United States     Office of Research and  Office of Environmental EPA/625/R-00/012
   Environmental Protection Development      Information      January 2001
   Agency        Washington, DC 20460  Washington, DC 20460 http://www.epa.gov/empact
   Lead-Safe Yards
   Developing and Implementing a
   Monitoring, Assessment, and
   Outreach Program for Your
   Community
       •
    J&ead (Safe 9/W cProjecl
    E  M   P A  C  T
Environmental Monitoring for Public Access

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DISCLAIMER
This document haas been reviewed by the U. S. Environmental Protection Agency (EPA) and approved for publication.
Mention of trade names or commercial products does not constitute endorsement or recommendation of their use.

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                                    EPA/625/R-00/012
                                    January 2001
             Lead-Safe Yards
    Developing and Implementing a
Monitoring, Assessment, and Outreach
      Program for Your Community
            United States Environmental Protection Agency
              National Risk Management Laboratory
              Office of Research and Development
                   Cincinnati, OH 45268
                                    100% Recycled/Recyclable
                                    Printed with vegetable-based ink
                                    on paper that contains a minimum
                                    of 50% post-consumer fiber.

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This  technology transfer  handbook is  intended  to  serve  as:  a)  a  case  study  of  the
EMPACT  Community-Based Lead  Assessment and  Educational Pilot Project  in  Boston (also
known as the Lead-Safe Yard Project or LSYP) that highlights the successes and lessons learned from
the project,  and b) a "hands on"  reference  for  community  members,  especially community
organizations, to  use  in identifying  and  reducing  risks from  residential soil  that  may be
contaminated with lead. The emphasis is on contamination from non-industrial sources, such as
the historic use of exterior house paint or gasoline that contained lead. The handbook provides
step-by-step guidance for measuring lead levels in soil, interpreting results in terms of potential risks
from these  levels, and planning and implementing simple and cost-effective landscaping techniques
to reduce these risks. While the focus is on  community organizations with access to professional
assistance, some recommendations may be  suitable for the individual homeowner, landlord, or ten-
ant to consider.

Based on  the case study from the  Pilot  Project  in  Boston,  the handbook was written to be
complementary to, and used in conjunction with, EPA and HUD  regulations and associated guid-
ance.  In particular, EPA has proposed a regulation entitled  "TSCA Title  IV, Section 403 Lead;
Identification of Dangerous  Levels of Lead." At the time of the handbook's publication, this rule,
which establishes standards for lead-based paint hazards in most pre-1978 housing and child-occu-
pied facilities, was not yet finalized. Nothing in the handbook should be construed as official
Agency guidance or regulation contradictory to the Final Section 403 Rule.

These simple, low-cost landscape treatment  measures  are presented as additional options beyond
the permanent  measures that may be  required by state, local, or federal  regulations. For cases
in which permanent solutions such as soil removal  would be preferable and/or required,  but
are not immediately possible due to cost  or other practical  considerations, the handbook offers
interim controls that may provide an immediate risk reduction, especially when combined with
continuing  maintenance  practices.  Users of the  handbook  should consult  applicable  state,
local, and federal regulations before deciding on any course of action.
                                                                                                 PREFACE

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                                                                           Page

CHAPTER 1  INTRODUCTION	  1
    1.1    About the EMPACT Program	  2
    1.2    About the EMPACT Lead-Safe Yard Project	  3
    1.3    About This Handbook	  5
    1.4    Acknowledgments	  6
    1.5    For More Information	  6

CHAPTER 2   HOW TO USE THIS HANDBOOK	  9

CHAPTER 3   LEAD IN SOIL: WHY IS IT A PROBLEM?	 11
    3.1    Lead and Lead Poisoning	 11
    3.2    Sources and Levels of Lead in Soil	 14
    3-3    Soil as an Exposure Pathway for Lead	 16
    3.4    Standards and Guidelines for Lead Poisoning Prevention	 17
    3-5    For More Information	 25

CHAPTER 4   BEGINNING THE PROGRAM	 29
    4.1    Program Structure: Overview of a Lead-Safe Yard Program	 29
    4.2    Selecting Program Partners	 30
    4.3    Identifying Potentially Impacted Communities	 32
    4.4    Getting to Know the Community	 33

CHAPTER 5   COMMUNICATING ABOUT LEAD IN SOIL
               AND YOUR  LEAD-SAFE YARD PROGRAM	 35
    5.1    Approaching Homeowners and Residents	 35
    5.2    Educating People About  Lead and Lead in Soil	 36
    5.3    Next Steps: Enlisting the Homeowner in the Program	 37
    5.4    For More Information	 39

CHAPTER 6   COLLECTING AND MANAGING
               DATA ON LEAD IN SOIL	 67
    6.1    Collecting and Managing Data: An Overview	 67
    6.2    Getting Started	 70
    6.3    Testing Step by Step	 70
    6.4    Health and Safety Precautions	 74
    6.5    Maintaining Equipment	 75
    6.6    Alternative Approaches	 77
    6.7    For More Information	 77

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                                                                   Page

CHAPTER 7  LEAD IN SOIL: WHY IS IT A PROBLEM?	  83
   7-1    Matching Treatments to Hazards	  83
   7-2    Treatment Options and Detailed Specifications	  87
   7-3    Developing a Budget for Each Yard Treatment	  92
   7-4    Homeowner Design Session	  93
   7-5    Contracting With a Landscaper	  94
   7-6    Health and Safety for Landscapers	  95
   7-7    Approval and Signoft on Work Complete	  97
   7.8    Handing Over the Case File	  97
   7.9    For More Information	  98

CHAPTER 8 YARD MAINTENANCE	111
   8.1    The Importance of Yard Maintenance	 Ill
   8.2    Maintenance Requirements for EMPACT Treatment Measures	 Ill
   8.3    Developing a Property-Specific Maintenance Manual	 Ill
   8.4    Educating Homeowners About Yard Maintenance	 112
   8.5    Strategies for Encouraging Ongoing Maintenance	 112

CHAPTER 9  EVALUATING YOUR LEAD-SAFE
             YARD PROGRAM	123
   9-1    Focusing Your Evaluation	 123
   9-2    Documenting Evaluation Points	 123

CHAPTER 10 NON-RESIDENTIAL APPLICATIONS OF
             LEAD-SAFE YARD MITIGATION STRATEGIES	127

APPENDIX A SAFER SOIL PILOT PROGRAM
             OF CAMBRIDGE, MASSACHUSETTS	129

APPENDIX B SOME PROPOSED MODELS FOR LESS-
             RESOURCE-INTENSIVE APPROACHES
             TO IMPLEMENTING LEAD-SAFE YARD
             PROGRAMS	133

APPENDIX C FUTURE OPTIONS—USING PLANTS
             TO TREAT LEAD-CONTAMINATED SOILS	135

APPENDIX D QUALITY ASSURANCE PROJECT PLAN FORA
             COMMUNITY BASED ENVIRONMENTAL LEAD
             ASSESSMENT AND REMEDIATION PROGRAM	139

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1
                                        INTRODUCTION
                                                          onmental
Over the past few decades, blood lead levels in children have
declined dramatically. However, lead poisoning remains a seri-
ous environmental health threat for children today. The legacy
of lead-based paint and leaded gasoline will be with us  for
many years to come. Without further action, large numbers of
young  children, particularly in older, urban neighborhoods,
will  continue to  be exposed  to  lead in amounts that could
impair their ability to learn and to reach their full potential.

Recent efforts at the state and federal levels to reduce childhood
lead poisoning have focused primarily on controlling hazards
from lead-based  paint. This focus is likely to  continue. In
February 2000, the Presidents Task Force on Environmental  Health Risks and Safety Risks to
Children released a federal, interagency strategy  for eliminating childhood lead poisoning. The
strategy calls for the control of lead paint hazards in 2.3 million homes where children under age 6
live (you can access the strategy at http://www.epa.gov/children/whatwe/leadhaz.pdf). To support
the Task Force's recommendations, the federal budget for 2001 includes a 50-percent increase in
lead paint hazard control grants issued  by the  U.S.  Department  of Housing and  Urban
Development (HUD).

While considerable attention has been given to lead-paint hazards in homes, less attention has been
paid to lead-contaminated soil that surrounds these homes. Generally, this has been because of the
more significant contribution to  lead poisoning in children made by deteriorated lead paint and
leaded  dust on the interiors of homes. However,  evidence exists that soil can be a source of expo-
sure. As lead poisoning rates decline and average childhood blood lead levels decline, lead exposure
from soil may be a more significant portion of the exposure for children. Therefore, it warrants
attention.

This EMPACT technology transfer handbook is  designed with two main goals in mind. The first
goal is to present a case study showing how one community-based program—the EMPACT Lead-
Safe Yard Project (LSYP)  in Boston, Massachusetts—is using a variety of low-cost  techniques to
reduce children's exposure to elevated levels  of lead in residential soil. The second—and perhaps
more important—goal is to provide you with step-by-step guidance for developing  a similar pro-
gram to address the problem of lead in soil in your own community. The guidance in the handbook
is based on the experience  of the  EMPACT LSYP, as well as that of several other programs. These
other programs are highlighted at points throughout the handbook.

The handbook is written primarily for community organizers, non-profit groups, local government
officials, tribal officials, and other decision-makers who will implement, or are considering imple-
menting, lead-safe yard programs. At the same time,  much of the information  will be useful to
individual homeowners interested in finding low-cost ways to reduce children's exposure to lead in
soil. Before attempting to implement the techniques described in this handbook, however, home-
owners need to be aware of the hazards associated with working with lead-contaminated soil. All
homeowners should carefully read those passages  of the handbook that describe soil-lead hazards,
                                                     1 li
                                                        NTRDDUCTON

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          safety guidelines for working with lead-contaminated soil, and federal and state regulations gov-
          erning acceptable work practices (in particular, see Sections 3-1, 3-3, 6.2, 6.4, and 7-6).

           1,1       ABOUT          EMPACT PROBRAM
          This handbook was developed by the U.S. Environmental Protection Agency's (EPA's) EMPACT
          Program (http://www.epa.gov/cmpact). EPA  created EMPACT (Environmental  Monitoring for
          Public Access and Community Tracking) in 1997, at President Clinton's direction. It is now one of
          the programs within EPA's Office of Environmental Information. EMPACT is a new approach to
          providing timely environmental information  to communities across the  nation, helping people
          make informed,  day-to-day decisions. By the year 2001, residents in 86 of the largest metropolitan
          areas in the United  States will have an easy way to  answer questions such as:

              • What is the ozone level in my city this morning?

              • What is the water quality at my beach today?

              • How high is the ultraviolet radiation in  my city today?

              • What is the level of contamination at the hazardous waste site in my community?

              • What are the levels of lead in the soil in yards in my neighborhood?

          To  help make  EMPACT  more  effective, EPA  is  partnering with  the  National  Oceanic and
          Atmospheric Administration, the U.S. Geological Survey, the U.S. Department of Interior, and the
          National Partnership for Reinventing Government. EPA will work closely with these federal enti-
          ties  to  help achieve  nationwide  consistency in  measuring  environmental  data, managing
          information, and delivering that information to the public.

          To date, environmental information projects have  been  initiated in 84 of the 86 EMPACT-desig-
          nated metropolitan areas. These  projects  cover a wide range of environmental issues,  such as
          groundwater contamination, ocean pollution, smog, ultraviolet radiation, and ecosystem quality.
          Some of these projects  have been initiated directly by  EPA. Others  have been  launched by the
          EMPACT communities themselves. Local governments from any of the 86 EMPACT metropoli-
          tan areas are eligible  to apply for EPA-funded Metro Grants to develop their  own EMPACT
          projects.

          Communities selected for Metro grants are responsible for building their own time-relevant envi-
          ronmental monitoring and information delivery systems. To find out how to apply for a Metro
          grant, visit the EMPACT Web site at http://www.cpa.gov/empact/apply.htm.

           1.2,                 THE  EMPACT                    YARD  PROJECT
          During the winter of 1998,  EPA's EMPACT program funded  "A  Community-Based  Lead
          Assessment  and Educational Pilot  Project,"  also  known  as the  Lead-Safe Yard  Project
          (http://www.epa.gov/region01/lcadsafc). The project is a joint effort between EMPACT, EPA's New
          England Regional Laboratory, and several community partners. The three primary objectives of the
          project are:

              1) To generate real-time data of lead concentrations in residential yard soils using innovative
                 field-portable x-ray fluorescence (XRF) technology, and to  communicate these data to resi-
                 dents for the purpose of informing them of the health risks of lead in soil.
1 INTRODUCTION

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                     DmOltf Sin*!
                   Tkrprt Community
                                              City of Boston
                                              Lead Poisoned Children
                                              Venous >  15ug/dL
                                              FY1985-1993
    2) To plan and implement low-cost and sustainable landscape measures in residents' yards
      that would reduce children's risk of exposure to contaminated soil and that residents
      would be taught to maintain.

    3) To develop a template that other communities and public agencies can use to address the
      issue of lead in residential soil.

The initial target community selected for the pilot project was a several-block area in the Bowdoin
Street neighborhood,  consisting  of approximately 150 mostly older, wood-framed houses in the
North Dorchester section of Boston. This is an inner-city community, with a large minority and
immigrant population. Bowdoin Street is situated in the "lead belt" of Boston, where the majority
of children in the city with elevated blood levels reside.

During the pilot phases, the project's  community partners in the Boston area were Boston
University School of Public  Health, the Bowdoin Street Community Health Center, and a  non-
profit landscaping company  called Dorchester Gardenlands Preserve. The project team identified
five tasks to be carried out by the partners:

    •  Outreach and education, led by the Health Center.

    •  Safety training, conducted  by staff from the Health Center.

    •  Sampling and analysis, led  by the EPA Regional Laboratory with assistance
      from  a certified  industrial hygienist from  the Health Center.
                                                                                        INTRODUCTION

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              • Soil mitigation, performed by the landscaping company.

              • Creation of a template for community action, led by Boston University School
                of Public Health with assistance from all partners.

          The pilot project was funded in two phases, which took place in the summers of 1998 and 1999-
          During these two  years, the project addressed 42 residences in the target area, at no cost to the
          homeowners; conducted a number of seminars on lead-safe yard work; and developed a ''Tool Kit"
          for use by other communities (the materials in the Tool Kit have been incorporated into this handbook).

          The third phase of the project, launched  in June 2000, is targeting a different community: the
          Dudley Street neighborhood, which is also  located in the "lead belt" of Boston. The partners in this
          phase  include Boston University  School  of Public Health, the Dudley Street Neighborhood
          Initiative (a local planning and organizing agency), and several commercial landscapers. The objec-
          tive of this phase is to use refined  landscape measures and an improved educational approach in
          treating yards of homes that meet requirements for structural lead abatement of interior and exte-
          rior  paint, or  that have already been lead abated  and are lead safe. As of September 2000,  18
          homeowners had enrolled to have their yards tested for elevated soil-lead levels, and testing had
          been completed at most of the properties. The project's goal is to  complete soil testing and imple-
          ment landscape treatments at 20 or more properties by the end of the year.

           I.Z.I  RELATED  LEAD-SAFE YARD
          A key objective of the EMPACT LSYP  is  to disseminate a template of materials and methods to
          public agencies whose mission is to prevent childhood lead poisoning. The ultimate goal is to insti-
          tutionalize soil remediation as  part of  a  comprehensive lead  poisoning prevention program in
          high-risk neighborhoods.

          Based on the success of the pilot phase of the EMPACT LSYP, the City of Boston has already ini-
          tiated two "spinoff" soil-lead programs, using the EMPACT project's template:

              • Lead Safe Boston, an office within the Boston Department of Neighborhood Development
                that assists homeowners financially and technically in home de-leading, is spearheading a
                HUD-funded lead-safe yard project that will target as many as 25 residential properties by
                the end of 2000. This demonstration project is meant to show how local government agen-
                cies can integrate soil-lead mitigation into  ongoing home de-leading work.  As  of September
                2000, Lead Safe Boston had enrolled 20 properties for soil-lead testing and yard treatments,
                and had completed treatments at nearly half of the properties. Lead Safe Boston has  also
                done extensive work to revise  materials in the EMPACT LSYP's template (such as permis-
                sion forms and contractor agreements) to meet the more rigorous legal standards required
                of a city agency. Many of the materials developed by Lead Safe Boston appear as samples in
                this handbook.

              • The Office of Environmental  Health, part of the Boston Public Health Commission
                (BPHC), initiated another spinoff lead-safe yard project in the year 2000 to address  nine
                residential properties in an area of North Dorchester. These nine  residences have previously
                undergone structural abatement of lead paint and are slated for yard intervention utilizing
                the EMPACT LSYP's template.  BPHC is leading the outreach effort and funding the land-
                scaping work. EPA's New England Regional Laboratory is providing testing support, and
                Lead Safe Boston is assisting with contract services.
1 INTRODUCTION

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   EMPACT LEAD-SAFE YARD
  PROJECT RECOGNIZED FOR
           EXCELLENCE

Because of the EMPACT LSYP's
innovative approaches and far-reaching
impacts, project partners have received
several prestigious awards for their work.
These include:
• 1999 Regional Science Award. The
  EPA Region 1 Science Council selected
  for this award Rob Maxfield and Paul
  Carroll, both from EPA's Office of
  Environmental Measurement and
  Evaluation, for their work on the
  EMPACT LSYP. The award noted that
  these scientists "demonstrated
  environmental leadership and utilized
  innovative yet simple solutions
  to this age old problem while gaining
  acceptance at the local, municipal, and
  national levels."  The two also received
  EPA Bronze Medals  for this work.
• 1999 Harvard Award for Excellence in
  Children's Health. LSYP project
  partner Bowdoin Street Health Center
  received this award for its work with
  the EMPACT LSYP. This  annual
  award, cosponsored by the Harvard
  Center for Children's Health at the
  School of Public Health, the City of
  Boston, and Children's Hospital,
  recognizes a Boston organization for
  extraordinary work in the area of child
  and adolescent health.
• 2000 Boston University School of
  Public Health Award for Excellence in
  Public Health Practice. Patricia Hynes,
  Professor  of Public Health, was
  recognized during National Public
  Health Week 2000 for her work with
  the EMPACT LSYP. Boston University
  School of Public Health selected this
  as one of three examples of excellence
  in public health  research and
  intervention work being done by the
  school's faculty.
 1  .2.2   LEAD-SAFE  YARD
            RESEARCH   STUDY
EPA New England and the National Center for Lead
Safe Housing (http://www.leadsafehousing.org) are lead-
ing a HUD-funded  research  study to  document the
effectiveness of the low-cost interim soil control measures
used by the EMPACT LSYR Other partners in the study
include  the  Boston Department of Neighborhood
Development and Boston University. This research study
will include a retrospective evaluation of the soil inter-
vention work conducted during the first  two phases of
the EMPACT LSYP (1998 and 1999). It also will exam-
ine data collected during the summer of 2000 by all three
Boston-based lead-safe yard projects: the EMPACT proj-
ect, the Lead Safe Boston demonstration project, and the
BPHC project (data will be collected before, during, and
after each yard intervention). The principal objective of
the study is the preparation of a technical paper that will
document the effectiveness of low-cost interim soil con-
trol measures in reducing risk to residents and to make
this data  available to HUD tor policy development. The
research study will also  seek to  answer several technical
questions about  the  suitability  of field-portable XRF
technology tor soil-lead  testing.

 1  .3  ABOUT THIS   HANDBOOK
A  number of cities have expressed interest in beginning
lead-safe yard programs, but they are limited by available
resources.  The  Technology  Transfer   and Support
Division  of  the   EPA  Office   ot Research and
Development's (ORD's)  National  Risk  Management
Laboratory initiated the development  of this handbook
to  help interested communities learn more  about the
EMPACT LSYP and to  provide them with the technical
information they need to develop  their own programs.
ORD, working with the LSYP from Region 1, produced
the handbook to  leverage EMPACT's  investment in the
project and minimize the resources needed to implement
it in new cities.

Both  print and  CD-ROM versions  of the  handbook
are  available  for  direct  online  ordering   from
ORD's    Technology    Transfer    Web   site   at
http://www.epa.gov/ttbnrmrl. A PDF version  of the
handbook can also be downloaded  from the  EMPACT
LSYP  Web  site  at  http://www.epa.gov/region01/
leadsafe.  This Web  site  is  in turn hyperlinked  to
the   main   EMPACT   Program    Web   site
                                                                                          INTRODUCTION

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          (http://wAvw.epa.gov/cmpact) and the ORD Technology Transfer Web site. In addition, you can
          obtain a copy of the handbook by contacting the EMPACT Program office at:

              EMPACT Program
              Office of Environmental Information
              U.S. EPA (2831R)
              1200 Pennsylvania Avenue
              Washington, DC 20460
              (202) 564-5179
          We hope that you find the handbook worthwhile,  informative, and easy to use. We welcome
          your  comments;  you  can  send  them  by  e-mail   from  EMPACT's   Web  site  at
          http://www.epa.gov/empiict/comment.htrn.

           1  .4      ACKNOWLEDGMENTS
          EPA and the EMPACT LSYP would like to recognize the following people and organizations for
          their substantial contributions to the contents of this  handbook:

              • Sandra Duran, a construction specialist with the Boston Department of Neighborhood
               Development in the City of Boston's Public Facilities Department, for creating many of
               the forms  used during the third phase of the EMPACT LSYP and creating the specifica-
               tions for construction contracting.

              • The EPA New England Lead Program in the Office of Ecosystem Protection, for assistance
               in reviewing early drafts of the handbook.

              • The New England Lead Coordinating Committee (NELCC), funded by EPA New
               England and the State Lead Programs, and the participants of the Lead in Soils Design
               Charrette, whose early work developing landscape treatments for lead-contaminated soil
               provided a foundation for the EMPACT LSYP's low-cost mitigation approach.

              • The EPA New England Urban Initiative, whose outreach and  capacity-building efforts
               established many of the community and city partnerships that made this project possible.

           1.5                         INFORMATION
          Try the following resources for more on the issues and programs this handbook discusses:

              The EMPACT Program
              littp://www.epa.cov/emp act
                I        I   O      I

              The EMPACT Lead-Safe Yard Project
              http://www. epa.gov/region01/leadsafe

              Robert Maxfield
              Chief, Environmental Investigation and Analysis
              EPA Region 1 Laboratory
              60 Westview Street
              Lexington, MA 02173
              (781) 860-4640
1 INTRODUCTION

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H. Patricia Hynes
Professor of Environmental Health
Director, Urban Environmental Health Initiative
Boston University School of Public Health
715 Albany Street
Boston, MA 02118
(617) 638-7720

The Dudley Street Neighborhood Initiative
http://www.dsni.org

The National Center for Lead Safe Housing
http://www.leadsafehousing.org
                                                                                   INTRODUCTION

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                             2
How  To
This handbook provides information your community can use to create and implement a lead-safe
yard program. It presents detailed guidance, based on the experience of the EMPACT Lead-Safe
Yard Project, on how to:
Identify target
communities and
select program
partners
^>
Provide lead-safety
education and
outreach to
homeowners
and residents
Use field-portable
x-ray fluorescence
technology to collect
real-time soil
lead data

=>


Design and implement
property-specific
treatment plans
and develop
yard-maintenence
plans
                                                                                              Evaluate the
                                                                                              effectiveness
                                                                                             of your program
The handbook provides simple "how to" instructions on each facet of planning and implementing
a lead-safe yard program, along with important background information on lead poisoning and the
hazards of lead-contaminated soil:

    •  Chapter 3 discusses why lead in general, and lead-contaminated soil in particular, is a
      health hazard; what data are available on lead in soil; and what standards and regulations
      may apply to your program.

    •  Chapter 4 describes the steps in beginning a program: identifying potential target
      communities, getting to know the community, and selecting partners for the program.

    •  Chapter 5 provides guidance on education and outreach to homeowners and residents
      about the problem of lead in soil and the benefits of participating in a lead-safe yard
      program.

    •  Chapter 6 provides detailed information about data collection and management, focusing
      on the use of the field-portable x-ray fluorescence instrument to collect real-time data.

    •  Chapter 7 describes soil mitigation strategies and techniques, including sample
      specifications, costs, and legal issues.

    •  Chapter 8 discusses how to develop and implement a maintenance plan for lead-safe yards,
      including homeowner education and strategies for ensuring ongoing maintenance.

    •  Chapter 9 provides guidance for evaluating the program, stressing the importance of
      documentation.

    •  Chapter 10 outlines the application of lead-safe yard  monitoring and mitigation techniques
      to non-residential settings,  such as tot lots, community gardens, and abandoned
      commercial buildings.

Interspersed throughout the handbook are success stories  and  lessons learned in the course of the
EMPACT LSYP The handbook  also refers you  to supplementary sources of information, such as
Web sites, guidance documents,  and other written materials. In addition, the handbook includes
three  appendices that present alternatives to the  approaches used by the EMPACT LSYP:
                                                             2 How  TO  USE THIS HANDBOOK

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                      • Appendix A describes the Safer Soil Pilot Program of Cambridge, Massachusetts, which
                       has used landscaping and other remedial measures to treat residential yards since 1997-

                      • Appendix B proposes four models for less-resource-intensive approaches to implementing
                       lead-safe yard programs.

                      • Appendix C discusses a new option, phytoremediation, being explored to address lead in
                       soil in a cost-effective manner.

                  Finally, Appendix D presents the EMPACT LSYP Quality Assurance Project Plan.

                  The handbook is  designed for  managers and decision-makers who may be considering whether to
                  implement a lead-safe yard program in their communities, as well as for organizers who are actu-
                  ally implementing lead intervention programs. Decision-makers likely will find Chapters 3,  4, 9,
                  and  10 most helpful. The other chapters are written primarily for people who will carry out the
                  program and provide detailed "how to" information. Individual homeowners interested in finding
                  low-cost ways to prevent children's exposure to lead in soil will find Chapters 7 and 8 most useful.
ID    2  Haw TO  USE THIS  HANDBOOK

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                             3
  IN
is   IT  A  PROBLEM?
This chapter provides an overview of the problems posed by lead in soil. Section 3-1 discusses lead
poisoning, its health effects and prevalence, and the pathways through which children and others are
exposed to lead. Section 3-2 describes the most common sources of lead in residential soil and sum-
marizes soil-lead levels found in the United States.  Section 3-3 reviews  evidence indicating that soil
is one  important pathway for childhood lead exposure. Finally, Section 3.4 describes the  national
strategy for reducing hazardous exposures  to lead and identifies standards and regulations that may
affect a lead-safe yard program.

The information in this chapter should be useful to any person interested  in soil-lead hazards and
mitigation, whether that person be a community organizer responsible for implementing a lead-safe
yard program or a homeowner concerned  about elevated soil-lead levels in his or her own yard.

3.1       LEAD  AND  LEAD POISONING
Lead is a heavy, soft, malleable metal. Due  to its physical and chemical properties, people have found
countless uses for lead in their daily lives. While certain  uses of lead are banned, lead is still found in
a myriad of products. Important sources of lead in  the environment today include:

    • Lead paint, and resulting lead dust, found in and  around homes built before 1978
     (when lead-based paint was banned). Lead dust from deteriorated lead-based paint
     is the most significant contributor to childhood lead poisoning.

    • Lead from automobile emissions  (before leaded gasoline was finally banned in 1986)
     that has been deposited on land and surface water.

    • Lead in occupational settings (often  brought  home on clothes or  skin).

    • Lead from industrial emissions, such as lead smelters, lead mining, hazardous
     waste sites, and battery-recycling  plants.

    • Lead in drinking water caused  by lead-containing plumbing.

    • Lead-containing tableware, such as leaded-crystal  glassware and lead-glazed pottery.

    • Certain hobbies and activities that use lead (e.g., car radiator repair, target shooting, stained-
     glass making, glass or  metal soldering).

    • Certain folk remedies  that contain lead  (e.g., azarcon, greta).

3.1.1  WHAT  Is   LEAD  POISONING?
Lead poisoning is entirely preventable.  However, according to the  Centers for Disease Control and
Prevention (CDC), nearly 1 million children living in the United States in the early 1990s had lead
in their blood at levels high  enough to  be associated with irreversible damage to their health.

CDC defines elevated  blood  lead in children as blood lead levels of 10 micrograms of lead per
deciliter of blood (ug/dL) or higher. Until  the early 1970s, CDC's blood lead levels of concern were
60 ug/dL for children and 80  ug/dL for adults. As the adverse effects of lead became better known,
                                                   3  LEAD  IN SOIL: WHY  is  IT A  PROBLEM?     1  1

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Blood lead levels considered elevated by the Centers
for Disease Control and the Public Health Service.

  50-1—
   40 —
   30
   20- —
   10- —
         1970
                  1975
                          1980
                          Year
                                  1985
                                          1990
Source: Centers tor Disease Control, 1991,
Preitenting Lead Poisoning in Young Children
                                          CDC lowered the level at which it recommends medical atten-
                                          tion, also known as the ''blood lead intervention level," on three
                                          separate occasions. After research showed that cognitive and
                                          developmental damage occurs at blood lead levels as low as 10
                                          ug/dL, CDC lowered the blood lead level of concern to the cur-
                                          rent 10 ug/dL value in 1991 • There is no known safe level of lead
                                          in blood.

                                          3.1,2   HEALTH  EFFECTS
                                                      OF            PQISONINB
                                          Lead poisoning affects nearly every system in the body,  and often
                                          occurs with no noticeable symptoms. Although  lead can affect
                                          adults, children under the age of six are especially vulnerable to
                                          the adverse effects of lead. The incomplete development of the
                                          blood-brain barrier in fetuses and very young children  (up to 36
                                          months of age) increases the risk of lead's  entry into the nervous
                                          system. Low but  chronic exposure  can  affect the developing
                                          nervous system in subtle but persistent ways. In children, blood
                                          lead levels as low as 10 to 15 ug/dL can stunt growth rates, affect
           attention span, cause learning disabilities, lower IQ scores, impair hearing acuity, and cause behav-
           ioral problems.  In addition, fetuses exposed to elevated levels of lead can suffer from  low birth
           weight, impaired hearing, and altered gestational age, which can lead to further complications.

           In addition to damaging the nervous system, elevated blood lead levels can  also affect the kidneys
           and reproductive system and cause high blood pressure. Very high levels (greater than 80 pg/dL)
           can  cause convulsions, coma, or death. Levels greater than 150 (Jg/dL are fatal if not treated quickly.
           Fortunately, exposures resulting in such high levels of lead are rare.

           The literature on the health effects of lead  is extensive.  For more information, see  CDC's
           Preventing Lead Poisoning  in  Young Children  (http://aepo-xdv-vvvvw-epo.cdc.gov/wciiider/
           prevguid/p()()()()()29/pO()()()()29.htm)   and   the   Agency   for   Toxic   Substances   and
           Disease   Registry's   Case   Studies   in    Environmental   Medicine:   Lead   Toxicity
           (hrtp://www.atsdr.cdc.gov/HEC/casclead.html). Additional resources and links listed at the end of
           this chapter provide a wealth of information on this  and other lead-related topics.

           3.1,3  How           LEAD  ENTER  THE   BDDT,
                      AND  WHAT  HAPPENS  TO  LEAD  IN THE  BODY?
           Lead enters the body through either ingestion or inhalation. Young children tend  to ingest more
           lead than adults do in a given environment, mainly because of their normal hand-to-mouth behav-
           ior.  The most common way for a child to ingest lead is by putting objects in the  mouth  (e.g., toys
           or hands) that have lead-contaminated dust or dirt on them. Children may also mouth surfaces
           having lead-based paint (such as window sills) or ingest lead-paint chips or soil (especially children
           who exhibit pica, a pattern of eating dirt or other non-food substances). Children may also ingest
           lead if their drinking water contains lead. (Lead in drinking water usually  comes from  lead-con-
           taining pipes, faucets, and solder in the plumbing of older buildings.) Children can also inhale lead
           via dust from deteriorating  paint, dust  on clothing brought home by parents exposed to occupa-
           tional lead sources, or fumes from hobbies or industries that use lead.
 1 2
3  LEAD  IN THE  SOIL; WHY is  IT  A PROBLEM?

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Young children tend to ingest more lead than adults do in a given environment, partly because of
normal hand-to-mouth behavior. They also take in more food and water per body weight.

The rate at which the body absorbs lead, once it has been ingested, depends on the chemical and
physical form of the lead and on the physiological characteristics of the exposed person. Nutritional
status and age are the factors having the  greatest influence on absorption rates. Adults  typically
absorb 10 to 15  percent of ingested lead through  the gastrointestinal tract, while children and
pregnant women can absorb  as  much as 50 percent.  Children are also at higher risk when their
nutritional needs are not being adequately met. Calcium, iron, zinc, and protein deficiencies, in
particular, increase lead absorption rates. Fasting conditions in adults have a similar impact on the
absorption of lead. Lead dust  inhaled and deposited into the lower respiratory tract is completely
absorbed by both adults and children.

Since lead is an inorganic metal, it  is not  metabolized and is distributed  throughout the  body by
the bloodstream. Over time, a portion of the lead may be eliminated  from the body. The majority,
however, remains in the bloodstream, or is  absorbed by soft tissue (kidneys, bone marrow, liver, and
brain), or mineralizing tissue (bones and teeth). In adults, 95 percent of the lead present in the body
is  found in  teeth  and bones, where  it remains inert. When the body experiences physiological
changes, however—such as pregnancy, lactation, or chronic disease—this  inert lead can leach into
the bloodstream and raise blood lead  levels to dangerous levels. During pregnancy, this mobilized
lead can also be transferred  to the fetus, which has no defense mechanism against it. This can result
in developmental and neurological damage.

In addition to absorbing a  greater proportion of the lead to which they are exposed, children also
tend to retain a greater percentage of lead in their blood than do adults. This is partly because
a  child's body is not  as  efficient as  an adult's  at absorbing lead into  mineralizing tissue.
Consequently, a greater  fraction  of  the lead absorbed  remains in the bloodstream and has a toxic
effect on internal organs.
3.1.4  HOW                 Is
           POISONING  IN  CHILDREN?
The Second National Health and Nutrition Examination
Survey (NHANES II),  released in  1980, showed  that as
recently as 1976, the average blood lead level of the typi-
cal  American child was  12.8  ug/dL. The survey also
revealed that at that time 88.2 percent of American chil-
dren  ages  one through five  were suffering from some
degree of lead poisoning (i.e.,  over CDC's current level of
concern of 10 pg/dL).

In the 1970s, the federal government banned the use of
lead-based paint in residential buildings and houses, and
phased out the use of lead as an additive in gasoline. These
two actions had an immense impact on the blood lead lev-
els of children nationwide. NHANES III reported that by
1988, the  national average blood lead level in children had
dropped to 2.8 pg/dL and the percentage of children suf-
fering from lead poisoning had dropped to 8.9 percent. By
the early 1990s, the average blood lead level of children ages
Change in blood lead levels in relation to a
decline in use of leaded gasoline, 1976-1980.
    110-1—
 S
    100--
     90
     80--
     70
     60--
     50 • —
           1976     1977      1978
                            Year
Source: Centers for Disease Control, 1991,
Preventing Lead. Poisoning in Young Children
                                    1979
                                            1980
                                                      3  LEAD IN  SOIL: WHY  is  IT A  PROBLEM?    1 3

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                                                                   one  through  five  was  2.3 ug/dL.1  A fourth
                                                                   NHANES  report  has  recently been completed;
                                                                   though the report  has not yet been made public,
                                                                   the survey  data apparently suggest that average
                                                                   blood lead levels  continue  to  decrease  among
                                                                   children in this age range.

                                                                   While childhood lead exposure has diminished
                                                                   over the past 25 years, the problem is far  from
                                                                   solved.  In particular, minority,  low-income,
                                                                   inner-city populations continue to  lag behind in
                                                                   improvement, relative to national averages:

                                                                   • 8 percent of impoverished children suffer
                                                                    from lead poisoning compared to only
                                                                    1 percent of children from high-income
                                                                    families.2

                       • 11.2 percent of all African-American children  are lead poisoned compared to 2.3 percent of
                         all white children.3

                       • 50 to 70 percent of the children living in the inner cities of New Orleans and Philadelphia
                         have blood lead levels above  10 ug/dL.4

                   Poor nutrition, deteriorating housing, lack of access  to medical care, and language barriers all con-
                   tribute to placing poor and minority children at risk for lead poisoning. It is important to  note,
                   however, that no economic or ethnic/racial group is  free from the risk of lead poisoning. A sizable
                   number of affluent families renovating older homes,  for example, have placed their children at risk
                   through  unsafe lead paint removal techniques.

                   3.2       SOURCES  AND   LEVELS  OF  LEAD  IN  SOIL
                   When lead is deposited in soil from anthropogenic sources, it does not biodegrade or decay and is
                   not rapidly absorbed by plants, so it remains in the soil at elevated levels. Lead is estimated to have
                   a half-time of residence in soil of 1,000 years.5 In soils with a pH of greater than or equal to 5 and
                   with at least 5 percent organic matter (which immobilizes the lead), atmospheric lead is retained in
                   the upper 2 to 5  centimeters of undisturbed soil.6 Urban soils or other soils that have been turned
                   under or otherwise disturbed may be contaminated to much greater depths.

                   EPA estimates that 23 percent, or 18 million, of the privately owned homes in  the  United States
                   built  before 1980 have soil-lead levels above 400 parts per million  (ppm); that 3 percent, or 2.5
                   million, have levels exceeding 2,000 ppm; and that 3 percent, or 2.5 million, exceed 5,000 ppm.7
                    Natural Resources Defense Couricil> Our Children at Risk: The 5 Worst Environmental Threats to Their Health,
                    Chapter 3: Lead, Washington, DC, 1997. Available at http://nrdc.org/heakh/kids/ocar/acarinx.asp
                   2Ibid.
                   3 Ibid.
                   ^Mielke, H.W., "Lead in the Inner Cities," American Scientist, vol. 87, no. l,Jan/Feb  1999.
                   -'Benninger et al., The Use of Natural Pb-10 as a Heavy Metal Tracer in the River-Estuarine System, ACS Symposium Series #18,
                    Marine Chemistry and the Coastal Environment, 1975.
                   ^U.S. Environmental Protection Agency, Air Quality Criteria for Lead, Research Triangle Park, NC, EPA600-8-83-018F, 1986.
                   'U.S. Environmental Protection Agency, Distribution ofSoilLeadin the Nation's Housing Stock,  1996.
14     3 LEAD  IN THE SDIL: WHY  is IT A PROBLEM?

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       Lead in residential soil comes from several different sources, including lead-based exterior paint and
       automobile tailpipe emissions from vehicles burning leaded gasoline. Industrial emissions are also
       a source of residential soil contamination in some areas. These sources of contamination are dis-
       cussed in more detail below.

       3.2.1   LEAD-BASED  PAINT
       EPA has found building age to be the strongest statistical predictor of soil lead, with soil around
       private homes built before 1940 having significantly higher levels of lead in soil than homes built
       between I960 and  1979-8 While the use of lead paint in residential buildings was federally banned
       in the United States in 1978, many homes built prior to 1978 still contain lead-based paint. Paint
       used in homes built between 1950 and 1978 contained between 0.5 and 50 percent lead, and the
       paint used prior to 1950 contained higher concentrations. One estimate is that more than 3 mil-
       lion tons of lead-based paint remain in the 57 million homes built prior to 1980.9

       Since a large portion of this lead-based paint covers building exteriors,  it continues to be a signifi-
       cant source of soil  contamination. Lead-based paint contaminates soil as the  paint film weathers
       and reaches the soil in the form of chips and dust. Renovating, remodeling, and performing rou-
       tine home maintenance will also mobilize this lead if proper precautions are not taken. As the paint
       on a building's exterior deteriorates, lead paint chips and dust concentrate in the surrounding soil.
       Dry scraping, sanding, and blasting of lead-based paint can mobilize  large amounts of lead in a
       short time and significantly increase lead concentrations in soil. Lead concentrations in soil are typ-
       ically highest in the drip  zone, or dripline, the area surrounding and extending out about 3 feet
       from the perimeter of a building.

       a.2.2   LEADED  GASOLINE
       The use of lead as a gasoline additive was phased out during the 1970s and banned in the United
       States in 1986.  It has been  estimated that 4 to 5 million metric tons of lead,  emitted  from auto-
                                                          mobile  tailpipes  as  fine dust particles,
                                                          remain in the  environment  in dust and
                                                          soil.10 This  represents  approximately 75
                                                          percent of the total amount of lead added
                                                          to gasoline. The remaining 25 percent was
                                                          deposited  on internal  engine surfaces  or
                                                          ended up in the oil. The  lead dust that
                                                          became airborne would migrate until hit-
                                                          ting a barrier such as  the side of a house or
                                                          some other  structure,  to which  it would
                                                          adhere. Subsequent rains washed this lead
                                                          dust down into the surrounding soil, where
                                                          it accumulated over time.
Scientists estimate that 4 to 5 million metric tons of lead emitted from
automobile tailpipes prior to 1986 remain in the environment in dust
and soil.
Soil-lead levels within 25 meters of road-
ways are typically 30 to 2,000 ppm higher
than natural levels, and can sometimes be as
       8Ibid.
       'Centers for Disease Control, Preventing Lead Poisoning in Young Children, 1991.
       10
        Ibid.
                                                            3  LEAD  IN BOIL:  WHY is IT A PROBLEM?     1 5

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                   high as 10,000 ppm.11 Some researchers have found that soil-lead concentrations typically are high-
                   est in  older, inner-city neighborhoods, especially those near high-traffic routes, and that soil-lead
                   concentrations diminish with distance from the city center. Another study found that soil-lead con-
                   centrations are 10  to 100 times  higher  in old communities  in  large cities than  in comparable
                   neighborhoods in smaller cities, perhaps because  traffic volume is higher and vehicles remain inside
                   the city longer.12
                                                             3.2.3  INDUSTRIAL  EMISSIONS
                                                             Communities near  industrial  and  mining  activities
                                                             that release lead (or released lead in the past) may also
                                                             have elevated  levels  of  lead  in  residential  soils.
                                                             Examples  of such industries and activities are lead
                                                             smelting or refining plants, lead mining, auto repair,
                                                             battery recycling or  manufacturing, bridge and water
                                                             tank repainting and reconstruction, plastic manufac-
                                                             turing,  shipbuilding, glass manufacturing,  printing,
                                                             and hazardous waste sites. EPA has found lead levels in
                                                             soils next to smelters as high as 60,000 ppm.13
                                                                   3.3    SOIL  AS  AN
                                                                            EXPOSURE
                                                                            PATHWAY  FOR  LEAD
                                                                  While  deteriorated lead-containing  paint  in
                                                                  housing is  generally accepted  as  the leading
                                                                  source  of lead exposure to children, outdoor
                                                                  activities  where individuals come into contact
                                                                  with lead-contaminated soil also represent  an
                                                                  exposure pathway that can be significant. When
                                                                  children play outdoors, lead-contaminated dirt
                                                                  and dust can get on hands, clothes, toys, and
                                                                  food. Putting these items in the mouth can lead
                                                                  to ingestion of lead.
       A back yard in Dorchester, Massachusetts, with areas of bare, contami-
       nated soil. When children play outdoors, lead-contaminated dirt and
       dust can get on hands, clothes, toys, and food.
                                                Children can also breathe lead dust or lead-con-
                                                taminated  dirt stirred up  by the wind or by
outdoor play activities. During dry periods, dust from bare patches of contaminated soil can read-
ily become airborne, increasing the chance that it will be inhaled. Also, airborne lead dust and
lead-contaminated dirt can settle on play clothes and shoes and can be tracked into homes, further
increasing exposure. Pets, as well, can track lead-contaminated soil into homes on their coats and
paws.

The relative contribution of lead-contaminated soil versus lead-based paint and house dust is the
subject of research and debate. Although there are differing opinions among researchers and experts
as to the degree of significance of exposure to lead-contaminated soil, evidence does exist that soil
is one important pathway for lead exposure among children. Some researchers have shown an asso-
                   11 Ibid.
                   12Mielke, H.W, "Lead in the Inner Cities," American Scientist, vol. 87, 110. 1,Jan/Feb 1999.
                      .S. Environmental Protection Agency, Air Quality Criteria-for Lead.
16     3  LEAD  IN THE  SDIL: WHY  is IT A PROBLEM?

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elation between increases in blood lead  and increases in
soil or dust concentrations. Factors that  influence this
relationship include access to soil, behavior patterns, pres-    As tne various pathways for lead exposure in young
ence of  ground  cover, seasonal  variation of exposure    children become better understood, the importance
conditions, and the particle size and chemical form of the    of addressing all of the sources of lead in and around
lead. Others  have found an  association  between time    the home has also become clearer. For example, even
spent outdoors and children putting soil or dirt in their    if the interior of a home is certified as deleaded,
mouths, which, in turn, is associated with elevated blood    a lead-contaminated yard can remain a dangerous
lead levels. ^                                             source of lead exposure for children living there.
                                                        Conversely, soil mitigation work will be ineffective
In  1996, EPA published  the  Integrated Report of the    if nothing is done about heavily leaded exterior paint
Urban Soil Lead Abatement Demonstration Project. This    on a home, because recontamination of the yard is
report assessed the scientific data  from  studies in  three    likely to occur.
cities (Boston, Baltimore,  and Cincinnati)  to determine    Because lead m yafd ^ ^ omy Qne aspect of a
whether abatement of lead in soil could reduce blood lead    multi-kyered problem, the EMPACT Lead-Safe Yard
levels of  inner-city children. The  report concludes that    Project decided in Phase 3 to address yards only for
when soil is a significant source of lead in the child's envi-    residences  where structural lead abatement had been
ronment,  the  abatement  of that  soil  will result in a    completed. Even in such homes, however, some lead
reduction in exposure that will, under certain conditions,    probably remains, and precautions must be taken
cause a reduction in childhood  blood lead concentrations.    (e.g., using lead-safe renovation techniques) to
Important  factors in reducing  blood lead levels  were    prevent recontamination of the yard.
thought to  be (1) the past history of exposure of the child
to lead, as reflected in pre-abatement blood lead levels; (2)
the magnitude of the reduction in soil-lead concentrations;
(3)  the magnitude of other sources of lead exposure; and (4) a direct exposure pathway between soil
and the child.15

Howard Mielke, a leading researcher on lead poisoning and prevention, reviewed other evidence for
soil lead as  an important exposure pathway in a 1999 article.16  Mielke demonstrated a strong cor-
relation between soil lead and blood lead in several studies.

3.4      STANDARDS   AND  GUIDELINES
            FDR  LEAD  POISONING  PREVENTION
This section provides an overview  of federal guidelines and standards that may affect a lead-safe
yard program.  When determining the requirements that apply to your program, it is important to
check with the state or tribal agency that addresses lead poisoning prevention. For example, many
states have requirements tor training and  certification of contractors performing lead hazard evalu-
ation and abatement work. For a  list of state/tribal lead  poisoning prevention  agencies, see
http://www.ncsl.org/programs/ESNR/pbdir.htm.

3.4.1   THE  FEDERAL   REGULATORY  INFRASTRUCTURE
Title X  of the  1992  Housing  and  Community  Development  Act  (available  online at
http://www.epa.gov/lead/titleten.html) otherwise known  as the Residential Lead-Based  Paint
Hazard Reduction Act (Public Law 102-550), mandated the creation  of an infrastructure that
      Lanphear and Klaus Roghmann, "Pathways of Lead Exposure in Urban Children,"
  Environmental Research, vol. 74, 63—73, 1997.
15 U.S. Environmental Protection Agency, Integi-a ted Report of the Urban Soil Lead Abatement Demonstration Project,
  EPASOO-P-93-OOlaF, Office of Research and Development.
^Mielke, H.W., "Lead in the Inner Cities," American Scientist, vol. 87, no. 1, Jan/Feb 1999.
                                              3 LEAD IN  THE SOIL  : WHY  is IT A  PROBLEM?    1 7

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                  would correct lead paint hazards in housing. Title X also redefined "lead paint hazards" and how
                  they can be controlled, and created Title IV of the Toxic Substances Control Act (TSCA), under
                  which EPA sets lead hazard standards, work practice standards, and training requirements  for lead
                  abatement workers. Based on scientific research in the 1980s, Congress defined "hazard" to include
                  deteriorated lead paint and the lead-contaminated dust and soil it generates. The infrastructure has
                  been developed and includes the following:

                      • Grant programs to make homes lead safe, now active in over 200 cities.

                      • Training of thousands of workers doing housing rehabilitation, remodeling renovation,
                        repainting, and maintenance to help them do their work in a lead-safe way.

                      • Licensing of inspectors and abatement contractors.

                      • Compliance with and enforcement of lead safety laws and  regulations.

                      • Disclosure of lead paint problems before  sale or lease.

                      • National and local education and outreach  programs.

                      • Promulgation of federal standards of care.

                      • Worker protection regulations.

                  The box below lists federal agencies and their programs related to lead poisoning prevention. For a
                  more detailed overview of these federal programs, see "Current and  Ongoing Federal Programs and
                  Activities" in Eliminating Childhood Lead Poisoning: A Federal Strategy Targeting Lead Paint Hazards
                  (http://www.epa.gov/children/whatwe/leadhaz.pdf).
                            FEDERAL AGENCY ROLES IN LEAD POISONING PREVENTION

                                                    AGENCY   PROGRAMS AND DUTIES
                                        Department of Housing
                                        and Urban Development
                           http://www.hud.gov/lea/leahome.html
                      Department of Health and Human Services:
                       Centers for Disease Control and Prevention
                          http://www.cdc.gov/nceh/lead/lead.htm
                           Health Care Financing Administration
                                           http ://www.hcfa.gov
                                                          Lead Hazard Control Grant Program, enforcement
                                                          of Disclosure Rule (with EPA and DoJ) and
                                                          federally assisted housing lead paint regulations,
                                                          National Survey of Lead Paint in Housing, Lead
                                                          Hotline (with EPA), Internet listing of lead paint
                                                          professionals, public education and training of
                                                          housing professionals and providers and others,
                                                          technical assistance, research.

                                                          Blood  Lead Screening Grant Program, public
                                                          education to medical and public health
                                                          professionals and others, National Health and
                                                          Nutrition Examination Survey, quality control for
                                                          laboratories analyzing blood lead specimens,
                                                          research.

                                                          Covers and reimburses for lead screening an
                                                          diagnosis, lead poisoning treatment, and follow-up
                                                          services for Medicaid-eligible children.
i  a
3 LEAD IN  THE SDIL: WHY  is  IT  A PROBLEM?

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           FEDERAL AGENCY        IN LEAD POISONING
                                ABENCY   PROGRAMS AND  DUTIES
           National Institute of Child Health
                   and Human Development
                  http://www.nichd.nih.gov
Health Resources and Services Administration
                       http://www.hrsa.gov
                 Agency for Toxic Substances
                        and Disease Registry
                   http://www.atsdr.cdc.gov
Conducts and supports laboratory, clinical, and
epidemiological research on the reproductive,
neurobiologic, developmental, and behavioral
processes, including lead poisoning related
research.

Directs national health programs to assure quality
health care to under-served, vulnerable, and special
need populations including children with lead
poisoning.

Studies blood lead in populations near Superfund
sites and funds state health agencies to undertake
this type of work.
              Food and Drug Administration
                        http://www.fda.gov

                National Institutes of Health
                        http://www.nih.gov

            Environmental Protection Agency
http://www.epa.gov/opptintr/lead/index.html
                      Department of Justice
                      http://www.usdoj .gov
       Consumer Product Safety Commission
                       http://www.cpsc.gov
Enforces standards for lead in ceramic dinnerware;
monitors lead in food.

Conducts basic research on lead toxicity.
Licenses lead paint professionals (or delegates this
responsibility to states); environmental laboratory
accreditation; enforcement of Disclosure Rule
(with HUD and DoJ) and Pre-Renovation
Notification Rule; hazardous waste regulation;
public education to parents, environmental
professionals, and others; training curriculum
design; Lead Hotline (with HUD); research;
addresses lead contamination at industrial waste
sites, including drinking water and industrial air
emissions.

Enforces  Federal Lead Paint Disclosure Rule (with
HUD and EPA); defends federal lead paint
regulations; enforces pollution statutes, including
hazardous waste laws.

Enforces  ban of lead paint; investigates and
prevents the use of lead paint in consumer
products; initiates recalls of lead-containing
products  that present a hazard; conducts dockside
surveillance and intercepts imported products that
present a risk of lead poisoning; recommends
elimination of lead from consumer products
through Guidance Policy on lead.
                                           3  LEAD IN THE SOIL  : WHY  is  IT A  PROBLEM?
                                                         1 9

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                               FEDERAL AGENCY ROLES IN LEAD POISONING PREVENTION

                                                    AGENCY   PROGRAMS AND DUTIES

                   Occupational Safety and Health Administration   Enforces worker protection regulations.
                    http://www.osha-slc.gov/SLTC/lead/index.html
                                     Department of the Treasury   Evaluates financial incentives (such as tax credits)
                                         http://www.ustreas.gov   for lead hazard control.

                                          Department of Energy   Conducts weatherization activities in a lead-safe
                                         http://www.energy.gov   manner.

                                         Department of Defense   Administers lead-based paint/lead hazard
                                     http://www.defenselink.mil   management programs in 250,000 family housing
                                                                 and child-occupied facilities worldwide,
                                                                 administers childhood lead poisoning prevention
                                                                 programs on installations worldwide, administers
                                                                 research and development programs to develop
                                                                 new cost-effective technologies for lead paint
                                                                 management and abatement, partners with other
                                                                 federal agencies to develop policies and guidance
                                                                 for lead hazard management on a national level.
                  3.4.2 THE  FEDERAL  STRATEGY
                            To  ELIMINATE LEAD  POISONING
                  The  interagency President's Task Force on Environmental Health Risks and  Safety Risks to
                  Children has proposed a coordinated federal strategy to eliminate childhood lead poisoning, focusing
                  on lead paint hazards (Eliminating Childhood Lead Poisoning: A Federal Strategy Targeting Lead Paint
                  Hazards, available at http://www.epa.gov/children/whatwe/leadhaz.pdf). The goals of the Strategy are:

                      • By 2010, to eliminate lead paint hazards in housing where children under six live.

                      • By 2010, to eliminate elevated blood lead levels in children.

                  To accomplish these goals, the Task Force makes the following recommendations:

                  Act before children are poisoned:

                      • Increase the availability of lead-safe dwellings by increasing federal grants for
                       low-income housing and leveraging private and other non-federal funding.

                      • Promote education for universal lead-safe painting, renovation,
                       and  maintenance work practices.

                      • Ensure compliance with existing lead paint laws.

                  Identify and care for lead-poisoned children:

                      Improve early intervention by expanding blood lead screening and follow-up
                      services for at-risk children, especially Medicaid-eligible children.
2O     3  LEAD IN THE  SDIL: WHY is IT A PROBLEM?

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Conduct research:

    Improve prevention strategies, promote innovative ways to drive down lead
    hazard control costs, and quantify the ways in which children are exposed to lead.

Measure progress and refine lead poisoning prevention strategies:

    Implement monitoring and surveillance programs.

The Strategy notes that research is needed to help develop, evaluate, and market new products, such
as x-ray fluorescence technologies. It also notes that research is needed to test the effectiveness of
specific actions to reduce exposure to lead in soil and dust. These are areas in which the EMPACT
Lead-Safe Yard Project and other similar programs can make significant contributions through their
data and experience.

3.4.3  FEDERAL REGULATIONS  AND  GUIDELINES
          AFFECTINB LEAD-SAFE  YARD  PROBRAMS
EPA and the Department of Housing and Urban Development have issued regulations governing
lead contamination in residential buildings and soil. EPA regulates lead contamination in homes
and yards from  lead-based  paint under Title IV  of TSCA. EPA's  Resource  Conservation  and
Recovery Act (RCRA)  regulations also regulate lead-contaminated soil in certain situations. HUD's
regulations parallel the TSCA regulations and apply to residential buildings that are either federally
owned or receive federal assistance under HUD programs.

3.4.3.1                      RULE UNDER  TSCA
                C4O         PART 745)
EPA is  currently preparing  a final  rule under  TSCA Section 403,  "Lead;  Identification of
Dangerous Levels of Lead," which will establish standards for lead-based paint hazards, including a
hazard level and level of concern for lead-contaminated residential soils. The pending rule is being
designed to contribute to the lead hazard identification and abatement mandates specified under
Title X, "The Residential  Lead-Based Paint Hazard Reduction Act of 1992."

The Section 403 rule is expected  to directly affect HUD and other federal agencies that own  resi-
dential property by requiring soil abatement (such as soil  removal or paving) before property sale if
soil-lead hazards are identified. It will also indirectly affect property owners who receive federal
housing assistance by potentially requiring hazard abatement or reduction. However, this pending
rule will not by itself require residential soil abatement, but will instead provide standards for use
in other regulations currently being implemented under Title X.

3.4.3.1,1        THE  TREATMENTS  IN  THIS HANDBOOK:
                CONSISTENT WITH  FEDERAL  REGULATIONS?
The EMPACT LSYP was  designed before the Section 403 rule was drafted; however, it can be con-
sidered to be complementary to the pending Section 403  rule. The project complements the "focus
on prevention" objective of TSCA Title IV and the pending Section 403 rule by providing residents
(particularly low-income urban minority residents) with practical low-cost yard improvements and
landscaping measures that will reduce exposure  to lead-contaminated soils. These low-cost meas-
ures may be used, in  the case of federally  owned or assisted properties, as interim shorter-term
solutions until  permanent, higher-cost solutions are employed. In addition, these low-cost measures
may also provide  longer-term, but not permanent, protection at non-federally and if needed, federally
owned/assisted properties so long as homeowners and/or residents carefully and conscientiously fol-
low specific maintenance procedures developed by the LSYP.
                                              3  LEAD IN THE  SOIL :  WHY is IT A PROBLEM?    2 1

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                   The tables below show the actions recommended for different soil levels by the EMPACT LSYP
                   and the pending Section 403 rule. Following the tables is a discussion of the context for the two
                   sets of recommended actions, as well as a comparison of the sampling plans used in each approach.
                                           EMPACT LEAD-SAFE YARD PROJECT
                             SOIL-LEAD  LEVEL
                          (PARTS PER MILLION)*
                               > 5,000 (very high)
                              2,000-5,000 (high)
                          400-2,000 (moderately high)
                             400 (urban background)
                                                               RECOMMENDED
                                                              INTERIM ACTION
                                                     If soil removal or permanent barriers
                                                     are not possible:

                                                         • Install semi-permanent barrier, such as
                                                         a wood-framed dripbox filled with gravel
                                                         or mulch.

                                                         • Relocate gardens—unsafe for all types
                                                          of gardening.

                                                         • Relocate gardens—unsafe for all types
                                                          of gardening.

                                                         • Relocate children's play area, pet
                                                          area, and picnic area, if possible. If
                                                          not, install wood platform or wood-
                                                          framed raised play and picnic area
                                                          filled with woodchips.

                                                         • Install path of walking stones for
                                                          high-traffic areas.

                                                         • Seed and fertilize grassy areas, or
                                                          cover with mulch or woodchips if
                                                          not suitable for grass.

                                                         • Install raised-bed garden and supplement
                                                          with clean topsoil.

                                                         • Install wood-framed raised play and
                                                          picnic area filled with  woodchips.

                                                         • Install path of walking stones for
                                                          high-traffic areas.

                                                         • Seed and fertilize grassy areas, or cover
                                                          with mulch or woodchips if not suitable
                                                          for grass.

                                                         • No treatment necessary.
                   * Based on in situ XRF analysis of surface soils (typically 15 to 25 samples per yard) and lead concentration mapping of
                   the entire yard to include areas of special concern (play areas, gardens, outside eating areas, pet runs, etc.).
22
3 LEAD  IN  THE SDIL:  WHY is IT A PROBLEM?

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                             PROPOSED SECTION 403
                 BARE SOIL-LEAD HAZARD IDENTIFICATION
          SOIL LEAD LEVEL                   RECOMMENDED
       (PARTS PER  MILLION)**               INTERIM ACTION

                                           Eliminate hazard:
          > 1,200 (hazard standard)             • Remove contaminated soil install
                                                 permanent covering.

                                           Implement interim controls:
                                               • Cover bare soil
         400-1,200 (level of concern)            . Use doormats in entryways.
                                               • Wash hands, toys,, etc., more frequently.


                   < 400                      * No action
** For the yard, concentration is derived from an arithmetic mean of two composite samples, one from the drip line and
one from mid-yard. For identified play areas, a single composite sample is used.

The  EMPACT LSYP's  mitigation strategy currently focuses on application  of interim controls,
though some permanent measures (blacktop) have been used for car park areas. Clearly, permanent
controls are desirable where the resources are available  to implement them. The EMPACT LSYP
targeted its mitigation measures toward low-cost/no-cost  options to  address neighborhoods and
homes where hazards exist and resources for mitigating  these hazards are limited.

It must be noted that the EMPACT LSYP approach to  soil measurement is different from the pro-
posed standard in several respects:

    1) The EMPACT LSYP maps the entire yard with  15 to 25 field screening XRF analyses;
      this results in clear identification of hazard areas  and the detailed information needed to
      apply controls in a cost-effective manner.

    2) Surface soils are analyzed in situ to provide data  on the soil material most likely to come
      into contact with the residents. Standard protocols would use field collection and offsite
      analysis of composite grab samples.

    3) The proposed 403 rule only applies  to bare soil,  while the EMPACT LSYP measures all
      yard surfaces.

    4) The proposed 403 rule relies on average measurements (composites) that will most often
      result in lower lead concentrations than the discrete in situ measurements used  to map
      yards in the EMPACT LSYP.
                                             3 LEAD IN THE  SOIL :  WHY is IT A  PROBLEM?    23

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                  For these reasons, the proposed 403 standards and the action levels used for the EMPACT LSYP
                  may not be directly comparable.  Nonetheless, before applying the EMPACT project's model to
                  your situation, you will need to consult local regulatory authorities to determine the requirements
                  you must meet. State/tribal and local government regulations may be more restrictive than existing
                  federal guidance.

                  3.4-.3.2    RESOURCE  CONSERVATION  AND
                                  RECOVERT  ACT  C4O  CFR  PARTS   24D—2991
                  RCRA regulates the disposal of solid and hazardous waste. EPA's interpretations  of RCRA regula-
                  tions  state  that soils  contaminated  with  lead-based  paint as  a result  of routine residential
                  maintenance and/or natural weathering or chalking of lead-based paint fall under the household
                  waste exclusion and are not regulated as hazardous waste. This means that material may be disposed
                  of off site in accordance with the regulations governing solid (non-hazardous)  waste, known as
                  RCPvA Subtitle D, as well as applicable state and local regulations. Lead-contaminated soil that falls
                  under the household waste exclusion need not be tested to determine if it is hazardous waste; if it
                  is tested and found to be hazardous waste, it is still exempt from the RCRA hazardous waste regu-
                  lations. You  should check with state and local authorities, however, to see what testing they require.

                  a.4-.3,3    LEAD-BASED  PAINT PQISQNINB
                                  PREVENTION  IN  CERTAIN  RESIDENTIAL
                                  STRUCTURES  C4O   DFR. PART 351
                  This HUD  rule establishes procedures to eliminate, as far as practicable,  lead-based paint hazards
                  in residential properties that are federally owned or receive federal assistance under HUD programs.
                  The rule requires lead  inspection  and  screening to be performed at all federally owned or assisted
                  target housing, or any time a child under six years of age is found to exhibit an environmental inter-
                  vention blood lead level (> 20  ug/dL for a single test or 15 to 19 ug/dL in  two tests taken at least
                  three  months apart). Target housing is defined as any residence built prior to 1978, excluding hous-
                  ing for the elderly or those with disabilities (unless children under the age of six are  expected to
                  reside there) or zero bedroom dwellings. Where a soil-lead hazard  is found to  exist, action  is
                  required to reduce the hazard.

                  The rule establishes six levels of protection: abatement of the lead-contaminated soil, abatement of
                  the lead soil hazards, interim controls, paint  stabilization, ongoing lead-based paint maintenance,
                  and safe work practices during rehabilitation.

                      •  When abatement (the permanent elimination of lead) is required for soil, the standards
                        promulgated under TSCA must  be followed. Abatement can be achieved through either soil
                        removal and replacement with uncontaminated soil or permanent covering of the
                        contaminated area (e.g., with pavement or concrete).

                      •  Interim controls are steps taken to temporarily reduce lead exposure or hazards. They
                        include impermanent surface coverings (e.g., sod, gravel, bark, artificial turf) and land use
                        controls (e.g., fencing, warning signs, landscaping).

                      •  The remaining actions (paint stabilization, ongoing lead-based paint maintenance, and safe
                        work practices during rehabilitation) are not directly applicable to soil, but can help reduce
                        the potential for increased soil contamination.

                  The specific level of protection required depends  on the  type of housing and the type of federal
                  ownership or assistance. Once  the required remedial action has been completed, the soil must  pass
                  the clearance examinations outlined in the regulations or further action will be required.
Z4     3 LEAD IN  THE SOIL;  WHY is IT A PROBLEM?

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3.5                         INFORMATION
3.5.1  ADDITIONAL
Agency for  Toxic Substances and Disease Registry.  1992.  Analysis Paper: Impact  of Lead-
Contaminated Soil on Public Health. Available online at http://www.atsdr.cdc.gov/cxlead.htnil.

Agency for  Toxic Substances and Disease Registry.  Philadelphia Neighborhood  Lead  Study,
Philadelphia, Pennsylvania. Report of Lead Exposure Pilot Study. Division of Health Studies. Atlanta,
GA. Available from NTIS (order # PB92-123777INZ).

Agency for Toxic Substances and Disease Registry.  1999- Toxicological Profile for Lead  (draft).
Atlanta: U.S.  Department of Health and Human Services, Public Health Service.

American Academy of Pediatrics Committee on  Drugs. 1995- "Treatment Guidelines  for Lead
Exposure  in  Children."  Pediatrics.  96:155—160. Available online  at http://www.aap.org/pol-
icy/0()868.html.

Center for Bioenvironmental Research at Tulane and Xavier Universities. 1996. Lead's Urban
Legacy. Available  online at http://www.tmc.tulane.edu/ecme/lcadhomc/soil.html.

Centers  for  Disease Control and Prevention. 1997- Screening Young  Children for Lead
Poisoning:  Guidance for State and  Local Public Health  Officials.   Available online  at
http://www.cdc.gOv/nceh/lead/guicle/l 997/guide97.htm, or call (toll-free) 1-888-232-6789.

Department  of  Housing  and  Urban Development.  1995-  Guidelines for  the  Evaluation
and  Control   of  Lead-Based   Paint   Hazards  in   Housing.  Available   online   at
hup://www. hud.gov/lea/ltarules.htrnl.

Department of Housing and Urban Development. 2000. Residential Lead Desktop Reference, 2nd
Edition. CD-ROM  containing more than 140 documents, including ASTM scopes, screening
guidance, community outreach materials, lead resources, scientific studies and reports, lead statutes
and regulations, lead training materials,  regulation support documents, reports  to Congress, HUD
guidelines, and other resources. Available for $10 by calling HUDUSER at 1-800-245-2691.

Lead-Based Paint Hazard Reduction and Financing Task Force. 1995- Putting the Pieces Together:
Controlling Lead Hazards in the Nations  Housing. Available online at http://www.hud.gov/lea/lcad-
wnlo.html.

Mielke, H.W. 1990.  "Lead Dust-Contaminated Communities and  Minority Health: A New
Paradigm," The  National Minority  Health  Conference:  Focus on  Environmental Contamination.
B.L. Johnson, R.C. Williams and C.M. Harris, Eds. Princeton, New Jersey: Princeton Scientific
Publishing Co., Inc.

Mielke, H.W. 1994.  "Lead  in New Orleans Soils: New Images of an  Urban Environment."
Environmental Geochemistry and Health.  16:123—128.

Mielke, H.W. 1997. "Leaded Dust in Urban Soil Shown To Be Greater Source  of Childhood Lead
Poisoning Than Leaded Paint." Lead Perspectives. 28—31 (March/April).

Mielke, H.W. 1999- "Lead in Inner Cities." American Scientist. Vol. 87, No. 1 (January-February).

Mielke, H.W, and J.L. Adams. 1989- "Environmental Lead  Risk  in the Twin  Cities." Center for
Urban and Regional Affairs. CURA 89-4. 22 pp.
                                              3  LEAD IN THE SOIL  ; WHY is  IT  A PROBLEM?    25

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                  Mielke, H.W., J.C. Anderson, K.J. Berry, P.W. Mielke, R.L. Chancy, and M. Leech. 1983. "Lead
                  Concentrations in Inner-City Soils as a Factor in the Child Lead Problem." American Journal of
                  Public Health. 73:1366-1369.

                  Mielke, H.W., S. Barroughs, R. Wade, T. Yarrow, and P.W. Mielke. 1984/1985.  "Urban Lead in
                  Minnesota:  Soil Transect Results  of Four Cities." Journal of the Minnesota Academy of Science.
                  50:19-24.

                  National Research Council. 1993-  Measuring Lead Exposure in Infants, Children and Other Sensitive
                  Populations.  Washington, D.C. National Academy Press. Order online at litcp://books.nap.edu/cat-
                  alog/2232.htnil.

                  U.S. Congress.  1992. Residential Lead-Based Paint Hazard Reduction Act of 1992. Title X (42 USC
                  4851). Available online at http://www.epa.gov/lead/tideten.html.

                  U.S. Environmental Protection Agency. 1994. EPA Guidance on Residential Lead-Based Paint, Lead-
                  Contaminated  Dust,  and  Lead-Contaminated Soil.  EPA540-F-94-045.  Order  online  at
                  http://WTvw.cpa.gov/nccpihom/ordcnng.htni.

                  U.S. Environmental Protection Agency. 1995- EPA Residential Sampling for Lead: Protocols for Dust
                  and Soil Sampling. EPA747-R-95-001.

                  U.S. Environmental Protection Agency. 1996. Distribution of Soil Lead in the Nations Housing
                  Stock. Available online at http://www.hud.gov/lea/lealead.pdt.

                  U.S. Environmental Protection Agency. 1997- Reducing Lead Hazards When Re modeling Your Home.
                  EPA747-K-97-001.  Order online at http://www.epa.gov/ncepihoni/ordering.htm.

                  U.S. Environmental Protection Agency. 1997- Risk Analysis To Support Standards for Lead in Paint,
                  Dust, and Soil,  Volumes 1 & 2.  EPA747-R-97-006. Available online at http://www.epa.gov/ncepi-
                  hom/ordering.htm.

                  3.5.Z
                  U.S. Environmental Protection Agency

                      National Lead Information Center
                      http://www.epa.gov/lead/niic.htm
                      A federally funded hotline and clearinghouse that provides information on lead hazard
                      reduction and exposure prevention. To speak with one of the Center's clearinghouse
                      specialists, call 1-800-424-LEAD Monday through Friday, 8:30 a.m. to 6:00 p.m. EST

                      Office of Pollution Prevention and Toxics (OPPT)
                      http://www.epa.gov/opptintr/lead/index.html
                      Responsible for EPA programs related to lead poisoning prevention and lead regulation.
                      OPPT also provides educational packets for parents, teachers, daycare providers, and
                      librarians, as well as  technical  information and publications.

                      Integrated Risk Information System (IRIS)
                      http://www.epa.gov/iris
                      An  electronic database containing information on human health effects that may result from
                      exposure to various chemicals  in the environment. The information in IRIS is intended for
                      those without extensive training in toxicology, but with some knowledge of health sciences.
26     3  LEAD IN THE SOIL; WHY is  IT  A PROBLEM?

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Lead Poisoning Prevention Outreach Program
http://www.nsc.org/ehc/lcad.htm
Funded through a cooperative agreement between EPA and the Environmental Health
Center.

Department of Housing and Urban Development,
Office  of Lead Hazard Control
h c t p: / / ww w. h u d - go v/1 ea/1 cah o rnc. h t rn 1
Sets standards for evaluation and management of lead in federally assisted housing,
and promotes efforts to reduce lead hazards in privately owned housing. In addition,
provides grants to communities to reduce lead hazards in housing.

Centers for Disease Control and Prevention
Childhood Lead Poisoning Prevention Program
http://www.cdc.gov/ncfh/lead/lcad.htm
Promotes state and local screening efforts and develops improved treatments for lead
exposure. CDC also provides a database, 1990 Census Data on Housing and
Population—Interactive Query, that allows you to search by county or zip
code to find the percentage of houses built before 1950.

Agency for Toxic Substances and Disease Registry (ATSDR)
h 11 p: / / www. atsdr. cdc.gov
An  agency of the U.S. Public Health Service established  by Congress in 1980 under the
Comprehensive Environmental Response, Compensation,  and Liability Act
(CERCLA), also known as Superfund. ATSDR is required by law to conduct a public health
assessment at each of the sites on the EPA National Priorities List to determine if people are
being exposed to hazardous substances, which includes lead. The public can search by region
to see which health assessments are currently available in an online  database located at
http://www.atsd r.cdc.gov/ H AC/PHA.

National Conference of State Legislatures
http://www.ncsl.org/progranis/ESNR/phdir.htni
Contains NCSLnet Search—a directory of state lead poisoning prevention contacts.

Consumer  Product Safety Commission
http://www.cpsc.gov
Identifies and regulates sources of lead exposure in  consumer products.

Occupational Safety and Health Administration
http://www.osha-slc.gov/SLTC/lcad/indcx.html
Develops work practice standards and worker exposure limits to protect workers
from occupational lead exposure.
                                          3  LEAD  IN  THE  SOIL :  WHY is IT A PROBLEM?    27

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                             4
THE
This chapter provides guidance on important first steps that you will need to take as you start your
lead-safe yard program. Section 4.1 presents a brief overview of the structure of a lead-safe yard pro-
gram and outlines the roles and  responsibilities of program  partners,  based on the  EMPACT
Lead-Safe Yard Project  model. Section 4.2 discusses the critical process of selecting program part-
ners who can best help  you meet your programs objectives within your target community. Section
4.3 presents guidance on identifying potentially impacted communities that you may want to tar-
get with your program.  Finally, Section 4.4 provides tips on getting to know your target community
in terms of the cultures and languages of residents, the types and conditions of housing stock, and
other factors.

The information in this chapter is designed primarily for managers  and decision-makers who may
be considering whether to implement lead-safe  yard programs in their communities, as well as for
organizers who are implementing such programs.

4.1                         STRUCTURE:
            OVERVIEW  OF  A  LEAD-SAFE  YARD  PRDBRAM
The EMPACT LSYP is a multifaceted project  that engages in a variety of activities—everything
from distributing flyers to planting grass. These  activities can be grouped into four main categories,
which make up the main components of the project: education and outreach, soil sampling, yard
treatment, and program evaluation.

The following paragraphs summarize these activities to  provide an overview of how the EMPACT
LSYP works. These activities are described in much greater detail in Chapters 5 through 9-

    Outreach  During  the outreach phase, the EMPACT LSYP approaches homeowners in the tar-
              get community to educate them  about the hazards of lead  in soil and to enroll them
              in the project. Outreach workers make contact with homeowners though flyers, let-
              ters, phone calls, and knocking on doors. Lead hazard education is conducted using
              a variety of tools (printed handouts, videos, quizzes), and then homeowners are
              asked to enroll in the project by  signing a permission form. Finally, outreach work-
              ers interview participating homeowners  about the activities  that take place in their
              yards; these  yard uses  are mapped on a  plot  plan, which is then given to the
              EMPACT LSYP's soil sampling  team and landscaping team.

    Sampling  During  the soil  sampling  phase, a field sampling technician (usually  a licensed,
              trained lead inspector) collects data on soil-lead levels in the yards of participating
              homeowners, using field-portable x-ray fluorescence technology.  Relying  on the
              yard-use map created during the  outreach phase, the technician develops  a sampling
              plan that focuses on high-risk and high-use yard areas, where the potential for dan-
              gerous   exposures to  lead-contaminated  soil  is highest.  Sampling   results  are
              transcribed onto a color-coded map of the property's lead levels, which is then given
              to the homeowner and  passed on to the landscaping team.

   Treatment  The EMPACT  LSYP provides each participating homeowner with up to $3,000
              worth of free landscaping materials and  labor  for yard treatment. Treatment  is
                                                                  4 BEGINNING THE  PROGRAM    29

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                                 conducted by one or more landscaping teams, headed by a landscape coordinator.
                                 This coordinator meets with the homeowner to go  over the color-coded map of
                                 sampling results and to develop a treatment plan. A typical treatment plan combines
                                 various landscaping measures (e.g.,  wood-framed drip boxes, newly planted grass
                                 and shrubs, stone walkways) with changes to the residents' yard use patterns (e.g.,
                                 moving a children's play area to a safe part of the yard). Once the treatment plan has
                                 been implemented  by the landscaping team,  the coordinator develops a property-
                                 specific  maintenance  manual to help the  homeowner maintain  the treatment
                                 measures.

                     Evaluation The EMPACT LSYP is currently involved in a major research study to evaluate the
                                 effectiveness of its low-cost yard treatment measures.  Evaluation is the last phase of
                                 the project; however, an effective evaluation process depends on adequate  docu-
                                 mentation of the project's work during all phases.  Key to the EMPACT LSYP's
                                 evaluation process is a property-specific case file begun by the outreach worker for
                                 each home, and maintained by all members of the EMPACT LSYP team.

                   The flow chart below summarizes  the  basic structure of  the EMPACT LSYP. The chart identifies
                   the  main activities of the project, the team members responsible for these activities, and the flow of
                   work between team members. It also indicates where in this handbook you can go for more infor-
                   mation about specific activities.
Program Manager
Identify target
community, select
program partners
(Chapter 4)

=>

Outreach Worker
Enroll homeowners In
program and educate
about soil-lead hazards
(Chapters)
                                                      Field Sampling
                                                       Technician
                                                    Collect and map data
                                                    on soil-lead levels at
                                                     target properties
                                                       (Chapters)
                                                                    Landscape Coordinator
                                                                    Design property-specific
                                                                   treatment plan, manage all
                                                                    landscape work, develop
                                                                     yard maintenence plan
                                                                      (Chapters 7 and 8)
  Program Manager
Evaluate effectiveness of
  yard treatments and
  education strategies
     (Chapter 9)
                   As described in Chapter 1, the EMPACT LSYP is a partnership of several public, private, and non-
                   profit organizations. These  include  a university, a federal government laboratory, a community
                   planning agency, and private landscape contractors.

                   Why are so many partners needed for what is essentially a small-scale program? The activities con-
                   ducted by the EMPACT LSYP demand a number of specialized skills, from communication and
                   language skills to soil sampling training, from landscape design experience to management skills.
                   Each partner plays a different role in the project, based on the specific skills and qualifications that
                   partner has to offer.

                   For example, EPAs New England Regional Laboratory, a founding partner in the EMPACT LSYP,
                   offers the technical skills needed for analysis of soil-lead levels.  The laboratory's staff also have the
                   training to work safely in contaminated  soil without endangering their own health. The Dudley
                   Street Neighborhood Initiative, the project's community partner, does not offer these kinds of tech-
                   nical skills,  but contributes something just  as  important: familiarity with the Dudley  Street
                   neighborhood and the communication skills necessary to work closely with its multilingual residents.

                   In starting your own lead-safe yard program, you'll need to assemble a team of individuals or organ-
                   izations who offer a similar range of skills and qualifications. To select partners or team members,
3D
4  BEDIMING THE PROGRAM

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                                                   LESSONS LEARNED: YOUTH
                                                  EMPLOYMENT AND TRAINING

                                                 In its pilot phase, the EM PACT LSYP
                                                 wished to incorporate youth
                                                 employment and training into its work.
                                                 The project hired high school students,
                                                 who learned on the job while being
                                                 supervised by adults. This system turned
                                                 out to be problematic in the pilot
                                                 phase. It was logistically complex, and
                                                 costs changed because the on-the-job
     training meant the work was accomplished more slowly than it would have with
     trained landscapers. For this reason, it is advisable to get your program organized and
     running smoothly, then determine which components of the program are a good match
     for youth training and employment. At that point, you can  focus on this aspect of
     a program.
you should think about how each will fit into the overall program structure, and how different part-
ners  can work together to create a successful program. You will also need to consider their
relationship to the target community. For example:

    • An organization or agency that already has strong ties to the community can be ideal for
     conducting outreach and education for your program. Neighborhood health centers or
     community action programs can be a good choice.

    • A nearby college or university can help with any research components of your program, or
     may be able to provide assistance and equipment for the sampling activities.  (See Appendix
     B for a more detailed discussion of this type of approach.) Make sure to check with your
     state or tribal lead poisoning prevention agency about certification requirements for lead
     inspectors. See Chapter 6 for more information on finding a qualified person to conduct
     the sampling and analysis components of your program.

    • Landscaping companies are key partners for the design and landscaping components of
     your program. A non-profit landscaping company specializing in community gardening
     and small parks can be a good choice. Another approach (being implemented by the
     EMPACT LSYP in Phase 3) is to develop a pool of small private landscaping companies.
     Encouraging companies to bid on lead-safe yard work, as described in Section 7-5, is a
     good way to obtain these services in a cost-effective manner. Landscaping companies should
     be bonded and insured, and should have the skills to manage the work involved in treating
     yards to meet your specifications.

As described  in Chapter 1, the EMPACT program selected partners who could carry out specific
activities. The community partners (Bowdoin Street Health Center, and later the Dudley Street
Neighborhood Initiative) led the education and outreach work; the EPA Regional Laboratory led
the sampling and analysis  activities, with assistance from a certified industrial hygienist from the
Health Center; a non-profit landscaping company performed the soil mitigation work; and Boston
University School of Public Health led the effort to  develop a template for community action for
use by other programs.
                                                                  4  BEGINNING THE  PRDERAM   3 1

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                  4.3       IDENTIFYINB  POTENTIALLY
                              IMPACTED  COMMUNITIES
                  The first step in beginning your lead-safe yard program is to identify communities that may have
                  homes with elevated soil-lead levels. For this purpose, you can determine where the important pre-
                  dictors of lead in soil are present. These predictors include large numbers of children with elevated
                  blood lead levels; a preponderance of older wood-framed housing (generally with wooden clap-
                  board), which is likely to have exterior lead-based paint; and heavy traffic flows, which are likely to
                  have caused deposition of lead from leaded gasoline. These characteristics are discussed in Sections
                  4.3-1 through 4.3-3- Industrial emissions of lead can also cause elevated soil-lead levels at residences
                  nearby (see Section 4.3-4).

                  You will also want to consider other characteristics of neighborhood life that can contribute to the
                  success of a program, such as the presence of a community organization that can partner with you
                  and help you get to know the community (see Section 4.3-5).

                  4.3.1  CHILDREN  WITH  ELEVATED
                  For Phases 1 and 2, the EMPACT LSYP reviewed available  blood lead data for children aged six
                  months to six years from the Massachusetts Childhood Lead  Paint Poisoning Prevention Program.
                  The target community was within the so-called "lead belt" in Boston  (see map on page 3). Your
                  city or state childhood lead program or health department likely has similar blood lead data, organ-
                  ized by census tract or zip code.  You can look up state and local lead poisoning prevention contacts
                  in your area on the following Web sites:

                      The Lead Program of the National Safety Council's Environmental Health Center:
                      http://www. iisc.org/ehc/nlic/contacts.htm

                      The National Conference of State Legislatures' Directory of State Lead Poisoning
                      Prevention Contacts: http://www.ncsl.org/progranis/csnr/phdir.htm
     SELECTION

 High incidence of lead poisoning
 Pre-1970 painted housing
 (generally wooden clapboard)
 Low-income/immigrant population
 Contiguous neighborhood (for
 neighborhood-wide impact)
 An existing health organization
 focused on the lead issue
 Existing neighborhood
 environmental activities the project
 could build on and enhance
•4.3.2 OLDER  HOUSING
          WITH  LEAD-BASED  PAINT
Another  way to identify potential  target  communities is  to  determine
which neighborhoods have older, wood-framed housing (generally with
wooden clapboard). Such houses are likely to  have  lead-based exterior
paint. As described in Chapter 3, some studies have found a strong link
between building age and soil-lead  contamination. Therefore, neighbor-
hoods with older housing (especially homes built before 1950) are more
likely than newer communities to have a soil-lead problem. The presence
of lead-based paint is also considered an important predictor of elevated
soil-lead levels. Both EMPACT study areas,  the Bowdoin Street neighbor-
hood in  North Dorchester  and the Dudley  Street neighborhood  in
Roxbury  and Dorchester, consist of predominantly older,  wood-framed
homes with painted exteriors  (generally wooden  clapboard).

The Centers for Disease Control provides a database, 1990 Census Data on
Housing and Population that allows you to  search by county, zip code, or
census tract for the percentage of houses built before 1950. The database
is at http://www.cdc.gov/nceh/lead/Iead.htm.
32    4  BEBININB  THE PROGRAM

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Keep in mind that some communities may contain vacant lots, greens, and parks in residential areas
that may  have historical lead contamination from gasoline deposition, past industrial activity,
or former housing. See Chapter 10 for tips on applying lead-safe yard mitigation strategies to
non-residential sites, such as tot lots, playgrounds, community gardens, and vacant lots.

4.3.3   HEAVY TRAFFIC   FLOWS
Some studies stress the concentration of lead-contaminated yards in congested high-traffic, inner-
city regions (see Chapter 3), pointing to  the  importance of  lead accumulations from leaded
gasoline. Both EMPACT study areas are in heavily traveled inner-city neighborhoods.

4-.3.4  INDUSTRIAL
Communities near industries that emit lead (or have emitted lead in the past), such as lead smelters,
lead mines, battery recycling plants, and incinerators, may also have elevated levels of lead in resi-
dential  soils. You  can find out where such industries are locating  by contacting your state
environmental agency or EPA Regional office, or by searching EPA's Toxic Release Inventory (TRI)
database for facilities  in your area  that have reported releases of lead to the  environment.
(http:\\www.epa.gov\cnviro \htrnl\toxic_rcl cases, hcml).

4-.3.5   OTHER  COMMUNITY CHARACTERISTICS
The EMPACT LSYP took into account several additional factors in potential target communities
that would contribute to the project's  success. For example, the  project targeted homes that were
located on adjacent streets rather than in dispersed  areas. This made the work more efficient and
made  it possible that homeowners would become interested in the lead-safe yard activities going on
nearby. It  also  meant that the neighborhood children would be better protected, because children
often  play in yards near their own.

The project also favored working in service areas of active community-based organizations—first
the Bowdoin  Street  Health  Center  and  later  the Dudley  Street  Neighborhood  Initiative
(http://www.dsni.org).  Both of the selected  neighborhoods had a history of environmental health
activities. The EMPACT LSYP could, therefore, build upon previous initiatives and take advantage
of neighborhood connections already made by these community organizations.

4.4                      TQ  KNOW  THE  COMMUNITT
Once  you  have identified your target community, your task is to learn more about it. Make sure
you have your target area clearly mapped and marked so that you can begin planning. Next, find
out the key "statistics" about the community. Some of the questions you will want to answer about
the community include:

    • What are the cultures and languages of the people who live there?

    • What are the residents' income and education levels?

    • What is the percentage of home  ownership/owner-occupied dwellings?

    • What is the percentage of housing built before 1978?

    • What is the condition of the older housing stock?

    • What organizations and agencies are active in the community?

    • What prior work has gone on in the community to prevent lead poisoning?
                                                                   4  BEGINNING THE  PROGRAM    33

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                      • What are the numbers, percentages, and location of lead-poisoned children in the community?

                      • Have any homes in the area been de-leaded?

                      • What are the names, addresses, and phone numbers of homeowners in the target area?

                  Information such as income and education levels and age of housing can be obtained from census
                  data; other questions about the community such as cultural characteristics can be provided by your
                  community partners. All this  information will help you form a clear picture of your  target com-
                  munity and the best  ways to  reach them. The EMPACT LSYP, for example, knew that many
                  residents in the Bowdoin Street neighborhood spoke Spanish, Cape Verdean Creole,  or Haitian
                  Creole, so that conducting spoken and  written outreach and education in these languages would be
                  critical to the  success of the program. Sample outreach flyers in four languages are included on
                  pages 41 to 44 in Chapter 5-
34     4 BEBININO THE  PROGRAM

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                                       COMMUNICATING  ABOUT
                                       IN   SOIL  AND YOUR
                                      YARD  PROGRAM
This chapter describes how to provide education and outreach to homeowners and residents about
the problem of lead in soil and the benefits of participating in a lead-safe yard program. Section 5-1
presents strategies for approaching homeowners and residents to inform them about your program
and to develop a sense of trust and credibility within your target community. Section 5.2 discusses
methods for educating people about soil-lead hazards and the benefits of your program. Section 5-3
is devoted to establishing an application process for enlisting homeowners in your program and
obtaining their consent for the work that will be done on their property.

The information in this chapter is designed primarily for managers who are implementing lead-safe
yard  programSj as well as for outreach workers who  are responsible for communicating about lead
in soil and your lead-safe yard program.

5.1      APPROACHING  HOMEOWNERS  AND  RESIDENTS
Once you have learned the basics about your target commu-
nity,  you can begin your education and outreach efforts.

First,  determine who will be conducting outreach and edu-
cation for your program. If possible, the outreach worker
should be a person who  lives  in  the community and is
respected and credible. People who do  not live in the com-
munity can sometimes be very effective, however (such as a
lead nurse from a community health center, or someone oth-
erwise familiar with the community and the issues people
there are facing).

A good next step is to develop an area-appropriate flyer, such
as the EMPACT LSYP's flyer on  pages 41 to 44 ("Dorchester
Lead-Safe Yard Program").  You  can ask  area businesses to
post  the flyer or allow you to do so. You  can also distribute
flyers to all the homes in your target neighborhood(s), then follow up by calling all the homeown-
ers to inform them of the project and their eligibility. Sending informational letters to the targeted
neighborhood homeowners might be an  effective alternative. Examples of initial and follow-up
letters used by the Lead Safe Boston program (a spinoff of the EMPACT LSYP) are included  on
pages 45 and 58 to 59. Other ways of increasing awareness of your program within the community
include radio promotions and forums at other local  promotional events.

The next step is to focus on meeting people  face to face. This is important because people need to
get to know and trust you before they open their home to your project. Below are some tips for
effective ways to approach people in person:

   • Walk around the area  on a pleasant  day or holiday, when people are most likely to
      be out of doors. Weekend  door knocking is recommended.

   • Vary the times of day at which you do outreach, but always be respectful of "normal waking
      hours" for people, unless you have been otherwise invited. Try not to go at family rush hours
      (around 8 to 10 a.m. or 4 to 6:30 p.m.); going at these times may turn people off to the project.
        Walk around your target community
on a pleasant day and talk to people face to face.
     5  COMMUNICATING ABOUT  LEAD  IN  SOIL AND YOUR LEAD-SAFE YARD PROGRAM   35

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Residents will need to get to know you
before they open their home to your project.
                                 If the area has a high percentage of non-English speakers and
                                 you don't speak the languages spoken in the area, try to get a
                                 friend or co-worker who speaks the most prevalent language
                                 to walk with you.

                                 Be sure to take project flyers with your name and number
                                 on them, permission slips, and information/referrals about
                                 lead testing, treatment, and de-leading programs.

                                 Attend events and meetings in the neighborhood to give out
                                 flyers and get to know people. The EMPACT LSYP
                                 outreach worker found that outdoor events such as
                                 community picnics are good venues for outreach work.
                                 Community garden and food projects may also yield
                                 receptive audiences.
                      • Remember that news about a project like this spreads by word of mouth and visible results.
                        Any negative perceptions will travel twice as fast as positive ones, so try to make only
                        positive impressions!

                  The EMPACT LSYP engaged in a wide  variety of additional activities to promote the  project
                  as well as to enhance community lead awareness. These included:

                      • Participation in a "Lead Expo" at a community  center, in the citywide Lead Awareness
                        Week, and in the neighborhood Multicultural Festival.

                      • Footage about the project on the local cable station (Neighborhood Network News).

                      • Discussion of the project in a segment entitled "Removing Lead from a Low-Income
                        Community" on National Public Radio's Living on Earth, an award-winning environmental
                        news magazine.

                      • Presentations at workshops  and conferences, including the Second  Syracuse Lead
                        Conference (October 1999)  in Syracuse, New York, and the Toxics Action '99
                        conference at Boston College in Newton, Massachusetts.
                              EDUCATING  PEOPLE
                              ABOUT   LEAD  AND  LEAD
5.2
                                                     IN  SOIL
Once you have identified people interested in the program and willing to speak with you at greater
length, you will have the opportunity to provide education about the problem of lead exposure,
explain the benefits of your program, and answer questions. The EMPACT LSYP's Education and
Outreach Plan is presented in the box on page 39-

In conducting education, you should convey the basic dangers of lead first—how and why lead is
dangerous to families' health,  as well as what  people can do to protect  themselves (de-leading,
proper nutrition, cleaning, etc.) Remember that you need to educate people not only about lead in
soil, but about all the sources of lead in and around the home. It is important to follow up on the
advice you give about these issues, so that people don't get frustrated and give up on slow-moving
assistance programs.

Many city or state childhood lead programs have developed excellent written materials on lead poi-
soning prevention  that you can use with residents. Examples  of some  used by the EMPACT
36    5 COMMUNICATING ABOUT LEAD IN  SOIL AND YOUR  LEAD-SAFE YARD PROGRAM

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program, from the Boston Childhood Lead Poisoning Prevention Program, are included on pages
46 to 55- Using the Internet, you can also access educational materials developed by EPA and other
federal agencies. These materials include:

    Protect Your Family From Lead in Your Home
    (EPA747-K-99-001, http://www.epa.gov/oppcintr/letid/Ieadpdfe.pdf) is a 16-page
    educational pamphlet that provides  general information about lead and lead hazards.
    A Spanish-language version can be found on HUD's Web site at
    Lead in Your Home: A Parent's Reference Guide
    (EPA 747-B-98-002, http://www.epa.gov/lt-ad/leadrev.pdf) is a more comprehensive
    guidebook, 67 pages long, that recommends steps parents can take to reduce their
    family's risk of lead exposure and prevent lead poisoning.

    What Every Parent Should Know About Lead Poisoning in Children
    (http://www.cdc.gov/ncch/lcad/hiq/cdcy7a.htrn) is a one-page fact sheet from the
    Centers for Disease Control and Prevention that provides basic information about
    lead poisoning and lead-paint hazards.

Keep  in  mind that written materials are  not always enough to  get  the message across.  The
EMPACT LSYP has found that outreach workers need to develop creative ways of emphasizing and
reinforcing the lead  hazard message (e.g., by using tools such as films and  quizzes), and to create
repeated opportunities for  homeowner re-education.  For tips  on  creative education strategies, see
"Lessons  Learned: Education and Outreach" on page  38, and Sections 8.4 and 8.5-

For your  lead-safe yard program, you will want to give special emphasis to why addressing lead in
soil can help protect health. You will need to explain how lead gets into soil, how children playing
in yards with contaminated soil are exposed  to lead, and how dirt and dust containing lead can also
be tracked into the home. Once the levels of lead in a yard's soil are tested, you can go over the rec-
ommended actions (based on these levels) for the yard (see Section 7-4).  Finally, the residents  need
to understand that landscaping measures do not  remove the contaminated soil; the landscaping
needs to be properly maintained to control exposure to the lead hazard, and future home improve-
ments need to be done safely to prevent recontamination.

            NEXT  STEPS;   ENLISTING
           THE  HOMEOWNER  IN  THE
If a homeowner has  shown interest in your program based on your initial outreach and education,
you can encourage him or her to take the next steps. The EMPACT LSYP found  that at this point
in the process  it was important to reassure  homeowners that they would not be  penalized if they
did not participate, and that there was no catch to the free landscaping provided.

The process  of enlisting the homeowner into your program  can  be as formal or informal as you
want to make  it. One option is to establish a formal application process that the homeowner will
complete before participating in the program. Lead Safe Boston, a spinoff of the  EMPACT LSYP
run by the City of Boston (see Section 1.2.1), requires homeowners to fill out an  application form
and submit copies of their insurance policy, their water and sewer payment  plan,  and a recent real
estate tax bill. Lead Safe Boston's application form is included on pages 56 to 57.

Once accepted into  the program,  the homeowner should sign a "permission slip" or consent form
that establishes an agreement between the  program and the  homeowner to allow testing of the
      5 COMMUNICATING ABOUT  LEAD  IN  SOIL AND YOUR LEAD-SAFE YARD PROGRAM    37

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                                LESSONS LEARNED: EDUCATION AND OUTREACH

                   A key to the success of a lead-safe yard program like EMPACT's is that residents understand
                   why lead in soil is harmful to their children. Without this understanding, it is more likely
                   that the landscaping measures will not be maintained, greatly reducing their effectiveness
                   in protecting children from lead exposure.

                   In its first two phases, the EM PACT LSYP followed a model commonly used for
                   community education and outreach: a bilingual outreach worker from the community
                   health center conducted typical outreach activities, including walking in the neighborhood,
                   door knocking, distributing flyers, speaking at community meetings, and talking with
                   people one on one. These efforts were culturally specific to the neighborhood and
                   conducted at an appropriate literacy level.

                   After Phase 2 was completed, the project returned to the residences where yard work had
                   been done to evaluate how the work had held up and what had been learned. They found
                   that people had not really taken in the problem of lead in soil, but viewed the project as
                   more of a landscaping program.

                   To remedy this shortcoming, in Phase 3 the project implemented a more comprehensive
                   education program, using several new approaches. The community outreach worker
                   received more extensive training on the lead issue. She helped devise a new plan to show
                   community residents a video, "The  Thief of Childhood," as a teaching tool about the
                   hazards of lead. After watching the video, residents were given a short quiz (see box oil
                   page 40). The quiz motivated the resident to pay attention to the video, whose key
                   messages were reinforced by the questions.  The outreach worker graded the quizzes and
                   discussed the answers with the residents. Thus, the education work used three different
                   modes of learning: visual (the video), written  (the quiz), and oral (discussion  of the video,
                   quiz, and educational flyers). The quiz will be used again when the yard mitigation work is
                   completed, to see whether the residents have retained the information.

                   So far, the project has judged this new approach to be more effective than using literature
                   alone. The video and quiz seem to be an engaging, interactive "hook" to promote a better
                   understanding of the lead problem and the health benefits of a lead-safe yard.

                   Another video that could be used for the same purpose is EPA's "Little Moccasins" Lead
                   Safety Program video, created for day care centers, clinics,  and families.  This  22-minute
                   animated video was developed by the Houlton Band of Maliseet Indians with funding from
                   EPA's Lead Program. An interactive "First Steps" CD-ROM is also available, presenting
                   helpful information on lead poisoning prevention in the form of video clips, games, and
                   songs. Ordering information for the CD-ROM and both videos is found in Section 5.4.
                   Ask your community or state lead officials to recommend other videos appropriate for
                   your audience.
                  property, participation in a design session, and subsequent remediation through landscaping. The
                  permission form should include language regarding the homeowners duty to have their property
                  in testable and workable condition (removal of trash, debris, and old cars; notification about/relo-
                  cation of pets). Again, the permission form can be formal or informal, depending on the needs of
                  your program. A very simple form, used by the EMPACT LSYP during Phases 1 and 2, is shown
                  on page 60. A more detailed consent form, developed by Lead Safe Boston, is shown on pages 61 to 62.
3B     5  COMMUNICATING  ABOUT  LEAD  IN  SOIL AND YOUR LEAD-SAFE YARD  PROGRAM

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At this point you should establish a case file that contains
all the information related to application, testing, mitiga-
tion, and follow-up tor  the  property.  The  EMPACT
outreach worker keeps all  this information,  including
"before and after" photographs, in a binder, which is
given to the homeowner when the work is completed.

Next, the outreach worker conducts a homeowner inter-
view. The interview is designed to obtain information
about the activities  that take place in the yard and the
ages and  numbers  of people  who use  the  yard. The
questionnaire  that the EMPACT outreach worker uses
is  shown on pages  63 and 64  (filled  out  for  a hypo
thetical home).

To map out yard use patterns, the outreach worker uses a
house plot plan, as shown on page 65- Plot plans can be
developed in  one of several  ways. For example, the out-
reach worker can visit the municipal assessor's office to
photocopy official drawings  showing the footprint of the
house and all property lines. A plot plan can also be devel-
oped using a geographic information system (GIS), or the
outreach worker can simply draw one by hand, using a
measuring tape and  pen and paper.  The plot plan devel-
oped during this outreach phase will be used later as a
guide for the field  testing crew and for the  landscape
coordinator, as described in Chapters 6 and 7-

The next step in the  process is testing of the yard soil, fol-
lowed by a design session with the homeowner if the yard
is  found to have high levels of lead. These steps  are
described in detail in Chapters 6 and 7 of this handbook.

5.4       FDR   MORE  INFORMATION
Your local or state childhood lead poisoning prevention
program may have  good educational materials  on lead
issues.

Lead education materials developed by EPAs Office of
Pollution  Prevention  and Toxics  can  be accessed at
http://www.epa.gov/lead/leadpbed.htm.

The following Web sites list state and local lead poisoning
prevention contacts:

    The Lead Program of the National Safety Council's
    Environmental Health Center:
    http://www.nsc.org/ehc/nlic/contacts.htm
        LEAD-SAFE YARD EDUCATION
            AND OUTREACH PLAN

1. Make appointment with interested applicants to
  discuss the problem of lead poisoning and the
  lead-safe yard and home program.
2. Home visit: First, ask them if they have had
  experience with lead poisoning. Have they had a
  child, relative, or neighbor who was lead poisoned?
  Using theeducational pamphlet, discuss five key
  points about lead poisoning:

    —How does a child usually get lead poisoned?
      (Paint chips, dust and dirt on hands and toys,
      lead in water)

    —How do you avoid lead in drinking water?
      (Run tap water until it is cold)

    —How do you avoid lead in the home?
      (Specific lead-safe home cleaning and
      maintenance procedures)

    —Why is dust on children's hands and toys, as
      well as on window sills and floors,  a problem,
      especially if the house is not de-leaded?
      (Children may put hands, fingernails, toys,  or
      food dropped on floor in their mouths)

    —What foods are good for preventing lead
      poisoning?  (Foods high in iron, calcium,
      and vitamin C, and low-fat foods)

    This is a good time to show the photos of the LSYP.

3. Give the homeowner the video which is available in
  multiple languages, explores the dangers  of lead
  paint poisoning, its adverse health effects, and prac-
  tical measures for protecting children  (see Section
  5.4 for ordering information). Also give the home-
  owner the set of questions to answer after viewing
  the video. (The answer sheet can be returned imme-
  diately after watching the video,  or later, with  the
  lead-safe yard and home application.)

4. Explain the application process and documentation
  needed for the lead-safe yard program.

5. Leave the application, video, and sheet of questions
  (if the homeowner hasn't  returned it already) with
  your business card.
      5 COMMUNICATING ABOUT LEAD IN  SOIL AND YOUR  LEAD-SAFE YARD  PROGRAM    39

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                      The National Conference of State Legislatures' Directory of State Lead Poisoning Prevention
                      Contacts: http://www.ncsl.org/programs/esnr/pbdir.htm

                  For guidance on writing clearly and effectively for a general audience, try http://www.plainlanguage.gov.

                  Video: "Lead Paint Poisoning: The Thief of Childhood" (20 minutes, 1996)

                      This video explores the dangers of lead-paint poisoning and its adverse health effects. It
                      provides information, education, and practical advice on  protecting children,  using
                      interviews and discussions with educators, health care providers, and culturally and
                      linguistically diverse parents whose children have been  lead poisoned. The video  is available
                      in English, Spanish, CapeVerdean Creole, Haitian Creole,  and Vietnamese. Available for $10
                      from: City of Boston, Office of Environmental Health, 1010 Massachusetts Avenue, Boston,
                      MA 02118. Phone 617-534-5966, Fax 617-534-2372.

                  Video: "Little Moccasins" Lead Safety Program Video (22 minutes)

                      This lead poisoning prevention video was developed for day care providers, clinics, and
                      families by the Houlton Band of Maliseet Indians, with funding from EPA's Lead Program.
                      The video is available in  English, but may soon be available in Spanish and some Native
                      American languages. Available free of charge  from  Philip  Quint, Lead Director, Houlton
                      Band of Maliseet Indians, at 1-800-545-8524 or 1-207-532-4273- E-mail quint@ainop.com.

                  CD-ROM: "First Steps"

                      This CD-ROM, developed by the Houlton Band of Maliseet Indians with funding from
                      EPA's Lead Program, presents helpful interactive information on lead poisoning prevention
                      in the form of video clips, games, and songs. Course manuals are available on the CD in
                      English, Spanish, and Native American motif. Available free of charge from Philip Quint,
                      Lead Director, Houlton Band of Maliseet Indians, at 1-800-545-8524 or 1-207-532-4273-
                      E-mail quint@ainop.com.
                          QUIZ TO ACCOMPANY FILM, "THE THIEF OF CHILDHOOD"

                    1. By what year was lead no longer used in new house paint?
                    2. How can a child get lead poisoned?
                               a) paint chips                 b) dust
                               c) drinking water              d) all of these
                    3. Name some foods that are good for children and that help decrease
                      blood lead poisoning.
                    4. How can you avoid lead in drinking and cooking water?
                    5. How can you avoid lead hazards from home interiors?
                    6. Name two ways in which lead has gotten into yard soil.
                    7. Give three suggestions for protecting children in the home and yard from
                       becoming lead poisoned.
4D     5  COMMUNICATING ABOUT LEAD IN SOIL AND YOUR  LEAD-SAFE YARD PROGRAM

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DORCHESTER  LEAD-SAFE YARD PROGRAM
      FREE SOIL TESTING  IN YOUR YARD FOR LEAD
            WE ARE LOOKING FOR 50 YARDS IN YOUR NEIGHBORHOOD
                          WITH HIGH LEVELS OF LEAD
             IF YOUR YARD MEETS A CERTAIN LEVEL, YOU COULD BE
           ELIGIBLE FOR $700 WORTH OF FREE MATERIALS AND LABOR
             WHICH WILL MAKE YOUR YARD SAFER AND ATTRACTIVE
                          WITHOUT ANY COST TO YOU!
The Dorchester Lead-Safe Yard Program is a collaboration of the Bowdoin Street Health Center, the New
England Environmental Protection Agency Laboratory, Boston University School of Public Health and
Garden Futures. The purpose of this pilot program is to show that low cost methods exist which will make
your yard safer. By improving the safety of your yard, we hope this will further reduce the risk of our chil-
dren six years of age and younger becoming lead poisoned.

Your neighborhood has been chosen for this pilot project because there are a number of children with high
levels of lead in their blood. Lead is especially hazardous to children. This is the main reason we want to
conduct this pilot program.  Because children play in many parts of this neighborhood,  you do not have to
have children six years of age or younger to participate.

We will first test your yard for lead content and if your yard qualifies, we will work with you on certain meth-
ods of reducing exposure to  elevated lead levels. Staff from Garden Futures will provide landscape materials
and  labor to complete the work in your yard.

If you are interested in participating in this program, please call the number listed at the bottom of this page.
We will be in the neighborhood speaking with you and your neighbors about this program. If you have ques-
tions, please do not hesitate  to call.

         FOR MORE INFORMATION OR TO PARTICIPATE IN THIS PROJECT,  CALL

                    Bowdoin Street Health Center, (617) 822-5318
       5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM   4 1

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          PROGRAMA DE PATIOS SIN PLOMO
                         DE DORCHESTER
                 (Dorchester Lead-Safe Yard Program)
                   PRUEBAS DE PLOMO GRATUITAS EN SU PATIO

    ESTAMOS BUSCANDOS 50 PATIOS EN EL VECINDARIO CON ALTOS NEVELES DE
                              PLOMO EN LA TIERRA.

            SI SU PATIO CONTIENE PLOMO, USTED PUEDE SER ELEGIBLE
           PARA RECIBIR 700 DOLARES, ENTRE MATERIALES Y TRABAJO,
             PARA REMOVER EL PLOMO DE LA TIERRA Y EMBELLECER
                   SU PATIO SIN COSTO ADICIONAL PARA USTED.

 El Programe de Patios sin Plomo de Dorchester es una colaboracion del Centra de Salud de Bowdoin Street,
 el Laboratorio de la Agenda de Protection Ambiental de Nueva Inglaterra, la Escuela de Salud Publica de
 Boston University y Garden Futures. El objective de este programa piloto es il mostrar que existen metodos
 a bajo costo que haran sus patios mas seguros. Mejorando los patios esperamos reducir el riesgo que corren
 los nifios de seis anos y menores de acabar envenenados com plomo.

 Su vecindario ha sido escogido para este programma piloto debido al alto numero de nifios envenenados o
 con altos niveles de plomo en la sangrue. El plomo es realmente perjudicial para los nifios, y eelo es la razon
 por la que queremos realizar este programa. Debido a que  los nifios juegan en diferentes partes del vecin-
 dario, usted no tiene que tener nifios de seis anos o menores para participar.

 Primero mediremos la tierra de su patio para ver si esta contiene plomo, y si es elegible trbajaremos con uste
 par mostrarle ciertos metodos para reducir el nivel de plomo en la tierra. Personal  de Garden Futures traba-
 jaran proveyendole materiales jardineria y trbajaran para completar el trabajo en su patio.

 Si usted esta interesado en participar en este programa, por favor llame a la persona listada mas abajo en esta
 pagina. Estaremos  en el vecindario hablando con usted y sus vecinos sobre este programa. Si tiene alguna
 pregunta, por favor llamenos.

             Para Mas information o Para Participar en este Programa, Llame
                    Bowdoin Street Health Center, (617) 822-5318
42    5 COMMUNICATING ABOUT LEAD IN SOIL. AND YOUR LEAD-SAFE YARD PROGRAM

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Dorchester Lead-Safe Yard Program
Um teste gratuito para detectar veneno de chumbo no seu patio/quintal. Procuramos 5
patios, na vizinhari9a, com nivel de veneno de chumbo elevado. Se o seu patio/quintal
mostrar um nivel elevado de veneno de chumbo no solo voce se qualificar a receber uma
quantia de $700 no valor de materials e mao-de-obra, o que Ihe ira ajudar a tornar o seu
quintal mais atractivo e seguro. Este programa Ihe sera ofericido  sem nenhum custo
monetario.

Este programa e uma colabora9ao de Bowdoin Street Health Center, New England
Environmental Protection  Agency Laboratoiy,  Boston University  School of Public
Health e Garden Futures. O proposito do programa e para mostrar que existen meios, a
pre?os accessiveis, para remover o veneno de chumbo do solo, e tornar o seu patio/quin-
tal mais seguro. Ao reduzir o nivel de chumbo no solo, esperemos que ira  diminuir a
possibilidade dos  seus filhos, menores de seis  anos di idade, contrairem  veneno de
chumbo no sangue.

A sua vizinhan9a foi escolhida para este programa porque existe un numero  elevado de
criancas contaminadas de chumbo no sangue, o que e bastante prejudicial, e pode causar
graves problemas de saude. Porque as crian9as brincam em varies lugares, nao e neces-
sario que voce tenha filhos/as para poder participar neste programa.

Faremos un teste para detectar resdios de chumbo. Se o seu patio qualificar, entraremos
em contacto consigo para discutirmos meios de como reduzir o nivel do chumbo. O pes-
soal de Garden Futures providenciara materials e mao-de-obra. Se voce esta interesada/o
em participar neste programa, por favor contacte:
               Bowdoin Street Health Center, (617) 822-5318
   5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM   43

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      Pwogram  Ki  Okipe Lakou Kont Plon
               Tes Gratis Nan Lakou Pou Plon

          Nap Chache  Sinkant Pie Nan Lakou Ki
                          Nan Zon Nan

             Ki  Genyen Yon Nivo Plon Ki Wo.
  Si lakou a genyen Yon nivo plon, ou kapab elijib pou yon zafe de set san dola an mateiyo & men dev
  sak ka fe lakou bel, san danje e gratis.

  Pwogram sila ki pou kimbe lakou san danje. Mare avek Bowdoin St. Sant pou Sante, N.E. EPA,
  B.U.S. of PH. & Garden Futures. Rezon pwogram sa se pou montre ou metod bon mache ki egziste
  pou fe lakou san danje ak plon. Pake timoun yo ap jwe tout kote. Ou pa bezyen gen timoun sizan ou
  byen timoun pi piti pou patisipe.

  Nap Teste lakou pou plon, si lakou a kalifye nap travay ak ou pou redwi nivo plon an. Nap ba ou
  materyo ak zouti pou travay sila.

  Si ou enterese patisipe nan pwogram nan souple rele moun sa ke ou we nan an ba fey la. Nap pale ak
  ou e ak vwazen ou o sije pwogram nan.

  Si yon gen keksyon pa ezite rele:

                  Bowdoin Street Health Center, (617)  822-5318
44   5 COMMUNICATING ABOUT LEAD IN SOIL. AND YOUR LEAD-SAFE YARD PROGRAM

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                     DEPARTMENT OF NEIGHBORHOOD DEVELOPMENT
                                     BOSTON'S PUBLIC FACILITIES DEPARTMENT
                                          THOMAS M. MENINO, MAYOR
                                   CHARLOTTE GOLAR RICHIE, CHIEF AND DIRECTOR
January 5, 2000


Dear Property Owner:

The City of Boston's Lead Safe Boston program, in conjunction with the National Center for Lead Safe Housing
and the Environmental Protection Agency, would like to offer you the chance to improve the quality of the grounds
surrounding your home through a unique program:

                         Low Level Soil Treatment Demonstration Project

                 There is no cost involved or work required on the part of the property owner!

 Properties meeting project criteria and enrolled in the program will be part of an effort to demonstrate low-cost soil
      interventions through the use of landscape treatments mat will enhance the appearance of your home!

                                What the Program Can Offer You!

              Up to  $3000 to cover the design, acquisition and installation of landscape elements.
                      Comprehensive testing/sampling of soil surrounding your home.
                       Scaled drawings of your property identifying lead hazard areas.
                     Fully developed plans showing proposed treatments and plantings.
                     Supervised construction and installation of all landscape treatments.
                                   Detailed educational information.

                              What We Ask Property Owners To Do!

                          Answer a questionnaire concerning Lead Paint Hazards.
                       Allow project staff to sample the soil surrounding your home.
                  Participate in and provide feedback during the landscape design process.
                                  Enjoy your newly landscaped yard!!!

             A representative of Lead Safe Boston and The National Center for Lead Safe Housing
                 will soon be contacting you about your possible involvement in this program.

                     We hope you decide to join us in this important endeavor!

       Please call the  Lead Safe Boston office at (617) 635-0190 with any questions regarding the program.
            COMMLJNICATfNB ABOUT  LEAD IN SOIL AND Ya U R LEAD-SAFE YARD PROGRAM   4-3

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           Fact  Sheet:  LEAD
      What is Lead?
      Lead is a poisonous metal found in nature.  Because it is durable
      and persistent, it was used in house paint, pipes, cans, old toys,
      cribs, and furniture.
                    If a house was built before 1978, it probably
                    has lead paint. Lead dust can be created by
                    just opening and closing windows.
      What does lead poisoning do to mv
      child?
      Lead poisoning can damage your child's
      brain, cause hearing loss and learning
      disabilities, and impair motor skills.
                    How can my child be exposed?
                    Your child can be exposed to lead by touching
                    window sills, ledges, an-d other areas which
                    have lead dust, and then putting their fingers in
                    their mouths.  This is normal behavior for
                    children.
     Finding the Lead
     The only way to find out where the lead is in the house is to have a
     lead inspection done by a licensed inspector,  if the inspector finds
     lead, then a licensed contractor must come in and make the
     house safe. You cannot live in the house while this is happening.
•46  5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM

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 Lead Dust is Invisible
 The most common way for children to be poisoned is by exposure
 to lead dust.
                    What Can 1 Do?
                    Make sure your child has a well-balanced diet,
                    which includes miik (for calcium), dark green,  '
                    leafy vegetables (for iron), and vitamin C.
                    Have your child's blood tested regularity.
  Wash Hands and Toys Often!
  Wash your child's hands and toys often, and
  keep fingernails short.

  Run the tap waterfor a few minutes every
  morning. Use only COLD water for cooking
  and drinking. Hot water concentrates the
  lead.
                       Keep It Clean!
                       Wipe windows, windowsiils and dusty
                       surfaces with warm water and TSP. Throw
                       used paper towels away after wiping.
Don't Disturb Leaded Paint!
Make sure that there is no loose or flaking paint.
NEVER scrape painted surfaces.
           For more information, contact the Boston Childhood Lead Poisoning
             Prevention Program at the Boston Public Health Commission
              1010 Massachusetts Avenue, 2nd Floor, Boston, 'MA 02118
                           (617)534-5966
  5 COMMLlNICATiNe ABOUT LEAD IN SOIL AND Ya U R LEAD-SAFE YARD PROBRAM  4- "7

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                    How Much Do You Know
                     About Lead Poisoning?
                           MYTH
                           There is no way to prevent children from
                           being lead poisoned.

                           FACT
                           Lead poisoning is completely preventable
                           Get the facts and learn how to protect
                           your child by getting lead out of your home
                           safely.
     MYTH
     Children have to eat paint chips, or chew on
     walls, to be lead poisoned.

     FACT
     Children can be poisoned simply by breathing
     lead dust. They can also be poisoned by
     having lead dust on their toys or fingers and
     then putting their fingers in their mouths.
                        MYTH
                        Only children with very high levels of lead in
                        their blood will be hurt by the lead.

                        FACT
                        Low levels of lead in a child's blood can cause
                        long term problems and permanently affect
                        [earning and behavior.
•4S   5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM

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                     MYTH
                     Only children who live in the inner city can be
                     lead poisoned.

                     FACT
                     Any child, from any neighborhood, can be
                     lead poisoned. Lead paint can be in any
                     home built before 1978.
MYTH
Lead poisoning is not a real problem. Many
people grew up in homes with lead paint
and are perfectly healthy.

FACT
The lead paint that existed in homes twenty
years ago is much more dangerous now,  As
lead paint gets older, it is likely to peel chip,
and create lead dust. This is a real health
hazard.
                 MYTH
                 Having a home deleaded is much more
                 dangerous than just leaving the lead paint there.

                 FACT
                 Lead removal must be done by a licensed
                 deleader who will use safe techniques and who will
                 clean up properly.
          Far more information, contact the Boston Childhood Lead Poisoning
            Prevention Program at the Boston Public Health Commission
              1010 Massachusetts Avenue, 2nd Roor, Boston, MA 02113
                          (617)534-5966
  5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROBRAM  4-9

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         TEMPORARILY REDUCING  LEAD  PAINT
                         HAZARDS  BY CLEANING
                                                                                   L window well
                                                                                 — window sill
1  Wear plastic gloves to clean
   Protect yourself from exposure to lead.

2  Pick up all chips by hand or use a damp paper towel
   {Window areas often have lots of paint chips)
   • Seal chips and paper towels in a plastic bag and throw out
    Do not use a household vacuum or broom to clean up
    lead paint chips or dust!

3  Wash household surfaces
   • Use TSP, a lead-specific detergent, or any all-purpose,
    non-abrasive cleaner.
   • Scrub well for best results. (Don't scrub hard enough to
    remove the intact paint.)
   • Clean window wells, window sills, play areas, and floors
    at least ones or twice a week.
   • Keeps children away when cleaning.
   • Keep all cleaners safely away from children.

4  Use a  spray bottle to keep dust levels down
   • Use a cleaner already in a spray bottle, or put the cleaner into a spray bottle.
   • If you must use a bucket, keep the wash water clean. Never put dirty paper towels into the wash water.

                                        5 Use paper towels
                                           • Don't use dish cloths or sponges to clean.
                                           • Use a new paper towel to clean aach area.
                                           • Seal the used paper towels and gloves in a plastic bag
                                            and throw them out.

                                         6 Rinse after cleaning
                                           Use clean water and paper towels for rinsing each area.

                                         7 Clean up properly
                                           • Wash your  hands when cleaning is done.
                                           • Pour any wash  and rinse water down the toilet not
                                            the  sink.
                                                Important! Do not use a household vacuum
                                                or broom to clean up lead paint chips or
                                                dust. This could spread the lead dust into the
                                                air and into your vacuum cleaner or broom.
        Massachusetts Department of Public Health « Childhood Lead Poisoning Prevention Program
5D
5  COMMUNICATING  ABOUT LEAD IN SOIL AND  YOUR  LEAD-SAFE  YARD PROGRAM

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TEMPORARY  WAYS  TO  KEEP  CHILDREN

      SAFE  FROM  LEAD  PAINT HAZARDS

    Under the Lead Law, the property owner is responsible for having his or her home deleaded or brought
    under interim control if it was built before 1978 and achild under the age of six lives there. Deleading
    permanently- reduces the risk of lead poisoning. Until deieading occurs, here are some temporary ways
    to reduce lead hazards:
.1  Clean often
    Wet wiping regularly reduces, lead dust levels in the home. See other side.
2  Put duct tape or contact paper over peeling paint and pfaster
    Put duct tape or contact paper on window wells, window sills, walls or other surfaces with peeling
    paint or plaster. Clean these areas often. Window wells and sills can be cleaned more easily when
    contact'paper or duct tape are put down first. See other side.
3  Keep the lower part of the window closed {if possible)
    If a window well'is in bad condition, keep the lower part of the window closed and open only the upper
    part. This will prevent your children from putting their hands or objects in the window well where the
    lead dust collects. It also helps keep lead dust from blowing into the. house.
4  Move furniture to block contact with peeling paint and plaster
    By moving a sofa in front of a crack in a wall, you can block a  child's access to lead hazards.
    Never place furniture where a child  may climb on it and fall out of a window.
5  Change child's bedroom (if possible)
    If your child's bedroom.has chipping paint or plaster, consider using another room.without chipping
    paint for the bedroom.
6  Other ideas
    Regularly have your child tested for lead poisoning; wash your child's hands and toys often; if you are
    renovating or repainting call  CLPPP for more information on how to do the work safely before you
    begin; feed your child food high in iron, calcium, and vitamin  C and low in fat.
   Lead Poisoning and your child health
   Lead pain is the most common cause of childhood lead poisoning. When old paint cracks or peels, or
   when lead paint surfaces rub against each other or are bumped, lead paint dust or chips are created.
   Children typically become poisoned by putting their fingers which have touched lead dust into their
   mouths. Lead poisoning can cause lasting damage to children's brains, kidneys and nervous system.
   Even lower levels of lead can slow children's development and cause learning and behavioral problems.
   Children under six are at greatest risk.

   Keep your child safe
   Remember, these are only temporary ways to reduce the risk of lead poisoning from lead paint hazards.
   The only permanent way to reduce the risk of lead poisoning is to have the home deleaded. The owner
   of a home built before 1978 is responsible for having it deleaded or brought under interim control when
   a child under the age of six lives there.
 FOR MORE INFORMATION, CONTACT:                   or your \oca\ \ea
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                        BOSTON CHILDHOOD LEAD POISONING PREVENTION PROGRAM
                       UNDERSTANDING WHAT BLOOD LEAD (PB)
                                     TEST RESULTS MEAN:
IF THE CHILD HAS A
PB LEVEL OF:
9 ug/dL or below
10 - 14 ug/dL
15 - 19 ug/dL
20 - 24 ug/dL
25 ug/dL and above
70 ug/dL and above
THEN:
A child with a blood lead level below 9 is not considered to be
poisoned.
The CDC defines a level over ten as a "level of concern/' The child
should be tested again frequently. Check with your pediatrician. He
or she may prescribe multi-vitamins and iron.
The child's pediatrician should be involved in helping brins this
blood lead level down by managing the child's diet and increasing
nutrition. In addition, the child should be tested frequently. An
environmental assessment should be done to find out where the lead
is coming from. Prevention measures should be implemented
immediately.
Get a complete medical evaluation, and have the child's home
inspected for lead. Find and get rid of lead hazards in the child's
home, school, and play areas.
A child with a blood lead level above 25 is considered poisoned.
A lead inspection in the home is required, and it is essential that the
child visit the doctor immediately. This is very serious. Medical
treatment such as chelation may be used.
A child with this level is considered a medical emergency.
         For help understanding your child's test result, talk with your pediatrician or health care provider. For
         information and assistance regarding inspections and removing lead hazards from your home in Boston
         contact: The Boston Childhood Lead Poisoning Prevention Program at (617) 534-5966.

         Outside of Boston, call  The Massachusetts  Department of Public Health's Childhood Lead
         Poisoning Prevention Program at (800) 532-9571.
                       For more information, contact the Boston Childhood Lead Poisoning
                          Prevention Program at the Boston Public Health Commission
                           1010 Massachusetts Avenue, 2nd Floor. Boston, MA 02113
                                            (617)534-5966
52
5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM

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         PROGRAMA DE PREVENCION DEL ENVENENAMIENTO INFANTIL CON PLOMO

 COiVIPRENDA EL SIGNIFICADO DE LOS RESULTADOS DEL EXAMEN
                     DE PLOMO EN LA SANGRE (PB):
SI SU NINO TLENE
UN NTVEL DE:
9 ug/dL o menos
10 - 14 ug/dL
15 - 19 ug/dL
20 - 24 ug/dL
25 ug/dL y mayor
70 ug/dL y mayor
ENTONCES:
Se considera que un nino con un nivel de plomo en la sanare con
menos de 9 no esta envenenado.
El Centro de Control de Enfermedades (CDC) define un nive! mavor
de 10 como un "nivel de interes." El nino defae ser chequeado
frecuentemente. Consulte con su pediatra, este le puede recstar
multi-vitaminas e hierro.
- El pediatra debe colaborar y ayudarle a reducir el nivel de plomo en
la sangre de su nino, atraves de cambios en la dieta y nutricion.
Tambien. el nino debe ser chequeado frecuentemente y ei ambiente
tiene que ser examinado para encontrar la fuente del plomo.
Medidas de prevencion tienen que ser implementadas
inmediatamente.
Su nino necesita una completa evaluation medica. EI pediatra puede
recetarie hierro. Localize el lugar de donde proviene el plomo y
aleje a su nino de este lugar. Recuerde que la fuente de plomo puede
estar en su casa, en la escuela y donde juesa su nino.
Se considera que un nino con un nivel de plomo en la sangre mayor
de 25 esta envenenado. _ Interventions ambientales y medicas tienen
que ser implementadas inmediatamente. Un tratamiento medico y
medicinas pueden reducir el nivel de plomo en la sanare.
Un nino con este nivel es considerado una emersencia medica.
Si necasita mas ayuda para coraprender los resultados de su nino, hable con su pediatra.  Para mas informacidn
sobre como puede  remover el plomo de  su casa en Boston,  [lame  ah Programa de Prevencion dc!
Envenenamiento Infandl Con Plomo al (617) 534-5966.

Si usted vive fuera de Boston, liame al Progranu de Prevencion del Envenenamiento Infantil Con Plomo del
Departamento de Salud Piiblica de Massachusetts al (800) 532-9571.
                      LA COMISION DE SALUD PUBLICA DE BOSTON
          1010 MASSACHUSETTS AVENUE, 2oo Piso / •» BOSTON, MASSACHUSETTS •* 0211S
                    * (617) 534-5966 (VOICE)* (617) 534-2372 (FAX) *
5 COMMUNICATiNO ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD  PROGRAM   53

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       Foods  That  Help  Reduce
   the  Harmful   Effects  of  LEAD

    Lead is poisonous to the body.  Infants, children under six, and
    pregnant women are at the greatest risk for lead poisoning.
              Caicium is very
           Important for growing
           bodies.  Extra calcium
              will help protect
            children from lead
                poisoning!
Foods to Eat for Calcium


         Milk
        Yogurt
         Tofu
        Cheese
    Sardines and Tuna
   Green leafy vegetables
 (Collard greens, broccoli, kale)
     Lead looks like calcium, zinc and iron to the body. The body absorbs
     lead just like these important minerals, but lead is harmful, not helpful,
     to normal development.   This  is why it is important for you and your
     children to eat a balanced diet.
54  5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM

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     When  you  don't  have enough vitamins  and  minerals  in
      your diet,  your  body will absorb  more lead.  Lead is
         stored in the  bones, just like calcium and iron.
         Foods to eat to get IRON
               Lean meats
             Chicken, Turkey
              Black beans
              Kidney beans
                  Rice
          Cereai with added iron
               Dried fruits
              Peanut Butter
              Corn Tortillas
        Dark green leafy vegetables
          (like spinach and kale)
     IRON is very
    important for
  growing bodies.
  Extra iron will help
protect children from
   lead poisoning!
Iron works better with Vitamin C.  Eat oranges, mangos,  green peppers
fomatos, and drink real fruit juices (not fruit punch or kool aide) to help
your body absorb iron.
                 For more information, contact the Boston Childhood Lead Poisoning
                   Prevention Program at the Boston Public Health Commission
                    1010 Massachusetts Avenue, 2nd Floor, Boston, MA 02113
                                  (617)534-5966
    5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM   55

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                                      CITY OF BOSTON
                DEPARTMENT OF NEIGHBORHOOD DEVELOPMENT
                             LEAD SAFE BOSTON PROGRAM

 38 Winthrop Street
 Hyde Park, Ma 02136
 (617) 635-0190

 LEAD SAFE BOSTON YARD PROGRAM APPLICATION
                                  APPLICANT (Owner of Property)

 Name:	

 Property Address:	

 I live here	      I do not live here	  # units in building	

 Mailing Address (Investor-Owners only):	
 Phone: (home)	(work)	  SS #_
 Identify your ethnic/racial category	Female Head of Household Yes	No

 Contact person	Phone (home)	
                      CO-APPLICANT (Co-owner of property only if listed on deed)

 Name:	

 Mailing Address:	

 Phone: (home)	(work)	SS #	

 Identify- your ethnic/racial category	


 Please check the appropriate answer                                 Yes           No
 1. Do you have a current homeowner's insurance policy in place?      	     	
    (If yes, attach a copy of the insurance certificate to application)

 2. Are you current with your Boston Water and Sewer Payments?      	     	

        If no, do you have a payment plan in place?                  	     	
 3. Are vou current with you real estate taxes?
 4. Please complete the child information below (use additional sheets if necessary).
56    5  COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD  PROGRAM

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Name of Child(ren)           Date of       Unit # where
Who live on the property      Birth          child(ren) lives
AUTHORIZATION TO PROCEED WITH
LEAD SAFE YARD PROGRAM APPLICATION

I am interested in participating in the Low level Soil Treatment Demonstration and Evaluation Project, as outlined
in the Homeowner Consent Form. I understand in order to be eligible for this grant program I. as the Owner of the
Property, must be in good standing with my Boston Water and Sewer account, be current on my real estate taxes and
have a homeowner insurance policy in place. I also understand that this program is being offered to protect children
and that there must be young children living here: either the child/ren who lived here during the Round 1 evaluation
or at least one child under the age of 6 years old.

I hereby certify that the information that is provided in this application is true and complete to the best of my
knowledge.  I will make mis information available for review upon request by the City of Boston's Department of
Neighborhood Development, the U.S. Department of Housing and Urban Development,  or its designee. I authorize
the program to proceed with my application.
Applicant's Signature:	    Date:


Co-Applicant's Signature:	    Date:
                        TERMS SUBJECT TO CHANGE WITHOUT NOTICE
       MISSING INFORMATION WILL DELAY PROCESSING THIS APPLICATION AND MAY
                             JEOPARDIZE FUNDING AVAILABILITY!
         5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD  PROGRAM    57

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                       DEPARTMENT OF NEIGHBORHOOD DEVELOPMENT
                                       BOSTON'S PUBLIC FACILITIES DEPARTMENT
                                            THOMAS M. MENINO, MAYOR
                                     CHARLOTTE GOLAR RICHIE, CHIEF AND DIRECTOR
 March 28, 2000

 Homeowner Name
 Homeowner Address
 Mattapan, MA 02126

 Dear Homeowner:

 Thank you for your interest in our Lead Safe Boston Yards Program. As you know from visiting w?ith our outreach
 person Yvonne Illich of Silver Linings, if you participate in this program you will receive at no cost to you,
 comprehensive testing/sampling of the soil surrounding your home; drawings of your property identifying lead
 hazard areas; fully developed landscape plans showing proposed treatments; supervised construction and installation
 of all  landscape treatments and detailed educational information about how to maintain your lead safe yard!

 On March 6. 2000 we sent you a letter requesting the following documents. As of today, we have not received the
 documents listed below. It is important to note that we need these items before we can enroll you property in our
 program. Please use the enclosed  self-addressed stamped envelope to send copies of the following documents to
 our office.

 	/	 Boston Water and Sewer written approved payment plan.

 	 Copy of current insurance policy for the property that will receive yard treatments.
 Since this program will begin in early spring and funding is limited, it is very important mat the document(s) be
 forwarded to our office as soon as possible. If your application is still incomplete after April 6, 2000, we will not be
 able to enroll you in our lead in soil grant program.

 We are looking forward to working with you on this Low: Level Soil Treatment Demonstration Project. Yvonne
 Illich will be contacting you later this week to offer you assistance in sending this information to our office. If you
 have any questions, please contact me at 617/635-0193.

 Sincerely,
 Sandra R. Duran
 Lead Safe Boston

 Cc: File
SB    5 COMMUNICATING  ABOUT  LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM

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                     DEPARTMENT OF NEIGHBORHOOD DEVELOPMENT
                                     BOSTON'S PUBLIC FACILITIES DEPARTMENT
                                          THOMAS M. MENINO, MAYOR
                                   CHARLOTTE GOLAR RICHIE, CHIEF AND DIRECTOR
June 12, 2000

Homeowner Name
Homeowner Address
Dorchester, MA 02124

Dear Homeowner:

Congratulations, you have been officially enrolled in the Lead Safe Boston Yards Program!

As a participant in our Lead Safe Boston/National Center for Lead-Safe Housing Low Level Soil Treatment
Demonstration and Evaluation Project, you will receive a grant of up to $3,000 worth of design and landscaping
work to reduce the exposures to lead in soil on your property. For your files, we have attached a copy of the consent
form that you signed. This form details the terms of our program that you are required to comply with in exchange
for this granted scope of services. This is a very important project and your participation is vital to our efforts to
demonstrate that low cost soil treatments are instrumental in reducing dust lead levels found inside homes.

Now that your property has been enrolled, EPA will sample the soil around your home and analyze the samples for
their lead content. Once the results are available, one of our landscape contractors will set up an appointment with
you to review your current yard use. With your input he or she will design a landscape plan that will abate the lead
hazards found around your home.

Once the  design is approved, the landscape contractor will schedule another appointment to review the design with
you and determine the start date of your project. It is important to note that any debris that the landscape contractor
determines needs to be removed in order to facilitate his work must be completed before work can begin.

Once the  new landscaping work is complete, the landscape contractor will schedule a convenient time to meet with
you to review the work and to explain the information contained in a Homeowner Maintenance Manual that will be
yours to keep. Over the course of the following year, there will be times when our outreach person will return to
your property to take dust wipes inside the entrance to your home and your tenant's units.  We would like to thank
you in advance for your cooperation in providing access to these areas.

If you have any questions regarding the program please feel free to contact me at 617/635-0193.

Sincerely.
Sandra R. Duran
Lead Safe Boston
         5 COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM    5"3

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                 HOMEOWNER PERMISSION FORM


 Most homes in Boston have lead in the yard soil. This comes mainly from leaded paint flaking or
 being scraped off houses and leaded gasoline which was used in cars until recently. Lead in soil
 can harm children because dirt and dust get on  children's hands, toys and other objects that
 they often put in their mouths. Lead in soil can also be tracked into the house.

 PURPOSE  OF THE PILOT PROGRAM

 The Lead-Safe Yard Program is a project to make yards in your neighborhood safer for residents,
 especially children. We plan to do this by making low-cost and easy-to-in stall landscape
 improvements in yards with high lead levels in soil.

 PROGRAM ELEMENTS

 1. Analysis.
    As part of your voluntary participation in the Lead-Safe Yard Program, the soil around your
    property at	
    will be analyzed for lead content. We  will provide the analysis free of cost.

 2. Improvements.
    If the lead in your  soil is above certain levels,  we will suggest different kinds of landscaping
    options for you to choose. These may include covering the soil with barriers such as: mulch,
    wood chips, crushed stone, and shrubs. We will discuss options for children's play areas and
    vegetable garden sites also. We will make the improvements that you choose, with materials
    and labor provided free of cost.

 VOLUNTARY PARTICIPATION

 Your participation is voluntary because there is no obligation to reduce or protect against the
 lead in your soil. If you wish to be part of the Lead-Safe Yard Program, we will make an
 appointment to analyze your soil and make the results available to you If your soil has high levels
 of lead, we  will make a second appointment to discuss the yard improvements and to plan a
 schedule for the landscaping work.

 Value

 If the levels of lead in your soil are above 400  parts per million, you are eligible to receive
 materials, services, and labor in landscape improvements free of cost from the Lead-Safe Yard
 Program.

 I understand the conditions of this agreement and  I agree to participate in the program.
 Signature                                                Date
SO   5  COMMUNICATING ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM

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                                   Homeowner Consent Form
                 Lead-Safe Boston/National Center for Lead-Safe Housing
             Low  Level Soil Treatment Demonstration and  Evaluation Project

I am interested in participating in the Low Level Soil Treatment Demonstration and Evaluation Project.
 If I meet the criteria for this project and if my property is accepted for the project, I understand that I
will receive up to $3,000 worth of design and landscaping work to reduce the exposures to soil lead on
my property in exchange for my participation in the program. The work will be completed in the year 2000 or 2001.

I will receive the following:
    1. Up to $3,000 worth of design and landscaping work for my property.
    2. Comprehensive testing/sampling of soil surrounding my home.
    3. Scaled drawings of my property identifying the lead hazard areas in my yard.
    4. Fully developed landscape plans showing proposed treatments and plantings.
    5. Results of limited dust testing taken before, immediately after and one year after the work has been done.
    6. Detailed educational information about how to maintain my yard.
    7. A new door mat after all dust collection activities have been completed.

I agree to do the following:
    1. Complete an application form and provide a copy of my homeowner's insurance policy to project staff.
    2. Remove any debris, trash, old cars or other identified items that would make soil sampling or landscape work
      difficult or not possible.
    3. Participate in an initial interview to identify my current or planned uses of the yard.
    4. Meet with the landscape designer to provide input into the plan.
    5. Allow access to my yard for site testing by Region 1 EPA, prior to starting and after completion of the
      landscape work.
    6. Allow access to my home for dust testing by Silver Linings, Inc. Dust testing will take place three times
      (immediately before the work is done, after work is done, and one year after work is done) and include wipe
      sampling and laying down a dust collection mat to better measure accumulation of lead dust over time. I will
      allow Silver Linings, Inc. access to my home to pick up the mats about two weeks after each has been put in
      place.
    7. Meet with the landscape designer after the plan has been developed, to review and approve the plan.
    8. Allow the landscape designer access to my yard to complete planned treatments.
    9. Cooperate with the landscape designer and allow him/her to use at no  cost my utilities (such as lights, heat,
      power and water) as needed to cam' out and complete the work.
    10. Meet with the interviewer and landscape designer after work is completed to review my Homeowner
       Maintenance Manual, conduct dust testing, and complete project evaluation forms.
    11. If a one year evaluation of this project is funded, allow one more site visit approximately one year after
       the yard work has been completed by the interviewer who will conduct dust testing and complete project
       evaluation forms.
    12. Speak with the press and/or participate in a press event and/or publicity related to the Lead Level Soil
       Treatment Demonstration and Evaluation Project.
         5 COMMUNICATING ABOUT  LEAD IN SOIL AND YOUR LEAD-SAFE YARD  PROGRAM   6 1

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  I will formally sign off on the proposed scope of work, Form #09 Owner Approval of Scope of Work, and Form #19
  Homeowner Education and Project Completion Certificate, indicating that the work has been successfully completed.

  I understand that Lead-Safe Boston will oversee the landscape work done in my yard and that the project's inter-
  viewer. Yvonne Illich of Silver Linings, will coordinate collection of most of the data for this project. Soil-lead
  measurements of my yard will be taken by the EPA as soon as it is  feasible to sample, depending on weather condi-
  tions; I do not need to be present during this sampling. Because of changes in field conditions such as weather, I
  will not be notified in advance of the EPA sampling date.

  If I have any questions about the construction work for this project, they will be answered by Sandra Duran. Lead-
  Safe Boson at 617-635-0193. If I have questions or concerns about the evaluation aspect of this project, they will be
  answered by Pat McLaine, National Center for Lead-Safe Housing at 1-800-624-4298.
  Homeowner #1 signature                     Date


  Homeowner #2 signature                     Date


  Interviewer signature                         Date


  1 copy to homeowner

  1 copy to Evaluation Files
62    5 COMMUNICATING ABOUT LEAD  IN  SOIL AND YOUR LEAD-SAFE YARD  PROGRAM

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          HOMEOWNER YARD USE/TREATMENT OPTIONS INTERVIEW

 Name:	
 Address:
 Using a "clean" copy of the plot plan with house footprint:

 1.  Show me where people walk through the yard going to and from the house.
    (exposed soil?)	
 2. Show me where children play (how many and how old?)
3. Show me where people raise vegetables (or do other gardening)
4. Show me where people eat outside
5. Show me where pets (especially dogs) spend their time
6. Show me where cars or other vehicles are parked or repaired
7. Show me where people walk to hang out clothes
8. Show me other areas for:
   Sunbathing	
   Garbage cans .
   Recycling bins
   Composting —
   Hobbies	
9.  Tell me any other places and ways children or adults spend their time in the
   yard,	
       COMMUNICATING ABOUT LEAD IN  SOIL AND YOUR LEAD-SAFE YARD PROGRAM   63

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                HOMEOWNER YARD USE/TREATMENT OPTIONS INTERVIEW

       Nome:	   		

       Address: IO

       Using o "cleon" copy of the plot plon with house footprint:

       1.  Show me where people walk through the yard going to and from the house.
          (exposedsoil?) H^>rc% ACUL>^ju^CL*-*"b-> Ax.cfc!.., 4-  Q^&^**.<3d?O~±-£
       2.  Show me where children play (how many and how old?) "oQ-C-L,*
                                       A lo-N>  -rvl
       3.  Show me where people raise vegetables (or do other gardening)
       4.  Show me where people eat outstde  oo  di«o\C-  4-
       5,  Show me where pets (especially dogs) spend their time  OO ~T
       6,  Show me where cars or other vehicles are .parked or repaired
           :xo.
          _    _ _ _          Ci

       8.  Show me other areas for:
          Sunbathing
Garbage cans
Recycling bins -rvx.r Jr..
                               L
          Composting   OO
          Hobbies rv>
       9.  Tell me any other places and ways children or adults spend their time in the
          yard. .CXt-f'Aga^jr. "tsn_r4" U^  Lrs M~Rjt^ ^ t. >WTNTN roJUT"
                                     - -  -    -                         —
64   5 CDMMUNICATINB ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM

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      10  HOME  STREET
                 oo-sC
       - .» « * «
       ****** » « _
        * .••»••:•.••>
SCALE: i"» r-io-
                                  \
                                    I
                                              YARD USE PATTERN KEY
                                                     DOTS
                                              High Traffic Area (Exposed Soil)
                                                     LINES
                                              High Risk Use Area
                                              (Play Area or Vegetable Garden)
                                                    CROSS HATCH
                                              Recreation Area (Picnic or BBQ)
  5 COMMLJNICATfNB ABOUT LEAD IN SOIL AND YOUR LEAD-SAFE YARD PROGRAM  63

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                            6
COLLECTION  AND  MANAGING
DATA  ON   LEAD  IN
This chapter describes a state-of-the-art technique, using field-portable x-ray fluorescence technol-
ogy, for collecting and managing data on lead in soil. This technique allows inspectors to discern
patterns of contamination in a property quickly and accurately. The technology can be used only
by trained, certified inspectors who meet federal, state, and local requirements for collection of
environmental samples,  as described in Section 6.4. This chapter is not intended to provide guid-
ance for inspectors, but  to give you, as a program organizer or decision-maker, an overview of the
data collection and management process.

Section 6.1 is an overview of data collection and management techniques used by the EMPACT
Lead-Safe Yard Project. Section 6.2 provides information on how to find the necessary equipment
and laboratories for testing and how to cut costs. Section 6.3 is a step-by-step description of test-
ing, quality control, and data  management procedures that are used by professional inspectors;
Section 6.4 discusses health and  safety precautions for inspectors; and Section 6.5 is devoted to
equipment maintenance.

If you mainly want a general idea of what data collection and management entails, you can focus
on Section 6.1 alone. Sections 6.2  through 6.5 present more detailed material for those who are
responsible for implementing a lead-safe yard program. Such readers may also be interested in the
reproducible site worksheets at the end of this chapter.

6.1   COLLECTING  AND  MANAGING
        DATA:  AN  OVERVIEW
A key component of the EMPACT Lead-Safe Yard Project is the use
of field-portable XRF technology. This technology allows inspectors
to provide residents with onsite, real-time data about lead contamina-
tion  in yards, without  having to wait for the results of laboratory
analysis. Field-portable XRF requires a substantial capital investment,
as noted in Sections 6.2 and 6.5-  On the other hand, programs com-
mitted to soil inspection for the  long haul may find
that  the investment more than pays for itself. The
EMPACT LSYP  has conducted XRF  analysis on
roughly 2,000 soil samples over the past three years,
which makes the cost per sample far less than it would
have been for laboratory work. After all, sending sam-
ples to a lab involves not only charges for the analysis
itself but also the expense of sample collection, ship-
ping, and handling.

Studies have affirmed the accuracy of XRF, and it has
received EPA verification as well.  (For example, EPA's
Environmental Technology Verification Program has
conducted field demonstrations to test several XRF
technologies.  Verification Reports  and  Statements
                                                  The XRF is a band-held field-portable device that allows inspectors
from   these   tests  are   available   online   at   to get a lead-level reading within seconds.
                                     COLLECTING  AND MANAGING DATA DN  LEAD IN  SDIL   E>"7

-------
                   http://www.epa.gov/etv/verifrpt.htm#monitoring.) What makes XRF technology especially valu-
                   able for a lead-safe yard program is that it offers real-time results with a hand-held, battery-powered
                   device. This means that inspectors, while on site, can get parts per million (ppm) lead levels for
                                                  individual soil samples within seconds, and, if necessary, adjust
                                                  their testing strategy  for the  property as  a whole accordingly.
                                                  Experience has shown that lead concentrations in properties often
                                                  vary significantly and unpredictably. With XRF, inspectors can
                                                  learn about any  unusually high lead levels right away and then
                                                  take more closely spaced readings in the area from which the high
                                                  reading came. The result is a clearer delineation of how soil con-
                                                  tamination differs from one part of the property to another.

                                                  One concern that has been raised about field-portable XRF is that
                                                  it tests for lead only at the surface level. Many experts, however,
                                                  are convinced that this is usually where the lead  level in soil actu-
                                                  ally is highest. Also, the top layer of soil clearly poses the greatest
                                                  potential health risk because ot its accessibility.
Inspectors mark the location of each XRF reading on
a plot plan and record lead levels on a site worksheet.
                   When the EMPACT LSYP conducts XRF testing, the first step is to determine some rough guide-
                   lines  by interviewing  the  homeowner and  observing current  conditions  in  the yard.  Several
                   high-risk or high-use areas may be identified. As the sample interview form in Chapter 5 suggests,
                   these could include gardens, picnic areas, and children's play areas,  in addition to areas of bare soil
                   and heavy foot traffic. Such parts of the property are singled out for  careful inspection. Another tar-
                   get is the drip line, generally a 3-foot-wide strip around the foundation of a house where lead tends
                   to have  been washed into the soil by rain.

                   The  EMPACT LSYPs procedure  for taking XRF  readings is  straightforward. The XRF and test
                   guard are placed on the exposed soil surface and depressed to open  the shutter. A 30- to 60-second
                   measurement should yield reliable results. As inspectors take these readings, they mark the location
                   of each  on a plot plan of the property and record the lead levels on  a site worksheet. Also recorded
                   on the worksheet are measurements that fix the location of the reading somewhat more precisely.
                   Any  other relevant  descriptive information, such as the weather and  the general  condition of the
                   yard, is noted on the worksheet as well.

                   The  ppm lead levels from different locations within a particular  area—say, the east drip line—are
                   averaged to yield a mean value. Depending on this value, the EMPACT LSYP assigns each area to
                   one of its four categories  (see Section 3-4.3-1  tor a comparison with proposed categories under
                   TSCA Section 403):

                       • Very high  (5000  ppm or more)

                       • High (2000 to 5000 ppm).

                       • Moderately high (400 to 2000 ppm).

                       • Low (400  ppm or less)

                   Detailed guidance about mitigation strategies for each of these categories is provided in Chapter 7
                   of this handbook.

                   The  EMPACT LSYP takes  several quality control measures  to  back up XRF readings on every
                   property. Accuracy and reproducibility  are checked periodically  using continuing calibrations
6B    6 COLLECTING AND MANAGING DATA ON  LEAD IN  SOIL

-------
(against a known standard) and replicate
measurements,  respectively.  Inspectors
also collect a small number of soil samples
for confirmatory lab analysis. Since XRF
is still a new technology, its results need
to be judged against the gold standard of
accepted practice, in this case inductively
coupled plasma  (ICP) or atomic absorp-
tion  (AA) methods, both of which are
conducted in a laboratory and take about
2 to  4 weeks.

Nevertheless,   inspectors  often  have
enough confidence in their XRF  findings
to give homeowners and landscapers  a
provisional color-coded  map  of a prop-
erty's lead levels  well before the results of
confirmatory lab tests are available. The
map on page 81  is an example.  Inspectors
may prepare such a drawing before they
even leave the site, using markers or col-
ored pencils and a copy of the plot plan.
This  hand-drawn  method  is  simple,
immediately  interpretable, and  readily
accessible    to    the    homeowner.
Alternatively, the XRF  readings  may  be
taken to an office and used to  produce a
computer-generated  map, as shown on
page 82.  Either way, homeowners and
landscapers  can  gain a general  under-
standing of what areas of a  yard need
remediation and start making plans.

Once a lead-safe yard program has tested
a sizable cross-section of properties in a city,
it might be useful to record the results on
a map to see if a  geographical pattern
emerges. If such a pattern does  emerge,
the information  could be made available
to the public, perhaps on  a Web site, to
promote  awareness  of the lead-in-soil
problem and help homeowners and com-
munities make more informed decisions.

As an  example,  maps showing the lead
content  of  soil in  various  parts  of
New  Orleans,  Louisiana,  are  available
online  at  http://www.tmc.uulanc.edu/
ccmc/leadhome/soil.huml.  Environmental
                                      1998

In Phase I of the EMPACT Lead-Safe Yard Project, lead in surface
soil concentrations measured in the Bowdoin Street neighborhood
ranged from 103 to 21,000 ppm.
The mean value for these data was 1,632 ppm (n=781). Twenty-
two percent of the measurements were above 2,000 ppm, and 87
percent were above 400 ppm.
       Distribution 0-10,000
          1000  2000  3000  4000  5000  6000  7000  8000  9000 10000

                               lead—ppm

       Distribution 0-2,000
   150
   100
          200   400   600   800  1000  1200  1400  1600  1800  2000

                               lead—ppm

              Lead Concentration Distribution for Phase 1 Field Work
                                                    6 COLLECTING AND MANAGING DATA ON LEAD IN BOIL    6 9

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                  toxicologist Howard Mielke of Xavier University in New Orleans analyzed 3,074 surface soil sam-
                  ples representing 283 census tracts. The data indicate that the most contaminated areas  usually lie
                  in the central part of the city, where traffic is heaviest.

                  6.2      GETTING  STARTED
                  Individual homeowners or groups planning a very limited lead-safe yard program will probably just
                  want  to hire a risk assessor certified tor use of XRF for soil analysis. In any case, local authorities
                  regulating lead abatement activities should be consulted.Those seeking to implement an extensive
                  program will probably want to buy their own field-portable XRF to be used by trained/certified
                  inspectors working with the program. The EMPACT LSYP uses an instrument manufactured by
                  Niton Corporation17, which also provides training. For information, call  1-800-875-1578 or visit
                  http://www.niton.com. See Section 6.4.2 for information about XRF use licenses and certification.

                  An XRF similar to the one used in the EMPACT LSYP, a field portable  Niton Model  702, costs
                  about $26,500, making it the most substantial expense a program will face. Day-to-day mainte-
                  nance of the XRF is generally not costly, though programs will face the additional expense (around
                  $2,600) for replacement of the instrument's radioactive source  at least  once every two years, if not
                  more frequently (see Section 6.5)- Some savings are possible, however. The box below provides
                  some suggestions; for example, it describes a less costly XRF instrument that was not available when
                                                     the  EMPACT LSYP purchased its instrument.

            "                                      A lead-safe yard program may also save money if it can align
 Recently, Niton has developed a field portable         itself with a university, which is much more likely if the work
 XRF that tests for lead  alone, not the wide range      has  a research component. In this case, the school might pick
 of other metals detectable with a 700-series           UP some or all of the cost of the XRF, and interns paid by the
 Niton. This instrument, the XL309, costs just        school  might conduct inspections under the supervision of a
 $17,000, and a version  exclusively for lead in soil      faculty member. This type of approach is described in more
 is available for $15,000. The main reason the         detail in Appendix B, which presents less-resouice-intensive
 XL309 is so much less expensive is that it lacks a       approaches to implementing lead-safe yard programs.
 high-resolution silicon pin detector. But this
 feature is useful largely for measuring levels of        6.3     TESTING  STEP  BY  STEP
 elements such as arsenic, which require a great        _,. .     .     ,    .,                             r   .
  ,   .  c    .  .    ,   . .   ,  .                        1 his section describes the  procedures  used by professional
 deal or precision. Lead levels, by contrast, are         .             .           '        r     .,
 c • i  L   j                . I • i     I   .            inspectors  in the EMPACT  LSYP  tor soil testing, quality
 rairly broad measurements. A high-resolution                                                              J
 silicon pin detector is not necessary.                  control> and data management.  In  developing these proce-
                                                     dures, the EMPACT LSYP relied on two primary sources: 1)
                                                     Method 6200 from EPA publication SW-846 (entitled Test
                  Methods for Evaluating Solid Waste, Physical/Chemical Methods], EPAs compendium of methods on
                  evaluating hazardous waste; and 2) the Quality Assurance Project Plan  (QAPP) that was  developed
                  for the EMPACT program. What  follows is mainly a  summary ot the directives from  these two
                  sources, along with  recommendations and insights from the programs inspectors themselves. You
                  can go  to http://www.epa.gov/epaoswer/hazwaste/test/sw846.htm to  learn more about SW-846
                  and obtain a copy online. The EMPACT LSYP's QAPP is provided in Appendix D.

                  6.3.1  BEFORE  BEGINNING
                  The inspectors should plan to allot about two hours for testing a typical  residence.  Homeowners
                  need  not be present, but they do have to have signed a permission form (see Chapter 5).  Ideally, all
                   'Mention of trade names or commercial products In this publication does not constitute endorsement
                    or recommendation for use.
VD     6 COLLECTING AND MANAGING  DATA ON LEAD IN  SOIL

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the information about yard use gained from observations and homeowner interviews will have been
incorporated into the plot plan prepared during outreach and education. This plot plan will be used
as a guide for testing. See Section 5-3 for guidance on conducting homeowner interviews and devel-
oping a plot plan. A sample kiterview form and plot plan can be found on pages 63 to 65.

Favorable weather conditions are necessary for testing. Experience shows that XRF testing does not
work well when the ground is frozen or when the air temperature falls below 40 degrees Fahrenheit.
And while high  temperatures usually pose no problem,
direct  sunlight can cause the  instrument to  overheat.
Inspectors should take care to shade it on sunny days, even
in relatively cool weather.

Soil moisture can not only interfere with readings but also
damage the XRF,  so soil that is saturated with water should
not be tested. This condition is most likely to occur  in
early spring, when the ground absorbs water inefficiently
because it hasn't yet thawed and dried out from the winter
months.  Inspection should be delayed in the event of rain
as well; even after the rain has stopped, testing may still  be
inadvisable for several hours, because of standing water on
the grass. The XRF can generally tolerate humidity, however.
                                                         Inspectors take at least two readings along
      ..  .       r     r i                                  the property border on each side of the house.
11 conditions are favorable, and all the necessary paperwork
is in place, inspectors may prepare the property for testing. Debris such as rocks, pebbles, leaves,
and roots should  be removed, and  the ground should be made flat enough to allow uniform con-
tact with the XRF. In some cases grass or plant material may need to be moved aside to expose the
soil surface. As they do this,  inspectors must remember that lead in soil is mostly  a surface phe-
nomenon,  and  that readings may not be accurate if the ground is disturbed too much.

6.3.2  TESTING  STRATEGY
Although each property is different and must  be approached with its unique characteristics  in
mind, testing typically focuses on four main concerns: the drip line, play areas, areas of exposed soil,
and areas that may be contaminated with lead from sources other than the house, such as structures
on abutting properties. In the EMPACT LSYP, if play areas are found to have lead levels greater
than 400 ppm, they are tested further to determine the extent of contamination. Other areas are
subjected to extra testing if they  are found to have levels greater than 2000 ppm.

A variety of formats for testing are possible, but data collection is generally more systematic and
efficient  if inspectors decide on one format and use it consistently. In the EMPACT LSYP, the sides
of the house on a property are labeled A, B, C, and D. The A side is that which bears the house's
address, and the B, C, and D sides follow in a clockwise fashion. Inspectors start at the corner where
the A and D sides meet, then cover the whole A portion of the yard, and after that the whole B,  C,
and D portions, until finally they arrive at the A-D corner again.

The pattern for testing a particular area on any of the sides of the house depends on the size and
shape of that area. In long, narrow areas such as drip lines, initial XRF readings are generally taken
at 10-foot intervals  along an imaginary line that extends from one end of the area to the other. If
an area is not long  enough to yield at least three  readings with this method,  inspectors  mentally
divide  the imaginary line into thirds and take a reading from each third.
                                                     6 COLLECTING AND MANAGING DATA ON LEAD IN SOIL    "7 1

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                        Generic Testing Pattern
                         19

11

10

9
House
3 2 LI— r1 1
                                 Street
                 Scale
                20 feet
             10ft.      10ft.
72   6 COLLECTING AND MANAGING DATA ON LEAD IN SOIL

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     Inspectors then take a second series of XRF readings along an imaginary
     line that is parallel to the first one but 2 to 5 feet away from it. If the area
     is in fact a drip line, this second imaginary line usually falls outside it, so
     lead levels are  expected to drop off. If they don't, further testing is con-
     ducted to ascertain whether and where they do.

     Before completing testing on any one side of the house, inspectors take
     at least two readings along the property border. These readings are gener-
     ally evenly spaced. If either reading shows elevated lead levels, additional
     reading are taken along the border.

     For other areas of concern, including play areas, an imaginary X is usu-
     ally superimposed  on the ground.  Readings are taken at 5- to 10-foot
     intervals along each line of the X. If the area is too small to yield at least
     five readings with this method, inspectors mentally divide the lines of the
     X into thirds and take a reading from each third.

     When sufficient  readings have been obtained from a given area, the lead
     levels  are averaged to produce a mean value, and on the  basis of this value,
     the area  is assigned to a specific  lead-level category, as explained  in
     Section 6.1.
                         Testing Pattern for Play Areas,
                      Gardens, and Other Areas of Concern
4
N
X
\
\
.
/
/
/
/
5
Play Area rjT\
| Q |
/
/
/
/
3
\ s
V
M

Scale
10 feet
5ft. '
5ft.
7
V
2
\
\
\
tu
t
[start Testing |

                    NOTE!

Borderline mean values for an area are judged to
fall into the more toxic category rather than the
less toxic one. For example, a mean value of 1,980
ppm would earn an area a "high" rating (2,000 to
5,000 ppm). The idea is to avoid the risk of
undertreating a contaminated area. Measurements
of lead levels are broad, and a difference of just
20 ppm is insignificant.
6.3.3  QUALITY  CONTROL
Niton XRFs are factory calibrated, so site-spe-
cific calibration  is  not necessary.  Regular
checks of the  instrument's  calibration  are an
essential  aspect of quality  control, however.
Before inspectors from  the EMPACT Lead-
Safe Yard Project begin to test a property, they
take readings on standard reference materials
(SRMs) whose lead levels are known to be 400
ppm, 1,000 ppm, and 5,000 ppm, the  antici-
                                                     pated range for lead in urban soil. They also
     take a reading on a blank—a soil sample whose lead level is less than 100 ppm, which is the detec-
     tion limit for the XRF instrument they use. If any of these readings fails the quality control criteria
     (+ 30% for SRMs; < 50 ppm for field blank), possible problems are investigated and the check is
     re-run  until the instrument passes. If it never passes, it is sent back to Niton to be recalibrated.
     These same calibration checks are conducted at the end of testing on a property, to ensure that the
     instrument's calibration has remained intact throughout.

     In addition, 10 percent of the XRF readings are replicate measures. That is, a particular location is
     tested a second time, to see if the reading on it falls into the same range. If it doesn't, inspectors try
     to find out what the problem is  and fix it, and calibration checks  and further repeat readings are
     performed until the XRF results are clearly reliable.

     The final quality control measure is to collect soil samples for confirmatory ICP or AA analysis. At
     evenly spaced intervals within a particular area, inspectors scoop up a subsample, which is about a
     tablespoon of the top half-inch of soil. These subsamples are emptied into a common ziplock bag
     to create a composite for the area. An XRF reading is then taken on the composite, after which it
     is ready to be sent to the lab.
                                         6  COLLECTING  AND  MANAGING DATA  ON  LEAD IN  SOIL    73

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                  Typically, a perimeter composite sample is created by taking twelve subsamples—three from the
                  drip line on each side of the house. Composite samples are also created for every other area desig-
                  nated as high use or high risk, such as gardens and play areas. As in XRF testing, an imaginary X
                  is superimposed on the area. Subsamples—a total of five, if possible—are taken along each line of
                  theX.

                  6.3.4  DATA   MANAGEMENT
                  The two main data management tools, the plot plan and the site worksheet, are versatile and easy
                  to use. As shown on page 81, the plot plan can be converted into a color-coded map of a property's
                  lead levels to  help homeowners  and landscapers discuss plans for remediation. The plot plan can
                  also be used to formulate a guide for testing, and during the inspection itself, test locations can be
                  recorded on the plot plan, as shown on page 80. Information on developing an initial plot plan can
                  be found in Section 5-3.

                  The site worksheet offers a simple way to identify the locations marked on the plot plan  more
                  closely. It also allows  inspectors  to keep track of the lead levels found at each  location. Finally, it
                  provides convenient spaces to write down any relevant descriptive information: a short form at the
                  top and a "comments" column  on the  right side. On  page 78  is a clean worksheet that groups
                  implementing a lead-safe yard program  can reproduce.  On page 79 is an example of a site work-
                  sheet that has been filled out.

                  The letters  A, B, C, or D in the "sample I.D." column of the filled-out site worksheet tell which
                  side of the house a particular XRF reading came from.  The number immediately after each  letter
                  corresponds to the testing location noted on the plot plan. The last letter in the "sample I.D." col-
                  umn tells how many  feet the testing location was from the  foundation of the house.

                  The number in the "location" column of the worksheet tells how many feet the testing location was
                  from the corner that would be on someone's right when facing the A, B, C, or D side of the house.
                  Thus the right corner on the A side would be the A-D  corner; on the B side it would be the A-B
                  corner; on the C side it would be the B-C corner; and on the D  side it would be the C-D corner.

                  The "ppm-lead" column tells the lead  levels measured at each testing location. The  comment
                  "repeat" in  the "comments" column indicates where a second reading was taken on a test location
                  as a quality control measure.

                  6.4  HEALTH  AND  SAFETT  PRECAUTIONS
                  Testing for lead in soil entails two different kinds of risk. The first comes from the soil itself, which
                  frequently does contain high levels of  lead. The second  comes from the XRF, which employs
                  radioactive  material. Inspectors must guard against both these kinds of risks.

                  6.4.1   GUARDING  AGAINST  LEAD HAZARDS
                  The important point to keep in mind is  that lead can enter the body  through ingestion, which
                  occurs as a result of routine hand-to-mouth  activities such  as eating, drinking,  and smoking.
                  Therefore,  inspectors should wear gloves  and  refrain from hand-to-mouth  activities on the job.
                  When their work is done, they should wash their hands and faces and clean off their work  shoes
                  after leaving the site. On a windy day, inspectors may need to use face masks to avoid breathing air-
                  borne lead-contaminated dust when working at dry, dusty sites.
74     6  COLLECTING AND MANAGING DATA ON  LEAD  IN SOIL

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6.4.2  GUARDING AGAINST
           RADIATION  HAZARDS 1B
Portable XRF instruments used for lead-based paint inspec-
tions  contain  radioactive isotopes that  emit x-rays  and
gamma radiation.  Proper training and handling of these
instruments is needed  to  protect the instrument operator
and any other persons in the immediate vicinity during XRF
usage. The XRF instrument should be in the operator's pos-
session at all times.  The  operator should never defeat or
override any safety mechanisms of XRF equipment.

For a discussion of required (and recommended) licenses,
certifications, and  permits for portable XRF instruments,
see the box on page 76.

6.5  MAINTAINING   EQUIPMENT
Day-to-day maintenance of the XRF is generally not diffi-
cult. The instrument's  display window should be cleaned
with cotton swabs. The case should be cleaned with a soft
cloth.  Batteries  should be  recharged as  directed in the
owner's manual. Beyond that, inspectors usually just need to
take care not to drop the instrument, not  to get it wet, and
not  to neglect  the calibration  checks  described  under
"Quality Control" in Section 6.3.3.

Over the long term, however, XRF owners face the very sig-
nificant maintenance concern of replacing the instrument's
radioactive source, a cadmium-109 isotope. Like all radioac-
tive  isotopes,  cadmium-109 decays  at  a fixed  rate.  Its
half-life, or the amount of time needed for the activity of the
radioactive source to decrease by one half, is  about fifteen
months. After that, the  XRF can still be used, but the instru-
ment  becomes progressively less  efficient. Readings that
once  took 30  to  60  seconds  take  progressively longer.
Eventually the wait becomes burdensome, and a new cad-
mium-109 isotope must be purchased from Niton, at a cost
of about $2,600.

Niton  recommends replacing the isotope source every fif-
teen months,  as soon  as its half-life is  spent,  but  most
inspectors find that they can postpone the job for another
three to nine months. After all, readings are no less accurate,
just somewhat less prompt. When inspectors do decide to
replace the cadmium-109 isotope, they simply send the XRF
to Niton. The corporation not only  puts  in a new isotope
but disposes of the old  one, upgrades the  instrument's soft-
ware, and provides whatever preventive  maintenance is needed.
       SAFE OPERATING DISTANCE

XRF instruments used in accordance with
manufacturer's instructions will not cause
significant exposure to ionizing radiation. But the
instrument's shutter should never be pointed at
anyone, even if the shutter is closed. Also, the
inspector's hand should not be placed on the end
plate during a measurement.

The safe operating distance between an XRF
instrument and a person during inspections
depends on  the radiation source type, radiation
intensity, quantity of radioactive material, and the
density of the materials being surveyed. As the
radiation source quantity and intensity increases,
the required safe distance also increases. Placing
materials, such as a wall, in the direct line of fire
reduces the  required safe distance. According to
NRC rules,  a radiation dose to an individual in
any unrestricted area must not exceed 2 millirems
per hour. One of the most intense sources
currently used in XRF instruments is a 40-
millicurie 57Co  (cobalt-57) radiation source.
Other radiation sources in current use for XRF
testing of lead-based paint generally produce lower
levels of radiation. Generally, an XRF operator
conducting inspections according to
manufacturer's instructions would be exposed to
radiation well below the regulatory level. Typically,
XRF instruments with lower gamma radiation
intensities can use a shorter safe distance provided
that the potential exposure to an individual will
not exceed the regulatory limit.

No people should  be near the other side of a wall,
floor, ceiling or other surface being  tested. The
inspector should verify that this is indeed the case
prior to initiating XRF testing activities, and check
on it during testing.

Finally, the effectiveness of the instrument's
radiation shielding should be assessed every six
months through a leak test. The XRF manufacturer
or owner's manual can be consulted to obtain
vendors of leak test kits.

If these practices are observed, the risk of excessive
exposure to  ionizing radiation is extremely low and
will not endanger any inspectors or occupants
present in the dwelling.
  Adapted from HUD Guidelines for the Evaluation and Control of Lead Based Paint Ha^zard Evaluation and Reduction Activities, Chapter 7: Lead Based Pain
Inspection, 1997 Revision. Available at http://www.hud.gov/lea
                                   &  COLLECTING AND MANAGING  DATA ON LEAD IN  SOIL    75

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                                      XRF USE

                    In addition to training and any required accreditation, a person using a portable XRF
                    instrument for inspection must have valid licenses or permits from the appropriate federal,
                    state, and local regulatory bodies to operate XRF instruments. (These are needed because
                    XRF instruments contain radioactive materials.) All portable XRF instrument operators
                    should be trained by the instrument's manufacturer (or equivalent). XRF operators should
                    provide you with information about their training, licensing, permitting, and certification
                    before an inspection begins. Depending on the state, operators may be required to hold
                    three forms of proof of competency: a manufacturer's  training certificate (or equivalent), a
                    radiation safety license, and a state lead-based paint inspection certificate or license. To
                    help ensure competency and safety, HUD and EPA recommend hiring only inspectors who
                    hold all three.

                    The regulatory body responsible for oversight of the radioactive materials contained in
                    portable XRF instruments depends on the type of material being handled. Some
                    radioactive materials are federally regulated by the U.S. Nuclear Regulatory Commission
                    (NRC); others are regulated at the state level. States are generally categorized as
                    "agreement" and "non-agreement" states. An agreement State has an  agreement with NRC
                    to regulate radioactive materials that are generally used for medical or industrial
                    applications. (Most radioactive materials found in XRF instruments are regulated by
                    agreement states). For non-agreement states, NRC retains this regulatory responsibility
                    directly. At a minimum, however, most state agencies  require prior notification that a
                    specific XRF instrument is to be used within the state. Fees and other details regarding the
                    use of portable XRF instruments vary from state to state. Contractors who provide
                    inspection services  must hold current licenses or permits for handling XRF instruments,
                    and must meet any applicable state or local laws or notification requirements.

                    Requirements for radiation dosimetry by the XRF instrument operator (wearing dosimeter
                    badges to monitor  exposure to radiation) are generally specified by state regulations, and
                    vary from state to state. In some cases, for some isotopes, no radiation dosimetry is
                    required. However, it should be conducted  even when not required, for the following five
                    reasons:

                    •  The cost of dosimetry is low.

                    • XRF instrument operators have a right to know the  level of radiation to which they are
                      exposed during the performance of the job. In virtually all cases, the exposure will be far
                      below applicable exposure limits.

                    •  Long-term collection of radiation exposure information can aid both the operator
                      (employee) and the employer. The employee benefits by knowing when to avoid a
                      hazardous situation; the employer benefits by having an exposure record  that can be  used
                      in deciding possible health claims.

                    •  The public benefits by having exposure records available to them.

                    •  The need for equipment repair can be identified more quickly.
76     o  COLLECTING AND MANAGING DATA ON  LEAD  IN SOIL

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        ALTERNATIVE  APPROACHES
A number of organizations that conduct lead-safe yard activities rely on laboratory analysis rather
than field-portable XRF for testing of yard soil. For example, Lead-Safe Cambridge, described in
Appendix A of this handbook, sends soil samples to a state laboratory for analysis.

A homeowner in an area where  no lead-safe  yard  program exists may also wish to  determine
whether there is a lead problem in his or her yard. In this case, the homeowner can collect soil sam-
ples in ziplock bags and send them to a laboratory for analysis. To determine sampling locations, a
homeowner can follow the guidance in Section 6.3, or refer to HUD Guidelines for the Evaluation
and Control of Lead Hazards in Housing, June 1995 (Title X, Section  1017) Appendix 13.3, available
at http://www.hud.gov/lea/learules.html#download.

Homeowners can contact their state or local childhood lead poisoning prevention program for
more information about obtaining soil-lead testing. The following Web sites list state and local lead
poisoning prevention contacts:

    The Lead Program  of the National Safety Council's Environmental Health Center:
    http://www.nsc.org/elic/nlic/contacts.lum

    The National Conference of State Legislatures' Directory of State Lead Poisoning Prevention
    Contacts: htrp://www.ncsl.org/progranis/ESNR/pbdir.htm

6."7              MORE   INFORMATION
6.Y.I   XRF  ACCURACY
Verification Reports and Statements on the accuracy of several XRF technologies are available on
the  Web   site  of   the  EPA   Environmental  Technology  Verification   Program:
iutp://www. epa.gov/etv/verifrpt.lum#monitoring.

Clark,  Scott, William Menrath, Mei Chen, Sandy Roda, and Paul  Succop. Use of a Field Portable
X-Ray Fluorescence Analyzer to Determine the Concentration of Lead and Other Metals in Soil and
Dust Samples. Call the University of Cincinnati Department of Environmental Health at 1-513-
558-1749-

Shefsky, Stephen. Comparing Field Portable X-Ray Fluorescence (XRF) to Laboratory Analysis of Heavy
Metals in Soil. Call Niton Corp. at 1-800-875-1578.

6.7.2 TEST  METHODS
Methods 6200, 6010B, and 7420 from EPA's SW-846 (entitled Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods). For ordering information, or  to  obtain a copy online, go to
http://www.epa.gov/epao.swer/ha/waste/test/sw846.lurn.

Sackett, Donald  and Kenneth Martin. EPA Method 6200 and Field Portable X-Ray Fluorescence
Analysis for Metals in Soil. Call Niton Corp. at 1-800-875-1578.

6.7.3  DUALITY  CONTROL.
Shefsky, Stephen. Sample Handling Strategies for Accurate Lead-in-Soil Measurements in the Field and
Laboratory.  Call Niton Corp. at 1-800-875-1578.
                                   6 CDLLECTINe AND MANAGING DATA ON LEAD IN  SOIL   77

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J
]
SITE WORKSHEET
Site Name: Date:
Site Address: Weather:
Building Tvpe: Lot Condition:
Yard Uses:
SAMPLE I.D. LOCATION PPM-LEAD COMMENTS








































































\ = front, B = left, C = rear, D = right
Location = distance from right corner of house

78   6 COLLECTING AND MANAGING  DATA DN  LEAD IN SOIL

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Site Name:
                      SITE WORKSHEET

                      	 Date:  »O
Site Address:  LC^L
                                    Weather:
                                                 -^A CoOJ
Building Type:_2-

Yard
                    VL
                            Lot Condition:
   SAMPLE I.D.   LOCATION
                              PPM-LEAD
                                              COMMENTS
    -  l - r\
  A-
  A-
        -
        -  4
     - 13 - i
  C-H4- (S
          .  13
     - ifc- |S
      -  IS -"22.
                 0
                   u
                 •2J
                  12-
                 2J
                 to

                 as
                  0
                 (0
                  to
                          -435 J:  M2>
                          (K -I  ±  (3*1
                                ^  130
A = front, B = left, C = rear, D = right
Location = distance from right corner of house
                      CDLLECTINB AND MANABiNe DATA ON LEAD IN SOIL   79

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              10 HOME  STREET
            ~J\
                                ii
                                             \

                                                      ! LiAO LEVELS DOLOR KEY I
                                                      »^mtem*m*jmMimVZmmimm!m?i^"°ypW^'fV®£W&^
                                                       6000 OP more ppm (Vtry High)

                                                       Must bt       with a
                                                       fwrnanenl barrier.
                                                       Unsafe for al typ>*s of gahdenf^,


                                                      , 2000-SOOO ppm (High)

                                                       Treatment is necessary for
                                                       iwj ree?       us» by       or
                                                       aduMs and for pet areee.
                                                       yn«afc for §1 types of gardening.

                                                      f11"""1 > *  •• «•'««-«    «' •    «
                                                     ; 40i3-2000 ppm (Moderately High) .
                                                                     is rec«mmerid*d for use ss
                                                             a children's play area and for jgardenir
                                                                     vegetable
                                                            1400 or less ppm (Low) \

                                                             No treatment is necessary fer
                                                             moirf uses by
                                                                      pets.
                                                             YARD Ufil WTTERN KEY
                                                             H«g|i Traffic Area (Exposed 0w
             t". x'-ior
                                                                          12
                                                             High Risk Mm
                                                             (Play Area or Vegetable Garden)

                                                                          HATCH:
                                                             Recreation .Ares (Picnic or BiQJ
so
6  COLLECTING AND MANAGING DATA ON  LEAD IN SOIL

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       10 HOME STREET
              Ife*
              V :' ~"' * ' -S
              AX  X/\
I LEAD LEVELS COLOR KEY j

 5000 or mote pprn (Very High)
                                                       be treated with 9
                                                  permanent barrier.
                                                  Unsafe for all types of gardening.
                                                 [aOOO-5000 ppm (High)

                                                      nert is nec^aary for
                                                    y reoreafkwnal use by children or
                                                  adults and for pet areas,
                                                  Unsafe for all types of gardening.
[
 40O-2000
                                                                      ^ Kgh)
                                                  Tret^ment is reoommended for uw as
                                                  a children's play area ar>d for gardening,
                                                  espaeially vegetable gapderiing,
                                                 6400 or less
              (LnvwJ I
                                                  No treatincf-t is ruecessary for
                                                  mosi uses by children.
                                                  adults, and
                                                  YARD USE PATTERN KEY

                                                          DOTS^
                                                  High Traffic Area (Exposed ©oil)

                                                          LJME9
                                                  High Risk UivS Area
                                                       Area or Vegetable Gwtlen)
                                                         CROSS HATCH!
                                                  Recreation Area (Picnic or SBQJ
SC4LJE:  r. r-
                           & COLLECTINC3 AND MANAC3INC3 DATA ON LEAD IN  SOIL   B 1

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32          6   COLLECTING   AND   MANAGING   DATA   QN   LEAD   IN   SOIL

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                             •7

Once you have sampled and analyzed a property's soil and determined that a lead hazard exists, the
process of designing and implementing landscape treatments can begin. This chapter provides
guidance on matching treatments to the hazards you've identified (Section 7-1), and describes spe-
cific low-cost treatment measures used by the EMPACT Lead-Safe  Yard Project (Section 7.2). The
chapter also  covers the many "nuts and bolts" issues involved in the treatment process, including:

    • Developing a budget for each yard treatment (Section 7-3).

    • Meeting with the homeowner to explain the sampling results and areas of concern
     and to develop/review the treatment plan (Section 7-4).

    • Contracting with a landscaper to complete all design and landscaping work
      on the property (Section 7-5).

    • Establishing guidelines to ensure landscaper health and safety (Section 7.6).

    • Securing the homeowner's approval and signoff on completed work (Section 7.7).

    • Reviewing and approving landscaping work prior to final contractor payment
     (also in Section 7.7).

If you are a  homeowner interested in learning about low-cost landscaping measures for reducing
children's exposure to lead in soil, you can focus on Sections 7.1, 7.2, and 7-6. (Section 7.6, Health
and Safety for Landscapers, is essential reading for anyone who intends to do landscaping work
in a lead-contaminated yard.) You should also read Chapter 8, which covers the development of a
maintenance plan for the finished yard—a critical  part of the treatment process.

Sections 7-3, 7-4, 7-5, and 7.7 present detailed information for those responsible for implementing
a lead-safe yard  program.

"7.1       MATDHINB  TREATMENTS  TO  HAZARDS
There are many ways of protecting children and other people from the hazards of lead-contami-
nated yard  soil. Possible methods include  removing and disposing of the contaminated soil,
covering it with a permanent barrier such as asphalt, covering it with a non-permanent barrier such
as mulch or  grass, or changing the way people use their yard to reduce exposures.

To select the best method or methods for a particular property, you need to consider a number  of
factors, including the level of lead contamination, the frequency and extent of potential exposures,
the  homeowner's esthetic preferences, the cost  of the protective measure, the amount of mainte-
nance it will require, and its likely effectiveness. Protective measures can vary greatly both in the
level of protection they provide and in their associated costs. Soil removal, for example, can com-
pletely eliminate a soil hazard, whereas use of a non-permanent barrier such as grass cannot.
However, soil removal can be prohibitively expensive for many people due to  the high cost of soil
excavation, transportation, and disposal.
                                                                          "7 YARD TREATMENTS   B3

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                  The EMPACT LSYP was  created to develop low-cost  landscape measures  that protect children
                  against exposure to high lead levels in yard soil. The landscape measures described in this handbook
                  were selected for four main reasons:

                      • They are relatively inexpensive.

                      • They can be implemented by the homeowner or a program partner
                       with a minimum of tools and experience.

                      • They are attractive and enhance the value of the yard.

                      • They are effective in reducing lead concentrations at the yard surface, and they therefore
                       effectively reduce the potential for children's exposures.

                  All of the measures presented here could be characterized as interim controls. None provide the sort
                  of permanent protection you could achieve through soil abatement (that is, by removing or paving
                  contaminated soil), nor are they meant as a substitute for abatement. In fact, in circumstances where
                  soil-lead levels are greatly elevated (i.e., above 2,000 ppm) and the possibility of children's exposure
                  is high (i.e., in residential settings), federal regulations recommend or require abatement of the soil
                  hazard (see Section 3-4.3).

                  The EMPACT LSYP encourages homeowners to follow all federal and state requirements and guid-
                  ance for soil abatement that apply to them. But the project also recognizes that there will be many
                  situations where homeowners  and community organizations cannot afford the cost of abatement
                  measures. In such situations, these landscape measures can provide some degree  of long-term, effec-
                  tive protection  so long as they are properly applied and well maintained. The  key is selecting the
                  right measures based on the existing lead hazards.

                  "7.1.1                    TREATMENT
                  So  how do you choose among the treatment measures presented in this handbook? Your goal in
                  developing a treatment plan is  to achieve a delicate balance between the safe use of the yard and the
                  existing lead levels. To do this, you should combine two  main approaches:

                      • Altering the surface cover. Select landscape measures that provide a sufficient barrier,
                       based on  the soil-lead levels and the types of yard use.

                      • Altering the yard use patterns. Encourage safe yard uses, and discourage certain activities
                       (e.g., gardening, children's play)  in the areas of highest contamination. These activities
                       may need to be relocated to a safer part of the yard.

                  In many  cases, you will need to design different treatments for each of the yard areas evaluated dur-
                  ing the sampling process: the house dripline, areas of bare soil, areas of unique use such as children's
                  play areas and picnic  and  gardening areas,  and  other areas. The  illustration  on  page  86,
                  Characteristics of a Lead-Safe Yard, shows how a number of treatment measures can be combined
                  to create  a yard that  is safe and attractive and meets the needs of the homeowner and/or residents.
                  In other cases, you may only have to address a single yard area, such as  the dripline (where soil-lead
                  levels are usually found to be highest).

                  The table on page 85 presents a list of treatment measures used by the EMPACT LSYP at specific
                  soil-lead  levels.  Each measure is described in greater detail in Section 7-2. However, before  incor-
                  porating  these measures  into your own program, you should refer to Section  3-4.3 for a discussion
                  of how the EMPACT treatment  approach  compares with the approach recommended under the
B4    *7 YARD TREATMENTS

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                       LSYP TREATMENT
     Soil-Lead Level
   (parts per million)
       5,000 (very high)
         EMPACT LSYP
       Treatment Measures

If soil removal or permanent barriers
are not possible:

• Install semi-permanent barrier, such as
 a wood-framed dripbox filled with gravel
 or mulch.

• Relocate gardens—unsafe for all types
  of gardening.
     2,000-5,000 (high)
  Relocate gardens—unsafe for all
  types of gardening.

  Relocate children's play area, pet
  area, and picnic area, if possible. If
  not, install wood  platform or wood-
  framed raised play and picnic area
  filled with woodchips.

  Install path of walking stones for
  high-traffic areas.

  Seed and fertilize grassy areas, or
  cover with mulch or woodchips if
  not suitable for grass.
400-2,000 (moderately high)
  Install raised-bed garden and
  supplement with clean topsoil.

  Install wood-framed raised play and
  picnic area filled with woodchips.

  Install path of walking stones for
  high-traffic areas.

  Seed and fertilize grassy areas, or cover
  with mulch or woodchips if not suitable
  for grass.
   400 (urban background)
 No treatment necessary.
                                                                   *7  YARD TREATMENTS    OS

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                Characteristics of  a Lead-Safe Yard
                Signs  of a Healthy Yard:
                           Mulch or gravel covering
                           contaminated soil m the
                           drip zone
                                                                      vvil-i
Walkways of stepping stones, paving.
or gravel lo keep contaminated soil
from being tracked into the house
           Play areas for kids and pels located
           away from the drip zone and covered
               mulcn or woodcrtips
             X
                                                                           Healthy, well-tended lawns lo
                                                                           provide safe outdoor spaces
                                                                           lor play and relaxation
                                                       • x  Shrubs planted around the house
                                                         \lo keep children and pets away from
                                                           the drip zone
                                             Cars confined lo driveway area
                                             covered with asphalt or gravel
                Signs of a Toxic Yard:
                                                        No plants, grass, or mulch covering
                                                        contaminated soil in the drip nonet
                                     Areas of dusty, exposed soil such as
                                     walkways, dog runs, ar>d backyard
                                     play and picnic areas
                          Cars parked on yard, creating dusty
                          areas of bare contaminated soil
                                                                                            Play areas located
                                                                                            near the drip zone
                                                                                   Vegetables growing in soil with a
                                                                                 -  high lead content
                                                                            Lead-based paint chips near
                                                                            the foundation of the house,
                                                                            con:u-n ratriq GUI  v.i'.-i'p th:-
                                                                            dnp zone
36     7 YARD TREATMENTS

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     pending  TSCA  Section   403  rule  (information  about  the  rule   can  be  found  at
     http://wwvv.cpa.gov/lead/Ieadha7.htm). Also  keep in mind  that decisions  on specific landscape
     measures (e.g., choosing between mulch or grass, or between types of grass) must be made on a
     yard-by-yard basis to account for variables such as regional climate, yard topography, the amount
     of available sunlight, and the homeowner's esthetic preferences. These factors will often play a major
     role in shaping the final treatment plan for a property.

     "7,2

     This section presents the specific landscape treatments used by the EMPACT LSYP. The treatment
     measures described here represent a suite of tools that the landscaper can use to address elevated
     soil-lead levels in specific yard areas: drip zones, grassed areas, parking areas, walkways, recreation
     and children's play areas, gardens, pet areas, and porches. As mentioned in Chapter 6, these are the
     high-risk and  high-use yard areas where children are most likely to experience dangerous exposures
     to soil lead.  For most of these yard areas, the EMPACT LSYP has developed two or more treatment
     options, giving the landscape designer some flexibility in selecting treatments that match both the
     homeowner's  esthetic preferences and other  variables such as  yard topography and the amount of
     available sunlight.

     It is important to keep in mind that not all  treatments will  be appropriate and/or effective at all
     locations. The treatments described here were selected by the EMPACT LSYP because they address
     the conditions found at a majority of sites in the project's target neighborhoods in Boston: high to
     very high soil-lead levels; inner-city homes that are typically wooden and  covered with lead paint;
     high rates of yard use by children and families; and many areas of bare and partially bare soil. These
     landscaping measures also work well given Boston's variable climate, with its cold, wet winters and
     relatively hot, humid summers.

     As you develop your own lead-safe yard program, you will  no  doubt want to pick and choose
     among the treatments presented here, rejecting some, revising others to fit your specific needs, and
                                                              devising some  entirely new  treat-
               PHYTOEXTRACTION:                     merits. The  work you  have done to
         AN                                                  get to know your target community
                                                              (see Section 4.4) will help you in this
All of the treatment measures used by the EMPACT  LSYP              T    , , • •
                .                  \                           process. In addition, you  may want
focus on employing grass, plants, and other materials as a               ,  ,    ,    ,
,    .        j      , ., j   ,            ,   ,       .     ,        to consult local garden centers, nurs-
barner to reduce children s exposure to lead-contaminated                      °                ,
soil. None of these treatments, however, remove the lead        enes' landscaPers> and  arbo»sts tor
from the soil.  Today, researchers are experimenting with         helP selecting Plants and grasses that
another approach  for using plants to actually extract lead        wil1 thrive in your area-  If 7OU  live in
and other contaminants from soil: phytoextraction.              an  arid  or  semi-arid  climate,  for
                                                              example, you  may  find  yourself
As a technology, phytoextraction is still in its infancy.              •      ,     fl  _          j-cc    <-
            &/  " '                             '             using plants  that are very different
Researchers are still struggling with a number of questions,      ,-    ,        , .   ,   x,    ,
   .      i •  i   i     i ^^i   I      •          •                from  those used in the Northeast.
such as which plants best absorb  certain contaminants,
and how to  make  the technology affordable. The               Qnce you have assembled a suite of
EMPACT LSYP does not use phytoextraction at this           treatment options that  will work in
point, but may consider it in the future, as more                      program  area,   you should
information becomes available about its applicability  in          ,  ,    j  -i  j     -c        L
   ,           .               ,.          i  -i   i               develop  detailed specifications that
residential settings. See Appendix C tor a detailed               . ,,         .  .     .   .    .
,.     .    LI-        • •      it                         define exactly now the landscaping
discussion about this promising technology.                                -                   ,
                                                              work  should   be done and what
                                                                                 7 YARD TREATMENTS    87

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                  materials should be used. These specifications should be provided to the landscaper and included
                  with the landscaping contract (see Section 7-5-1) if you intend to engage a contractor. A set of sam-
                  ple specifications, developed by Lead Safe Boston and used by the EMPACT LSYP, is provided on
                  pages 99 to 100.

                                                 7.2.1   DRIP  ZONES
                                                 The drip zone is the narrow 3-foot strip around the foundation of
                                                 the house. There, soil-lead levels are usually highest, because lead-
                                                 based paint on the outside of older homes weathers over time and
                                                 falls into the top layer of soil adjacent to the foundation, contam-
                                                 inating it. Play areas,  picnic areas, and vegetable  gardens must  be
                                                 located away from  the drip zone. In addition, covering the zone
                                                 with a permanent or  semi-permanent  barrier provides long-term
                                                 protection from the contaminated soil.

                                                 The  EMPACT LSYP uses raised perimeter boxes that  not only
                                                 cover the contaminated soil in the drip zone, but also prevent ero-
                                                 sion and offsite  transport of the soil and allow for continued
                                                 weathering of the  exterior.  Built from 2"  by 6" ACQ  (Alkaline
                                                 Copper Quaternary)  pressure-treated lumber, the boxes are lined
                  with a filter-fabric weed barrier and then filled with  either gravel or mulch and plantings, depend-
                  ing on the homeowner's preference. Plantings, such as evergreen shrubs, azaleas, boxwoods, holly, or
                  thorny bushes, help keep children  and  pets
                  away from the drip zone. Plantings used by
                  the EMPACT LSYP are listed in the sample
                  specifications on page 99. Consult a local gar-
                  den  center, nursery,  or  arborist to select
                  plantings appropriate for your area.
A perimeter mulch bed covering the drip zone.
                  7.2.2  BRASSED  AREAS
                  Maintaining a healthy lawn is one of the best
                  ways  to  reduce exposure  to  lead-contami-
                  nated soils. A healthy lawn acts as  a
                  natural  barrier between  people and
                  contaminated  soils,  and provides  a
                  safe outdoor space for play  and relax-
                  ation.    Lawns   require    routine
                  maintenance with water and fertilizer,
                  and  should be protected from foot
                  traffic for the first 3  to 4 weeks after
                  seeding. Consult a local garden center
                  or lawn  care  professional   to  select
                  grasses that will grow in  the soil and
                  climate conditions  found  in your
                  region. In areas of heavy foot traffic or
                  low light where grass won't grow well,
                  install  a stone path  or raised  mulch
                  bed to cover all bare soil.
                                                       Top: Before—bare soil in drip zone (1660 ppm).
                                                       Bottom: After—mulched planting bed covering soil.
aa
        7  YARD TREATMENTS

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    Existing lawn improvement. Improvement of
    an existing lawn can be accomplished quite
    inexpensively. Rake bare areas to loosen the
    soil, apply seed mix at the rate specified by the
    manufacturer, then apply 1A" of top soil over new
    seed. Water thoroughly.

    New lawn installation (at existing grade). Where
    little or no grass exists on a lawn, the entire lawn
    area should be rototilled and reseeded (apply water
    to contain dust during rototilling). Spread 1/4" of
    loam (soil composed of sand, clay, silt, and other
    organic matter) on top of the seed, then water
    thoroughly.                                       Two months post treatment. Lawn growth over
                                                     previously bare, contaminated soil (1,770 ppm).
    New lawn installation (raised bed). For sloped yards,
    the EMPACT LSYP sometimes uses raised grass beds to create a terraced effect and limit
    runoff and erosion. A raised grass bed can also be installed in areas where roots or rocky
    soil  prevent grass from growing. In a perimeter box made of 2" by 6" ACQ pressure-
    treated lumber, install 6"  of loam over filter fabric weed barrier. Apply seed mix, then
    spread 1A" of loam on top of seed and water thoroughly.
Wood platform built with ACQ lumber.
                                                    LESSONS LEARNED:
                                            USING ACQ PRESSURE-TREATED
                                              LUMBER FOR ADDED SAFETY

                                           Over the past 30 years, pressure-treated
                                           lumber has become standard for outdoor
                                           construction because it deters rot, decay, and
                                           termite destruction. The EMPACT Lead-
                                           Safe Yard Project used pressure-treated wood
                                           for these reasons during its first two years of
                                           yard treatments. Recently, however, there has
                                           been a growing awareness of the dangers
                                           posed by chemicals used in the traditional
wood-treatment process. There is some evidence that these chemicals, which include the
EPA-listed hazardous compounds arsenic and chromium, can leach out of pressure-treated
wood and into the environment.

During its third phase of yard treatments, the EMPACT LSYP began using a relatively new
type of pressure-treated lumber: ACQ Preserve. ACQ-treated lumber contains no EPA-
listed hazardous compounds and is guaranteed to protect against rot, decay, and termites.
hi other words, it offers all of the values of traditional pressure-treated lumber with fewer
hazards. This is especially important when you use wood in and around gardens and
children's play areas, as the EMPACT LSYP does. Costs of ACQ-treated wood vary, though
the EMPACT LSYP has found these costs comparable to the costs of traditional pressure-
treated wood. For an information sheet on ACQ-treated wood, go to
http://www.conradwp.com/acq.htm.
                                                                         VYARD  TREATMENTS    B9

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                        Raised mulch bed (with or without plantings). Raised mulch beds can be used to cover
                        areas of bare soil where grass won't grow well. The beds can serve as children's play areas,
                        or can be filled with various plantings to form an attractive garden area. Install a perimeter
                        box made of 2" by 6" ACQ pressure-treated lumber to completely cover bare soil area.
                        Install 4" of loam and 2" of pine bark mulch  over filter fabric weed barrier. Select plantings
                        that are appropriate for the area (e.g., shade, partial shade, full sun; arid or semi-arid soil).
                        Provide recessed egress stepping-stones from the bed to  an existing walkway.
                   7.2.3  PARKING AREAS
                   Cars parked on yards destroy grassed areas, turning them into
                   dusty areas of bare contaminated soil. Cars should be confined
                   to  designated parking areas  covered  with gravel  or asphalt.
                   Heavy landscape timbers can be sunk at the perimeter of the
                   parking  area  to  define  the  edge and  prevent stones from
                   spreading into grass areas. All lots, whether gravel or asphalt,
                   should  have at  least a 2-percent pitch across  the  surface
                   to  ensure that water will not puddle. Detailed specifications
                   for creating a gravel  or  asphalt parking area are included on
                   page 99-
                                                                       A stone driveway.
Install stepping stones to prevent contaminated
soil from being tracked into the house.
                                  7.2.4 WALKWAYS
                                  Worn dirt paths create dust. By installing stepping stones in areas where
                                  people regularly walk, you keep contaminated soil from being tracked
                                  into the house. Alternatives include concrete walks,  cement stepping
                                  stones, gravel over filter fabric, recycled concrete, and brick paths.

                                  7.2.5 RECREATION  AND
                                            CHILDREN'S  PLAY  AREAS
                                  If possible, swing sets, sand boxes,  and other children's  play areas should
                                  be relocated away from the drip zone and other areas of highly contami-
                                  nated soil. The same is true for picnic,  barbecue, and other family
                                  recreation areas that receive  heavy  use. If relocation is  not  possible, the
                                  EMPACT LSYP uses one of two options:
                       • Wood Platform. A wood deck, made from ACQ pressure-treated 2" by 6" stock, can serve
                        as a site for picnics, cook-outs, and children's play, and provides long-term protection from
                        contaminated soil. Decking should be installed with a 1A" pitch to drain rainwater off the
                        surface.

                       • Raised bed filled with mulch or woodchips. Raised beds can be used to cover areas of bare
                        and/or highly contaminated soil. The beds provide an effective barrier and a safe, attractive
                        place for children's play and family gatherings. Install a perimeter box made of 2"  by 6"
                        ACQ pressure-treated lumber, then install 4" of loam and 2" of pine bark mulch or
                        woodchips over filter fabric weed barrier.

                   7.2.6   GARDENS
                   Homeowners and residents should take precautions when gardening in or around lead-contami-
                   nated soil.  Though plants generally do not accumulate lead, it is possible for a plant to absorb some
                   lead in settings where soil-lead levels are very high. In addition, lead-contaminated dust  can settle
                   on the surface of garden plants.
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7 YARD TREATMENTS

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Basic precautions include washing all vegetables with a vinegar-water solution, locating gardens
away from roads and highly contaminated yard areas,  and planting crops that are less likely to
absorb or accumulate lead. In general, this means planting fruiting crops (e.g., corn, beans, squash,
peppers, cucumbers, tomatoes, strawberries, apples) and avoiding root crops and leafy vegetables
(e.g., carrots, radishes, lettuce, collard greens, spinach) since they are more likely to absorb lead from
soils or become coated with lead-contaminated dust. Two excellent resources on lead in gardens are:

    Lead in the Home Garden and Urban Soil Environment,
    by Carl J. Rosen and Robert C. Munter
    http://www.extension.umn.edu/distribution/horticulture/DG2543.html
    Lead Contamination in the Garden, a fact sheet by Terry Logan
    http://ohioline.ag.ohio-state.edu/hyg-fact/1OOO/1149.html

The EMPACT LSYP recommends relocating gardens away from the drip zone  and other areas of
highly contaminated soil. The EMPACT LSYP treatment approach recommends using raised beds
in areas of moderate contamination (400 to 2,000 ppm). (Please refer to Section 3-4.3 for a discus-
sion of how the EMPACT treatment approach compares with the approach recommended under
the pending TSCA Section 403 rule.) Beds should be  framed with 2" by 8" ACQ pressure-treated
wood, lined with a filter-fabric weed barrier, then filled with 6" of loam that has been tested for lead
levels (levels over 400 ppm are unacceptable). Gardening is considered safe in yard areas where lead
levels are below 400 ppm.
7.2.7  PORCHES
The soil found  underneath porches is often  contaminated
with lead from  paint chips and  with  other chemicals that
leach from pressure-treated wood used  in outdoor construc-
tion.  Because it receives  little sunlight,  this soil  is also
naturally  bare.  The EMPACT LSYP has developed two
strategies  to discourage children  from playing in contami-
nated soil beneath porches:

    • Lattice and Trim Barricade. All exposed  soil under
     porches is  to be barricaded by ACQ wood
     framing, lattice, and pine trim. Prep, prime,
     and paint pine trim or apply two coats of
     wood sealant. Install a framed access door of
     like material. If loose soil is  likely to be
     blown out from under porches, a covering of
     gravel or pea stone over bare soil  would be
     appropriate.

    • Raised bed filled with mulch or  gravel.
     Install a wood box made from 2" by 6"
     ACQ pressure-treated lumber along
     footprint of porch. Line the box with filter-
     fabric weed barrier, then fill with either 2" of
     loam and 3" of pine bark mulch or 3" of
     loam and 2" of crushed stone.
Top: Before—bare soil under porch deck.
Bottom: After—area barricaded with lattice and trim.
                                                                             7 YARD TREATMENTS    9 1

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                  7.2.B  PET  AREAS
                  By tracking lead-contaminated soil and dust indoors, dogs and other pets can be a major source of
                  lead exposure for humans. Pets that play regularly in certain parts of the yard can also create dusty
                  areas of bare  contaminated soil. If possible, pet areas should be located away from areas of highly
                  contaminated soil. If not, install a wood box made from 2" by 6" ACQ pressure-treated lumber to
                  completely cover the bare soil area. Line the box with a filter-fabric weed barrier, then fill it with 4"
                  of loam and 2" of pine bark mulch or woodchips.

                  7.3      DEVELOPING  A  BUDGET
                             FDR  EACH  YARD  TREATMENT
                  Once you have selected a suite of treatment measures for your program, you may want to develop
                  a  standard budget that can be used to guide each yard treatment. This budget will represent the
                  maximum amount that the landscaper is authorized to expend in designing and  implementing a
                  treatment plan for each home.

                  Three main factors will drive  the budget development process: the amount of funding available to
                  your program,  the number of yards you hope to treat, and  the actual costs of materials and labor
                  needed to create a lead-safe yard. Some yards will obviously cost more than others to treat. Your goal
                  is to establish a reasonable budget for an average yard, with  the possibility of authorized cost over-
                  runs at certain yards where treatments turn out to be unusually expensive.

                  A sample budget developed by the EMPACT Lead-Safe Yard Project is shown on page 101. The
                  budget was developed in two steps. First, the project team  calculated an allowance for  each indi-
                  vidual treatment measure by estimating the total cost of labor and materials. There are a number of
                  reference books that can help with this process. The RSMeans Company, for example, offers several
                  such books, including Means Site Work  & Landscape Cost Data 2000  (ISBN 0-87629-547-2) and
                  Landscape Estimating, 3rd Edition by Sylvia H. Chattin (ISBN 0-87629-534-0). These  books can
                  be found in some libraries and bookstores  or ordered online (http://www.rsmeans.com). Keep in
                  mind that labor and material costs vary by region. You may want to consult a local landscaper as
                  you develop allowances for each measure.

                  Second, the project team identified ways in which the individual measures might be cost-effectively
                  combined to  create a lead-safe yard. The goal was to make the yard lead safe by addressing as  many
                  areas as possible within a set budget (in this case, $3,000), while giving homeowners some freedom
                  to choose the types of landscape measures they prefer. Note that the budget includes a standardized
                                             construction  management allowance of $500, which allows  the
                       <\OI TRPFS OF        landscaper to cover costs such as landscape design, permits and fees,
                    CDCT: \/f ATTDTAT c     a workmanship  and  materials warranty, insurance, construction
                    rKrih iVLAl bKiA_Lo                                          .
                                             oversight, and the  development of a maintenance manual for the
                    Parks departments         completed yard.

                           °                 Remember that the standard budget  you develop represents  the
                    Tree services              maximum amount that the landscaper is authorized to expend for
                    Corporate  sponsors        each yard. Some yard  treatments will cost less than the maximum.
                                             For this reason, you should consider developing a standard cost esti-
                                             mate sheet that the landscape coordinator can complete for each yard.
                                             A sample cost estimate sheet is shown on page 102.
92     7  YARD  TREATMENTS

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            LESSONS LEARNED: ESTIMATING TREATMENT COSTS

  The experience of the EMPACT Lead-Safe Yard Project illustrates the importance of
  accurately estimating the per-yard costs of materials and labor. At the inception of the
  project, the project team set a target of treating 70 yards over the first two years, with a
  goal of expending about $750 per yard in landscape labor and materials that would be
  offered free to the participating homeowners. However, the project quickly found that
  treatment costs were running much higher than expected, partly because the project had
  chosen to employ a landscape team of city youths who were learning on the job (see also
  Section 4.2, "Selecting Program Partners"). The average cost per yard was roughly $2,100,
  with $300 going toward materials and $1,800 toward labor. Project management and
  indirect costs amounted to another $900 per yard. Because of these unexpected costs, the
  project was forced to scale back its objectives, though it still managed to treat 42 yards over
  the two-year period.
  The EMPACT LSYP is currently investigating alternative models for organizing a lead-safe
  yard program that could reduce current average costs,  in particular costs for labor,
  management, and overhead. For example, the EMPACT LSYP is investigating a model
  based  on the principles developed by Habitat for Humanity, in which the work involved in
  achieving a lead-safe yard is carried out with the help of the homeowner by using volunteer
  labor and donated materials. See Appendix B for more information on this and other
  proposed models.
7.4      HOMEOWNER  DESIGN  SESSION
The EMPACT LSYP has found that it is critical to include the homeowner in designing landscape
treatments for his or her yard. Why? First, the homeowner is the person who can best verify that
the selected treatments provide enough actual protection from the lead-contaminated soil, based on
the way the yard is used. Second, the homeowner is there to ensure that the selected landscape treat-
ments meet his or her approval in terms of their esthetic value. A homeowner who is unhappy with
the appearance or layout of his or her yard is unlikely to commit the money and effort needed  to
maintain the landscape treatments year after year.

Chapter 5 of this handbook described the necessity of creating a permission form to document the
homeowner's participation in your lead-safe yard program. That permission form should also spec-
ify  the homeowner's  role in choosing treatment  options,  should  soil-lead levels  on his  or her
property turn out to be elevated. The homeowner design session is where these choices are made.

The EMPACT LSYP has tried using both the outreach worker and the landscape coordinator for
the design session. The landscape coordinator is the better option. However, the outreach worker
should facilitate a smooth transition for the homeowner from the outreach/sampling  phase to the
design phase. For example, the outreach worker should convey names, numbers, and any linguis-
tic  barriers  to the landscape  coordinator soon after the soil sampling is complete. The outreach
worker may also  want to attend the initial meeting between the landscape coordinator and home-
owner to maintain a sense of familiarity, trust, and continuity for the homeowner. During the design
session, the landscape coordinator will do three things:

    1) Communicate with the homeowner about the testing results. Using the color-coded map
      developed during the data-collection phase, the landscape coordinator should describe the
      testing results, the areas of concern, and the need for changes.
                                                                          7 YARD TREATMENTS    93

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                      2) Ask follow-up questions about yard uses. During their initial meeting, the outreach
                        worker should have interviewed the homeowner about the activities that take place in the
                        yard and the ages and numbers of people who use the yard. Yard uses should have been
                        mapped on a plot plan using colored markers or crayons  (see Section 5-3). During the
                        design session, the landscape coordinator should review the yard uses with the homeowner
                        and ask any follow-up questions.

                      3) Work with the homeowner to select appropriate treatments based on the lead levels, the
                        yard uses, and the homeowner's esthetic preferences. The selected treatments should be
                        mapped on the plot plan showing yard uses, and this treatment plan should be used  by
                        the landscaper as a blueprint for work to be done. A sample treatment plan is shown on
                        page 103- See Section 7.1 above for guidance on matching treatments to hazards.

                  You may wish to develop a legally binding form that the homeowner can sign at the conclusion of
                  the  design session, stating that he or she understands  and  approves of the final treatment plan. A
                  sample homeowner's approval form is included on page 104.

                  "7.5       CONTRACTING WITH  A
                  Early in the development of your lead-safe yard  program, you will want to identify a program part-
                  ner  for the design and landscape components of your  project (see  Section 4.2, "Selecting Program
                  Partners"). This could be a non-profit landscaping company, a private landscaping company, or even
                  a team of youth volunteers who have been trained in landscaping techniques. Another option, cur-
                  rently being tested by the EMPACT LSYP, is to develop a pool  of landscaping contractors  trained
                  at designing and implementing landscape treatments that can reduce exposure to lead-contaminated
                  soil. Why  create a contractor pool? By training  and partnering with multiple contractors, you cre-
                  ate competition—a market—for the work you have to offer, and you  also build "capacity" within
                  your community  for  this  type of work. This is  an  important  goal  of your  program:
                  to  increase your  community's base of knowledge about  soil-lead  hazards  and strategies for
                  yard treatment.

                  No  matter who you  use for the design and landscape components of your project, you will need to
                  develop  a contract for the work. If you have chosen to  use only a single landscaper, this process will
                  be relatively straightforward: you will  simply negotiate an agreement for the property or properties
                  requiring treatment, and then capture the agreement in the form of a contract. Guidance on devel-
                  oping a  contract is provided below.

                  If you have succeeded in creating a contractor pool, you will need to develop a system  for choosing
                  which contractor to  use at a particular property. Here are two possible ways of doing this:

                      • Group the properties geographically, then assign several to each contractor. Under this
                       scenario, each  contractor is given a budget for each property he or she is assigned,  and is
                       asked to develop and implement a treatment plan within the  budget. This method is
                       relatively noncompetitive, in that contractors are not asked to bid against one  another.
                       However, over time, you  can determine which contractors do the best and most cost-
                       effective work, and then increase their workload.

                      • Solicit bids for the property (or properties) requiring treatment. This works best  if you (or
                       a professional landscape designer) have already developed a treatment plan for each property,
                       identifying which landscape measures will be used. Each contractor is then given a copy of
                       the treatment plan(s), along with detailed specifications for the work to be done, and is asked
94     *7 YARD TREATMENTS

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     to submit a bid. The work goes to the lowest bidder. The disadvantage of this method is
     that the landscape contractor is not included in the development of the treatment plan.

Whatever method you use, you should consider assigning or awarding several properties at a time
to each contractor, rather than one at a time. This allows contractors to benefit from the economies
of scale when buying materials and planning their work.

7.5.1   DEVELOPINB  A  CONTRACT
To simplify the contracting process, you should develop a standardized contract for use at every
property. This contract should define the scope of services the contractor will perform, the time-
frame for the work, the contractor's  legal  responsibilities, and the details of compensation.  The
sample contract on pages 105 to 108  shows some of the details that should be incorporated into a
standardized contract, including:

    • Warranty—Contractors should provide a warranty guaranteeing their work from defects in
     workmanship and materials for a specified period. The EMPACT LSYP requires a one-year
     warranty from its contractors.

    • Draws—The term "draws" refers to the timing of compensation. Many contractors will
     want one-third of their compensation up front, one-third at the halfway point, and the
     final third upon completion  of the project. You should attempt to negotiate a payment
     schedule that is mutually acceptable,  though you should keep in mind that draws are
     typically market-driven.

    • Insurance—Each contractor should be required to maintain general liability and workman's
     compensation insurance to protect against claims due to bodily injury or property damage
     and claims under state workman's compensation acts.

    • Pollution insurance—Most general liability insurance policies do  not cover injury or illness
     caused by pollution (for example,  illness caused by lead exposure). You should look into the
     costs and the potential necessity of pollution  insurance in your state and consider
     encouraging contractors to purchase such insurance.

7.6       HEALTH AND  SAFETY
Before any field work begins, your program should develop safety guidelines that protect your soil
sampling team and landscape workers from the risks associated with  working with lead-contami-
nated soil. All field workers  should  be educated  about lead hazards, health  effects, safe work
practices, and any federal or state regulations that apply to their work.

OSHA regulation 1926.62, the "lead in construction standard," applies to all private sector work-
ers, no matter how few are employed. Although it  does not apply to workers in the public sector,
it is  nevertheless  a useful  reference on  responsible practices. The regulation, available online at
http://www.osha-slc.gov/OshStd_data/1926_0062.html, requires  a written description of the work
to be done, an estimate of the anticipated exposure to lead, and a statement detailing the precau-
tions to be taken.  If the anticipated exposure to lead reaches the "action level"—30 micrograms per
cubic centimeter of air, averaged over an 8-hour day—extensive guidelines come into play to  pro-
tect workers.

Since the lead to which landscapers in the EMPACT LSYP are exposed falls below the action level,
compliance with the lead in construction standard has not been  difficult. However, to be on the
                                                                            *7YARD  TREATMENTS    95

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                                                     safe side, the project has adopted an important con-
                                                     tract requirement that  goes  beyond what  OSHA
                                                     stipulates  for enterprises whose employees are
                                                     exposed to lead below the action level. This require-
                                                     ment is health and safety training for landscapers.
                                                     One of the main points conveyed in  the training is
                                                     that lead enters the body chiefly through ingestion,
                                                     which  happens  as a  result  of routine hand-to-
                                                     mouth  activities  such  as eating, drinking,  and
                                                     smoking. An information sheet used in the training
                                                     is  shown  in  the box,  "Lead-Safe Yard Program
                                                     Health and Safety."

                                                     Even small amounts of lead on the hands can affect
                                                     blood lead levels. Also,  lead on clothing is easily
                                                     transferred to the hands, and then from the hands
                                                     to the mouth. Another danger is that lead will be
                                                     brought into the home on landscapers' clothing,
                                                     especially their boots or shoes.

                                                     A key precaution is to avoid activities that generate
                                                     dust. When the ground must  be disturbed,  as  is
                                                     often the case in landscaping, it should be damp-
                                                     ened to minimize the dust that may be generated.
                                                     Leather or comparable work gloves should be worn
                                                     to cut  down on  hand  contamination,  and land-
                                                     scapers should not eat, drink, or smoke in the work
                                                     area. After they leave, they should wash their face
                                                     and hands before doing any of these activities. They
                                                     should remove their boots or shoes at the door of
                                                     their home to keep from tracking in  contaminated
                                                     soil,  and they should  wash their work clothing
                                                     separately from their other clothing.

          Blood lead tests are advisable to make sure such measures are effective, and in fact are mandated by
          OSHA for employees exposed to lead at or above the action level. Almost any doctor at almost any
          clinic can perform this service, but an occupational health physician and an occupational health
          clinic are recommended, primarily for skillful interpretation of test results.

          Landscapers should have their lead levels taken before doing any work and then every two months
          for the next six months. If levels are still less than 40 ug/dL, the  time between tests can increase to
          six months. If levels are between 40 and 50 ug/dL, testing should continue every two months. Levels
          above 50 pg/dL should trigger monthly testing, and if they don't  decrease, the landscaper should be
          removed from  the work area. However, this step may well be avoided. As soon as blood lead levels
          rise, employers should try to find out why and remedy the situation. Often the  cause is some break
          in the accepted work practices, which can  be handled by re-educating the employee.

          The EMPACT LSYP has not seen any elevated blood lead levels among its team members as a result
          of exposure to  lead in soil during landscaping work.
           LEAD-SAFE YARD PROGRAM
               HEALTH AND SAFETY
I. Primary route of entry of lead into the body is ingestion:
    A. Lead can enter the body through normal
      hand-to-mouth activities.
    B. Small amounts of lead left on hands or clothing
      can impact blood lead levels.
    C. Lead-contaminated soil can be transferred to the
      interior
      of dwelling (by pets, shoes, clothing).
II. Preventive measures:
    A. Avoid dust-generating activities.
    B. Dampen soil to minimize dust generation.
    C. Keep children and pets away from area where
      work is being done.
    D. Wear leather or comparable work gloves to
      minimize
      hand contamination.
    E. Do not smoke* or eat while in work area.
    F. Wash face and hands before smoking* or eating.
    G. Remove shoes/boots before entering a dwelling to
      limit contaminated soil transfer.
    H. Wash work clothing separately from other clothing.

* Do not smoke at all.
7 YARD TREATMENTS

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7.7     APPROVAL  AND  SIBNDFF
           ON  WORK COMPLETE
After all landscape work and construction is complete, both you and the homeowner should inspect
the property. You should look for the following things:

    • That all landscape treatments have been successfully implemented as per the scope of
     work agreed to during the design session.

    • That, for each treatment measure, the landscaper has followed the detailed specifications
     defining exactly how the work should be done and what materials should be used.

    • That the property has  been left in a clean state. The homeowner must approve any
     material remaining on site after completion of the landscape work.

This process of approving the completed work can be as  formal or informal as you want to make
it. During Phases  1 and 2, the EMPACT LSYP approved each yard treatment during an informal
visit between  the outreach worker and the homeowner (the outreach worker also used these visits
to reinforce the lead hazard  education delivered during previous visits). On the other hand, Lead
Safe Boston, a spinoff of the EMPACT  LSYP run by the City of Boston, has developed a legally
binding project completion certificate (see page 109) to be signed by the homeowner and the land-
scape contractor after the property has been inspected and all work approved. The certificate also
serves as a lien waiver, in which both the homeowner and contractor discharge Lead Safe Boston
from any legal claims that may arise in connection with the work performed under the program.

Lead Safe Boston has also created an additional form (see page 110) for the contractor to sign upon
receipt of final payment. The form certifies that the contractor:

    • Has paid all debts associated with the work done on the property.

    • Discharges the program and the homeowner from any claims made by subcontractors,
     material suppliers, or workers, in connection with the work performed under the program.

    • Has completed all work on the property according to the terms of the contract.

    • Warrants the completed work against workmanship and material  defects for the period
     stipulated in the contract.

    • Has been paid in full for all work complete.
7.B      HANDING  OVER
            THE  CASE  FILE
At the conclusion of the yard treatment process, after all land-
scape work  has  been  inspected and approved,  you should
present the homeowner with the case file that has been devel-
oped  for his or her property. This  file should be a  binder
containing all information related  to the property, including
copies of application and permission forms, testing results,
treatments plans, and approval forms. The binder should also
contain a copy of the maintenance manual that the landscape
coordinator develops for the property (see Chapter 8). Keep a
copy of each case file for your program's records.
                                                          A finished project.
                                                                           VYARD TREATMENTS    97

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                  7.9      FDR             INFORMATION
                  For  information  on U.S. EPA's proposed standards (TSCA 403)  for lead-based paint hazards
                  (including lead-contaminated residential soils), visit the Office of Pollution Prevention and Toxics
                  at http://www.epa.gov/lead/leadhaz.htrn.

                  The Department  of Housing and Urban Development's Requirements for Notification, Evaluation
                  and  Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and Housing
                  Receiving Federal Assistance (24 CAR Part 35) can be found online at http://www.hud.gov/lca/.

                  For an information sheet on ACQ pressure-treated lumber, go to http://www.conradwp.com/acq.ritm.

                  Two excellent resources on lead in gardens are:

                      Lead in the Home Garden and Urban Soil Environment, by Carl J. Rosen and
                      Robert C. Munter, http://www.extension.umn.edu/di.stribiition/liorticulture/DC2543.html

                      Lead Contamination in the Garden, a fact sheet by Terry Logan,
                      http://oliioline.ag.ohio-state.edu/hyg-fact/1000/1 l49.html

                  The RSMeans Company publishes two  reference books  that  can  help  with  the  process of
                  estimating landscaping  costs. The  books,  Means Site  Work  dr Landscape  Cost  Data 2000
                  (ISBN   0-87629-547-2)  and  Landscape Estimating,  3rd  Edition by  Sylvia H.  Chattin
                  (ISBN 0-87629-534-0), can be ordered online at http://www.rsmeans.com.

                  Information on OSHA's "lead in construction standard" (OSHA Regulation 1926.62) can be found
                  online at http://www.osha-slc.gov/OshStd_data/1926_0062.html.
9B     *7  YARD  TREATMENTS

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                                                         TREATMENTS

                                    DRIP
 SI JGGFSTFD PI ANTTNGS      Raised perimeter box filled with gravel (no plantings). Install 2" x 6" ACQ
                                    pressure-treated wood box 3' from foundation wall. All joints and corners shall
Azalea evergreen hybrid (2 gallon)     be mechanically fastened with 3" galvanized wood screws to a 1-1/2" square
Torch azalea (2 eallon)                stake driven into the ground to a minimum depth of 12". All corners shall be
                                    braced with triangular exterior grade plywood keystones mechanically fastened
Japanese boxwood  (1 gallon)          directly to the wood box with 3" galvanized wood screws. Install 3" of loam and
Common boxwood (2 gallon)         2" of 3A"  crushed stone over filter fabric weed barrier.

American holly (2'-3')                Raised perimeter box filled with mulch and plantings. Install 2" x 6" ACQ
„    ,   .    /..nun/Hi                pressure-treated wood box 3'from foundation wall. All joints and corners shall
Regal privet (18 -24 )                f      .   .  „  r      .   . . „„   .    .   .      .     '       , , .„„
                                    be mechanically tastened with 3  galvanized wood screws to a 1-1/2  square
Columbine (1 gallon)                 stake driven into the ground to a minimum depth of 12". All corners shall be
Chrysanthemum (I gallon)           braced with triangular exterior grade plywood keystones mechanically fastened
                                    directly to the wood box with 3" galvanized wood screws. Install 4" of loam and
foxglove (1 gallon)                  3" of pine bark mulch over filter fabric weed barrier. Install a minimum often
Day lily (1 gallon)                    perennials per the list of plantings or approved equal.

Black-eyed susan (1 gallon)
Hosta (1 gallon)                     Existing lawn improvement. Rake bare areas to loosen soil. Apply rye, fescue,
                                    and bluegrass seed mix at the rate specified by manufacturer. Apply lA"o( top
                                    soil over new seed and water thoroughly.

      New lawn installation (at existing grade). Rototill existing lawn bed 6" deep. Apply water to contain dust
      during rototilling. Apply rye, fescue, and blue grass seed mixture at the rate specified by manufacturer. Spread
       V4" loam on top of seed. Water thoroughly.

      New lawn installation (raised  bed). Install 2" x 6" ACQ pressure-treated  wood box at owner-approved
      location. All joints and corners shall be mechanically fastened with 3" galvanized wood screws to a 1-1/2"
      square stake driven into the ground a minimum of 12". All corners shall be braced with triangular exterior
      grade plywood keystones mechanically fastened directly to the wood box with 3" galvanized wood screws.
      Install 6" of loam over filter fabric weed  barrier. Apply rye, fescue, and blue grass seed mixture at the rate
      specified by manufacturer. Spread 1A" loam on top of seed. Water thoroughly.

      Raised mulch bed (with plantings). Install 2" x 6" ACQ pressure-treated wood box to completely cover bare soil
      area. All joints and corners shall be mechanically fastened with 3" galvanized wood screws to a 1-1/2" square
      stake driven into the ground a  minimum of 12". All corners shall be braced with triangular exterior grade
      plywood keystones mechanically fastened directly to the wood box with 3" galvanized wood screws. Install 4"
      of loam  and 2" of pine bark mulch over filter fabric weed barrier. Install a minimum often perennials per the
      list of plantings or approved equal. Provide recessed egress stepping-stones from  bed to walkway.

       PAHICINB
      Gravel parking areas. Install 6" of compacted gravel/crushed stone base to all areas designated as parking areas.
      Top of base shall be 2" to 3" below finish grade of surrounding area. Install a top layer of 1-1/2" to 2" of
      processed gravel or crushed  stone (3/8" or %" size) over gravel/crushed stone base. Final grade is to have a
      minimum of 2% pitch across the surface to  ensure that water will not puddle.

      Asphalt parking areas. Level surface by preparing a 6" gravel base over a uniformly graded and compacted
      subgrade. Form, spread, and roll 2" of bituminous base coat and 1" topcoat to create a driveway 10' wide.  Final
      grade is  to have a minimum of 2% pitch across the surface to ensure that water will not puddle.
                                                                                 "7YARD TREATMENTS   99

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 WALKWAYS
 Stone path. Install round or square red patio stepping stones at all egresses from front to rear yard. All stones
 shall protrude no more than VV above the existing or new grade.

                         CHILDREN'S  PLAY
 Raised play area. Install 2" x 6" ACQ pressure-treated wood box. All joints and corners shall be mechanically
 fastened with 3" galvanized wood screws to a 1-1/2" square stake driven into the ground a minimum of 12".
 All corners shall be braced with triangular exterior grade plywood keystones mechanically fastened directly to
 the wood box with 3" galvanized wood screws. Install 4" of loam and 2" of pine bark mulch or woodchips
 over filter fabric weed barrier.

 Wood platform. Install a 10' x  12' ACQ wood platform built from 2" x 6" stock, 16" on center with 5/4" x
 6" radius edge decking. All decking and joints to be mechanically fastened with 3" galvanized screws. Platform
 shall be installed with a V4 " pitch  to drain rainwater off of surface.


 Raised vegetable garden bed. Install 2" x 8" ACQ pressure-treated wood box at owner approved location. All
 joints and corners shall be mechanically fastened with  3" galvanized wood screws to a 1-1/2" square stake
 driven into the ground a minimum of 12". All corners shall be braced with triangular exterior grade plywood
 keystones mechanically fastened directly to the wood box with 3" galvanized wood screws. Install 6" of loam
 over filter fabric weed barrier.
 PET
 Raised pet area filled with mulch or woodchips. Install 2" x 6" ACQ pressure-treated wood box to
 completely cover bare soil  area.  All joints and corners shall be mechanically fastened with 3" galvanized wood
 screws to a 1-1/2" square stake driven into the ground a minimum of 12". All corners shall be braced with
 triangular exterior grade plywood keystones mechanically fastened directly to the wood box with 3" galvanized
 wood screws. Install 4" of loam and 2" of pine bark mulch or woodchips over filter fabric weed barrier.

 PORCHES
 Bare soil under porches (lattice and trim). All exposed soil under porches is to be barricaded by ACQ wood
 framing,  lattice,  and pine trim.  Prep, prime, and paint pine trim or apply two coats of wood sealant. Install
 framed access door of like  material. Include galvanized metal hasp and hinges.

 Bare soil under porches (mulch bed). Install 2" x 6" ACQ pressure-treated wood box along footprint of
 porch. All joints and corners shall be mechanically fastened with 3" galvanized wood screws to a 1-1/2" square
 stake driven into the ground a minimum of 12". All corners shall be braced with triangular exterior grade
 plywood  keystones mechanically fastened directly to the wood box with 3" galvanized wood screws. Install 2"
 of loam and 3" of pine bark  mulch over filter fabric weed barrier.

 Bare soil under porches (gravel bed). Install 2" x 6" ACQ pressure-treated wood box along footprint of porch.
 All joints and corners  shall be mechanically fastened with 3" galvanized wood screws to a 1-1/2" square stake
 driven into the ground a minimum of 12". All corners shall be braced with triangular exterior grade plywood
 keystones mechanically fastened  directly to the wood  box with 3" galvanized wood screws. Install 3"  of loam
 and 2" of 3/4" crushed stone  over filter fabric weed barrier.
1 DO  "7 YARD TREATMENTS

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House perimeter (drip zone)
Each house receives approximately 150 l.f. of perimeter raised boxes installed 3' from
foundation wall where feasible. (Exceptions to perimeter boxes are existing asphalt/concrete
paving, bulkhead, under rear porches, etc.)- fill perimeter boxes with homeowner's choice of:

Option #1: 6" of pine bark mulch, filter fabric, and ten 1-gallon plantings (i.e., common
boxwoods, azaleas, holly,  or equal). Plantings to include compost/top soil/manure.

Or Option #2: 4" of gravel, filter fabric (no plantings).

     soil                porch      (all                              to receive
Option #1: Barricade exposed soil by wood framing and lattice secured to porch
framing/supports. Install access door of like material with hasp.

Or Option #2: Area under porch to received raised perimeter boxes, filter fabric,
and installation of 6"  of pine bark mulch  or 4" of gravel.

     yard (homeowner to choose one option)
Option #1: Each house shall receive a 10' x 12' wood platform built from 2" x 6" ACQ stock,
16" o.c. with 5/4" x 6" radius edge decking.

Each house shall also receive approximately 10' x 12' area of lawn. Treatment to include
rototilling soil 6" deep, installing filter fabric, adding 6" of conditioned top soil to be spread
by hand, perimeter edging to be constructed of 2" x 6" ACQ stock, and a 6# shade mix to be
installed by push spreader.

Or Option #2: Each house shall  receive a 10' x 12' wood platform built from 2" x 6" ACQ
stock, 16" o.c. with 5/4"  x 6" radius  edge decking.

Each house shall also receive approximately 10' x 12' garden area. Treatment to include
rototilling soil 6" deep, installing filter fabric, adding 6" of conditioned top soil to be spread
by hand, perimeter edging to be constructed of 2" x 6" ACQ stock.

Or Option #3: Each house shall  receive approximately 20' x 24' area of woodchips. Treatment
to include installation of filter fabric, adding 2" of topsoil spread by hand and covered with 6"
of woodchips, and installation of perimeter edging to be constructed of 2" x 8"  ACQ stock.

Each house shall also receive misc. treatments to adjoin mulched area to egresses. Misc.
treatments to include up  to 30 additional 12" x 12" red patio stepping stones, misc.
plantings, additional mulching, etc.

Walkways
Each house shall receive up to 30 red patio stepping stones, 12" x 12", to be used at major egresses.


SUBTOTAL (house perimeter, rear porch, back yard, and walkways)
Allowance

 $1060.00

 $1060.00


  $350.00


  $ 350.00



  $780.00


  $250.00


  $780.00


  $250.00


  $905.00


  $125.00



   $60.00

 $2500.00
CONSTRUCTION MANAGEMENT ALLOWANCE (general requirements; landscape
design and site development; construction oversight; homeowner education and maintenance           $500.00
manual development)

TOTAL (APPROXIMATE) COST PER LOT                                                    $3000.00
                                                                             7YARD TREATMENTS  ID!

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                                         SAMPLE COST ESTIMATE SHEET
                   Property address:.
                   House perimeter (homeowner to choose one option)
                   Option #1                          	l.f.
                   Perimeter box with pine bark mulch, filter fabric, and plantings.        $.
                   Or Option #2                       	l.f.
                   Perimeter box with gravel, filter fabric; no plantings.                   $.
                   Bare soil area under rear porch area (all areas matching this criteria to receive treatment)
                   Option #1
                   Wood framing, lattice, access door, stepping stones.                  $	
                   Or Option #2
                   Raised perimeter boxes, filter fabric, and mulch or gravel.             $	

                   Back yard (homeowner to choose one option)
                   Option #1
                   Installed 10' x 12' x 6" ACQwood platform.                        $	
                   New 10' x 12' area of lawn with ACQ perimeter edging.              $	
                   Or Option #2
                   Installed 10' x 12' x 6" ACQwood platform.                        $	
                   New 10' x 12' x 6" garden area framed with ACQwood.             $	
                   Or Option #3
                   New 20' x 24' x 8" area of woodchips framed with ACQwood.        $	
                   Stepping stones, misc. plantings, additional mulching, etc.            $	

                   Walkways
                   Egress stepping stones.                                            $	

                   Misc. treatments:
                   Existing lawn improvement.                                       $	
                   Additional edging, material, plantings, etc.                          $	
                   Total (Approximate) Cost
                   Cost Estimate Submitted by:.
Date:.
                   Company name:.
1 DZ  7 YARD TREATMENTS

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10 HOME STREET
                                 YARD USE (Wf ERM KEY
                                 High li«ffic A»a (Exposed toi
                                 High Wds,
                                    Area or ¥B§e*nlbiB Banfan)
                                              I
                                              ;
                                 Recreation   fPienle er 8W)|
 . i-.ior
       -^
                                        TREATMENTS 1 D3

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                                                      SAMPLE FORM:
                                  HOMEOWNER'S APPROVAL OF TREATMENT PLAN
                  Date:
                  Property Owner: .

                  Property Address:
                  I/We have reviewed the construction documents (specifications, plans, drawings, etc.) for
                  the proposed treatment of the soil around my/our property and attest that they are complete,
                  accurate and conform to my/our wishes.

                  I/We authorize the program to proceed with my/our application using said construction
                  documents fully aware that said documents may change. I/We understand that any changes
                  to the documents will be reviewed by me/us and I/We shall approve such changes prior to
                  commencement of the work by the landscaper. I/We also understand that [the lead-safe yard
                  program coordinator] must approve all changes to the proposed scope of work before
                  work begins.
                  Date of Specifications/Plans:
                  Date Landscaper can begin scope of work:
                  Number of days required to complete scope of work:
                                        Calendar Days
                        Owner # 1
Date
    Landscaper
Date
                        Owner #2
Date
Program Coordinator
Date
1 D4  7 YARD  TREATMENTS

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                              CONSULTANT CONTRACT

THIS CONSULTANT CONTRACT (the "Contract") is made as of this	day of	200_ between
(Organization Name), with its principal office located at (Organization Street Address, City, State, Zip, hereinafter called
"(Organization acronym)", and (Contractor Name), the principal place of business of which is located at (Contractor Street
Address, City, State, Zip).

WHEREAS, the (Organization acronym) desires to engage the Consultant as an independent contractor, and the Consultant
desires to accept such engagement on the terms and conditions set forth hereinafter;

NOW, THEREFORE, in consideration of the covenants and agreements herein contained, the  (Organization acronym) and
the Consultant agree with each other as follows:

1.  Scope of Services.
    • Obtain completed Homeowner Yard Use Interview and plot plan, developed by the Environmental Protection Agency,
     from (the organization acronym).

    • Design and landscape (number of) properties recruited and enrolled from (Target Area). All landscaping designs shall
     include but not be limited to the attached Attachment A Lead Safe Boston/National Center for Lead Safe Housing
     Standard Plan for Low Level Lead Soil Treatment dated December 29, 1999.

    • Meet with homeowner within ten business days after receipt of testing results and homeowner use questionnaire from
     (Organization acronym/name) to complete Landscape!' Information Sheet and to discuss current and future use of yard.

    • Generate landscape design within five business days from the date of meeting with the homeowner. Obtain
     (Organization acronym/name) approval of design; obtain homeowner approval of same. Provide (Organization
     acronym/name) with four copies.

    • Generate property specific cost proposals and submit to  (Organization acronym/name) for approval.

    • Secure planting stock and materials required for specific project(s).

    • Pay for and post all necessary fees/permits.

    • Install  landscapes as per owner and (Organization acronym) approved designs within thirty days from the date of
     landscape plan approval.

    • Generate homeowner maintenance manual specific to each property.  Provide (Organization name) with three copies
     and homeowner with one copy.

    • Conduct 30-minute educational session with homeowner to review homeowner maintenance procedures and manual.

    • Obtain homeowner and (Organization acronym) final approval of landscape work.

    • Leave property in a clean state.  Owner  must approve any material remaining on site after completion of landscape
     installation.

    • Provide a 1-year workmanship and materials warranty from date of final homeowner approval. This warranty is limited
     to defects in workmanship and materials attributable to the consultant only and does not cover losses caused by: acts of
     God, third parties or failure of the homeowner to comply with the maintenance procedures and manual.

    • Coordinate with Lead Safe Boston representatives and/or other applicable agencies in the execution of this contract.

    • Complete all work as per local, state and federal rules and regulations.
                                                                             "7YARD TREATMENTS  1 D5

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1. Compensation. The (Organization acronym/name) shall reimburse Consultant on a semimonthly basis for (Contractor name) serv-
  ices on receipt of itemized invoices as follows:

    • $(Negotiated amount)/ea. On completion of initial visit with homeowner to discuss landscape design

    • $(Negotiated amount)/ea. On completion and approval of landscape design and maintenance manual.

    • Half of property specific cost proposal (less design fee) on commencement of landscape installation.

    • Balance on completion and approval of installation and 30-minute educational session with homeowner to review homeowner
      maintenance procedures and manual.

    • No one property shall exceed $3,000 including general conditions, design work and maintenance manual without prior
      approval from (Organization acronym/name).

    • Invoices shall  reflect actual costs per property and are to be submitted semimonthly to (Organization acronym/name) for
      processing and payment.

2. Term. The term of this Contract shall be from (Start  Date) to (End Date).  Either party  on 30 days notice may terminate this con-
tract.  In the event of premature termination by the (Organization  acronym/name), the Consultant shall be paid for all work
completed prior to the termination as well as the reasonable value of all work partially completed and all materials obtained and
stored on-site.

3. Benefits. The (Organization acronym/name) is not responsible  for any insurance or other fringe benefits, including, but not limited
to social security, worker's compensation, income tax withholdings, retirement or leave benefits,  for Consultant or employees of
Consultant.  The Consultant assumes full responsibility for the provisions of all such insurances  and fringe benefits for himself or
herself and all Consultant's employees.

4. General Liability and Workman's Compensation. The contractor shall purchase and maintain such insurance as will protect
him/her from claims under the Workman's Compensation Acts (chapter 152 of the Massachusetts General Laws) and from claims  for
damages because of bodily injury, including death and all property damage including, without limitation to, damage to the buildings
and adjoining the site of construction which might arise from and during operations under any Contract, whether such operations  be
by himself/herself or by any subcontractor or  anyone directly or indirectly employed by either of them. The Contractor shall, with-
out limiting the generality of the foregoing, conform to the provisions of the Section A of Chapter 149 of the Massachusetts General
Laws, which Section is incorporated  herein by reference and made a part hereof.

General Liability Insurance Minimum bodily  injury limits of $100,000 per person and
$300,000 per accident, and $300,000 aggregate during any twelve-month period, shall
include  the following:

    a. Public Liability (bodily injury and properly damage)

    b. Independent Contractor's Protective Liability

    c. All Risk Insurance - covering  all contractor equipment with provisions of waiver of Subrogation against the Owner

    d. Comprehensive All Risk Motor Vehicle Liability Insurance—minimum bodily injury limits of $100,000 per person,
      per accident, and property damage limit of $300,000 per accident

5. Arbitration. Any controversy or claim arising out of, or relating  to, this Contract or the breach thereof, shall be settled by arbitra-
tion in accordance with the rules then obtaining of the American Arbitration Association.  Judgement upon the award rendered may
be entered in any Court having jurisdiction thereof.  Any award rendered hereunder shall be final and binding on all parties thereto.

6. Construction. This Contract shall be construed, interpreted and applied under and in accordance with the laws of Massachusetts.

7. Parties Bound. The terms and provisions of this Contract shall be binding upon the parties hereto, their legal representatives, suc-
cessors and assigns.
 IDS   *7 YARD TREATMENTS

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8. Federal Requirements. The Consultant's services may be reimbursed in part from funds under a contract funded directory or
indirectly by the U.S. Department of Housing and Urban Development.  Consultant is bound by the provisions of that contract.

9. Entire Agreement. This instrument contains the entire agreement between the parties. No statement, promises or inducements
made by any party hereto, or agent of either party hereto, which is not contained in this written contract, shall be valid or binding;
and this contract may not be enlarged, modified or altered except in writing and signed  by the parties.

IN WITNESS WHEREOF, the parties have caused to be properly executed on their respective behalf, this Consultant Contract,
effective for all intents and purposes as of
(Month, Day, Year).


(Organization Name)
Title:
(Contractor's Name)

By:	
Title:
                                                                                       7 YARD TREATMENTS  1 D7

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                                      ATTACHMENT A—Narrative
                     Lead Safe Boston/National Center for Lead-Safe Housing
                         Standard Plan for Low Level Lead Soil Treatment
                                             December 29, 1999


Goals of the Low Level Soil Treatments
The goal of this project will be to improve the lead safety in homes by the reduction of exposure to high levels of lead in soil.  All
work will be based on soil assessments conducted by EPA. EPA will conduct all soil testing and provide to the vendor/contractor a
plot plan indicating areas of concern.

Abatement strategies shall be designed to change the use of the yards while providing a lead safe area for children and families to
enjoy.

Outreach and Enrollment
The outreach and enrollment component of the project will be undertaken by a contractor already in use by The National Center
(Silver Linings). Outreach will focus on a pool of properties deleaded under Lead Safe Boston's Round 1 Evaluation project. These
properties will be targeted primarily because of the extensive data collected to date.

Typical Yard
When the deleading of a home was complete, the single soil treatment conducted by Lead Safe Boston deleading contractors
included a final cleanup of the soil by hand raking after abatement of the structure as per the Massachusetts Lead Law.  The proper-
ties averaged 4000 s.f. and  the footprint of the home averaged 1000 s.f.  In addition, the yards are mostly flat, compacted soil with
evidence of tree roots and shade. Most properties do not have driveways.

General Requirements
The General Requirements are to include but are  not limited to: permits/fees, a 1 year workmanship and material warranty period,
general liability and worker's compensation requirements (see attached).

Landscaping and Site Development
Landscaping and Site Development is to include generation of the initial Landscape  design based on use and the plot plan provided
by EPA. Also to be included is the generation of the maintenance manual for the homeowner education component.

Construction Oversight
The construction oversight allowance is to include construction monitoring, final  inspection/sign off and homeowner final approval.
The date of final homeowner approval will be the starting date of the 1 year warranty period.

Homeowner Education
The homeowner education allowance is to include two on-site meetings:  initial meeting to obtain homeowner approval and a final
meeting to review all site specific maintenance manuals and work completed by the vendor/contractor.

Design
The Consultant shall use this document as a guideline for all landscape design decisions.
 IDS  *7  YARD TREATMENTS

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                                      SAMPLE PRO'fECT
                                COMPLETION CERTIFICATE
Date:	                        Building ID:.

Property Owner: 	

Property Address: 	
I/We have inspected my/our property and found that the work conducted to make our yard lead safe has
been successfully completed according to the scope of work I/we approved dated	
I/We have met with [Contractor name] and attended a 30-minute educational session to review the Lead
Safe Yard Maintenance Procedure Manual. [Contractor Name] has provided me/us with a copy of this
manual for my use.
In accordance with the scope of work and in connection with the final payment made to the contractor, I
hereby agree to discharge, and hold [Your Program] harmless from any and all claims which arise against
the Owner and/or his/her property, in connection with the work performed under this Program.
      Homeowner Name         Date               Homeowner Name              Date

Inspection has been made of the yard made lead safe through the [Your Program]. I have examined the work
and found all the work to be completed in a satisfactory manner and in accordance with the scope of work
dated	
       Program Representative              Date
In accordance with the contract dated	and in connection of the final payment made there-
under, I hereby agree to discharge, and hold the Owner and [Your Program] harmless from, any and all claims
(including all liens resulting therefrom) which arise against the Owner of his/her property the contractor as its
assignee now has or ever had by virtue or, or in connection with the work performed under, said Agreement.

That also in consideration of said final payment I hereby agree to discharge, and hold the Owner harmless
from, any and all claims (including all liens resulting therefrom) which may be brought within forty (40) days
of the date hereof by all sub-contractors, all suppliers of materials and equipment,  and performers of work,
labor or services arising by virtue of, or in connection with the work performed under, said Agreement.

That I warrant same for one (1) year from the date hereof, against workmanship and materials defects. One-
year warranty does not cover losses caused by: acts of God, third  parties or failure of the homeowner to comply
with the maintenance procedures and manual.
         Contractor Name                 Date
                                                                   "7  YARD  TREATMENTS  1 D9

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                                            SAMPLE FORM:
          CONTRACTOR'S AFFIDAVIT OF PAYMENT OF DEBTS, RELEASE OF CLAIMS,
                  WARRANTY OF WORKMANSHIP AND RECEIPT OF PAYMENT
       Property Address:.
       Pursuant to the Agreement between [Contractor Name] and [Your Program], dated	/	/, for
       the scope of work conducted at the above listed property, the undersigned, acting on behalf of the
       contractor, hereby certified and agrees as follows:

           1) That he/she has paid in full, or has otherwise satisfied obligations for all materials and
             equipment provided, and for all work, labor, and services performed and for all known claims
             for all damages arising by virtue of, or in connection with the work performed under, said
             Agreement for which the owner of his/her property might in any way be held responsible.

           2) That in accordance with said Agreement and in connection of the final payment made
             thereunder he/she hereby releases the Owner and [Your Program] of any lien, or claim or right
             to lien on said property resulting therefrom, which against the owner of his property the
             contractor or its assignee now has or ever had by virtue of, or in connection with the work
             performed under, said Agreement.

           3) That also  in consideration of said final payment he/she hereby agrees to discharge, and hold
             the Owner and  [Your Program]  harmless from, any and all claims  (including all liens resulting
             therefrom) which may be brought within forty (40) days from the date hereof by all
             subcontractors, all suppliers  of materials and equipment, and all performers of work, labor,  or
             services arising by virtue of,  or in connection with the work performed under, said Agreement.

           4) That all work in connection with said Agreement has been performed in accordance with terms
             thereof.

           5) That he warrants same for one (1) year from the date hereof, against workmanship and materials
             defects. The one-year warranty does not cover losses caused by: acts of God, third parties, or
             failure  of the homeowner to comply with the maintenance procedures and manual.
           6) That he/she has received from [Your Program] all sums of money payable to the contractor
             under said Agreement and any modifications or changes thereof.
       By:
                          Contractor Name                                   Date
1  1 D  *7 YARD TREATMENTS

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                           B
YARD  MAINTENANCE
Since the start of the EMPACT Lead-Safe Yard Project in 1998, the project's leaders have gained a
heightened appreciation of the importance of yard maintenance to the project's overall success. It
is safe to say that good maintenance is as critical as gathering accurate soil samples or selecting
appropriate treatment measures.

This chapter explains the importance of yard maintenance (Section 8.1) and provides guidance on
making maintenance an integral part of your lead-safe yard program. Section 8.2 presents specific
maintenance guidelines for the landscape treatments found in Chapter 7. Section 8.3 describes the
development of a property-specific maintenance manual and presents a sample manual used by the
EMPACT Lead-Safe Yard Project.  Section  8.4 provides tips  on homeowner education, while
Section 8.5 suggests creative ways of encouraging ongoing maintenance.

All of these sections will be useful to someone responsible for implementing a lead-safe yard  pro-
gram. Homeowners interested in applying landscape treatments to their own yards can focus on
Sections 8.1, 8.2, and 8.3.

B.l      THE  IMPORTANCE OF  YARD  MAINTENANCE
Why is yard maintenance such an important part of a successful lead-safe yard  program?  The
answer is quite simple. All of the landscape measures used by the EMPACT LSYP are interim con-
trols: that is, they are designed to protect children and other people from existing soil-lead hazards
without  permanently abating the hazards. These landscaping measures provide protection only so
long as they are kept in good repair. Evergreen shrubs, for example, will discourage children from
playing in the  drip zone only if the shrubs are kept alive.  Grass serves as a protective barrier only if
it is healthy and well maintained. Likewise, a mulch-filled pet area must be raked regularly to main-
tain a 6-inch mulch barrier and keep pets from contacting lead-contaminated soil.

The  good news is that all of these landscape measures can provide effective, continuing protection
if well maintained. And most maintenance tasks are relatively simple—as easy as tightening a screw,
watering  a lawn, or raking  a gravel drive.

O.Z     MAINTENANCE  REQUIREMENTS
                   EMPACT TREATMENT
The  table on pages 114 to  116 summarizes all maintenance tasks required for the landscape treat-
ments described in Section 7-2 of this handbook. The table includes information on the optimum
frequency of maintenance and the tools needed for each task.

B.3     DEVELOPING  A  PROPERTT-
           SPECIFIC  MAINTENANCE  MANUAL
For each  completed yard treatment, the landscape coordinator should prepare a property-specific
maintenance manual that can  be provided to the homeowner as part of the case file for his or her
property (see Section 7-8). This maintenance manual should tell the homeowner what maintenance
tasks need to be performed, when it is best to do them,  and what tools (if any) are required for
each job.
                                                                     B  YARD MAINTENANCE  111

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                  The maintenance  manual used by the EMPACT LSYP during its  Phase  1  and 2 treatments is
                  shown on pages 117 through 122. The manual has several features that make it effective and easy
                  to use:

                     • It is easily customized for each yard treated. The landscape coordinator simply places
                       a checkmark next to each treatment measure used in that particular yard.

                     • It is easy to read. The homeowner simply looks for the checkmarks identifying the
                       treatments used, then follows the maintenance guidelines provided.

                     • It is keyed to correspond with the treatment plan developed during the design session.
                       The letters identifying particular treatment measures match up with those shown on
                       the site worksheet (see page 79 in Chapter 7).

                     • It includes a list of materials used for yard maintenance, their typical costs, and places
                       they can be obtained (including sources of free materials).

                             EDUCATINB
                             ABOUT  YARD  MAINTENANCE
                  At the conclusion of each  yard treatment, the landscape  coordinator should meet with the home-
                  owner to  review  all  landscape work  that has been  completed  in  the  yard,  pass  on  the
                  property-specific maintenance manual, and explain the information it contains.

                  This meeting  provides a perfect opportunity to educate  the homeowner about the importance of
                  yard maintenance  and to re-emphasize some of the key lessons of your program. The EMPACT
                  LSYP has found that homeowners often don't retain the information on soil-lead hazards that was
                  presented to them by the  outreach coordinator (see Lessons Learned below). For this reason, the
                  landscape coordinator should use this opportunity to review the following:

                     • The results of the soil-lead  sampling and the areas of concern.

                     • Why lead-contaminated soil is harmful to children and other people.

                     • The landscape treatments that were employed and how they protect
                        against  harmful exposures.

                     • The homeowner's responsibility in maintaining the landscape installations.

                  Throughout the meeting, the landscape coordinator should emphasize that  the  landscape treat-
                  ments will only be effective if well  maintained.  He or she should also emphasize that all involved
                  maintenance is easy and inexpensive to perform.

                                                           ENCQURAQINQ
                             ONBOINB  MAINTENANCE
                  Once you have finished treating  a yard, met with the homeowner one last time,  thanked him or
                  her for participating, and said goodbye, the success of that yard treatment is almost entirely in the
                  homeowner's hands.  If he or she completes all maintenance tasks as  outlined in  the maintenance
                  manual,  the treatments that have  been installed can provide ongoing protection for many years. On
                  the other hand, if the homeowner neglects all maintenance, the benefits of the yard treatment will
                  be limited.
112  8 YARD  MAINTENANCE

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             LESSONS LEARNED: RE-EDUCATING HOMEOWNERS
                           ABOUT SOIL-LEAD HAZARDS

  During Phases 1 and 2 of the EMPACT Lead-Safe Yard Project, the project team made
  focused efforts to educate homeowners about the need for maintaining the landscape
  treatments that "were installed in their yards. These efforts included the creation of a
  homeowner packet for each completed property; the packet contained a record of the
  soil-lead sampling results, a color-coded plot plan showing treatments used, and a
  property-specific maintenance manual identifying maintenance tasks needed for that yard.

  In the spring of 2000, less than two years after  the first Phase 1  treatments were
  completed, members  of the EMPACT team revisited several of the Phase 1 and 2
  properties to evaluate  the level of maintenance that had taken place. The results were
  disappointing. Their  observations indicated that, at some properties, little or no
  maintenance had occurred. Many of the landscape installations (especially those requiring
  frequent attention from the homeowner, such as grassed areas and plantings) had degraded
  to the point where they no longer appeared to provide effective protection. Some
  homeowners were unable to locate their maintenance manuals when  asked.

  In assessing the reasons for these disappointing results, the project  team found that many
  of the homeowners perceived the LSYP as a "yard beautification" project rather than as a
  risk-prevention program designed to protect children from dangerous lead exposures.
  Though each homeowner had been given extensive information about soil-lead hazards and
  how landscape measures could help protect their family's health, the  homeowners had not
  always retained this message. The project team concluded that they needed to find new
  strategies for emphasizing the lead hazard message during Phase 3  of the project, and for
  creating repeated opportunities for homeowner re-education.
  The strategies devised by the project team included sending out
  reminders about the need for yard maintenance, holding
  community-wide lead-safe yard maintenance days, and offering
  annual educational events about soil-lead hazards. These
  strategies are presented in Section 8.5. Additional strategies are
  described in Section 5.2, "Educating People About Lead and
  Lead in Soil."
Here  are  three strategies  for  encouraging ongoing  maintenance
over time:
     Send out reminders. Try developing a standard maintenance
     reminder that can be sent out annually to all homeowners
     who have participated in your program.
Organize a presentation on lead poisoning and soil-lead
hazards to encourage ongoing yard maintenance within
the community.
    • Hold community maintenance days. Once or twice a year (perhaps in spring and/or fall),
     organize a community-wide "Lead-Safe Yard Maintenance Day." Such an event could be
     combined with community clean-up days.

    • Offer annual educational events within your community about soil-lead hazards. For
     example, you might want to organize a presentation on lead poisoning and soil-lead
     hazards at a local community center or community college.

Above all, remember to be creative in communicating your message about soil-lead  hazards, and
repeat it at every opportunity.
                                                                         3 YARD MAINTENANCE  113

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Yard Area
Drip zone
Grassed
areas
Treatment
Measure
Raised perimeter
box filled with
mulch and
plantings
Raised perimeter
box filled with
gravel
Existing lawn
improvement
OR
New lawn
installation
(at existing grade)
New lawn
installation
(raised bed)
Raised mulch bed
(with plantings)
Maintenance Tasks
Check that all screws and other
connections on box are secure
Look tor and remove splinters
Remove weeds and debris
Replenish mulch to 6" depth
Water plantings
Check that all screws and other
connections on box are secure
Look for and remove splinters
Remove weeds and debris
Apply grass fertilizer
Water lawn
Reseed bare spots
Check that all screws and other
connections on box are secure
Look for and remove splinters
Apply grass fertilizer
Water lawn
Reseed bare spots
Check that all screws and other
connections on box are secure
Look for and remove splinters
Remove weeds and debris
Replenish mulch to 6" depth
Water plantings
Frequency
Annually
Annually
Three times a year
Every two years
Regularly
Annually
Annually
Annually
Twice a year
(spring and fall)
Regularly
Annually (spring or
early fall)
Annually
Annually
Twice a year
(spring and fall)
Regularly
Annually (spring or
early fall)
Annually
Annually
Three times a year
Every two years
Regularly
Tools Needed
Screwdriver,
hammer
None
None
Mulch fork or rake,
shovel, wheelbarrow
Sprinkler, garden hose
Screwdriver,
hammer
None
None
None
Sprinkler, garden hose
Rake, seed mixture
Screwdriver,
hammer
None
None
Sprinkler, garden hose
Rake, seed mixture
Screwdriver,
hammer
None
None
Mulch fork or rake,
shovel, wheelbarrow
Sprinkler, garden, hose
114  8 YARD MAINTENANCE

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EMPACT
Yard Area
Parking
areas
Recreation
and
children's
play areas
Pet. areas
Bare soil
under
porches
Treatment
Measure
Gravel parking
area
Asphalt parking
area
Wood platform
Raised bed filled
with mulch or
woodchips
Raised pet area
filled with mulch
or woodchips
Install lattice and
trim
Maintenance Tasks
Remove weeds and debris
Rake to maintain evenly spread
top layer of 1 Vi " to 2"
No maintenance needed
Check that all screws and other
connections are secure
Look for and remove splinters
Sweep to maintain cleanliness
Check that all screws and other
connections on box are secure
Look for and remove splinters
Remove weeds and debris
Replenish mulch to 6" depth
Check that all screws and other
connections on box are secure
Look for and remove splinters
Remove weeds and debris
Rake to maintain 6" depth
Replenish mulch or woodchips to
6" depth
Check that all screws, nails, and
other connections on installation
are secure
Look for and remove splinters
Scrape, sand, and paint or apply
additional coats of sealant
Frequency
Twice a year
(spring and fall)
As needed
None
Annually
Annually
As needed
Annually
Annually
Three times a year
Every two years
Annually
Annually
Twice a year
As needed
Every two years
Annually
Annually
Annually
Tools Needed
None
Rake
None
Screwdriver, hammer
None
Broom
Screwdriver, hammer
None
None
Mulch fork or rake,
shovel, wheelbarrow
Screwdriver, hammer
None
None
Rake
Mulch fork or rake,
shovel, wheelbarrow
Screwdriver, hammer
None
Scraper, sandpaper,
paintbrush, paint or
sealant
                                                                     Q YARD  MAINTENANCE  115

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          EMPADT             TREATMENTS
Yard Area
Bare soil
under
porches
Garden
areas
Walkways
Treatment
Measure
Raised bed filled
with mulch or
gravel along
footprint of porch
Raised vegetable
garden bed
Stone path
Maintenance Tasks
Check that all screws and other
connections on box are secure
Look for and remove splinters
Remove weeds and debris
Rake to maintain evenly spread
top layer
For mulch beds, replenish mulch
to 6" depth
Check that all screws and other
connections on box are secure
Look for and remove splinters
Add additional loam
(or compost)
Sweep to maintain cleanliness
Frequency
Annually
Annually
Annually
As needed
Every two years
Annually
Annually
Annually
As needed
Tools Needed
Screwdriver,
hammer
None
None
Rake
Mulch fork or rake,
shovel, wheelbarrow
Screwdriver,
hammer
None
Shovel, wheelbarrow
Broom
116 O YARD MAINTENANCE

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     LEAD-
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             LOOK FOR THE
Ef
THAT SHOWS THE TREATMENTS
            USED IN YOUR YARD AND FOLLOW THE GUIDELINES
                     A.  Pressure Treated Wood Drioline Boxes
                                    MAINTENANCE
                                      Once a year:
                              Check to make sure that all screws
                               and other connections are secure

                                Look for and remove splinters

                                     Tools Needed:
                                 Screwdriver and/or hammer
             Dripline Boxes are Lined with Perforated Plastic or Landscape Film
                         Then Filled with One of the Following:



./ Mulch
" MAINTENANCE
Three times a year:
Remove weeds and debris
spring and summer
Tools Needed:
None
Every two years:
Replenish mulch to 6" depth
Tools Needed:
Mulch fork or rake
Shovel
Wheelbarrow
1


./ gravel
MAINTENANCE
Once a year:
Remove weeds and debris
Tools Needed:
None




U Mulch Over Gravel
MAINTENANCE
Three times a year:
Remove weeds and debris
spring and summer
Tools Needed:
None
Every two years;
Replenish mulch to 2" depth
Tools Needed:
Mulch fork or rake
Shovel
Wheelbarrow
1 1 S O YARD MAINTENANCE

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          7
        B.  Pressure Treated  Wood Raised Picnic/Play Areas

                               MAINTENANCE
                                 Once a year:
                        Check to make sure that all screws
                         and other connections are secure

                          Look for and remove splinters

                                Tools Needed:
                           Screwdriver and/or hammer
             Pressure Treated Wood Raised Play or Picnic Areas are Lined
                 with Perforated Plastic or Landscape Fabric and then
                           Filled with One of the Following:
J
Woodchips
       MAINTENANCE
      Three times a year:
    Remove weeds and debris
      spring and summer

        Tools Needed:
           None

       Every two years:
Replenish wood chips to 6" depth

        Tools Needed:
      Mulch fork or rake
           Shovel
        Wheelbarrow
                                 I     I   Gravel

                                  *"    MAINTENAN
      INTENANCE
     Once a year:
Remove weeds and debris

    Tools Needed:
        None
Mulch
                                                              MAINTENANCE
                                                             Three times a year:
                                                           Remove weeds and debris
                                                             spring and summer

                                                               Tools Needed:
                                                                   None

                                                              Every two years:
                                                          Replenish mulch to 6" depth

                                                               Tools Needed:
                                                             Mulch fork or rake
                                                                  Shovel
                                                               Wheelbarrow
                                          See Resource List for Sources of Free Materials
                                                                    YARD MAINTENANCE  119

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                   C.   Pressure Treated  Wood Raised garden Plots
                                        MAINTENANCE
                                          Once a year:
                                 Check to make sure that all screws
                                  and other connections are secure

                                   Look for and remove splinters

                                         Tools Needed:
                                    Screwdriver and/or hammer
         Pressure Treated Wood Raised Garden Plots are Lined with Landscape
                     Film and then filled with Loam and Compost:
                                        MAINTENANCE
                                          Once a year:
                                     Add additional Compost
                                          Early spring

                                         Tools Needed:
                                            Shovel
                                         Wheelbarrow
1 2D  O YARD MAINTENANCE

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              D.  Covered Surface Areas for People,  Cars and Pets
  /[Stepping Stone Paths
Y  [       *WINTm4NCE
           Sweep as needed

            Tools Needed:
               Broom
              Grassed Areas
      (Recommended for sunny spaces)
                 Twice a year:  .
              Apply grass fertilizer
                 spring and fail

                 Tools Needed:
                    None

            Water regularly especially
             during hot, dry weather

                 Tools Needed:
                  Sprinkler
                 Garden hose

                 Every Year:
               Reseed bare spots
               spring or early fall

                 Tools Needed:
                    Rake
gravel Driveways and Paths
     (travel spread to 2"depth)
         MAINTB^NOE
           Twice a year:
      Remove weeds and debris
          spring and fall

          Tools Needed:
              None

         Rake as needed to
         maintain 2" depth

          Tools Needed:
              Rake
       Areas For Pets
(Woodchips spread to 6" depth)
         MAINTENANCE
           Twice a year:
      Remove weeds and debris
         spring and summer

          Tools Needed:
              None

         Rake as needed to-
         maintain 6" depth

          Tools Needed:
              Rake

         Every two years:   ^
       Replenish woodchips to
         maintain 6" depth

          Tools Needed:
        Mulch fork or rake
             Shovel
          Wheelbarrow
                                             See Resource List for Sources of Free Materials
                                                                      YARD  MAINTENANCE  121

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                             RESOURCES AND TYPICAL COSTS
                       Prepared for Dorchester Lead Safe Yards Program 1999
           MATERIAL
           Gravel
           Mulch
           Woodchips
           Pressure Treated
           Lumber (2"x 6")

           Grass Seed
           Grass Fertilizer
           Plastic in Rolls
           Landscape Fabric

           Compost
           Stepping Stones
 SOURCE
Building Supply
Garden Center

Garden Center
Tree Service or
Recycling Center or
Parks Department
Lumber Yard

Garden Center


Garden Center


Hardware Store

Garden Center

Garden Center or
Recycling Center or
Parks Department

Building Supply or
Garden Center
TYPICAL COST
$20.00 per cubic yard
plus delivery

$25.00 per cubic yard
$6.00 per 3 cubic foot
bag
plus delivery

      FREE
      FREE
      FREE

$.75  per linear foot
plus delivery

$10.00 per 3 Ib.  bag
(covers 1700 sq. ft.)

$10.00 per bag
(covers 5000 sq. ft.)

$3.00 per 3'x50f roll

$15.00 per 3x50' roll

$5.00 per 50 Ib. bag
      FREE
      FREE

$2.00 per 12" pre-cast
square or round stone
1 ZZ  O  YARD MAINTENANCE

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                                       EVALUATING YOUR
                                       LEAD-SAFE  YARD
This chapter provides guidance on evaluating the  effectiveness of your lead-safe yard program.
Section 9-1  suggests questions that you may want to focus on during your evaluation. Section 9-2
discusses the need for documenting your program's work at key evaluation points.

The information in this chapter is designed primarily for managers and organizers who are respon-
sible for running lead-safe yard programs.

9.1      FDCUSINB YOUR  EVALUATION
How effectively does your program reduce young children's exposure to lead? To answer this, you
will need to evaluate  your program.

As described in Section 1.2.2, EPA New England and the National Center for Lead Safe Housing
(http://www.leadsafchousing.org) are currently leading a HUD-funded research study to document
the effectiveness of the low-cost interim soil control measures used by the EMPACT Lead-Safe Yard
Project. The study will include a retrospective evaluation of the soil intervention work conducted
during Phases 1 and  2 of the EMPACT LSYP It also will examine data collected during the sum-
mer of 2000 by all three Boston-based lead-safe yard programs: the EMPACT project,  the Lead
Safe Boston demonstration  project, and the Boston Public Health Commission  project. Soil-lead
data will be collected before, during,  and after each yard  intervention, mainly to document the
effectiveness of the landscape treatment measures in reducing risk to residents.

In designing an approach to evaluating your own program, you can focus on any of a number of
criteria. Some of these are easily measurable, others are not. Here are four questions you may want
to look at in your evaluation:

    • How effective were the yard treatments in reducing soil-lead  levels?

    • How well did the yard treatments hold up over time?

    • What effect did the yard treatments have on children's blood lead levels?

    • How well did your program educate residents about lead poisoning?

9.2      DOCUMENTINB  EVALUATION  POINTS
An effective strategy for evaluating mitigation work  is to compare the yard at three points in time:
pre-treatment,  immediately after treatment, and one year after treatment. Key to conducting an
evaluation is adequate documentation  of the program's work. Throughout this handbook, tools for
documenting lead-safe yard  activities have been identified. The following documentation should be
contained in the case file you began upon initial contact with the homeowner:

    • Homeowner application materials and consent form  (Chapter 5).

    • Results of educational 'quiz' (Chapter 5).

    • "Homeowner Yard Use/Treatment Options Interview" Form (Chapter 5).

    • "Before and after"  photographs of the yard.
                                        9 EVALUATING YOUR  LEAD-SAFE YARD PROGRAM  123

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         • Site worksheet (with monitoring results) and color-coded plot plan (Chapter 6).

         • Treatment plan (Chapter 7).

         • Contract (Chapter 7).

         • Cost estimate sheet (Chapter 7).

         • "Homeowner's Approval of Treatment Plan" Form (Chapter 7).

         • Project Completion Certificate (Chapter 7).

         • Any information available about blood lead levels of children living in the home.

     When you return a year later, you  should again obtain the homeowner's permission for inspecting
     the yard  and taking additional measurements and  photographs. A sample form  is shown on
     page 126 ("Homeowner Permission Form—One Year Follow Up"). Your photos and notes from the
     follow-up visit will help document how well the landscaping measures have been maintained. You
     should also get input from the owner on:

         • His or her impressions of the benefits and/or drawbacks of the landscaping done
           at the home.

         • How hard or easy it was for  the homeowner (or another resident) to maintain the
           landscaping measures and whether the maintenance plan was clear and easy to follow.

         • How your lead-safe yard program could be improved (e.g., through better treatment
           measures or better maintenance procedures).

     You can  also try to evaluate how  well your educational efforts worked;  the EMPACT outreach
     worker, for example, plans to readminister the quiz that she gives following the educational video,
     'Lead Poisoning: The Thief of Childhood.' Finally, you can ask the  residents if they are willing to
     give you the results  of any lead testing done on children who live at the home.

     All of this information will help you document and assess the various aspects of the program. This
     evaluation will be of value to your project team, your funders, the community, and each family
     involved in the program.
1  24  9  EVALUATING YOUR  LEAD-SAFE YARD PROGRAM

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                                                 IN

  In the summer of 1999, the EMPACT Lead-Safe Yard Project returned to several
  residences in the Bowdoin Street neighborhood to assess changes in surface soil-lead levels.
  All of these residences had been treated one year earlier, during Phase 1  of the project.
  Retesting efforts focused on play areas and/or areas that had been found to have high soil-
  lead levels during the initial testing. As illustrated in the graphs below, the results of the
  retesting showed that lead concentrations in the yard surfaces were significantly lower at
  each site. This indicated to the project team that the landscape barriers installed at the
  sites during the yard treatments were effectively covering the contaminated soil below.
  In the year 2001, the EMPACT LSYP intends to do another round of retesting at 25 sites.

                            Property #1
                                                             before

                                                             a Her*
                                 tot avg

                             Property #2
                                 tot avg         A-Side       Picnic Area

                      Lead Concentration Before and After Mitigation for Three Phase 1 Properties
*$oil-lead concentrations were sampled ] 0 10 13 months atrer mitigation.
                                    EVALUATING YOUR LEAD-SAFE  YARD PROGRAM   123

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                                 Homeowner Permission Form
                                Boston Lead Safe Yard Program
                                       One Year Follow Up

 Your yard has been made more safe for children to play in and for you to enjoy by the landscaping improvements
 that we have done through the Lead Safe Yard Program. Thank you for your cooperation during this community
 effort.

 Now that we have finished a large number of yards in your neighborhood, we would like to inspect the work to see
 how well the improvements are holding up over time. We would like your permission to talk with you and to visu-
 ally inspect all of the landscape improvements made by our program. During the visual inspection, we would also
 make some measurements and take a few photographs of the work. The inspection will take about an hour. This
 evaluation  is funded by Lead-Safe Boston and the U.S. Department of Housing and Urban Development (HUD)
 and coordinated by the National Center for Lead-Safe Housing.

 I give my permission for a visual inspection and measurements of the landscape improvements made by the Boston
 Lead Safe Yard Program.
 Homeowner #1 signature                    Date
 Homeowner #2 signature                    Date
 Lead-Safe Yards Evaluation staff             Date
 or Interviewer
1 26  9  EVALUATING YOUR  LEAD-SAFE YARD PROGRAM

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                                       NON-RESIDENTIAL
                                       APPLICATIONS  OF   LEAD-SAFE
                                       MiTIBATIDN
Many of the mitigation strategies and approaches incorporated into a lead-safe yard program can
be applied to non-residential properties as well. Properties such as tot lots, playgrounds, commu-
nity gardens, and vacant lots where children play may contain high levels of lead in their soil. Also,
while children should not be playing at abandoned industrial sites or commercial buildings, these
properties can be sources of increased exposure if children have access to areas of lead-contaminated
soil. Specific mitigation approaches  that have proven successful in reducing lead exposure risk at
residential properties can be just as effective when applied to certain non-residential properties.

At tot lots and playgrounds, for instance, raised sand boxes can be constructed. The bottoms  of
these boxes should be lined with perforated plastic, landscaping fabric, or even indoor-outdoor car-
peting to create a barrier between  the  lead-contaminated  soil and the clean sand in which the
children play. Clean sand should be tested to ensure that it does not contain lead levels of concern
(i.e., greater than 400 parts per  million). Similar raised boxes can be built around  playground
equipment and play areas and filled with sand, gravel, or mulch. Another alternative is to lay down
rubber matting in play areas, or even paving lots.  Planting  and maintaining healthy grass cover is
yet another option for play areas. Planting evergreen shrubs in areas with especially high lead levels
can also be effective in keeping children from playing in these areas.

Community gardens can also incorporate lead-safe yard principles to protect against lead exposure.
Raised garden boxes can be constructed, lined with perforated plastic or landscaping fabric, and
filled with clean loam and compost.  Loam should be tested to ensure that it does not contain lead
above the 400-ppm level.  Clean compost should be added yearly to replenish nutrients and help
control lead levels.

Vacant lots where children play can  be made lead-safe by covering exposed areas of soil. Planting
grass is one approach, but other materials such as woodchips,  mulch, or even gravel could be used.
To keep children from playing in areas with high levels of lead in the soil, plant evergreen bushes
and shrubs.

For abandoned industrial sites and commercial buildings, construct barriers (such as fences or walls)
to keep children out of these potentially dangerous areas.
                                                1  O  LEAD  IN SOIL: WHY is IT A  PROBLEM?   1 27

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Jk  D D F" W n I ^    A  OF  CAMBRIOBE»   MASSACHUSETTS
        ABOUT  THE  PROGRAM
        The Lead-Safe Cambridge (LSC) program works to make the homes of income-qualified people in
        Cambridge, Massachusetts, lead safe through interior and external lead hazard control. It began the
        Safer Soil Pilot Program in 1997 to build on this effort by making the yards of participants in its
        interior de-leading program lead safe as well.

        Alter soil sampling was initiated for the Safer Soil Pilot Program, LSC found that over 95 percent
        of the yards it investigated contained soil with lead levels above 400 parts per million. Currently,
        all homeowners participating in LSC are eligible for additional assistance under the Safer Soil Pilot
        Program. However, after September 2000,  participation in the Safer Soil Pilot Program will be
        required, in keeping with new federal regulations.

        Under the pilot program, soil samples are taken from select areas of a home and tested to determine
        their lead content. If elevated lead levels are found, a landscape planner works with the homeowner
        and/or tenants to develop an appropriate landscape remediation plan. The Safer Soil Program pro-
        vides  homeowners free soil sampling and grant support to reimburse them for  the  cost of
        implementing  LSC-recommended soil remediation and landscaping plans.  Specifically, the
        program offers:

            • Free soil testing.

            • Training on the dangers of lead exposure.

            • Free technical advice on preventing lead exposure.

            • Grant support of up to $2,000 per unit and $6,000 for three or more
             units toward the cost of approved materials  used to make the yard leadsafe.

        PARTNER ORGANIZATIONS
        LSC receives funding for its Safer Soil Pilot Program from the U.S. Department of Housing and
        Urban Development. LSC collaborates with a number of local non-profit housing groups, includ-
        ing Just-A-Start and Homeowner's Rehab, as well as with the U.S. Environmental Protection
        Agency and the Massachusetts Department of Environmental Protection.

        OUTREACH                 AND  STRATEGIES
        Cambridge is a diverse community. Its residents come from many different cultural backgrounds—
        English is not always their  primary language. Successful communication with homeowners and
        residents often requires close cooperation and coordination with their English-speaking relatives, as
        well as the help of multilingual LSC staff members.

        Homeowners and tenants are recruited to participate in the program through newspaper ads, Web
        announcements, property owner workshops (such as Cambridge Homefair), and word of mouth.

        As part of its soil education strategy, LSC distributes flyers  to educate homeowners about the soil-
        lead problem and inform them  about the program, disseminates fact  sheets via the Internet
                                                                                         APPENDIX A  1  29

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                   (hrtp://www-ci.Cambridge.ma.us/-LcadSafe), and presents lead-safety materials at public meetings
                   throughout Cambridge. In addition, LSC offers two annual Safer Soil workshops, free and open to
                   the public, at which people can learn why lead in soil is a  problem, find out how to landscape a
                   yard to make it safer, and get technical advice from a landscape planner. LSC also enlists the help
                   of local garden centers, which sponsor the workshops and offer coupons to workshop participants.

                   Son_  SAMPLING  AND ANALYSIS
                   After their units have been de-leaded  under the LSC program,  homeowners interested in partici-
                   pating in the Safer Soil Pilot Program sign an agreement with LSC to have their soil tested for lead.
                   LSC takes soil samples from different use areas in each yard—such as driplines, play areas, gardens,
                   walkways, and other bare areas—and sends them to a state laboratory in Jamaica Plain for analysis.

                   All samples are analyzed using the  atomic absorption  method  (microwave digestion followed by
                   flame atomic absorption spectroscopy). LSC relies on laboratory analysis, as opposed to onsite
                   analysis  using field portable x-ray fluorescence  technology, because of cost and liability issues. A
                   new XRF costs $15,000 or more (see Section 6.2); because  an XRF contains radioactive materials,
                   only a trained technician can use it. Getting sample results back from the laboratory takes about 7
                   to 10 days, but this has not been a problem.

                   Once LSC receives the sample results, it reviews them  and consolidates them in the form of hand-
                   drawn plot  diagrams. These are then presented to (and interpreted for) the homeowners and/or
                   tenants.  If the test results reveal  that soil on a property exceeds EPA-recommended levels for lead,
                   an LSC  landscape planner works with the homeowner and/or tenants to design attractive, usable
                   lead-safe urban yards, providing them with plans,  product  recommendations, and cost estimates.
                   The landscape planner works with homeowners in the  design and construction of these plans. LSC
                   believes that close cooperation with homeowners helps  to create a sense of ownership, community,
                   and most importantly, safety for children. In addition, this cooperation makes for longer-term com-
                   pliance and better maintenance.


                   The Safer Soils Pilot Program favors a combination of techniques for remediating lead-contami-
                   nated soil around a residence. These  include selectively  paving contaminated areas, using softer
                   paving materials  (such as gravel with brick edging), and incorporating  plants and shrubs in the
                   yard. The program often recommends placing plants and shrubs around  house driplines to reduce
                   access to these areas while making the yard more attractive.

                   The program also works to reduce  lead toxicity in the soil by rototilling organic  matter (such as
                   composted  cow manure)  and rock phosphate, which  bind with lead, into affected areas. Once
                   organic material has been introduced, the Safer Soil Pilot Program  recommends taking the addi-
                   tional step of putting down landscape fabric over the  contaminated area and covering the fabric
                   with 3 to 4  inches of bark mulch or pea gravel to create a natural barrier. Sodding is another effec-
                   tive option, although its drawbacks include its high cost relative to other treatments and the need
                   for routine watering in its early stages of establishment.

                   In areas  where lead levels  in the soil are found to be greater or  equal to  5,000 ppm, LSC follows
                   current EPA recommendations for remediating high-lead-content soil by covering the area with an
                   impermeable surface (such as concrete  or pavement) or, in  extreme  cases, removing the soil
                   altogether. However, the Safer Soil program generally tries to avoid complete soil removal, in large
                   part because of its cost and the difficulty of disposing of lead-contaminated soil.
1 3D  APPENDIX A

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Participants in the Safer Soil program are offered grants to help them pay for the materials they need
to remediate their properties. The standard grant is $2,000 per unit and up to $6,000 for three or
more de-leaded  units.  In order  to make  full use of an available grant, the  homeowner (or a
landscape contractor)  must implement the program's recommendations  for the property. Work
must be done according to the landscape planner's recommendations; soil must be kept damp in
order to prevent unnecessary lead  dust exposure. Homeowners can use landscape contractors to exe-
cute their Safer Soil landscape plans if they are unable to do the work themselves. If the homeowner
chooses to use a  landscape contractor, he or she takes the landscape plan and specifications devel-
oped by the landscape planner and obtains three estimates for the landscaping work. The landscape
planner approves the selected contractor, who then begins work. Homeowners save all receipts for
materials and labor and submit them to the landscape planner for reimbursement (up to the total
grant amount) after work has been completed.

The Safer Soil program also offers homeowners and tenants guidance on preliminary steps they can
take to mitigate children's exposure to lead-contaminated soil. These tips include:

    • Establishing a play area away from areas once exposed to old paint, such as the
     house or a  fence.

    • Covering leaded dirt with clean gravel or grass (preferably sod).

    • Buying or  creating a sandbox to cover leaded soil (making sure that the bottom
     is sealed away from the soil).

RESULTS
To date, 27 yards have been landscaped through the Safer Soil  Pilot Program, with 106 yards tested
for lead. Landscaping plans and specifications have been  developed for an additional 11 yards, and
will be implemented in the near future.

AWARDS AND  REGOBNITION
In 1999, LSC's Safer Soil Pilot Program was presented a National Merit Award from the American
Society of Landscape Architects for its innovative approach to addressing lead in residential soil.

FDR            INFORMATION
    Ann Stroobant
    Landscape Planner
    (617) 349-4652
    astroobant@ci.cambridge.ma.us
                                                                                         APPENDIX A 1 3 1

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                                     FDR  L.ESS-RESQURCE-INTENSIVE
                                     APPROACHES  TQ   IMPLEMENTINB
                                     LEAD-SAFE  YARD
To develop feasible working models that can be applied in other communities, the issues of cost-
effectiveness and homeowner participation need to be addressed. In the absence of a HUD-funded
municipal program, or for those homeowners or residents not eligible for grants or loans from such
a program, less costly approaches can be considered.  In Boston,  the EMPACT Lead-Safe Yard
Project is currently investigating the following possibilities, several of which could be drawn upon
in carrying out a lead-safe yard program at the local level:

    • Using a model based on the principles developed by Habitat  for Humanity, in which the
     work involved in achieving a lead-safe yard is carried out by the homeowner with the help
     of community volunteers (possibly other residents in the area who would then receive help
     with their yards). Habitat for Humanity is a non-profit organization that builds and
     rehabilitates low-cost homes through volunteer labor and donations of money and
     materials, with the help of homeowner  (partner) families.

    • Offering courses/workshops for homeowners and for landscapers through a local
     community  college or other adult education program. Such a course would include
     information on building and landscaping techniques and materials, as well  as
     maintenance required to achieve lead-safe yards. This could be part of a longer
     course on home maintenance or a course for new homeowners.

    • Training environmental science students at a local community college to carry out
     sampling of yards for lead contamination. Students would be trained in how to draw plot
     plans, how to take samples, and how to interpret and write up the results, as well as in
     health and safety issues surrounding the handling of lead-contaminated soil. This would
     substantially reduce sampling costs, while providing an educational experience for the
     students concerned.

    • Involving youth volunteers from a program such as City Year in carrying out the
     construction and landscaping work for lead-safe yards. City Year, a program of AmeriCorps
     (the domestic Peace Corps), engages young people aged 17 to 24 in youth development,
     human services, public health, and environmental programs.  Another option would be to
     contract with a training and construction program such as Youth Build. Youth Build is a
     youth and community development program that offers job training, education,
     counseling, and leadership development opportunities to  unemployed and out-of-school
     young adults, aged 16 to  24, through the construction and rehabilitation of affordable
     housing in their own communities.
                                                                              APPENDIX B  133

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APPENDIX    C
                                                                                    —•
                                                                                TO
         This handbook focuses on measures that can keep children safe by reducing their risk of exposure
         to lead. The fact is, though, that unless the lead is permanently removed, exposure can reoccur (for
         example, if landscaping measures are not maintained).

         The most frequently used method of removing the lead is to dig up the contaminated soil and haul
         it to a hazardous waste facility. This method is costly and requires intensive labor. However, some
         promising and innovative experiments explore how to minimize lead exposure by actually extract-
         ing  it from the soil. This angle  of research explores  how nature itself, through  a  process called
         phytoextraction, might hold a potent solution for removing lead and other hazardous metals  from
         contaminated soils.

         Phytoextraction involves using living green plants for removing contaminants, such as lead,  from
         soil and water. The term refers to the uptake of metal contaminants by the plant's roots and the sub-
         sequent transport of the contaminants to various parts of the plant. In general, plants do not absorb
         or accumulate lead.19 But certain plants, such as the sunflower and Indian mustard, absorb remark-
         ably large  amounts of metals compared to other plants and actually survive. After  the plants are
         allowed to grow on a contaminated site for a period of time with proper soil amendments to mobi-
         lize  the metal, they are harvested. After this, they are either disposed  of as a hazardous waste or
         incinerated (and  the metals recycled). The schematic below  illustrates phytoextraction  processes
         (adapted from http://aspp.or^/puWic_afiAirs/bnehn^/pliyroivmcdianon.lum).
                      Plants are
                     cultivated us
                    special agronomic
                      practices
                         1
                                       Solublllzed lead Is
                                     taken up by the roots and
                                     transported to the shoots
                                             3
Water evaporates
  while lead is
  concentrated
  In the plant
     4
              Rosen and Robert Munter. 1998. Lead in the Home Garden and Urban Soil Environment. University of Minnesota Extension
          Service. FO-2543-GO. i
                                                                                            APPENDIX  C  1 35

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                  Scientists have studied phytoremediation (the use of plants to recover contaminated soils and water)
                  extensively. It is slowly becoming an acceptable, and even preferred, technology. Numerous demon-
                  stration projects have shown the promise of phytoremediation. For example:

                      • In Trenton, New Jersey, the Gould National Battery site was home to commercial lead-acid
                        battery manufacturers from the 1930s to the 1980s. In those years, the land became heavily
                        contaminated with lead. Under the Brownfields Initiative, the U.S. Environmental
                        Protection Agency awarded Trenton a grant to restore the site. In 1995, Phytotech Inc.
                        (now Edenspace Systems Corporation) approached the city about using "green technology"
                        to clean up the site. Three crops of plants over a summer reduced lead levels on 75  percent
                        of the treated area to  below the New Jersey residential standard of 400 parts per million.
                        See http://www.edt'nspace.com/CaseStudies.htm.

                      • In Chernobyl, a team of scientists from  Rutgers University headed  by plant biologist Ilya
                        Raskin tested phytoextraction to  remove radioactive cesium and strontium from a
                        contaminated pond. Sunflowers were set floating on small polystyrene rafts so that their
                        roots dangled in the water. Despite the poisons, the plants thrived. So  far, Raskin has used
                        phytoextraction techniques in sites in New Jersey, Massachusetts, and Connecticut.

                  Only a handful of demonstration projects focused on removal of lead from residential soils. Here's
                  an example from the Boston metro area:

                      • The Boston Health Department sought a comprehensive strategy to remove lead from a
                        small Dorchester neighborhood that hosted a cluster of childhood lead poisoning cases.
                        Excavation and removal simply cost too much, so the department sought other methods.
                        They teamed with Edenspace Systems Corporation to explore phytoextraction using Indian
                        mustard plants on a 1,000-square-foot test site in the  neighborhood. They spread a soil
                        amendment that would loosen the lead so it dissolves in the moisture.  They planted Indian
                        mustard, which is well suited for  metal removal because it accumulates the metal in its
                        leaves rather than its  roots. After  six weeks, they harvested the plants and analyzed the soil.
                        Lead concentrations decreased 47 percent, and after a second growing, the overall lead
                        reduction was 63 percent (from 1,500 ppm to under 300 ppm). The harvested plants were
                        incinerated, and the metals in the ash were recycled. Based on the results of the
                        demonstration, Tom  Plante of the Boston Health Department feels this method is very
                        effective in reducing lead levels in soil and has the  potential for a wide array of applications
                        including brownfields—and now urban residences (if there is enough sunlight and
                        moisture). For more information  on  this demonstration project, visit the Boston Childhood
                        Lead Poisoning Prevention Program at http://www.tiac.ner/users/bdph/oeh/leadhome.htm.

                  Edenspace Systems Corporation  is continuing research on residential soil-lead remediation. One of
                  the challenges of lead remediation in residences is that the plantings can put an entire yard out of
                  use and out of sight for months or even years. Therefore, the company is researching the potential
                  of turf grasses to extract lead from the soil. Making the technology affordable, ensuring proper
                  sunlight and irrigation, bringing heavy machinery into residential neighborhoods,  and  reaching
                  lead that is too far for plant roots to reach might pose additional challenges. However, research will
                  continue to build on existing knowledge of phytoextraction and help address the potential challenges.
1 36  APPENDIX C

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For more information on phytoextraction and other forms of phytoremediation, see the following
online resources:

    Edenspace Systems Corporation
    Edenspace now owns or licenses an array of proprietary techniques used in removing lead,
    arsenic and other metals from the environment. The resources page provides many useful
    links to articles on phytoremediation.
    http://www.edenspace.com/newpage4.htm

    Phytoremediation: using plants to remove pollutants from the environment
    An overview of phytoremediation written by Rutgers University plant biologist Ilya Raskin.
    http://aspp.org/piiblic_arrairs/briefmg/phyto remediation, htm

    Rutgers University Center for Agriculture and Environmental Technology
    One of the pioneer research institutions for phytoremediation.
    http ://aesop. rutgcrs.edu/-' bio tech/brochure/index, html

    U.S. EPA Citizen's Guide to Phytoremediation
    http://www.cpa.gov/swortiol/prodLicts/citguidt7phyto2.htm
                                                                                          APPENDIX C  137

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APPENDIX   D
       Quality Assurance Project Plan for:
                     A COMMUNITY BASED ENVIRONMENTAL
                 LEAD ASSESSMENT AND REMEDIATION PROGRAM
       Prepared for:
          Lead Safe Yard Program
          USEPA New England Lab
          60 Westview Street
          Lexington, MA 02421
       Prepared by:
          Paul Carroll, Chemist
          Investigations and Analysis Unit, OEME
       Approved by:
          Robert Maxfield, Chief
          Investigations and Analysis Unit, OEME
       Approved by:
          Andy Beliveau, QA Officer
          Quality Assurance Unit, OEME
                                                                     APPENDIX D 1 39

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                 1  .a              AND APPLICATION
                This QAAP outlines procedures for the field analysis of lead in soil using the Niton 700 Series Field
                Portable X-Ray Fluorescence Spectrometer. These methods are designed as part of the sampling and
                analysis protocol for the Lead Safe Yard Program and are applicable to the measurement of lead in
                urban soils.
                                                 Project
                                              Management
                        R. Maxfield, EPA
P. Hynes, BU
                                          Outreach Coordinator
                                             T. Settles, DSNI
                                                            Quality Control
                                                             A. Beliveau, EPA
                                          Sampling and Analysis

                                      W. Straub and P. Carroll, EPA
                                             Site Remediation
                                             L. Pettrucci, DGP
                2.  PROJECT  ORGANIZATION  AND  RESPONSIBILITY
                The Project Managers  are in charge of coordinating, maintaining and monitoring all activities,
                including direction for preparation of work plans, sampling plans, and analytical procedures rela-
                tive to  the project. The Quality Assurance personnel will evaluate and approve  QA/QC plans
                through the course of the project and oversee all data quality assurance aspects of the project. The
                Outreach Coordinator will be responsible for locating potential properties for sampling and analy-
                sis, contacting property owners and gaining consent to work on the property. The sampling and
                analysis team will be responsible for scheduling and conducting data collection and data reduction
                procedures,  properly maintain  samples,  develop  site sketches and other observations, generate
1 4D APPENDIX D

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required QA/QC records and implement corrective actions. The site remediation group will apply
innovative and cost effective landscape techniques for site improvements.

3.                    DEFINITION
Lead poisoning continues to  be an extremely serious environmental health issue for youth, partic-
ularly in  poorer inner city neighborhoods with older wood framed housing. While considerable
attention has been focused on the lead contaminated paint prevalent on the surfaces of homes in
these neighborhoods, less attention has been paid to the lead contaminated soil that surrounds each
home. The reasons for this lack of attention by regulators stems from a variety of concerns: perhaps
foremost is the cost of soil removal and disposal.

4.  PROJECT  DESCRIPTION
The overall objective of the  proposed project is to produce a summary report documenting the
effectiveness of low  cost residential soil intervention. The project will incorporate two sampling
plans to accomplish this goal. One sampling strategy will be to measure surface soil lead at resi-
dential properties in the Greater  Boston area.  Properties  that exceed project specific action levels
will be mitigated with simple, low cost methods that are  designed to minimize the risk of human
exposure to the contaminated soil. Soil surfaces will then  be measured to evaluate the effectiveness
and durability of the intervention measures over time. A  second sampling strategy involves meas-
uring tracked-in soil Pb (house dust) to compare pre and  post intervention Pb levels inside the
residence. This Quality Assurance Project Plan outlines protocol for the residential soil surface sam-
pling program that will be used in this project.

4A.  PROJECT  TIMELINE

                  Activity                              Start        End
                   Review existing data                  11/99
                   Determine target community                     2/00

                   Community  Outreach                2/00       9/01

                   Site Investigations                    3/00       11/01
                   Meet with property owners

                   Site Remediation                     3/00       11/01
5.   BAMPLINB
The sampling strategy is designed to assess the potential of excessive lead exposure to humans from
soil on the property. Each  property will be  evaluated with focus  on four areas of concern: the
dripline along  the house foundation, play areas in the yard, areas of exposed soil in the yard,  and
any other potential sources of soil lead contamination including those from abutting properties.
Play areas found to contain greater than 400 parts per million (ppm), and other areas that are found
to contain greater than 2000 ppm lead will be further characterized to determine  the nature  and
extent of contamination (note Appendix 1, the Sampling Logic Tree). Two soil sampling strategies,
                                                                                     APPENDIX D   14-1

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                  in situ  and bag  sampling,  will be  used to determine lead content  in  these residential soils.
                  Descriptions of each along with QA/QC protocol follow.

                  In-Situ Sampling. Samples will be analyzed with a Niton Model 702 XRF Spectrum Analyzer. The
                  702 is  a  field portable multi-element,  multi-functional  x-ray  fluorescence analyzer (FPXRF)
                  equipped with a lOmCi cadmium-109 source and a high resolution Silicon-Pin detector. The hand
                  held, battery powered  FPXRF is capable of in-situ  analysis techniques. Based upon a minimum
                  detection limit study (MDL), the detection limit for this method is approximately 100 ppm. These
                  data are attached as Appendix 4. This instrument is factory calibrated, has been found to hold cal-
                  ibration quite well, and is software compensated for any deterioration of the source. In addition to
                  the MDL, precision and accuracy studies (1998 and 2000) are attached as Appendix 5.

                  Soil lead measurements will be taken  in-situ during the screening phase provided that the surface is
                  not inundated with water. Large nonrepresentative debris, including rocks, pebbles,  leaves and
                  roots, will be removed  from  the soil surface prior to sampling. The area will be smooth enough to
                  allow uniform contact between the FPXRF  and the ground surface. The initial sample locations
                  will depend upon the size and shape of the region of interest. A line pattern will be used when the
                  area is linear (e.g.  dripline).  In-situ measurements will be taken at approximate 10 foot intervals
                  along the line depending upon the length of the building. Additional lines are tested at 2 to 5 foot
                  sampling intervals away from the original sampling area to characterize the  extent of any lead con-
                  tamination. Target patterns will be used for sampling larger, nonlinear areas of potential exposure
                  (e.g. play areas). A large "X" will be  superimposed upon the space to be analyzed.  In- situ meas-
                  urements will be  taken at 5  to 10 foot intervals  along each line  of the "X" unless the samplers
                  determine that additional (or less)  resolution is required. Screening data and descriptive informa-
                  tion about each site will be recorded on the Site Worksheet (Appendix 2).

                  Quality control checks will consist of replicate measurements, standard reference material (SRM)
                  checks and  confirmation samples as  defined  in Section 10, Acceptance Criteria for Soil Lead  by
                  XRF. Replicate measurements will be conducted over a minimum of 10% of the screen samples to
                  indicate the precision of analysis and the homogeneity of the sample matrix. Three point SRM
                  measurements and a blank measurement will  be conducted at the beginning and end of each sam-
                  pling day to ensure linearity over the expected sampling range  (e.g.  400-5000  ppm)  and  to
                  determine that the instrument is operating contaminant free. SRMs (NIST 2586 @ 432 ppm lead
                  in soil)  will be used as continuing calibration checks after every 10th screen sample. A minimum
                  of one confirmation sample  will be collected from each site. Approximately 4 tablespoons of sur-
                  face soil, to  no more than the approximate depth of 0.5 inches, will be collected into a soil sample
                  container and  thoroughly mixed for each confirmation sample. The sample will be properly labeled
                  and returned to the laboratory for analysis by EPA Method 6010A.

                  Bag Sampling. If site conditions are such that in-situ sampling is not  appropriate and sampling
                  activities must continue, this bag sampling method will be used to evaluate soil lead conditions on
                  the residential properties. The sampling strategy will be a scaled down version of the in-situ strat-
                  egy. The focus will still be on the dripline of the building on the property, play areas, bare soil and
                  other concerns such as sources from abutting properties. The bag approach involves collecting soil
                  samples into a sampling container and returning them to the laboratory for preparation, XRF
                  analysis and ICP confirmation.

                  Typically,  a minimum  of 4 discreet soil samples will be collected from each side of the building
                  perimeter within 1 to 3 feet of the foundation (dripline). These samples will be collected at the very
                  minimum of 2 feet from each other. Bare soil areas are the preference (vs. covered areas).
1 42  APPENDIX D

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Composite samples from play areas will consist of aliquots collected along an X shaped grid. These
subsamples will be collected at a minimum of 1 foot from each other. Bare soil areas are preferred.
This method will also apply to bare areas of soil, vegetable gardens and high use areas noted on the
subject property.

The decision to sample along the property boundary will be determined by the samplers at the time
of the site visit. If conditions  exist on an abutting property that would appear to present a risk of
soil lead contamination to the subject property, the following protocol will be followed. Aliquots of
surface soil will be collected along the property line(s) of interest. These subsamples will be collected
no closer than 1  foot apart and will  be located within 1 to 5 of the property line. Subsamples will
only be collected  on the subject property.

Quality control for the composite method measurements will be identical to QA/QC for the in situ
method. Three point SRM measurements and a blank measurement will be conducted at the begin-
ning and  end of each sampling day to ensure linearity  over the expected sampling  range (e.g.
400-5000 ppm).  SRMs will be used as continuing calibration checks after every 10th screen sam-
ple. A minimum of one confirmation sample will be collected from each site.

All bag samples will be collected according to protocol outlined in Section 7 (Sample Handling and
Chain of Custody Requirements). The samples will be returned to the EPA laboratory where they will
be dried, screened to remove nonrepresentative debris, and analyzed using XRF technology. Select
samples will be designated for confirmation  analysis  by Inductively  Coupled Plasma  Optical
Emission Spectroscopy (ICP).

Confirmation Samples. Confirmation samples are collected during sampling  activities to  be ana-
lyzed  at the University of Cincinnati, Hematology and Environmental  Laboratory  by  Atomic
Absorption  Spectrometry. These  samples are collected  in selected  intervals around the house
perimeter (designated HC for house composite), any play areas (PC), from any on-site vegatable
gardens (GC)  and from any high use areas (HUC).

Typically,  12 subsamples are collected for each perimeter composite sample (3 from each side of the
house). If possible, 5 subsamples are collected for  each  play area composite, garden composite
and/or each high use area composite using the target pattern approach. The samples are returned
to the EPA laboratory, sieved with a number 10 sieve (U.S.A. Standard Sieve Series) to removed any
coarse debris,  rebagged and analyzed for lead content using the Niton XRF. Each sample is then
labeled (street  number and name and composite designation), recorded on a chain of custody form
and sent to the U. of C. Lab for the extraction and AA analysis for lead content.

6.
     ANALYTICAL,
    Parameter    Matrix   # of Samples    Analytical    Containers    Preservation Hold Time

    Lead (XRF)     Soil        TBD       EPA 6200       N/A          N/A        N/A
       insitu

    Lead (XRF)     Soil        TBD          —          ziplock        4°C       1 year
   confirmation                                           bags

    Lead (ICP)      Soil        TBD       EPA 6010A      ziplock        4°C       1 year
   confirmation                                           bags
                                                                                       APPENDIX  D  1 4-3

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                  "7.  SAMPLE  HANDLINB  AND
                       CHAIN  OF  CUSTODT
                  The majority of the soil lead measurements will be taken in situ during the site characterization
                  phase. Sample handling and chain of custody requirements will not apply to these procedures. Soil
                  will be collected as confirmation samples and as discreet bag samples. Chain-of-custody (COC)
                  procedures will be followed for these samples to  maintain and document possession from the time
                  they are collected  until they are delivered to the laboratory for analysis. A sample COC form is
                  attached. The sample handling and COC predator will include:

                     — sample information on the jar/bag with sample ID, time and date of collection and
                        technician ID, all written in unerasable ink.

                     —a sample seal attached firmly to the sample cover as soon as possible after collection when
                        using sample jars.

                     —a chain of custody record containing  the project name and number, the sampling station
                        ID, date and time of collection, a brief description of the type of sample collected,
                        parameters for analysis, the samplers  name and signature, adequate space for any
                        transferee's name and signature and a comment section to describe any special conditions
                        associated with the samples.

                  All sample sets will be accompanied by a COC  document. Any time the samples are transferred,
                  both the sample custodian  and the receiver  shall sign and date the COC document. COC docu-
                  mentation will be maintained in the project folder.

                  B.  QUALITY  CONTROL

                                                                                             Accuracy****

                                                                                                 ±25
                                                                                                 ±10

                                                                                                 ±20
                  **Typically 3 times the MDL
                  ***Precision determined by replicate sample analyses
                  ****Accuracy determined by analysis of SRMs
                  9.  DATA  MANABEMENT  AND  DOCUMENTATION
                  A field log book, dedicated to the project, and field data sheets will be maintained during sampling
                  events. There will be separate field sheets for the screening and additional site characterization
                  phases. Each sheet will include the date, time, property name and address, sample locations, a site
                  sketch that includes sampling locations, sample description, important details about how the sam-
                  ple was collected, analyst(s) names, along with the respective measurement data, and any additional
                  comments that would accurately and inclusively describe the sampling activities. Care will be taken
                  to maintain the logbook and field data sheets neatly with factual, objective language that is  free of
                  personal feelings and other terminology that may be deemed inappropriate.
Analyte
Lead
Lead
Lead
Analytical
Method
EPA 6200
EPA6010A
Kevex XRF
Detection
Limit*
- 75 ppm
42ppb
50 ppm
Quantitation
Limit**
-225
-120
-150
Precision'
±50
±20
±20
1  44  APPENDIX  D

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These field data sheets, along with confirmation sample data received from the laboratory will
be kept on file at the EPA Region 1 Lab. The confirmation information will include results of
sample analyses, method blanks, matrix spike/spike duplicates and acceptance criteria. Copies
of the field data sheets and  validation information from the confirmation samples will be dis-
tributed to members of the remediation team to help determine where remediation activity will
take place.

 1  Q.  ASSESSMENT AND   RESPONSE  ACTIONS
        ACCEPTANCE CRITERIA FOR SOIL LEAD BY XRF(IN-SIT[f)
  Audit

  Initial
  Calibration
  (SRM) @ 50,
  500, 5000 ppm

  Continuing
  Calibration
Frequency

Run prior to daily
sampling events
Sample data must
be bracketed every
10th sample (or
less) using SRM
Limits         Corrective Action

%RSD=30      Investigate problem and
               re-run initial calibration
               until an acceptable
               calibration is obtained

%D <±25%    Re-analyze CC and if passes
               continue sample analysis. If
               fails investigate problem and
               re-analyze all samples following
               the last acceptable CC starting
               with a new initial calibration.
  Field Blank
  Replicate
  Analysis
  (Accuracy)

  Confirmation
  Samples
Varies by site
Varies by site
Site Dependent,
minimum I/site
<100 ppm


%D <±50%



Variable
Corrective action determined
by end user.
Intrusive sample for
conformation and/or
confirmation analysis
  MDL
  IDC
When there is
a change in the
method or
instrument.

When there is a
change in sampling
method or
instrument
Instrument
Specific
± 30%
recovery*
Action taken at data validation
level.
Investigate problem
and correct. Re-run.
                                                                                  APPENDIX  D  1 4B

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                  APPENDICES

                     Appendix 1	Sampling Logic Tree

                     Appendix 2	Site Worksheet

                     Appendix 3	IDC Study

                     Appendix 4	MDL Studies

                     Appendix 5	Accuracy Studies

                     Appendix 6	Results of Confirmation Samples

                     Attached	Sample Chain of Custody Form

                  APPENDIX   1

                                                Sampling Logic Tree
                                                    In-Situ Sampling

/' A
Lead Levels < Action Level
\ V
Lead Levels at Action
Level +/- 10%
Lead Levels > Action Level
                          Complete QA/QCX
                           Measurements
                          No Further Action  }*— NO-
     Replicate X,
     colocated
    x analyses /
Lead Levels at Action   / \
       Level
      +/-10%
^ /Complete QA/QC
 x. Measurements
   /' Consider Site for
       Remediation

                                                     Replicate Analyses
                                                      Fail QC Criteria
                                                                                 /
                                                                               Yes
                                                   Composite Samples for
                                                  ^Confirmation Analysis,
                                                /  Lead Levels at Action
                                                          Level
                                                \	+/-10%
1 46  APPENDIX  D

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APPENDIX 2:  SITE
Site Name:,




Address: 	
                                   Date:
Building Type:.




Condition: 	




Lot Condition:




Yard Uses: 	
   Sample ID
Location
PPM-Lead
Comments
Distance
                                                                   APPENDIX D 1 47

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              APPENDIX 3



                 INITIAL DEMONSTRATION

                 OF CAPABILITY FOR LEAD

                   IN SOIL BY NITON XRF

                                  ppm—lead
IDC1
IDC2
IDC3
IDC4
IDC5
IDC6
IDC7
IDC8
IDC9
IDC10
IDC11
1123
1144
1127
1225
1076
1036
1095
1235
1208
1228
1140
                     True Value         1162





                      Average
                    r               1148.8
                    Concentration



                    % True Value        98.9



                  Standard Deviation      67.2



                      %RSD          5.9





              Criteria: %RSD<30%


                      %TV<±30%
1 4B  APPENDIX  D

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APPENDIX  4
              MINIMUM DETECTION LIMIT STUDY
             OF LEAD IN SOIL BY FIELD PORTABLE XRF


MDLl
MDL2
MDL3
MDL4
MDL5
MDL6
MDL7
MDL8
MDL9
MDL10
"Rue Value
Avg. Cone.
% True Value
Standard Deviation
MDL
%RSD
H.P. 600703
5/12/98
PPM-Lead
190
151
170
177
188
196
170
138
138
128
129
164.6
127.6
24.3
68.7
14.8
H.P. 600703
2/29/00
PPM-Lead
170
209
179
161
220
164
137



129
177.1
137.3
28.7
90.3
16.2
LCS 0996
2/29/00
PPM-Lead
235
246
303
242
320
254
250



224
264.3
118.0
33.2
104.3
12.6
NIST 2586
2/29/00
PPM-Lead
365
357
398
355
423
392
422



432
387.4
89.7
29.1
91.4
7.5
Criteria:  %RSD<30%
       %TV<±30%
                                                           APPENDIX D  1 49

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              APPENDIX 5
                       ACCURACY DATA (1998) FOR LEAD IN SOIL BY FPXRF





                                NIST2710  NIST2711   LCS 0996   HP 69073    Cleve-1
5427
5632
5651
5587
5657
5372
5516
5769




True Value 5532
Average Concentration 5576.4
% Recovered 100.8
Standard Deviation 122.5
RSD 2.2
1123
1144
1127
1225
1076
1036
1095
1235
1208
1228
1140

1162
1148.8
98.9
64.1
5.6
268
283
269
280
291
202
383
343




224
289.9
129.4
50.3
17.4
204
190
151
170
177
188
196
170
138
138
128
203
129
171.1
132.6
25.6
15.0
426
554
526
440
488
490
456
494
456
441


433
477.1
110.2
38.8
8.1
1 5D APPENDIX D

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APPENDIX 5
                 CDNT.
          ACCURACY DATA (2000) FOR LEAD IN SOIL BY FPXRF
             NIST2710  NIST2711   NIST 2586   LCS 0996  HP 690703  Lot 217
5580
5780
5590
5970
5490
5610
5530
5780
5460
5750
1070
1140
1190
1290
1110
1070
1160
1170
1090
1140
365
357
398
355
423
392
422
397
388
408
235
246
303
242
320
254
250
275
391
277
170
209
179
161
220
164
137
242
232
146
241
220
230
159
144
135
211
175
173
126
  True Value
5532
1162
432
224
129
101
Average
Concentration
% Recovered
Standard
Deviation
RSD
5654.0
102.2
152.4
2.7
1143.0
98.4
62.8
5.5
390.5
90.4
23.4
6.0
279.3
124.7
45.5
16.3
186.0
144.2
35.1
18.9
181.4
179.6
39.4
21.7
                                                                   APPENDIX D 151

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                  APPENDIX  6   CONFIRMATION  SAMPLE  RESULTS
                        10000
                         8000
                         6000
                         4000
                         2000
                                 >
                                                    Niton v. ICP
                                                     as of 8/19/99
                                                                   R-squared = 0.926
                                                                   y intercept = 168.4
2000       4000        6000

           ICP (ppm - Lead)
8000
                                                                                     10000
1  52  APPENDIX D

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