Fwd: Letter from Auditor General on DEQ and Flint water
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Bryn and Kristen,
I'm guessing that Ron is off this week since we haven't heard from him about letter from the
Office of the Auditor General. this. I'll pass it along to you two
First, here’s a copy of the letter in case you don’t have
The letter from the Office of the Auditor General includes some criticisms, but also reflects that
state officials were following accepted protocols, or in one case, an interpretation of the
corrosion control program that the EPA later clarified.
But we need to do better in ensuring Flint residents have safe water and tracking children
affected by elevated lead levels. We continue to work with the bipartisan task force that is
reviewing all the actions at the state, local and federal level and is expected to offer
recommendations in a month or so. Gov. Snyder is committed to working with Flint Mayor
Weaver and officials on these issues.
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We appreciate the efforts of the Auditor General and will carefully consider all of the
recommendations contained in the letter.
Bryn and Kristen, for your background, here is a summary of answers from the Office of the
Auditor General in response to questions mostly posed by Sen. Jim Ananich’s office (the auditor
added a few questions in the 11-page report). The questions were posed as the OAG conducts an
audit of the Office of Drinking Water and Municipal Assistance’s handling of the Flint water
crisis.
Conclusions:
@ While the Flint City Council voted in March 2013 to move to the KWA pipeline, it didn’t designate the Flint
River as an interim water source. But the Department of Environmental Quality had approved the river as
a backup source for emergency purposes in 2006. The treated water met safety standards in quarterly
tests by the Flint Water Treatment Plant, but Flint had never tested its effect on the distribution system.
@ In an email review of key DEQ managers to determine if there was an effort to conceal information, only
one email exchange raised red flags. The Environmental Protection Agency had asked DEQ in February
2015 if Flint had a corrosion control program; the DEQ responded the city had an optimized program in
place. In April the EPA asked again, and the DEQ said that the Flint Water Treatment Plant was not doing
corrosion control. DEQ later explained that the first answer was referring to its Lead and Copper Rule
program, in which it monitors a new water source (in this case, the Flint river) for lead/copper for two
consecutive six-month periods to determine if corrosion treatment is necessary. The report says there's
no reason to believe that DEQ willfully misrepresented information to the EPA. It also concludes that
Office of Drinking Water and Municipal Assistance employees appeared to have notified management
properly about the unfolding Flint water situation.
@ DEQ did not consult with the EPA on how best to apply the Lead and Copper Rule monitoring practices
after the switch to Flint water, but from past experience, DEQ believed it was doing so correctly by doing
two rounds of six-month monitoring on the new water source before determining optimal corrosion
control. The EPA disagreed with DEQ‘s interpretation of the LCR, but later stated that the LCR was open
to interpretation. It then clarified the rule: Corrosion controls already in place when Flint was on Detroit
water should have been maintained after the switch.
m@ DEQ should have notified the Flint WTP to start corrosion controls once the first round of six-month
sampling results arrived in late March 2015 and showed the water exceeded acceptable lead levels.
@ DEQ doesn’t operate the Flint WTP so it doesn’t have any accountability measures to ensure the WTP is
collecting water samples from tier 1 homes, i.e., residences with lead service lines, soldering or plumbing.
Instead, DEQ relies on Flint’s certification of sample sites. The auditor suggests DEQ should consider an
independent verification of the sampling pool or of Flint’s certifications. In November 2015, Flint said it
had no way to ensure the sites were all tier 1. Water samples came from 175 randomly distributed
testing bottles. DEQ has asked Flint to verify its prior samples by this Wednesday (12/30).
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@ There's been controversy that DEQ dropped two sampling sites with high lead levels from its second six-
month review. The auditor determined it was appropriate for DEQ to do so because those sites did not
meet federal criteria. It was also appropriate for DEQ to require flushing taps the night before sampling
to ensure faucets didn’t contain overly stagnant water.
@ Charts show that most water samples were taken in the sixth month of the six-month testing period. The
auditor said it’s difficult to determine if the lateness of the sampling affects the accuracy.
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