EPA- “Science will determine the ultimate outcome”
Bull Run Waiver.org is a non-political volunteer working group made up of scientists, engineers, families and individuals from all walks of life in the community. We seek the continuation of reliable, healthy Bull Run drinking water and have no affiliations to any political groups. We encourage everyone to educate, advocate, and participate in the Bull Run wavier process. EPA has stated that science will determine the ultimate outcome of LT2. The Safe Drinking Water Act waiver is the only solution to keeping our Bull Run drinking water pristine and safe.
The future of Portland’s pristine Bull Run water as it exists today is now in our hands; our heritage, our health…
The Bull Run system has performed well for over 100 years without a public health incident. We provide full disclosure and describe the scientific basis for an EPA Safe Drinking Water Act Waiver from an unnecessary and costly EPA regulation that will degrade our drinking water.
Without an EPA Safe Drinking Water Act Waiver, Portland will have to cover our open reservoirs and continue with the uncertain costs of adding unnecessary artificial UV radiation drinking water treatment in the Bull Run watershed. These actions will result in significantly degrading our drinking water quality with toxic and carcinogenic chemicals while adding undue financial hardship on residential and commercial customers. We ask that Portland’s open reservoirs and the pristine Bull Run watershed be recognized for their long public health history of clean, safe drinking water for over 100 years.
Summary of Water Bill increases over a decade.
FY 2001: 3.0 percent annual increase; 103 percent compounded*
FY 2002: 6.9 percent ; 110.1 percent
FY 2003: 8.8 percent ; 119.8 percent
FY 2004: 6.0 percent ; 127 percent
FY 2005: 5.0 percent ; 133.3 percent
FY 2006: 0.6 percent ; 134.1 percent
FY 2007: 2.5 percent ; 137.5 percent
FY 2008: 5.1 percent ; 144.5 percent
FY 2009: 8.6 percent ; 156.9 percent
FY 2010: 17.9 percent ; 185 percent
FY 2011: 12.0 percent ; 207.2 percent
FY 2012: 12.9 percent ; 233.9 percent
FY 2013: 7.8 percent estimate
*Portland Water Bureau
Bull Run Water Shed – The source of Portland’s water and distribution system
Important history to know…
EPA – One Size Fits All Regulations
Equal Drinking Water Sources?
In March 1993 for 3-4 weeks the citizens of south Milwaukee Wisconsin drank partially treated sewage water. Sewage contains hundreds of disease causing microorganism species and trillions of microorganisms discharged into the drinking water.
Sewage is the cause of the public health issues, not Cryptosporidium as EPA has continually asserted. EPA attributed only one microorganism, Cryptosporidium as the cause of illness. This event was the origin and basis for EPA Long Term 2 Enhanced Surface Treatment Rule. Our Bull Run watershed has no industrial, agricultural, or municipal sewage exposure, thus eliminating the threat of corresponding microbial and chemical public health risks.
“What happened in Milwaukee, Wisconsin was a failure of a water treatment plant and sewage treatment system that allowed sewage to get into a drinking water system. That’s not possible in the Bull Run. The Bull Run is 35 miles away from Portland; it is in a protected watershed where human entry is prohibited.” OPB- Portland Water Bureau 2007
Contributing to the significant scientific deficiencies in EPA LT2 methodology were two major issues. The first issue was the analysis of blocks of ice for microbial confirmation. Because the public health authorities came to Milwaukee after the event was over they had to do a retrospective analysis of the water using blocks of ice. This is unacceptable because the EPA 1623 manual in identification is very clear in requiring that frozen samples “must be rejected”. This is because identification is compromised because of morphological (organism shape) variations. Secondly, in 1994, a survey of laboratory quality assurance in identifying Cryptosporidium was found to be woefully inadequate due to inconsistency, lack of training, and false positives. Thus laboratory results for Cryptosporidium were determined to be unreliable. EPA allowed both gross discrepancies to be used for regulation enactment.
Our pristine Bull Run Lake with Dodge Island in the foreground is an example of how fortunate we are to benefit from natures natural process that provides clean, healthy water to our citizens. The Bull Run system has performed well for over a hundred years without a public health incident.
2001-Portland Bull Run Treatment Panel convened
2002- Scott Fernandez M.Sc. microbiologist presented paper to review panel demonstrating Cryptosporidium was not public health drinking water problem. Portland Utility Review Board unanimously adopted the EPA waiver exemption for Portland at the request of Fernandez.
2003- EPA introduced a LT2 comment period. Scott Fernandez sent documents to EPA confirming it was a sewage event and could not be blamed on one microorganism. Gross deficiencies in EPA scientific methodologies.
2004- New York, San Francisco, Boston, and other Unfiltered Systems, American Water Works Association, etc. entered their comments to EPA. They were consistent with Scott Fernandez’s findings. Independent Review Panel convened to discuss open reservoirs. The Panel concluded open reservoirs were safe with a risk mitigation program.
2005- Mayor Tom Potter wrote EPA to provide allowance to review regulation as it applies to Portland.
2006- EPA enters LT2 regulation requiring covered reservoirs and treatment for unfiltered systems.
2007-Portland v. EPA court case challenging LT2. City of Portland withheld critical information from court challenge, eventually losing.
2008, 2009, 2010, 2011 began planning and designing for covered reservoirs and artificial UV treatment plant.
2012- Oregon Health Authority final order grants a temporary treatment variance. EPA begins review of LT2 regulation.
2013- Request of a Bull Run drinking water system Waiver for over a decade continues.
Open Reservoirs-Public Health Benefits
The deep open water reservoirs of Mount Tabor and Washington Park provide many public health advantages. Gases that are released in the Columbia South Shore Well field (Radon) and those that are part of the disinfection process (chloroform), two carcinogenic chemicals, are able to escape harmlessly into the atmosphere before enter indoors.
Natural oxygenation from the reservoir fountains and waterfall action at the inlet provides additional disinfection properties. The resulting increased water surface area allows oxygen to diffuse close to the anaerobic microorganisms leading to death and increased disinfection. Dissolved oxygen in open air reservoirs allow aerobic bacteria to further breakdown unwanted organic material 20 times more efficiently than anaerobic bacteria found in covered reservoirs.
The chloramines we currently use are a stable disinfectant. Their chemical integrity will remain in water system for days. Chloramine is stable in sunlight and decay is negligible as a result of mixing in the water column.
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 carcinogen. Covered reservoirs do not break NDMA down. Sunlight inhibits chloramine residual breakdown from nitrification bacteria and subsequent formation of nitrite and nitrate. Covered reservoir systems allow nitrification bacteria to thrive. The increase in nitrification episodes associated with covering previously uncovered reservoirs within chloraminated systems was not discussed or provided for in the LT2 literature or discussion. Increased levels of nitrate or nitrite can result in cancer causing nitrosamines, resulting in blood, gastric, and other serious health disorders.
Reservoir burial does not provide true public health benefits.
Death from unvented methane gas and salmonella outbreaks from undetected birds roosting inside covered reservoirs has been documented. Covered reservoirs do not vent disinfection by products. Monitored open reservoirs can quickly contain any deliberate action using chemical analysis and laser technologies. Properly maintained open reservoirs pose no more risk than what we are exposed to in everyday life. Bird wires, current chlorination treatment at the outlet, added security, isolation valves in the distribution system provide the appropriate protection.
The Public Health Risks of RADON
A storage reservoir left exposed to the atmosphere such as our open reservoirs will quickly and harmlessly lose Radon from diffusion into the air and natural decay. Once Radon in covered reservoir water supplies reaches water users, it will produce human exposure via two methods; inhalation and direct ingestion. Radon in water will transfer into the air during showers, washing dishes, flushing toilets and washing clothes. The generated aerosols tend to deposit Radon in the lungs where they release radioactive particles that are shown to increase likelihood of lung cancer. Radon is second only to smoking in causing lung cancer in United States, contributing
~20,000 deaths per year. Radon can reach body tissues through ingestion resulting in radiation exposure to internal organs. Ingestion of Radon can increase risk of stomach cancer.
Click Map for full size.
Current data from Oregon Department of Health and Human Services show more than 25% of the homes in Multnomah County exceed the 4pCi/liter mainly due to geological conditions. A 1000 sq. ft. house with a 4pCi of Radon has nearly 2 million atoms in the air decaying every minute. One single atom/alpha particle can begin the cancer process when inhaled. 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.
In the spring of 2001 three Portland Public schools were closed for monitoring high levels of Radon from soil. Kelly, Whitaker and Gregory Heights schools in northeast Portland were all affected. 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, work places.)
EPA has acknowledged methods for Radon mitigation from drinking water. Seven of the eight methods recommend aeration applications consistent with our open reservoirs. The eighth uses activated carbon, ground up coal, a less desirable method because it can be ineffective and uneconomical.
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:
- Chloroform- Chloroform can be generated during the breakdown of chlorine containing compounds and are found in drinking water. Chloroform is suspected of causing cancer. Chloroform evaporates very quickly when exposed to air as in open reservoirs. If left in covered reservoirs people will ingest, inhale and absorb chloroform through skin. Chloroform exposures increase through drinking water, showering/bathing, preparing food and laundry. New water saving technologies significantly increase aeration of shower heads and faucets to enhance water conservation.
- Bromoform- Bromoform is formed as a byproduct when chlorine is added to drinking water to kill microorganisms. It is soluble in water and readily evaporates into air and is broken down by sunlight from the open reservoirs. Covered reservoirs allow passage into distribution system. Bromoform may enter through skin while bathing. It can be inhaled by cooking, showering/bathing doing dishes.
- Dibromochloromethane- Dibromochloromethane is another byproduct of adding chlorine to drinking water systems. It is soluble in water, broken down by sunlight, and can readily evaporate into atmosphere as in our open reservoirs. In a closed/covered reservoir system it goes into the distribution system. It can be inhaled during showering/ bathing, cooking and other household activities. EPA classifies it as a possible human carcinogen.
- Bromodichloromethane- bromodichloromethane is a byproduct of chlorine added to drinking water for disinfection purposes. It also is water soluble, broken down by sunlight, and will evaporate into atmosphere from open reservoirs. Covered reservoirs allow the chemical to move into the distribution system. Exposure can be through the skin, showering/bathing, cooking, laundry, etc. US Department of Health and Human Services has determined bromodichloromethane is reasonably anticipated to be carcinogenic.
Public health benefits summary of open reservoirs-
Covering or burying the reservoirs will eliminate the natural Radon and trihalomethane gas removal process we currently enjoy in our open reservoir drinking water system. Open reservoirs provide a natural healthy barrier to unwanted gases and chemicals entering the drinking water distribution system. Covering or burying the reservoirs will give Radon along with other toxic and carcinogenic chemicals only one place to vent; our homes, schools, and work places.
Bull Run Ultra Violet Radiation Drinking Water Treatment
In 2009 the Portland City Council adopted the artificial ultraviolet radiation treatment process over the objections of Randy Leonard who wanted a filtration plant. Wholesale customers have expressed their lack of interest in a UV plant because it will not achieve a better drinking water.
The cost will total more than $100 million dollars for a public health problem that does not exist. In 2012 Oregon Health Authority provided a variance which is a temporary pause in the implementation of the treatment process. However, construction on supportive parts of the plant continues. Increasing and unnecessary variance costs are being passed on to the ratepayer, such as expensive water sampling and analysis.
Public health issues with UV radiation
UV radiation units use light bulbs filled with toxic and carcinogenic mercury. UV bulbs used in drinking water treatments have long history of breakage, allowing toxic mercury into the water distribution system. The plant design for UV radiation does not provide for bulb breakage and mercury mitigation. A large pool called a “clear well” has not been established, thus allowing mercury debris to have complete access entering through the Headworks conduits to the drinking water distribution system.
Photos by Portland Water Bureau