To: Portland City Council, Multnomah County Health Department, PURB and
Interested Parties
March 25, 2010
RE: PRECAUTIONARY PRINCIPLE AS RELATES TO PORTLAND’S OPEN
RESERVOIRS, COLUMBIA SOUTH SHORE WELL FIELD, AND SEATTLE
FIASCO
The Friends of the Reservoirs thank Dr. Gary Oxman, Multnomah County Health
Officer for his public health perspective presented at the PURB March 3, 2010
reservoir public “hearing”. We appreciate his acknowledgement of the benefits of
open reservoirs, “sunlight and air”1 and his having encouraged the newly formed
PURB to listen to the community.
ABSENCE OF SOURCES OF CONTAMINANTS AT OPEN RESERVOIRS
The goal of the EPA LT2 reservoir requirement is to reduce disease in the
community from Cryptosporidium, Giardia and viruses, contaminants never found
at Portland’s open reservoirs. The American Water Works Association
Research Foundation’s (AwwaRF) Infectious Cryptosporidium study, project #
3021 scientifically documented the absence of Cryptosporidium in Portland’s
open reservoirs2.
While beavers are a potential source of Giardia in the Bull Run watershed there
are no beavers at the open reservoirs. With regard to viruses, during stakeholder
meetings no one including Dr. Gary Oxman and Dr. Amy Sullivan from
Multnomah County Health Department (MCH), the Portland Water Bureau, and a
local physician, Oregon Wild or the Friends of the Reservoirs were able to
identify any virus that could hypothetically pose a unique public health risk with
uncovered reservoirs.
Subsequent to the March 3, 2010 public hearing, Multnomah County Health has
stated that either covered storage or additional treatment would offer improved
protection from the potential harms of Crypto, Giardia or viruses, problems that
do not exist at the open reservoirs. Multnomah County Health department fails to
cite any potential sources of these contaminants at the open reservoirs.
1
The benefits of sunlight and ventilation were further expounded upon by former PURB member Scott
Fernandez, M.Sc. Biology Microbiology and are acknowledged in the AwwaRF 3021 preliminary report
2
Extensive AwwaRF 3021 reservoir outlet sampling took place between 2008 and May 2009 with ZERO
Cryptosporidium detected. This sampling supplements earlier sampling.
MCH acknowledges that science is lacking with regard to open reservoirs stating
that literature addresses the potential for adverse health outcomes from
uncovered storage. However, a substantially larger volume of literature
documents not only the same potential problems with covered storage, but also
more importantly documents actual public health illness and deaths only with
covered storage. EPA documents unique public health risks only with covered
storage, cancer-causing nitrification.
Historically, many municipalities throughout the nation have safely provided
drinking water from open reservoirs to no small number of the U.S. population, to
more than tens of millions. Contemporary examples of large cities with open
reservoirs include New York, Rochester, Baltimore, Los Angeles, Pittsburgh’s
Highland Park, Seattle, Tacoma and Portland.
FAULTY RATIONALE
Engineering firms involved in negotiating and benefiting from the EPA LT2
regulation, are members of the AWWA, the organization the MCH cites as the
rationale for their supporting covered reservoirs.
PROBLEMS WITH THE PRECAUTIONARY PRINCIPLE
Subsequent to the March 3 public hearing, the Multnomah County Health
Department referenced the precautionary principle. Compare the open reservoir
situation with that of the Columbia South Shore Well Field. At the open
reservoirs, the contaminants for which MCH supports additional “treatment” are
absent. At the Columbia South Shore Well Field 3 sewage-based contaminants
are present, specifically pharmaceuticals that include pain killers, antibiotics, birth
control hormones (estrogen) and Prozac.4 Additionally toxic and carcinogenic
Radon is continuously present in the Well Field.
While there is broad-based and enduring support for retaining Portland’s open
reservoirs, there is no such support from the informed community for the
Columbia South Shore Well Field, Portland’s secondary lower-quality ground
water back up supply.
In July 2009 the Seattle Times reported on a recent local example of the
precautionary principle resulting in contamination of the water supply, Major doover for two Seattle reservoirs http://seattletimes.nwsource.com/cgibin/PrintStory.pl?document_id=2009485902&zsection_id=2003925728&slug=res
ervoir17m&date=20090717 Seattle’s newly constructed 50 million gallon
underground concrete tanks designed by MWH5 were discovered to have leaks.
Contamination of the water supply and a massive costly do over is the result.
3
The Columbia South Shore Well Field is tested infinitely less frequently than the open reservoirs and
Bull Run source water
4
Portland’s 2009 Water Quality Report,
http://www.portlandonline.com/water/index.cfm?a=244813&c=29551
5
MWH has been the beneficiary of a long-string of PWB consultant contracts including a 2010 design
contract for Kelly Butte
AFFORDABILITY, RESERVOIR VARIANCE, RULE REVISION 2012
Regarding affordability, Portland water users were hit with an 18% increase in
their water bills just last year and will be paying for costly 2003-2010 open
reservoir upgrade construction projects for the next 25 years. These open
reservoir projects address public safety and open reservoir operations.
The available Safe Drinking Water Act reservoir "treatment technique" variance
is approvable with the already-collected, publicly financed scientific data
collected from the AwwaRF 3021 study as well as data collected as required for
compliance with the Total Coliform Rule.
The EPA LT2 regulation is scheduled for revision in 2012 with the Total Coliform
Rule presently under revision. Current studies including AwwaRF 3021 that
acknowledge the benefits of sunlight will be considered in the revision of the
flawed EPA LT2 rule.
The Friends of the Reservoirs take seriously the goal of assuring that Portland’s
drinking water is safe and affordable for all. We support sound science, not
political science as the foundation for public health policy. We believe that from
“forest to faucet” our current open reservoir Bull Run system is the best drinking
water system in the nation.