June 16, 2019 Letter from Dr. Andrew Whelton to Director Ghilarducci and Director Sobeck
Dear Director Ghilarducci and Director Sobeck (CalOES Executive Team - inserted by NSWT) : On June 14, 2019, the California State Water Resources Control Board (SWRCB) issued plumbing testing guidance to persons affected by the Camp Fire. I ask that the SWRCB please retract and revise the guidance as I believe there are critical flaws. For reasons described below and attached, that guidance is not adequately protective of public health. Improved guidance can be issued by considering the implications of plumbing design, operation, materials, sampling, and exposure.
After repeated requests that I have received from those affected by the Camp Fire, my colleagues and I created the enclosed plumbing testing considerations document. We were going to provide it to the Camp Fire Water Task Force before publicly releasing it. Our intent was that you could consider this input from several experts who have been involved in investigating and responding to building drinking water contamination incidents in the development of your own guidance. But, CalOES, SWRCB, USEPA, and the health department never responded to my email on June 7 and SWRCB issued their guidance document on June 14.
There are several clear and important differences from what SWRCB made public to what we believe is more appropriate that maximizes protections to public health and is based on our respective experiences investigating and conducting building water testing. For clarity, the 7 individuals who helped to create the attached plumbing testing considerations document are engineering faculty and staff at multiple universities across the U.S. They, like myself, have specialized expertise for building drinking water sampling, chemical analysis, and decontamination. These individuals are accomplished engineers and researchers in this exact domain – which is why I sought out their input for you and citizens affected by the Camp Fire. As you know, I currently lead a national plumbing safety research program at Purdue University (funded by the USEPA) to help the USEPA and the water and public health sectors better understand plumbing safety (www.PlumbingSafety.org).
For review, my Purdue University / Manhattan College team volunteered to help county, state, and federal agencies on the Camp Fire Water Task Force conference calls with plumbing testing guidance since February. We offered this again to CalOES while we visited Sacramento, CA in March 2019. I reached out as recent as last week to CalOES, the SWRCB, USEPA, and health department to provide help but received no response.
My concern for the safety and well-being of those impacted by the Camp Fire and the specialized expertise needed to respond has prompted this document. The people affected by the Camp Fire have been through enough and any guidance issued should adequately identify contaminated plumbing and protect public health. Please contact me if you have any questions or want assistance. You can reach me at email@example.com and (765) 494-2160.
Respectfully, Andrew Whelton, Ph.D.
cc: Jason Blumenfeld, Secretary for Environmental Protection, CalEPA
cc: Director Zeise, Ph.D. CA Officer of Environmental Health Hazard Assessment
cc: Andrew Miller, MD, Health Officer, Butte County Health Department
cc: Ann O’Leary, Chief of Staff, State of California Governor’s Office
cc: Michael Stoker, Administrator USEPA Region 9