Monday, January 25, 2016

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

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