Op-Ed By Scott Fernandez M.Sc. Biology chemistry/microbiology

US Executive Order 13563- “The American people deserve a regulatory system that works for them, not against them; a regulatory system that protects and improves their health, safety, environment, and well-being and improves the performance of the economy without imposing unacceptable or unreasonable costs on society.”

We need our open reservoirs at Washington Park and Mount Tabor activated immediately to preserve our public health. The open reservoirs are the barriers keeping toxic and carcinogenic chemicals from getting into our drinking water distribution system.

Portland is not the green and healthy city we once thought it was. While our current outdoor air crisis has brought attention to a community-wide public health wake-up call, we also need to address our indoor air as it relates to our drinking water.

The increased use of the toxic and carcinogenic Columbia South Shore Well field (CSSW) drinking water last summer and in the future (70% CSSW 30% Bull Run – PWB) has profoundly endangered community public health and wellbeing.

As a result, our indoor air exposure to Radon saturated CSSW drinking water (PWB 2015 Water Quality Report p.4 at 310 picocuries) and other gases such as chloroform remain serious.

Portland Water Bureau (PWB) incorrectly asserts 4,000 picocuries is the level of Radon for water. EPA standard for us is Multi Media Mitigation  300 picocuries, and we exceeded that level last summer at 340 picocuries.

Radon can pass through the placenta and into the developing child; chloroform crosses the placenta also, resulting in concentrations in fetal blood that are greater than maternal blood concentrations. Radon can decay into radioactive components such as Lead.

Lead is a toxic substance that can affect people of any age. It is especially harmful to children, pregnant women and unborn babies. Lead accumulates in the body, so even small amounts can pose a health hazard over time.

There is “no safe level of Radon” (USEPA) (MCLG zero pCi/L) and chloroform; in addition to toxic and carcinogenic nitrification chemicals found only in dark covered reservoirs and drinking water pipes (USEPA).

Radon exposure from drinking water throughout your home at 4 picocuries generates 2 million radioactive decays per minute/ 1000 square feet. (USGS)

CSSW wells are recharged from Columbia River water contaminated by municipal, industrial and Hanford wastes, adding to drinking water toxins. (or.water.usgs.gov/pubs_dir/journals/mccarthy_and_others_1992.pdf)

New York City provided open reservoir science and public health benefits to the EPA. Portland City Council refused to acknowledge them. Over the years, many scientific studies and data support open reservoirs’ health benefits. By not acknowledging the meaningful public health science available  to pursue an EPA LT2 waiver keeping our reservoirs open, Portland City Council has not lived up to their commitment to provide safe drinking water.

In 2004/2006, the City of Portland and Multnomah County adopted safe health practices using the Precautionary Principle as an effective policy framework for decision-making to prevent harm to human health and the environment.

In other words: keeping citizens healthy, stating “where threats of serious or irreversible harm to people or nature exist, anticipatory action will be taken to prevent damages to human and environmental health, even when full scientific certainty about cause and effect is not available, with the intent of safeguarding the quality of life for current and future generations.” (multco.us/file/13368/download).

Additionally, CSSW has  other toxic and carcinogenic residual contaminants that can remain in our drinking water because Portland City Council won’t support open reservoirs.

Sunlight is not there to break down these chemicals and would provide the natural removal of sulfamethoxazole, fluoxetine, triclosan, ethylene estradiol, trichloroethylene, etc. (Oregon DEQ, PWB)

New York City has recognized the open reservoir health benefits, working and negotiating with EPA. So should Portland City Council.

New York City: “Given (1) the extremely low public health risk in at least some water systems from pathogens entering uncovered finished water storage reservoirs, (2) the enormous cost of covering an uncovered reservoir or treating the discharge from such a reservoir, and (3) the existence of effective and far less costly methods of achieving the same public health protection, the draft LT2 rule included a waiver provision that would have allowed for site-specific risk assessments and appropriate treatments.

This waiver provision was inexplicably eliminated from the final LT2 rule. In its enforcement of the rule, EPA has refused to exercise the discretion afforded by the variance provision of the Safe Drinking Water Act to consider waivers based on alternative proposals that would achieve the same public health benefit.

In light of EPA‘s narrow reading of the variance provision, they should revise LT2 to allow alternative means of mitigating the risk to uncovered finished water storage facilities, and prioritize review of any submissions of alternative mitigation plans.

In light of the minimal public health risk posed by leaving Hillview uncovered, the cost of complying with LT2 is not justified. Covering the reservoir will harm the environment and water quality because of the absence of sunlight, and will make maintenance more difficult.

Finally, covering the reservoir would present significant costs, as the City has water and wastewater infrastructure needs that are a far higher priority from a public health perspective.” (NYC EPA 2012)

Stop the demolition of Washington Park reservoirs (costing +$200 million and 30,000 truckload trips over many years – PWB) and reconnect Mount Tabor drinking water facilities for increased public health.

Why? Because drinking water environmental chemical exposures negatively impact public health through continued bio-accumulation processes. Of the +85,000 chemicals EPA has registered, many are toxic and carcinogenic, yet fewer than 100 regulated for drinking water consumption.(USEPA)

Toxic and carcinogenic chemical exposure levels established for safe drinking water are based on adult standards. (USEPA) Children are not smaller adults and therefore the chemical health risk is much higher.

Children have a higher metabolism and increased cell activity, along with higher respiration rates than adults; negatively impacting their health from toxic and carcinogenic liquid and gas exposures in the homes, schools, daycare centers etc..

The greatness of a community can be judged by the quality of its drinking water. Retain the open reservoirs and their proven public health benefits without illness for over 100 years.

The city’s 2004 Open Reservoir Independent Review Panel confirmed over a 5 month process the open reservoirs provided safe drinking water, adding security and risk mitigation applications.

Public testimony and engineering reports during community reviews demonstrated the open reservoirs can endure landslide and seismic challenges for the next 50 years.

Without the open reservoirs to efficiently remove gases and toxins, our drinking water remains at risk. There is no public health reason for PWB to “reconfigure” our drinking water system.

The EPA LT2 open reservoir regulation is being reviewed during 2016. We still have an opportunity to save our open reservoirs and ask for an EPA LT2 Waiver, so we can keep our children and community safe and healthy.

For more information, see bullrunwaiver.org.