Wednesday, June 8, 2011

Treatment Variance application reveals a stale plant design, flawed testing, and more nonsensical behavior

This morning I read just one section of the Treatment Variance Application Portland Water Bureau submitted to the state Drinking Water Program this week. LT2 is outlandishly expensive. Even the variance is going to cost us (testing at high volumes takes money). LT2 is also completely void of benefit to us, because we don’t have the problem LT2 is trying to fix. So, to summarize, LT2 is expensive and unnecessary for Portland’s pristine Bull Run Water. And yet, in section 6.5 of the variance application PWB just filed with the state, PWB makes the case for conducting useless LT2 tests even MORE frequently and at higher volumes than LT2 requires. Wha? If a useless test is no good, then doing even more of them is better? Well, it will funnel a little more money to PWB’s consulting buddies (a.k.a. their future employers) so somebody is getting something out of this, right?

In section 6.4.2, PWB lets slip that the UV plant design we are paying for right now (to wait on the shelf, just in case we don’t get our variance) will be stale, and possibly need “updating” (cha-ching). And the land use and environmental permits they are buying now, will likely also have to be redone (cha-ching). This is good planning? I don’t generally pack my potato salad the week before the picnic, because, that isn’t actually efficient preparation. If there is the possibility the UV plant design will be STALE by the time we need it, surely they built a clause into the contract that allows for a brief review for updating. Oh no, silly me, I keep forgetting. The principle is “funnel more money” not “conserve limited public resources.”
But most upsetting of all (it gets more upsetting) is the trigger to build the $100 million UV plant and the flawed testing protocol PWB put on that trigger. With so much at stake ($100 million dollars + future operating expenses) on the line for just two inconclusive test results, wouldn’t it seem prudent to be particularly careful when negotiating the test method. We wouldn’t want to choose a test method with well-known flaws, that the scientific community has identified as producing high false positives which overstate public health risks. Yet, rather than make the case for how much the science of Crypto testing has changed since EPA suggested testing Method 1622/23 as the standard for LT2 tests, PWB stated in the variance application they would employ flawed testing Method 1622/23. Almost unexplainable.

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