Use Flint River, Failed to Ensure Corrosion Control
Lindsey,
| didn’t know if you want a copy of our statement regarding the Office of Auditor General’s letter.
First, here’s a copy of the letter in case you don’t have
it: htte://www.audeen michigan gov/finalodis/15 16/1761032015 pat
Our statement:
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.
We appreciate the efforts of the Auditor General and will carefully consider all of the recommendations contained in the
letter.
Lindsey, 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
xxxEND_PAGE:executiveofficeemails20_b1315_3404_3405_1
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.
@ 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).
™@ 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.
H@ 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.
Dave Murray
higandmurray
xxxEND_PAGE:executiveofficeemails20_b1315_3404_3405_2