Frequently Asked Questions
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1. What is the purpose of the Bull Run Waiver?
A “waiver” is voluntarily giving up a right or privilege. Whereby, EPA would give up the right to force us to add unneeded Bull Run treatment and cover our reservoirs under the Long Term 2 Enhanced Surface Water Treatment Rule. The purpose of the waiver is to stop spending, building, and degrading our drinking water for a public health problem that does not exist.
The waiver is a simple agreement between City of Portland and EPA/Congress to exempt City of Portland from scientifically unsupported EPA Long Term 2 Enhanced Surface Treatment Rule. The “variance” process used in the past has been a failed strategy and is insufficient because it is temporary. It allows unneeded construction projects and water rates to increase and tolerates an uncertain outcome.
2. What is the EPA LT2 Rule and how does it affect the Bull Run water system?
The purpose of the EPA Long Term 2 Enhanced Surface Water Treatment Rule was to reduce incidence of disease from Cryptosporidium. This microorganism was allegedly found in the Milwaukee Wisconsin catastrophic sewage event and was thought to be involved in illness.
“What happened in Milwaukee, Wisconsin was a failure of a water treatment 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’s in a protected watershed where human entry is prohibited.” — Oregon Public Broadcasting – Portland Water Bureau 2003
3. Is Bull Run drinking water currently filtered or treated with chemicals?
Bull Run source water is in a federally protected watershed prohibiting human entry unless to provide water maintenance. It is one of a very few US watersheds that is unfiltered. It remains unfiltered because the water is pristine and is not exposed to agricultural, industrial, or municipal sewage, thus removing risk from toxic chemicals and human based disease microorganisms. It is treated with chlorine and ammonia to manage microorganisms.
4. Are the open reservoirs at Mount Tabor and Washington Park at risk from terrorism, vandalism, or earthquakes?
The open reservoirs at Mount Tabor and Washington Park provide significant public health benefits for our drinking water. Portland has had no microbial or chemical public health incidents or deaths since the reservoirs were opened 100 years ago. In 2004 the City of Portland convened the Independent Review Panel to determine the future of our open drinking water reservoirs. After months of review and public testimony, a majority of the Panel’s members decided that there was no compelling reason to bury the reservoirs at that time, nor may there ever be a compelling reason to bury them. A risk mitigation plan including increased security would be sufficient. During the long review panel process reservoir seismic summaries stated that the reservoirs are not located in an area of high seismic concern creating no potential risk to the reservoirs. A few years ago an extensive engineering study acknowledged the reservoirs are in “good condition” and with routine maintenance would safely function for the next half century.
5. The City of Portland already has a variance for treatment; why is waiver process being sought?
The “variance” process used in the past has been a failed strategy and is insufficient because it is temporary, allows unneeded construction projects and water rates to increase, and tolerates an uncertain outcome.
The waiver provides an enduring and permanent solution to a public health problem that does not exist. A waiver saves jobs, stops increases in residential and commercial water rates, and discontinues construction of unnecessary reservoirs and treatment plant that would degrade our drinking water.
6. Portland’s reservoirs are over 100 years old. Is the system still functional or outdated?
Past and recent engineering reports support long term usage of the open reservoirs. Routine maintenance is an important part of the long term program. The open reservoirs are proven to be consistent with natural and sustainable engineering and public health.
7. What are the benefits of open reservoirs vs. covered reservoirs?
The open reservoirs at Mount Tabor and Washington Park provide significant public health benefits for our drinking water. Portland has had no microbial or chemical public health incidents or deaths since the reservoirs were opened 100 years ago. The public health benefits of our open reservoirs provide a deep contrast to the negative health effects of covered drinking water reservoirs. Portland’s open air reservoirs provide natural and efficient venting of unwanted gases such as water treatment disinfection byproducts, and Radon from the periodic use of the Columbia South Shore Wellfield. Open reservoirs serve as a barrier to unwanted gases entering the distribution system. With no efficient way to escape, covered reservoirs allow these toxic and carcinogenic gases to end up in our homes, schools and workplaces.
Sunlight and oxygenation provide additional open reservoir health benefits. Open reservoirs support a healthy ecosystem starting with natural disinfection from broad spectrum sunlight and oxygenated aerobic microorganisms that break down unwanted chemicals 20 times more efficiently than covered reservoir anaerobic organisms. No one has ever died from an open reservoir microbial or chemical event. Covered reservoirs in Gideon, Missouri and Alamosa, Colorado have a history of deaths from salmonella contamination.
8. EPA based the LT2 Rule on a sewage event in Milwaukee Wisconsin in 1993; is this concern to the Bull Run water system?
Absolutely not. Portland has no industrial, municipal, or agricultural sewage exposure.
“What happened in Milwaukee, Wisconsin was a failure of a water treatment 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’s in a protected watershed where human entry is prohibited.” — Oregon Public Broadcasting – Portland Water Bureau 2007
9. Does Cryptosporidium pose a threat to our drinking water and our health?
No. Because we have no sewage exposure in the Bull Run watershed the public health risk is not measurable. Bull Run has had no public health incident from microorganisms and chemicals. Risk from Cryptosporidium and the other microorganisms found in sewage have been linked to fecal incidents in day care centers, swimming pools, and water park fecal accidents.
10. What is the cost of complying with the EPA LT2 Rule and how will that cost affect ratepayers?
Water rates in Portland have doubled over the last few years because of EPA LT2 spending. Hundreds of millions have been wasted planning, designing, and building projects for a public health problem that does not exist and never will. The public health risk is not measurable because we do not have sewage exposure in Bull Run. If we do not demand an EPA Safe Drinking Water Act Waiver from LT2 we will continue to spend over $1 billion including debt.
11. How is the issue of Radon related to drinking water?
Radon is a radioactive gas that originates from soils in Portland especially along the Columbia River and throughout North and Northeast Portland. Radon enters our drinking water when we use the Columbia South Shore Wellfield (CSSW) as a backup water source. Radon kills +20,000 people in the US every year. EPA has an action level of 4 pC (picocuries). Our CSSW water contains ~400pC. We need a waiver from EPA LT2 so we are able to retain the open reservoirs allowing the Radon gases to harmlessly vent and escape into the atmosphere rather than our homes, schools and work places. If we allow water containing radioactive Radon into our homes, Radon will enter the air in every room in our home while it continues to decay. The radioactive decay will attach to dust and other particle surfaces remaining forever.
12. Will UV treatment of our water pose health risks?
UV radiation reacting with surface drinking water in a covered system generates formaldehyde, aldehydes and ozone byproducts. Formaldehyde etc. is a known toxin and carcinogen and can create other toxins as it goes through the distribution system. UV radiation treatment uses toxic mercury filled bulbs to react with the water. Portland has a UV test plant that has a history of broken bulbs incidents discharging mercury into the drinking water. The UV radiation plant designed for the Bull Run has no plan to contain the mercury in case of an accident. The broken bulb mercury would then be able to go into the distribution system for consumption by Bull Run water drinkers.
13. Is it true EPA has said; “Science will determine ultimate outcome”?
Yes. This is good news for Portland and for our request for an EPA Safe Drinking Water Act Waiver. The scientific weight of evidence continues to grow for Portland to obtain our waiver. It’s up to us and our elected officials to demand a waiver we clearly deserve.
14. Has there been any public health evidence this EPA rule is really needed?
No. From around the United States none of the public health benefits EPA proposed as the reason for the Cryptosporidium regulation have come true. For over 20 years since Milwaukee Wisconsin sewage event;
0 – surface water utility outbreak events
0 – deaths from Cryptosporidium
0 – endemic disease from drinking water
There is no scientific evidence Portland has to add treatment to Bull Run water or cover our open reservoirs.
15. What can I do to help preserve our Bull Run Water system which has served us so well over 100 years?