by Jonathan Oosting and Chad Livengood, originally posted on June 17, 2016

Lansing — Flint’s water distribution system is too large and its treatment plant is inadequately staffed, operated and administered, Environmental Protection Agency chief Gina McCarthy said in a Thursday letter to Gov. Rick Snyder and Flint Mayor Karen Weaver.

While testing shows that Flint’s water quality is improving, McCarthy stressed there are “significant challenges to the long-term goal of reliable and sustainable clean drinking water” as the city considers using its plant to treat raw Lake Huron water from the Karegnondi Water Authority.

Flint operators lack the appropriate expertise to run a granular media surface water treatment plant, according to an EPA-commissioned evaluation by Sleeping Giant Environmental Consultants of Montana, which noted mistakes “can have a huge impact” on public health.

The plant also has few written operating procedures, an inadequate number of maintenance staff and lacks a formal preventative and corrective maintenance program, according to the evaluation, which indicates that maintenance priorities “appear to be established by crisis.”

The report includes a series of prioritized recommendations for the city to take to ensure it complies with federal rules for surface water treatment plants. An earlier EPA emergency order requires the city to demonstrate it has the technical, managerial and financial capacity to comply with the Safe Drinking Water Act before it switches to the KWA or another primary water source.

McCarthy said the Weaver administration must ensure the drinking water system can hire rapidly and contract quickly for expert support. The technical viability of the system requires a long-term plan for financial support.

“The drinking-water-treatment system must have the people, equipment, management, training and expert support it needs to function reliably and well,” the EPA chief wrote.

The size of Flint’s water distribution system is too large for current and projected water demand in Flint, McCarthy said. Oversized systems can lead to water resting in pipes too long, “potentially causing a loss of chlorine residual, which is a necessary barrier against pathogens.”

McCarthy noted the EPA, Flint officials and the Michigan Department of Environmental Quality have installed a flushing system designed to combat stagnant water, “but the state and city will have to determine and implement a solution for the long-term.”

The letter and water treatment plant evaluation come as the city continues to weigh whether it will move forward with plans to draw and treat water from the new KWA pipeline, which could be operating by spring 2017.

Flint returned to Detroit’s Lake Huron water source in October after temporarily switching to the Flint River in April 2014, a decision along with the lack of corrosion controls that helped lead to the contamination crisis. Flint, under control of a state-appointed emergency manager at the time, had not previously operated the plant on a full-time basis.

Weaver said McCarthy’s letter confirms what Flint officials have been saying for months: “We not only need new pipes, we need new infrastructure.”

“The water system in the City of Flint is old, antiquated and too large to adequately serve the city’s current population, which is much smaller than it was decades ago when the water system was put in place,” the mayor said in a statement. “Our city needs a complete infrastructure update to address these issues now and in the long term.”

The EPA consultants acknowledged their April 25-28 review of the Flint water treatment plant was limited because it was not fully operational, KWA would not provide them data on its raw water quality and they could not interview “the person who was responsible for process control decisions when the plant was in operation,” according to the report.

McCarthy said the city and state “face an important decision” on the long-term source of drinking water for Flint and said that decision “must be based on what is best for protecting public health and ensuring compliance with drinking-water standards.”

Snyder spokeswoman Anna Heaton said the governor’s office is reviewing the letter and will be “working with the city to address the issues” raised by the EPA.

Heaton noted that the fiscal year 2017 state budget awaiting Snyder’s signature includes $1.5 million for the DEQ to hire 10 new full-time employees to help Flint with water operations, including corrosion control specialists, sampling staff, lab staff and service line verification staff.

State legislators have so far approved roughly $236 million in funding to address the Flint water crisis since October.

The KWA decision is ultimately up to the city, Heaton said. The Snyder-created Flint Water Interagency Coordination Committee is helping to evaluate options, including continued use of treated Detroit water or KWA water treated by a new Genesee County plant.

Weaver said the city is dealing with the “aftermath” of state-appointed emergency managers who reduced water plant staff when they ran Flint between December 2011 and April 2015.

“Our current employees are getting the job done and administration is actively working to recruit additional experienced and qualified people for several posted positions,” she said. “But we also need additional resources to pay experienced, qualified people. That’s money that must come from the state.”

The consultant’s evaluation of the Flint plant paints a picture of an unorganized facility charged with ensuring 100,000 residents have clean water, saying Flint’s municipal water treatment plant staff were “unprepared and ill-equipped” to treat Flint River when the city left Detroit’s system.

“As one would expect with a staff that has limited experience with surface water treatment, there is an apparent lack of understanding of water treatment concepts and how those concepts can apply to controlling treatment processes in ways that ensure high quality finished water,” the consultants wrote.

The firm found Flint’s water plant has no inventory of its equipment or documentation detailing how old it is and what it would cost to replace the water treatment equipment.

“There is no inventory of critical spare parts, and purchasing policy has limited the acquisition of an appropriate inventory of parts,” the consultants wrote in its report. “There is no formal work order program to prioritize, track, and evaluate the effectiveness of maintenance tasks.”

Water plant staff described Flint’s purchasing policy as “cumbersome” and “lengthy,” the consultants said.

The EPA’s consultants also expressed concern the Flint water plant has far too few employees.

“Staffing is inadequate for water treatment plant maintenance needs, and additional staff are also required for maintenance of facilities that are not essential for water quality,” the consulting firm wrote in its report.

Flint officials last week announced that the city had installed a new temporary system at the water plant to boost chlorine levels following an EPA warning that warm summer temperatures could lead to chlorine decay.

The federal agency had recommended the city install a new pumping system to increase levels of chlorine, which is used in municipal systems to prevent disease-causing organisms from developing.

“In a well-performing system, these issues would be anticipated and addressed as a matter of routine, rather than on a crisis basis,” McCarthy wrote. The urgent action “demonstrates, more powerfully than any report can, that there are basic operational deficits for personnel, contracting and funding that are essential to resolve.”