RE: Flint WTP PH2 SEG4 - Corrosion Control
- From
- Stephen Busch
his will surimarize our phone conversation of 10/19 and provide clarification regarding the previous comments.
The City of Flint converted back te purchasing of Detroit Water and Sewerage Departrnent water on Friday Gctober 16,
2615. No indications of upset in the distribution systern have been reported to date.
Detroit Water and Sewerage Department (DW5D} has confirmed the use of Innephas “Phosphoric Acid 7596 Technical”
product which is NSF Standard 60 certified with a maximum allowable feed rate of 13 mg/L as product.
The City of Flint will need to supaly a similar phosphoric acid product, NSF Standard 60 approved with allowable
maximum dosage.
DASE supplied water is currently dosed at 0.39 mg/L as PU1.2 mae/fl as PO4) slightly above DWSD’s OCCT requirement
o dose a minimum of 0.9 mg/L as PO4 and have a minimum plant tap residual of 0.8 mg/l as PO4. DWSD plant tap
residuals have been shown to consistently be at 0.39 mg/L as P OL2 me/b as PO4), In addition water supply entering
Flirt has been tested and so far shown to contain approximately 0.39 me/i as POL? me/E as POS) as well,
fo achieve pipe passivation Flint will boost orthophosphate dosage to establish @ rninimurn distribution residual of 1.0
mae/Las P (3.1 mg/h as POS), The chemical feed systern will be sized to achieve a dose up to 2.0 mg/L as Pi6.. mg/L as
POd) in case orthophosphate foss is observed.
Fling will continue Water Quality Parameter Monitoring in accordance with the LOR at the same 25 distribution locations
used under the Flint River, in addition LO of these locations alsa serve as total colifarm monitoring sites, including
disinfectant residual, and Flirt will be told te, for the purpase of assessing water stability, conduct water quality
parameter monitoring along with turbidity and iron sarapling will be at these 10 locations ora weekly basis as
suggested, This wil also ensure that a minimiurn recornmended ph levels are being maintained throughout the system,
EPA ORD staff will provide instructions ta the City of Flint for creating test loans to help confirm effectiveness of the
corrosion control treatment. This data will help in rebuilding public trust.
The County Health Department and Mi Department of Health and Human Services will be conducting blood lead level
esting of children in Flint. Chifdren with elevated blood lead levels will be offered exposure assessments of their
homes, These assessrnants should inchide the contribution of lead fram service line and interior plurnbing
sources. Such diagnostic testing should help further substantiate the effectiveness of corrasian contral
reatment Procedures recommended by EPA should be shared with the Michigan Department of Health and Human
Services,
The University of Michigan in Ann Arbor had previously expressed interest in assisting the City of Flint. Both the
Department of Chil and Environmental Engineering, and Schaal of Public Health should be contacted to determine if
hat interest still exists with potential to assist in both test loop construction and monitoring, and exposure assessment
monitoring in homes. Any water analysis should occur at a certified laboratory.
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The City will be required ta complete a6 month round of lead and copper compliance monitoring in the January ~ tune
2016 period, The City continues to offer all residents a first draw lead sarmple collection and analysis. Any additional
staggered monitoring suggestions should be brought before the City’s Technical Advisory Committee.
Criteria for deerning the treatment optimized must be established as the LOR only requires cornpliance with the lead and
copper Action Levels once this determination has been made.
The City of Flint is continuing to digitize service line index card records into a Geographic information System to confirm
the location of lead service lines. EPA can provide additional information to the City regarding a sampling procedure to
verify lead service line sites.
The City’s engineering corsultant will need te evaluate RWA water in conjunction with the City of Flint treatment plant
processes to determine any necessary adjustrnents in optimized carrasion contral treatment prior to initiating service te
customin's. Full scale testing rnay not be feasible.
Stephen Busch, PLE.
MDEO Lansing (istrict Coordinater
Office of Drinking Water and Municinal Assistance
Lansing and Jackson District Supervisor
BE? -643-2344
[email protected]