The Whelton Group – Relocating

Late Monday afternoon August 4, the City of Toledo released their Preliminary Water Crisis Study Report. This report describes some of the data and actions taken during the recent large-scale tap water contamination incident. Earlier in the day, the Mayor of Toledo declared tap water safe to drink for the entire 500,000 person area. The Toledo-Lucas County Health Department then issued guidance to residents and businesses on how to flush their plumbing systems.

I provided some thoughts about their report below mainly focusing on tap water contamination response and recovery. In short, their preliminary report does not address many questions pertaining to the degree scientific principles were considered in water use, water testing, and flushing recommendations. The report also does not answer many of the public’s remaining questions. For an incident that affected 500,000 people, residents being told to flush contaminated water into their homes, and that the new water is safe, the lack of information provided by officials as of today is remarkable. Hopefully someone explains what happened and what data they used to make decisions in the coming days.

Who actually was involved in the response and decisions remains somewhat of a mystery

The report cites the Mayor, City of Toledo, Toledo-Lucas County Health Department, the Oregon treatment plant, Lake Superior University, Ohio EPA Columbus, and US EPA Cincinnati, but has no mention of CDC. According to the report the organizations listed above were the only organizations that had a hand in the data collection, analysis, reporting, and decision making process. Publicly, the health department proclaimed CDC was involved during an interview.  But CDC was not listed in the City of Toledo report? Who was involved and what advice did they provide? This is important information as it can clarify why certain decisions were made and who provided information.  I know many folks in the drinking water industry including other water companies and experts that contacted Ohio organizations involved and offered assistance. From what I understand, responders did not accept any assistance except from the few organizations listed above. Even so, they seem to have had contact with other organizations they did not disclose in their report (i.e., CDC).

Did officials mislead the public? It was really a Do Not Use order for some of the residents

The report portrays the responders considering the incident as a Do Not Drink /Do Not Boil Order, but that is not quite accurate. After issuing the Do Not Drink/Do Not Boil Order, the Toledo-Lucas County Health Department actually went further and publicly advised immunocompromised persons, children, and breastfeeding individuals not to have any contact with the water. That’s not a Do Not Drink Order. That’s a Do Not Use Order more similar to what was issued in West Virginia following the Crude MCHM Chemical Spill where 300,000 people were denied access to tap water for up to 10 days. The Toledo-Lucas County Health Department also advised people it was okay to brush their teeth with the contaminated water, then pulled back on that recommendation a day later. These conflicting messages implied that the responders were creating guidance on the fly, and/or did not understand what a Do Not Drink Order was.  The media kept reporting Do Not Drink orders, but the Health Department was advising the population to do more than simply not drink the water. The incident was a Do Not Use order for some people not just a Do Not Drink /Do Not Boil order.

Some of the reported microcystin data could be suspect because of water collection practices. It was a good decision to use multiple labs.

Water samples that were shipped to Lake Superior State University had chlorine residual present. Microcystin (toxin) is known to react and degrade (and transform into other compounds) when exposed to chlorine. Thus, during shipping some of the toxin could have been destroyed or transformed into other compounds. To limit these changes, chlorine residual neutralization should have been considered once the water was collected. No justification of why samples were allowed to react with chlorine during transport (or not) was provided. Microcystin experts reading this will likely have more insight into the analytical methods. Kudos to Lake Superior State University for their work on this effort. Great to see independent experts involved. It would be helpful if officials could explain their methods.

Were the water samples collected representative of the highest chemical levels in the water  system and at exposure locations?

During a quick response, responders generally collect water at easy to access locations such as at the source (i.e., Lake Erie), water plant, and within in the water distribution system (i.e., hydrants, restaurants, etc). This information is important to understand the scale of contamination (where the tainted water is). After tap water leaves the treatment plant, it does however take tap water different times to travel to different parts of the community so some tap water may be newer in certain other parts of the water system. Why were certain water distribution system locations selected for sampling? Do they  represent the entire water system or are they biased? Reasoning why the certain locations were selected was not provided in the report. Did the responders sample to find out the highest chemical levels in the water distribution system? Were they representative?

Also important to point out is that tap water quality at a fire hydrant is not necessarily the same as tap water quality in a residential building. It remains unclear if responders tested in-home locations. [BP Gas station plumbing systems are not the same as two story home plumbing systems, dormitories, or apartment complexes].Restaurants, government buildings, hydrants, gas stations, etc. were some of the tap water collection points. This is similar to West Virginia’s initial response. West Virginia only tested hydrants, government buildings, and businesses. But, the question everyone asked in West Virginia that turned out to be important was what chemical levels were in found at the exposure points….within people’s homes?

If Toledo learned from West Virginia, they would have considered sampling in homes. What did they do and why did they do it?

The plumbing system flushing protocol was never tested before residents were told to partake

The ability of the flushing protocol to reduce chemical levels within homes was never tested. The reason for this decision by the responders was not described in the report. Moreover, no personal safety guidance was provided to residents about how to avoid tap water chemical exposure during flushing. Was it okay to flush hot water with your children in the room or house? (see below for some scientific analysis)

The Toledo-Lucas County Health Department plumbing system flushing guidelines were nearly identical to those used in West Virginia (where people experienced acute chemical exposure symptoms while following those guidelines). Similar to West Virginia’s flushing guidelines, the Toledo-Lucas County Health Department guidelines are also similar to those when tap water with high levels of pipe corrosion products such lead and copper needs to be removed from plumbing systems. Water utilities have a long history of flushing certain chemicals out of their system to include lead, copper, iron, sediment, etc. I am not aware of any existing protocols for flushing microcystin contaminated tap water from homes however. This could be the first. What conditions would have been needed for officials to “test” the protocol before directing residents to partake?

There are key differences between the Toledo and West Virginia tap water contamination incidents that pertaining to flushing. Chemicals in West Virginia’s tap water were volatile meaning that they would readily evaporate from water into air. When West Virginians opened their taps to flush contaminated tap water, chemicals volatilized into the air. Flushing hot water in West Virginia exacerbated this problem. Many homes in West Virginia my team visited had poor ventilation bathrooms and chemically contaminated air accumulated. Like the West Virginia incident, hot water flushing was recommended in Toledo. But, in Toledo, microcystin (and likely its degradation products) were much less volatile. So, the probability of chemicals in Toledo’s water evaporating into air was much less. Still, should hot water flushing been recommended in Ohio knowing that organic chemicals volatilize into air faster than cold water?

As of August 5, no increased reports of acute chemical exposure symptoms had been reported in the Toledo area which is a good sign. I hope they address this topic in the coming days.

In Closing…

The Toledo incident again demonstrates that in the US, large portions of our population can be denied access to safe tap water and responding to contamination incidents is very complex. Seven months ago 15% of the people who live in West Virginia experienced something very similar.

I have no doubt officials responding to the Toledo incident worked very long hours, likely days without sleep and sacrificed many hours away from family and friends to help. We will never know the names of many of these individuals, but they should be widely thanked for their service in helping investigate and recover the community from this incident. These individuals helped out because they care about the health and welfare of the community similar to what I witnessed in West Virginia.

Several hours after the City Council meeting we have a little more information, but not much. According to the City of Toledo, EPA still has not released all of their data. There were tremendous data release delays by Federal government agencies during the West Virginia crisis. Federal agencies, from my perspective, were at times completely detached from the timeline of people who lived through the incident. The State of West Virginia requested numerous times for Federal agencies to provide data and results took months to obtain. Federal agencies were on their own timetable. Will that be the case in Ohio?

If residents affected by this incident are to feel confident in their tap water and officials, they need and deserve answers soon. If the Nation is to learn from this incident, more information must be made public. While there clearly is a need for improved nutrient control near Lake Erie, communities across the Nation can benefit from learning about the good and bad of this large-scale tap water contamination response. It’s inevitable; We all need safe tap water and these incidents will happen again.

Sincerely,

Andrew Whelton, Ph.D.

NOTE: This post could be revised if information is brought to my attention requiring the post to be revised. Revision explanations, if any, will be posted at the bottom of the page.