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July 16 1997 Memorandum to Bill Glasser from Rosemary Menard

MEMORANDUM
WQ 1.11.1

DATE: July 16, 1997

TO: Bill Glasser, Project XL EPA Region 10

FROM:Rosemary MenardDirector, Water Resources Management Group

SUBJECT: XL Community Pilot Program, Portland Water Bureau Proposal Response to Recent Questions
 

In June, I had the opportunity to meet with EPA Headquarters staff to discuss our XL proposal. A set of questions, listed below, was presented at this meeting. In this memo, we are providing brief responses to these questions. Some of these responses refer to one or more of the following documents:

  1. Proposal for Project XL - March 21, 1997
     
  2. Lead Hazard Reduction Program Report - December 12, 1996
    (submitted with XL proposal)
     
  3. Updated description of the Home Lead Hazard Reduction Component of the Lead Hazard Reduction Program - March 13, 1997 (submitted with XL proposal)
     
  4. Technical Memorandum 1: Health Models for Lead Exposure through Portland's Drinking Water - June 1997 (submitted in June)
     
  5. Comprehensive Evaluation of Alternatives for Lead and Copper Rule Compliance, Draft Final Report - August 1995.
We look forward to, in the near future, discussing these and other additional questions that may be raised by the EPA's review of our XL proposal.
 

1. How will the potential adverse health effects to other sensitive populations (non-crawling infants, pregnant women, other adults at risk) through the drinking water pathway be addressed through this project?

As described in the Lead Hazard Reduction Program (LHRP) Report, our proposed program consists of four main components:

  1. Water Treatment for Corrosion Control
     
  2. Expanded Free Lead-in-Water Testing
     
  3. Home Lead Hazard Reduction
     
  4. Lead Exposure Prevention Education
     
Reduction of potential risks posed by lead in drinking water are addressed by Components 1, 2, and 4 as described in our XL proposal and the Lead Hazard Reduction Program Report. Briefly, limited corrosion control treatment is expected to reduce lead levels in standing water by about 40% as compared to levels before treatment. Through the expanded free lead-in-water testing program, sites with elevated lead levels at the tap will be identified; customers at these sites will be offered assistance in reducing exposure, including plumbing system inspection and education. The purpose of the Lead Exposure Prevention Education program is to effectively provide information about multiple sources of lead exposure for those at greatest risk of these exposures.

Lead exposure through Portland's drinking water and related health effects are described in Technical Memorandum 1 referenced above.
 

2. How has the Water Bureau figured in the cost of not doing optimal corrosion control (for example, the added cost of purchasing point-of-use treatment devices, increased water consumption by consumers due to flushing taps and the deterioration of pipes due to corrosive water)?

The Water Bureau has not attempted to estimate the cost incurred by its customers for purchase of treatment devices for lead and copper or tap flushing. As indicated in Technical Memorandum 1, we estimate that prior to corrosion control treatment, about 95% of the running water samples and about 70% of the standing water samples in Portland would meet the FDA standard of 5 ug/L of lead in bottled water. With limited corrosion control treatment now being provided, these percentages are expected to increase.

The incremental cost of treatment devices and flushing due solely to provision of limited, as compared with optimal, corrosion control treatment would almost certainly be negligible compared to the cost of other program components.

Regarding pipe deterioration, the Comprehensive Evaluation of Alternatives report referenced above indicates that corrosion control treatment would probably provide little realizable economic benefit due to extension of pipe life, except perhaps for owners of large commercial buildings in which new galvanized steel pipe is installed. We therefore would expect few incremental economic benefits resulting from optimal, as compared to limited, corrosion control treatment.
 

3. What would happen after the three-year period proposed for the Home Lead Hazard Reduction Program, the Lead Exposure Prevention Education, and the Expanded Free Lead-in Water Testing Program? Would there be a commitment to continue this work beyond the three-year period?

Corrosion control treatment (Component 1) is expected to continue indefinitely.

Expanded free lead-in-water testing (Component 2), home lead hazard reduction, (Component 3), and lead exposure prevention education (Component 4) were developed in conjunction with state and county public health agencies based on consideration of the current assessment of the type and extent of local lead risks, the best means of addressing those risks, and availability of community resources to address those risks.

These components will be funded by the Portland Water Bureau and its wholesale customers for at least three years. The continuation of each component would be decided based on revised assessment of prevalence of risk due to various sources of lead, and effectiveness of these LHRP components in reducing these risks. The level of continued funding of desirable community lead hazard reduction activities by the Portland Water Bureau and its wholesale customers would be determined considering the availability of other community resources to address those risks.
 
 

4. Would you provide us additional information on how the lead abatement program would work? How would the impacts of the intervention be measured?

In order to respond to this question, it would be helpful to know what specific additional information is requested. The current plan for the Home Lead Hazard Reduction component, including measures of evaluation, is described in the main body of the XL proposal and the CLEARCorps update submitted with the proposal.

The Home Lead Hazard Reduction component was intentionally not developed in great detail for the XL proposal. We anticipate that the program details will be developed based on input from the local community, guidance from the CLEARCorps program, and discussions with the EPA regarding development of an XL final project agreement. We also expect that program will evolve based on knowledge gained from our own implementation experience and from experiences of other communities throughout the nation implementing similar projects.

The National CLEARCorps Program's grant renewal application was recently approved by the Corporation for National Service for FY 98. This month, staff from the national CLEARCorps program will begin working with the Portland CLEARCorps Site Director and local stakeholders to further develop the program for implementation this fall.
 

5. Children are not only exposed to lead in the home. How would high lead levels through drinking water in public buildings (e.g., schools, day care centers) be addressed through the proposed project?

Same response as for Question 1.
 

6. The proposal presents the results of LCR monitoring done in 1992. Has the Water Bureau completed any additional monitoring since 1992? Has the Water Bureau conducted monitoring since limited corrosion control was installed?

During the first week of June, the Portland Water Bureau and its wholesale customers conducted their first round of follow-up monitoring for lead and copper at customer taps, as described in our joint monitoring plan approved by the Oregon Health Division (OHD). Results from this required round of monitoring and required monitoring in 1992 are summarized below.
 

1997

after "limited" control treatment 

Portland and Wholesale Custs 

90th %tile value

Round 1

 1992 

before treatment

Portland

90th %tile value

Round 1
 
 
 
 

Round 2
 
 
 

Action Level
Lead (mg/L) 0.012  0.044 0.053 0.015
Copper (mg/L) 0.65 1.8 1.3 1.3

7. We have gotten some information on the status of lead service lines in the Water Bureau service area - through staff here at EPA who have some knowledge of the infrastructure in Portland and through your letter of 6/13/94 to Carol Browner, stating that "portland's water distribution system is essentially free of significant sources of lead. There are no lead pipes or service lines within our distribution system network, and any remaining lead pigtails will be removed by 1995." We understand that the scheduled completion date for removal of the remaining pigtails has been moved back. What is the new scheduled completion date?

Since 1984, the Portland Water Bureau has removed more than 9,600 lead pigtails from its distribution system. By June 30, 1998, an additional 1500 remaining lead pigtails will be removed. Approximately 200 additional pigtails, primarily located in commercial and industrial areas, will still exist in the system on this date because substantial difficulties, including excavation in major arterial roadways, are associated with their removal. They will be removed as soon as possible after June 30, 1998. We are working with the OHD to evaluate the need for interim measures to provide equivalent health protection for these cases.
 

8. In determining whether XL projects meet the Superior Environmental Performance (SEP) criteria the Agency relies heavily on assessment of the current baseline for proposed project activities. Several reviewers

commenting on your proposal have asked for addition information on lead abatement and remediation activities currently underway in Portland (your proposal states that the LHRP will augment existing efforts). Would you supply us with that additional information?

Our proposal states that one of the Lead Hazard Reduction Program design concepts is to supplement or complement efforts performed by other organizations with similar objectives, including State and County health agencies and community-based groups.

In the past several years, the Oregon Childhood Lead Poisoning Prevention Project, funded by a grant by the Centers for Disease Control, focused efforts on blood lead level screening of children, and community education. Also, the OHD and County Health Departments record and follow-up on reports of elevated blood lead levels.

Currently, there are no programs within the Bull Run Service area for lead-based paint hazard evaluation and control in housing. Because of this current void, state and county public health agencies recommended development and implementation of the home lead hazard reduction component of the Lead Hazard Reduction Program. This component would represent the first organized effort in the Portland area for lead-based paint hazard evaluation and control in housing.

The City of Portland and the Multnomah County Health Department are currently preparing a grant application to the U.S. Department of Housing and Urban Development for funding of a more extensive lead-based paint hazard control program. If funded, the HUD-sponsored program would be an ideal supplement to the Lead Hazard Reduction Program.
 

9. In addition to asking for flexibility for the water treatment portion of the LCR, your proposal also requests flexibility for the public education requirements of the Rule. What does this flexibility entail? What would be the content of the public education campaign for drinking water and who would it be directed toward?

The current plan for Lead Exposure Prevention Education component is described in the Lead Hazard Reduction Program Report. This component was intentionally not developed in great detail for the XL proposal. Similar

to the response for Question 4, we anticipate that the program details will be developed in consultation with state and county public health agencies, the Oregon Drinking Water Program, the EPA as part of the process of developing an XL final project agreement, and other interested community stakeholders.

Under the Lead and Copper Rule, water systems are not required to implement a public education program if lead action levels are met in the most current round of monitoring, as in currently the case for Portland. It should be noted that the lead exposure prevention education component will be implemented whether or not the lead action level in drinking water met, because this component is important for primary prevention of significant lead exposure from lead-based paint and other significant sources of lead exposure.
 

10. How will be the XL Project proposed by the Portland Water Bureau affect the entire service area? What does the Bureau envision for the entire service area? Will the entire service area be covered by the lead abatement and remediation activities? It appears from your proposal the Home Lead Hazard Reduction component will be limited to target neighborhoods in the north and northeast Portland. If this component of the LHRP is not extended outside the City of Portland, are the 14 water systems that purchase water from the Bureau prepared to install corrosion control treatment to optimize lead and copper levels for the consumers in their systems? To what extent have the systems purchasing water been included as stakeholders in the development of the proposal?

Because the Lead Hazard Reduction Program is risk-based, all four components will not be implemented uniformly throughout the water service areas of Portland and its wholesale water customers. Corrosion control treatment (Component 1) and free lead-in-water testing (Component 2) will be provided throughout the Bull Run service area. Home lead hazard reduction (Component 3) will be provided only in the highest risk neighborhoods within the Bull Run service area, which according to the Oregon Health Division, are located within the City of Portland. The various elements of lead exposure prevention education (Component 4) will be provided throughout the Bull Run service area.

As indicated in our XL proposal and the Lead Hazard Reduction Program report, the Water Managers Advisory Board (consisting of the managers of water systems using water supplied by Portland) has participated in the development of, and has formally expressed support for, this program.
 

11. The LHRP addresses a number of lead sources in the attempt to minimize lead exposure to sensitive populations. The Lead and Copper Rule requires water systems to optimize for both lead and copper. In your proposal, it is stated that a pH of 7.3 will reduce copper levels by 55% whereas a pH of as 9-9.5 will reduce copper levels by 80%. Has the Bureau considered a free copper testing program to address those homes where drinking water copper levels are not optimized?

The Portland Water Bureau provides free water testing for a number of constituents, including copper, to customers with specific water quality concerns.

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