering homes 

There are, as the Williams' sample results showed - when compared to their neighbors -, houses within Flint that are more impacted then others.  

There is overwhelming evidence that there is lead present in Flint's water and it is higher in lead than water produced by Detroit.

Response:  We coordinated a citizen sampling event of homes in Detroit during 2010, and confirmed that Detroit water met Federal Standards—Flint’s water does not. 

What is more telling as to the extent of the problem is the spike in elevated blood-lead levels that I wrote about in my last post.  Exposure is problematic, uptake is worst when you know it has happened, but proof of an elevated level found children under five...well that's pretty damning evidence that you have a problem.

So what can we take away from all of this?


Next post: Flint Water: A Political Football.  Part 11

Flint Water: A Political Football. Part 9

How about some data from a non-governmental source?

Sept. 24-25, 2015: A group of doctors led by Dr. Mona Hanna-Attisha of Hurley Medical Center in Flint urges the city to stop using the Flint River for water after finding high levels of lead in the blood of children. State regulators insist the water is safe.

Here is how this played out:

In August, Hanna-Attisha looked back at the lead tests of 1,750 children taken at a local hospital. She and colleagues released the results at a news conference in September.

Her findings:

“We found that when we compared lead levels before and after the [water] switch, the percentage of kids with lead poisoning doubled after the switch,” she said last week. “In some neighborhoods, it tripled. And it all correlated with where water lead levels were the highest.”

And the state's response to her work:

State officials questioned the findings and accused Hanna-Attisha of causing unnecessary hysteria. The state has since agreed that her data were accurate.

Let's look at her work and judge it for what it shows.

What's interesting here is that she asked a question that should have been obvious to the MDHHS.  Was there a difference between children's blood-lead levels (BLL) before the water change and after.  And more specifically, in zip codes where the leaching of lead would most likely take place.

You can look at her presentation here.  I am going to showjust her methodology and findings below.

First, her methodology:

She looked at the same period of time, pre-switch and post-switch. Was there a statistical difference between the period pre-switch and the same period post-switch?

Her analysis of the BLL data pre and post-switch shows affirmative. Before the switch 2.1% of the children in those zip codes in Flint had elevated BLL.  After the switch it was 4%.  That's a pretty good indication that the water is the culprit.

But wait a minute.  Maybe its not the water and something else going on! Okay, fair question. How about we look at the children in that immediate area, but not in the zip codes where they used Flint water.  If we see an increase in their elevated BLL then we can rule the water out as a soul source contributer. Does that sound reasonable?

No statistical change.  What happens if we look at the BLL of children where Marc Edwards found elevated levels of lead above 15 ppb in the tap water samples they took? We'll call that data "High-water lead."

Putting it all together we get this:

Just in case you have had enough of the "golly we goofed" quotes, let's look at this talking point prepared in November 18, 2015 by the MDHHS:



And y'all never saw a reason for this level of testing while all this was going on?

But you did see a reason to question Hanna-Attisha's data on September 25th, correct? From an email for Gerlyn Lasher with MDHHS to the Governor's chief of staff Dennis Muchmore:

Notice how he put the quotes around the word data?

On October 2nd we get this statement from MDHHS Director Nick Lyon in the Governor's press release:

State health experts said there has been an increase in elevated childhood blood lead levels in some specific communities. Initial analysis of MDHHS data found that blood lead levels of children in Flint have followed an expected seasonal trend. While this analysis for Flint as a whole remains true, a comprehensive and detailed review brealking down data by ZIP codes with the city revealed that MDHHS data is consistent with a study presented recently by Hurley Children's Hospital.

Look everyone, we found the same thing! Dr. Lyon continues:

"While we cannot conclusively say that the water source change is the sole cause of the increase, this analysis supports our efforts as we take active steps to reduce all potential lead exposures in Flint," 

Dude, give it up...its the water.

Let's take a look at Marc Edwards' data next.


Next post: Flint Water: A Political Football.  Part 10

Flint Water: A Political Football. Part 8

September 24-25th:

A group of doctors led by Dr. Mona Hanna-Attisha of Hurley Medical Center in Flint urges the city to stop using the Flint River for water after finding high levels of lead in the blood of children. State regulators insist the water is safe. [source]

On September 25th we get the "political football" email:

The DEQ (Department of Environmental Quality) and DCH (Department of Community Health) feel that some in Flint are taking the very sensitive issue of children's exposure to lead and trying to turn it into a political football claiming the departments are underestimating the impacts on the populations and particularly trying to shift responsibility to the state," said Muchmore. [source]

All of this data coming in and the MDEQ and the MDCH - the agencies with public health responsibility - tell the Governor's man that it ain't their fault.

The wheels have come off and they all know it.

These dates on the timeline are when it can reasonably be assumed that it is known.  It would be very odd that before that date parties that have something to do with this issue had no idea what was being looked at.

So let's look at blood-lead levels.

Before I knew about the work of Dr. Hanna-Attisha, I saw this table in the Detroit Free Press:

Detroit Free Press

When I saw this I thought, 'well there is not a difference between 2014-2015 when the water was from the Flint River and 2012-2013 when the water was from Detroit!'

That's what I saw. That's what I see. And I was told this by the MDHHS:

Michigan Department of Health and Human Services spokeswoman Angela Minicuci told the Free Press on Thursday that the increase was "seasonal and not related to the water supply."

Look at the graph MDHHS provided in September:

September 2015

This graph looks at the number of children with elevated blood-lead levels (EBL) per quarter.  .

I have looked at the data the MDHHS provides and I cannot make anything out as bad.  Maybe I am missing it, but what they provided does not indicate a problem.  And that, could be why they did not see it. The data is in there, but it is covered up and not obvious.

"This is definitely being driven by a little science and a lot of politics," Wes Priem, an Industrial Hygiene Manager with the Healthy Homes Section of the Michigan Department of Health and Human Services, said in September 2015.

That's an interesting quote and tells you where there conventional wisdom was coming from.

In preparation for a late-September 2015 press conference and in response to data released by Edwards, Michigan Department of Health and Human Services Director Nick Lyon emailed fellow staff, "I would like to make a strong statement with a demonstration of proof that the lead blood levels seen are not out of the ordinary and are attributable to seasonal fluctuations."

On Thursday night, I shared this thinking as well.  But then I got some data...

"It wasn't until later that MDHHS epidemiologists took a more in-depth look at the data by ZIP code and confirmed an increase outside of normal trends,"

December 2015

The graph presented in December it looks at the incidence of EBL per quarter and looks at it based on zip codes.  This removes the noise generated from all the other data points so you can see there is a significant spike.  To be honest, these graphs are all over the place, but they do show similar peaks and valleys.

Still...

January 23, 2016: The Michigan Department of Health and Human Services' own review last July showed a spike in blood-lead levels in Flint children in the months after the city switched its water supply to Flint River water. "If I knew then what I know now ... We needed a much more robust analysis," Dr. Eden Wells, Health and Human Services' chief medical executive, said Friday.

Which brings me back to looking at this in contexts, as a whole. New water source, complaints, EPA Del Toral memo, lead found at the Walters home, Walters' kids with an increase in blood-lead levels.  What more do you need to see to conclude that a closer look is necessary?  that's not hindsight in my opinion.

"We should have torn it up and apart and gone up and down with that (data). That wasn’t done. "When I think about how Flint citizens have just had one thing after another — not just over the past two years, but many, many years — I wish that was not a missed opportunity." [source]

There seems to be a lot of "golly, if I had only known!" coming from Michigan's governmental agencies responsible for protecting public health.

Enter Dr. Mona Hanna-Attisha of Hurley Medical Center in Flint.

 Next post: Flint Water: A Political Football.  Part 9

Flint Water: A Political Football. Part 7

On our timeline we are a "T = September 21, 2015" and the MDEQ and the city of Flint are still acting as if there isn't a problem.

On September 9th, Marc Edwards with Virginia Tech writes an email to the mayor of Flint, Dayne Walling:

I understand how you could have been misled. All I can tell you, is that from a scientific and engineering perspective, everything in Mr. Del Toral’s memo was 100% accurate. I verified many of the facts personally myself.  The rest is perfectly obvious to someone with any reasonable training and experience in the field.

I too could not find anything wrong with EPA's Del Toral's memo.

I am sorry that MDEQ did not take his memo seriously, and that they did not cause the City of Flint to consider corrosion control from the start of this process. It was their job to do so. I have no idea what MDEQ’s agenda is, but based on their press releases and actions to date, protecting the public and following Federal laws, does not seem to be a priority.

Remember that "primacy" thing I wrote about? That's my contention as well.

The mayor then sends an email that very same day to Susan Hedman with the EPA about Marc Edwards' recent findings:

September 10th we get this bit of news:

The EPA said that while city water is within allowable levels for lead, it has "recommended that Flint implement corrosion control treatment as soon as possible since the city's lead service lines can leach lead into the drinking water if left untreated."

  From that same news article we learn this:

Virginia Tech students and faculty have posted the results of 252 water tests from Flint online, concluding the city has "a very serious lead in water problem."

The Virginia Tech testing so far has shown 10 percent of the water samples from across the city tested at 25 parts per billion of lead or more -- far more than the allowable level -- 15 ppb -- set in federal guidelines.

Overall, the Virginia Tech testing showed 16.7 percent of Flint samples showed more than 15 ppb of lead.

And...

Meanwhile, the city's official test results show 90 percent or more of the samples are 15 ppb or less, according to the state, and the water is meeting all standards for safety.

Okay, so data wise, by September 10th we know this for pretty gosh-darn certain:

• 104 ug/L that jumped to 397 ug/L after ferric chloride was added.
• Home #2 (4614 Bryant Street) indicate that the portion of the service line from the external shut-off valve to the water main is likely made of lead, which is consistent with the historical practice in Flint. The sampling had a high lead result (peak value) of 22 ug/L.
• Water at 216 Browning Avenue (using a firstdraw, pre-flushed sampling protocol) yielded a high lead result (22 ug/L). 
• Water at 631 Alvord Avenue, yielded a high lead result (42 ug/L).
• Removal of the old service line to the Walters' home showed all kitchen tap and bathroom tap results for lead and copper were low, confirming that the sources of lead were external to the home.
• 10% of 252 water samples tested at 25 parts per billion of lead or more.
• 16.7 percent of Flint samples have been shown to have more than 15 ppb of lead.

So what does MDEQ's Communications Director Brad Wurfel have to say about that?

Flint residents "who have lead pipes or a lead service connection had lead in their water at some level before this issue was in the newspaper ...  before the switch to the Flint River, Optimizing (corrosion control) can minimize impacts, but it won't alleviate the issue."

Now you can kind of see why the guy was asked to resign. Just in case you may be confused here, the LCR requires corrosion control.  Corrosion control was what they were required to do and what they should have done when they were told by Del Toral of the issue. The goal of corrosion control is to get the lead that leaches from these old pipes to as low as possible.

Had they done that, in the very early days, all these folks would still have a job and I would not be writing these long-winded posts.

You can file this next email under "you are only as good as the people you listen to."

It's around September 30th that the wheels really start to come off their spin machine. Let me remind you, at this point we have not talked about that other data out there regarding the blood-lead levels.

October 7th, 2015:

"Actions that the state of Michigan and the city of Flint announced last week are important steps to protect public health," said Susan Hedman, the EPA's administrator for the region. "The immediate steps being taken to implement corrosion control will reduce lead in drinking water, as required by the Safe Drinking Water Act. U.S. EPA will continue to provide technical assistance to the state of Michigan and the city of Flint to support their joint effort." [source]

Would you look at that! Just what the Del Toral's EPA memo back in June recommended.  Imagine that!

Right before this, around September 24-25th:

A group of doctors led by Dr. Mona Hanna-Attisha of Hurley Medical Center in Flint urges the city to stop using the Flint River for water after finding high levels of lead in the blood of children. State regulators insist the water is safe. [source]

I wonder what data we can get from that?

Next post: Flint Water: A Political Football.  Part 8

Flint Water: A Political Football. Part 6

We kinda know now that what was going on in Flint from April of 2014 to July 2 of 2015 was being downplayed by the EPA, MDEQ, and Flint.

There are a number of reasons for this, some of them valid, other not so much.  I can speculate as to why I think this happened, and I probably will at the end if I can make a good argument.

Right now I want to be able to show a reasonable person that what was known at the time should have lead to a different approach.  Forget hindsight in this case. Was there data known that should have moved the response in a different direction?

The "political football" comment the Governor's chief of staff made on July 22, 2015 is based on the prevailing attitude at that time.  Don't blame him for that conclusion.  That's the input he has been getting from all the players who have a responsibility to protect the public.

On July 2, the head of the Midwest region of the EPA, Susan Hedman, tells the Flint mayor that “it would be premature to draw any conclusions” based on Del Toral's draft EPA memo that is now out in the public.  That comment, in context, was directed at the ACLU who is asking questions.

Still...the data...

If you were the mayor of Flint, and all this was going on, and you aren't a public health official, you aren't a toxicologist, you aren't a water operator, and the Head of the EPA's region tells you “it would be premature to draw any conclusions” - and nothing else of substance - what would you conclude about your water "crisis" going on?

All of this downplaying, or at best "bad choice of words," leads to this statement on September 25th from the Governor's chief of staff:

The DEQ (Department of Environmental Quality) and DCH (Department of Community Health) feel that some in Flint are taking the very sensitive issue of children's exposure to lead and trying to turn it into a political football claiming the departments are underestimating the impacts on the populations and particularly trying to shift responsibility to the state,

 July 2nd to September 25th, we have the Governor's office, the MDEQ, and the EPA doing what?

July 9th the ACLU press release is issued.  Del Toral is quoted - as a private citizen - telling the ACLU:

I don’t want to scare people unnecessarily, but there is absolutely a problem in Flint that needs to be addressed right away.

We also learn from the ACLU this:

According to Del Toral, Flint should be adding corrosion-control chemicals designed to help keep lead and copper in pipes from leaching into drinking water. Doing so is required by federal regulations, wrote Del Toral in his memo.

We have discussed this EPA memo in detail already.  What we find out from the ACLU is how Flint sees this:

"To our knowledge, that is inaccurate,” said Flint spokesman Lorenz. “Before the plant was placed in operation, the City (and our engineering firm) had numerous discussions with DEQ personnel and inquired if corrosion-control chemicals – typically phosphates --needed to be included in the treatment process. The use of these chemicals was not required or mandated.”

This statement perplexes the heck out of me.  It shows a complete lack of understanding of the city's responsibility under the Lead and Copper Rule (LCR). When the plant was built has nothing to do with corrosion control responsibilities.  That's why under the LCR you sample every year.

Now let's look at this letter from the MDEQ to Flint dated August 17, 2015:

As you can see, the Flint Spokesman, Lorenz, has been,,,err,,,misinformed. Who is advising these folks in Flint?

Let's also look at the ACLU's concern that has now been pointed out.

The Walters family surely isn’t alone in dealing with the threat of lead-laced drinking water. About half of Flint’s 40,000 homes are a half-century old or older, built at a time when water service lines were typically made of lead.

That's the concern I went with as well when I looked at the data presented in the Del Total memo.

Regardless of the LCR requirements on when to report, there is now evidence of lead leaching into the water caused by the City's failure to treat. If triple digit lead results were seen in a house without lead plumbing, what is happening to homes with lead plumbing?

To me, that's a reasonable and prudent approach to take if your concern is protecting public health.

Look, I am trying to remain as neutral and objective as I can, but I am finding it increasingly hard to not conclude gross incompetence as the mitigating factor for the City of Flint and the MDEQ.

Back to the timeline.  May 9th the ACLU story breaks. How does the city respond?

Flint's mayor drinks water from tap to prove it's safe 

July 10, Susan Hedman sends out a benign press release:

Not much in terms of emails takes place until August 23 when Marc Edwards with Virginia Tech informs all the parties of their Flint Water Study group that they have formed.

About one month later in September, MDEQ spokesperson Brad Wurfel writes:

Mr. Wurfel also resigns after a task force cited department failures in addressing the Flint water crisis.

In a letter to Gov. Rick Snyder, the Flint Water Advisory Task Force pegged the "substance and tone" of the department's communications as one of three failures, along with failing to correctly interpret lead and copper rule and a regulatory failure.

On September 21st the MDEQ is responding as if the lead in the water is just as normal as it has always been.  Mr. Wurfel also states that the water "presently meets all state and federal water quality standards."  That's false as Del Toral's EPA memo states.

"Throughout 2015, as the public raised concerns and as independent studies and testing were conducted and brought to the attention of MDEQ, the agency's response was often one of aggressive dismissal, belittlement, and attempts to discredit these efforts and the individuals involved," noted the task force's letter. "We find both the tone and substance of many MDEQ public statements to be completely unacceptable."

After his resignation Mr. Wurfel is quoted stating:

There's no denying it, the Department of Communications could have been better...the department was doing its best with highly technical information that frequently changed. When the department realized it looked like it had made a mistake, it admitted that.

My sympathies are guarded here.  On September 21st, the MDEQ was still not catching on.

Remember this from the Del Toral EPA memo?

But as they say on infomercials selling us all kinds of stuff, "but wait there's more!"


Next post: Flint Water: A Political Football.  Part 7

Flint Water: A Political Football. Part 5

Let's go over the data and some important points that we have talked about so far.  By June 24th the EPA, Flint, and the MDEQ know all this based on Del Toral's EPA memo:

• 104 ug/L that jumped to 397 ug/L after ferric chloride was added.
•  Children in this home with blood-lead levels that went from 2 to 3 ug/dL.
• Home #2 (4614 Bryant Street) indicate that the portion of the service line from the external shut-off valve to the water main is likely made of lead, which is consistent with the historical practice in Flint. The sampling had a high lead result (peak value) of 22 ug/L.
• Water at 216 Browning Avenue (using a firstdraw, pre-flushed sampling protocol) yielded a high lead result (22 ug/L). 
• Water at 631 Alvord Avenue, yielded a high lead result (42 ug/L).
• Removal of the old service line to the Walters' home showed all kitchen tap and bathroom tap results for lead and copper were low, confirming that the sources of lead were external to the home.

Here is where it starts to fall apart for those responsible for public health.

FOIA Source

Okay, Del Toral erred in releasing his June 24th memo to the public without it being vetted.  That was wrong on his part, in particular because it included medical data attached to a name. It is possible, now that I look at it, that the MDEQ may not have seen this memo.

Nevertheless, the data (as I put in bullets at the start) is known as of this July 1 email by Susan Hedman.  That data does not need to be vetted.  That data is from a number of different times and collectors.  That data is known and cannot, in my opinion, be ignored as invalid.

That data shows lead leaching from pipes owned by Flint due to the condition of the water Flint is providing.  That data supports the contention that the Lead and Copper Rule's (LCR) requirement for corrosion control is not being followed even if it does not meet the requirements for when to report and notify.  There is an issue with lead leaching from the distribution system in Flint regardless of the legal requirement to report or do something about it in the LCR.

The EPA should come to this conclusion based on the data Del Toral reported, regardless of "fully vetted" not being performed.

How did Susan Hedman with the EPA see it?

FOIA Source

It's the “it would be premature to draw any conclusions” that was her death knell. On January 21 Ms. Hedman resigns from the EPA.

You know, everything looks better in hindsight. That's what makes writing this so very hard.  How do you hold someone accountable without making it into a witch hunt based on comments from emails that were generated while it was unfolding?

Remember, we have hindsight.  We can see all the pieces known to this point.  Still...the data that they did know should have elevated the level of response from both the MDEQ and the EPA, in my opinion.

It is hard for me to accept that the situation going on in Flint at that time (new water, taste, smell, GM not using it) was not factored in to their decision making regarding looking more closely at public health impact.

This was not just another day of going over a bureaucratic threshold reporting requirement to meet a rule requirement, there were significant issues with this water enough to at least make the response a little more expedient in looking at the leaching of lead - which is a common problem with water and old water systems.

But that's hindsight on my part.

Still...

What happened next?

Next post: Flint Water: A Political Football.  Part 6

Flint Water: A Political Football. Part 4

Let's go over the data and some important points that we have talked about so far:

• 104 ug/L that jumped to 397 ug/L after ferric chloride was added.
•  Children in this home with blood-lead levels (BLL) that went from 2 to 3 ug/dL.
• Lead and Copper Rule (LCR) states that if lead concentrations exceed an action level of 15 ppb,,,the system must undertake a number of additional actions to control corrosion.
• LCR states that if the action level for lead is exceeded, the system must also inform the public about steps they should take to protect their health and may have to replace lead service lines under their control

September 25th we get the "political football" email:

The DEQ (Department of Environmental Quality) and DCH (Department of Community Health) feel that some in Flint are taking the very sensitive issue of children's exposure to lead and trying to turn it into a political football claiming the departments are underestimating the impacts on the populations and particularly trying to shift responsibility to the state," [source]

We know that none of the LCR stuff (those two last bullets) were done. We seem, at least to me, to have a state agency - the MDEQ - that does not fully understand its responsibilities...which falls under the state's responsibility...which becomes the governor's responsibility (the buck stops here).

Flint's failure to act is one thing, but the state not stepping in is another.  Why does the state have responsibility over Flint's inaction to comply with the LCR?  Because of this thing we call "primacy" that is written into the Safe Drinking Waster Act (SDWA).

State Primacy: Section 1413 authorizes states to assume primary oversight and enforcement responsibility (primacy) for public water systems. To assume primacy, states must adopt regulations at least as stringent as national requirements, develop adequate procedures for enforcement (including conducting monitoring and inspections), adopt authority for administrative penalties, and maintain records and make reports as EPA may require. States also must develop a plan for providing safe drinking water under emergency circumstances. Currently, 55 of 57 states and territories have primacy authority for the public water system supervision (PWSS) program. [source]

According to the EPA, "Currently, all states and territories have primacy."  Since Michigan is a state, well...they have primacy, which means they have oversight and enforcement responsibility.

Should the MDEQ have understood their role?  Should they have done something to help Flint comply?  Here is what the EPA writes about PWSS:

As codified in 40 CFR Part 142 Subpart B, to obtain primacy the State must have regulations that are no less stringent than the regulations promulgated by EPA. States with primacy implement and enforce State drinking water regulations. At all levels of government, regulatory agencies have some discretion in determining what type of enforcement action to take and when to impose penalties. 

The EPA goes on to tell the state:

The most successful State efforts to achieve compliance are often preventive efforts and informal enforcement actions. Preventive efforts are aimed at notifying and educating an operator about requirements, and can result in avoiding critical problems. These activities are based on the belief that most water suppliers want to do the right thing if they understand how and why it must be done. 

It's not rocket science.

Shall we continue with the timeline?

March 27, 2015: Based on a suspected conflict of interest at the local health department that conducted the February 2015 BLL testing, the Walters’ take their child to a healthcare facility in a different location to have his blood lead re-tested. The result from this BLL test (6.5 ug/dL) is significantly higher than the February BLL test (3 ug/dL).

We will come back to the blood-lead levels.  Right now I want to focus on the lead in the water from the tap.

April 3, 2015: The water is shut off at Walters’ residence due to the high lead levels.

Okay...

April 28, 2015: The water at the Walters’ residence was turned back on temporarily to collect additional water samples.

Cool, more data!

The kitchen tap was flushed at low flow for 25 minutes the night before (on April 27, 2015) the sequential sampling conducted on April 28, 2015. On April 28, 2015, 30 Sequential samples were collected at Walters residence. Extremely high lead levels were found in all samples. The minimum lead value was 200 ug/L; the average lead value was 2,429 ug/L; and the maximum lead value was 13,200 ug/L.

Here is what the EPA memo says about this sampling in more detail:

Since the water had stagnated for an extended period of time, the kitchen tap was flushed for 25 minutes the night before collecting the samples. Three sets of samples were collected at different flow rates (10 at low flow, 10 at medium flow and 10 at high flow).

I was skeptical of those high numbers.  That's a lot of lead to leach out.  So I did some research to see what levels of lead have been shown to leach out of plumbing that contains lead.

Source is behind a paywall:
Effect of pH on the concentrations of lead and trace contaminants in drinking water:
A combined batch, pipe loop and sentinel home study

Okay, it looks like 30 ppm leaching out is a possibility, especially with corrosive water. I'll take those sample results as sound.  My gosh though, 13 ppm - parts per MILLION - was found. That's a lot of lead.

We now have some compelling and convincing data that tells us that lead can be in the Flint drinking water.  Again though, this is just what we found in one house.

By May 6th, a lot more data and conformation is coming in.  From the Del Toral's EPA memo we learn this:

EPA inspection reveals that the portion of the Walters’ service line from the water main to the external shut-off valve on the corner of Bryant Street and Browning Avenue is made of lead. EPA’s inspection also confirms that the portion of the Walters’ service line from the home to the external shut-off valve appears to be galvanized iron pipe. 

Now we know pretty much for sure that it was Flint who put the lead into the water coming out of the Walters' house.  It was Flint's water corrosivity that was leaching the lead and it was lead plumbing that Flint owned where the lead was leaching from.

EPA Region 5 collects a set of sequential samples from each of two residences on Bryant Street which are connected to the same main as the Walters’ old service line. The results tells us that:

• Home #1 (4526 Bryant Street) does not appear to have a lead service line and lead results in all samples are low.

• Home #2 (4614 Bryant Street) indicate that the portion of the service line from the external shut-off valve to the water main is likely made of lead, which is consistent with the historical practice in Flint. The sampling had a high lead result (peak value) of 22 ug/L.

Now we have a second home with lead above the 15 ppb LCR threshold.

The City of Flint tests the water at 216 Browning Avenue at resident’s request, again using a firstdraw, pre-flushed sampling protocol, which yielded a high lead result (22 ug/L). The City of Flint tests the water at 631 Alvord Avenue, yielding a high lead result (42 ug/L).

Now we have four houses with knowledge of lead above the LCR threshold of 15 ppb.

The suspected lead items have been removed from the service line to the Walters' home on May 6th.

The water in the Walter's home is tested again on May 13th.

All kitchen tap and bathroom tap results for lead and copper were low, confirming that the sources of lead were external to the home. 

What happened next?

Next post: Flint Water: A Political Football.  Part 5

Flint Water: A Political Football. Part 3

At this point in the timeline we are looking at June 24, 2015 as the date that data showing lead in the water and an increase in blood-lead levels (BLL) in the children who were exposed to that water is now known.  These folks were made aware of this based on the "cc" we see in that Del Toral EPA memo:

We can assume that the MDEQ is aware of these results:

• 104 ug/L that jumped to 397 ug/L after ferric chloride was added.
•  Children in this home with BLL that went from 2 to 3 ug/dL.

What is important to note here is this.  The protocol used by Flint for collecting samples is believed to under report the concentration of lead found at the tap.  EPA's Del Toral makes note of this in his memo:

The practice of pre-flushing before collecting compliance samples has been shown to result in the minimization of lead capture and significant underestimation of lead levels in the drinking water. Although this practice is not specifically prohibited by the LCR [Lead and Copper rule], it negates the intent of the rule to collect compliance samples under 'worst-case' conditions...

That result of 397 ug/L lead in the water the City of Flint reports appears to be the result obtained with the pre-flush:

The water is once again tested after pre-flushing for 3-4 minutes the night before but this time with the iron filter removed

So what happened next?

March 19, 2015: EPA Region 5 calls MDEQ expressing concern regarding the high lead levels found.

...and how did the MDEQ respond to this concern by the EPA?

The MDEQ response received via voicemail states that the high lead levels at the Walters’ home are due to lead sources in the homeowner’s plumbing. 

This is, in my opinion, one of many mistakes made by those responsible for public safety and an egregious one at that.

This mistake rests squarely on the shoulders of the MDEQ. It is why I have empathy for the Governor if these were the guys advising him.

The reason for those high levels of lead DOES NOT MATTER.

The MDEQ's response to the EPA indicates either a complete lack of understanding of the Lead and Copper Rule (LCR), or...or...nope, that's all I can think of as the reason for that reply.

What's worse than this irrelevant response by the MDEQ is what the EPA memo states next:

In previous and subsequent conversations with Ms. Walters, she stated that the plumbing has always been all plastic. An inspection conducted by EPA Region on April 27, 2015, confirmed that all pipes, fittings and valves in the Walters’ home are NSF approved CPVC pipe (certified for drinking water use) and sequential sampling results following the replacement of the service line found that there are no sources of lead in the home plumbing.

Not only does the lead coming from the homeowner's plumbing NOT MATTER, the lead was not coming from this homeowner's plumbing period.

Let's look at what the LCR says about where the responsibility for lead found at the tap above action levels rests.

The treatment technique for the rule requires systems to monitor drinking water at customer taps. If lead concentrations exceed an action level of 15 ppb or copper concentrations exceed an action level of 1.3 ppm in more than 10% of customer taps sampled, the system must undertake a number of additional actions to control corrosion.

You see that word "must?" You see how it applies to the system?  Where the lead is leaching from DOES NOT MATTER.

I have been focusing on the data because the data is important as it relates to what should be done.

Let's go back and look at the lead results that the Flint water system, as well as the MDEQ, are aware of in the middle of March, 2015.

• 104 ug/L that jumped to 397 ug/L after ferric chloride was added.

What's the action level? 15 ppb (ug/L).  What's supposed to happen if that level is exceeded?

If the action level for lead is exceeded, the system must also inform the public about steps they should take to protect their health and may have to replace lead service lines under their control

See that word "must?"  Now we can argue if this one house really requires this to legally happen, you know, the "not enough data!"  You need to look at this one house in context with everything that was going on at that time in Flint.  You take corrosive water - which they knew about...

October 2014: A General Motors plant in Flint stops using municipal water, saying it corrodes car parts. [source]

...and you become aware that the plumbing in the house with lead levels at the tap of 397 ppb is new and cannot possibly leach lead, and, well, you should have done what the LCR required you to do.

That's March 19, 2015.  On September 25th we get the "political football" email:

The DEQ (Department of Environmental Quality) and DCH (Department of Community Health) feel that some in Flint are taking the very sensitive issue of children's exposure to lead and trying to turn it into a political football claiming the departments are underestimating the impacts on the populations and particularly trying to shift responsibility to the state," said Muchmore. [source]

To me, and this is where I kind of feel sorry for the Governor, nobody in the know seems to be in the know about what needs to happen and who is to make it happen if it is not happening.

We have this term in the drinking water regulatory world called "primacy" under the Safe Drinking Water Act. Someone IS responsible and the finger pointing going on in the state is counter-productive.

What happened next?

Next post: Flint Water: A Political Football.  Part 4