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