The drinking water lead crisis in Flint, Michigan continues to receive national and local media coverage and attention from Congress, USEPA and the state of Michigan. This tragic incident gives us the opportunity to take a fresh look at our collective lead and copper regulation implementation efforts to assure that we are collectively doing all we can do to minimize lead in drinking water. The August 2016
issue of the Pipeline is devoted entirely to this topic.
Before we look in detail at the Flint crisis, what does it mean to water suppliers here in Oregon? Here are our recommendations for action in the aftermath of the Flint crisis:
- Revisit your water system materials evaluation. Revisit status of lead pigtail removal from service lines, ensure completion.
- Review your sample site selections, be sure to include homes with lead pigtails if any remain.
- Revisit sampling instructions for residents to ensure instructions meet EPA guidelines — no “prestagnation flushing,” no aerator removal or cleaning, use wide-mouthed sample bottles.
- Sample result invalidation by the state is limited only to lab error, bottle damage/tampering, or site did not meet sample site selection criteria. Be sure you sample from sites with current active use because all results from legitimate sampling sites will count.
- Revisit your corrosion control treatment, especially when adding a new source or treatment. Look for opportunities to optimize corrosion control treatment performance to reduce lead at the tap as much as possible.
- Ensure consumer notification is timely following routine tap sampling.
- Ensure required follow-up actions are taken on schedule after any lead action level exceedance, including timely and complete public education.
- Be transparent to the public in all you do.
Flint, Michigan experienced a population drop of more than 50% since the 1960s, due largely to the exodus of automobile manufacturing in the 1980s. The remaining and largely minority population is severely economically disadvantaged and faces dismal health indicators and outcomes. The housing stock is old, with a substantial percentage of houses receiving city drinking water through lead service lines.
The state placed the city under its direct fiscal control in recent years in response to severe city financial shortfalls. In April 2014, the state-appointed financial emergency manager directed that water purchased from the nearby city of Detroit be discontinued to save money. The city’s original water source up to the 1960s, the Flint River, was reactivated along with the existing water filtration plant. Detroit water was treated with orthophosphate corrosion inhibitors, but the original city source
Water complaints rose rapidly after the source switch, including widespread red water and taste and odor, followed by E. coli detections. Subsequent increased chlorination levels resulted in elevated disinfection byproducts. Finally, increased numbers of Legionella infections in the community were reported. Lead levels at the tap were increasing through all of this because of the lack of corrosion control and the presence of lead water service lines, but this rise in lead levels was initially obscured by city sampling deficiencies.
Some city residents began to worry about lead, and persistently complained to local and state officials, to no avail. Help ultimately arrived from an EPA Region V inspector and a Virginia Tech academic expert and his students. Together they demonstrated alarming levels of lead at the taps of city residents. The county health department issued a “do not drink” advisory in October 2015 (18 months after switching sources), and the city switched back to Detroit water that same month.
In December 2015, a local pediatrician published a peer-reviewed journal article documenting a significant rise in the number
of Flint children with elevated blood lead levels. That rise was associated with the increase in tap water lead levels resulting from the water source change to the Flint River. The Michigan governor declared an emergency, and distribution of bottled water and home filters began. Lead levels at the tap started and continue to decline, but recommendations to use bottled water or filters remain in place.
The Flint, Michigan lead crisis and why it occurred continues to be a focus of both investigative journalism and oversight by agencies and interest groups. The Flint Advisory Task Force final report, dated Mar. 16, 2016 (see http://www.michigan.gov), provides a detailed timeline of the events, assignment of responsibilities for the crisis, findings and recommendations. The report found:
- The Flint water crisis is a story of government failure, intransigence, unpreparedness, delay, inaction and environmental injustice.
- Though there may be some ambiguity in the EPA Lead and Copper Rule, none of it relates to what the Michigan Department of Environmental Quality should have done in Flint. There was and remains no justification for MDEQ not requiring corrosion control for the switch of water source to the Flint River.
Local media outlets across the country focus on the question, Could Flint happen here? In Oregon, we know there was little past use of lead water service lines compared to the United States. Use in Oregon was primarily short lead “pigtails” several feet in length that connected water mains to the water service line (see photo above).
Oregon prohibited use of lead materials in 1985, including lead pipes in water systems and lead solder in plumbing. Water suppliers were required to identify and remove lead “pigtails” or “goosenecks” and any lead pipe. Later in the early to mid-1990s, the EPA Lead and Copper Rule was thoroughly implemented because the natural corrosiveness of Oregon water sources was well known. Corrosion control treatment was installed and operates in 165 communities.
In direct response to the Flint crisis, US EPA officially followed up with each state on its status of implementing the Lead and Copper Rule. You can view these “asks” and our responses to EPA below: