Archive

decision-making


The concept of regulations is to address problems.  All regulations are based on trying to correct a problem that has already occurred.  We have rules that were developed to try to address contaminants in water, and rules designed to address a variety of potential threat to water supplies.  In a blog over a year ago I asked the question, in light of the mess in West Virginia, why do we permit power companies to store coal ash next to streams?  This is a huge potential health impact to water customers, as well as to the ecosystem that we rely on to protect water supplies in natural areas.  A 20 year old Congressional Act did sorta prohibit the discharge of coal ash to streams from mining, but did not address storage where the accidents actually occur.  So we have rules that didn’t remove the piles from the banks, and didn’t offer a solution to remove it which would have been the appropriate regulatory response.  We should all be on the bandwagon that urges Congress to require power companies to properly dispose of this stuff, and to provide a means to do so.

However, in classic “Failure to Learn from the Past” mode, instead we get a directive in Washington to review the rollback of the stream rule that was developed to address a 20 year old lawsuit over stream protections and “waters of the US.”  That revised stream rule got held up in 2015 by litigation (EPA Secretary Pruitt led one of those suits), and while the directive is not exactly allowing coal ash into streams as noted in the media, it does give you the sense that there will not be any effort to address this problem.  That should concern water industry leaders.

Advertisements

The troubling aspect of that is that Governing magazine reports that many state are likely to see less revenue in 2017 vs 2016.  Governing‘s analysis of projected 2017 budget data from the National Association of State Budget Officers shows shows states now have a median 4.9 percent of annual expenditures saved for the fiscal year, down from 5.1 percent the previous year.  Illinois, Nevada, New Jersey and North Dakota have no reserves as of 2017.  They add to Kansas, Oklahoma, Arkansas, and Montana who had no reserves last year.  And Alaska that is burning though theirs.  Economic and tax policies are to blame.  The Kansas solution to cut taxes to create economic growth has not worked.  The state continues to get farther behind and it is becoming harder to pretend all is well.  Having no reserves is a crazy bad idea.  It is hard to explain just how crazy bad this idea is – it means that if a negative economic issue occurs, these states are in huge trouble unless they start cutting education and other essential services.  The best way to get out of a budget hole is not cutting education – the one thing needed to dig out and attract new economic activity.  Clearly these officials did not learn from 2008-2011 when there reserves were depleted to address the economic downturn. That makes no sense and dooms their residents to a repeat of 2009/2010, only worse.

 


DSCF0032Curtailed water use and conservation are common topics of conversation in areas with water supplies limitations.  As drought conditions worsen, the need for action increases, so when creating a regulatory framework, or when trying to measure water use efficiency, water supply managers often look for easily applied metrics to determine where water use can be curtailed.  Unfortunately, the one-size-fits-all mentality comes with a potential price of failing to fully grasp the consequences decision-making based on such metrics.

One of the issues that water supply regulator like to use is per capita water use.  Per capital water use is often used to show where there is “wasted” water use, such as excessive irrigation.  However such a metric may not be truly applicable depending on other economic factors, and may even penalize successful communities with diverse economic bases.  A heavy industrial area or dense downtown commercial center may add to apparent per capita use, but is actually the result of vibrant economic activity. Large employment centers tend to have higher per capital use than their neighbors as a result of attracting employees to downtown, which are not included in the population.

In south Florida, a recent project I was involved with with one of my students showed that while there was significant variability among utilities, but the general trend of increased economic activity was related to increased per capita use.  Among the significant actors were health care, retail trade, food service and scientific and technical services.  It appears to be these sectors that drive water use upward.  As a result when evaluating the efficiency of a utility, an analysis should be conducted on the economic sectors to insure that water regulations do not stifle economic growth and jobs in a community.   And conversely if you do not have these sectors, you water use should be lower.  Something to think about when projecting or regulating water use.  Limited water use may in fact be limiting economic activity in the area. Of course if you are water limited, limited new withdrawals may be perfectly acceptable if you want to encourage other options, like direct or indirect potable reuse, irrigation, etc.  

It would be interesting to expand this study across the country to see what the national trends look like and how different tourism oriented South Florida might actually be.


For those wondering what the big report was going yo say, interesting reading, and a lot like Walkerton – plenty of blame to go around.

https://www.michigan.gov/documents/snyder/FWATF_FINAL_REPORT_21March2016_517805_7.pdf

And some related articles:

http://www.fox2detroit.com/news/flint-water-crisis/112311306-story


How to Predict the next Flint?

IMG_4803In the last blog we talked about Flint’s water quality problem being brought on by a political/financial decision, not a public health decision.  Well, the news get worse.  Flint’s deteriorated water system is a money thing as well – the community has a lot of poverty and high water bills, so they can’t pay for improvements.  They are not alone.  Utilities all over the country have increasing incidents of breaks, and age related problems. So the real question then is who are the at risk utilities?  Who is the next Flint?  It would be an interesting exercise to see if a means could be developed to identify those utilities at risk for future crises, so we can monitor them in more detail as a means to avoid such crises.

So what would be the measures that might identify the future “Flint?”  These could be things like age of the system, materials used, economic activity trends, income, poverty rate, unemployment rate, utility size, reserves, utility rates, history of rate increases, etc.?  Could these be developed into a means to evaluate risk?  If so, who would use it and how would we address the high risk cases?  I suggest that lenders have means to evaluate this using many of these same measures, but from a risk of events, this method has not been applied.  So I think this would be a useful research project.  So if anyone has some ideas, time or ideas for funding, let me know.  Let’s get rolling!


I was at a recent AWWA technical and Education Council meeting in Denver. One of the major discussions was the issues with lead service lines as highlighted by the current problem in Flint, and how many utilities are now fielding questions about and dealing with lead in their services lines, research that will come for lead, and regulatory requirements for upgrades. One issue that remains unanswered is what happens on the customer’s side of the meter, which may also be lead piping. So removing the utility’s lead service would not solve the lead issue completely, but it will help. But why has lead not been an issue in 25 years? Did it suddenly arise?
While the lead has arisen again as a public health topic, the lead and copper rule has been in effect for nearly 30 years and much of the lead and copper testing was conducted in the early 1990s. Most utilities made water treatment upgrades based the findings from the testing, and utilities have been required to continue to monitor their system ever since. Normally lead levels, even when present, were not a health issue because the zinc orthophosphates and other treatment methods kept the pipe
encapsulated. Others like Cincinnati, Lansing, Madison, Boston and others had ongoing programs to replace lead pipes. 30 years ago in North Carolina we changed out lead goosenecks and galvanized lines rather than replace them – it was just easier.
Most of the folks in the room agreed most utilities have or have such programs and that the number of lead service lines and lead goosenecks on the utility side is
limited. So I suggested that maybe the lesson we should learn from Flint is not about lead service lines, but instead the risks we incur with decision-makers who only look at money when making decisions. Flint’s decision to change water sources was driven by money, not public health.
In fact the report just published indicates that public health was not a real consideration at all. But decisions based on money impacted not only Flint, but Alamosa, CO in 2008, where disinfection was not practiced, and Walkerton,
ONT in 2001 where a Flint like set of decisions cascaded into contamination that killed people. There are utiity systems who contract operations and their contract operator makes decisions based on money, and now there is a distribution system problem. This is a repetitive pattern that has less to do with personnel operating these systems, than decision-makers, who tend to look more at the business case or money as opposed to public health. The lesson we need to learn is that money cannot be the
deciding factor when operating public water and sewer system. And to reduce the chance it happens in the future, perhaps there should be penalties if it does.

Speaking of water supply problems, welcome to Flint, Michigan.  There have been a lot of coverage in the news about the troubles in Flint the last couple of months.  However if you read between the lines you see two issues – first this is not new – it is several years old, going back to when the City’s water plant came back on line in May 2014.  Second this was a political/financial issue not a public health issue.  In fact, the political/financial goals appear to have been so overwhelming, that the public health aspects were scarcely considered.  Let’s take a look at why.

Flint’s first water plant was constructed in 1917.  The source was the Flint River.  The second plant was constructed in 1952. Because of declining water quality in the Flint River, the city, in 1962, had plans to build a pipeline from Lake Huron to Flint, but a real estate scandal caused the city commission to abandon the pipeline project in 1964 and instead buy water from the City of Detroit (source:  Lake Huron).  Flint stopped treating its water in 1967, when a pipeline from Detroit was completed. The City was purchasing of almost 100 MGD.  Detroit declared bankruptcy.  The City of Flint was basically bankrupt.  Both had appointed receivers.  Both receivers were told to reduce costs (the finance/business decisions).  The City of Flint has purchased water for years from Detroit as opposed to using their Flint River water plant constructed in 1952.  The Flint WTP has been maintained as a backup to the DWSD system, operating approximately 20 days per year at 11 MGD.

The City of Flint joined the Karegnondi Water Authority (KWA) in 2010.  The KWA consists of a group of local communities that decided to support and fund construction of a raw water pipeline to Lake Huron. The KWA was to provide the City of Flint Water Treatment Plant with source water from Lake Huron. An engineer’s report noted that a Genesee County Drain Commissioner stated that one of the main reasons for pursuing the KWA supply was the reliability of the Detroit supply given the 2003 power blackout that left Flint without water for several days.  Another issue is that Flint no say in the rate increases issued to Flint by Detroit.  Detroit’s bankruptcy may also have been a factor given the likelihood of increased prices.  While discussion were ongoing for several years thereafter, the Detroit Free Press reported a 7-1 vote in favor of the KWA project by Flint’s elected officials in March, 2013.  The actual agreement date was April 2013. The cost of the pipeline was estimated to be $272 million, with Flint’s portion estimated at $81 million.

The City of Detroit objected due to loss of revenues at a time when a receiver was trying to stabilize the city’s finances (in conjunction with the State Treasurer).  In February 2013, the engineering consulting firm of Tucker, Young, Jackson, Tull, Inc. (TYJT), at the request of the State Treasurer, performed an analysis of the water supply options being considered by the City of Flint.  The preliminary investigation evaluated the cost associated with the required improvements to the plant, plus the costs for annual operation and maintenance including labor, utilities, chemicals and residual management.  They indicated that the pipeline cost was likely low and Flint’s obligation could be $25 million higher and that there was less redundancy in the KWA pipeline than in Detroit’s system.  In 2013, the City of Detroit made a final offer to convince Flint to stay on Detroit water with certain concessions.  Flint declined the final Detroit offer. Immediately after Flint declined the offer, Detroit gave Flint notice that their long-standing water agreement would terminate in twelve months, meaning that Flint’s water agreement with Detroit would end in April 2014 but construction of KWA was not expected to be completed until the end of 2016.

It should be noted that between 2011 and 2015, Flint’s finances were controlled by a series of receivers/emergency managers appointed by the Governor.  Cutting costs was a major issue and clearly their directive from the Governor.  Cost are the major issue addressed in the online reports about the issue.  Public health was not.

An engineering firm was hired as the old Flint River plan underwent $7 million in renovations in 2014 to the filters to treat volumes of freshwater for the citizens.  The project was designed to take water from the Flint River for a period of time until a Lake Huron water pipeline was completed.  The City of Flint began using the Flint River as a water source in May of 2014 knowing that treatment would need to be closely watched since the Michigan Department of Environmental Quality in partnership with the U.S. Geological Survey, and the City of Flint Utilities Department conducted a source water assessment and determined the susceptibility of potential contamination as having a very high susceptibility to potential contaminant sources (take a look at this photo and see what you think).

FLint WTP

Flows were designed for 16 MGD. Lime softening, sand filters and disinfection were in place.  Everything sounded great.  But it was not. Immediately, in May and August of 2014, TTHM samples violated the drinking water standards.  This means two things – total organic carbon (TOC) in the water and additional chlorine being added to disinfect and probably reduce color caused by the TOC.  Softening does not remove TOC.  Filtration is not very effective either.  High concentration usually needs granular activated carbon, ion exchange or membranes.  The flint plant had none of these, so the carbon staying in the water.  To address the TTHM issue, chlorine appears to have been reduced as the TTHM issue was in compliance by the next sampling event in Nov 2014.  However, in the interim new violations included a total coliform and E. coli in August and September of 2014, and indication of inadequate disinfection.  That means boil your water and lots of public outcry.  The pH, salinity (salt) and other parameters were reported to be quite different than the Detroit water as well.  A variable river system with upstream agriculture, industry and a high potential for contamination, is not nearly as easy to treat as cold lake water.  These waters are very different as they City was to find.  What this appears to indicate is that the chemistry profile and sampling prior to conversion and startup does not appear to have been fully performed to identify the potential for this to occur or this would have been discovered.  This is now being suggested in the press.

The change in water quality and treatment created other water quality challenges that have resulted in water quality violations. Like most older northern cities, the water distribution system in almost 100 years old. As with many other municipalities at the time, all of the service lines from the cast iron water mains (with lead joints) to end users homes were constructed with lead goosenecks and copper lines.  Utilities have addressed this with additive to prevent corrosion.  In the early 1990s water systems were required to comply with the federal lead and copper rule.  The concept was that on the first draw of water in the morning, the lead concentration should not exceed 0.015 mg/L and copper should not exceed 1.3 mg/L.  Depending on the size of the utility, sampling was to be undertaken twice and a random set of hoses, with the number of samples dependent on the size of the system.  The sampling was required to be performed twice, six months apart (note routine sampling has occurred since then to insure compliance).  Residents were instructed on how to take the samples, and results submitted to regulatory agencies.  If the system came up “hot” for either compound, the utility was required to make adjustments to the treatment process.  Ideally water leaving the plant would have a slightly negative Langlier saturation index (LSI) and would tend to slightly deposit on pipes.  Coupon tests could be conducted to demonstrate this actually occurred.  As they age, the pipes develop a scale that helps prevent leaching. Most utilities tested various products.  Detroit clearly did this and there were no problems.  Flint did not.

The utility I was at was a perfect 100% non-detects the first time were tested.  We had a few detections of lead and copper in samples the second time which really bothered me since the system was newer and we had limited lead in the lines.  I investigated this and found that the polyphosphate had been changed because the County purchasing department found a cheaper product.  I forced them to buy the old stuff, re-ran the tests and was again perfect.  We instructed our purchasing department that saving a few bucks did not protect the public health, but the polyphosphate product did.  Business and cost savings does not trump public health!  Different waters are different, so you have to test and then stay with what works.

Now fast forward to Flint.  They did not do this testing.  The Flint River water was different that Detroit’s.  Salinity, TOC, pH and overall quality differed.  Accommodations were not made to address the problem and the state found no polyphosphates were added to protect the coatings.  Veolia reported that the operations needed changes and operators needed training.  Facilities were needed to address quality concerns (including granular activated carbon filter media).  As a result the City appears to have sent corrosive water into the piping system, which dissolved the scale that had developed over the years, exposing raw metal, and created the leaching issue. Volunteer teams led by Virginia Tech researchers reported found that at least a quarter of Flint households have levels of lead above the federal level of 15 ppb, and as high as 13,200 ppb.  Aging cast-iron pipe compounded the situation, leading to aesthetic issues including taste, odor and discoloration that result from aggressive water (brown water). Once the City started receiving violations, public interest and scrutiny of the drinking water system intensified.

The City Commission reportedly asked the receiver to switch back to Detroit water, but that request was initially rebuffed and the damage to pipes continued.  Finally in October 2015, the water supply was switched back to Detroit and the City started adding additional zinc orthophosphate in December 2015 to facilitate the buildup of the phosphate scale eroded from the pipes by the Flint River water. But that means the pipes were stable, then destabilized, now destabilized again by the switch back.  It will now take some time for the scale to rebuild and to lower lead levels, leaving the residents of Flint at risk because of a business/finance/political decision that had not consideration of public health impacts.  And what is the ultimate fate of the KWA pipeline?

Just when things were starting to look up (?), in January 2016, a hospital in Flint reported that low levels of Legionnaires’ disease bacteria were discovered in the water system and that 10 people have died and another 77 to 85 affected.  From the water system?  A disinfection problem?  Still TOC in the water?  The lawsuits have begun but where does the problem lie?  Let’s look at Walkerton Ontario for guidance in the aftermath of their 2000 incident.

First it is clear that public health was not the primary driver for the decisions.  Treating water is not as simple as cost managers think.  You need to understand what water quality, piping quality and stabilization you have and address the potential issues with new water sources.  Membrane systems are very familiar with these challenges.  Cost cannot be the driver.  The Safe Drinking Water Act does not say cost is a consideration you use to make decisions.  Public health is.  So the initial decision-making appears to have been flawed. Cost was a Walkerton issue – cost cannot be the limiting factor when public health is at risk.

The guidance from consultants or other water managers is unclear.  If the due diligence of engineers as to water quality impacts of the change in waters was not undertaken, the engineering appears to have been flawed.  If the engineer recommended, and has lots of documentation saying testing should be done, but also a file full of accompanying denials from the receivers, another flawed business decision that fails the public health test.  If not, I see a lawsuit coming against the consultants who failed in their duty to protect the public health, safety and welfare.

The politics is a problem.  A poor community must still get water and sewer service. Consultants that can deal with rate and fee issues should be engaged to address fairness and pricing burdens.  Was this done?  Or was cutting costs the only goal?  Unclear.  The politics was a Walkerton issue.

Was the water being treated properly?  Water quality testing would help identify this.  Clearly there were issues with operations.  Telling the state phosphates were used when they were not, appears to be an operations error.  Walkerton also had operations issues as well.  A major concern when public health is at risk.  Veolia came to a similar conclusion.

The state has received its share of blame in the press, but do they deserve it?  The question I have is what does the regulatory staff look like?  Has it been reduced as the state trims its budget?  Are there sufficient resources to insure oversight of water quality?  The lack of provincial resources to monitor water quality was an issue in Walkerton – lack of oversight compounded local issues.  That would then involve the Governor and Legislature.  Politics at work.  Likewise was there pressure applied to make certain decisions?  If so, politics before public heath – a deadly combination.

So many confounding problems, but what is clear is that Flint is an example of why public utilities should be operated with public health at the forefront, not cost or politics.  Neither cost of politics protect the public health.  While we all need finances to pay for our needs, in a utility, money supports the operations, not controls it.  We seems to have that backward. Private entities look sat controlling costs.  Public agencies should look at public service first; cost is down the list.   We need the operations folks to get the funds needed to protect the public health.  And then we need to get the politicians to work with the staff to achieve their needs, not limit resources to cut costs for political gain.  Ask the people in Flint.

So is Flint the next Walkerton?  Will there be a similar investigation by outside unconnected people?  Will the blame be parsed out?  Is there a reasonable plan for the future?  The answers to these questions would provide utilities with a lot of lessons learned and guidance going forward and maybe reset the way we operate our utilities.  Happy to be a part of it if so!

%d bloggers like this: