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Oregon Health Authority Denies Portland's Request for More Time to Complete Reservoir Compliance Schedule

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PORTLAND, OR– The Oregon Health Authority Public Health Division Drinking Water Program (OHA) today denied the Portland Water Bureau’s request for an adjustment to its regulatory schedule to replace the uncovered drinking water reservoirs at Mt.Tabor and Washington parks. The decision by OHA means that Portland’s existing regulatory schedule to end the use of the uncovered reservoirs by December 31, 2020 remains in effect. Portland had requested an extension of that schedule to the year 2026.

“We are very disappointed in this decision,” said Portland Water Bureau Administrator David Shaff. “We made a case to the state that was very similar to the one made by New York City in successfully extending its reservoir compliance schedule. Oregon is clearly choosing a very different approach for administering federal drinking water rules.”

The Long Term 2 Enhanced Surface Water Treatment Rule (LT2), issued by the federal Environmental Protection Agency (EPA) in 2006 requires that all uncovered finished drinking

water reservoirs in the United States either be covered or have treatment facilities installed at the outlets. In March 2009 Portland entered into a compliance schedule with EPA to end the use of its uncovered reservoirs by the year 2020. When the State of Oregon took primacy for the rule in July 2009, the Oregon Health Authority assumed enforcement responsibilities for the compliance schedule.

Portland submitted a detailed request for an extension to its uncovered reservoir compliance schedule in February 2012 based largely on the challenges of successfully managing the several large design and construction projects that would be necessary to complete the work by 2020. Similar arguments about the sequencing of large projects were cited by New York City when it succeeded in its request for an extension to its own reservoir compliance schedule in 2009.

To view the February 10, 2012 Portland Water Bureau deferral request, click here.

To view the May 17, 2012 letter from OHA denying deferral request, click here.

Terry Black

Public Outreach

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1

1hotpotato

May 21, 2012 at 4:12 PM

This should not be a surprise to the WB. The state & federal governments told the city to cover their open reservoirs in November 1969 due to bird feces. City Council passed a resolution in December 1972 to cover all open reservoirs, 1 every biennium, over a period of 12 yrs., which would have been completed by fiscal year 1984-1985. City Council rescinded the resolution December 1976, the same year cryptosporidium became a known pathogen (within the first half of 1976). If the city council hadn't reneged on its promise to cover the open reservoirs, Portland would have been far ahead of the USEPA Jan. 2006 final LT2ESWTR. The WB will have to reorganize its CIP budget in order to demolish the current 10 million gallon Kelly Butte Reservoir & build its 25 million gallon replacement, as well as put back in the budget the other projects required to decommission & disconnect the open reservoirs by 2015 & 2020. The WB backed itself into a corner. Now they will be scrambling until April 1, 2014 to complete the projects necessary before their reservoir compliance schedule deadlines. It would have been wiser to ignore the demands of the FotRS & the PWUC the last 10 yrs. The city would have saved millions had it not catered to them. They should have listened to their own history instead. Ignoring it cost them millions. It's good that the USEPA & OHA/DWP didn't ignore the city's history on open reservoirs. It isn't likely the USEPA will change the LT2ESWTR, if at all, before 2016.

2

buster

June 21, 2012 at 11:39 AM

Seems that alternative options have not been considered. after all the testing upon testing and coming up with results to prove the water is safe, some are still insisting we go through this very expensive approach. I don't know what technology is out there to deter birds from coming near the resevoirs, but it is possible if an engineer put their mind to it they could create a invisible type of noise fencing not offensive to humans.
The OHA is taking their 'authority' too seriously and not considering all the odds. Truth is, I don't beleive anyone has become ill from this. Is there some kind of record of that?

3

1hotpotato

June 24, 2012 at 4:00 PM

Bird wires were installed over the open finished distribution reservoirs in the past, such as during WWII. They were removed.

Yes, there was a waterborne Giardia lamblia outbreak in Portland, OR October 1954-May 1955. It centered around OHSU students, staff, & faculty. Yes, Water Bureau employees studied this event & concluded that Bull Run surface source water was most likely the culprit source of contamination. (I have copies of both of these reports.) This was before Bull Run Dam 2 was constructed in 1962 & it was before a PSU study in the mid-1970's which recommended the Water Bureau drain & clean open finished distribution reservoirs twice per year. They were not on a regular draining & cleaning schedule before then. Sometimes they weren't drained or cleaned at all during a calendar year. Some were & some weren't. Since the mid-1970's, they are all drained & cleaned twice per year on a regular basis. During the 1970's-1990's the bacteria level in the open finished distribution reservoirs was bad June-September every year. I've spoken with a retired Water Bureau water quality inspector many times over the last several years about this.

Chlorine is in your drinking water to kill bacteria & viruses. It does not kill protozoan parasites like Giradia lamblia or Cryptosporidium parvum. (Yes, both have been detected in Bull Run surface source water. I have the Cryptosporidium report, too. It was cited by the USEPA's LT2ESWTR.) Aqueous ammonia is added to keep the chlorine in contact with the water for a certain amount of contact time in order to disinfect it. (Chlorine & ammonia create a chlorimine. You could say it "holds the hand" of chlorine to keep it in contact with the water until it is distributed throughout the entire public water system.) Otherwise, without the ammonia, the chlorine evaporates from the water, particularly at the open finished distribution reservoirs. (That's why you smell chlorine gas when it evaporates from water, whether it's at the open finished distribution reservoirs, swimming pool, or your tap.) Soda ash is added to prevent pipe corrosion. It raises the pH level of the water slightly. There are hypochlorine booster buildings at the open finished distribution reservoir sites where chlorine is added to the drinking water before it is distributed directly to your tap. No, sunlight does not disinfect water in 25'-30' deep open finished distribution reservoirs. It doesn't penetrate deeply enough to do it. Besides, water reflects sunlight. It doesn't absorb it.

You can purchase water filters to attach to your tap to remove chlorine, etc. from your drinking water before you consume it. Or you could draw water out of your tap & leave it standing at room temperature overnight to let the chlorine evaporate from the water.

About 46% of all bottled water is from public water systems, that is your local drinking water. Look on all the bottled water labels & see how the water is treated. Don't be surprised to find it's treated by filtration, ozone, or ultraviolet (UV) light. The latter two inactivate protozoan parasites by scrambling their DNA so they don't reproduce or break open in your gut making you ill. These are methods recommended by the USEPA that public water systems can use to treat drinking water for protozoan parasites, among other things. These methods are mentioned in USEPA's LT2ESWTR.

By the way, you can learn more about your city government by going to the Portland Archives & Records Center, 5th floor, @ the PSU Urban Plaza. You must go at certain times, Monday-Friday. It's free & open to the public. The city archivists are very helpful in assisting you with your research. Water Bureau Engineering Services engineers are good teachers too.

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