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Portland Water Bureau (XLC)
January 26, 1999 Portland's Lead Hazard Reduction Program (LHRP) Project XL for Communities Final Project Agreement (DRAFT)
Portland's Lead Hazard Reduction Program (LHRP)
Project XL for Communities
Final Project Agreement (FPA)
January 1999 DRAFT
Project XL for Communities
Final Project Agreement (FPA)
January 1999 DRAFT
TABLE OF CONTENTS
I. OVERVIEW Page
A. Purpose of the XL for Communities program ..................................................................1
B. Purpose of this Agreement ..............................................................................................1
II. DESCRIPTION OF THE PROJECT
A. History of Program Development ...................................................................................2
B. General Background on the Community and Issues .........................................................4
C. Brief Description of the Components of the Lead Hazard Reduction Program .................5
D. Goals and Objectives of the Lead Hazard Reduction Program ........................................6
E. Description of the Activities and Accomplishments of the Lead Hazard Reduction Program
1. Water Treatment and Water Quality Monitoring ...................................................9
2. Home Lead Hazard Reduction Program .............................................................11
3. Stakeholder Involvement, Public Education, and Outreach ..................................15
4. Lead-in-Water Testing Program .........................................................................19
F. Problems and Barriers the Lead Hazard Reduction Program is Intended to Address ......20G. Why the Lead Hazard Reduction Program is Beneficial to Project Sponsors and Co-
Sponsors, the Environment, and other Affected Parties .....................................................31H. What will occur with the Lead Hazard Reduction Program, compared with what would
occur if the Program were NOT Implemented ..................................................................34I. How the Lead Hazard Reduction Program Addresses XL Criteria
1. Environmental Results ........................................................................................37III. REQUIREMENTS AND COMMITMENTS OF THE PROGRAMS
2. Stakeholder Involvement, Support, and Capacity for Community Participation ....38
3. Economic Opportunity .......................................................................................42
4. Feasibility ..........................................................................................................43
5. Transferability ....................................................................................................44
6. Monitoring, Reporting, and Evaluation ................................................................45
7. Equitable Distribution of Environmental Risks .....................................................46
8. Community Planning ..........................................................................................47
9. Innovative Approaches, Multi-Media Focus, and Pollution Prevention ................48A. Legal Mechanisms .............................................................................................48B. Key Commitments .............................................................................................49
C. The Lead Hazard Reduction Program as a Demonstration Project ......................54
V. ADMINISTRATION OF THE AGREEMENTA. Term of the Agreement ......................................................................................59B. Decision-Making Processes
1. FPA Development ...................................................................................60C. Public Participation, Public Notice, Public Records, Reporting and Periodic
2. FPA Implementation ................................................................................61
Reviews..................................................................................................................61D. Events preventing Project Implementation ..........................................................63
E. Modification of the Agreement ...........................................................................63F. Termination/Withdrawal .....................................................................................63
G. Means of Giving Notice ....................................................................................64
H. Orderly Transition .............................................................................................64
I. Statement of Unaffected Authorities ....................................................................64
J. Contact Points and Signatories ...........................................................................65
APPENDICES
Appendix 1 Stakeholders Involved in the Lead Hazard Reduction Program......................69
Appendix 2 XL Stakeholder Categories .........................................................................70
I. OVERVIEWA. PURPOSE OF THE XL FOR COMMUNITIES PROGRAM
This Agreement states the intention of:
" the U.S. Environmental Protection Agency (EPA),
" the Project Sponsor:
- the City of Portland Water Bureau (PWB)," the Project Co-Sponsors:
- the Portland Water Bureau's wholesale water purveyors,
- the Multnomah County Health Department (MCHD),
- the Oregon Health Division Drinking Water Section (OHD)" and Stakeholders from the Portland metro community and elsewhere, to carry out a pilot project as part of EPA's "Project XL for Communities" program. This project, called the Lead Hazard Reduction Program, is designed and implemented for the purposes of testing innovative approaches to environmental protection from human exposure to lead and copper.
Project XL, which stands for "eXcellence and Leadership", is a national pilot program that provides a unique opportunity to test innovative ways of achieving better and more cost-effective public health and environmental protection. Under Project XL, the EPA offers flexibility in its regulations, policies, procedures, processes, and guidance, as well as other benefits to encourage project sponsors and communities to develop and test innovative, tailored, and more effective alternatives to the current system of environmental and public health protection. Project XL for Communities is designed to provide flexibility specifically for communities, including local governments, community organizations, citizen and neighborhood groups, and other public or private organizations.
B. PURPOSE OF THIS AGREEMENT
This Final Project Agreement (FPA) is intended to be a joint statement of the plans and intentions of the parties above with regard to Portland's Lead Hazard Reduction Program.
1. The FPA is intended to clearly state the plans of the various participants and to represent the firm commitment of each participant to carry out the project.
2. The FPA is not, however, intended to create legal rights or obligations and is not a contract, or a regulatory action such as a permit or rule.
3. The Lead Hazard Reduction Program is also implemented through a separate rule which is legally enforceable (the Lead and Copper Rule under the Safe Drinking Water Act; administration of this Rule is by the Oregon Health Division, as granted primacy by the EPA in the state of Oregon).
4. The FPA does not give any of the parties a right to sue other parties for any alleged failure to implement its terms, either to compel implementation or to recover damages.
II. DESCRIPTION OF THE PROJECT
A. HISTORY OF PROGRAM DEVELOPMENT
In 1992, the Portland Water Bureau conducted monitoring for the Lead and Copper Rule, a drinking water regulation under the Safe Drinking Water Act. In 1993 and 1994, a research study was conducted on Portland's drinking water as required by the Lead and Copper Rule. Portland's source water contains no detectable lead, and Portland has no lead pipes in the distribution system, or in pipes which connect to the customer's plumbing. However, because Portland's water is very soft with a naturally low pH and alkalinity, the water is termed as "corrosive", and it can leach lead, copper, and other metals into water left standing in plumbing systems.
As a result of the research study and the requirements of the Lead and Copper Rule, the Portland Water Bureau was faced with chemically treating Bull Run water for maximum reduction of the water's ability to leach lead and copper from home plumbing systems. To meet this requirement, the water's pH would have been raised to 9.5 and alkalinity to 20-25. Outreach was conducted to industrial and residential customers, and the community about the recommended treatment changes. These stakeholders expressed a negative perception of the perceived quality of Bull Run water if the recommended changes were implemented. Dramatically increasing the pH of Bull Run water would have also produced unacceptable levels of potentially toxic by-products of chlorine disinfection, potentially resulting in noncompliance with drinking water standards for those compounds. The community asked for a better approach which would
" look at a combination of alternatives that addressed different sources of lead exposure,
" recognize the fact that while Portland's drinking water can be a source of lead in the environment it is not typically the primary source of a person's exposure to lead,
" recognize the fact that lead-based paint and lead-containing household dust are the most commonly identified sources of lead in the environment, and the primary causes of elevated blood lead levels both locally and nationally, and
" develop a treatment strategy that balanced conflicting treatment and regulatory needs without dramatically altering water quality.
In 1994, the Portland City Council approved a strategy for compliance with the Lead and Copper Rule that included design of water treatment facilities to control corrosion, and a study to investigate alternatives for compliance. The Water Bureau then worked with consultants and other stakeholders to develop a preliminary strategy that included minimal treatment of the water for corrosion, combined with other effective environmental and public health alternatives. In August 1995, the Council directed the Portland Water Bureau to construct a corrosion control treatment facility, and to work with other stakeholders to develop the Lead Hazard Reduction Program.
The Portland Water Bureau then worked with staff from regional health departments, community organizations, and other stakeholders to more fully develop an alternative strategy called "The Lead Hazard Reduction Program" (LHRP). The LHRP uses a combination of approaches to reduce lead and copper hazards, and a public health approach which focuses efforts where the risks of exposure are the greatest. The program minimizes the need for treatment and the perceived changes in water quality, while also achieving significant corrosion control benefit, and meeting the public health intent of the Lead and Copper Rule.
In December 1996, the Portland City Council supported the implementation of the Lead Hazard Reduction Program, and directed the Water Bureau to work with EPA and the Oregon Health Division (the drinking water regulatory authority in Oregon as granted primacy by the EPA) to achieve approval of the program and compliance with the Lead and Copper Rule.
In January 1997, the Portland Water Bureau began corrosion control treatment of the Bull Run source water. In March 1997, the Portland Water Bureau, in partnership with the wholesale water purveyors, submitted the Lead Hazard Reduction Program to the Oregon Health Division. A joint water quality monitoring plan was also submitted, which was designed to ensure that monitoring of lead, copper and water quality parameters would be representative of the entire Bull Run Service Area, including monitoring by wholesale purveyors. In November 1997, the Oregon Health Division approved the Lead Hazard Reduction Program "as optimal corrosion control treatment for lead and copper at the customer taps throughout the regional distribution system", thus declaring that the Portland Water Bureau and it's Portland-area wholesale water purveyors were in compliance with the Lead and Copper Rule.
Also in March 1997, the Portland Water Bureau, in partnership with the wholesale water purveyors, submitted a proposal for acceptance of the Lead Hazard Reduction Program under the EPA's Project XL for Communities. EPA staff familiar with lead and copper environmental and public health issues reviewed the proposal and also looked for commitment to several criteria. The EPA focused its review on two primary criteria. The first was whether the project could produce environmental or public health outcomes superior to what would have resulted had the project not been implemented. The second criterion was a commitment to participatory community planning and consensus-building, as well as stakeholder involvement and support. In March 1998, the EPA determined that the Lead Hazard Reduction Program met the Project XL criteria, and offered the Portland Water Bureau the opportunity to negotiate a Final Project Agreement (FPA) for acceptance as an EPA Project XL for Communities program. In April 1998, the Portland Water Bureau accepted EPA's offer, and began the process to develop this FPA.
B. GENERAL BACKGROUND ON THE COMMUNITY AND ISSUES
Early project work indicated that there was a general lack of knowledge, or erroneous knowledge, about lead issues in the community. However, when community members are given the opportunity to learn more about occurrences of lead in the environment and the very real problems of lead exposure, then lead becomes an important issue for them. It is an issue that has elicited emotional responses from members of the community, along with strong expressions of concern and calls for programs that effectively address the issues. Information on the demonstrated connections between lead exposure and potentially serious learning difficulties for children cause concern, but knowledge about the relatively simple measures that can be taken to identify and control lead exposure gives hope for resolution of these problems.
From the beginning, there has been a high level of community support for programs that reduce lead exposure and provide effective education on the issues. Community members continue to ask for effective, comprehensive solutions for the entire Portland metro region, and public health approaches which focus efforts where the risks of lead exposure are the greatest. Stakeholders in the community also want programs which identify and provide follow-up assistance for those instances where exposure to lead and copper from drinking water is an issue. Industrial and residential customers continue to ask for alternatives which minimize the need for treatment and the perceived changes in water quality, while also achieving some corrosion control benefit.
Since the Lead Hazard Reduction Program was begun, there have been a number of observed changes in the response to lead exposure and health issues in Portland and elsewhere. More programs are now being developed with an emphasis on community involvement, such as HUD's Portland Lead Hazard Control Program. The Water Bureau is now a party to many partnerships with other organizations and agencies which have been developed to better address lead issues: blood lead screening with Physicians for Social Responsibility and The Portland Urban League; Lead Summits which will be convened annually; development of a Comprehensive Lead Planning effort for Portland with efforts led by the Urban League and including a large diversity of organizations, agencies and community members; and development of the Portland Metro-wide Lead Educational Campaign, led by the Water Bureau and including a wide range of stakeholders. There is now a move to develop a state-wide blood lead screening plan by Oregon Medical Assistance Programs (OMAP) and the Oregon Health Division. Lead is also an issue now at other levels and in other arenas, as evidenced in work by the Governor's Environmental Justice Advisory Board in Oregon, and in the stated positions of persons such as Tipper Gore, Reverend Jesse Jackson, and the federal Housing and Urban Development agency.
C. BRIEF DESCRIPTION OF THE COMPONENTS OF THE LEAD HAZARD REDUCTION PROGRAM
The Lead Hazard Reduction Program uses a combination of approaches to reduce lead and copper hazards, and a public health approach which focuses efforts where the risks of exposure are the greatest. The program minimizes the need for treatment and the perceived changes in water quality, while also achieving corrosion control benefit and meeting the public health intent of the Lead and Copper Rule. The four components of the Lead Hazard Reduction Program (LHRP) are:
1. Water Treatment and Water Quality MonitoringPrograms 1 and 4 address risks from lead and copper in drinking water. Programs 2 and 3 address other lead issues that are critical for the Portland metro area.
2. Home Lead Hazard Reduction Program
3. Stakeholder Involvement, Public Education, and Outreach
4. Lead-in-Water Testing ProgramThe Water Treatment and Water Quality Monitoring program began with pH treatment of Bull Run source water in January 1997. The Home Lead Hazard Reduction Program and Stakeholder Involvement, Public Education, and Outreach components of the LHRP began on July 1, 1997; these programs were implemented as pilot programs in their first year, and are now expanding to other Portland communities and to the entire Bull Run Service Area. The Lead-in-Water Testing Program is scheduled to be implemented in the Summer of 1999.
D. GOALS AND OBJECTIVES OF THE LEAD HAZARD REDUCTION PROGRAM
Goals and Objectives are listed below by consideration of each component of the Lead Hazard Reduction Program.
Details on how the specific goals and objectives are implemented and realized, is provided in the following section (part II. E).
Goals and Objectives of the WATER TREATMENT AND WATERQUALITY MONITORING program component:" Produce reduced lead and copper levels at the customers tap
" Comply with monitoring and reporting requirements of the Lead and Copper Rule
" Provide consistent lead and copper monitoring methods
" Provide consistent water quality
" Provide safe and reliable water treatmentGoals and Objectives of the HOME LEAD HAZARD REDUCTION PROGRAM component:" Decrease the number of children being exposed to lead risks in their living situations
" Raise public awareness about the dangers and risks of lead in the living environment
" Increase the capacity of the community to detect and prevent elevated blood lead levels
" Help insure sustainability of lead reduction efforts over time
" Increase the number of affordable "lead-safer" housing units in the metro area through the reduction of
lead hazards primarily associated with lead-containing dust in targeted housing
" Prepare CLEARCorps Team members as information and education resources for the community
" Teach CLEARCorps Team members marketable work skills, and help them prepare for future employment
" Gather data, and analyze the effectiveness and public health benefits of the program
" Use these data to make program changes as needed, and maintain an effective program
" Estimate the prevalence and magnitude of household lead dust hazards to which children living in
high-risk neighborhoods can be exposed
" Determine the characteristics of dwellings most likely to have dust lead hazards so that:
- high-risk homes can be identified, and CLEARCorps program recruitment more effectively targeted, and
- program resources are ensured to be targeted and used effectively
" Ensure that the Home Lead Hazard Reduction Program functions as part of the larger Lead Hazard
Reduction Program to address the Water Bureau's public health, regulatory compliance, and stakeholder
involvement objectivesGoals and Objectives of the STAKEHOLDER INVOLVEMENT, PUBLIC EDUCATION, AND OUTREACH program component:The goal of the program is a metro community whose members have a good knowledge of the sources, effects, and control of lead and copper hazards in their home environments, and a community whose members are involved in shaping the Lead Hazard Reduction Program to meet their needs." Provide education and referral to resources for free blood lead testing for young children
" Provide education on risks from exposure to lead in the home environment, sources of lead exposures, and how those sources can be reduced and controlled
" Provide education on potential sources of lead and copper in drinking water, resources for water testing and follow-up assistance, and how these lead and copper sources can be reduced and controlled
" Provide education community-wide, in a way which targets parents of young children, and pregnant mothers
" Provide information on the risks from use of culture-based lead-containing products, safer alternatives to those products, and encouragement and support to use the alternatives
" Educate health care providers to include lead and copper exposure prevention information in their daily dialog with clients
" Develop educational materials that can be used by a wide diversity of communities and individuals
" Provide numerous opportunities and invitations for involvement by community and environmental groups, and interested citizens
" Facilitate the development of partnerships between agencies, community organizations, and individuals in order to achieve the above objectivesGoals and Objectives of the LEAD-IN-WATER TESTING PROGRAM component:
The goal of the program is to identify customers in the Bull Run Service Area who are at greatest risk from exposure to elevated levels of lead and/or copper in their drinking water, and provide assistance in reducing their exposure to lead and/or copper from this source.
This program is being developed. Preliminary program objectives include:
" Develop a program that targets those customers at greatest risk of exposure to lead and copper in drinking water
" Provide free or low cost water testing for lead and copper in drinking water
" Make testing available to customers throughout the Bull Run Service Area
" Educate customers, including school administrations, and landlords and landlord-tenant associations on lead and copper in drinking water issues and how problems can be identified and remediated
" Encourage the participation of school administrations, landlords, and landlord-tenant associations in the program, and educate them on understanding of the liability issues, and how they can be addressed
" Provide follow-up assistance to those customers found to have elevated lead and/or copper levels in their drinking water
" Ensure there is a predictable and manageable demand for services
" Provide a program that is cost effective
" Evaluate the program's results and provide measures of effectiveness for the programE. DESCRIPTION OF THE ACTIVITIES AND ACCOMPLISHMENTS OF THE LEAD HAZARD REDUCTION PROGRAMSpecific activities and accomplishments are described below by consideration of each component of the Lead Hazard Reduction Program.
1. Activities and Accomplishments of the WATER TREATMENT AND WATER QUALITY MONITORING program component
The Water Treatment and
Water Quality Monitoring Program in BriefThis program was developed to:
"Adjust the pH of Portland's source water
"Significantly reduce the ability of treated water to leach lead and copper from household plumbing
"Balance the conflicting treatment and regulatory needs without dramatically altering water quality
"Conduct ongoing monitoring of water at taps in targeted customers homes """Evaluate the program's results to ensure that public health benefit can be measuredIn January 1997, the Portland Water Bureau began corrosion control treatment of the Bull Run water supply. This pH adjustment has changed Portland's water from slightly acidic (about pH 6.5) to slightly basic (about pH 7.5). Objectives of water treatment are to significantly reduce the ability of treated water to leach lead and copper from common household plumbing materials, such as copper, brass, and lead from lead-based solder, and to balance the conflicting treatment and regulatory needs without dramatically altering water quality.In order to achieve safe and reliable water treatment, the treatment process is operated to assure that the Bureau meets its goals of providing a reliable supply of safe drinking water at affordable rates. This includes protecting public and employee safety, and ensuring continuous operations, and process monitoring through use of back-up power, redundant equipment, and appropriate back-up systems as needed.
A water quality monitoring plan was developed to ensure that monitoring of lead, copper and water quality parameters would be representative of the entire Bull Run service area, including monitoring by wholesale purveyors. Representative "Tier 1" or "targeted" homes, as defined by the Lead and Copper Rule, were identified across the Bull Run Service Area. Monitoring sites also include the "entry point" to each participating water system, and sites for monitoring routine water quality parameters within each distribution system. The joint monitoring plan has been approved by the Oregon Health Division (OHD; Oregon's drinking water regulatory authority as granted primacy by the Environmental Protection Agency).
Ongoing compliance with water quality monitoring and reporting requirements are key elements of this component. This includes monitoring of "targeted" or "Tier 1" homes in the Bull Run Service Area every six months, plus routine monitoring at the entry point to each distribution system, and periodic monitoring of water quality parameters in each of the distribution systems.
The corrosion control treatment process is intended to provide consistent water quality, and to limit the degree of change in water quality by avoiding dramatic changes in pH, alkalinity, and hardness. The existing process is, and will continue to be, operated in such a way to assure consistent water quality by meeting water treatment goals for pH at the entry points to the distribution systems, and maintaining consistent levels of pH and alkalinity within the distribution systems. All such monitoring to date has been in complete compliance with regulatory requirements.
The Lead and Copper Rule sets Action Levels of 15 parts per billion (ppb) for lead and 1.3 parts per million (ppm) for copper as monitored in "Tier 1" homes. Four rounds of lead and copper monitoring in these targeted homes have been completed in accordance with the joint monitoring plan. Lead levels were at or below the Action Levels in the first three rounds of monitoring, and copper levels have been well below the Action Levels in all four rounds of monitoring. The fourth round of monitoring showed levels that are now slightly above the Action Level for lead.
The pH adjustment treatment process has resulted in significant reductions in both lead and copper levels in the targeted homes. This process has resulted in lead levels being reduced by more than 50% from 1992 levels. The treatment has also proven to be highly effective in reducing copper levels to about one-half of the copper Action Level, and has nearly eliminated aesthetic concerns associated with copper plumbing systems, such as blue-green staining of plumbing fixtures. It appears that as a result of pH adjustment, copper is no longer a key water quality issue in the Bull Run Service Area. Although pH adjustment treatment may not consistently reduce lead levels below the lead Action Level, lead concentrations at the customers taps will continue to be far below levels found in 1992. Treatment will also be adjusted as needed to attempt to further reduce lead levels within the constraints of the current treatment process.
Nevertheless, exceedance of Action Levels functions as an alert, and the need for taking further "action". In accordance with OHD requirements, part of the action being taken is notification and education of all water customers by the Portland Water Bureau and its wholesale purveyors. Customers are notified of the Action Level exceedances, and educated on the risks of lead exposure and how to control and significantly reduce or eliminate any exposure to this source of lead in their home. In addition, customers are also informed about additional research that the Water Bureau is doing to better understand and control the specific causes of any elevated lead levels at customers taps.
This additional research includes investigation into how consistent the home lead and copper monitoring methods are. Existing lead and copper sample collection methods, while meeting the requirements of the Lead and Copper Rule, are subject to inconsistency due to variability of standing time of the water in the home's pipes, sample collection site within the home, in-home plumbing materials, and other "homeowner- or home occupant-controlled" factors. Follow-up investigations will be conducted to evaluate the influence of these factors on the resulting lead and copper monitoring results in the "Tier 1" homes.
2. Activities and Accomplishments of the HOME LEAD HAZARD REDUCTION PROGRAM component
The Home Lead Hazard Reduction Program in Brief This program was developed to:
"Reduce the risks from major lead hazards in home environments: household dust from deteriorating lead-containing paint and soil
"Prevent children from being exposed to lead hazards in the home environment
"Perform lead hazard control work and education activities in eligible homes
"Estimate the prevalence and magnitude of lead dust hazards in high-risk neighborhoods, and the characteristics of dwellings most likely to have dust lead hazards
"Evaluate the program's results to ensure that public health benefits can be measuredImplementation of the Home Lead Hazard Reduction Program
The purpose of the program is to prevent children from being exposed to lead hazards in the home environment. Primary sources of lead in the home environment are deteriorating lead-based paint causing high levels of lead dust in the home, and lead-containing soil which is tracked in from exposed soil outside the home.The program is being implemented as an AmeriCorps program called CLEARCorps (Community Lead Education and Reduction Corps). The program is "risk-based" -- it is being implemented in targeted Portland area neighborhoods in which children are likely to be at greatest risk for home lead dust exposure. Total program duration is expected to be five years.
The initial Portland CLEARCorps Team was recruited and trained in 1997 and 1998. Team members may serve up to two years. Replacement Team members continue to be recruited and trained as members terms expire. Team recruitment is city-wide, with an emphasis on recruitment from Portland's North and Northeast neighborhoods where program efforts are currently targeted. Training and development for Team members covers a variety of activities related to lead control work, but also includes personal development activities (communication skills, cultural diversity, development of personal career portfolios, personal career goal setting) and training on accessing available resources in the community and from local and regional governments. The Portland CLEARCorps office has been established, and is based in the Humboldt community.
CLEARCorps Activities and Protocols
CLEARCorps Team members perform "interim lead hazard control" activities to clean up lead sources in homes. Team members do not perform licensed lead abatement work. Assessed needs for lead abatement work are referred to Portland's HUD program (see below).
Eligibility of program participants is determined by the presence of a child with an Elevated Blood Lead Level (EBLL) in the home, presence of children under seven in the home, age of the home (built before 1950), and household income. Immediate preferences are given when a child with an EBLL is found. All homes referred to this program receive some level of service. After inspections of homes and interviews with owner/occupants are conducted, a determination is made as to whether participants are eligible for this program, and whether lead dust problems are present which can be remediated by this program.
Participants who are concluded to be eligible for this program receive a free home lead risk assessment, free child blood lead testing, education about the sources and management of lead hazards in the home (including lead in drinking water), and free in-place interim lead hazard control services by the CLEARCorps Team. Lead control services may include repair of deteriorated painted surfaces, repainting, treatment of friction surfaces, treatment of windows (especially sills and wells) and specialized cleaning. Team members make follow-up visits to check in again with the family, and to evaluate the long-term effectiveness of the program in reducing lead hazards.
For homes where HLHRP household income guidelines are exceeded, Team members provide a free walk-through visual inspection of the home, and education about the sources and management of lead hazards in the home (including lead in drinking water). If appropriate, these families also receive a list of licensed contractors certified to do lead hazard control work in the state of Oregon.
Since this program and its related components have been established, increased blood screening has identified more children with EBLLs. Consequently, CLEARCorps program work is now focused on homes having children with EBLLS. This shift in program priorities leaves potential participants who do not have children with EBLLs with limited options. Therefore, plans are being developed to provide education resources for these persons who could also be at significant risk of lead exposure. A video will be produced on lead risks in the home, procedures to control lead dust and avoid lead exposure, and referrals to resources for any extensive lead abatement services which may be needed.
What was Learned in Year 1 of the ProgramIn Year 1 (July 1997 through August 1998), the program was implemented as a "pilot program" in Portland's Humboldt neighborhood. During the pilot year, 55 homes were evaluated for lead paint and dust, and in 38 of these homes, CLEARCorps lead hazard reduction activities were conducted.
Work in the first year of this program has shown that the primary locations in the home environment where lead dust is found are window wells and sills in older housing units, deteriorating exterior home surfaces, and bare soil. Windows possibly make the greatest contribution to lead dust in the home. Therefore, work in the second year of the program is focusing on window and door treatment, specialized cleaning, education, and, if needed, interim soil controls. The CLEARCorps/AmeriCorps program can not perform work on exterior surfaces, except for porches and entryways; exterior work is referred to Portland's HUD program (see below).
Evaluation of the Program
The program contains a significant and critical evaluation component (see part III. C.). Data collected and knowledge gained in the formative "pilot" year (Year 1), are being used as a model to expand the program to other neighborhoods in the Portland Water Bureau service area, and to provide information for the design and implementation of similar programs elsewhere.
Household Dust Lead Prevalence Study
Efforts to design the Home Lead Hazard Reduction Program resulted in the realization that little, if any, information existed that systematically quantified the magnitude and nature of the actual home lead problem in the Portland service area. Therefore, a Household Dust Lead Prevalence Study was added to the program. Data collection in this epidemiological study was completed in December 1998, and analysis of the data will be completed by February 1999. The objectives of the Household Dust Lead Study are to:
Results of the study will be made available to others, thus enabling the design of similar studies, or the application of the results to analogous situations.
- estimate the prevalence and magnitude of household dust lead hazards in high-risk neighborhoods
- determine the characteristics of dwellings most likely to have dust lead hazards so that high-risk homes can be identified and residents can be recruited for participation in the HLHRP program more efficiently
- insure that program resources are targeted wisely to a problem of known magnitude
Linkage between the HLHRP and Portland's HUD program
The funding of Portland's HUD program (fall of 1998) resulted in an opportunity to establish a linkage between that program and the HLHRP. The HUD program provides for more extensive and costly "abatement" services for the occupants of eligible homes than does the HLHRP whose focus is on "interim lead hazard controls". Houses that are processed by the HLHRP are those where appropriate Ainterim control@ work costing less than $2,500 are determined. For houses requiring more extensive hazard control or abatement (greater than $2,500), a referral will be made to the HUD program for partial or full abatement, or other appropriate rehabilitation activities. Financial eligibility requirements for the HLHRP were established using HUD guidelines to insure that people needing services would receive them.
3. Activities and Accomplishments of the STAKEHOLDER INVOLVEMENT, PUBLIC EDUCATION, AND OUTREACH program component
The Stakeholder Involvement, Public Education,
and Outreach Program in Brief
This program was developed to:
"Reach stakeholders who can provide critical information about community preferences and needs
"Provide general and preventive education and widespread access to information
"Provide compliance with the Public Education and Notification Requirements of the Lead and Copper Rule
"Provide numerous opportunities for public involvementThe concentration of outreach in Year 1 has been in Multnomah County. As year two proceeds, discussions have begun to develop partnerships with Washington and Clackamas County's Health Departments. These partnerships will provide the Lead Hazard Reduction Program with opportunities for public education and outreach into at-risk neighborhoods across the Bull Run Service Area.Year 1 Activities and Accomplishments and Direction for Year In our first year, through data provided by Oregon Health Division and the Multnomah County Health Department, the program identified the Humboldt neighborhood as the pilot neighborhood. This was established by looking at the statistics for the ethnic makeup, high concentrations of children under five who tested for elevated blood levels, and history of homes built before 1958. The pilot was a success. Relationships were built with groups, including the Physicians for Social Responsibility (PSR), Portland Urban League, Screening Kids and Informing Parents (SKIP) and the African American Health Coalition. These partnerships led to free blood lead level testing for young children under the age of five in the targeted communities. This project is still in force under the partnership of the Physicians for Social Responsibility, the Urban League of Portland and Common Bond.
Through extensive outreach efforts with the CLEARCorps program, presentations were made to a number of health, environmental, day care and community centers, and agencies within the Portland area at the beginning of this program. These efforts resulted in a large number of requests for program participation in Year 1, and ongoing support for the programs as they have evolved.
Outreach staff are currently coordinating and consulting with other agencies doing outreach on lead issues, such as the County Health Departments, the Oregon Health Division, and additional community-based organizations. Collaboration efforts with immigration agencies will provide us with a more extensive outreach approach to those populations during year two. Outreach is being conducted to a number of organizations, including the Hispanic Health Services Roundtable, International Refugee Center of Oregon and the Asian Commission.
Solicitation of Formal Letters of SupportDuring year one, a consultant was hired to interview and secure formal letters of support for the Home Lead Hazard Reduction Program from seventeen community leaders. The consultant assembled a report with suggestions from the leaders on issues which the HLHRP should address, recommended program revisions and enhancements, suggestions on how to solicit and gain formal support from community leaders. It is hoped that this report might serve as a set of guidelines for others who wish to build relationships and obtain formal support from persons and agencies that have fundamental or critical connections to the success of their community-based effort.
Community Forums
The Lead Hazard Reduction Program (LHRP) has also initiated community wide public forums. The public forums will allow us the opportunity to educate a larger audience and gather important feedback on the components of the LHRP. The first public forum was held at the local Portland Cable Access public access television studios. This location provided call-in capabilities, and aired live over the government programming cable channel, 30Net. Participation was invited by use of paid newspaper ads, and by the issuing of a press release to media outlets and community stakeholders.
There will be three more public forums scheduled. The objectives are to meet the needs of continued education in the communities on the importance and effects of the program within their neighborhoods, obtain feedback on the programs and how to implement them in these communities, and provide a way to effectively solicit public comment during the 30-day public comment period of this Final Project Agreement. Press releases and paid newspaper ads will be used to publicize all Public Forums.
Members of the community also participate in the committee which provides review, oversight, and planning feedback to the Home Lead Hazard Reduction Program component on an ongoing basis. This committee will continue with community representation, but will transition to a community forum format in February 1999. This will provide more opportunities for feedback and involvement in that program from a diversity of community members.
Educational Materials
During Year one, a public information brochure on the Home Lead Hazard Reduction Program (HLHRP) Let Us Help You Reduce Your Family's Exposure to Lead was developed and printed in four languages (English, Russian, Spanish and Vietnamese).
A nine minute public education video Lead: A Community Fights An Invisible Danger , was produced and is currently being translated into Russian, Spanish and Vietnamese. The video continues to air on Public Access Channel 30-City Net and Paragon Channel 22-PAX TV.
A brochure for the Lead Hazard Reduction Program (LHRP) is also being developed and will be ready for distribution in January 1999. These publications are developed to provide information in easily understandable terms and in lay person's language.
Public Education/Notification Requirements for the Lead and Copper Rule
Outreach staff are also working with Bureau Public Information staff to ensure compliance with the Public Education and Notification Requirements of the Lead and Copper Rule. Brochures about lead and copper in drinking water are being developed, along with public notification of all customers via other mediums as specified in the Rule. Brochures include notification of any exceedances of lead Action Levels, mandatory lead-related language as specified in the Rule, information on how drinking water can be a source of lead and copper exposure, and how this exposure can be controlled and avoided.
As long as our monitoring shows we are over the lead Action Level, the Water Bureau will continue to strive to comply with customer education and notification requirements as established in the Oregon Administrative Rules for Public Water Systems.
Stakeholder Advisory Committee and the Metro-wide Educational Campaign
A Stakeholder Advisory Committee (SAC) was formally established in September, 1998 to develop a four-year Portland Metro-wide Lead Poisoning Prevention Educational Campaign. Implementation of the Campaign will begin in the Spring of 1999. The SAC consists of representatives from environmental, public health, and media groups, business and landlord associations, city bureaus, and community activists. SAC members have identified and provided advice on preferences, issues and workable solutions for the diverse communities. The Metro-wide Campaign will use a variety of approaches to educate and involve the community. It will provide education and information on control of exposure to both lead and copper from a variety of critical environmental sources.
The Metro-wide Campaign for city-wide extensive education and lead prevention outreach includes various projects. Train the Trainers will consist of a lead prevention and education workshop in four languages for community outreach providers. As a part of this project, participants will be educated on lead issues and how to communicate those messages. Participants will be encouraged to use this material in their daily client outreach. A consultant has been hired to work with Lead Hazard Reduction Program staff and SAC to develop and implement the program. Simplified Language Public Information Materials will be developed to reach a specific population consisting of parents with limited education abilities in all cultures. These projects will be implemented in the Spring of 1999.
Also as a part of the Metro-Wide Campaign, Public Service Announcements will be developed in partnership with CLEARCorps, HUD and the Portland Public School System. The information is being scheduled for presentation on culturally guided advocacy programs on television and radio. A short video will also be produced on lead risks in the home, procedures to control lead dust and avoid lead exposure, and referrals to resources for any extensive lead abatement services which may be needed. This video will provide education resources for those households whose residents may be at significant risk of lead exposure, but are not immediately eligible for the CLEARCorps program. This video will be distributed upon request to persons in the Bull Run Service Area.
Lead Summits and Community Planning Efforts
During the first year, the Water Bureau conceived and organized the first Annual Lead Summit. Until the Summit, there were no forums for organizations doing lead work in the community to share information, identify opportunities for collaboration, and begin to develop an organized community-wide effort centering on lead issues.
As a part of the commitment to establishing continuing collaboration, the Urban League of Portland took on the responsibility of developing a community driven, city-wide lead comprehensive plan. Subcommittees consisting of community members and representatives from public agencies meet frequently to work on defined tasks and strategies. The comprehensive lead plan is expected to be completed in 1999.
The Lead Summit will continue to be held annually during the month of April, which has been designated as Lead Health Month.
4. Activities and Accomplishments of the LEAD-IN-WATER TESTING PROGRAM component
The Lead-in-Water Testing Program in Brief This program was developed to:
"Provide free or low cost water testing to customers in the Bull Run Service Area who may be at significant risk from elevated levels of lead or copper in their drinking water
"Provide assistance to customers in reducing their risk to exposure from elevated levels of lead or copper in their drinking water
"Evaluate the program's results to ensure that public health benefit can be measuredThe Lead-In-Water Testing Program will be designed and developed by the Portland Water Bureau's project team, including Bureau staff, wholesale water purveyors, and consulting assistance, with the input of stakeholders. The program will be made available throughout the entire Bull Run Service Area, with outreach and marketing to customers in all of the wholesale water districts.It is anticipated that the program will include water testing for both customers expressing general interest or concern, as well as testing of targeted classes of services and customers at significant risk from highly elevated lead and/or copper levels in their drinking water. Groups of customers at special risk from lead/copper exposure (such as day-care centers and schools) will be identified, as well as classes of services most likely to have elevated lead/copper levels in their drinking water (such as housing of a certain age or with certain plumbing materials).
The program will focus on awareness, the operations related to providing the testing services, customer assistance (follow-up assistance for customers with highly elevated lead/copper levels in their drinking water), and evaluation of the overall effectiveness of the program.
The Water Bureau's project team is in the process of designing and developing this program. The concepts for this program have grown in complexity, and have resulted in a new concept which is effectively breaking some new ground in the water utility and customer service arenas. It is a program which will require significant and effective levels of stakeholder involvement. The addition of copper as a constituent of interest is a worthy program enhancement, and has also increased the complexity of the issues to be addressed. Therefore, development of the work plan has taken much longer than originally anticipated. However, this additional work will serve to allow for more feedback from a variety of stakeholders during the program development stage, and will produce an end product of higher quality.
The program development process will provide a work plan to further refine program objectives, provide a process for targeting the program, and produce an implementation plan. The final implementation plan should be completed by late Spring of 1999. Staging and start-up of the program is expected to begin by Summer of 1999.
F. PROBLEMS AND BARRIERS THE COMPONENTS OF THE LEAD HAZARD REDUCTION PROGRAM ARE INTENDED TO ADDRESS
Problems and barriers, and how they will be addressed
are described below by consideration of each component of the Lead Hazard Reduction Program.Problems and Barriers the WATER TREATMENT AND WATER QUALITY MONITORING program component is Intended to Address:" Disinfected Bull Run water tends to be corrosive, and can leach lead and copper from water left standing in plumbing systems. The 1992 Lead and Copper Rule monitoring showed exceedances of the Action Level for lead, so there was a need for the Water Bureau to take definitive action, conduct research, and begin some level of corrosion control.
Research was conducted, and treatment improvements were put in place. The pH of disinfected Bull Run water was raised to decrease its corrosivity. The pH adjustment changes the water from lightly acidic (about pH 6.5) to slightly alkaline (about pH 7.5). This reduces the degree to which common household plumbing material such as copper, brass, and lead from lead-based solder is dissolved into water standing in pipes.Monitoring of targeted homes before treatment in 1992 found lead levels greater than the lead Action Level (AL) identified in the Lead and Copper Rule. 1992 copper levels were at or slightly above the copper AL. The pH adjustment is intended to significantly reduce both lead and copper levels. Although this treatment may not consistently reduce lead levels below the lead AL, lead concentrations at the customers taps are far below levels found in 1992. In addition, this treatment has successfully reduced copper levels to well below the copper AL, and has nearly eliminated aesthetic concerns associated with copper plumbing systems, such as blue-green staining of plumbing fixtures.
Additional research will be conducted into how consistent the home lead and copper monitoring methods are. Sample collection methods meet the requirements of the Lead anc Copper Rule, but are subject to inconsistency due to variability of standing time of the water in the home's pipes, sample collection site within the home, in-home plumbing materials, and other homeowner- or home occupant-controlled factors. Follow-up investigations will be conducted to evaluate the influence of these factors on the lead and copper monitoring results in Tier 1" homes.
"" Performing high levels of corrosion treatment and dramatically increasing the pH of Bull Run water would have produced higher levels of potentially toxic by-products of chlorine disinfection than those currently observed. These levels would have been have been unacceptable from a public health standpoint, and could have resulted in noncompliance with drinking water standards for those compounds. Consequently, there was a need for a treatment strategy that balanced these conflicting treatment and regulatory needs without dramatically altering water quality.Limited corrosion control treatment has kept the levels of disinfection by-products at low levels, and maintained compliance with drinking water regulations for these compounds. The chemical nature of Portland's water has not been dramatically altered, and regulatory needs are continuing to be met.""" Water customers in the Portland area have consistently endorsed and appreciated the chemical nature of the Bull Run water, and routinely praise the low mineral content of this soft, natural water that requires minimal chemical addition to assure compliance with drinking water regulations. Several industries (such as silicon wafer and computer component manufacturers, and other high-tech industries) located in the Portland area based on the chemical nature of Bull Run water. In 1992, industrial and residential customers expressed a negative perceived quality of their tap water if the chemistry of Bull Run water were altered.Portland's corrosion control treatment strategy was selected based on input from industries and residents of the community, in an attempt to BALANCE the conflicting treatment and regulatory needs without dramatically altering water quality. The chemical nature of Portland's water has not been dramatically altered, and regulatory needs are continuing to be met.""" In some arenas there is an erroneous belief that drinking water is a person's primary source of exposure to lead and copper, and that all actions to reduce exposure should be focused there. This belief can exist within the medical community, among members of the general public, in public agencies, and elsewhere. Public health data does not support this assumption.By providing limited corrosion control treatment, the Lead Hazard Reduction Program effectively necessitates that the Water Bureau and the community continue to pay greater attention to the most prevalent sources of lead exposure in the community, and to the efforts where the greatest public health benefit can be achieved.Problems and Barriers the HOME LEAD HAZARD REDUCTION PROGRAM component is Intended to Address:" When this program began, there was a critical lack of resources for addressing the problems of children with Elevated Blood Lead Levels (EBLLs), and of lead dust and paint in home environments. There was also a belief that remediation of lead problems was prohibitively expensive.Current and ongoing work with Physicians for Social Responsibility, the Urban League of Portland, and Common Bond is providing resources to ensure that low-income children receive free blood lead testing.Through this program, controls for lead sources related to paint, soil, and dust are provided. The program does lead hazard control work for less than $2,500 per unit. This work is not prohibitively expensive, and often includes extensive window repair work, which directly addresses one of the primary locations in the home environment where lead dust is commonly found. Other low cost efforts with a large return include education on ways to control lead hazards. These controls cost residents little or nothing, save the time and cost of cleaning supplies.
" The federal Residential Lead-based Paint Hazard Reduction Act was amended in 1992 by the addition of a tenth chapter. One of the changes found in Chapter X (or Title X, as it is more commonly known) requires that all known lead-based paint or lead-based paint hazards in housing units build before 1978 be disclosed by the owner upon sale or lease of property. This Disclosure Rule has resulted in an increased awareness for these lead issues with members of the general public.Program staff serve as resources for the general public in answering a wide variety of lead-related questions, including questions about the Title X Disclosure Rule. Information on how to contact Outreach staff and the CLEARCorps office are provided in program brochures and during public presentations. The Title X Disclosure Rule (along with much more information on other lead-related issues) is also addressed in a telephone information line through The Oregonian newspaper which is the state's most widely circulated newspaper. These information phone lines are co-sponsored by the HLHRP and other community organizations through a partnership called Coalition for a Lead Safe Portland." There is a general lack of knowledge and awareness regarding specific sources of lead in the environment, a person's risk of exposure to each, and how lead hazards can be controlled.Education of community members is an important part of the HLHRP. Team members conduct one-on-one education activities with program participants directly in their homes on where lead exists in their environment (including drinking water sources), the relative risk from these sources of lead, and how lead hazards can be controlled. Written information is provided, along with hands-on training on how to control lead hazards in the home. HLHRP staff and CLEARCorps Team members have also given presentations at community group meetings and other venues." There is a belief that lead is an outdoor problem, and not an indoor problem." There is a lack of federal or state legislation to effectively manage lead issues.The CLEARCorps program's primary focus is on control of lead-containing dust in the home. However, participants are also educated on areas on the outside of homes which may contribute lead to their environment, such as deteriorating lead-based paint and large amounts of exposed lead-containing soil. Team members educate participants on the significant risk from lead originating in these locations, and provide any needed referrals to the Portland HUD Lead Hazard Control Program.Legislative initiatives have been identified as a critical need by the Comprehensive Lead Planning efforts led by the Portland Urban League. HLHRP staff actively participate in these efforts, which focus on developing a comprehensive strategy for the Portland area on lead issues in general. Of special concern is the need for increasing resources for children with elevated blood lead levels, but there is also a wide range of lead legislation which would be beneficial. HLHRP and Outreach staff are working with other community groups and elected representatives to encourage and provide input into needed lead legislation." There was a lack of knowledge regarding how to control lead problems in homes, the extent to which such lead problems could be reduced, and the resulting amount of public health benefit that could be achieved and quantified.Work in the first year of this program has shown that windows in older housing units, and bare lead-containing soil can be major contributors to lead dust in the home, and that lead levels in these locations can be reduced and controlled. CLEARCorps program work now focuses on window and door treatment, specialized cleaning, and, if needed, interim soil controls.Participants in the program are contacted one and three months after the CLEARCorps work is completed to see if lead hazard controls are being maintained, and to reinforce the educational messages. At six months, another visit is made to collect samples and determine if lead dust is still below desired levels. Child blood lead screening is completed before and after work is completed, and at six months if necessary.
Data collected in this program will be shared with others, and will be used to determine the degree to which lead in the participants homes is actually reduced, and how much public health benefit has been achieved. The impact of the program will be calculated, including the degree to which housing units have been made lead safer , and how elevated blood lead levels in children have been prevented or reduced.
" When this program was begun, there was no systematic knowledge about the magnitude and distribution of the home lead problems in the Portland area. Information is being gathered which may indicate that home lead problems may be larger and more widespread than earlier predicted. It will therefore be a challenge to manage the limited resources of this program to address an increasing workload, preserve the risk-based objectives, and also focus on prevention. A balance between the work in the homes, the need for outreach and education, and the expectations that are created in the community will be important.Over a 3-month period, the cross-sectional Household Dust Lead Prevalence Study will analyze composite dust samples collected using the HUD screening procedure in 125 dwellings built in 1930 or earlier, and in which children under the age of seven live. Dwellings are selected randomly from within 11 Portland Zip Codes that contain the highest concentrations of older housing. The study will estimate the prevalence and magnitude of household lead problems in the Portland area, and also determine the characteristics of dwellings most likely to have problems.Using study results, the HLHRP work will continue to be prioritized by focusing efforts where they are needed most. Program staff are also looking at alternative ways to do work in the homes and provide education, so that limited resources can be used most effectively.
There are more than 100,000 housing units built before 1950 in Multnomah County alone, and 40,000 are rental units. So, there are more housing units at risk than this program, or any single program, will ever be able to address. The Comprehensive Lead Planning effort led by the Portland Urban League is devising strategies to help address these long-range problems.
" Getting landlords involved in the program and addressing those issues has proven to be complicated.The program recognizes that rental properties often present a larger problem for children at risk, than do owner-occupied units. Outreach is being conducted to landlords, but especially those who provide housing for low-income families. Outreach will also be conducted with landlord and tenant associations, so that owners can be encouraged to take part in this program, and be educated on program benefits.""" Ways must also be found to expand this program to the entire Bull Run Service area, which includes significant areas of Clackamas and Washington counties. Planning work must be undertaken in partnership with the Health Departments in those counties and the Oregon Health Division Lead programs. Most critically, as the program evolves it must continue to be a program that is risk-based and directs the program efforts where they are needed most.Planning work with Clackamas and Washington counties is beginning, and will address the issues defined above. This program will begin to expand into additional high-risk neighborhoods in the Bull Run Service Area in Year 3 (July 1999 - June 2000).
Problems and Barriers the STAKEHOLDER INVOLVEMENT, PUBLIC EDUCATION, AND OUTREACH program component is Intended to Address:" There is a general lack of knowledge, or erroneous knowledge, about lead issues in the community, and sometimes within agencies. There is a myth that lead is not a problem in Portland, or at least not in my home . In general, the community has not been made aware of the actual sources of lead in their environment, and their relative risk of exposure to each. There also seems to be a general mistrust of government sources of information, and some of this information is characterized as incomprehensible.Educational materials will be provided by a variety of means, including brochures in lay person's language, simplified language text, videos, and cable television broadcasts. All materials will be translated into other languages to meet the needs of the diverse populations within the program's target areas.Trust within the community is being addressed by the formation of many partnerships with organizations that are well established within the various neighborhoods. Partnership efforts are focused on those community groups that address environmental, public health, and community stability issues.
" Lead problems in children are often asymptomatic and are not easily diagnosed. Once identified, there is no quick and easy technological fix for an Elevated Blood Lead Level. It is a challenge to raise lead issues on the priority lists of members of the medical community.Materials on screening of children and prevention of lead exposure are being developed for distribution to the medical community. Information will be provided to physicians and clinics, but also to workers in other facilities (day care, etc) who have daily contact with young children and parents.""" People experience a wide variety of competing problems in their every day lives, and this can make it difficult for individuals to become concerned about lead issues.The Train the Trainers program will give us access to providers in the targeted areas who deliver services to clients directly within their homes. Because of the relationship these trainers have established with their clients, they will be best able to address language issues, understand competing problems, and reach and educate the people who can most benefit from this information.""" It is a challenge to train people in providing accurate and complete information in a way that clearly states the issues, without understating the problem and its solutions, and also without unduly raising alarm.These issues are being addressed in the Train the Trainers program, and in training for other education messages that are provided by program staff, the CLEARCorps, etc.""" This program must reach a great diversity of populations and communities in the Portland area. Different messages and methods of communication are needed for these diverse groups and populations. It is a challenge to identify existing community groups and other venues that allow the program to provide the information where it is needed most --- to parents of children. Some communities, such as migrant and homeless persons, are isolated from certain forms of communication which are easily accessible and used by other communities. In some communities, there is a cultural reluctance to change traditions and practices that are related to lead exposure. Members of communities also possess a wide variety of learning abilities.Ongoing outreach work is getting a wide variety of community groups, advocates, and members of the general public involved as stakeholders with an interest in the methods and outcomes of the Lead Hazard Reduction Program. These issues are being addressed in the areas and groups to which outreach is conducted, the types of materials that are being provided, language translations of materials, holding public forums, and the resulting benefits from the Train the Trainers program. In addition, stakeholder groups and participants in the Public Forums are routinely asked to review the work that is being conducted, and to provide feedback so that improvements can be made." This program requires organizations and communities with a wide variety of different cultures to develop partnerships and work together.Problems and Barriers the LEAD-IN-WATER TESTING PROGRAM component is Intended to Address:Establishing bridges to communication and good working relationships is facilitated and encouraged by Outreach staff. Program staff actively develop numerous partnerships and enlist community organizations and groups assistance in performing education and outreach. Convening the Lead Summit and the comprehensive lead planning effort that has come out of it, has also furthered the partnerships and working relationships.""" Any exceedances of the Lead and Copper Rule Action Levels for lead and copper also require the Water Bureau and its wholesale purveyors to provide notification and to distribute mandatory language from the EPA about lead and copper in drinking water to ALL water system customers and by a variety of communication methods. Compliance with these requirements is a complex task.The Outreach program is providing additional opportunities for distribution of these messages beyond the traditional practice of mailing bill stuffers. Information will be provided as part of the metro-wide campaign, public forums and presentations, and to the wide variety of audiences identified as being impacted by lead and copper issues.""" Water utilities have not historically undertaken this kind of program. Therefore it is not a simple matter to lay the groundwork and support for such a program.The very nature of the Outreach program, and the endorsement and resources the Lead Hazard Reduction Program has received from the Water Bureau and the Portland City Council provide the basis and support for a successful effort." The Water Treatment and Water Quality Monitoring Program component provides significant reduction of the ability of Portland's water to leach lead and copper from household plumbing. However, there are still households and facilities with elevated levels of lead and copper in their drinking water. Customers need determination of whether there is a problem in their home or facility, education on ways to avoid such lead and copper exposure, and assistance in identifying and reducing the sources of lead and copper in their plumbing system.G. WHY THE LEAD HAZARD REDUCTION PROGRAM ISAddressing these problems summarizes the very objectives of the Lead-in-Water Testing Program. The Water Bureau's project team, including Bureau staff, wholesale customers, and consulting assistance, with the input of stakeholders, will design and develop an effective program which addresses these objectives. The Bureau will use the services of consultants with extensive experience in a wide variety of drinking water issues, including lead, copper, and corrosion. The Bureau will also utilize the services of consultants with expertise in stakeholder involvement and outreach, and marketing. Opportunities for community participation and feedback will be provided as the program is developed and implemented. The program will also work with Lead Hazard Reduction Program Outreach staff to integrate Lead-in-Water Program marketing, education, and stakeholder efforts with ongoing efforts.""" There are a number of challenging issues for the Lead-in-Water Testing Program:- The program will be a challenge to design and implement because it is difficult to determine exactly where the problems exist in the Bull Run Service area. It is possible for problems to be found in almost any home or facility, and the locations of existing problems are not known. Problems can not be located by focusing on specifically defined geographical areas, or by using typical home characteristics as was done in the Home Lead Hazard Reduction Program. Even though lead solder has been banned, it could still be in use in some homes and facilities. People have also been observed to use plumbing for electrical grounding, which produces the conditions for a localized corrosion problem.""" It is likely that many residential customers will take advantage of the opportunity to find and reduce lead and copper problems in their drinking water. But there may be some reluctance on the part of schools, landlords and others to do the same because of fear of potential liability concerns.
- Lead-containing plumbing fixtures are still available, and still in use. Many customers do not know how to find out whether plumbing fixtures contain lead, and do not know that it is important to do so. Some customers may not be aware that lead solder was banned in Oregon in 1984, or that their home may still have plumbing with lead solder.
- Most customers are not aware of simple measures to avoid potential lead and copper exposure in their water by running the tap to flush standing water from their system, and using only fresh cold water for drinking and cooking.
- As in the other Lead Hazard Reduction Program components, this program must also use a public health approach which focuses efforts where the risks of lead and copper exposure are the greatest. Because of the problems described above, it will be difficult to determine exactly who will be targeted for the program, and how the outreach will be designed and implemented to effectively reach those persons.
- Resources are available for the program, but they are necessarily limited and must be prioritized. The demands for water testing and follow-up assistance are expected to be large, and will need to be effectively managed. It will be important to avoid excess workloads, and perceptions of inadequate service to the customer.All of these issues will be addressed in the program design and development work by the Water Bureau's project team, which includes Bureau staff, wholesale water purveyors, and consulting assistance, with the input of stakeholders. The Water Bureau project team will develop plans to best to address these issues, and will also seek feedback from the community. Work during all phases of the program will be monitored to ensure that efforts are focused where they are needed most.School administrations, landlords and landlord-tenant associations will be educated on lead and copper in drinking issues, and how problems in their facilities can be accurately identified and remediated. Schools and landlords will be encouraged to participate in the program, and will be educated on understanding of the liability issues, and how they can be addressed.
BENEFICIAL TO PROJECT SPONSORS AND CO-SPONSORS, THE ENVIRONMENT, AND OTHER AFFECTED PARTIESWhy the program is beneficial to Project Sponsors, the environment, and other affected parties is described below by consideration of each component of the Lead Hazard Reduction Program.
Why the WATER TREATMENT AND WATER QUALITY MONITORING program component is beneficial to:
Project Sponsors and Co-sponsors:Why the HOME LEAD HAZARD REDUCTION PROGRAM component is beneficial to:" The program produces significantly lower lead and copper levels at the customers taps. This, in turn, results in secondary benefits such as increased public trust, enhanced customer satisfaction, and fewer customer complaints related to copper staining of plumbing fixtures.The Environment:
" The program provides a simplified treatment process, which helps assure reliability of performance, consistency of water quality after treatment, reduced operation and maintenance requirements, and improved on-site safety for employees.
" The program provides a regional solution which avoids the need for duplication. This program provides corrosion treatment for the entire Bull Run Service Area, thus avoiding the need for construction of new treatment systems for each wholesale water purveyor on the Bull Run system. This also assures adequate treatment for those systems that otherwise lack the resources or technical skill needed to implement and operate such treatment systems.
" The program provides a reduced risk of the secondary impacts of more aggressive control treatment. By avoiding dramatic changes in treated water quality, there is a much lower risk of red water complaints, scaling of pipes, increased formation of by-products to disinfection, generation of adverse tastes and odors, or biological regrowth." This treatment program produces lower copper levels in sewage. Treatment has resulted in a dramatic reduction in copper loadings at wastewater treatment plants, with accompanying reductions in subsequent copper discharges to the environment.Other Affected Parties:
" The program results in reduced consumption and production of chemicals. By implementing only limited corrosion control treatment, fewer chemicals are needed. This, in turn, reduces the environmental impacts associated with chemical production, transport, potential spills, and disposal of wastes." Community preference is accommodated with this program. The community's preference for minimal use of chemical additives or modification of their drinking water is respected.
" Impacts on businesses and industries are minimized. Large employers in the community that rely on large quantities of water are not adversely impacted by significant changes in water quality that would have otherwise been required.
" The program results in increased lifetimes of copper plumbing systems. Decreased corrosion rates will undoubtedly result in fewer corrosion-related copper pipe failures. This provides indirect benefits of reduced costs to residential and commercial customers for piping repair, maintenance, and replacement.Project Sponsors and Co-sponsors:
The Environment:" The program is a demonstration of how government agencies can work together with community groups and concerned individuals to understand and address a critical public issue.
" The program provides resources to address an important public health issue in a creative and cost effective manner.
" Information is being collected that will be useful for region-wide strategic planning of education and hazard reduction efforts, and for grant writing to obtain resources for future programs.
" The Household Lead Dust Prevalence Study characterizes dwellings and neighborhoods most likely to have household dust lead hazards so that:
- education and hazard reduction work can be targeted effectively to the populations
or neighborhoods most likely to be affected, and
- blood lead screening efforts can be targeted." HLHRP/CLEARCorps is creating a pool of lead-safer housing stock by addressing the problem of household lead dust, which in turns benefits residents in those units.Other Affected Parties:
" Multnomah County ranks forty-eighth out of over 3,000 counties in America in terms of potential lead problems affecting children in low-income living situations. Children who do not have elevated blood lead levels or who are not exposed to elevated levels of lead in their living environments have one less environmental toxin that can affect their health and intellectual development." Participating community members benefit because there is a reduction in the risk of exposure to lead for their children during critical developmental years.
" Money not spent dealing with elevated blood lead levels can be used to address other community health concerns.
" HLHRP also works with a linkage to Portland's HUD Program to provide additional resources and benefit for community members who need those services.
" Information on the magnitude and severity of household lead dust hazards can be used by communities to target education efforts.
Why the STAKEHOLDER INVOLVEMENT, PUBLIC EDUCATION, AND OUTREACH program component is beneficial to:Project Sponsors and Co-sponsors:
" The program provides a community that is better informed on important issues and the roles they play in them.The Environment:
" The program provides people who are involved in defining and implementing effective solutions to the problems within their own communities.
" The program helps to establish community partnerships that can be used for the design and implementation of other programs." The program provides the community with the necessary tools and alternatives to conduct their daily lives in a healthy and safe manner with respect to lead and copper issues.Other Affected Parties:" The program fosters community partnerships between organizations and individuals who focus on environmental issues.
" The program provides many opportunities for participation by individual citizens.
Why the LEAD-IN-WATER TESTING PROGRAM component is beneficial to:Project Sponsors and Co-sponsors:
" The program expands free or low cost lead and copper water testing services to the entire Bull Run Service area.The Environment:" The program identifies customers who are most at risk from exposure to lead and copper in drinking water, and provides assistance to reduce that exposure.Other Affected Parties:
" The program provides greater reduction in exposure to lead and copper and more public health benefit than water treatment alone." The program benefits the community by expanding free or low cost water testing services to the entire Bull Run Service area.
" The program provides resources and solutions to lead and copper in drinking water problems that are tailored to meet the needs of the individual customer or facility.
H. WHAT WILL OCCUR WITH THE LEAD HAZARD REDUCTION
PROGRAM, COMPARED WITH WHAT WOULD OCCUR IF THE PROGRAM WERE NOT IMPLEMENTEDComparisons are described below by stating what will occur (and what IS occurring) with the Lead Hazard Reduction Program, compared with
- what would occur if the program were not implemented.
The Oregon Health Division (EPA's drinking water regulatory authority in Oregon) approved the program as an acceptable alternative strategy for optimal corrosion control treatment for lead and copper at the customer taps throughout the regional distribution system. Lead and copper levels in drinking water have been significantly reduced. The program does not result in excess production of Disinfectant By-Products and the need to manage them. Water quality and water chemistry have not been dramatically altered and the perceived changes in water quality to customers have been minimized.- The Portland Water Bureau would have treated Bull Run water to increase the pH to 9.5 and the alkalinity to 20-25. Lead and copper levels in drinking water would be optimized and at very low levels.With the approved alternative for compliance with the Lead and Copper Rule, the Water Bureau is implementing a risk-based, multi-media strategy for managing environmental exposure to lead and copper from a variety of sources. The program will measure and evaluate the resulting health benefits, and is expected to provide a greater health benefit than that provided by optimal water treatment as stipulated in the Lead and Copper Rule. There will be an increased level of knowledge about the efficacy of reduction of lead hazards and resulting public health benefits.
- The Portland Water Bureau would likely be exceeding Maximum Contaminant Levels (MCLs) for some Disinfectant By-Products, and would be managing that outcome, including large capital outlays for installation of additional water treatment facilities, public information and education.
- Portland Water Bureau residential customers would be reacting in a variety of ways to perceived changes in water quality, possibly including increased use of bottled water, point-of-use water treatment devices, and losing trust in the water utility.
- Portland Water Bureau industrial customers would be reacting in a variety of ways to changes in water chemistry, including expending resources to treat tap water, or relocating from the Portland area, or deciding not to establish new businesses and facilities in Portland in the first place.- There would be less public health benefit for overall lead exposure, since the actions taken would focus only on drinking water and not other environmental sources of lead.Resources have been redirected to address children with Elevated Blood Lead Levels (EBLLs), and perform lead hazard control work in homes with elevated lead dust levels. More children with EBLLs are being diagnosed and brought into the programs. A need for more blood lead screening has been identified. There is a study which will estimate the magnitude of the lead dust problem in homes in the Portland area.
- There would be a continuing lack of knowledge regarding the efficacy of reduction of lead hazards and resulting public health benefits.- Fewer children with EBLLs would be diagnosed.Community support for effective solutions for lead and copper problems is significant and growing. Awareness of sources of lead in the environment and how they can be controlled is increasing.
- There would be a continuing lack of resources to effectively respond to children with EBLLs.
- Residents of homes in the Bull Run Service area would have lead dust problems of some relatively high magnitude, and fewer resources to remediate these problems.
- Residents of homes would be less aware of simple home lead control measures that could be undertaken, and fewer of these measures would be undertaken.
- There would possibly be less impetus to develop a statewide blood lead screening plan.
- There would be no systematic information on the magnitude of the lead dust problem in homes in the Portland area.- There would be less community support around lead and copper issues, and the momentum and benefits created by current outreach, stakeholder involvement, and partnership efforts would be missing, or at least less of a reality.Treatment is significantly reducing, but not minimizing, the ability of treated water to leach lead and copper from household plumbing. Locations with elevated levels of lead and copper in drinking water will be targeted, and specific causes will be identified. Customers will be educated on lead-containing plumbing fixtures, and related leaching potentials and negative health effects. Lead and copper in drinking water problems in schools and day care facilities will be significantly diagnosed and remediated. Customers will have increased free or low cost services for lead and copper in water testing, and increased service for follow-up assistance when problems are identified. Customers will be more aware of available services for water testing and follow-up assistance.
- There would be less awareness of sources of lead in the environment and how they can be controlled.- There would be fewer and less effective resources to target locations with elevated levels of lead and copper in drinking water and identify the causes.
- There would be less available knowledge on lead- and copper-containing plumbing fixtures, and the effects from them.
- Lead and copper in drinking water would be significantly reduced, but any problems in specific homes, schools and day care facilities would receive less emphasis, diagnosis, and remediation.
- Customers would have fewer on nonexistent free or low cost services for lead and copper in water testing.
- Customers would have very limited services for follow-up assistance when lead or copper in drinking water were found to be a problem.
- Customers would be less aware of any available services for water testing and follow-up assistance.
I. HOW THE LEAD HAZARD REDUCTION PROGRAM ADDRESSES XL CRITERIAIn 1997, Project Sponsors submitted a proposal to EPA for review by Agency staff familiar with the environmental or public health problem addressed by the project. In this review EPA looked for a commitment to several criteria. Particular attention is paid to how the programs address the criteria which are considered most important and critical for success: superior environmental performance and effective stakeholder involvement. The Agency looked for evidence that implementation of the project would produce an environmental or public health outcome superior to what would have resulted had the project not been implemented and had flexibility not been granted by EPA. The EPA also looked for a commitment to participatory community planning and consensus-building as well as stakeholder involvement and support.
In March 1998, the EPA determined that the Lead Hazard Reduction Program met the Project XL criteria, and offered the Portland Water Bureau the opportunity to negotiate a Final Project Agreement (FPA) for acceptance as an EPA Project XL for Communities program. In April 1998, the Portland Water Bureau accepted EPA's offer, and began the process to develop this Final Project Agreement.
How each of the XL criteria are addressed is described below.
1. ENVIRONMENTAL RESULTS
" The Water Treatment and Water Quality Monitoring Program:Without implementation of the Lead Hazard Reduction Program, none of the environmental results below would have been realized, or realized to a significant extent:- Provides significantly reduced levels of lead and copper in drinking water throughout the Bull Run Service Area.
- Provides reduced levels of copper discharged to the environment by reducing copper levels in sewage.
- Will provide follow-up investigation of monitoring results to help identify homeowner- and home occupant-controlled factors that result in elevated lead and copper levels at taps in targeted homes.
" The Home Lead Hazard Reduction Program will use interim lead hazard control methods and in-home education to demonstrate that:- Household lead dust levels will be significantly lower (approximately 85%) in housing units after receiving services.""" The Household Lead Dust Prevalence Study will:
- Residents can be trained to maintain household dust lead levels below HUD action levels over time in a majority of the housing units receiving services.- Provide quantitative information on the prevalence of household lead dust hazards in the sample studied.""" The Lead-in-Water Testing Program is in the design phase, so while significant environmental results are expected, it is difficult to predict and quantify them at this time. The Lead-in-Water Testing Program will:
- Use study data to estimate the prevalence of lead dust hazards in housing built before 1931 in the Bull Run Service Area.- Provide direct intervention with at risk customers throughout the Bull Run Service Area.
- Identify specific locations with elevated lead and copper levels at the tap, including schools and day care facilities.
- Provide information on typical causes of elevated lead and copper levels at the tap.
- Provide information on remediation that would be needed to reduce exposure to lead and copper in drinking water.
2. STAKEHOLDER INVOLVEMENT, SUPPORT, AND CAPACITY FOR COMMUNITY PARTICIPATIONStakeholder Involvement Efforts and Program Direction
Selection of the existing corrosion control treatment process included stakeholder involvement and community participation. Activities included public presentations to the Bureau's Water Quality Advisory Committee, public meetings with water quality-dependent industrial and commercial users, community meetings with the general public, and presentations to wholesale water customers. In 1992, industrial and residential customers expressed a negative perceived quality of their tap water if the chemistry of Bull Run water were altered. They expressed their preference for a water of consistent quality, and encouraged the Water Bureau to avoid a dramatic change in water quality.
The Lead Hazard Reduction Program (LHRP) as a comprehensive program which used a combination of approaches was conceptualized by key stakeholders from the Multnomah County Health Department, Portland Water Bureau, consultants to the Water Bureau, and the Oregon Health Division. Subsequent design and implementation of the Home Lead Hazard Reduction Program (HLHRP) component then continued with ongoing efforts by these key stakeholders, but also with involvement of members of the community. The HLHRP is also informed by feedback from the U.S. Department of Housing and Urban Development programs, and other members of the national public health community. As HLHRP development work began, it became clear that a more defined and comprehensive strategy for public participation would be beneficial to both the Lead Hazard Reduction Program, and to the XL for Communities effort. This resulted in the formation of the Stakeholder Involvement, Public Education, and Outreach program component of the LHRP.
Members of the community also participate in the committee which provides program review, oversight, and planning feedback to the HLHRP on an ongoing basis. This committee will continue with community representation, but will transition to a community forum format in February 1999. This will provide more opportunities for feedback and involvement from a diversity of community members.
The goal of the Stakeholder Involvement, Public Education, and Outreach program is a metro community whose members have a good knowledge of the sources, effects, and control of lead and copper hazards in their home environments, and a metro community whose members are involved in shaping the Lead Hazard Reduction Program to meet their needs. Outreach Program efforts work by developing relationships and partnerships with community groups and individuals, and also by providing numerous opportunities for feedback and involvement by community members. For a more detailed description of program activities and accomplishments, refer to part II. E. 3.
At the beginning of the HLHRP, Outreach program staff and CLEARCorps staff made a number of presentations to health, environmental, day care and community centers, and agencies in the Portland area. These efforts were successful in recruiting program participants and building community support for the program.
Outreach Program staff identify the key organizations, agencies, and individuals in the community who focus their efforts on lead issues or have special interests in them. Ongoing relationships are developed with these stakeholders. Where appropriate, partnerships are developed to further specific Lead Hazard Reduction Program objectives. These relationships have also resulted in other activities, such as the Lead Summit which was convened because of the perceived need for a forum to share information, identify opportunities for collaboration, and develop an organized community-wide effort on lead issues.
Specific partnerships have included Physicians for Social Responsibility, Screening Kids Informing Parents, The Urban League of Portland, and Common Bond for providing free blood lead level testing for low-income children; and formation of the Stakeholder Advisory Committee to implement the Portland metro-wide Lead Poisoning Prevention Educational Campaign. Partnerships are being developed with immigration advocacy organizations, the Asian Commission, and others to expand outreach in the second year of the program. Relationships and partnerships will continue to be developed as program needs and opportunities are identified.
Appendix 1 is a listing of the organizations and advocates who are stakeholders involved in the Lead Hazard Reduction Program efforts. This list includes those who have been involved in the Oversight, Review and Planning process for the Home Lead Hazard Reduction Program, provided letters of support, participated in the Lead Summit, been involved in partnerships for the program efforts, and those who participate as stakeholders in the XL for Communities project.
Community-wide public forums are being held to provide information on the Lead Hazard Reduction Program, and to provide easy and accessible opportunities for a wide range of stakeholders to contribute feedback and become more involved. Forum participants are encouraged to provide feedback to allow these lead programs to be shaped to meet the needs of their community.
Paid newspaper ads and press releases are used to announce public forums. Newspaper ads are placed in all major and community papers in the Portland area. Press releases are distributed to the newspapers, in addition to TV and radio stations, and the list of stakeholders.
The Water Treatment and Water Quality Monitoring program component will conduct follow-up investigations of the monitoring program for Tier 1 homes. This will provide input to the Outreach program by identifying home occupant-controlled factors that may contribute to elevated lead and copper levels (such as faucet type, critical standing times, flushing practices, electrical grounding, etc.). The Outreach program will educate customers on how these occupant-controlled factors can affect their drinking water quality and potential exposure to lead.
Stakeholder involvement for the Lead-in-Water Testing Program will link with the ongoing Lead Hazard Reduction Program Outreach efforts. The Water Bureau's wholesale water providers and the Oregon Health Division Drinking Water Section will also be extensively involved. As with other components of Portland's LHRP, the Lead-in-Water Testing Program will inform the community stakeholders, and provide opportunities to receive their feedback. Stakeholders will be invited to participate to assist the program in implementing the best methods for reaching the targeted populations and facilities such as schools, day care facilities, and landlord-tenant associations.
XL for Communities Stakeholder Involvement Process
Outreach for the XL for Communities efforts included bringing in stakeholders at the regional and national levels, enlarging the list of stakeholders to include persons and agencies who focused on drinking water public health and water utility issues, and invitations to stakeholders to place themselves within the role of Direct Participants, Commentors, or General Public stakeholders. XL stakeholder categories are explained in Appendix 2. Outreach and invitations to participate were extended to members of the National Environmental Justice Advisory Council (NEJAC), members of the Governor's Environmental Justice Advisory Board in Oregon (GEJAB), the National Resource Defense Council (NRDC; Erik Olson), the Alliance to End Childhood Lead Poisoning (Don Ryan), managers of Portland's wholesale water systems, and community stakeholders who were already involved in the Home Lead Hazard Reduction Program and Outreach Program efforts. Invitations to participate as XL stakeholders are also extended via public forums, paid advertisements, and web sites.
Participants in Public Forums are also invited to become more involved by reviewing the Lead Hazard Reduction Program components as they are designed and implemented, and becoming stakeholders in the Project XL for Communities effort.
Details on:
are contained in part IV. J. of this document.
- how to provide feedback on this document and the Lead Hazard Reduction Program,
- how to receive information on the Lead Hazard Reduction Program,
- who to contact to get more involved in the community or as an XL stakeholder, and
- signatories to this document
3. ECONOMIC OPPORTUNITY
4. FEASIBILITY
- Use of pH adjustment water treatment has minimized the financial impact on industrial and water quality sensitive users by minimizing their need to demineralize the water prior to using it. This has helped to maintain Portland's Bull Run water as a desirable feature in attracting future industrial growth and employment opportunities in the region.
- CLEARCorps Team members who successfully complete 1700 hours of service receive a $4725 award to be used for further education or vocational training, or to pay existing educationally incurred debt.
- Approximately 20% of CLEARCorps Team members time is spent on personal development, including career counseling, resume writing and college level course work.
- CLEARCops Team members receive training to become certified and licensed as lead abatement workers in Oregon, and also receive 1-2 years on the job experience as a result of their CLEARCorps service. Graduated Team members are marketable resources for contractors looking for qualified lead abatement workers.
- For the Household Lead Dust Prevalence Study, recruitment of participants, and collection of dust samples was contracted to local businesses.
- LHR Outreach staff work with the CLEARCorps Team supervisor to help create job opportunities for CLEARCorps Team members after their term of service.
- If demand forewater testing in the Lead-in-Water Testing Program becomes larger than what is manageable by the Water Bureau's Lab, the testing and analysis will be outsourced, or customers will be referred to labs in the private sector.
- The Lead-in-Water Testing Program will provide follow-up assistance to homes and facilities with elevated levels of lead and copper in their drinking water, but will not be able to provide resources for re-plumbing projects. Customers will be referred to private plumbing contractors.
- Lead-in-Water Testing Program work will increase the demand for low-lead and lead-free plumbing fixtures.
Summary of the Water Bureau's Lead Hazard Reduction Program Budget:
- The existing pH adjustment water treatment process has already demonstrated that it can result in dramatic reductions in lead and copper levels at customers taps. Both lead and copper levels at the tap are now less than one-half of what they were prior to the start of pH adjustment in 1992.
- Three of the four Lead Hazard Reduction Programs have been in place for more than a year, and are demonstrating success in meeting their stated objectives.
- Technical capabilities begin with the internal organization and expertise of the Portland Water Bureau as Project Sponsor, supplemented by significant public health expertise and resources drawn from Multnomah County Health Department and Oregon Health Division, drinking water and corrosion expertise from private engineering consulting firms, and assistance from consultants with expertise in stakeholder involvement, outreach and marketing.
- The Portland City Council has consistently supported the development and implementation of the Lead Hazard Reduction Program (LHRP) by approval of program directions and budgets. LHRP programs and resources have been scoped to provide public health approaches that focus efforts where the risks of exposure are the greatest, and achieve significant corrosion control benefit, while also meeting the public health intent of the Lead and Copper Rule.
Program Component "Water Treatment and
Water Quality Monitoring"Home Lead Hazard
Reduction Program"Stakeholder Involvement,
Public Education, and Outreach
"Lead-in-Water Testing Program"Project XL for Communities TOTALS $1,104,000 Notes: 1 Fiscal years are from July 1 to June 30. Budgets do NOT include the costs of functions performed by existing staff (regulatory reporting, water sampling and analysis, Water Treatment supervision and management, Home Lead Hazard Reduction Program management, Lead-in-Water Testing Program management, Project XLC management). Annual budgets are shown for FY 98-99 and FY 99-00; budgets for FY 00-01 and FY 01-02 (the term of this Final Project Agreement) have not yet been formally established, but are expected to be similar to the budgets shown for FY 99-00.
2 This cost is currently budgeted as shown, but costs may increase once the once the program is designed and implemented.5. TRANSFERABILITY
- The Water Bureau as Project Sponsor oversees and administrates all LHRP programs and contracts. The Water Bureau also coordinates program efforts with the wholesale water purveyors through monthly meetings with the managers of the water systems, and quarterly meetings with the operational staff of the water systems. Water Bureau staff who manage each of the LHRP program components have frequent interactions, and coordination and progress meetings with entities with whom program work is contracted or partnered.
- The Water Bureau has been providing free drinking water testing, including lead and copper analyses, to its customers for more than twenty years. In addition, the Water Bureau has been providing some level of follow-up assistance to customers where appropriate. So the feasibility of the Lead-in-Water Testing Program in some form has already been demonstrated.
6. MONITORING, REPORTING, AND EVALUATION
- The existing pH adjustment process is already used for water treatment in many communities throughout the world.
- CLEARCorps is a national program and a part of the AmeriCorps National Service Network. The national program is now in its fourth year of operation, and the Portland program is one of five active sites throughout the U.S. CLEARCorps will be expanding its programs into a number of other cities in the coming years, and is using the information gathered at this site, along with other sites, to continually improve their program efforts and effectiveness.
- The Household Lead Dust Prevalence Study used epidemiological and dust sampling methods that can be performed by others wishing to conduct similar studies in their communities.
- Lead Hazard Reduction Program outreach efforts have established many partnerships in the community, and will continue to do so. Wherever possible and beneficial, outreach efforts work towards facilitating community organizations in taking on important roles themselves, such as outreach, education, coordinating, etc.
- Outreach efforts have been successful, and can serve as a model for similar efforts elsewhere. The outreach consultant's report on how to build relationships and obtain formal support from persons and agencies that are fundamentally connected to the success of this community-based effort should provide useful guidance to others.
- Although the Lead-in-Water Testing Program isn t developed yet, it would appear that the program concept could lend itself to being duplicated by other utilities. This program model could be used to enhance the programs of other utilities to help achieve public health benefit, because of its focus on proactive, risk-based targeting of services and education, and follow-up assistance for customers.
- For more than a year, Lead Hazard Reduction Program staff have been answering questions from other agencies and organizations that are interested in these programs and investigating whether similar efforts might be feasible in their communities.
- The EPA will be able to use the information developed by this innovative program to determine the feasibility and benefits of similar public health programs elsewhere.
- This is the first Project XL for Communities program as part of the national pilot XL program. Information gained here will be useful to the EPA in the development and implementation of future XLC programs.
- For more information on the demonstration potential of the Lead Hazard Reduction Program, see part III. C.
7. EQUITABLE DISTRIBUTION OF ENVIRONMENTAL RISKS
- All Lead Hazard Reduction Program (LHRP) components utilize evaluation protocols, so success of each program component can be demonstrated. For a complete description of evaluation of each of the components of the Lead Hazard Reduction Program, see part III. C.
- The Portland Water Bureau is the entity that is ultimately responsible for the programs, and does this by its own actions and activities, and by subcontracting and working in partnership with the Multnomah County Health Department, the CLEARCorps program, Oregon Health Division, consultants, and the community.
- Progress reports on the Lead Hazard Reduction Programs will be provided to the EPA, XLC Stakeholders, and the public. Reports will include regular reporting of program results, including results from evaluation processes, and measures of success and public health benefit. At the end of the term of this FPA, a report will be provided summarizing results and success of the Lead Hazard Reduction Program as a whole. For a complete description of the reports provided, and the availability of information for public review, see part IV. C.
8. COMMUNITY PLANNING
- The focus of the Lead Hazard Reduction Program is to reduce, remove and control environmental hazards, not create new hazards. In addition, the focusing of the programs in areas where the risks are the greatest, and to low-income families and areas where assistance is most needed, lessens the burdens that these entities have traditionally borne.
- CLEARCorps Team members are trained in worker safety and lead safety issues. All CLEARCorps work is closely supervised to ensure that only those methods approved by the Oregon Health Division (OHD) are used in all work done in homes. All CLEARCorps work areas are contained according to OHD protocols in order to prevent exposure to lead by residents of the homes.
- All lead-containing waste products from CLEARCorps are disposed of according to Multnomah County Risk Management program and Oregon Department of Environmental Quality protocols. Waste includes plastic sheeting, protective suits, dust from HEPA filters, and small amounts of paint chips and other debris. The CLEARCorps program is classified as a small quantity generator under the federal Resource Conservation Recovery Act (RCRA) because it generates less than 220 pounds of waste per month. Therefore, it is permissible to double-bag the waste in plastic, and dispose through the regular garbage collection and disposal process. If regulations change, the CLEARCorps waste management protocols will be revised accordingly.
- The Lead Summit provided the first forum in the Portland area for organizations and agencies doing lead work in the community. Summit participants identified the need for a city-wide comprehensive lead plan, whose goals and objectives would be based on need and the consensus of the stakeholders involved. Since there are more housing units at risk for lead than this program can address, this community planning effort will be important in developing strategies to address these problems over the long term. The Urban League of Portland is leading the efforts to keep this collaboration and community planning progressing. The Lead Summits will also be convened on an annual basis.
- Home Lead Hazard Reduction Program and Outreach staff are using information from comprehensive planning efforts to work with community groups and elected representatives to encourage and provide input into needed lead legislation.
- Measured public health outcomes of the Home Lead Hazard Reduction Program can be used for region-wide strategic planning purposes, and for writing grants to obtain funds for future programs.
9. INNOVATIVE APPROACHES, MULTI-MEDIA FOCUS, AND POLLUTION PREVENTION
III. REQUIREMENTS AND COMMITMENTS OF THE PROGRAM
- To the best of our knowledge, the Lead Hazard Reduction Program (LHRP) currently has no counterparts elsewhere in the country, and there are not other water utilities with similar programs. The LHRP is unique because:
- it works through a partnership of a public drinking water utility, county and state public health agencies, community organizations, and citizen advocates
- it provides numerous opportunities for feedback and involvement by the general public and other stakeholders
- outreach efforts are innovative beyond many traditional community involvement projects, by use of methods such as cable access television for airing of public education videos, and live public forums which directly address questions and concerns from the public- The Lead Hazard Reduction Program (LHRP) uses a combination of approaches to provide a more comprehensive and effective solution that a single approach would. The LHRP has programs which take actions to reduce lead dust in homes, and components which take actions to reduce lead and copper in drinking water. The LHRP will also provide education on the risks from use of culture-based lead-containing products, such as folk medicines and lead-glazed pottery. Information will be provided on safer alternatives to these products, and encouragement and support to use them.
- Corrosion treatment of drinking water results in less leaching of copper from plumbing systems, and subsequent discharge of these contaminants to the sewer system. This results in lower quantities of these contaminants which must be removed by the sewage treatment plants before discharge of plant effluents to the environment.
- Through use of a simplified water treatment process, environmental risks associated with chemical production, transport, handling, and potential spills is minimized.
A. LEGAL MECHANISMS
A number of legal mechanisms are in place which are used to implement components of the Lead Hazard Reduction Program. These mechanisms are described below, along with the parties responsible for implementing them, and the parties responsible for administering them.
Party Responsible
For Legal Mechanism:Party Responsible
For Implementation:Party Responsible
For Administration:"The Safe Drinking Water Act PWB & Wholesalers OHD-DW "The Lead and Copper Rule PWB & Wholesalers OHD-DW "Oregon Administrative Rules for
Public Water SystemsPWB & Wholesalers OHD-DW "Project XL for Communities
ProgramProject Sponsor and
Co-SponsorsEPA AmeriCorps/CLEARCorps
AuthorizationCLEARCorps office
Baltimore MDAmeriCorps office,
Washington D.C."Portland CLEARCorps contract MCHD, CLEARCorps
ProgramCLEARCorps office,
Baltimore MD"Department of Housing and Urban
Development Guidelines for lead-based paint control and abatementMCHD, CLEARCorps Program OHD-LEAD "Intergovernmental Agreement by the City of Portland with the Multnomah County Health Dept MCHD, CLEARCorps
ProgramPWB Notes: 1. PWB and Wholesalers: Responsibility is by the City of Portland Water Bureau, and by the Wholesaler Water Purveyors in each of those water districts, in accordance with Oregon Administrative Rules and the Joint Monitoring Program approved by the Oregon Health Division.
2. OHD-DW: Oregon Health Division Drinking Water Section, as granted primacy for administration of drinking water regulations in the state of Oregon, and as described in the Oregon Administrative Rules.
OHD-LEAD: Oregon Health Division, Lead-Based Paint Activities Program, as granted approval for administration by the U.S. EPA.
3. Project Sponsor: The City of Portland Water Bureau
Project Co-Sponsors: The Portland Water Bureau's wholesale water purveyors, the Multnomah County Health Department, and the Oregon Health Division Drinking Water Section
4. EPA: The U.S. Environmental Protection Agency, Office of Innovation
5. MCHD: Multnomah County Health DepartmentB. KEY COMMITMENTS
These commitments reflect the serious intentions of the Project Sponsor and Co-Sponsors to effectively implement the four components of the Lead Hazard Reduction Program (LHRP). The Project Sponsor and wholesale water purveyors are also implementing the LHRP for the purposes of compliance with the Lead and Copper Rule. The EPA has granted primacy to the Oregon Health Division (OHD) as the drinking water regulatory authority in Oregon, and the OHD approved the LHRP as optimal corrosion control treatment for lead and copper at the customer taps throughout the regional distribution system in November 1997.
Key Commitments are described below by consideration of each component of the Lead Hazard Reduction Program.
Key Commitments of the WATER TREATMENT AND WATER QUALITY MONITORING program component:
This follow-up investigation will be completed within twelve months of the effective date of this Final Project Agreement
- Operate and maintain the pH adjustment treatment process to:
- Produce reduced levels of lead and copper at the customers tap (when compared to 1992 levels)
- Meet water quality goals for pH in the distribution system as established by the Oregon Health Division
- Adjust the existing process as appropriate, including chemical feed rate and treatment targets, to further reduce lead and copper levels, if possibleIt is recognized and agreed that the existing pH adjustment process and future process adjustments or modifications do not assure that lead levels in Tier 1 homes will be below the Lead Action Level of 0.015 mg/L.
- Conduct all ongoing water quality monitoring for lead, copper and corrosion control treatment operation as required under the Oregon Administrative Rules
- Monitoring includes, but is not limited to, lead and copper of Tier 1 homes in the Bull Run Service Area, process control monitoring for the pH adjustment process, point of entry monitoring as required for participating wholesale water systems, and monitoring of water quality parameters in the distribution system.
- All regulatory monitoring results will be reported to the Oregon Health Division as per their reporting schedule (typically monthly reports, and reports on monitoring of Tier 1 homes every six months)- Conduct follow-up investigations of monitoring results to address:
- Identification of possible explanations, and potential corrective actions for recent trends of increasing lead levels in Tier 1 homes
- Identification of homeowner- or home occupant-controlled factors such as improper electrical grounding, sample collection procedures, or plumbing materials that may contribute to inconsistent results in Tier 1 home sampling
- Further analysis of corrosion chemistry to identify potential adjustments to the existing treatment process that may be used to further reduce lead levelsKey Commitments of the HOME LEAD HAZARD REDUCTION PROGRAM component:
In Year 2 (July 1998-June 1999) the following commitments will be fulfilled:
- Provide effective daily management of the HLHRP/CLEARCorps Program efforts
- Recruit CLEARCorps Team members in a way that reflects the diversity of the neighborhoods in the Portland metro region
- Assure that CLEARCorps Team members receive the necessary training to do their work in a safe and cost effective manner
- Train CLEARCorps Team members to become community resources of lead-related information
- Help to prepare CLEARCorps Team members for future employment
- Manage program workloads to provide up to 20% of the CLEARCorps Team members time for personal development activities
- Work cooperatively in whatever capacity needed to help facilitate the Water Bureau's public outreach and education efforts
- Assist in developing and distributing lead-related informational and educational materials
- Evaluate the HLHRP/CLEARCorps program's recruitment, remediation, and education activities to ensure that public health benefits and degree of program success can be measured (see part III. C.)
- Evaluate the Public Education and Outreach activities, to ensure that the degree of success can be measured, and program improvements can be made as needed (see part III. C.)
- Complete the Household Lead Dust Prevalence Study, present the results, and use the results to assist the CLEARCorps program, and other Lead Hazard Reduction Program components to ensure that resources are targeted efficiently, and Prevalence Study findings are used effectively (see also part III. C.)
- Assist the Water Bureau in educating the residents of homes where CLEARCorps work is performed on the importance of lead water testing, and the resources available for water testing
- Provide effective protocols for, and referrals to the Portland HUD Lead Hazard Control Program
- Serve as liaison with the National CLEARCorps organization
The scope of work and commitments for Year 3 and beyond will be drafted and provided to stakeholders for review as they are developed near the end of Year 2. The final scope of work and commitments for each year of the program will be set on a yearly basis with the Portland Water Bureau, and will be part of the Intergovernmental Agency Agreement by the Portland Water Bureau with the Multnomah County Health Department.
- Provide level-one service (walk through inspections and in-home education services) in 35 housing units
- Provide level-two service (lead risk assessments and in-home education services) in 35 housing units
- Reduce lead hazards in targeted housing stock by an average of 85%, at an average rate of 3.7 housing units per month
- Work with the Water Bureau to expand the HLHRP/CLEARCorps program into additional high-risk neighborhoods in the Bull Run Service Area in Year 3
- Provide an effective forum for gathering and processing feedback from the public through revision of the format of the monthly meeting of the Oversight, Review, and Planning Committee
Key Commitments of the STAKEHOLDER INVOLVEMENT, PUBLIC EDUCATION, AND OUTREACH program component:
Key Commitments of the LEAD-IN-WATER TESTING PROGRAM component:
- Meet the public education and notification requirements of the Lead and Copper Rule whenever monitoring shows that lead levels in Tier 1 homes are above Action Levels
- Provide education on the potential sources of lead and copper in drinking water, resources for water testing and follow-up assistance, and how these lead and copper sources can be reduced and controlled
- Provide education and referral to resources for free blood lead testing, targeting pregnant women and children under five years of age
- Provide education materials to all defined populations and target audiences in the Bull Run Service Area
- Provide education in a way which targets pregnant women and children under five years of age
- Provide numerous opportunities for community participation and feedback to all defined populations and target audiences in the Bull Run Service Area
- Produce and distribute educational materials for all educational levels, and by using a diversity of educational means, including brochures, videos, instruction and information tapes, simplified language materials, and written reference materials
- Translate critical education materials into Russian, Spanish and Vietnamese as determined by the cultural needs of the defined community or target audience
- Produce lead exposure prevention materials for use on television and radio
- Develop and maintain relationships with community advocacy groups and individuals in defined communities and target populations in order to better provide education
- Develop and maintain partnerships with environmental and health advocates in order to continue education in target areas
- Educate health care providers to include lead and copper exposure prevention information in their daily dialog with clients
- Provide education on the risks from use of culture-based lead-containing products, safer alternatives to those products, and encouragement and support to use the alternatives
- Provide process and outcome evaluations of the Lead Summit, selected public education efforts, and the public forums.
- Seek feedback on the design and implementation of the program from stakeholders who are impacted by the program, and who can provide critical information about community preference and needs
- Create a strategy that targets those customers at greatest risk of exposure to lead and copper in drinking water
- Educate homeowners, home occupants, school administrations, landlords and landlord-tenant associations on lead and copper in drinking water issues and how problems can be identified and remediated; encourage participation in the program and understanding of how liability issues can be addressed
- Provide outreach to and involvement of stakeholders in the defined communities and target populations
- Provide plans and protocols for follow-up assistance to customers found to have elevated lead and/or copper levels in their drinking water
- Develop an implementation plan describing activities, responsible parties, and resources
- Develop an evaluation plan that will evaluate the program's results and provide measures of effectiveness and public health benefit
- Design and implement a Lead-in-Water Testing Program in Summer 1999
C. THE LEAD HAZARD REDUCTION PROGRAM AS A DEMONSTRATION PROJECTA key objective of EPA's XL program is to provide opportunities to test innovative alternatives, and determine whether these alternatives have potential in serving as models or prototypes for similar programs elsewhere. Project Sponsors and Co-Sponsors feel that the very nature of the Lead Hazard Reduction Program (LHRP) lends itself well to the program being a good candidate for testing as a national pilot program. The LHRP uses a multi-media approach. That is, it uses a combination of alternatives to address environmental exposure to lead and copper from a variety of sources. The LHRP places importance on drinking water as a source of lead in the environment, but recognizes that drinking water is not typically the primary source of a person's exposure to lead. The LHRP directs a significant portion of its efforts on lead-based paint and lead-containing household dust as the primary sources of risk from lead exposure in the environment, and the primary causes of elevated blood lead levels both locally and nationally. The LHRP places primary importance on the prevention of lead exposure. And finally, the LHRP will measure and evaluate program results, and provide increased knowledge about the efficacy of reduction of lead hazards, and the resulting public health benefits that can be achieved.
Potential as a demonstration project can not be achieved unless programs are designed from the onset to gather information in such a way that the results can be monitored and evaluated, thus allowing a determination of whether or not the program has the likelihood of success if implemented in other communities.
How the Lead Hazard Reduction Program will be monitored and evaluated to ensure that public health benefit can be measured, and how the program will be tested to determine whether the results will be transferable to other applicable situations is described below by consideration of each component of the program.
How the WATER TREATMENT AND WATER QUALITY MONITORING PROGRAM is a demonstration project:How the HOME LEAD HAZARD REDUCTION PROGRAM is a demonstration project:
- Monitoring of Tier 1 homes will include lead and copper monitoring of representative Tier 1 homes in the Bull Run Service Area, and will be conducted as required under the Oregon Administrative Rules for Public Water Systems.
Monitoring will be conducted in conformance with the requirements of a monitoring plan approved by the Oregon Health Division. Monitoring will be conducted every six months for the duration of this Final Project Agreement.
- Point-of-entry Monitoring of the pH Adjustment Treatment Process
Monitoring will include continuous pH monitoring of the pH adjustment treatment process as needed to verify treatment operation performance, and compliance with treatment goals established by the Oregon Health Division.
- Monitoring of Water Quality Parameters in the Water Distribution System
Monitoring will include routine sampling and analysis for pH and alkalinity in water distribution systems in the Bull Run Service Area, and will be conducted as defined in the Oregon Administrative Rules for Public Water Systems. Such monitoring will be conducted in conformance with the requirements of a monitoring plan approved by the Oregon Health Division, and will be conducted at least monthly for the duration of this Final Project Agreement.
- Routine Regulatory Compliance Reporting
All of the above regulatory monitoring results will be reported to the Oregon Health Division in conformance with the Health Division's routine reporting schedule (typically, monthly).
- Follow-up Evaluation of Tier 1 Home Monitoring Results
The Water Bureau will provide follow-up investigation of routine lead and copper monitoring results in order to identify possible explanations and potential corrective actions for recent trends of increasing lead levels in Tier 1 home samples. Homeowner- or home occupant-controlled factors such as improper electrical grounding, sample collection procedures, or plumbing materials that may contribute to inconsistent results in Tier 1 home monitoring will be identified. The corrosion chemistry will be further reviewed to identify potential adjustments to the existing treatment process that may result in further reductions in lead levels.
- Evaluation of the Home Lead Hazard Reduction Program
Process and outcome data will be used to make revisions as needed, and mains an optimally effective program in Year 2 and subsequent years. Evaluation processes, tools, and procedures will be adapted to program changes in Year 2 and subsequent years.
- Evaluation of CLEARCorps Interim Lead Hazard Control Work
Monitoring includes a process and outcome evaluation, consisting of results of:
- before and after hazard assessments,
Reports will be provided on the findings, including:
- dust and soil sample data,
- blood lead level tests,
- resident interviews, and
- resident satisfaction survey data.- numbers and characteristics of households recruited and in which work was done,
- kinds of lead hazard controls and education provided,
- baseline and post-intervention changes in home environmental lead levels,
- changes in household knowledge and preventive behavior, and
- resident satisfaction with intervention and educational efforts.- Evaluation of CLEARCorps Neighborhood-Based Outreach
Monitoring includes a process and outcome evaluation to:
- measure the awareness and support for the CLEARCorps program from the communities in which it is implemented,
Data will include:
- assess the impact of outreach on knowledge on types of childhood lead hazards, and lead exposure prevention, and
- measure success in recruiting households- documentation of target population,
Additional evaluation of the impact of the outreach on participants knowledge and behavior will be obtained using post-presentation questionnaires. Reports will include:
- number of persons reached,
- goals and topics of presentations and outreach activities
- end-of-presentation participant evaluations.- numbers and characteristics of persons/groups attending the presentations,
- kinds of education provided,
- participant satisfaction, and
- changes in knowledge and behavior as a result of the presentation or outreach.- Evaluation of the Household Lead Dust Prevalence Study
Evaluation will include monitoring of:
Outcome data will consist primarily of composite dust lead loadings, supplemented by resident demographics and housing conditions.- the pace and quality of recruitment,
- dust sampling, and
- laboratory analyses.
Participants will be notified of lead loading levels found in their dwellings. Participants will also be provided with appropriate recommendations for follow-up testing and lead hazard reduction activities.
Study findings will be released to the general public in a manner that protects the confidentiality of the participants, but presents data that can be used to maximize public health and reduction of lead hazards. Recommendations for effective household recruitment strategies, and other procedures and protocols will be made. Findings will be presented at scientific meetings and/or prepared for publication in public health journals.
- The Evaluation Team and Tools
Evaluation tools are developed and revised as needed (databases, data collection forms, data confidentiality and informed consent procedures, data collection protocols and record keeping forms, data analysis methodologies, and data management and quality assurance protocols). Data entry and data evaluation team members are hired as needed. CLEARCorps Team members, Multnomah County, and Water Bureau staff are trained as needed to facilitate the collection of quality data.
Reports on results will be provided to the Multnomah County Health Department, the Water Bureau, the HLHRP Oversight, Review and Planning Committee, and to XL stakeholders. Presentations on evaluation findings will be presented at national scientific conferences, and manuscripts will be prepared for publication.
How the STAKEHOLDER INVOLVEMENT, PUBLIC EDUCATION, AND OUTREACH program is a demonstration project:
How the LEAD-IN-WATER TESTING PROGRAM is a demonstration project:
- Evaluation of Public Education and Public Participation Activities
Monitoring includes both process and outcome evaluations. The outcome evaluation will consist of pre- and post-training assessment of the:
The evaluator will collaborate with Outreach program staff in using prevalence study data to increase the awareness of lead hazards, increase the frequency of blood lead screening by the health community, and evaluate awareness of the health community.- Train the Trainer sessions,
- Jefferson High School and Hosford Middle School education programs
- in-depth ethnographic interviews of ten members of a group that has been targeted with educational messages,-- Evaluation will determine the amount of the education that was understood and retained,
- and post-session participant evaluations of:
-- the changes in the beliefs and intentions that were modified as a result of the educational messages,
-- changes in the recipient's health and prevention behavior in response to the information presented-- Lead Summits,
-- selected public education efforts, and
-- three Public ForumsA plan for evaluation of the penetration and impact of public service announcements will be developed and implemented.
- Report on the Solicitation of Formal Letters of Support
This report includes suggestions from community leaders on issues which the Home Lead Hazard Reduction Program should address, recommended program revisions and enhancements, and suggestions on how to solicit and gain formal support from community leaders for a project such as this. This report can serve as a set of guidelines for others who wish to build relationships and obtain formal support from persons and agencies that have fundamental or critical connections to the success of their community-based effort.
The Evaluation Plan for the Lead-in-Water Testing Program will be developed by the Portland Water Bureau's project team, including Bureau staff, wholesale water purveyors, and consulting assistance, with the input of stakeholders.
The Evaluation Plan for the Lead-in-Water Testing Program will:
- describe the criteria used for monitoring, evaluating, and determining the effectiveness of the program
- generate alternatives for evaluation options or methods, and evaluation of the alternatives against the criteria
- describe the chosen evaluation methods to be implemented
- describe exactly how the results and outcomes of the program will be evaluated by these methods
- be used to make future program changes, enhancements, and refinements as needed
- describe the means used to make program adjustments and the process for continually improving the program
- describe the frequency of program evaluation (most likely annually)IV. ADMINISTRATION OF THE AGREEMENTA. TERM OF THE AGREEMENTThe Water Treatment and Water Quality Monitoring program began with pH treatment of Bull Run source water on January 1, 1997. The Home Lead Hazard Reduction Program and Stakeholder Involvement, Public Education, and Outreach components of the LHRP began on July 1, 1997; these programs were implemented as pilot programs in their first year, and are now expanding to other Portland communities and to the entire Bull Run Service Area. The Lead-in-Water Testing Program is scheduled to be implemented in the Summer of 1999.The Home Lead Hazard Reduction Program (HLHRP) is currently envisioned as a five-year program. The three remaining components of the Lead Hazard Reduction Program will continue as ongoing programs for the Portland Water Bureau in partnership with its wholesale water purveyors.
All four components of the Lead Hazard Reduction Program will be developed, implemented, and reviewed by Project Sponsors, Co-Sponsors, and Stakeholders in accordance with this Final Project Agreement for a term which gives the HLHRP a lifetime of five years since its inception on July 1, 1997. The total term of this FPA will begin with the signing of this agreement in its final form, and will continue until July 1, 2002. The Development Phase will be one year, beginning with the signing of this agreement. The Implementation Phase will begin after the Development Phase and will continue until the end of the term for this FPA (July 1, 2002).
Feedback, information and recommendations from Project Sponsors, Co-Sponsors, and Stakeholders gathered during the life of this agreement will be used by the Portland Water Bureau to determine whether or not the need exists for continuation of the Home Lead Hazard Reduction Program past its current term of five years, and to determine whether the Bureau should commit resources to do so.
Feedback, information and recommendations from Project Sponsors, Co-Sponsors, and Stakeholders gathered during the life of this agreement will also be used by the Portland Water Bureau to improve and continue the ongoing efforts of the remaining components of the Lead Hazard Reduction Program (Water Treatment and Water Quality Monitoring; Stakeholder Involvement, Public Education, and Outreach; and Lead-in-Water Testing).
B. DECISION-MAKING PROCESSES
Decision-making processes were developed by collaboration of Project Sponsors, Co-Sponsors, Direct Participant Stakeholders, and the EPA who met as a group to discuss these issues. Each member of the group was polled, and the decision to adopt these procedures was unanimous (EPA participants chose not to vote). All participants, including those who were not present at the meeting where these procedures were finalized were provided these procedures in draft form for review and comment. The Decision-Making processes as described below are those processes agreed to by all Project Sponsors, Co-Sponsors, and Direct Participant stakeholders.
1. FPA DEVELOPMENT
Project Sponsors, Co-Sponsors, and Direct Participant stakeholders agreed to use the following Decision-Making process for FPA Development:
Public Comment on the Final Project AgreementPublic Notice
The Final Project Agreement (FPA) will be made available for comment during the 30-day public comment period. The public comment period will begin on and end on . The FPA will be signed and published, after accepting and processing comments.
NOTE TO ALL STAKEHOLDERS AND REVIEWERS:
For the January 25th meeting, please be prepared to provide your suggestions:
- Where should the FPA be made available during the 30-day public comment period?
- How and where should public notices be placed for the 30-day public comment period?
- How should opportunities for public comment be provided? We will need numerous and varied opportunities.
- How should we ask that public comment be provided to us? Again, we will need a variety of ways for people to provide comment.
- How should public comments be processed by the Project Sponsor?
- Where should the final, signed FPA be published?
(Add details after Jan 25 meeting)Reporting and Periodic Reviews
Progress reports on the Lead Hazard Reduction Programs will be provided to the EPA, XLC Stakeholders, and the public. Reports will include regular reporting of program results, including results from evaluation processes, and measures of success and public health benefit. At the end of the term of this FPA, a report will be provided summarizing results and success of the Lead Hazard Reduction Program as a whole.
- Water Treatment and Water Quality Monitoring - reports every six months, after each round of monitoring in targeted homes
- Home Lead Hazard Reduction Program -quarterly reports during the FPA development phase, and end-of-year reports thereafter (during FPA implementation)
- Stakeholder Involvement, Public Education, and Outreach -quarterly reports during the FPA development phase, and end-of-year reports thereafter (during FPA implementation)
- Lead-in-Water Testing Program -quarterly reports during the FPA development phase, and end-of-year reports thereafter (during FPA implementation)
NOTE TO ALL STAKEHOLDERS AND REVIEWERS:
For the January 25th meeting, please be prepared to provide your suggestions:- How should information be maintained?D. EVENTS PREVENTING PROJECT IMPLEMENTATION
- Where should information be maintained?
- How should information be made available to the public?
- How should we ask that comment be provided to Project Sponsors? Again, we will need a variety of ways for people to provide comment.
- How should public comments be processed by the Project Sponsors?The parties recognize that in certain circumstances it may be impossible for a party to fully implement a commitment it has made in this agreement, due to events beyond the control of, and not reasonably foreseeable by, that party, and which cannot be overcome by due diligence by that party.In such cases the parties will attempt to modify the agreement to reflect their revised expectations, and not to terminate it unless the parties conclude that the entire project is no longer worthwhile due to the intervening event.
If a party becomes aware of such an event that may prevent it from carrying out a commitment in a timely way, it will promptly notify the other parties.
E. MODIFICATION OF THE AGREEMENTThis FPA may be modified upon agreement of all the signatories, after involvement of the Stakeholders. If the FPA is substantially modified, public notice and an opportunity to comment on the modification will be provided.F. TERMINATION/WITHDRAWALBecause this FPA is not legally enforceable, no party may be legally compelled to continue with the project against its wishes. The parties to this agreement are strongly committed to the continuation of the project, and desire that the FPA remain in effect and the project be implemented as fully as possible. It is not intent of the parties to terminate or withdraw from the FPA unless there is a compelling reason to do so.To ensure an orderly transition if any party wishes to withdraw, or wishes to have the agreement terminated, the parties intend for written notice to be provided to that effect to all the other parties and Stakeholders.
The parties agree that appropriate grounds for a party to seek to withdraw or to terminate their participation in the agreement would include, but not be limited to, the following:
1. Substantial failure by another party to implement the terms of the FPA
2. A conclusion by all the parties that the project is not achieving success and does not warrant continuation
3. Discovery of failure by the Project Sponsor to disclose relevant facts during development of the FPA
4. Discovery of new information indicating that implementation of the project is presenting unexpected risks or adverse consequences, or may present a substantial threat to public health, safety, welfare, or to the environment
5. Significant or repeated violations of environmental requirements by the Project Sponsor and/or Co-Sponsors, including requirements that are not addressed in this agreementG. MEANS OF GIVING NOTICEIf a party wishes to withdraw, or wishes to have the agreement terminated, the following process will be used:1. That party will submit a written notice to all other parties who are signatories to this agreement, including members of the group of Stakeholders. The written notice will clearly state the party's wishes, along with a description of supporting reason(s) for wishing to withdraw or have the agreement terminated.
2. Termination of the agreement, or withdrawal of that party, will occur 30? days after the written notice is received by other parties and Stakeholders, unless the parties agree that a different deadline is appropriate, either to attempt to resolve any dispute, or to achieve an orderly transition
H. ORDERLY TRANSITIONIf this Agreement is terminated, or is not renewed at the end of its term, the Project Sponsors and wholesale water purveyors shall remain subject to the requirements of the Safe Drinking Water Act, and the Lead and Copper Rule as implemented in Oregon under the Oregon Administrative Rules for Public Water Systems. This may include establishing compliance schedules, supplemental monitoring and reporting requirements, or other such actions as determined by the primacy agency in order to achieve and demonstrate compliance with existing Oregon rules.I. STATEMENT OF UNAFFECTED AUTHORITIES
Nothing in this agreement limits the authority of EPA, the Oregon Health Division, or other regulatory authority to:J. CONTACT POINTS AND SIGNATORIES1. undertake any criminal enforcement authority against any person including parties to the agreement; orNothing in this agreement is intended to limit the Project Sponsor's rights to administrative or judicial appeal or review of the legal mechanisms used to implement the project, or modification or termination of those mechanisms in accordance with the normal procedures for such review.
2. undertake actions in response to conditions which present an imminent and substantial endangerment to public health or welfare, or to the environment.
For:contact:
- information on components of the Lead Hazard Reduction Program, and Portland's XL for Communities project
- details on how to provide feedback on this document and the Lead Hazard Reduction Program
- details on how to get more involved and participate as a Project XL for Communities Stakeholder
Alberta Seierstad
Portland Water Bureau
2010 N. Interstate Avenue
Portland OR 97227
phone: 503-823-4900
fax: 503-823-4910
email: aseierstad@water.ci.portland.or.usFor information on EPA's Project XL for Communities, contact:the XL web site: https://www.epa.gov/ProjectXLC
the XL for Communities Information Line at 703-934-3241
Chris O donnell, Director, Project XL for Communities at 202-260-2763,
or the automated phone system at 202-260-8590For additional information on the Water Bureau and the Lead Hazard Reduction Program, contact: Water Bureau web site: http://www.portlandonline.com/waterFor more information about the Home Lead Hazard Reduction Program, call:
Chris Johnson, Multnomah County Health Dept. at 248-3842, ext 262For more information on how you can become a stakeholder, or become involved in the programs at a community level, call: Stacey Drake Edwards at 503-823-1579For more information about the CLEARCorps program, including services and eligibility, call:
CLEARCorps office at 503-248-5240For information on how to get your water tested for lead and copper:
If you get your water from the Portland Water Bureau, call:
Portland Water Bureau Customer Service at 503-823-7770If you get your water from another supplier:
contact that water district directly
or
call the Oregon State Health Division for information on labs certified to perform drinking water testing: 503-731-4010For information on a wide variety of lead issues, call:
The Oregonian Information Line on Lead, sponsored by the Coalition for a Lead Safe Portland, at 503-225-5555, extension LEAD (ext. 5353)For questions on lead and medical issues, call:
the Oregon Health Division at 503-731-4025For remodeling questions, and information on certification to perform lead-based paint work, call:
the Oregon Health Division at 503-731-4500For information on drinking water issues, call:
the EPA Drinking Water Hot Line at 1-800-426-4791
or the EPA Drinking Water web site: https://www.epa.gov/OWFor information on lead issues, call:
the National Lead Information Line at 1-800-LEADFYI (1-800-532-3394)For information on lead-free faucets, contact:
NSF International: 313-673-8010
or the NSF web site: http://www.nsf.orgSIGNATORIES TO THIS FINAL PROJECT AGREEMENT:Environmental Protection Agency:
Who? Date
Office for Innovation?Project Sponsors:
Michael Rosenberger, Administrator Date
City of Portland Bureau of Water Works
Erik Sten, Commissioner Date
City of Portland, Oregon
Project Co-Sponsors:
Who? Date
Name of Water District, **OR**
on behalf of the WATER MANAGERS
ADVISORY BOARD of bull run water users
(Portland Water Bureau wholesale water purveyors)
Portland Water Bureau wholesale water purveyors who are participating in the Lead Hazard Reduction Program:
Tualatin Valley Water District
Rockwood Public Utility District
City of Gresham
Powell Valley Road Water District
City of Tualatin
City of Tigard
West Slope Water district
Raleigh Water District
Pleasant Home Water District
Valley View Water district
Burlington Water district
Lorna Water company
Public Health Officer? Date
Multnomah County Health Department
Dave Leland, Administrator Date
Oregon Health Division, Drinking Water SectionParticipating Stakeholders:
Name Date
Representing ..... (if appropriate)
Name Date
Representing ..... (if appropriate)
Name Date
Representing ..... (if appropriate)
Name Date
Representing ..... (if appropriate)
Appendix 1
Stakeholders Involved in the Lead Hazard Reduction ProgramAfrican American Health Coalition,
Barbara Taylor
Albina Headstart, Sue Carey
Albina Ministries Alliance, Cornetta Smith
Alliance to End Childhood Lead Poisoning,
Don Ryan
Black United Front, Richard Brown
City of Gresham, Oregon Water Department,
Marty Wegner
Clackamas County Health Department,
Dr. Alan Melnick, Health Officer
Common Bond
Environmental Justice Action Group,
Ann Ishimaru
Environmental Protection Agency,
Monica Kirk, Office of Oregon Operations
Environmental Protection Agency, Barbara
Ross, Regional Lead Coordinator for
Oregon, Washington, Idaho and Alaska
Environmental Protection Agency, Bob
Kirkland, Region 10
Hernandez, Ursula, concerned parent
Hispanic Access Center, Peter Sayer
Hispanic Round Table and Neighborhood
Health Division, Noel Wiggins
Housing and Urban Development, Portland
Office, Roy Scholl
Lawyers Committee for Civil Rights Under
Law, Washington D.C., Damon P.
Whitehead
Lead Poisoning Prevention Comprehensive
Planning Group, LeRoy Patton
Multnomah County Health Department,
Gary Oxman, Health Officer
National Environmental Justice Advisory Council, and staff liaison to Governor's
Environmental Justice Advisory Board, Annabelle Jaramillo
National Resource Defense Council, Erik
Olson
North Portland Nurse Practitioner Clinic, Mariah Taylor, Nurse Practitioner
Oregon Child Development Coalition,
Marco Beltran
Oregon Council for Hispanic Advancement, Jamie Rodriquez
Oregon Department of Environmental
Quality, Rick Gates
Oregon Environmental Council, Sarah Doll
Oregon Health Division, Administrator,
Elinor Hall
Oregon Health Division, Drinking Water
Section, Dave Leland
Oregon Health Division, Environmental
Epidemiology Section, Rick Leiker, Narda Tolentino
Oregon Health Division, Lead-Based Paint
Program, Michael Bergman
Oregon Health Division, Office of Multi-
cultural Health,Suganya Sockalingam
Oregon Health Sciences University,
Multicultural Affairs, Alfonso Lopez
Oregon Legal Services, Ellen Johnson,
Ira Zarov
Oregon State Representative,
JoAnn Bowman
Oregon State Senator, Avel Gordly
Oregon Water Utilities Council, and City of
Corvallis, Oregon, Tom Penpraze
Physicians for Social Responsibility, and Governor's Environmental Justice
Advisory Board, Josiah Hill
Portland Bureau of Housing & Community
Development, Rob Bole, Andrea Taylor
Portland Office of Neighborhood
Involvement, Paul Duong
Rice, Harvey L., Member of General Public
interested in lead & other health issues
Screening Kids Informing Parents (SKIP),
Wanda Silverman
The Urban League of Portland, Alan Hipolito,
Lore Wintergreen, Lawrence Dark
Tualatin Valley Water District, Beaverton,
Oregon, Dean Fritzke
Washington County Health Department,
Roberta Hellman, Health Officer
West Slope Water District, Jerry Arnold
Western Regional Lead Training Center,
Ann Kimerling, Peter Nelson
Workers Organizing Committee, Advocacy
for Immigration Issues, Jeri SundvalAppendix 2
XL Stakeholder CategoriesStakeholders are grouped into three categories, each with a distinct role in the development of an XL for Communities project. Those stakeholders interested in the broader implementation of the concepts being tested in the project, as well as those stakeholders physically impacted by the project, have the opportunity to place themselves in any one of three categories described below.
Direct Participants
Direct Participants have a significant role in the development of the project. They work intensively with project sponsors, regulators, and EPA XL staff to construct and develop a project, and to develop the Final Project Agreement. The views of Direct Participant stakeholders will strongly influence the details of the project, as well as EPA's ultimate decision to approve or not to approve the XL for Communities project.
Commentors
Commentors have a specific interest in or expertise relating to the project, but not the desire or availability to participate as intensely in its development. The project development process informs and is informed by the Commentors on a continuing basis. The view of informed Commentors are a strong indicator of the broader potential of the innovation being tested in an XL for Communities project.
General Public
Members of the General Public should have easy access both to the project development process and to information about the environmental results of the project once it is implemented. Members of the General Public should have the ability to participate more actively if they so choose. Information about XL for Communities projects is made available in a variety of ways, such as mailings, web sites, press releases, public notices, etc.
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