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Letter from Chuck Findley to Rosemary Menard

Reply To
Attn Of: RA-140

Rosemary Menard, Director
Water Resources Management Group
City of Portland Bureau of Water Works
1120 S.W. 5th Avenue
Portland, OR 97204-1926

Dear Ms. Menard:

I would like to take this opportunity to reiterate the Agency's support for your XL Communities project and your ongoing commitment to making this project a model of excellence for local agencies nationally. We have been enthusiastic about this project from the beginning and continue to support your efforts with the same degree of enthusiasm that we expressed at the outset.  We continue to believe that the multimedia approach the Water Bureau is taking to reduce exposure to lead in the community through the Lead Hazard Reduction Program has the potential to achieve superior public health protection.  In addition, EPA staff, having had the opportunity to work with Bert Seierstad and Stacey Edwards on your staff,  have been impressed and appreciative of the level of support and effort that Bert and Stacey have invested in making this project a success.

I would like to address your current concerns and do this by restating some of the key points made in our letter to you of November 26, 1997.  As an Agency we fully stand by the statements made in that letter and most importantly in the context of our current discussions, our statement that we did not have then and do not now have any intention of  challenging Oregon's finding that Portland is in compliance with the treatment requirements of the LCR.

EPA fully supports the Oregon Health Division in its role in serving as the primacy agency for the  drinking water program in Oregon.  Because water treatment issues under the LCR fall directly in the areas addressed by the Optimal Corrosion Control Treatment plan Portland has in place with the State, we think that discussion of the results of any recent monitoring are appropriately an issue between the State and the City. Our expectation is that monitoring results would be communicated to the Agency through the normal, routine channels that have been established between the State and Regional drinking water programs.  And because the Portland Water Bureau is also engaged in FPA negotiations for an XLC project where drinking water treatment is one of the four key components of the project, we want you to communicate the results of any monitoring event to the direct participant stakeholder group.

For the duration of the XLC project, EPA does not intend to take action when there are small exceedances of the lead action level.  In the unlikely scenario that  lead concentrations in drinking water were to reach pretreatment levels, EPA, in consultation with the State and Water Bureau,  would reevaluate the appropriateness of proceeding under Project XL.

We remain committed to completing the FPA and assisting the Bureau to assess the anticipated positive public health benefits of the LHRP. Should you continue to have questions and concerns regarding the Agency's intentions,  please feel free to contact me directly at 206 553-1793.


Chuck Findley
Deputy Regional Administrator

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