THUNDER BAY WATER WATCH November 9th, 2015 Dear Mayor Hobbs and City Councillors, Please find attached the signatures of over 600 concerned citizens who ask you to stop the sodium hydroxide test slated to begin in Current River in January 2016. The signatures were collected by Thunder Bay Water Watch in the short period leading up to and immediately following the public meeting about the issue on September 17th, 2015. In truth, since City staff said at the meeting that the test would proceed even if all 600 affected Current River residents were opposed to it, our efforts to collect signatures stopped after the meeting in preference for spending time looking into the test dangers and possible alternatives. We believe most of the Current River residents are unhappy with the test and think the plan to add sodium hydroxide to water for the whole City starting in January 2017 will meet with strong opposition. We oppose adding sodium hydroxide to our drinking water. While we acknowledge that the problem of lead contamination due to lead feeder pipes to approximately 8000 residences is serious, adding this chemical is at best an expensive and eternal band-aid solution and at worst a risk to health and a deterrent to drinking City water. We have understood that the pH will be raised as high as 9.6. This is well outside the “acceptable” range as defined by the US Environmental Protection Agency1 (pH 6.5 – 8.5) which notes that high pH water may have a slippery feel and soda taste and may leave deposits. It is also far above the 2014 Health Canada guideline for acceptable drinking water2 which is also the pH range of 6.5 – 8.5. This is worrisome for a number of reasons. Because the pH scale is logarithmic, water with a pH of 9.5 is 10 times as basic as water with a pH of 8.5. Health Canada3 wrote: "An acceptable range for drinking water pH is from 6.5 to 8.5. Corrosion effects may become significant below pH 6.5, and the frequency of incrustation and scaling problems may be increased above pH 8.5. With increasing pH levels, there is also a progressive decrease in the efficiency of chlorine disinfection processes." Health Canada also suggests that a pH of over 7 can result in corrosion and pitting of copper and that increased pH can lead to steel corrosion in the form of hard crusty deposits and a resultant loss of head (meaning more energy required for pumping, or lower water pressure). High pH, they wrote, may result in drinking water with a bitter taste. The impacts on drinking water quality are, according to Health Canada, complex: "Insofar as aqueous chemical equilibria invariably involve hydrogen (and hydroxyl) ions, pH will be related, in one or more of several different ways, to almost every other water quality parameter." (4) It is clear that it is not possible to JUST introduce sodium hydroxide to raise the pH – there may be many unintended consequences, including for homeowners who have installed water softening equipment. The consequences can be serious: "By keeping the pH below 8.5, the rate of chlorine disinfection is increased and the production of trihalomethanes is reduced.... the increased yield of trihalomethanes at high pH values may be detrimental."(5) Trihalomethanes are environmental pollutants that may be carcinogenic and are limited to 80 parts per BILLION in drinking water by the US EPA.(6) What we find most troubling is that according to Health Canada, “Few waters are plumbo- solvent if the pH is above 7.0.”(7) “Lead is immune to corrosion at all pH levels above 6 in pure water.”(8) In lay terms, this means that lead does not generally corrode easily in water that is basic – which Thunder Bay’s water already is. And yet, according to City staff at the September 17th meeting, some water tests in homes with lead feeder lines exceeded the allowable lead content. It is hard to believe that Thunder Bay’s water could be unique enough to require pH that is over 2.5 points about the level at which most water does not corrode lead. This inconsistency makes it appear that the test may be a desperate attempt to appease the Ministry of the Environment and Climate Change despite evidence that increasing the pH is unlikely to be effective, and potentially harmful. There are two more reasons why we oppose adding sodium hydroxide to solve the lead level problem in some of Thunder Bay’s water. First, if the chemical is added to the entire water supply, City employees will need to frequently handle sodium hydroxide in solid form, increasing the risk of injury or adverse health effects. Second, adding the chemical will cost the City a half-million dollars per year, every year, forever. We favour postponing the test and asking City staff to enter into discussion with citizen stakeholders to come up with alternate solutions. At the September 17th meeting City staff said that if Thunder Bay had a viable plan to replace lead feeder pipes that the MOE would be satisfied. While we do not presume to know what the result of a consultation process would be, or the final form of a plan to retire lead feeder lines, we suggest a high probability of success using the following scenario as a departure point. The City would initiate a campaign to encourage homeowners with lead feeder lines to have them replaced. Information could be sent with water bills to reach all homeowners and local media could be asked to help inform the public. The City, recognizing that the lead problem was not caused by bad decisions by individual homeowners, could subsidize the pipe replacement with a $500 payment (costing $400,000 per year for 10 years for 8000 total replacements) and would offer to pay the balance with repayment amortized over 10 years, added to the water bill. At the September 17th meeting a figure of $2000 per home for the pipe replacement was discussed. An economy of scale might help to reduce this cost, and homeowners could be encouraged by the knowledge that the resale value of their property would increase. Concurrently, the media campaign could advise homeowners with lead feeder lines to flush the lines each morning or when returning after being absent all day by running the cold water for 5 minutes. This would immediately reduce the risk of lead contamination – very likely in all cases below acceptable levels. While City staff said at the September 17th meeting that the City tried for three years to get people to change their lead feeder lines, we do not believe many people knew anything about the issue. A small incentive, a loan over 10 years, and more information would get homeowners active on replacing the lines, and while the subsidy would cost the City almost as much as the sodium hydroxide scheme over the next ten years, once the lines are replaced the expenditure would stop. Thunder Bay Water Watch is willing to work with the City as it works on a permanent solution to this problem. We look forward to hearing from you. Rhonda Hanah Chair - Thunder Bay Water Watch Paul Berger Member -Thunder Bay Water Watch tbaywaterwatch@gmail.com , ph #333-0131 -------------------------------------------------------------- 1http://water.epa.gov/drink/contaminants/secondarystandards.cfm 2 http://www.hc-sc.gc.ca/ewh semt/alt_formats/pdf/pubs/water-eau/sum_guide- res_recom/sum_guide-res_recom_2014-10_eng.pdf 3 http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/ph/index-eng.php 4 http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/ph/index-eng.php 5 www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/ph/index-eng.php 6 https://en.wikipedia.org/wiki/Trihalomethane 7 http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/ph/index-eng.php 8 http://www.hc-sc.gc.ca/ewh-semt/alt_formats/hecs-sesc/pdf/pubs/water-eau/ph/pH- eng.pdf