Summary of Flint s Implementation of Veolia s Recommendations

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1 Summary of Flint s Implementation of Veolia s Recommendations A comparison between Veolia s Technical Recommendations vs. EPA Findings On March 12, 2015, Veolia delivered its final report to Emergency Manager, Gerald Ambrose, the city s Technical Advisory and Citizens Advisory committees, and public officials. The report provided recommendations to address disinfection byproducts (TTHM), taste and odor issues. On April 25-28, 2016, the U.S. EPA Office of Civil commissioned an evaluation of the Flint Surface Water Treatment Plant. *** The results of the EPA report show that 13 months after Veolia completed its study and delivered recommendations to public officials very few recommendations were implemented -- and those implemented were done so incorrectly without proper monitoring, controls or expertise.

2 Flint, Michigan: Partial, incorrect implementation of Veolia s recommendations without proper monitoring and controls Summary of Flint s Implementation of Veolia s Recommendations Veolia s Technical Recommendations March 12, 2015 Veolia #1 Priority Recommendation: Implement operating programs for process control management. Flint s Implementation as of April 28, 2016 No recommendations were implemented. Veolia #2 Priority Recommendations: Three recommendations related to water filtration and chemistry to address TTHM, taste and odor issues. Veolia #3 Priority Recommendations: Three recommendations for effective pretreatment of Flint River water to affect water chemistry, related to TTHM, taste and odor. Veolia #4 Priority Recommendations: Two recommendations to improve distribution system functioning for TTHM, taste and odor. (water storage, hydrology, valves) City of Flint s Action: Partial, incorrect implementation without proper expertise, monitoring and controls. City of Flint s Action: Partial, incorrect implementation without proper expertise, monitoring and controls. No recommendations were implemented.

3 Detailed Background of Flint s Implementation of Veolia s Recommendations Veolia s Technical Recommendations March 12, 2015 Flint s Implementation as of April 28, 2016 Veolia Priority #1 Recommendations: Implement operating programs for process control management. Excerpt from Veolia s Report: Implement operating programs for: process control, lab QA/QC, maintenance, training, safety program and vulnerability assessment. These programs are needed regardless of the TTHM issue and will help with transition to lake water. The City has decided upon a central maintenance software and the water system should be the first to utilize this program since costs are already budgeted. These programs should be initiated immediately. None of Veolia s recommendations were developed or implemented. Furthermore, the EPA s report stated, 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. Excerpts from EPA Report: management has not established and communicated measureable goals and objectives for finished water quality. There are few, if any, written standard operating procedures available for staff to follow in order to ensure consistent and appropriate operation of the FSWTP. There is no preventative maintenance. The maintenance is done primarily on a crisis basis. There is no asset management system available. There is no inventory of the equipment. There is no inventory of the operational status of the equipment or condition. There is no understanding and/or documentation of the remaining useful life of the equipment. There is no estimate of the value of the equipment or the costs of replacement. "

4 Veolia Priority #2 Recommendations: Veolia made several recommendations related to water filtration and chemistry to address TTHM, taste and odor issues. Each recommendation required the city to contract an engineer, coordinate with the State, and perform rigorous monitoring. Excerpts from Veolia s Report: Granulated Activated Carbon filtration to help TTHM/chlorine residuals. Contract with your engineer and initiate discussions with the State on the reduction of chlorine prior to the filters and changing the filter media to GAC. This activity has the longest time frame for design and approval, but also is extremely critical to assuring reduced TTHM production. The current filter cleaning and maintenance project needs to be adjusted to take into consideration the change in filter media both to dispose of the anthracite instead of cleaning and to install the GAC. This entire project needs to be done by early July to assure a flow of water throughout the system. Several months are required for the engineering design, State approval, bidding of work and installation of GAC and as such needs to begin now. Adjust use of potassium permanganate to help TTHM, taste and odor issues. Contract with your engineer and initiate discussions with the State on the addition of 0.5 to 1.2 mg/l of either potassium permanganate (dry) or sodium permanganate (liquid). This will take time to get approved and to implement. The use of liquid tanks at the raw water pump station may be the quickest and least expensive alternative for a temporary measure. Corrosion inhibitors recommended to help taste and color issues. Contract with your engineer and initiate discussions with the State on the addition of a corrosion control chemical. This action can be submitted and discussed with the state at the same time as the other chemical and filter changes saving time and effort. A target dosage of 0.5 mg/l phosphate is suggested for improved corrosion control. Flint converted to granular activated carbon. GAC filter was improperly operated and maintained, which is highlighted in the EPA s report. Potassium permanganate. Unknown. Status of this recommendation was not included in the EPA report. Based on the EPA report, it seems the city is adding phosphate. However, it appears as though the City did nothing until the State DEQ requested that they optimize their corrosion program on August 15, Clearly, the city chose to ignore Veolia s recommendation made in March The State set a January 2016 compliance date, losing five precious months in the process. Excerpts from EPA report: GAC operation - The original filter media have recently been changed out, but SGEC was not able to determine the precise specifications of the sand or GAC that were installed. The specifications are important for determining if the new media are appropriate for treatment of water, for estimating appropriate filtration rates and filter run times, and for determining appropriate backwash techniques. In the first five filters examined, the sand and GAC were found to be almost completely mixed from top to bottom. This was cause for concern as the sand and GAC should be re-stratified after each backwash.

5 Veolia Priority #3 Recommendations: Three recommendations for effective pre-treatment of Flint River water to affect water chemistry, related to TTHM, taste and odor. Excerpts from Veolia report: Increase the ferric chloride dosage to 100 mg/l depending on river water TOC levels. (Lower TOC levels can be treated with less ferric chloride.) This change can be made now and is allowed by the State. Increase of Ferric Chloride -.. please note, that the amount of chemical needed changes with the nature of the river and as such, water must be tested multiple times a day with corresponding changes in chemical dosages. Reduce the ozone feed rate to 5 mg/l. This change can be done now and does not require State approval. Treating water is a delicate balance - increasing ozone to fix the TTHM problem can raise bromate levels to a point of violation. The introduction of permanganate is being recommended to reduce the demand for ozone so that feed rates will not exceed 5 mg/l. The current ozone dosing has been as high as 8 mg/l and, as such, if allowed to continue, will increase the risk of violating the bromate levels. Ferric chloride. Unknown whether recommendation was implemented. According to the EPA report, there were ongoing maintenance issues, which impacted reliability and operability of the ozone system. Unknown whether recommendation for lime dosage was implemented. Excerpt from EPA report: Operators are deficient in experience and expertise regarding the concepts of coagulation control and surface water treatment when using a conventional high rate granular media filtration plant. When treating Flint River water using ferric chloride at sufficient concentrations for enhanced coagulation, there were problems with sediment removal from the basins. Operators reported this problem was primarily a result of the inability to fully open sludge wasting valves. Operators report that there have been operational problems with the ozone injection facilities Reduce the lime dosage to minimize hardness levels after softening. This will eliminate magnesium removal during treatment, but will also reduce total hardness. A reduction in carbon dioxide dosing for recarbonation treatment also is expected due to the reduction in lime feed. This change can be made now and does not require State approval. As we have noted before, the dosage needs to be adjusted daily or more often based on process control monitoring.

6 Veolia Priority #4 Recommendations: Two recommendations to improve distribution system functioning for TTHM, taste and odor. (water storage, hydrology, valves) These recommendations help support proper water flow within the distribution system. Excerpt from Veolia s report: Confirm with the engineer when the revised hydraulic model will be completed and if necessary for time to focus on areas of longest water age if that would speed up the effort. Identify impact of reducing tank levels or eliminating a tank seasonally to improve water age. Include with this effort a list of hydrants to flush along with time required to assure drawing fresh water through the system. The engineer has been assigned this task already and confirmation of the timing of a delivery is needed. Ask the engineer to identify closed valves on a map that are impacting water age and that can be bid for replacement as soon as weather permits. Have the engineer identify areas of the system where the valve contractor should be focused on finding and fixing closed valves. According to Change Order #4 dated April 14, 2015, it appears as though the City contracted with its engineer to make modifications to the Hydraulic Model. However, Veolia s recommendations were not fully developed or implemented. This was confirmed by the EPA s report. Excerpt from EPA report: In the current Flint booster chlorination arrangement, there seems to be little control over where the inflow to the tank is coming from or where the outflow is going. Therefore, control over distribution residuals is unreliable and, aside from strategic flushing, there is no certainty that the chlorinated water is directed to the areas where it is needed most. Over the long term, the hydraulics of the distribution system should be assessed and, assuming booster chlorination is necessary, improvements made to target the areas of low free chlorine residual. Additionally, the volume of the two distribution storage reservoirs may be greater than what is needed or desirable for the current population. Since chlorine residuals are lost in storage and disinfection byproducts are produced, the system's storage needs should be evaluated.