Up-to-date information on our collaborative research and citizen science work with the residents of Flint, MI in light of reported water quality issues
The US Environmental Protection Agency Region 5 Administrator Susan Hedman has responded to Congressman Kildee’s letter. In it, she states that:
“Consistent with the recommendations in the internal memorandum cited in your letter, EPA is working with MDEQ to monitor Flint’s compliance with the federal Lead and Copper Rule. On August 17, 2015, MDEQ notified Flint that additional treatment will be required to optimize corrosion control and the City is taking steps to do so. Experts from EPA’s Office of Research and Development are providing technical assistance to Flint to implement those corrosion control improvements.”
While the letter hasn’t answered several of Congressman Kildee’s questions (including whether Flint water is safe?), more details are expected in a meeting being setup for Monday 9/21.
For those who want a simple explanation of the legislator’s questions and the MDEQ responses, we provide a summary table below. For some questions posed, there was no response, perhaps it will be forthcoming in the MDEQ briefing next week.
Select questions from Congressman Kildee, Sen. Ananich, State Rep. Neeley and State Rep. Phelps:
MDEQ’s response (culled from two letters below):
Congressman Kildee:
“The [EPA memo] suggests that there are high levels of lead in the city of Flint, Mich., water transmission lines.”
Are the findings of the EPA memo regarding lead levels in Flint water accurate?
—
Sen. Ananich, State Reps Neeley and Phelps:
When did the MDEQ become aware of the [EPA memo] and whom was it shared with?
Which Flint city officials also received this information?
What response did MDEQ hake to the EPA concerns raised in the memo?
Were any actions taken by the MDEQ as a result of the issues mentioned in the memo?
“The MDEQ does not review or receive draft memos from US EPA, nor would they expect to do it while in a draft form.”
Flint water has “no unresolved violations of state and federal standards.”
Congressman Kildee:
“I am very troubled by recent tests$ suggesting high levels of lead in Flint’s water system”
Given the demonstrated level of lead in the water in Flint, MI, is the water safe?
$ FLINTWATERSTUDY notes: Refers to Virginia Tech’s testing
“Regulations associated with lead […] require communities to monitor water quality at customer taps. […] Any home with lead plumbing or service connections will impart some amount of lead to water samples. […] The City’s monitoring program’s purpose is to show aggregated levels throughout the entire system, not individual home levels.”
“Each customer with an individual sample result that exceeds 15 parts per billion is provided information on actions they can take to limit lead exposure in drinking water.”
“There has always been detectable levels of lead in the City’s water sampling program for homes that have lead plumbing and service connections” both before and after the switch to Flint River; the switch itself has not resulted in an Action Level exceedance
“The City performed extensive home tests for lead […] last year and this year, and is meeting state and federal drinking water standards.”
Flint water has “no unresolved violations of state and federal standards.”
Sen. Ananich, State Reps Neeley and Phelps:
“And most importantly, what can be done immediately to ensure safe, affordable drinking water for the citizens of Flint?”
“MDEQ is working closely with Flint’s water department and USEPA to ensure Flint residents have ample water that meets state and federal standards.”
“MDEQ takes seriously its responsibility to ensure safe drinking water for all Michigan residents.”
Sen. Ananich, State Reps Neeley and Phelps:
What steps, if any, were taken to determine the validity of the Virginia Tech study?
NO RESPONSE
Sen. Ananich, State Reps Neeley and Phelps:
Please explain why the pre-flushing method of sampling was used in this instance.
Is it the same method that is applied to all sampling or does the agency have the discretion to decide?
Who is responsible for making the decision to pre-flush?
The EPA recommends allowing water to rest for at least six hours, but no more than 12 hours, before taking a sample. On MDEQ’s website, it suggests flushing the line for five minutes before the six-hour rest. How did the department arrive at this method?
“Flint’s test results were conducted according to the same testing protocols every Michigan community uses and the same protocols Flint has used to test its water every three years for the past 25 years.”
Sen. Ananich, State Reps Neeley and Phelps:
The EPA memo references the Lead and Copper Rule requirement that systems greater than 50,000 users maintain “corrosion control treatment.” As the regulator, why did the MDEQ choose not to enforce this standard?
“While the results from Flint’s testing show compliance with the federal action level for lead and copper, on August 17, 2015, MDEQ instructed the City to move forward expeditiously with developing additional corrosion control treatment to minimize the corrosive effects between drinking water and lead service connections and home plumbing in the Flint service area.”
Congressman Kildee:
“The [EPA memo] reflects that children consuming this water had levels of lead in their blood in excess of three times what they were prior to the city of Flint switching its source water from Detroit […] to the Flint River.”
“Local health departments also administer annual blood level testing on children in Flint; results show no discernable rise in levels that might be expected if there was an elevated lead level in the City water supply.”
Congressman Kildee:
“It is the responsibility of these agencies (MDEQ and EPA) to ensure that the people of the city of Flint have safe drinking water.”
“MDEQ maintains a robust public water supply regulatory program through long-standing partnerships with the USEPA and the state’s regulated public water systems.”
“The MDEQ continues to work with City and federal regulators on the shared goal of ensuring safe, reliable drinking water in this community.”
Congressman Kildee:
If there were high lead levels of lead in the water in the city of Flint, when did the EPA and/or MDEQ plan to alert the public?
NO RESPONSE
Sen. Ananich, State Reps Neeley and Phelps:
Who refused the EPA’s offer of expert assistance and why?
NO RESPONSE
Sen. Ananich, State Reps Neeley and Phelps:
Is the damage done to the pipes (as described in the EPA report) accurate?
If yes, will damaged pipes continue to leach lead or will properly treated water safely reach consumers?
We will be posting updates from our second Flint trip (Sep 14-16) in the coming days. In the meantime, we wanted to make available both our presentation at the Saints of God Church, Flint MI on Sep 15, 2015 and the lead results from across the City distributed by ward and zip codes; we shared these maps at the Town Hall Meeting earlier this evening.
We are really excited and proud to announce that our research team just won a $50k Rapid Response Research (or RAPID) grant from the National Science Foundation (NSF). The grant proposal titled “Synergistic Impacts of Corrosive Water and Interrupted Corrosion Control on Chemical/Microbiological Water Quality: Flint, MI.” was submitted to NSF in late July.
RAPID grants are “used for proposals having a severe urgency…., including quick-response research on natural or anthropogenic disasters and similar unanticipated events.”
Dr. Marc Edwards serves as Principal Investigator for this grant. He is joined by Drs. Amy Pruden (Civil and Environmental Engineering) and Joe Falkinham III (Biology) who will serve as Co-Principal Investigators. Dr. Brandi Clark and PhD Candidate William Rhoads contributed to writing this NSF proposal.
Experiment: When we visited Flint, we took pieces of copper pipe joined with lead solder (old solder is 50% lead by weight) inside them. Lead solder is probably present in the plumbing of many Detroit/Flint homes built before 1986 when it was banned from use in drinking water systems. We put the lead solder-copper pipe test pieces in 250 mL containers, and filled them with the following three waters:
Test 1) Detroit water
Test 2) Current Flint River water
Test 3) Current Flint River water with orthophosphate (a typical corrosion inhibitor)
Test 3 was conducted, to see if adding orthophosphate to Flint River water would stop lead corrosion. About 50% of water companies in the U.S. add orthophosphate to their water to control lead corrosion, but it is not currently added to Flint River water.
Results and Observations:
Figure 1 – Data from Week 3 comparing lead corrosion in Detroit water (left), current Flint water (middle), and Flint water with orthophosphate (right)
From the data shown above in Figure 1, it is clear that Detroit water is much less corrosive to lead solder than the Flint River water. On average, Detroit water is 19 times (or 19X) less corrosive than the Flint River water currently in use. That is, the current Flint River water leaches 19X more lead to the water than Detroit water. This explains why the lead in Flint’s water in our survey, is so high, even when it was low before when Detroit water was being used.
Orthophosphate still does not seem to help stop lead leaching in Flint River water, which is also consistent with expectations based on experiments in high chloride water. There is a slight improvement, but even with phosphate, Flint River water has 16 times more lead compared to the same condition using Detroit water. We will continue to run these tests, but at present it does not seem like orthophosphate will provide a quick answer to the very high lead levels in Flint water.
Conclusion:On a scientific basis, Flint River water leaches more lead from plumbing than does Detroit water as predicted before. This is creating a public health threat in some Flint homes that have lead pipe or lead solder. Unfortunately, adding orthophosphate corrosion inhibitor to the Flint River water, does not solve the lead problem.
PRACTICAL IMPLICATIONS
We believe, that in the weeks and months ahead, MDEQ and Flint will be forced to admit they failed to protect public health as required under the Federal Lead and Copper Rule. The question that will then be asked is “What can be done to protect residents?”
Step 1: Issue Scientifically Sound Advice.
The first step is to admit that the water in Flint is not safe for cooking or drinking — a fact that MDEQ still denies. According to MDEQ statements provided to reporter Ronald Fonger this week, which were presented to us for comment, MDEQ’s Brad Wurfel asserts that:
“the issue here isn’t Flint’s water source or water plants. It’s the high number of older homes with lead pipes and lead service connections….Folks who have concerns should get a water specialist to take a look at their home and see what they need to do to achieve peace of mind, because lead and copper are home plumbing problems that no water source can eliminate entirely.”
Likewise, during our sampling events in Flint homes, we are finding very high lead in other homes with modern lead free plumbing, which again points to city owned lead pipes and corrosive water as the problem.
On the basis of these facts, we consider MDEQ’s position to be both unscientific and irresponsible, and we stand by our recommendations to Flint consumers, that they immediately reduce their exposure to high lead in Flint’s water by implementing protective measures when using tap water for drinking or cooking.
Step 2. Implement Corrosion Control.
The second step will ultimately require some sort of corrosion control treatment to reduce lead in Flint water. Three options are possible as detailed below:
Switch back to the non-corrosive Detroit water. It is our opinion, based on years of experience, that Flint’s lead levels would drop markedly in about one month.
Add orthophosphate to Flint River water. As indicated in this work, orthophosphate will not reduce lead leaching from all lead plumbing sources. On the basis of our extensive experience, we would only expect modest improvements to water lead levels if orthophosphate was added.
Wait for KWA pipeline. If orthophosphate was added to water from the KWA pipeline, it would be about the same corrosivity as Detroit water (Option A). In that case, Flint residents will have to live with the very high lead in their water, until at least one month after the pipeline is connected.
Politicians and residents will ultimately have to look at which of the above options is best for Flint, after weighing feasibility and costs.
