Prepared for the Deep River Citizens Coalition
Daniel A. Okun
Kenan Professor of Environmental Engineering, Emeritus
University of North Carolina at Chapel Hill
Chapel Hill, NC 27599-7400
April 20, 2000
The purpose of this statement is to render my opinion that the construction of Randleman Dam on the Deep River to provide additional water supply for the Piedmont Triad would impose an increased public health risk on those who would be obliged to drink the water from that heavily polluted source. It is also my opinion that other feasible alternatives exist that would make the use of Deep River water for the people of the Triad unnecessary. It is important that prospective consumers of that water should understand that the quality of the water they would be getting at the tap would be poorer than they now receive and that it would pose an increased threat to their health, particularly for those who are vulnerable, such as children, the elderly, and immune-compromised individuals.
I have been actively engaged in drinking water quality issues for more than 50 years. I have degrees in civil engineering and a doctorate from Harvard University. I served as an engineer in the U. S. Public Health Service on the Ohio River Pollution Survey and in the U.S. Army during World War II. After four years with a consulting firm in New York City, I joined the faculty at the University of North Carolina (UNC) in 1952. I served as chair of the Department of Environmental Sciences and Engineering for some twenty years, and retired from teaching in 1982. Throughout my career I have served, and continue to serve, as a private consultant to consulting engineering firms, industry, and to public and private local, state, national, and international agencies.
I was the first engineer from North Carolina elected to the National Academy of Engineering and one of the few engineers elected to the Institute of Medicine. From 1991 to 1994 1 served as chair of the National Research Council's Water Science and Technology Board. I have won awards from the American Society of Civil Engineers, the American Water Works Association, the Association of Metropolitan Water Agencies, the Water Environment Federation and many other organizations. At UNC, I was chair of the Faculty, serving from 1970 to 1973, and was accorded UNC's Thomas Jefferson Award. A Distinguished Professorship in Environmental Engineering has recently been established by UNC in my name.
I have been involved in municipal water supply projects in many cities throughout the world including Chapel Hill, Asheville, Greenville (SC), Roanoke (VA), New York City,Boston, Newark (NJ), San Diego, East Bay Municipal Utilities District (CA), West Palm Beach (FL), Bangkok, Singapore, Melbourne (Australia), Auckland (NZ), Bogota and Cali (Colombia), and Beijing-Tianjin (China).
Deep River Water Quality
I do not here present data on water quality in the Deep River nor what the quality is expected to be in the future. Adequate data have been assembled to show that it is now and will continue to be heavily polluted. The reservoir that would be created on the Deep River by Randleman Dam would receive wastewater discharges from High Point. A highly contaminating toxic chemical disposal site is on the watershed. Runoff from urban and industrial development is now heavy and can expect to be even greater in the future. Additional nutrients from agricultural activities assure high levels of algal growths that make the water difficult to treat and contribute to increased levels of disinfection byproducts. Agricultural pesticides also create problems. Fecal coliform levels are exceedingly high and augur the presence of a wide range of human pathogens in the water that are more resistant to inactivation and removal than fecal coliform.
Proponents of the Randleman Dam project claim that the water, after treatment, will meet the drinking water standards. It is recognized today by all professionals in the field that water that meets current standards may be, and often is, unsafe. Water that met current drinking water standards was responsible for about 400,000 cases of cryptosporidiosis, some 4,000 hospitalizations, and some one hundred deaths in Milwaukee in 1993. Many pathogens, including viruses, bacteria and protozoa, are being found in human and animal wastes for which we are not prepared. The fecal coliform test that has been the basis for assuring safety of water for almost a century is no longer adequate to assure the absence of Cryptosporidium and many other microorganisms of concern.
A major public health problem is the presence of rapidly increasing numbers of trace synthetic organic chemicals (SOCs) which are being introduced into the environment during the manufacture and use of products from the prolific chemical, electronic and pharmaceutical industries. Chemical compounds created by the chlorination of water, so called disinfection by-products (DBPs), have been indicted as being carcinogenic; the higher the level of natural organic material in water, the higher the concentration of these DBPs. In addition to cancers that stem from the long-term ingestion of these chemicals, evidence is emerging that reproductive health effects may result from exposure to these contaminants. The potential for contaminant-induced endocrine disruption, signaled by physiological impacts on fish in polluted surface waters, is receiving considerable attention from the scientific community.
The National Academy of Sciences, in its 9-volume treatise Drinking Water and Health, stated that only about 15% of the SOCs in water have been identified, with few of these characterized for their health effects. The National Research Council's Committee on Drinking Water Contaminants recognized this problem with the following statement in its report on its December 1999 Workshop on Emerging Drinking Water Contaminants: ".... no comprehensive list of potential drinking water contaminants exists, and there is a paucity of data on occurrence or health effects for the majority of potential contaminants. " The report goes on to state: "The total number of contaminants in this universe (of contaminant categories) is likely to be close to 100,000, . . ." Only 83 chemical and microbial contaminants are included in the current Drinking Water Regulations.
The watershed that feeds the proposed Randleman Dam currently provides a wide variety of sources of chemical and microbial contaminants. The number will undoubtedly increase as new chemical compounds are invented and recognized and as new pathogens emerge.
State and federal agencies have only a second-hand responsibility for protecting the quality of the drinking water of the people who live in the Triad area. Those charged with direct responsibility for drinking water quality for the residents are the municipal officials, including the local health departments and the water purveyors. They should not have to depend upon inadequate regulation at the state and federal levels to assure safe water for their constituency. Instead of seeking state and federal approval of a highly questionable water source, they should be examining better alternatives for the people they serve.
Some years ago, in an effort to attract industry, officials of the City of Asheville sought to obtain additional sources of water to add to their very high-quality supply drawn from protected watersheds in the surrounding mountains. They selected the heavily polluted French Broad River and spent more than a decade in getting it approved by the state. The French Broad was a "C" river throughout its length; fish kills in the vicinity of Asheville were not infrequent. However, the state, to its shame, was induced to change the classification from a "C" to an "A" for a stretch of river from a few miles above Asheville to a few miles below the city where it reverted to its "C" rating. With that approval in hand, city officials sought to have the citizenry approve a $40 million bond issue for a treatment plant and intake on the French Broad, for which they had already purchased a site. However, when the people realized that they would have French Broad water issuing from their faucets, they defeated the proposal overwhelmingly. The city then sought a better source; a plant taking water from a high quality tributary upstream on the French Broad went into operation in November, 1999.
My belief, and I have had experience with many such issues in cities around the country, is that when the people of the Triad are faced with the possibility of having to drink water from the Deep River, they will reject it. One important reason for this rejection is that they will recognize that other, better, alternatives are available. Meanwhile, time and money will have been squandered.
Alternatives to Randleman Dam
Alternatives include: other sources of water, purchase of water from nearby communities, and water reclamation which is essentially conservation of water. The first two options have been considered, though not seriously, but water reclamation for nonpotable reuse, an option that has become attractive to many cities in the U.S. and abroad, has not been considered.
The Dan and Yadkin, among other possible rivers, have been passed over because of a reluctance to even consider inter-basin transfers of water. While other utilities, such as electricity and gas, travel long distances, crossing all kinds of lines, both natural and man made, why must water remain within hydrologic boundaries? Most of the major cities of the world could not exist without drawing their water from outside their own watersheds. Los Angeles receives water from the Colorado River and from the San Francisco Delta, the latter being pumped more than 500 miles across high mountains. New York City draws most of its water from the Delaware River basin, which is far west of the Hudson River, which is the western border of the city. The only obstacles to using other sources for the rapidly-growing Triad are created by North Carolinians and are not dictated in nature or in engineering. Are people to be obliged to drink from highly polluted sources because their leaders are reluctant to even attempt to gain access to better sources?
The City of Reidsville has contracted to sell the City of Greensboro an average of 2.5 mgd from its excess supply which will profit their consumers. Burlington has a 50-year safe yield of 48 mgd and is reported as using less than 15 mgd at present. Martinsville, Virginia, and Winston-Salem are both expected to have surplus water. Such transfers of excess water to cities in the Triad are win-win situations as the excess water can provide monetary benefits to the people of the water-rich cities while the prospective purchasers can avoid water shortages at reasonable cost while they develop other long-term alternatives.
Water reclamation and nonpotable reuse:
This alternative involves using reclaimed wastewater for nonpotable purposes within urban areas, reducing the demand on limited supplies of high quality water. It involves the provision of dual distribution systems, one for potable water and the other for the reclaimed water. Initially, the major uses of the reclaimed water were for landscape irrigation and for market crop irrigation at the outskirts of the cities, as well as for large industries. This has expanded to irrigation of residential and commercial properties, road medians, sporting grounds such as golf courses, football and baseball fields, for parks and other environmental enhancement, and to large and small industries for process and cooling purposes, for vehicle and other cleansing, construction, air conditioning, and for toilet-flushing, particularly for multistory buildings. Toilet-flushing is the major use in Japanese cities. It appears absurd to use limited high-quality water for flushing toilets.
That this is an accepted practice is evidenced by the publication in 1994 of the second edition of an American Water Works Association Manual of Practice, No. M24, Dual Water Systems, the first having been published in 1983. While the U.S. Environmental Protection Agency has no regulations for reclaimed water quality, it published recommended standards in the 1992 (second) edition of Guidelines for Water Reuse. The first state to adopt regulations was California; their current regulations were published in 1978. Some forty states have adopted regulations for reclaimed water, with North Carolina adopting standards in 1997.
Many of the some one hundred cities that have initiated reclamation programs were obliged to retrofit the reclaimed water distribution systems in existing streets, while their customers retrofit their own facilities. Despite this cost burden, dual systems have proven to be economical. Of course, if the reclaimed water lines were to be installed at the same time as the potable water and sewer lines were installed, when an area was being newly developed, the costs would be significantly less. Inasmuch as the additional water required is for new residential, commercial and industrial development, the dual systems can be installed as the development grows. The Orange County Water District, which serves Irvine, CA, requires all new customers to connect to the two water lines as new areas are developed. In addition, the District has found it to be economically attractive to retrofit the older parts of the city that were built before the reclaimed water was available.
Cost comparisons in the Triad between a new dam, with a new treatment plant and new transmission lines, and dual systems are likely to show that reclamation is more economical. One reason is that the reclamation investment can be made gradually, as areas develop or as individual large customers such as industries, golf courses, and multistory buildings seek the reclaimed water. On the other hand, the dam, the water treatment plant and the transmission lines from the dam would require the total investment to be made at the outset. The present value of the staged reclamation program would likely be much less than that of the dam and its related facilities.
Commonly, wastewater treatment plants are located at low elevations in the system, so as to collect as much wastewater as possible by gravity. If the prospective reclaimed water markets are distant from the existing plants, satellite reclamation plants can be built near the areas to be served. Such plants would decrease the investment in enlargements that would otherwise be required at the existing wastewater treatment plants. Another advantage to satellite plants is that the sludge generated at the satellite plant can be returned to the sewer and handled at the original wastewater treatment plant. This permits the satellite reclamation plants to be small and built entirely enclosed so that they can be architecturally appropriate in residential and commercial areas. The odors and the noise from equipment and trucks that are associated with wastewater treatment would not be present. A very large satellite reclamation plant in Los Angeles has created Japanese gardens around the facility that are made available to the public for festive occasions.
It is my understanding that a large development is soon to be undertaken in the northeast of Greensboro, not too distant from one of the city's wastewater treatment plants. The reclamation program with its dual distribution systems can begin there while existing large customers can be recruited elsewhere.
In addition, the reclamation of the wastewater for nonpotable purposes in Greensboro, as well as in other cities in the Triad, would not only extend the usefulness of its existing high-quality sources for high-quality uses, it would significantly reduce the pollution burden on North and South Buffalo Creeks and the Haw River. The assimilative capacity of Buffalo Creek has been over-allocated for oxygen-consuming wastes ( 1996 Cape Fear River Basinwide Water Quality Management Plan) while the 2000 Draft Plan states: "Based on benthos monitoring, this (South Buffalo Creek below the Greensboro Osborne Wastewater Treatment Plant) portion has the worst water quality in the Cape Fear River Basin." Some of the costs of the dual systems have been shown to be offset by the savings in investments in control of wastewater discharges.
The purpose of this statement is not to propose that reclamation and reuse be adopted. What is proposed is that water reclamation be examined as thoroughly as the other options and that a decision be made when all the facts are available.
I feel confident that the public would readily accept the reclamation option, because it represents conservation of resources and less public health risk than life-long ingestion of Deep River water. In the many cities in the U.S. where reclamation programs for nonpotable reuse have been instituted, they have been adopted enthusiastically.
Reclassification of the Deep River
I cannot end this statement without a comment on the State's Deep River reclassification decision. The basis for the decision was outlined in a letter from Francis W. Crawley, Special Deputy Attorney General in the North Carolina Department of Justice, to Steve Zoufaly of the Department of Environment, Health and Natural Resources on behalf of the Environmental Management Commission, dated May 22, 1997. Based on the State statutes, Crawley stated ". . . that the best usage that can be made of the waters being classified is the guiding factor in determining the proper classification." He goes on to state: "Thus, the highest classification that may be assigned to a water body is that classification with uses that the (Environmental Management) Commission believes may be attained through the imposition of allowable pollution control requirements."
He goes on to conclude: "The fact that data indicate the waters do not meet the standards for the proposed classification does not prevent the Commission from reclassifying the waters to the higher classification if pollution controls will bring the waters up to standards."
On this basis, every surface water in North Carolina can be classified as being "WS-IV,"suitable for drinking, if some agency declares that it desires to use that water for their public drinking water supply, because the water can be treated to meet current standards. The fact that current standards do not include many already known chemical and microbial contaminants, and future standards will always be behind in incorporating known contaminants, let alone those that are not yet been identified, would not prevent any source being declared suitable for drinking by the State.
The absurdity of this approach flows from the fact that Mr. Crawley bases his conclusions on the federal Clean Water Act, which is intended to address ambient water quality, to make the waters of the nation fishable and swimmable, but not necessarily drinkable. In fact, the Primary Drinking Water Regulations, promulgated under the federal Safe Drinking Act, states in regard to selection of sources of water for drinking: "Because of human frailties associated with protection, priority should be given to selection of the purest source. Polluted sources should not be used unless other sources are economically unavailable,.. " The polluted Deep River is certainly not the purest source available to the Triad nor are other sources economically unavailable.
Furthermore, the Environmental Management Commission recognized that the waters impounded by Randleman Dam would not satisfy the water quality standard for chlorophyll a, but approved the reclassification to "WS-IV" presumably because chlorophyll itself is not a health threat. However, waters high in chlorophyll are notoriously more difficult to treat in conventional water treatment plants, with the associated algae shortening filter runs while sheltering microbial contaminants from disinfection processes. Furthermore, reservoirs in this area commonly stratify in summer and are anaerobic (devoid of oxygen) at the bottom because of the decomposition of algae and other organic material that accumulates. Under such circumstances, the water dissolves heavy metals that may be raised to the upper layers in the autumn when the reservoirs overturn.
Those responsible for assuring the citizens of the Triad an adequate supply of safe drinking water should examine all alternatives from the standpoint of the quality of the water for drinking, as well as its quantity. Citizen groups must be involved early in the process of arriving at a solution to the urgent problem of providing adequate water supply for this rapidly-growing region.