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Project XL Logo

Portland Water Bureau (XLC)XLC Logo

March 21, 1997 Proposal Submission

March 21, 1997
WQ 1.11.1

Regulatory Reinvention Pilot Projects: XL Community Pilot Program,
FRL-5322-9

Water Docket, Mail Code 4101

U.S. Environmental Protection Agency
401 M Street SW
Washington, D.C. 20460

To Whom It May Concern:

The Portland Water Bureau is pleased to submit this proposal for the XL Community Pilot Program. The Portland Water Bureau is submitting this proposal to request regulatory flexibility for compliance with the Lead and Copper Rule promulgated under the Safe Drinking Water Act. Specifically, we are requesting approval of our Lead Hazard Reduction Program as a substitute for requirements for optimal corrosion control treatment and public education. We believe that the Lead Hazard Reduction Program will achieve better public health protection from lead exposure, at an equivalent or lower cost, than would be obtained by strict adherence to these Lead and Copper Rule requirements.

The Lead Hazard Reduction Program was developed by the Portland Water Bureau in partnership with the Oregon Health Division (Drinking Water Section and Environmental Epidemiology Section), the Multnomah, Washington, and Clackamas County Health Departments, the Oregon Childhood Lead Poisoning Prevention Program, and the managers of water systems purchasing water from Portland.

Enclosed are one original and three copies of the proposal and a set of attachments containing supporting information. The first attachment is the Lead Hazard Reduction Program Report dated December 1996. Since that report was completed in December 1996, a decision has been made to implement the Home Lead Hazard Reduction Component through the Multnomah County Health Department with an AmeriCorps program called CLEARCorps (Community Lead Education and Reduction). The second attachment includes a description of how the CLEARCorps program will be implemented in Portland, and should be considered an updated description of the Home Lead Hazard Reduction Component.
 

We look forward to the opportunity to work with you in developing a successful XL project. If you have any questions or would like to discuss this proposal further, please feel free to contact Rosemary Menard at (503) 823-7792 or Babette Faris at

(503) 823-7498.
 

Sincerely,
 
 

_________________________________

Rosemary Menard, Director

Water Resources Management Group

City of Portland Bureau of Water Works

____________________________

Grant Higginson, MD, MPH

_____________________________

Gary Oxman, MD, MPH

Oregon State Health Officer Multnomah County Health Officer
 

rcm:kbf
 

cc: EPA Region X: Larry Worley, Wendy Marshall, Bill Glasser

attachments
 
 

CITY OF PORTLAND BUREAU OF WATER WORKS

PROJECT XL PROPOSAL

_______________________________________

 


Introduction

The City of Portland Bureau of Water Works (Portland Water Bureau) is the largest water system in Oregon, serving about 500,000 people within the City of Portland and an additional 300,000 people throughout the Portland metropolitan area through wholesale agreements with 19 other water systems.

Through the XL Community Pilot Program, the EPA grants flexibility in the implementation of environmental regulations to communities in exchange for a commitment to achieve superior environmental performance. The Portland Water Bureau is submitting this XL project proposal to request regulatory flexibility for compliance with the Lead and Copper Rule (LCR). Specifically, we are requesting approval of our Lead Hazard Reduction Program (LHRP) as a substitute for Lead and Copper Rule requirements for optimal corrosion control treatment and public education.

The Lead and Copper Rule

In 1991, the EPA promulgated the LCR under the Safe Drinking Water Act Amendments of 1986 to reduce lead and copper in water at customer taps (Federal Register, 1991). The LCR establishes a treatment technique that includes a regulatory schedule and requirements for corrosion control treatment, public education, and monitoring.

The LCR requires large water systems such as Portland's to determine the optimal type of corrosion control treatment for their system and provide this treatment by January 1997. The LCR defines optimal treatment as that which minimizes lead and copper levels in drinking water without causing violations of other drinking water standards. The LCR also requires implementation of a specified public education program as long as lead action levels are exceeded1.
 

Portland's LCR Compliance Activities

Portland has an excellent record of compliance with drinking water regulations and has complied with all LCR requirements to date. In 1992, initial monitoring was conducted, including monitoring of lead and copper at customers' taps. Lead and copper action levels were exceeded in Portland and in other water systems using Bull Run water2 . Portland has been implementing the LCR-specified public education program in partnership with its wholesale water customers since 1992.

There is no detectable lead and there are very low levels of copper in Portland's Bull Run source water. Lead and copper enter drinking water primarily as a result of corrosion of building plumbing materials. The most common sources of these metals include lead-soldered joints in copper pipe and faucets and other fixtures made from lead-bearing brass.

Portland's LCR-required corrosion control study (Montgomery Watson and EES, 1994) indicated that lead and copper concentrations could be minimized in the distribution system by increasing Bull Run water pH from approximately 6.8 to pH 9.0-9.5 and increasing alkalinity from 6-12 mg/L to at least 25 mg/L as CaCO3.

Because optimal corrosion control treatment as defined by the LCR would mean a significant change in water quality with potential adverse effects, the Portland City Council, in accordance with recommendations from the Water Quality Advisory Committee3 and the Water Managers Advisory Board4 , directed the Bureau of Water Works to investigate alternatives. The resulting reports (EES, 1995; EES and Portland Water Bureau, 1996) describe the development of the Lead Hazard Reduction Program.

Portland has installed a sodium hydroxide feed system which has been operating since January 1997 to increase the pH of Bull Run water. The initial pH goal for water in the distribution system is in the range of 7.3-7.5, as described for the Water Treatment Component the Lead Hazard Reduction Program.

Lead Exposure in the Portland Area

Occurrence of Elevated Blood Lead Levels

The Centers for Disease Control and Prevention offers these guidelines for interpretation of blood lead levels (CDC, 1991):


Blood

lead level

(ug/dL)


Interpretation and 

guidance for health care providers


10-14

10 is currently identified as lowest level of concern;

provide education to decrease exposure with simple inventions 


15-19

Children are at risk for subtle adverse effects of lead poisoning; discuss interventions to reduce levels, do follow-up testing 

>19

Children require full medical evaluation, including environmental and behavioral history; >44 requires urgent medical follow-up 

The median and 90th percentile blood lead levels for children in Multnomah County are estimated at 3.8 and 10 ug/dL, respectively (OCLPPP, 1994).

Medical laboratories in Oregon are required to report cases of elevated blood lead levels (EBLLs) of 10 ug/dL or higher to the Oregon Health Division (OHD). Since 1993, the Multnomah County Health Department (MCHD) has conducted about 120 follow-up investigations of EBLLs. These investigations indicate that lead-based paint is the most likely source of exposure for 70% of EBLLs of at least 15 ug/dL, and for 80% of the EBLLs of at least 20 ug/dL (OHD, 1997). As part of 24 of these follow-up investigations, the Portland Water Bureau was requested to analyze tap water samples for lead. For this group of 24 samples, the median concentration of lead in standing samples is 0.002 mg/L and the 90th percentile concentration is 0.013 mg/L (PWB, 1997), which are below the lead action level of 0.015 mg/L5 . These data suggest that water was an insignificant or minor exposure pathway in these cases.

As part of the CDC-sponsored Oregon Childhood Lead Poisoning Prevention Program (OCLPPP), blood lead level screening of children is conducted in Multnomah County by the MCHD. These data show a strong positive relationship between occurrence of elevated blood lead levels and age of the child's home. About 1 out of 6 children tested living in homes built before 1930 had blood lead levels at or above 10 ug/dL, as compared to about 1 out of 15 children tested living in homes built in 1930 or thereafter (OCLPPP, 1994).

The observation that lead-based paint is the most commonly identified source of EBLLs in Multnomah County is consistent with the CDC's statement that lead-based paint is the most common high-dose source of lead exposure for children (CDC, 1991). Also, the EPA has estimated that, for a typical 2-year-old child living in an urban environment or in a non-urban house with interior lead-based paint, household dust and soil account for more than 90 percent of the child's daily intake of lead (EPA, 1995).

Occurrence of Lead in Drinking Water

As part of the studies to evaluate alternatives for LCR compliance (EES, 1996; EES 1997), models were developed to estimate the contributions of lead in water to lead in blood in the Portland area. An "individual-based" model was used to estimate the contribution to a person's total blood lead level that would be due to consumption of water with a specified lead concentration. These calculations made use of absorption coefficients to estimate how much lead in water is absorbed into the blood of infants, children, and adults. The coefficients used were those from EPA-preferred studies (Federal Register, 1991).

A "population-based" model was developed to compare the existing distribution of blood lead levels of infants, children, and adults in Multnomah County to predicted distributions after implementation of various corrosion control treatment alternatives. This model uses as input: 1) the existing distributions of water lead levels and blood lead levels; 2) anticipated reduction of water lead levels with corrosion control treatment; and 3) absorption coefficients as described in the previous paragraph. Because the distribution of blood lead levels, and to a lesser extent, the distribution of water lead levels varies with home age, the model was applied to eight subcategories of homes based on year of construction. For each home age subcategory, a statistical model of the distribution of blood lead and standing water lead levels was developed from existing data. A Monte Carlo simulation technique was used to generate a synthetic population with co-occurrences of blood lead and standing water lead levels consistent with their observed distributions. New blood lead distributions were calculated by reducing the existing distributions by the expected reduction of the water lead level due to various levels of corrosion control treatment. Detailed information about the models is presented in the study reports cited above. Some of the conclusions of the modeling efforts are:

Project XL and the Lead Hazard Reduction Program

Portland is proposing to implement a Lead Hazard Reduction Program as an alternative to the optimal corrosion control treatment and public education requirements of the LCR. The goal of the LHRP is to achieve better public health protection from lead exposure, at an equivalent or lower cost, than would have been achieved with strict adherence to the corrosion control treatment and public education requirements of the Lead and Copper Rule.

The LCR defines optimal treatment as that which minimizes lead and copper levels in drinking water without causing violations of other drinking water standards. The EPA (1995) emphasizes that interventions to reduce lead exposures should be targeted at those exposure pathways that have the greatest impact on the health of the child by reducing his or her body-lead burden. Potentially, an intervention (such as corrosion control treatment) can be successful in reducing a particular environmental exposure (lead in drinking water) and yet produce no positive impact in a child only marginally exposed to the abated lead hazard.

Under our proposal, optimal treatment would include corrosion control treatment that would reduce - but not necessarily minimize - lead and copper levels in drinking water, along with additional interventions to reduce lead exposures that have the greatest health impact on children at most risk. As part of the LHRP, corrosion control treatment would be provided, but at a reduced level (pH adjusted up to 7.3-7.5) than that defined as optimal by the Lead and Copper Rule (pH 9.0-9.5 with an alkalinity increase). The savings in capital and operating costs would be used to fund other targeted interventions to produce real, positive health impacts on the greatest number of at-risk individuals.

Design Objectives

The LHRP was developed using these objectives as a basis of design:

Components of the Lead Hazard Reduction Program

The four main components of the LHRP are summarized below. The attached Lead Hazard Reduction Program report (EES and Portland Water Bureau, 1996) contains a more detailed description of program components.

Since that report was completed in December 1996, a decision has been made to implement the Home Lead Hazard Reduction Component through the Multnomah County Health Department with an AmeriCorps program called CLEARCorps (Community Lead Education and Reduction Corps). This is a national demonstration project operating in several cites that focuses on targeted, feasible, and cost-effective solutions to reduce lead exposure in high-risk neighborhoods. It is directed nationally from the Shriver Center at the University of Maryland. The second attachment includes a description of how the CLEARCorps Program will be implemented in Portland, and it should be considered an updated description of the Home Lead Hazard Reduction Component.

1. Water Treatment for Corrosion Control

Corrosion control treatment for the Bull Run supply consists of raising water pH to about 7.3 in the distribution system, or slightly higher if needed to achieve the objective of meeting the copper action level. This level of treatment is expected to reduce lead and copper levels in standing water by 40 and 55 percent, respectively (EES, 1995). However, neither this level of treatment, nor the higher level of treatment defined as optimal by the LCR 6, is likely to result in the lead action level being met in water systems using the Bull Run supply 7 . Portland has installed a sodium hydroxide feed system, which has been operating since January 1997, to increase the pH of Bull Run water. The initial pH goal for water in the distribution system is in the range of 7.3-7.5 as a component of the Lead Hazard Reduction Program.

2. Expanded Free Lead-in-Water Testing Program

The purpose of this component is to identify customers within the Bull Run service area that may be at significant risk from elevated lead levels in drinking water and to assist them in reducing the risk of lead exposure from this source. Portland currently has a free lead-in-water testing program for its customers. This program would be expanded to include customers within the entire Bull Run service area. The program would also be expanded in terms of services provided. Currently, service is limited to mailing laboratory results with informational brochures. In the expanded program, customers whose tap water samples exhibit elevated levels of lead would be offered some level of assistance in determining the source of water lead and reducing lead exposure. The type and extent of assistance offered would depend on water lead level, but would be consistent with the LHRP the design objective to implement feasible and cost-effective methods of reducing lead hazards.

3. Home Lead Hazard Reduction Program

The purpose of this component is to prevent children from being exposed to hazards due to lead-based paint in their home environments. This program will operate in targeted Portland neighborhoods in which children are likely to be at greatest risk for home lead exposure. Parents in these neighborhoods will be offered individual home lead risk evaluations, child blood lead testing through the OCLPPP, and lead-safe education materials. In homes where significant lead exposure risks are identified, cost-effective in-place management or abatement techniques will be used to reduce lead-based paint hazards, including safe repair of deteriorated painted surfaces, repainting, specialized cleaning, and use of encapsulants. These techniques are consistent with the lead-based paint maintenance and hazard control standards for rental housing recommended by an HUD/EPA task force (HUD, 1995). In-home education and follow-up will be used to sustain the reduction. Work will be conducted by MCHD staff and AmeriCorps members certified as lead abatement workers, lead abatement supervisors, and/or lead inspectors. For the initial year of operation, the goal is to evaluate 350 homes and remediate 75 homes.

4. Lead Exposure Prevention Education

The purpose of this component is to provide primary prevention of lead exposure through public education and to increase the awareness of the entire community about lead health risks. Special efforts will be made to provide relevant information to those populations at greatest risk to lead exposure. Program messages would address multiple sources of lead exposure, not just water. Furthermore, program messages would be delivered to target audiences, especially those providing care to young children.

It should also be noted that, with the exception of corrosion control treatment, some additional development work is required before full implementation of the LHRP. We intend to develop and implement the LHRP according to the preliminary schedule provided in the Lead Hazard Reduction Program Report (EES and PWB, 1996) to the extent possible.

The Water Treatment Component of the LHRP will continue indefinitely. The Portland Water Bureau and its wholesale customers are committed to funding the other three components of the LHRP for a minimum of three years. During this period, much will be learned about the local occurrence of lead exposure risks and cost-effective ways to reduce those risks. This base of knowledge and experience gained through the LHRP will allow the Portland Water Bureau, local public health agencies, and community organizations to work together to develop a plan and the resources for sustained primary prevention of lead exposure in the Portland area.

Evaluation Criteria for Project XL Proposals

There are eight criteria for XL project selection presented in this proposal:

A discussion of "Superior Environmental Results" is closely related to a discussion of the "evaluation" of those results. Before presenting these in this proposal, a review of issues related to assessing effectiveness of interventions to reduce lead hazards is presented.

This information that follows is summarized from a recent EPA review of literature regarding the effectiveness of lead hazard interventions (EPA, 1995). Interventions include activities that attempt to remove or isolate a source of lead exposure as well as activities that attempt to modify behavior patterns. Interventions can be assessed for their effectiveness in lowering a child's body-lead burden or the levels of lead in his or her environment.

It is often not feasible to directly assess health benefits following intervention, as some outcomes may not manifest themselves for a long time, and can be subtle, complicated, and costly to measure directly. Blood lead concentrations can serve as a good surrogate health endpoint in some instances due to the established association between blood lead levels and adverse health effects. For example, in studies where interventions sought "secondary" rather than "primary" prevention (i.e., assessing the effectiveness of interventions on already poisoned rather than unexposed children), blood lead concentrations of exposed children have been used as the primary measure of intervention efficacy.

However, assessment is made more difficult when considering interventions targeted at children with low to moderate exposure (as would be the case with primary prevention projects, such as the proposed Lead Hazard Reduction Program.) When it is impractical or inappropriate to measure blood lead levels, levels in environmental media, such as dust lead levels can provide valuable information. Such measures cannot demonstrate an intervention's impact on affected children in terms of actual exposure or health effects, but they can be used to evaluate its effectiveness in reducing or eliminating a targeted lead hazard.

Currently, there is insufficient information available to identify a particular intervention strategy as markedly more effective than others. Comparable reductions in blood lead levels are observed resulting from the abatement of lead-based paint, and dust and soil at elevated lead levels, and in-home educational efforts. It is unclear whether more costly, large scale abatement strategies are more successful than less-expensive in-place management practices.

1. Superior Environmental Results

We believe that implementing the Lead Hazard Reduction Program will provide superior environmental performance by providing better public health benefits than would be achieved by strict adherence to corrosion control treatment and public education requirements of the Lead and Copper Rule. The superior performance would result from the Lead Hazard Reduction Program's design which is based on evaluation of existing local lead risk assessment data.

Demonstration of superior environmental performance involves comparison of benefits achieved by activities required by the LCR and those proposed in the LHRP:
 
 
 
 

Lead and Copper Rule 

vs.

Lead Hazard Reduction Program

Corrosion control treatment to minimize lead and copper in drinking water

vs.

Corrosion control treatment to reduce lead and copper in drinking water

+

Expanded free lead-in-water testing program

+

Home Lead Risk Reduction Program

Public Education Program focused on lead in drinking water

vs.

Public Education Program addressing a variety of lead exposure pathways

In order for the LHRP to provide superior environmental performance:

Consider first the potential benefits resulting from corrosion control treatment. As part of the study to evaluate alternatives for LCR compliance (EES, 1996; EES 1997), models were developed to estimate and compare the potential reduction in blood lead levels that would be obtained with "optimal" and reduced levels of corrosion control treatment. These models are relatively simplistic and make use of best available input data. Results are not intended to be interpreted on a precise quantitative basis, but rather should be used as indicators of potential reductions under various lead exposure scenarios.

It is likely that more people would experience greater blood lead reduction benefits with "optimal" treatment as compared to a reduced level of treatment. However, model results indicate that the difference in benefits may be relatively small, not only in terms the number of people affected, but also in terms of the magnitude of blood lead reductions and the actual health benefits realized.

The expanded free lead-in-water testing program and the high-risk neighborhood-based home lead risk reduction program would be expected to provide greater health benefits than the difference in benefits provided by "optimal" and reduced corrosion control treatment. This is because the LHRP's interventions are targeted to children who are at most risk of significant lead exposure, and are targeted at those exposure pathways that would have the greatest impact on a child's body lead burden. However, quantitative prediction of the reduction in blood lead levels due to the free lead-in-water testing program and the high-risk neighborhood-based home lead risk reduction program is not possible, primarily because they are primary prevention programs attempting to prevent rather than reduce significant lead exposures.

For these reasons, a rigorous quantitative "apples and oranges' comparison of benefits of activities required by the LCR and those proposed in the LHRP are essentially not feasible. However, the environmental performance of the LHRP can be assessed with a number of evaluation methods and measures described in the following section describing "Monitoring, Reporting, and Evaluation". Agreement on definitions and measures of superior environmental performance would be developed by stakeholders during the XL project development process.

Water systems nationwide incur significant costs in order to comply with Lead and Copper Rule requirements. In light of this investment, it would be interesting to evaluate the LCR for its environmental performance, i.e., assess its impacts on public health using direct measures (specific health effects) or indirect measures (blood lead levels) of performance.

2. Monitoring, Reporting, and Evaluation

The primary objectives, along with a brief description of evaluation methods and measures are summarized in the table below. Additional information is contained in the attachments.


LHRP Component

Primary Objective(s) 

Outcome Evaluation 

Corrosion Control Treatment

Reduce risks from exposure to lead and copper in tap water 

Track LCR-required lead and copper level data from "Tier 1" homes; track similar data from free lead testing program 

Determine if lead and copper levels are met

Track LCR-required lead and copper level data from "Tier 1" homes

Expanded Free Lead-in-Water

Testing Program


Identify buildings in which water may be a significant pathway for lead exposure 

Track information for buildings in which significantly elevated lead levels in standing water occur (e.g., location, plumbing system characteristics; lead levels in standing and running samples)

Reduce risks to residents through education or other assistance; sustain reduction with follow-up education

Track changes in resident behavior (tap flushing) or changes in plumbing system components through surveys/interviews

Home Lead Hazard Reduction in High-Risk Neighborhoods

Identify residences in high-risk neighborhoods in which lead-based paint may be a significant source of lead exposure

Track information for residences in which significantly elevated lead levels in blood, household dust, soil, or other samples occur (location, home age, owner or tenant occupied, maintenance condition, etc.) 

Reduce risks of lead exposure from lead-based paint sources in homes in high risk neighborhoods using cost-effective in-place management or abatement techniques; sustain reduction with follow-up education and monitoring. 

Track changes in dust lead levels and changes in resident behavior (maintenance practices) through follow-up monitoring and interviews.

Lead Exposure Prevention Education

Prevent lead exposure throughout the entire community by increasing awareness of lead health risks

Track changes in knowledge and attitudes about lead hazards though OHD's ongoing Behavior Risk Factor Surveillance Survey

Reduce risks to others at significant risk to lead exposure who are not elsewhere targeted in LHRP (e.g., remodelers not living in high-risk neighborhoods)

Track information distributed (content, extent of distribution, how distributed);

to the extent possible, track changes in knowledge and behavior in targeted groups. 

Evaluation of the Water Treatment Component will be conducted by the Portland Water Bureau as part of its LCR compliance activities and its supplemental monitoring of the distribution system.

Evaluation of the other components of the LHRP will be conducted by the Program Design and Evaluation Services (PDES) group, an interdisciplinary, inter-agency technical work group composed of public health professionals and research staff whose functions are to design and execute evaluations of public health projects, including designing interventions, crafting and implementing evaluation strategies, and disseminating evaluation results through technical reports and publications. The purpose of the team is also to provide interdisciplinary technical assistance regarding behavioral approaches to disease prevention and control. PDES activities are supervised jointly by the director of the MCHD Planning and Development unit and the OHD State Epidemiologist. PDES will assist in the formulation and implementation of the LHRP, and be primarily responsible for evaluation of the outcome of these components.

The outcome evaluation of the Home Lead Hazard Risk Reduction Component will add to the universal fund of knowledge about home lead hazards because it will address several areas where additional data is needed. In particular, information is generally lacking on the effectiveness of lead hazard interventions 1) that attempt to prevent elevated blood lead levels before they occur 2) among children with blood lead levels <= 20 ug/dL and 3) beyond one year following the intervention. It should be noted that about 30% of the initial year's operating budget for this component is for PDES evaluation services.

Specific monitoring, reporting, and evaluation methods would be agreed upon by stakeholders during XL project development and included in the Final Project Agreement.

3. Stakeholder Involvement and Support

The LHRP was developed as the Portland Water Bureau sought advice from local organizations involved in lead exposure issues to determine how it could best contribute to reducing lead hazards in the community as an innovative component of its regulatory compliance program. The idea was to supplement and/or complement efforts by other organizations with similar objectives and not duplicate existing efforts in the community. The LHRP was developed in partnership with members of a development committee through a series of workshops and numerous subcommittee meetings. The development committee included representatives from the following agencies and organizations: the Oregon Health Division (Drinking Water Program and Environmental Epidemiology Section); Multnomah, Washington and Clackamas County Health Departments; the Oregon Childhood Lead Poisoning Prevention Program; and the managers of the water systems purchasing water from Portland.

Community involvement and support from community-based organizations, businesses and individuals will be critical to the success of the LHRP program. We anticipate that the community will provide valuable advice and assistance in program development, implementation, review, and evaluation. The "community mobilization framework" approach will be applied in this project. This approach was used successfully by the CDC in demonstration projects in Portland and other cites to prevent HIV infection in women and children. This approach includes becoming familiar with the individual, social, and organizational roles and relationships in the community that might be useful in promoting awareness of lead safety issues, then developing a continuum of involvement ranging from simple endorsement of activities to building active coalitions. This approach offers the potential advantages of 1) extending limited resources of single agencies; 2) maximizing exposure to program through collaboration; 3) building on unique strengths and access channels or organizations and individuals in the community, and 4) allowing public health agencies to develop credible relationships with non-traditional community partners.

Portland is in the process of identifying and communicating with additional stakeholders to those who have been involved so far in LHRP development. These include local community members who have a direct interest in the program's outcomes - such as members of neighborhood organizations, businesses, local community health and environmental justice advocates, community development corporations, and those involved with low cost housing issues. These may include but are not limited to the following organizations:

African-American Health Coalition

Albina Ministerial Association

Black United Front

Center for Maternity and Family Support

Coalition of Community Clinics

Community Action Planning Office

Enterprise Foundation

Hispanic Roundtable

Host Development

Housing Authority of Portland

Housing Development Center

MultiFamily Housing Council

Oregon Housing Now Coalition

Portland Bureau of Housing and Community Development

Portland Development Commission

Portland Office of Neighborhood Associations

Reach Community Development

Rose Community Development

Urban League of Portland
 

Stakeholders also include those who may be interested in the broader implementation of such programs, including national public interest organizations such as the Alliance to End Childhood Lead Poisoning or the National Association for Lead Safe Housing.

These stakeholders may function as direct participants or commentors in project development, implementation, and review. We are in the process of identifying and contacting potential stakeholders to exchange information about what we are working on and learn what interests they may have in the project. We will use the input we receive to frame our ongoing community involvement process and develop a stakeholder involvement plan for Project XL.

The LHRP will strengthen the community by:

4. Innovation / Multi-Media Pollution Prevention

The Lead Hazard Reduction Program is an innovative alternative for Lead and Copper Rule compliance in that it attempts to contribute to the development of an integrated community response, both in terms of effort and financial resources, to an environmental and public health problem. Also, because the LHRP is tailored to local conditions, it can deliver better results than "one-size-fits-all" approaches that structure solutions through national mandates.

The being several fundamental differences between the Lead Hazard Reduction Program and Lead and Copper Rule approaches to lead risk reduction. First, the LHRP recognizes that children are exposed to lead from a variety of sources and through different pathways, not just water. Second, the LHRP was designed based on consideration of local lead risk assessment data. This allowed the program's interventions to be targeted to those persons who are at most risk of significant lead exposure, and to be targeted at those exposure pathways that have the greatest impact on a child's body lead burden in our local community. Third, the LHRP was designed to build on efforts by other organizations in the community with similar objectives.

Another innovative aspect of the LHRP is the plan to implement the Home Lead Hazard Reduction Program through the MCHD with an AmeriCorps program called CLEARCorps (Community Lead Education and Reduction). CLEARCorps members will conduct a number of activities, including providing individual home lead risk evaluations in targeted neighborhoods and, in homes where lead exposure risks are identified, providing in-place management with specialized cleaning, repair, repainting or using encapsulant products for reduction of lead-based paint hazards.

Also, the innovative "community mobilization framework" approach will be applied in this project. This approach was used successfully by the CDC in demonstration projects in Portland and other cites to prevent HIV infection in women and children, as discussed in the "Stakeholder Involvement and Support" section above.

5. Shifting of Risk Burden / Equitable Distribution of Environmental Risks

XL projects must be consistent with Executive Order 12898 on Environmental Justice, the intent of which is to prevent minority and low-income communities from being subject to disproportionately high and adverse environmental effects. In fact, this proposal is likely to have the greatest benefits for these communities of concern.

Children from low-income and/or ethnic minority families are more likely to show elevated blood lead levels than other children because their families are more likely to reside in older homes in deteriorated condition, lack money to undertake home and soil remediation, lack access to medical care, and lack knowledge of the lead exposure issues (CDC, 1997; Phoenix, 1993).

The OHD has developed an index to estimate the relative risk of lead exposure in the home environment in Multnomah County neighborhoods. The neighborhoods with the greatest lead exposure risks are located predominantly in north/northeast Portland, which are among the most ethnically diverse in the city and include the largest African-American, Native American, and Latino populations and the third largest Asian population in the city. Residents of north and northeast Portland communities are more likely to have children, live below the poverty level, be unemployed, live in pre-1950's housing, and less likely to have college degrees than other residents of Portland. Data from the OCLPPP also suggest that some subpopulations may be at higher than average risk, including children 2-3 years old, and African-American and Hispanic children.

The Home Lead Hazard Reduction Component of the Lead Hazard Reduction Program is specifically designed to prevent children from being exposed to hazards due to lead-based paint in their home environments in north and northeast Portland neighborhoods. By implementing this component of the LHRP, the disproportionate risk of lead exposure which currently exists in the Portland area will be reduced. Parents in these neighborhoods will be offered individual home lead risk evaluations, child blood lead testing through the OCLPPP, and lead-safe education materials. In homes where significant lead exposure risks are identified, cost-effective in-place management techniques will be used to reduce lead-based paint hazards and in-home education will be used to sustain the reduction.

6. Transferability

The LHRP can serve as a model strategy for other water systems interested in reducing lead exposure in their communities by targeting pathways and sources that otherwise would not be addressed under the Lead and Copper Rule. This LHRP also could serve as a model strategy for compliance with drinking water regulations that target other contaminants found in multiple sources and multiple exposure pathways in the environment (e.g., radon).

Additionally, in a recent review of literature regarding the effectiveness of lead hazard interventions, the EPA notes that information is lacking on the effectiveness of lead hazard interventions 1) that attempt to prevent elevated blood lead levels before they occur; 2) among children with blood lead levels <= 20 ug/dL; and 3) beyond 1 year following the intervention (EPA, 1995). Evaluation of results of the Home Lead Hazard Reduction Component of the LHRP will contribute to this fund of knowledge that will be useful to government agencies with public health missions and communities involved in lead-safety issues nationwide.

Lessons learned from implementation of this LHRP will be available to interested parties locally and nationally.

7. Feasibility

The Portland Water Bureau will be responsible for implementing the Water Treatment and the expanded Free Lead-in-Water Testing components of the Lead Hazard Reduction Program. Portland has installed a sodium hydroxide feed system, which has been operating since January 1997 to increase the pH of Bull Run water.

The Home Lead Hazard Reduction component will be implemented by the Environmental Health Section of the Multnomah County Health Department. The Lead Exposure Prevention Education component will be implemented through the Oregon Health Division and community-based organizations. Evaluation of the LHRP will primarily be conducted by Program Design and Evaluation Services, an interdisciplinary, inter-agency technical work group, jointly established by the Multnomah County Health Department and Oregon Health Division.

Contractual arrangements in the form of interagency agreements between the Portland Water Bureau and the Multnomah County Health Department and also the Oregon Health Division will include detailed work plans and budgets. The Portland Water Bureau has included the estimated $1.0 million cost of implementing the Lead Hazard Reduction Program in its FY 97-98 operating budget.

8. Cost Savings / Economic Opportunity

Implementation of the LHRP is expected to result in cost savings compared to strict adherence to the corrosion control treatment and public education requirements of the Lead and Copper Rule. As part of the LHRP, corrosion control treatment would be provided, but at a reduced level than that defined as optimal by the Lead and Copper Rule. These savings would be used to fund the other LHRP program components, including an expanded free lead-in-water testing program, a program based in high-risk neighborhoods to prevent children from being exposed to lead-based paint hazards in their home environments, and a community primary prevention education program. Preliminary cost estimates indicate that the LHRP could result in a capital cost savings up to $2 million and an additional $200,000 or more per year in operating costs, benefiting water ratepayers in the Portland area. Indirect cost savings or valuable benefits for the community such as reduced cost of treatment of lead-poisoned children and increase in the stock of "lead-safer" housing are not included in this estimate.

The Home Lead Hazard Reduction component and the Lead Exposure Prevention Education component of the LHRP will initially be implemented through the Multnomah County Health Department and Oregon Health Division. However, with increased lead-safety awareness in the community, other alternatives with local economic opportunities may emerge with time. For example, existing community-based organizations may wish to expand their activities, or new organizations may be formed specifically to engage in lead hazard reduction activities.

List of References

CDC (Centers for Disease Control and Prevention). Preventing Lead Poisoning in Young Children: A Statement by the Centers for Disease Control. Atlanta, GA. October 1991.

CDC (Centers for Disease Control and Prevention). Updated Blood Lead Levels in the United States. Morbidity and Mortality Weekly Report: Vol 46, No. 7. February 1997.

EES (Economic and Engineering Services). Comprehensive Evaluation of Alternatives for Lead and Copper Rule Compliance. Portland, OR. August 1995.

EES (Economic and Engineering Services) and PWB (Portland Water Bureau). Lead Hazard Reduction Program Report. Portland, OR. December 1996.

EES (Economic and Engineering Services). Comprehensive Evaluation of Alternatives for Lead and Copper Rule Compliance, Technical Memorandum No. 1: Models for Lead Exposure Through Portland's Drinking Water. Portland OR. [expected April 1997].

EPA (US Environmental Protection Agency, Office of Pollution Prevention and Toxics). Review of Studies Addressing Lead Abatement Effectiveness. EPA Report No. 747-R-95-006. July, 1995.

Federal Register. Maximum Contaminant Level Goals and National Primary Drinking Water Regulations for Lead and Copper; Final Rules. Vol 56, No 110, p. 26460-26564. June 7, 1991.

HUD (U.S. Department of Housing and Urban Development). Summary Lead-Based Paint Hazard Reduction and Financing Task Force. 1995.

Montgomery Watson and EES (Economic and Engineering Services). Lead and Copper Corrosion Control Study for the Portland Water Bureau and Participating Wholesale Customers. Portland, OR. June 1994.

OCLPPP (Oregon Childhood Lead Poisoning Prevention Program). Status Report to the OCLPPP Task Force. Portland, OR. 1994.

OHD (Oregon Health Division, Occupational, Environmental, and Injury Epidemiology Section). Oral communication from R. Leiker to B. Faris based on review of STELLAR lead exposure surveillance data base. Portland, OR. March 1997.

Person, B., and Cotten, D. A Model of Community Mobilization for the Prevention of HIV in Women and Infants. Public Health Reports 1996; Vol 111, Supplement 1, pages 89-98.

Phoenix, J. Confronting Environmental Racism in Getting the Lead Out of the Community, Bullard, R. Ed. South End Press. 1993

PWB (Portland Water Bureau). Interoffice memorandum from M. Sheets. Portland, OR. March 12, 1997

Proposal for Project XL

City of Portland Bureau of Water Works


Date: March 21, 1997

Sponsored by: City of Portland Oregon

Bureau of Water Works

1120 S.W. 5th Avenue

Portland, OR 97204-1926

Submitted in The Oregon Health Division and association with: The Multnomah County Health Department

Environmental Problem Addressed by the Project:

Childhood lead exposure from a variety of sources and through a variety of pathways in our community

Description of Project:

The Portland Water Bureau seeks regulatory flexibility in compliance with the Lead and Copper Rule promulgated under the Safe Drinking Water Act. Specifically, we propose to implement a comprehensive Lead Hazard Reduction Program as an alternative to the optimal corrosion control treatment and public education requirements of the Lead and Copper Rule. This program is designed based on local lead risk assessment data and recognizes that children are exposed to lead from a variety of sources through variety of pathways. The Program's interventions are targeted to children who are at most risk for lead poisoning and are targeted at those exposure pathways that would have the greatest impact on a child's body-lead burden.

Project's Anticipated Results:

The Lead Hazard Reduction Program is expected to provide greater public health protection from lead exposure in our community, at an equivalent or lower cost, than would be obtained by strict adherence to Lead and Copper Rule requirements.

Contacts:

Rosemary Menard Babette Faris, P.E.

Director, Water Resources Mgmt Water Quality Engineer

Phone: (503) 823-7792 Phone: (503)823-7498

Fax: (503) 823-6133 Fax: (503)823-6133

E-mail: rmenard@water.ci.portland.or.us E-mail: bfaris@water.ci.portland.or.us


NOTES:

  1. The lead action level is met if the concentration of lead in at least 90% of standing tap water samples, collected from a group of sites with LCR-specified characteristics, is less than or equal to 0.015 mg/L. Similarly, the copper action level is met if the concentration of copper in at least 90% of samples is less than or equal to 1.3 mg/L.
  2. 1st round of monitoring: 90th percentile lead and copper values = 0.044 and 1.8 mg/L 2nd round of monitoring: 90th percentile lead and copper values = 0.053 and 1.3 mg/L
  3. Comprised of 9 members of the public representing various community interests
  4. Comprised of the 19 managers of water systems purchasing Portland water on wholesale basis
  5. By way of comparison, for the city of Portland, the median concentration of lead in standing samples is estimated at 0.006 mg/L and the 90th percentile concentration is estimated at 0.026 mg/L (EES and PWB, 1996).
  6. Portland s LCR-required corrosion control study (Montgomery Watson and EES, 1994) indicated that lead and copper concentrations could be minimized in the distribution system by increasing Bull Run water pH from approximately 6.8 to pH 9.0-9.5 and increasing alkalinity from 6-12 mg/L to at least 25 mg/L as CaCO3.
  7. Based on 1) distribution of standing lead levels at customers  taps for LCR-required initial monitoring in 1992 and 2) estimate that LCR-defined optimal treatment (pH 9.0-9.5, alkalinity >=25 mg/L as CaCO3) would reduce lead and copper levels in standing water by 70 and 80 percent, respectively (EES, 1995).


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