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10-1-14.pdf; Flint Monthly Pumpage Comparison.pdf; ODWMA-399-022 pdf Importance: High Dear Governor, Dennis, and Val: Per your request, the attached briefing paper is on the City of Flint drinking water situation. Director Dan Wyant has asked that I send this to you. A Word version as well as a pdf version is attached. We have also included a copy of the policy ODWMA-399-022 which specifically provides guidance regarding boil water advisory situations, and a chart showing the significant increase in the City of Flint’s water demands following the extreme conditions experienced this past winter. Allison, please forward to the Governor. Thank you. If you have any questions or need further information, please let us know, Thank you. Mary Beth Mary Beth Thelen Management Assistant to Director Dan Wyant Department of Environmental Quality Constitution Hail, 6th Floor South Phone: 517-284-6712 or 284-6700 (new numbers) Fax: 517-241-7401 [email protected] Attachments xxxEND_PAGE:deq26_b114_1143_1162_01 DEPARTMENT OF ENVIRONMENTAL QUALITY GOVERNOR’S OFFICE BRIEFING PAPER CITY OF FLINT DRINKING WATER What contributed to the Boil Water Advisories in the city of Flint? A number of factors, not one specific cause, likely contributed to the Boil Water Advisories (BWAs) in the city of Flint during August and September 2014. While use of the Flint River has increased the amount of natural organic matter in the city’s water, the Flint Water Treatment Plant (WTP) has performed well above treatment requirements for organic carbon removal. In addition, less than 20 percent of the water system was included in the advisory area. {f treatment had been compromised, detections would have been widespread throughout the city, rather than in such a iocalized area. The city’s water distribution system has suffered from a lack of infrastructure investment and asset management. Most of the city’s over 550 miles of water mains are now over 75 years old and constructed of cast iron piping. Cast iron pipe is subject to internal corrosion, called tuberculation, which causes buildup on the pipe interior, leading to water quality issues, reduced flow and pressures, and leakage. Tuberculation also encourages the development of biofilms, layers of bacteria that attach to the interior pipe wall. Biofilm growth is common in areas of piping with little or no disinfectant residual, and together with tuberculation can clog water lines to the point of insufficient water pressure. The city has aiso experienced decades of a declining user base and water use associated with vacant homes, commercial businesses, and industrial property. Declining water use leads to excess residence time within the city’s distribution pipes and water storage facilities, accelerating tuberculation, biofilm growth, and disinfectant residual degradation. While the city has recently seen an infusion of funding for blight removal, contractors completing this work have been improperly using fire hydrants, causing hydraulic disturbances that dislodged and suspended settled debris, which may have contributed to the bacterial contamination. The winter of 2014 was also one of the coldest experienced by the water system. The city, which historically has unaccounted water losses of over 30 percent, has seen even greater losses since February 2014 due to an increase in cold weather-related water main breaks and leaks. The city lacks a formal maintenance program for its over 7,250 valves, which would normally be used to limit impacts during break repairs. Two valves on the transmission line used to supply the area of the BWAs were found to be closed during the city’s investigation, causing longer residence time, reduced disinfectant residual, reduced flow, and reduced pressure. One of these valves has remained broken. xxxEND_PAGE:deq26_b114_1143_1162_02 Governor's Office Briefing Paper City of Flint Drinking Water Page 2 The BWAs also occurred during the warmest and, for 2014, relatively wet periods of August and September. Warm weather conditions are not only more conducive to bacterial growth but also degrade the water's disinfectant residual carried out from the WTP more quickly. Longer residence times, biofilms, and tuberculation also contribute to disinfectant residual degradation. Warm wet weather conditions also allow water contaminated with bacteria to pool around piping with leaks and breaks. Process for issuance and Cancelation of a Boil Water Advisory There are a number of conditions that can trigger BWAs. This includes the following: - Bacteria Monitoring Detections - Loss of System Pressure - Bacteria Standards Violations - Water Main Breaks ~ Treatment System Failures - Other Interruptions in Service - Waterborne Disease Outbreaks The Department of Environmental Quality (DEQ) has developed a policy and procedure regarding BWAs to help guide staff, provide consistency, and maintain public health. A PDF of Policy and Procedure No. ODWMA-399-022 is being forwarded with this briefing paper, BWAs may be self-initiated by the water systern, issued collaboratively in consultation with the DEQ, or when necessary mandated by the DEQ. Requesting customers to boil the water when bacterial contamination has occurred provides an added barrier of public health protection. The BWAs that recently occurred in the city of Flint were associated with bacteria monitoring detections and violations of bacteria standards. These advisories were issued by the city of Flint collaboratively in consultation with the DEQ. Current regulations regarding monitoring and standards for bacteria in water distribution systems were developed by the U.S. Environmental Protection Agency, have been in effect since 1990, and were incorporated into the Michigan Safe Drinking Water Act, 1976 PA 309, as amended. There are a variety of bacteria, parasites, and viruses that can potentially cause heaith problems if humans ingest them in drinking water. Testing water for each of these potential pathogens would be difficult and expensive. Instead, water systems test for total coliform and E.coli. Total coliform bacteria react to water treatment in a manner similar to many pathogens. Therefore, the presence of total coliform in drinking water indicates there may be a pathway for pathogens or other contaminants to enter the system. The absence of total coliforms in the distribution system minimizes the likelihood that pathogens are present. E.coil/is itself a pathogen, and its detection would be direct evidence of a health risk. xxxEND_PAGE:deq26_b114_1143_1162_03 Governor's Office Briefing Paper City of Flint Drinking Water Page 3 Once a BWA has been issued, time is needed to investigate potential causes and implement corrective measures. The larger the water system, the more time this may take. Once corrective measures have been taken, samples must be collected and analyzed to confirm that bacteria are no longer present. Using the most common analytical method, sarnples must be incubated for a periad of 24 hours before results can be obtained. In situations where the bacterial contamination has been confirmed, two consecutive rounds of safe samples coilected at least 24 hours apart are normally obtained before canceling a BWA. Adding each of these steps together, a normal response period to cancel a BWA under these circumstances would be expected to take at least 3 to 4 days. Recent History of the City of Flint Water System Historically, the city of Flint had been a customer of the Detroit Water and Sewerage Department (DWSD) while simultaneously maintaining the Flint WTP to provide emergency backup service using the Flint River. The WTP performed quarterly test operations to maintain readiness and was utilized twice in 2009, supplying water once for 2 days and the other for 3 days. in April 2013 the city of Flint notified the DWSD that it would be terminating service in the future and contracting for raw water service from the Karegnondi Water Authority (KWA). Work on the KWA pipeline from Lake Huron broke ground in June 2013 and is expected fo be completed with connection in late 2016. In August 2013 Rowe Professional Services Company completed an engineering proposal for improvements to the Flint WTP that would allow continuous operation of the WTP utilizing the Flint River in lieu of continuing service frorn the DWSD until completion of the KWA pipeline. In March 2014 the city of Flint entered into a Consent Agreement with the DEQ regarding the Flint WTP’s lime sludge facility. In April 2014 the DEQ issued a construction permit for improvements to the Flint WTP. On April 25, 2014, the city of Flint began continuous operation of the WTP, using water from the Flint River and discontinued the purchase of water from the DWSD. A BWA was issued for August 15-20, 2014, for a portion of the city of Flint due to localized detections of total coliform and E.colf bacteria. Another BWA was issued for September 5-9, 2014, due to localized detections of total coliform bacteria in the same and adjacent portions of the city of Flint. The advisory covered an area of approximately six square miles. The city of Flint has a total land area of just over 34 square miles. xxxEND_PAGE:deq26_b114_1143_1162_04 Governor's Office Briefing Paper City of Flint Drinking Water Page 4 While many of the BWA contributing factors listed above require long-term solutions, the city has taken operational steps to limit the potential far a BWA to reaccur. The city has increased flushing of water mains to limit residence time, maintain disinfectant residual, and help remove buildup and deposits within the piping. The city is boosting chlorine disinfectant residual at locations in the distribution system as needed. The city continues to investigate water leaks and water main breaks and the status and condition of system vaives. Prepared by: Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance Department of Environmental Quality October 1, 2014 xxxEND_PAGE:deq26_b114_1143_1162_05 DEPARTMENT OF ENVIRONMENTAL QUALITY GOVERNOR’S OFFICE BRIEFING PAPER CITY OF FLINT DRINKING WATER What contributed to the Boil Water Advisories in the city of Flint? A number of factors, not one specific cause, likely contributed to the Boil Water Advisories (BWAs) in the city of Flint during August and September 2014. While use of the Flint River has increased the amount of natural organic matter in the city’s water, the Flint Water Treatment Plant (WTP) has performed well above treatment requirements for organic carbon removal. in addition, less than 20 percent of the water system was included in the advisory area. If treatment had been compromised, detections would have been widespread throughout the city, rather than in such a localized area. The city’s water distribution system has suffered from a lack of infrastructure investment and asset management. Most of the city’s over 550 miles of water mains are now over 75 years ald and constructed of cast iron piping. Cast iron pipe is subject to internal corrosion, called tuberculation, which causes buildup on the pipe interior, leading to water quality issues, reduced flow and pressures, and leakage. Tuberculation also encourages the development of biofilms, layers of bacteria that attach to the interior pipe wail. Biofilm growth is common in areas of piping with little or no disinfectant residual, and together with tuberculation can clog water lines to the point of insufficient water pressure. The city has also experienced decades of a declining user base and water use associated with vacant homes, commercial businesses, and industrial property. Declining water use leads to excess residence time within the city’s distribution pipes and water storage facilities, accelerating tuberculation, biofilm growth, and disinfectant residual degradation. While the city has recently seen an infusion of funding for blight removal, contractors completing this work have been improperly using fire hydrants, causing hydraulic disturbances that dislodged and suspended settled debris, which may have contributed to the bacterial contamination. The winter of 2014 was also one of the coldest experienced by the water system. The city, which historically has unaccounted water losses of over 30 percent, has seen even greater losses since February 2014 due to an increase in cold weather-related water main breaks and leaks. The city lacks a formal maintenance program for its over 7,250 valves, which would normaily be used to limit impacts during break repairs. Two valves on the transmission line used to supply the area of the BWAs were found fo be closed during the city’s investigation, causing longer residence time, reduced disinfectant residual, reduced flow, and reduced pressure. One of these valves has remained broken. xxxEND_PAGE:deq26_b114_1143_1162_06 Governor's Office Briefing Paper City of Flint Drinking Water Page 2 The BWAs also occurred during the warmest and, for 2014, relatively wet periods of August and September. Warm weather conditions are not only more conducive to bacterial growth but also degrade the water's disinfectant residual carried out from the WTP more quickly. Longer residence times, biofilms, and tuberculation also contribute to disinfectant residual degradation. Warm wet weather conditions also allow water contaminated with bacteria to pool around piping with leaks and breaks. Process for issuance and Cancelation of a Boil Water Advisory There are a number of conditions that can trigger BWAs. This includes the following: - Bacteria Monitoring Detections - Loss of System Pressure - Bacteria Standards Violations - Water Main Breaks - Treatment System Failures - Other Interruptions in Service - Waterborne Disease Outbreaks The Department of Environmental Quality (DEQ) has developed a policy and procedure regarding BWAs to help guide staff, provide consistency, and maintain public health. A PDF of Policy and Procedure No. CDWMA-399-022 is being forwarded with this briefing paper. BWAs may be self-initiated by the water system, issued collaboratively in consultation with the DEQ, or when necessary mandated by the DEQ. Requesting customers to boil the water when bacterial contamination has occurred provides an added barrier of public health protection. The BWAs that recently occurred in the city of Flint were associated with bacteria monitoring detections and violations of bacteria standards. These advisories were issued by the city of Flint collaboratively in consultation with the DEQ. Current regulations regarding monitoring and standards for bacteria in water distribution systems were developed by the U.S. Environmental Protection Agency, have been in effect since 1990, and were incorporated into the Michigan Safe Drinking Water Act, 1976 PA 399, as amended. There are a variety of bacteria, parasites, and viruses that can potentially cause health problems if humans ingest them in drinking water. Testing water for each of these potential pathogens would be difficult and expensive. Instead, water systems test for total coliform and E.coli. Total coliform bacteria react to water treatment in a manner similar to many pathogens. Therefore, the presence of total coliform in drinking water indicates there may be a pathway for pathogens or other contaminants to enter the system. The absence of fotal coliforms in the distribution system minimizes the likelihood that pathogens are present. E.colfis itself a pathogen, and its detection wauid be direct evidence of a health risk. xxxEND_PAGE:deq26_b114_1143_1162_07 Governor's Office Briefing Paper City of Flint Orinking Water Page 3 Once a BWA has been issued, time is needed to investigate potential causes and implement corrective measures. The larger the water system, the mare time this may take. Once corrective measures have been taken, samples must be collected and analyzed to confirm that bacteria are no longer present. Using the most common analytical method, samples must be incubated for a period of 24 hours before results can be obtained. In situations where the bacterial contamination has been confirmed, two consecutive rounds of safe samples collected at least 24 hours apart are normally obtained before canceling a BWA, Adding each of these steps together, a normal response period to cancel a BWA under these circurnstances would be expected to take at least 3 to 4 days. Recent Histary of the City of Flint Water System Historically, the city of Flint had been a customer of the Detroit Water and Sewerage Department (DWSD) while simultaneously maintaining the Flint WTP to provide emergency backup service using the Flint River. The WTP performed quarterly test operations to maintain readiness and was utilized twice in 2009, supplying water once for 2 days and the other for 3 days. in April 2013 the city of Flint notified the DWSD that it would be terminating service in the future and contracting for raw water service from the Karegnondi Water Authority (KWA). Work on the KWA pipeline fromm Lake Huron broke ground in June 2013 and is expected to be completed with connection in fate 2016. in August 2013 Rowe Professional Services Company completed an engineering proposal for improvements to the Flint WTP that would allow continuous operation of the WTP utilizing the Flint River in lieu of continuing service from the DWS0D until completion of the KWA pipeline. In March 2014 the city of Flint entered into a Consent Agreement with the DEQ regarding the Flint WTP’s lime sludge facility. in April 2014 the DEQ issued a construction permit for improvements to the Flint WTP. On April 25, 2014, the city of Flint began continuous operation of the WTP, using water from the Flint River and discontinued the purchase of water from the DWSD. A BWA was issued for August 15-20, 2014, for a portion of the city of Flint due to localized detections of total coliform and E.colf bacteria. Another BWA was issued for September 5-9, 2074, due to localized detections of total coliform bacteria in the same and adjacent portions of the city of Flint. The advisory covered an area of approximately six square miles. The city of Flint has a total land area of just over 34 square miles. xxxEND_PAGE:deq26_b114_1143_1162_08 Governor's Office Briefing Paper City of Flint Drinking Water Page 4 While many of the BWA contributing factors listed above require long-term solutions, the city has taken operational steps to limit the potential for a BWA to reoccur. The city has increased flushing of water mains to limit residence time, maintain disinfectant residual, and help remove buildup and deposits within the piping. The city is boosting chlorine disinfectant residual at locations in the distribution system as needed. The city continues to investigate water leaks and water main breaks and the status and condition of system valves. Prepared by: Stephen Busch, P.E. Lansing and Jackson District Supervisor Office of Drinking Water and Municipal Assistance Department of Environmental Quality October 1, 2014 xxxEND_PAGE:deq26_b114_1143_1162_09 25,008,000 48,000,000 2018 | Be | 2 = 8 8 10,000,000 - 8,000,000 xxxEND_PAGE:deq26_b114_1143_1162_10 Original Effective Date: October 12, 2007 Revised Date: Reformatted Date: OFFICE OF DRINKING WATER AND MUNICIPAL ASSISTANCE POLICY AND PROCEDURE __