I obtained a copy of Benton Harbor"s Water Asset Management Plan to see if it answers any of my questions. The 2017 WAMP includes a copy of a 2008 inspection report for the elevated tank.Based on the information to which I have access, I want to raise concerns about the current tank project. I see that the tank rehabilitation project has the potential to increase lead exposure in an already vulnerable environment justice population, it is not economically sustainable over the medium to long term , and the decision to undertake it was made years ago and does not consider current circumstances
Public Health circumstances in Benton Harbor and availability of infrastructure funding have changed substantially since the 2017 Benton Harbor Water Asset Management Plan. It is important to take a moment to consider stopping the immediate course of action and changing course to designing and building a new tank. This action , though extraordinary, may have the out come of protecting public health, spread money more efficiently , and more rapidly meeting the water quality needs of the residents of Benton Harbor.
The following discussion summarizes my observations, concerns, and questions regarding the current tank rehabilitation project.
The 2008 tank inspection report does not identify the lead paint/lead dust risk from the original 1962 coating, but it says that the 1990 coating is lead free. Where the tank assessment discusses the option of scouring the surface, it merely presents the cost of sandblasting with containment , but it doesn't explain the range of potential risks that the containment system is protecting from. The potential for lead exposure is not identified as a risk associated with the work. I do not if anyone in Benton Harbor has had the opportunity to consider its full implications, especially how this potential lead exposure layers on top of the three consecutive years of lead action level exceedances in the drinking water which were unknown at the time of the 2017 Water Asset Management Plan.
The 2008 inspection report identifies the myriad and water quality issues that need to be resolved with the old tank , the safety deficiencies based on current code (3 updates since original construction) and "The age and design of this tank with its lattice legs , structs , sway rods , and riveted construction make it very expensive to maintain compared to modern tanks". I'm sure the number of issues has only increased since 2008, but additional deficiencies are not identified in the 2017 plan.
From my brief read, it looks like Benton Harbor is investing a minimum of $400 k in a tank they know must be replaced for $ 3 million within the next 20 years with the unidentified consequence of potentially exposing the entire city to lead dust.
The $319 K rehab estimate in the 5 year plan does not include the sandblasting which is estimated at $375 K. Since I do not know the scope of the current tank rehab contract and whether that contract addresses all the deficiencies identified in the 2008 report. It's possible that the current contract could be for much more than $600 K given the extent of deficiencies identified in the 2008 report, thus making the funding even more difficult to raise in the future with more effective , modern tank in the future. The net results will be an even greater burden on rate payers for water quality and reliability that they need now.
Further I received FOIA information on the history of operators in charge at the Benton Harbor water treatment plant. The current operator in charge has only been in the position for one month and is certified for treatment , but not distribution. The person in the most important position to advocate for Benton Harbor water system needs is new and has not yet achieved the certification most relevant to operating elevated drinking water storage tanks. This put Benton Harbor at a severe disadvantage for identifying issues and modifying strategies's to best meet Benton Harbor's needs as the tank rehabilitation project progresses.
Given the influx of new money at the municipal and state level in Michigan, the current funding environment is substantially different in July 2021 compare to when the Benton Harbor Water Asset Management Plan was written in 2017. It is important to consider whether an immediate change of course can leverage new sources of funding , accelerate tank replacement in Benton Harbor , prevent a citywide exposure to lead dust, and provide a much-needed new tank that provides better water quality for the city, reduced maintenance costs, and improved safety for water department employees.
Lead is a potent irreversible neurotoxin with no safe level of exposure. Benton Harbor is a highly vulnerable environmental justice community with many ongoing sources of lead exposure that need to be removed and re mediated. Every time we miss an opportunity for exposure prevention, we are exposing another generation.
Here are the question I have based on the information available to me;
Does the city have access to clear information about the potential lead dust exposure risk from tank sandblasting? What site inspection and monitoring requirement are built into the current rehabilitation contract?
What is the scope and cost of the current contract to rehabilitate the old tank?
Has the engineering consultant considered the additional lead dust exposure risk from sandblasting the tank on top of the current ongoing lead exposures, including the ongoing lead in water action level exceedance , and known lead in paint in housing ? If this project was approved in 2017 , they wouldn't have had the additional context of three consecutive years of lead action level exceedances to understand that this is layering lead exposure on top of lead exposure, but it is important to consider at this time.
Has there been any assessment of whether dismantling the old tank(which must happen eventually ) might be a lower lead dust exposure risk that sandblasting.
What are the financial and health risks that would be associated with stopping work on the current rehabilitation project/ Can Benton Harbor change course right now and minimize losses associated with the tank.
Has Benton Harbor submitted any water infrastructure projects for earmarks? has the new elevated tank already been submitted ? This is a great opportunity to immediately put the influx of new money to work for Benton Harbor without impacting water rates. I recommend prioritizing earmark requests for a new elevated tank and lead service line replacement for the entire city.