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Portland Water Bureau (XLC)XLC Logo

August 4, 1998 Letter to Rosemary Menard from Kristina Heinemann and Bill Glasser

United States Environmental Protection Agency
Washington, D.C. 20460

Office of Policy, Planning and Evaluation

August 4, 1998

Rosemary Menard, Director
Water Resources Management Group
City of Portland Bureau of Water Works
1120 S.W. 5th Avenue
Portland, OR 97204-1974

Dear Ms. Menard:

In preparation for the sponsor-stakeholder meetings this Fall, we are writing to you today to propose a short list of discussion topics which we desire to explore further with you and the participant stakeholders in the context of Final Project Agreement (FPA) development.

After considerable deliberation within our internal Agency workgroup, we would like to propose five items for FPA discussions. We present them here accompanied by only a brief description with the intention of having additional discussion with the Water Bureau and project stakeholders over the next several months. We hope this discussion will further define and clarify what we hope would result from expanding and/or refining the Lead Hazard Reduction Program (LHRP) in the ways that we identify below. Since you are now concluding the pilot year of the Home Lead Hazard Reduction Program (HLHRP), we assume that some of these changes could be included as part of your evaluation and planning for subsequent years of the Program. We look forward to the upcoming discussions and the further development and implementation of the LHRP and most importantly, the realization of its benefits for the citizens of Portland and other communities served by the Water Bureau.

Home Lead Hazard Reduction Program (HLHRP)

  1. We understand that interim controls for soil are not currently included in the HLHRP. Lead from soil can be tracked into a home, recontaminating a property where indoor work has been completed by CLEARCorps workers. Lack of any management controls for contaminated soil may reduce up front resource requirements, but could in the long run, make interior interventions less effective. We would like to look at opportunities to reduce this risk of recontamination.
Public Education and Outreach
  1. We believe that some of the language currently being used in public information brochures produced by the Water Bureau, "Let Us Help You Reduce Your Family's Exposure to Lead" and "What about lead in drinking water?" could be misleading. Specifically, we would like you to reconsider any statements that imply to the casual reader that there is no risk of exposure to lead through drinking water in Portland or the surrounding metropolitan service area. Statements along the lines of "no risk" could contradict any effort to effectively market a Free Lead in Water Testing Program.  
Lead-in-Water Testing Program
  1. The Lead and Copper Rule requires water systems to collect lead and copper tap water samples in homes most at risk for high lead levels (homes built after 1982). In Oregon, these are homes built between 1983 and 1984, when the State's lead ban went into effect. Because testing of homes built after 1984 has not been required, we propose that you include free copper testing along with lead in the Lead in Water Testing Program. Newer copper plumbing in homes built after 1984 may be a source of copper contamination in drinking water.
  2. We also recommend that you consider targeted marketing of the Lead-in-Water Testing Program to the small, outlying municipalities in the Bureau's service area. Because of their size and location, these communities could miss some of the benefits of the Lead Hazard Reduction Program (e.g., the Home Lead Hazard Reduction Program will not initially focus on areas outside of the City of Portland). By raising this as a discussion topic, we hope to explore how the benefits of the LHRP can be distributed throughout the entire service area.
Performance Monitoring and Evaluation Program
  1. XL projects are an opportunity for EPA to conduct "regulatory experiments". As such EPA has a strong interest in the data that results from these experiments which may eventually inform changes to our regulatory programs. Effective monitoring and evaluation of the project will be critical to obtaining this data. We want to engage in a full discussion with the Water Bureau and project stakeholders on the elements of an evaluation and monitoring plan that meets the needs for evaluation, but also will not impose significant additional burden on you as the project sponsor.
In addition to the above FPA discussion items we would like to bring to your attention two additional questions raised by your most recent communication to us on July 1. In this note you include an outline of ongoing efforts for additional stakeholder involvement and a time line for these activities. You specifically reference the formation of an HLHRP Stakeholder Advisory Committee (SAC). Is this SAC for the HLHRP only? Is there an equivalent group that will represent and focus on the water treatment components of the LHRP? We highlight these questions with the recommendation that you convene a stakeholder group that will be able to address all the components of the LHRP, not just household lead paint and dust issues.

The second question addresses the Lead-in-Water Testing Program. According to the schedule in your July 1 note, this program will be refined and an implementation plan developed before or concurrent with the first sponsor-stakeholder meeting in September. Given that two of EPA's discussion topics address the Testing Program, will the opportunity still exist to influence the ultimate design of the Program after discussion at the first sponsor-stakeholder meeting in September? We hope that it will.

We look forward to the upcoming discussions with the Water Bureau and the larger community of stakeholders. We would also like to thank you for your considerable effort up until now to make this XLC project a success. If you have questions or concerns in response to this letter please contact us.

Kristina Heinemann
Bill Glasser

cc: Alberta Seierstad, Portland Water Bureau
EPA FPA Development Team
EPA Project Support Team

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