Spellchek participates in a variety of web based opinion formats. The Flint water crisis is a hot global topic. Exposing the truth is a concern to all and judging by the response we’ve had in other formats, more needs to be done concerning educating the public about lead in our drinking water. So we’ll continue to post on it here and elsewhere. Particularly on exposing the E.P.A. end. It’s bad enough that the residents of Flint were poisoned due to cost cutting, but the law said to protect the citizens may do the opposite.

Federal drinking water regulations contain a provision called the lead and copper (LCR) rule. Issued in 1991 and revised in 2007, it sets the standards public water supplies must follow to insure excessive levels of lead and copper are kept out of our drinking water. Or does it?

Physicians everywhere will tell you that no amount of lead is acceptable in humans. Particularly infants. Lead poisoning is irreversible. Yet the LCR sets an allowable limit of 15 parts per billion (PBB) in our water. Why? Shouldn’t it be zero? Regardless, the 15 PBB threshold wasn’t exceeded during the two six month monitoring periods conducted by the city of Flint after switching their source water. The first period was 6 PBB and the second was 11 PBB. Consequently, the city avoided a public notification and the required actions to correct it.

However, let’s say that the 15 PBB threshold was exceeded. The LCR requires a public water supply to supply treatment recommendations to the state within eighteen months of exceeding an allowable limit, in this case the 15 PBB for lead. States then have six months to respond to those recommendations. If required, public water supplies then have up to 24 months to install the treatment system.

Have you been keeping track? After a public water utility changes its water source it must conduct two six month monitoring periods, an eighteen month recommendation period, a six month state reply period, and a 24 month implementation period. That’s 5 years folks! Up to 5 years of putting excessive amounts of lead in to the drinking water. We are all sheep! We’re guinea pigs! The Feds have determined the best way to optimize corrosion control in a public water supply is to have real world data to work with. Your health is that data!

Where the DEQ screwed up concerning Flint was to misinterpret the rule concerning implementing optimized corrosion control. Cities with under 50,000 residents don’t require it during their two six month monitoring periods after a source water switch. Flint was improperly put in this category as they have over 50,000 residents and should have had corrosion control in place from day one.

Keep in mind that the rule doesn’t address the effectiveness of the corrosion control program. Only that it must be in place during the monitoring period. In water chemistry, there are a great many variables concerning treatment options. Changing any part of a treatment program may create unwanted or unforeseen changes elsewhere. Does it seem a bit strange that water treatment utilizes a key factor such as your health in optimizing change? Particularly when so much data and case studies are available to prevent such trial and error experimentation?

Would it not be better to require more extensive bench testing and jar testing beforehand (common water treatment testing practices)? Bench testing can simulate the same conditions found in the distribution system if properly set up. Would it not make more sense to force utilities to submit to an federal approval process that takes into account all existing data (the system now puts the impetus on the public water utility to submit the treatment proposal)? Spellchek usually never advocates any big government style program but the potential for disaster dictates that oversight by a broad based entity would help eliminate errors from utilities that may not have every resource available to them.

The process is certainly debatable, however the point is to take the human guinea pig out of the equation. The almighty buck factors mightily in the drinking water safety rulebook. Minimizing health risks can be an intensive and expensive process. Ask the poisoned kids in Flint if it’s worth it?

It is estimated that it will take $1.5 billion dollars to replace Flint’s water pipe infrastructure to eliminate the lead issue once and for all. Neither the city or county or state has that kind of money available. Only the federal government could. What about the pandoras box that bailing out Flint would open up? Every other community across the country with lead issues would also be in line for federal dollars.

The saddest part of all is that this disaster in Flint was entirely preventable and still could have delivered the cost savings the city sought. The chloride sulfate mass ratio (CSMR) was hard evidence that switching coagulants from alum to ferric chloride would result in aggressive, corrosive water. Flint had case studies available from other cities that had already implemented comparable changes with the same lead leaching results.

Switching to Flint River water wasn’t the issue that created the lead poisoning. The treatment process selected was. Those decision makers are the people that need to go to jail. People want heads to roll all the way up to the Governor himself. It’s easy to understand the outrage as so many innocent people have been harmed. Perhaps people need to look to our nations lawmakers as well when it comes to blame. Their Safe Drinking Water Act is a failure when it comes to protecting the public from lead. As I’ve laid out for you, you can see how a public utility can legally deliver a toxic lead soup to its customers. For up to 4 years in this scenario. That’s criminal is anyone’s book.