Update: This article has been revised. Corrections and clarifications are noted at the end. We regret the errors.
Recent events in Portland’s water world have been exciting, controversial and downright confusing. November’s E. coli scare and Boil Water Notice caused neighbors to question the safety of Portland's drinking water—questions that made Portland’s ongoing reservoir and treatment debates relevant to a wider audience.
But, what are these debates all about? Should our water storage system be covered? Should Portland’s water be treated? These issues are related, complicated and confusing—especially since most of us just really want to know if our tap water is safe for consumption now and in the future. But learning about our water system truly is a good idea, given that the debate outcomes could affect our water quality and increase rates for new and improved systems for the water we drink, bathe in, flush, boil and pour into our vegetable gardens.
Bull Run reservoir. Photo: Portland Water Bureau
The Great Reservoirs Debate—Open or Closed?
This question has been the focus of impassioned debate long before the E. coli scare. In Portland's Open Reservoirs—A Primer, Portland Water Bureau (PWB) Chief Engineer Michael Stuhr lays the groundwork—more than you ever wanted to know, perhaps—to help explain the origins leading us up to the great reservoirs debate. (Key points from PWB Director David Shaff's notes for PWB's overview and status update on compliance efforts to the open reservoir rule are included here, as well.)
- Our City’s Water Bureau operates five open, finished (finished = treated water that does not need any more treatment steps to be delivered to the public for consumption) water reservoirs—three at Mt Tabor and two at Washington Park.
- These reservoirs are all nearing 100 years old, but were typical construction before the turn of the century. (Long-term, expensive maintenance would certainly become a huge challenge for many municipalities with such systems in time.)
- Since we’ve learned so much about waterborne disease and water quality issues, some key organizations—American Public Health Association (APHA), the U.S. Public Health Service (USPHS) and the American Water Works Association (AWWA)—all came to recommend that finished reservoirs be covered by the middle of the 20th century.
- Before Bull Run, people got their water from wells, rivers, streams—sources that could be potentially and easily contaminated from humans and animals via direct dumping or surface run off. Bull Run offered improved water quality and thus, improved public health.
- The EPA was created in the 1970s and also heeded the call to cover finished drinking water reservoirs.
- A serious Cryptosporidium outbreak in Milwaukee, WI occurred in 1993. Over 50 deaths and 400,000 illnesses resulted from this micro-organism (Crypto) that is naturally present in surface water worldwide.
- In 1999 the EPA established rules requiring that finished water be stored in enclosed tanks. These rules included a grandfather clause that exempted existing open reservoirs from this particular requirement.
- In August 2003, the EPA proposed a rule that Crypto is a contaminant that must be regulated for "health risk reduction for persons served by public water systems."
- In 2004, the Long Term 2 Surface Water Treatment Rule (LT2) was merely a proposed rule offering three options to reduce risk potentially inherent in open water systems: cover open reservoirs, “treat water to achieve 4-log virus inactivation, or implement a State-approved risk mitigation plan.”
- Portland City Council decided "to pursue alternative forms of compliance for the LT2 rule" and "met with EPA officials to encourage the agency to alter the final rule" to "include alternate approaches that would allow Portland to avoid building additional treatment."
- By January 2006, the LT2 rule was finalized with some modifications—the third “risk mitigation” option was eliminated, and the second option was altered to “require 3-log Giardia and 2-log Cryptosporidium treatment.” The LT2 open reservoir rule also eliminates the 1999 rule’s grandfather clause and requires “that all finished drinking water must be stored in enclosed tanks without exception.”
Reservoir No. 3 in Washington Park empty for cleaning after testing positive for E. coli
While no one really denies that Bull Run provides pristine water, the problem [in the EPA's estimation] begins with the transportation of that good, clean water via thousands of miles of pipe from an isolated location to the City’s reservoirs in a populated or “high intensity” environment. According to the EPA, the access to an open water source in a high intensity environment "greatly increases the risk of decreases in water quality that can affect human health. Water leaving the open reservoirs goes directly to customers without the required contact time to properly disinfect prior to the tap.” It’s both the travel to and the storage in an open facility that potentially muddy our drinkable water as there’s no treatment of water leaving the reservoirs. Two of Portland’s open reservoirs—one at Mt Tabor and one at Washington Park—receive “booster chlorination.” This treatment is different than what the EPA calls for in the LT2 rule.
Expanded knowledge in the areas of science and public health as well as midcentury recommendations (via various guidance manuals) to cover finished water reservoirs influenced the EPA to continue to push for covered reservoir systems. As water science continued to advance, risk-reduction became the motivating force in regulation creation. Disinfection methods became important protection measures, as did covering open sources. It was discovered that the longer water stays in its distribution system, its quality deteriorates. Managing that time (known as retention time) is what water utilities focus on, in addition to managing “the physical environment of the water to minimize negative effects on water quality. These two goals, as simply stated as they are, lead to the need and now Federal requirement to cover the reservoirs.” [From: Portland's Open Reservoirs—A Primer.]
PWB's utility peers agree upon the main concerns with open reservoirs: unstable water quality; algae, taste and odor issues; nuisance, aesthetic and security concerns; no protection against pathogens; not meeting regulatory requirements.
But many, such as Friends of the Reservoirs (FOR), do not believe that covering the reservoirs is necessary at all. FOR (and others) argue that there’s been no significant trace of Cryptosporidium in Portland’s water system for decades and point to the potential of covered reservoirs contributing to cancer-causing nitrification and other serious health risks. Crypto was actually last detected in 2002, but monthly sampling in Portland began in the 1990s. Remember that the 1993 incident brought national attention to Crypto, leading up to the LT2 rule requiring that Crypto be addressed at the source. The rule must be complied with to eliminate the opportunity for recontamination. (More on the treatment requirement later in this article.)
Reservoir No. 1 on Powell Butte, an underground reservoir
Request for Variance Application—Denied
The LT2 is one rule with two requirements—the open reservoir requirement and the treatment requirement. As the reservoir debate simmered into a slow boil, Commissioner Leonard sent a letter of inquiry to the EPA informing the agency that Portland would like to pursue a variance for open reservoirs. The City’s sequence of tasks related to this request for variance process was criticized by many, especially FOR and other open reservoir supporters. Criticisms included that the “initial investigative steps took too long,” that “PWB didn’t supply appropriate scientific data as requested by the EPA,” and that the “EPA’s request relies on faulty science.”
But the criticisms and public pressure didn’t prevent the EPA from telling Portland that a request for variance was not an option. The feds require cities with uncovered reservoirs to cover them, or provide treatment systems at the source (in our case: Bull Run) “to inactivate Cryptosporidium, Giardia and other viruses.” PWB then challenged the LT2 rule by filing a lawsuit with the Court of Appeals—and lost. Portland now must adhere to the rule that “reservoirs must be covered or treatment plants in place at the outlets or be in compliance with a State-approved schedule to meet these conditions no later than April 1 2009. PWB has received an approved compliance schedule from EPA for the reservoirs.” Mid to late March 2009, the EPA signed off on Portland’s plan to end its use of open reservoirs—Mt Tabor by 2015, and Washington Park by 2020.
Portland presented the EPA with its very first request for variance application. No variance application has ever been filed for the open reservoir requirement under the LT2 rule; however, the treatment requirement of the LT2 rule does have a variance option. PWB spent 14 months generating a sampling plan for the EPA. In mid May 2009, David Shaff alerted the public that the "14 months designing a variance approach—work done specifically at their [EPA] direction—was more or less for naught" and that new “issues raised by the EPA about the city's proposed water quality sampling program will delay implementation of the program until the city can address them to the satisfaction of the agency." PWB submitted two more sampling plans to the EPA, the last one in November 2009; sampling began in mid-December 2009. The EPA later asked for other items not originally on the punch list of deliverables—demonstrating statistical validity, testing raw water outtake and more. Ed Campbell, Director of Resource Protection and Planning at PWB, detailed the lengthy and complicated history around the variance process. "We are all engaged in a very serious effort to comply…and yet because no one has done this before it’s become tricky.”
Reservoir No. 5 on Mt Tabor
The consequences of non-compliance with the EPA ruling loom large, too. These potential penalties span:
- daily fines for separate reservoir violations;
- EPA-mandated regular notices to all Portland water customers about health risks and out-of-compliance status;
- violation of Portland’s wholesale contracts;
- state sanctions that include potential loss of public water system certification; and
- EPA seeking injunctive relief demanding compliance. (If the City of Portland refuses to comply with a court injunction, the U.S. District court could assume power of PWB.)
While many still argue that the City didn’t comply with the EPA’s process when it was attempting to apply for the LT2 variance, PWB assures me that they did indeed move forward with the treatment variance request, providing all requested evidence to the EPA. The open reservoir option is now moot—the EPA says we must cover our reservoirs. PWB’s David Shaff noted recently that “Refusing to comply with federal law, and incurring fines of $37,000 per day for non-compliance, no matter how much the City Council disagrees with the law, is simply not a viable option or approach.”
Reservoir No. 1 on Mt Tabor
Water Treatment Debate
Remember that the LT2 rule has two requirements—including one that requires all surface water sources of drinking water (our Bull Run) be treated for Crypto. Many of us are not aware (and are certainly confused about) that compliance with the LT2 open reservoir rule is completely independent of compliance with the LT2 surface water rule. Risk mitigation (by eliminating Crypto) is the primary goal of the surface water rule, while Crypto is not a major factor or concern in the open reservoir rule. (The LT2 open reservoir requirement is a minor update to existing storage rules.) In order to maintain water quality and help ensure public safety, Portland disinfects its water with chlorine from “the initial treatment point through the distribution system to the tap.” The EPA is allowing the City of Portland/PWB to test the water in the Bull Run watershed to prove that the water does not need to be treated for Crypto. (Reminder: Portland’s water is indeed treated for other bad bugs.)
The steps to the pump house at Reservoir No. 5 on Mt Tabor
Recent Developments
On January 5, 2010 members of the Portland Utility Review Board (PURB) Water Bureau subcommittee presented Portland City Council with a memo outlining their opinion (not voted upon by PURB) and recommendation to “think long term and adopt an all encompassing approach to managing the water bureau’s response to the LT2 open reservoir rule.” The memo also requested that the City Council identify and gather additional information before presenting a discussion to the public. The areas to be discussed include: the EPA's open reservoir requirement, its relationship to Crypto and the EPA's LT2 surface water rule; the best way to store finished drinking water (enclosed tanks or open reservoir) and the life expectancy/condition of the existing in-town reservoirs.
The subcommittee recommended that the City Council replace the existing in-town open reservoirs with enclosed storage for a variety of reasons:
- Current reservoirs are now near the end of their useful lives, requiring dramatically increasing maintenance efforts to remain operational;
- Enclosed tanks are the standard for storing finished water, offering substantial water quality improvements compared to open reservoirs.
Note that in 2004, the 13 member Mt Tabor Independent Review Panel formed "to review the City's decision to retire Reservoir 1 and replace Reservoirs 5 and 6 at Mt Tabor...The panel was not charged with and did not address the open reservoirs at Washington Park."
Reservoir No. 1 on Mt Tabor
To coincide with the City Council work session (mid January), FOR sent a letter to Portland City Council with a series of requests, or “advice” spanning multiple issues including the following points:
- The variance process is flawed;
- The EPA’s arguments for closed reservoirs are unsubstantiated;
- The City has not provided adequate scientific research/viable supporting evidence to the EPA;
- The City has not responded in a timely manner to the EPA;
- There’s no public health benefit derived from underground/covered reservoirs; covered reservoirs actually produce cancer-causing nitrification;
- There has been no infectious Cryptosporidium detected in our open reservoirs;
- The relationship between the City and some contractors is precarious at best, and approval of particular consultant contracts must cease;
- Building a purification treatment plant at the Bull Run source is a useless and costly endeavor.
But Campbell says it’s all more complicated than FOR lets on. To some of the points FOR has continued to raise, he offers that the EPA now requires a blanket level of security, that NO amount of Cryptosporidium in water systems is considered safe, so all unfiltered water systems (like Portland’s) need to be treated either by filter or by UV radiation systems. [It’s important to note that Portland City Council voted July 29, 2009 to direct PWB to only plan for a UV treatment system, resolution #36720. Filtration was ruled out as a viable option for a variety of reasons including its high price tag—it’s three or four times the cost of building a UV system.] The problem is compounded at the Bull Run source. He states:
Even if our water has a treatment system at the source, the water still travels to Portland and therefore can be exposed to contamination from people and animals by the time it gets to our open reservoirs. The EPA wants us to treat this water again because it’s considered raw water, potentially contaminated.
The options? “To close or cover the reservoirs, or to build treatments systems that handle Giardia, Crypto and other viruses.”
Reservoir No. 6 on Mt Tabor
FOR’s Floy Jones (and other individuals and organizations like Oregon Wild) remains focused on moving the City to action (i.e., continue to fight the EPA). Jones recently posted commentary on the EPA regulation requiring additional treatment or covering of open reservoirs is a mandate:
for a problem that does not exist, Cryptosporidium. The open reservoirs were extensively tested for this microbe with ZERO detected. Additionally treating the open reservoirs will provide no measurable pubic health benefit. The requirement benefits the PWB's favorite cozy consultant and the corporation that employs him, but will provide no measurable public health benefit to citizens whose water bills will double in five years.
So, Now What?
FOR and other open reservoir supporters may not agree that the debate is over, but PWB is moving forward. It stepped up the testing process—from testing 50 liters of water to testing 800 liters of water—to meet EPA established rules for its continued source water quality sampling program and gather a solid data set to show if Crypto exists. PWB plans to install a fully functioning treatment plant that uses a UV radiation system for treatment, and is also now chasing another variance—an extension until 2014 to build a UV treatment facility at Bull Run. “Remaining compliant with EPA regulations is really important or the whole process and timeline could be in jeopardy,” warns Campbell, “and we could potentially be in violation of our wholesale water contracts.”
Reservoir No. 4 in Washington Park
PWB contends that it is pursuing parallel tracks toward treatment compliance by seeking both a treatment variance (e.g., an alternate form of compliance) and planning for conventional compliance (e.g., design, approve, build a treatment facility) in order to not threaten various elements of operational status, as outlined previously, as the best way to move forward since tight water quality testing and design review deadlines both are looming large. The PWB will continue to generate a robust, full year's worth of data to possibly support its application for the treatment variance. Design of a UV system will also move forward so plans will be ready if a variance is not possible or not awarded. “There won’t be any construction until the City Council’s first quarter of design is completed in April. Then we’ll move forward with design,” clarifies Campbell. By early 2011, PWB will know if it’s likely (or not) that the EPA will grant a variance. If it is likely, then the variance track will move forward; if unlikely, then City Council will need to authorize an action plan so construction of a UV treatment facility can begin.
Another active voice in these issues is PURB. The group held a public hearing on March 3, 2010 to gather public testimony on water issues relating to open reservoirs and water treatment. What appears now on the site are many PDFs offering written public testimony and documentation from citizens, activists, neighborhood association members and the Alliance for Democracy that was collected for this public hearing. (Audio testimony can be accessed here) Most assert that the City of Portland and the PWB are acting with negligence when it comes to protecting our resources, both water and dollars. One accuses the City and PWB of a serious conflict of interest with its choice to use the engineering consultants CH2M Hill as one of three contracted firms to both sample and build. Read through the varied documents and you'll get a snapshot view of how some Portlanders feel about our reservoirs with plenty of commentary about what the City should do.
Reservoir No. 2 under construction on Powell Butte.
Photo courtesy of Portland Water Bureau
Why We Should Care About Our Water Quality
As noted previously, Portland’s reservoirs have a limited life expectancy, and the City is already investing in underground reservoirs on Powell Butte as a replacement for the current reservoirs that are between 98 and 115 years old. An eight member majority of the Mt Tabor Independent Review Panel (in 2004) recommended that the City "pursue a risk mitigation plan to improve security and water quality at Tabor" while a five member minority of that same group recommended that the City "bury the Mt Tabor reservoirs while attempting to leave the existing open water features as intact and visually similar to their current state..." Director Shaff asserted at the PURB public hearing that Mt Tabor reservoirs 1, 5 and 6 must be disconnected from the distribution systems no later than December 2015, that Reservoir 3 in Washington Park must be replaced with a buried tank, and that Reservoir 4 must be disconnected from the system no later than December 2020. These directions are in compliance with the approved LT2 schedule.
Jones emphatically details that not only is there no public health benefit to closed reservoirs, but there are “issues that are unique to underground” systems, aside from the “budget burden” that an already strapped City will face. “There’s no public health issue with Portland’s current water system. The City is acting upon an artificial emergency, and, to what end?” She reports that not one organization who has independently studied this issue supports Portland’s (City and Water Bureau) position including the Sierra Club and Oregon Wild who apparently supports the retaining of open reservoirs and hopes Portland will not build a UV radiation treatment plant. [Neither Sierra Club nor Oregon Wild reps returned phone calls for this article.]
Crews removing dirt for Reservoir No. 2 at Powell Butte
Depending upon which expert opinion you enlist, our good Bull Run sourced water may (or may not) diminish in quality once it is treated and/or stored in a covered unit. As with any large-scale project the City takes on, the ratepayers are responsible to cover costs—and any new water filtration or storage system is going to cost plenty. In the coming months, we’ll know more about where our City is headed on the issue. In the mean time, you can keep updated on both the PWB and FOR sites—these two parties are committed to bringing information to the public that hopefully helps us all understand more about our reservoirs, treatment plant plans, water quality testing, costs and more. In the long term, we all should be invested in the conversation about how our resources (both water and rates) are being handled. I urge you to conduct your own due diligence to stay informed about how your water is being managed, protected and delivered for your—hopefully risk-free—consumption.
This article has been revised to reflect the following corrections and clarifications:
Corrections and Clarifications (3.15.2010):
Taxpayers were identified as being financially responsible for any new water systems and improvements. In fact, it is the ratepayers who would bear the financial burden for new water systems and improvements. No tax dollars would be used for these projects and improvements.
LT2 was identified as being two separate rules (and is often labeled as such in other official documents, too). The LT2 is one rule with two requirements—the open reservoir requirement and the treatment requirement.
It was stated that the City’s LT2 variance was denied. In fact, no variance has even been filed for the LT2 open reservoir requirement. In the revised article, we further clarified that Commissioner Leonard made a request for variance, but the EPA said that a variance was not possible. In a nutshell: Portland never even got to apply for the variance, much less have it denied. The request was denied.
Many groups claim that no Crypto has been detected in Portland’s water for years, yet it was detected as recently as 2002. Portland’s water has been tested for Crypto in different samplings and quantities since the 1990s. The EPA is allowing PWB to test Bull Run to prove that the water doesn't need to be treated for Crypto.
Portland is moving forward with the EPA mandate to discontinue the use of open reservoirs.
Portland City Council made a decision in July 2009 to seek alternatives to compliance in building a treatment facility at the Bull Run source. If Portland must build a treatment facility, then it will be a UV system not filtration.
PWB is pursuing parallel tracks for compliance by planning for both a treatment variance and a treatment facility. In 2011, Portland will know which path must be taken.
Further reading
For more LT2 information, see:
http://www.portlandonline.com/water/index.cfm?c=51794
For more on the treatment variance request, see:
http://www.portlandonline.com/water/index.cfm?c=52066
For treatment compliance and City Council resolutions, see: http://www.portlandonline.com/water/index.cfm?c=51796&
For the legal challenges, Court of Appeals decisions, and related documents, see: http://www.portlandonline.com/water/index.cfm?c=52037&
For more information on Friends of Reservoirs’ opposition to buried reservoirs, see: http://friendsofreservoirs.org/resources.html
To learn more about Portland’s water sampling plan, see: http://www.portlandonline.com/water/index.cfm?c=39678&a=272429
To read the public comments collected at the March 2010 PURB meeting, see:
http://www.portlandonline.com/omf/index.cfm?c=52331
To hear the March 2010 PURB meeting audio files, see:
http://www.portlandonline.com/omf/index.cfm?c=52330
To read Oregon Wild’s position on clean water and Bull Run, see:
http://www.oregonwild.org/waters/bull_run
To read the City’s official statement addressing the $73 million water revenue and refunding bonds, see:
http://www.portlandonline.com/omf/index.cfm?c=31438&a=287469
The City Council wants the people to shut up and pay up, as water rates skyrocket for the next few years...for no public health benefit!. The PURB "subcommittee" are two people appointed by, and for Commissioner Randy Leonard. I know because I have been at almost every PURB meeting in 2009. Shooting video.
You can see and lIsten to the UNANIMOUSLY OPPOSED TO COVERING Citizen Comments at the March 3, PURB Hearing on Open Reservoirs. PART TWO: CITIZEN'S COMMENTS. http://vimeo.com/10051067
Yes, sorry, it's slow to stream...start it and come back in awhile.. That's the way Vimeo works..
Brad, It actually streams quite well. You can start watching it immediately. It's well worth watching to hear an array of Portland citizens' well-thought-out, intelligent comments on this serious and seriously expensive issue.
It's my understanding that Portland residents pay more per unit of water than suburban customers do, and that suburban customers are not asked to pay debt service. Consequently, I wonder why there is so much concern about these customers.
citizensforportlandswater.org is another website that can be checked, as well.
Jack Bog's Blog often has entertaining bits. Detailed information regarding debt instruments often shows up at Jack's first.
At least two physicians testified against covering, possibly three.
Working one-on-one with Portland residents enjoying Mt. Tabor Park, I can say people are worried about these plans and about the hikes in living costs and health risks they mean.
Except for the government sector and contractors attached, living costs go up, while employment goes down. This is an equation with variables that may not work the way the Water Bureau forecasts.
Already, usage is over over-estimated by the Bureau, meaning shortfalls in budgets at the end of the year.
If Portland were to get a 10-year extension, piggy-backing on New York, there would be time for state-of-the-art technology, as practiced in private wineries in California, to trickle up to government agencies.
It is curious to me why the Bureau seems so little concerned about ratepayers' health and financial burdens.
Is this because it is the county on the line when people fall in to dire straits, so it is "not my concern" territory?
With its beautiful, pristine, and energy-efficient system, Portland could have taken the lead in speaking with a firm voice against federal impoverishment plans. It seems a shame that no one at the city seems prepared to exercise this courage. Citizens have volunteered untold hours to ask for this.
Acknowledgment of independent citizens' due diligence could have enhanced creation-care on a national basis. Instead, we have a West Coast version of hilltop desecration. Sad.
The Portland Water Bureau (PWB) information being distributed here and elsewhere is both misleading and intentionally leaves out critical bits of information that an uninformed public needs to know. Regarding the contaminant Cryptosporidium for which the EPA LT2 requires source water and open reservoir “treatment”, problematic Cryptosporidium genotypes, those causing public health concern, are from humans or cows neither of which are present in the Bull Run watershed nor in Portland’s open reservoirs. The contamination in Milwaukee, WI was from human and cow sewage back flowing thru a state-of-the-art chemical filtration plant. The reason for need of a filtration plant in Milwaukee is that their watershed unlike Bull Run was not protected from human entry or cows.
With regard to the EPA LT2 Crypto regulation, equipment and chemical suppliers were involved in negotiating this rule, creating a variety of problems for the drinking water community. The Portland Water Bureau compounded the problem by secretly hiring its favorite cozy consultant, Joe Glicker, MWH (now with CH2MHILL), to assist PWB in negotiating a rule that now benefits same consultant and corporations.
Regarding the PWB Thanksgiving “scare”, the trace bacteria detect was determined to be non-infectious, just like bacteria we encounter in our every day lives. PWB corporations had just installed automated isolation valves at the open reservoirs such that the Washington Park Reservoir 3 could have been taken offline and the unnecessary boil water alert averted. The source of the non-infectious bacteria was never confirmed per Dr. Gary Oxman, Multnomah County Public Health officer despite the PWB wanting the community to think birds were the source. If birds were considered a problem at the open reservoirs, bird wires have proven effective at New York’s Hillview and Tacoma open reservoirs as well as in other locations. Per a PWB consultant report and the State Drinking Water Program data on Portland’s water, bacteria is detected throughout the distribution system and not focused at the open reservoirs. The PWB, in violation of EPA protocol, takes it’s water samples without using gloves.
Much of what the Bureau is trying to sell today was thoroughly and comprehensively examined (and rejected) by a costly City-selected 2004 open reservoir panel lead by a EPA LT2 Federal Advisory Committee consultant who was paid $325,000. A friend of the PWB and cozy consultant engineers chaired the panel.
The 13 -member panel excluded all neighborhood associations and neighborhood coalitions as well as all Bull Run advocacy groups including The Friends of the Reservoirs who at that time had intensively researched all issues related to the open reservoirs, LT2 and our Bull Run system for a year and a half. The panel included then PURB chair, Frank Ray. The panel cost ratepayers $5-600,000 including extensive PWB staff time, MWH global involvement as well facilitator costs of $30,000. The panel met for 2-3 hours per week for 3 months allowing for only a few minutes of public testimony at the end of the 2-3 hours. A couple of additional meetings were scheduled for public testimony. The panel did not support burial or covering the reservoirs. The panel report as well as an article by a panel member can be found at http://friendsofreservoirs.org/resources.html
The Panel addressed:
· “Everybody else is doing it”- Irrelevant and false
· Water Quality (no Giardia, virus or Crypto problems) Portland Water Quality is excellent. Consultant MWH Water Quality study showed no degradation from Portland open reservoirs. No unique public health risks
· Security and Protection, risks low, no unique public health risks.
· Age and Condition- Determined to be in good shape for age. PWB 2008 consultant report confirmed same; PWB 1995-2004 consultant study confirmed same
· Costs excessive
Open reservoirs will continue to provide safe drinking water to tens of millions around the nation, i.e. Hillview, NY, Highland Park in Pittsburgh, Rochester, and Baltimore.
Community stakeholders support sound science as the foundation for policy not corporate influence. NY’s water department has scientists on staff. The PWB hires public relations people or geography majors and calls them Water Quality experts. You can read about the background of the Portland Water Bureau managers in the City’s official water bond statement.
Does the corporate industry support projects that guarantee them a steady stream of build and rebuild projects? Yes. Is there ANY EPA SCIENCE that supports burial or covering? No. EPA’s own Total Coliform Rule revision white papers on Storage Facilities and Nitrification speak to the problems with covered storage.
RECENT TABOR AND WASHINGTON PARK OPEN RESERVOIR UPGRADES- $45 MILLION + BETWEEN 2003-2010 (Not counting secondary water main installed at Tabor)
Open reservoir upgrade projects at Washington Park and Mt. Tabor, projects designed for a 50-year life span will be completed in 2010.
Four corporate contracts were involved in these upgrade projects; two contracts are still outstanding including a $23 million Slayden Construction Group open reservoir contract. The Portland Water Bureau’s plan is to reduce the 50 year + life span value of these upgrades to 4 years at Tabor. As soon as the upgrade corporate contracts expire, the Bureau’s plan is to award more corporate contracts to dismantle the upgrades.
Ratepayers will pay for these upgrade projects for the next 20-25 years.
Reservoir Variance Application not made-The PWB spent public monies participating in an open reservoir Infectious Cryptosporidium scientific study through the American Water Works Association Research Foundation (AwwaRF 3021) sampling large volumes of water at the outlet of open reservoirs (the location were water is distributed to customers) between 2008 and May 2009. Zero Cryptosporidium were detected. Unlike New York, the PWB has failed to compile this and other supportive data into a report that could then be submitted in support of the available and approvable Safe Drinking Water Act “treatment technique” variance.
From page 23 of the City’s official $73 million Water Bond statement, http://www.portlandonline.com/omf/index.cfm?c=31438&a=287469 “… the rule would require changes to how open finished drinking water reservoirs are utilized, managed and/or operated.
The rule requires that water systems with uncovered finished water reservoirs, like those at Mt. Tabor and Washington Parks, either cover the reservoirs or provide treatment at the outlets of the reservoirs to inactivate Cryptosporidium, Giardia and other viruses.”
None of these organisms, Crypto, Giardia or viruses are present in Portland’s open reservoir. Portland has the scientific data to support the available and approvable variance but has failed to prepare the data document in support of a variance application.
The EPA source water variance plan is flawed. You can read details of this in our September 2009 letter to City Council found at our website, www.friendsofreservoir.org
Source water treatment
For the record, City Council has already rejected the PWB/ corporate plan for a chemical filtration plant. The Council vote took place last July 29, 2009. A broad-based group of community stakeholders fought against chemical filtration with 40 folks signed up to testify.
Bull Run advocates will continue to fight against the unnecessary new risks from UV radiation and burying the open reservoirs.
Tell Commissioner Leonard and the rest of City Council that you want him to require that the Portland Water Bureau prepare the data document in support of an open reservoir variance and avoid the creation of new risks from cancer-causing nitrification or more radon venting into Portland homes. And avoid the unnecessary doubling of water bills for no measurable public health benefit.
Eve,
Over the years it has been the covered reservoirs that have had public health problems from microorganisms and chemicals. Incidents of Salmonella deaths and chemical leaching from hot mopped coal tar, lead paint coating, and volitile organic compounds are well documented in covered reservoirs. No public health problems have occured in our open reservoirs. Open reservoirs efficiently vent gases, closed reservoirs do not. Since you are in the EPA RED zone for RADON, please see below. EPA is clear: there is "no safe level for RADON".
To: Interested Citizens
From: Scott Fernandez, M.Sc. Biology/ Microbiology
PUBLIC HEALTH BENEFITS of DEEP OPEN WATER RESERVOIRS
The deep open water reservoirs of Mount Tabor and Washington Park provide many public health advantages.
• Gases that are natural (Radon) and those that are part of the disinfection process (chloroform), two suspected carcinogens, are able to escape into the air before entering the household, school, or business indoor environment.
• Oxygenation from the fountain and waterfall action at the inlet provides a similar additional disinfection similar to ozone. The resulting increased water surface area allows oxygen to diffuse close to the anaerobic organisms leading to death thus providing disinfection.
• Dissolved oxygen in open air reservoirs allows aerobic bacteria to further break down organic materials.
Unlike free chlorine, chloramines we currently use are a stable disinfectant. It will remain active in water for many days. Aeration and the boiling of water are not effective in removing chloramines. Chloramine is quite stable after sunlight exposure, and decay is negligible as a result of mixing in the water column. Conversely, ultraviolet light may deplete the free chlorine in the surface layer of the water. (1)(2)
• Sunlight and open air provide control of microbial growth by allowing the natural oxygen exchange process in the water to continue.
• Sunlight breaks down n-Nitrosodimethylamine (NDMA), a byproduct of chloramine disinfection and a suspected carcinogen. (1)
• Sunlight inhibits chloramine residual breakdown from nitrification bacteria and subsequent formation of nitrate and nitrite. The increase in nitrification episodes associated with covering previously uncovered reservoirs within chloraminated systems was not discussed or provided for in the Long Term 2 Enhanced Surface Water Treatment Rule literature. (3) Increased levels of nitrate and nitrite can result in blood, gastric, and other serious health disorders. (4)
Permanent burial and floating covers may not provide a true public health benefit.
• Plastic covers will shrink, crack, and deteriorate over time. The subsequent unknown breakdown by-products will be consumed.
• Animals can contaminate the surface. They may breach the barrier through equalizer pressure vents to nest and drown. This debris will find its way into drinking water.
• Biofilm will develop under the surface. Algae will likely develop around the perimeter and off flavors and odors can be expected.
• Covered reservoirs do not vent disinfection by-products.
• Any contamination to drinking water systems can occur downstream from the reservoir and provide a catastrophic occurrence through backflow into the uncontrolled system Monitored open reservoirs can quickly contain any deliberate action.
• Properly maintained open municipal reservoirs pose no more risk than any river, lake or watershed contamination.
• Bird wires, current chlorination treatment at the outlet, added security, and public access hours will provide the acceptable protection we need.
RADON
Radon, primarily from the Columbia South Shore Wellfield, has been found in our drinking water at various levels. (5) Radon is a gas formed from radioactive decay of soil and rock material. It is odorless, colorless, and easily transfers from water to air. A storage tank left open to the atmosphere such as our open reservoirs will lose Radon through diffusion into the air and natural decay. (6)
Once Radon in water supplies reaches water users, it may produce human exposure via two methods: inhalation and direct ingestion. Radon in water transfers into the air during showers, flushing toilets, washing dishes, and washing clothes. The generated
aerosols tend to deposit Radon in the lungs where they release radioactive particles that have been shown to increase the likelihood of lung cancer. Radon is second only to smoking in causing lung cancer in the United States, contributing ~ 20,000 deaths per year. Radon can also reach other body tissues through ingestion resulting in radiation exposure to the internal organs. Ingestion of Radon is believed to increase the risk of stomach cancer. (6) (7)
Current data from the Oregon Department of Health and Human Services show more than 25% of the homes tested in Multnomah County exceed the action level of 4pCi / liter, mainly due to geological conditions. A 1000 sq. foot house with a 4 pCi / of radon has nearly 2 million atoms in the air decaying every minute. (8) One single atom / alpha particle can begin the cancer process when inhaled.(9) Homes in the zip codes 97210- 97213 in north and northeast Portland are especially at risk, and there are many other areas in the city. (10)
In the spring of 2001 three Portland Public Schools were closed for monitoring high levels of Radon. Kelly, Whitaker, and Gregory Heights schools in northeast Portland were all affected. (11) Student health and safety were put at risk. Superior public health conditions exist, provided by our open drinking water reservoirs. We do not need to add Radon to all community area homes, schools, and businesses.
EPA has established methods for removal of Radon from drinking water. Seven of eight methods recommend aeration of drinking water. The eight uses activated charcoal, a less desirable method. (6) (12)
Disinfectant Byproducts
While disinfectants are effective in controlling microorganisms, they react with natural organic and inorganic matter in source water and distribution systems to form unwanted by-products. Chlorine treatment of drinking water is necessary to prevent diseases that can be a major cause of illness. Because we have no sewage exposure in the Bull Run water system disinfectant by-products are well below EPA standards, but still need to be vented.
TRIHALOMETHANES
Trihalomethanes are disinfectant by-products regulated by EPA. These are generated during the disinfection process and are required to be kept at very low levels. These include the following chemicals;
1. Chloroform – chloroform can be formed during the breakdown of chlorine containing compounds, and may be found in drinking water. Chloroform evaporates quickly when exposed to air. People may ingest and inhale chloroform through drinking water, preparing food, laundry, or showering / bathing. New water saving technology significantly increases aeration of shower heads and faucets to increase water conservation goals. Chloroform is suspected of causing cancer. (13)(14)
2. Bromoform – Bromoform is formed as a by-product when chlorine is added to drinking water to kill microorganisms. It is soluble in water and readily evaporates into air. It can be broken down by sunlight. Bromoform may enter through the skin while bathing. It may be inhaled during cooking, doing dishes, or showering / bathing. In humans exposure can affect the central nervous system. In animals it has been linked to cancer, and is a probable human carcinogen. (14) (15)
3. Dibromochloromethane- This is another by-product of adding chlorine to drinking water systems. It is soluble in water and readily evaporates into air. It is also broken down by sunlight. It can be inhaled during showering / bathing, cooking, or other household activities. EPA classifies it as a possible human carcinogen. (14)
4. Bromodichloromethane – It is a by-product of the chlorine added to drinking water for disinfection. It is water soluble, but will evaporate when exposed to air. It is broken down by sunlight. Exposure can be through skin from showering / bathing. It also occurs by inhalation when cooking, bathing / showering, laundry, etc. The US Department of Health and Human Services has determined bromodichloromethane is reasonably anticipated to be carcinogenic. (14)
Summary – Our deep open water reservoirs at Mount Tabor and Washington Park have been wrongly portrayed as not supporting public health benefits for our drinking water, when just the opposite is true. The sunshine and open air waters break down and vent gaseous chemicals, reflecting the natural functioning of a healthy water system. We do not live in a sterile world and the open reservoirs expose us to nothing more than we are already subjected to in everyday living. Covering or burying the reservoirs will eliminate the natural Radon and trihalomethane gas removal process we currently enjoy in our drinking water system. Covering or burying our reservoirs will give Radon and the trihalomethane disinfectant by-products only one place to vent; our homes, schools and businesses.
References
1. San Francisco Public Utilities Commission -2003
2. Guidelines for Drinking Water Quality. World Health Organization.2003
3. EPA –Safe water / Nitrification. 2003
4. Nitrate in Drinking Water and Human Health. Center for health Effects of Environmental Contamination. University of Iowa. 2001
5.Portland Water Bureau – Water Quality Reports
6. EPA – Removal of Radon from Drinking Water 1999
7. EPA – Proposed Radon Drinking Water Rule April 2000
8. US Geological Survey. The Geology of Radon. 1995
9. EPA – Indoor Radon. NAS 1998
10. State of Oregon Health Services Division. Radon. 2001
11. Portland Public Schools Summary. Radon. 2001
12. US Filter. Water Technologies. Aeration. 2001
13. Wisconsin Department of Health. 2000
14. Agency for Toxic Substances and Disease Registry. CDC. 1997
15. EPA. Air Toxics. Bromoform. 2003
Scott Fernandez M.Sc. © 2004
This comment has been removed. Comments are moderated and generally will be posted, unless they are spammy or abusive. For more information, please see our Comment Guidelines.
Brad, Dee, Mary and Floy: Thank you for taking the time to share your thoughts on a complicated, confusing and important issue. We admire and appreciate your passion, commitment and diligence.
In the interest of transparency and fairness—especially for neighbors who are new to (or grappling with) this issue—we respectfully ask that commenters reveal their identity (no anonymous posts, please) and any affiliations with organizations engaged in this issue (supporter/member of PURB, PWB, FOR, etc.). We don’t want anyone to feel misled.
Cosmic Dancer Water Watcher: Please resubmit your comment. You have every right to level these accusations, but they don't hold water without your identity. Your current comment will be deleted at 5 p.m. today.
The goal of this article is to distill a complex issue into something readable. We aren't interested in taking sides or engaging in arguments—we're interested in facilitating understanding of the issue. We hope that those of you with a more fluid knowledge of this issue will exercise patience with those of us who are simply trying to get a handle on it.
We look forward to an informative and engaging conversation.
Thanks, neighbors!
Lynnette (Editor, NN)
Hello Lynnette,
I read your editorial note, above, with interest.
It prompted me to wonder about the original post that generated the comments and about the comment-filtering process.
The water bureau is an enterprise that collects ratepayer funds and then disburses them in ways that some of us have found puzzling.
Was the author of the original article paid to write it? If so, who paid?
Is the editor paid to read and delete comments? If so, who pays?
What is the relationship of the water bureau to this group of writers?
For the record, I was not paid to post my comment.
What I hope to encourage with my advocacy is a reduction in the use of concrete to bury water (energy-reduction is a value of mine), a reduction in debt-service costs to bury water (I disapprove of current debt-management trends of the federal government and of some governments below them in the hierarchy of governments), and a reduction in risk to water quality, for the reasons carefully enumerated in the comment stream above and as documented by testimony recorded in previous Portland Utility Review Board proceedings.
Thank you for your attention to my questions here.
Hi, Mary.
Thanks for your thoughtful reply about your advocacy efforts. It was not my intent to imply that you (or any other commenters) were paid or induced in any way to share your thoughts here.
Our priority here at Neighborhood Notes is to create a healthy space where community members can create, communicate and connect. In order to keep these conversations informative and constructive, we instituted a comment policy for those who wish to participate.
Normally, this policy is enough to keep things safe, civil and productive. Unfortunately, a FOR supporter [who I will NOT identify] posted comments under both his real identity and an anonymous screen name. I felt it would be irresponsible to publish his second [anonymous] comment, so I contacted him and offered the option of resubmitting the comment under his real identity. That comment has yet to be published, but my hope is that it will be resubmitted.
After this incident, I decided that it did not serve the best interest of our community (or the conversation) to allow anonymous comments on this particular post. That necessitated the removal of the comment by Cosmic Dancer Water Watcher. As I indicated, I am more than happy to publish that comment if it is resubmitted under his real identity.
I also want to be clear that, if the shoe were on the other foot, I would not publish an anonymous comment that undermines your efforts. I respect your work too much for that.
Now, regarding your questions about Neighborhood Notes…
I must admit that your questions stunned me a little—just a little, though, because someone else [from FOR] sent me an email with similar questions on Monday. Neighborhood Notes has never been the subject of a conspiracy theory, and despite how delicious a romp in the hay with PWB sounds, the truth simply isn’t that sexy.
Neighborhood Notes is owned and operated by two Portland neighbors (Ken Aaron and Lynnette Fusilier). We pay an incredible team of local freelance writers and photographers to report on news and events in Portland’s 95 neighborhoods. (FYI: we pay our writers .10/word. Writer Eve Connell will be paid approximately $350 dollars for her article Making Sense of Portland’s Water.)
Neighborhood Notes is privately funded (from our own pockets). Our business generates revenue from advertising, photography and sponsored content (i.e. paid event and press release submissions) via our wire service, NNwire. As part of our charitable giving, qualified submissions are sponsored by us. Otherwise, there is a small fee. NNwire items are clearly marked (see the archive here) and separate from our editorial, which is influenced by our own curiosity. Nothing else.
Regarding our relationship with PWB and City of Portland…
We live here. We’re curious. Like many Portland neighbors, we’re interested in what our governing institutions have to say and what they’re doing, because it affects us. We think sharing that information with our neighbors is important, too.
Unfortunately it’s difficult for so few of us to handle the volume of information we receive from the City (not to mention the local business and nonprofit communities) in addition to our own journalistic efforts. That’s why we were thrilled when Jennie Day-Burget volunteered (i.e. no money exchanged hands) to contribute PWB info to Neighborhood Notes. You can see her post archive here. Recent post titles include: Water Main Construction at Intersection of SW 45th Avenue and SW Multnomah Boulevard and The Portland Water Bureau Reminds Customers to Prepare Home Plumbing for Cold Weather.
Other city bureaus share their press releases and events on Neighborhood Notes via NNwire. The more the merrier, we say. We’re always happy to share information that will help neighbors make proactive decisions about where they live, work and play. And we deeply appreciate those folks who make the effort to share that information with all of us.
If I can answer any other questions for you, please let me know.
Best,
Lynnette
Thanks, all, for the links, additional related information, clarifications, and attention to this important issue. It would be great to hear from neighbors - especially those living near the Mt Tabor and Washington Park reservoirs, too - to get their take on open/closed reservoirs.
Scott - the radon information you posted is especially compelling - and something I'm now worrying about as I get ready to test my basement levels.
Two recent local overviews re: Portland's water issues may add to the conversation here, too. Check out:
http://news.opb.org/article/6916-new-confusion-over-portland-water-future/
http://www.portlandtribune.com/news/story.php?story_id=126876755186509000