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 Douglas WisePortland Water BureauPortland Water Bureau (PWB) would like to submit the following comments regarding initial review application G-18798. PWB understands that the application has been placed on hold effective October 29, 2019 but that the comment period for the Initial Review will still close November 28, 2019, and is submitting this information to ensure it may be considered by OWRD during the initial review period. The proposal will affect groundwater resources in the City’s Columbia South Shore Well Field and requires further analysis to determine whether these impacts will be compatible with the use of the Troutdale Sandstone Aquifer (TSA) for municipal supply under permit G-8755, with a priority date of November 12, 1976. PWB is pursuing additional analysis in collaboration with the applicant to more fully understand the proposal’s effect on drinking water well development in the TSA. OWRD should consider the following points in its review of the application: 1) The initial review documentation references only an existing municipal TSA production well roughly 1.3 miles from the proposed project area and not the areal extent of permit G-8755. PWB has 3 easements for future wells that are closer to the proposed injection wells than the TSA well identified in the application, at roughly 4,500 feet, 3,500 feet, and 3,000 feet from the proposed injection. The injection wells are likely to be within the 30 year capture zone of at least one and possibly two of these future municipal production wells in the same aquifer. This would amplify the risk of contamination reaching such a well should the injection wells be impacted by spills, leaks, or otherwise introduce contaminants into the TSA. 2) The long-term reliability of TSA water quality influenced by injected water and potential public health ramifications of utilizing injected water for municipal water supply are unknown and merit further evaluation. 3) Future regulatory or treatment requirements that could be imposed by OHA, DEQ and/or EPA for the municipal wells that would be sourcing injected water from an industrial use such as the proposed project are not clearly understood. PWB believes that these concerns regarding the project’s potential effects on municipal water supplies are substantial and warrant OWRD’s attention.