\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* WASHINGTON, B.C. 20460
August 22, 2003 OSWER 9285.7-50A
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: Superfund Lead-Contaminated Residential Sites Handbook
FROM: Michael B. Cook, Director /s/ Elizabeth Southerland for
Office of Superfund Remediation and Technology Innovation
TO: Superfund National Program Managers, Regions 1-10
Purpose:
I am pleased to transmit the attached Superfund Lead-Contaminated Residential
Sites Handbook (subsequently referred to as the Handbook). The Handbook has been prepared
to assist Superfund project managers working on the characterization and cleanup of lead-
contaminated residential sites. Resource Conservation and Recovery Act (RCRA) project
managers and others may also find it useful. It is intended to promote national consistency in the
characterization and cleanup of lead-contaminated residential sites, while retaining the flexibility
needed to respond to different sites and communities to ensure the success of the remedy and
provide long-term protection of human health. The Handbook incorporates lessons learned from
EPA's experience in remediating residential lead sites, as well as current technical and scientific
literature addressing lead-contaminated residential sites.
The Handbook is not intended to apply to lead-contaminated commercial or industrial
properties, other non-residential areas, or sites with ecological risks, although some of the
concepts may be useful for such properties. The Handbook does not, outside the federal
facilities universe, apply to lead-contaminated residential sites addressed under Title X
procedures. A separate section of the Handbook is devoted to lead-contaminated properties at
federal facilities.
-------
BACKGROUND:
The draft handbook was developed primarily by the Lead Sites Workgroup
(LSW), consisting of members from U.S. Environmental Protection Agency (EPA)
Regional and Headquarters offices. This handbook has undergone previous reviews
and has been revised to incorporate the comments from various EPA Regional and
Headquarters offices, the Agency for Toxic Substances and Disease Registry (ATSDR)
and more than 20 State agencies.
-------
The LSW was established to develop guidance and position papers that clarify national
policy, or address issues lacking clear policy regarding response to lead contamination at
Superfund sites. The LSW is made up of representatives from Office of Site Remediation and
Technology Innovation (OSRTI) and Federal Facilities Restoration and Reuse Office (FFRRO),
Regional Remedial Project Managers (RPMs), RCRA project managers and a representative
from the Agency for Toxic Substances and Disease Registry (ATSDR).
Consistent with the OSWER Clarification Memorandum (OSWER Directive # 9200.4-
27P), residential properties are defined in the Handbook as any area with high accessibility to
sensitive populations, and includes properties containing single- and multi-family dwellings,
apartment complexes, vacant lots in residential areas, schools, day-care centers, community
centers, playgrounds, parks, greenways, and any other areas where children may be exposed to
site-related contaminated media. The Handbook defines sensitive populations as young children
(those under 7 years of age, who are most vulnerable to lead poisoning) and pregnant women.
Throughout the development of the Handbook, the goal was to produce a complete
reference that new and experienced project managers will find useful, while also keeping it to a
manageable size. This has been accomplished by including the minimum considerations for
addressing lead-contaminated residential sites in the Handbook and referring to appropriate
agency guidance and/or policy where necessary. The Handbook addresses all aspects of the
remediation process, from initial research on the nature and extent of site contamination, through
cleanup level selection and the prevention of recontamination. Separate sections of the
Handbook are devoted to community involvement and health education. To supplement the text,
the Handbook includes flowcharts that provide a general overview (Figure 1-1) and a detailed
'roadmap' (Figure 5-1) of the cleanup process. Examples of property access forms, inspection
checklists, closeout forms and 'clean letters' are provided in the Appendices for the convenience
of the user.
Conclusions:
This handbook is intended to provide a comprehensive reference that new and
experienced project managers will find useful in the characterization and cleanup of lead-
contaminated residential sites. The handbook lays out only the minimum considerations for
addressing lead-contaminated residential sites and the project manager is encouraged to use site-
specific considerations in making final decisions. The LSW is available for brief training
sessions and consultation on the use of the Handbook. Please contact your regional
representative of the LSW for assistance (see page iii of the Handbook). If you have other
questions, please e-mail or call Shahid Mahmud at Mahmud.Shahid@epa.gov or (703) 603-
8789.
Attachments
cc: Steve Luftig,, Senior Advisor to OSWER Assistant Administrator
Jim Woolford, FFRRO
-------
Debbie Dietrich, OEPPR
Robert Springer, OSW
Cliff Rothenstein, OUST
Linda Garczynski, OBCR
Elliott Gilberg, FFEO
Susan Bromm, OSRE
Charles Openchowski, OGC
Walt Kovalick, TIP/OSRTI
OSRTI Center Directors and Senior Process Managers
Nancy Riveland, Superfund Lead Region Coordinator, USEPA Region 9
Jeff Josephson
NARPM Co-Chairs
Joanna Gibson, OSRTI Documents Coordinator
-------
The attached Superfund Lead-Contaminated Residential Sites Handbook
(subsequently referred to as the Handbook) was prepared to assist
Superfund project managers working on the characterization and cleanup
of lead-contaminated residential sites. Resource Conservation and
Recovery Act (RCRA) project managers and others may also find it
useful.
It is intended to promote national consistency in the characterization
and cleanup of lead-contaminated residential sites, while retaining the
flexibility needed to respond to different sites and communities to
ensure the success of the remedy and provide long-term protection of
human health. The Handbook incorporates lessons learned from EPA's
experience in remediating residential lead sites, as well as current
technical and scientific literature.
-------
-------
United States Office of Emergency OSWER 9285.7-50 PB2004-100017
Environmental Protection and Remedial Response August 2003
Agency
Superfund
Lead-Contaminated
Residential Sites Handbook
Final: August 2003
Prepared by the
Environmental Protection Agency
Lead Sites Workgroup (LSW)
NOTICE
This document has been reviewed in accordance with U.S.
EPA policy and is approved for publication. Mention of trade
names or commercial products does not constitute
endorsement or recommendation.
-------
DISCLAIMER
This document provides guidance to EPA Regions concerning how the Agency intends to
exercise its discretion in implementing one aspect of the CERCLA remedy selection process.
The guidance is designed to implement national policy on these issues.
Some of the statutory provisions described in this document contain legally binding
requirements. However, this document does not substitute for those provisions or regulations,
nor is it a regulation itself. Thus, it cannot impose legally-binding requirements on EPA, states,
or the regulated community, and may not apply to a particular situation based upon the
circumstances. Any decisions regarding a particular remedy selection will be made based on the
statute and regulations, and EPA decision makers retain the discretion to adopt approaches on a
case-by-case basis that differ from this guidance where appropriate.
Interested parties are free to raise questions and objections about the substance of this guidance
and the appropriateness of the application of this guidance to a particular situation, and the
Agency welcomes public input on this document at any time. EPA may change this guidance in
the future.
-------
Ill
CONTRIBUTING MEMBERS of
Lead Sites Workgroup of
U.S. Environmental Protection Agency
Shahid Mahmud, Co-Chair
U.S. EPA HQ
Bus: (703) 603-8789
E-mail: mahmud.shahid@epa.gov
Brad Bradley, Co-Chair
U.S. EPA Region 5
Bus: (312)886-4742
E-mail: bradley.brad@epa.gov
Monica McEaddy
U.S. EPA HQ
Bus: (202) 603-0044
E-mail: mceaddy.monica@epa.gov
Ron Morony
U.S. EPA HQ
Bus: (202) 260-0282
E-mail: morony.ronald@epa.gov
Byron Mah
U.S. EPA Region 1
Bus: (617) 918-1249
E-mail: mah.byron@epa.gov
Mark Maddaloni
U.S. EPA Region 2
Bus: (212) 637-3765
E-mail: maddaloni.mark@epa.gov
Khai Dao
U.S. EPA Region 3
Bus: (215)814-5467
E-mail: dao.khai@epa.gov
Charlie Root
U.S. EPA Region 3
Bus: (215)814-3193
E-mail: root.charlie@epa.gov
Beth Walden
U.S. EPA Region 4
Bus: (404)562-8814
E-mail: walden.beth@epa.gov
Rafael Casanova
U.S. EPA Region 6
Bus: (214) 665-7437
E-mail: casanova.rafael@epa.gov
Mark Doolan
U.S. EPA Region 7
Bus: (913)551-7169
E-mail: doolan.mark@epa.gov
Sara Sparks
U.S. EPA Region 8
Bus: (406) 782-7415
E-mail: sparks.sara@epa.gov
Shea Jones
U.S. EPA Region 9
Bus: (415)972-3148
E-mail: jones.shea@epa.gov
Sean Sheldrake
U.S. EPA Region 10
Bus: (206) 553-1220
E-mail: sheldrake.sean@epa.gov
Steve Jones
ATSDR
Bus: (703) 603-8729
E-mail: jones.steve@epa.gov
-------
IV
CONTENTS
DISCLAIMER ii
CONTRIBUTING MEMBERS of Lead Sites Workgroup of U.S. Environmental Protection Agency . . iii
CONTENTS iv
LIST OF TABLES AND FIGURES vi
ACRONYMS vii
1.0 INTRODUCTION 1
1.1 BACKGROUND 4
1.2 GENERAL DISCUSSION ON CERCLA's APPLICABILITY TO LEAD SITES 4
1.2.1 Background 4
1.2.2 Response Authorities 5
1.2.3 Applicable or Relevant and Appropriate Requirements (ARARs) 6
1.3 DEFINITION AND PURPOSE 7
2.0 COMMUNITY INVOLVEMENT 9
2.1 EDUCATION ACTIVITIES 9
2.2 COMMUNITY ADVISORY GROUPS 10
2.3 EPA's TECHNICAL ASSISTANCE GRANT PROGRAM 11
2.4 INFORMATIONAL MEETINGS 12
2.5 COMMUNITY INVOLVEMENT SPECIALIST/COORDINATOR 13
3.0 HEALTH EDUCATION 14
3.1 APPROPRIATE USES FOR HEALTH EDUCATION 14
3.2 PLANNING FOR HEALTH EDUCATION 14
3.3 EVALUATION OF HEALTH EDUCATION ACTIVITIES 15
3.4 AGENCY FOR Toxic SUBSTANCES AND DISEASE REGISTRY (ATSDR) INVOLVEMENT 15
3.5 OUTREACH 16
4.0 SITE CHARACTERIZATION 17
4.1 CONTAMINANT ZONE DELINEATION 17
4.2 RESIDENTIAL PROPERTIES 19
4.2.1 Sampling Access 19
4.2.2 Residential Yards 21
4.2.3 Drip Zones 23
4.2.4 Play Areas, Gardens, and Driveways 24
4.2.5 Potable Water, Lead-Based Paint and Interior Dust 24
4.2.6 Backfill and Waste Soil 24
4.3 SAMPLING METHOD AND ANALYSIS 25
4.3.1 Sample Collection 25
4.3.2 Sample Depth 25
4.3.3 Sample Preparation 27
4.3.4 Sample Analysis 27
5.0 CLEAN-UP LEVEL SELECTION 29
5.1 PRIORITIZING RESPONSE ACTIONS 29
5.2 LONG-TERM REMEDIAL ACTION 35
6.0 APPLICATION OF CLEAN-UP NUMBERS/REMEDIATION 37
6.1 MINIMUM EXCAVATION DEPTH/SOIL COVER THICKNESS 37
6.2 SOIL CLEAN-UP OPTIONS 38
6.3 INTERPRETING SAMPLING RESULTS 39
6.4 OTHER CLEANUP CONSIDERATIONS 44
6.4.1 Background Lead Concentrations 45
-------
6.5 YARD CLEANUP SPECIFICS 46
6.6 CLEANUP OF OTHER SOURCES OF LEAD 49
6.6.1 Lead-Based Paint 50
6.6.2 Interior Dust 50
6.6.3 Lead Plumbing/Tap Water 52
6.7 PREVENTION OF RECONTAMINATION 53
6.7.1 Early Actions 56
6.7.2 Long-term Remedial Action 57
6.7.3 Institutional Controls (ICs) 58
6.8 CLEAN-UP DOCUMENTATION 61
6.9 ENFORCEMENT 62
7.0 FIVE-YEAR REVIEW 64
8.0 FEDERAL FACILITIES 66
REFERENCES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
APPENDIX G
APPENDIX H
70
Title X and EPA's Toxic Substances Control Act (TSCA) Title IV Lead
Program A-l
1998 OSWER Directive 9200.4-27P ('Clarification') B-l
Contacts and Software for Sampling Design C-l
Examples of Property Access Agreement Forms D-l
Example of Dust Abatement Access Form E-l
Example of Property Inspection Checklist F-l
Examples of Property Closeout Forms G-l
Examples of Clean Letters H-l
-------
VI
LIST OF TABLES AND FIGURES
Table 4-1.
Rationale for Sampling Residential Properties 20
Figure 1-1. An Overview to the Clean-up Process 3
Figure 4-la. Recommended minimum soil sampling in yards less than or equal to 5,000 square feet with
small side yard 21
Figure 4-lb. Recommended minimum soil sampling in yards less than or equal to 5,000 square feet with
substantial side yard 22
Figure 4-2. Recommended minimum soil sampling in yards greater than 5,000 square feet 23
Figure 5-1. Recommended clean-up process for lead-contaminated residential sites 30
Figure 6-1. Interpreting Sampling Results 40
Figure 6-2a. Partial cleanup of residential lot less than or equal to 5,000 square feet in size 42
Figure 6-2b. Partial cleanup of residential lot greater than 5,000 square feet in size 43
Figure 6-3. Implementing Best Management Practices (BMPs) during construction work 55
-------
Vll
ACRONYMS
ARARs Applicable or Relevant and
Appropriate Requirements
ASTM American Society for Testing
and Materials
ASTSWMO Association of State and
Territorial Solid Waste
Management Officials
ATSDR Agency for Toxic Substances
and Disease Registry
BMPs Best Management Practices
BRAC Base Realignment and Closure
CAGs Community Advisory Groups
CERCLA Comprehensive Environmental
Response, Compensation, and
Liability Act
CIC/CIS Community Involvement
Coordinator/ Specialist
DOD Department of Defense
FOSL Finding of Suitability to Lease
POST' Finding of Suitability to
Transfer
FP-XRF Field-Portable X-Ray
Fluorescence
HUD Department of Housing and
Urban Development
1C Institutional Control
LBP Lead-Based Paint
IEUBK Integrated Exposure Uptake
Biokinetic Model for Lead in
Children
LSCG
MCL
NCP
NLLAP
NTCRA
OSWER
PRO
PRP
RCRA
SEP
TAG
TCLP
TCRA
TITLE X
TRW
TSCA
UAO
Lead Sites Consultation Group
Maximum Contaminant Level
National Contingency Plan
National Lead Laboratory
Accreditation Program
Non-Time-Critical Removal
Action
EPA Office of Solid Waste and
Emergency Response
Preliminary Remediation Goal
Potentially Responsible Party
Resource Conservation and
Recovery Act
Supplemental Environmental
Project
Technical Assistance Grant
Toxicity Characteristic
Leaching Procedure
Time-Critical Removal Action
Title X of the Housing and
Community Development Act
of 1992, 42U.S.C. 4822
EPA Technical Review
Workgroup
Toxic Substances Control Act
Unilateral Administrative Order
-------
-------
1.0 INTRODUCTION
This Superfund Lead-Contaminated Residential Sites Handbook (subsequently called the
Handbook) has been developed by the U.S. Environmental Protection Agency (EPA) to promote a
nationally consistent decision-making process for assessing and managing risks associated with lead-
contaminated residential sites across the country.
The primary audience for this risk management document is Superfund project managers working
on the characterization and cleanup of lead-contaminated residential sites; however, Resource
Conservation and Recovery Act (RCRA) project managers may also find it useful. This information was
developed primarily for EPA staff, but may prove useful to others working on lead-contaminated
residential sites, including states, other federal agencies, tribes, local governments, public interest groups,
and private industry. While this Handbook is not intended to apply to lead-contaminated commercial or
industrial properties, other non-residential areas, or sites with ecological risks, some of the concepts may
be useful for such properties. Addressing lead-contaminated properties at federal facilities requires a
different approach, and this Handbook provides a special section (Section 8) on addressing this universe
of sites.
Generally, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
response actions are undertaken to address a release or threat of release of a hazardous substance such as
lead into the environment. Lead contamination found inside homes may be caused by deteriorating lead-
based paint (LBP), plumbing, or other sources not resulting from a release into the environment, and
therefore may be more appropriately addressed by authorities and programs other than CERCLA (see
Appendix A and Section 6.6 of this Handbook). However, it may be appropriate to use CERCLA
authorities to conduct sampling and site characterization activities to determine the source of the lead
contamination and to differentiate between various site-related sources.
The Handbook lays out only the minimum considerations for addressing lead-contaminated
residential sites and encourages users to refer to appropriate agency guidance and/or policy to conduct
more stringent investigation and clean-up activities on a site-specific basis, if necessary. In addition, the
site manager should determine the applicable and relevant or appropriate requirements (ARARs),
including state laws and regulations, that apply to the site. It should also be noted that this Handbook
does not, outside the federal facilities universe, apply to lead-contaminated residential sites addressed
under Title X (HUD, 1992) procedures.
Lead site characterization and clean-up procedures are unique owing to the ubiquitous nature of
lead exposures and the reliance on blood lead concentrations to describe lead exposure and toxicity. Lead
-------
risks are characterized by predicting blood lead levels with computer models and guidance developed by
EPA, which are available on the internet: http://www.epa.gov/superfund/programs/lead/products.htm.
Major improvements in the removal of lead from gasoline, paint, and food packaging have significantly
reduced the incidence of severe lead poisoning. The results of this progress mean that most
environmental sources of lead exposure are more likely to cause subtle adverse health effects, primarily
behavioral and learning impairments.
An overview to the clean-up process is provided as Figure 1-1. Section numbers are provided in
the figure to help the reader locate information within this document.
-------
Figure 1-1. An Overview to the Clean-up Process
Start
Sampling Goals
•determine extent of contamination -
interior/exterior
•risk assessment model inputs
•prioritize response actions
(Section 4.0)
Research site
history/nature of
contamination
(Section 4.1)
Delineate zone(s) of
contamination
(Sections 4.1,4.3.2)
Prioritize response
actions
(Section 5.1)
Cleanup residential properties:
TCRA, NTCRA, Remedial
(Sections 5.0,6.0)
Community Involvement
(Section 2.0)
Goals:
•engage/involve stakeholders
•buy-in by stakeholders
•reduce blood lead in children
5 year review
(if required)
(Section 7.0)
(S
CAGS/TAGS
ections2.2, 2.3)
health education
(Sections 2. 1,3.0)
'
blood lead study /survey in children
(Sections 2. 1,3.4, 7.0)
-------
1.1 BACKGROUND
Elevated blood lead concentrations in young children in the United States are still prevalent in
many areas. Major sources of lead contamination historically included mining and milling sites, primary
and secondary smelters, battery manufacturing and recycling facilities, pesticide formulators, pesticide
use in orchards, and paint manufacturers (prior to 1978). Many of the source facilities are located near
residential areas or have had residential areas develop around them. Fugitive emissions from the facilities
have resulted in soil contamination in the yards of residences, which in turn can cause high blood lead
levels in children.
Although numerous sites of this type exist, EPA has remediated, or overseen the remediation of,
many of these sites and surrounding residences. Many different clean-up methods have been
implemented with varying degrees of success. This document is based on the lessons learned from EPA's
experience in remediating residential lead sites. It is intended to promote consistency in the
characterization and cleanup of lead-contaminated residential sites, while retaining the flexibility needed
to respond to different sites and communities to ensure success of the remedy and provide long-term
protection of human health. The document also provides guidance on addressing lead sources and media
that the Superfund does not usually remediate, such as LBP and lead plumbing. It is anticipated that this
information will be periodically updated as we strive to improve our ability to respond to environmental
lead hazards.
1.2 GENERAL DISCUSSION ON CERCLA' s APPLICABILITY TO LEAD SITES
This section provides a general discussion of the sections of CERCLA that address lead-contam-
inated sites. A description of Title X and EPA's Toxic Substances Control Act (TSCA) IV Lead Program
is provided in Appendix A. The Title X discussion is provided for informational purposes and is
primarily applicable to federal facilities. Section 4.2.5 also provides useful information for LBP and dust
sampling.
1.2.1 Background
Historically, the CERCLA has been used as a tool to implement clean-up activities at a large
number of sites across the country. CERCLA authorities have been used for cleanups ranging from the
removal of drums of hazardous substances from long-abandoned sites, to major privately funded remedial
actions at sites on the National Priorities List (NPL).
-------
CERCLA may apply any time there is a release or threatened release of: (1) a hazardous substance
into the environment, or (2) a pollutant or contaminant "which may present an imminent and substantial
endangerment to the public health or welfare" (EPA, 2000a). The term "release" is defined broadly in the
statute and includes discharging or leaking of substances into the environment. This also includes the
abandonment of closed containers containing hazardous substances, pollutants, or contaminants.
The definition of hazardous substance is extremely broad, and is defined in CERCLA
Section 101(14). A comprehensive list of these substances is provided in 40 CFR 302.4. In addition to
general listings for "lead", "lead and compounds", and "lead compounds," the regulation lists fourteen
other subcategories of lead.
Additionally, CERCLA is not media-specific. Thus, it may address releases to air, surface water,
groundwater, and soils. This multi-media aspect of CERCLA makes it possible to conduct environmental
assessments and design clean-up projects that address site contaminants in a comprehensive way.
The Agency has pursued a number of CERCLA response actions involving lead-contaminated soil
using the abatement authority under Section 106 (which also requires a showing of imminent and
substantial endangerment). CERCLA covers almost every constituent found at mining and mineral
processing (primary lead and other metals smelters) sites. Exceptions include petroleum (that is not
mixed with a hazardous substance) and, in some cases, responses to releases of a naturally occurring
substance in its unaltered form. It should be noted, however, that the latter exception does not include
any of the releases typically dealt with at mining sites, such as acid mine drainage, waste rock, or any ore
exposed to the elements by man.
1.2.2 Response Authorities
CERCLA's main strength is its response authorities. EPA can either use the Superfund to perform
response (removal or remedial) activities (Section 104) or require private parties to perform such
activities (Section 106). CERCLA gives EPA the flexibility to clean up sites based upon site-specific
circumstances. EPA's clean-up decisions generally are based upon both risk assessment and consideration
of ARARs. As long as the jurisdictional prerequisites have been met, CERCLA gives EPA the ability to
perform virtually any clean-up activity necessary to protect public health and the environment.
There are potential limitations in CERCLA which may be relevant to lead-contaminated sites. For
example, Section 104(a)(3) limits EPA's ability to respond to releases within residential structures as
follows:
-------
"Limitations on Response. The President (EPA) shall not provide for removal or remedial action
under this section in response to a release or threat of release . . . from products which are part of
the structure of, and result in exposure within, residential buildings or business or community
structures ..."
The above cited section of CERCLA generally limits EPA's authority to respond to LBP inside a
structure or house as written in Section 6.6.1 of this Handbook. However as noted in Section 6.6.1 of the
Handbook, EPA has the authority to conduct response actions addressing soils contaminated by a release
of lead-contaminated paint chips from the exterior of homes to prevent recontamination of soils that have
been remediated. In addition, Section 104(a)(4) provides an exception to the limitations in
Section 104(a)(3).
CERCLA provides EPA with the authority to perform "removal" and "remedial" actions.
Assessments generally are considered "removal" actions and evaluate contaminants of concern, exposure
pathways, and potential receptors. The assessment process includes the review of available information,
as well as sampling, to obtain other necessary information. The process is broad in its application and is a
powerful tool in evaluating environmental risks posed by a site. Removal actions can be performed on
mining and mineral processing (primary lead and other metals smelters) sites, and other sites with lead
releases to the environment, of any size. Removal actions are subject to limits on time (12 months) and
money ($2,000,000) under the statute; however, these limits are subject to exceptions.
Remedial actions are typically long-term responses performed at those sites placed on the NPL.
Remedial actions also may be performed at non-NPL sites, through administrative orders on consent
(AOCs) or consent decrees, if they are privately financed. Remedial actions are not subject to the time or
dollar limitations imposed on removal actions, but require a more detailed and formal decision process.
1.2.3 Applicable or Relevant and Appropriate Requirements (ARARs)
Under Section 121(d) of CERCLA, remedial actions must comply with substantive provisions of
federal environmental laws and more stringent, timely identified state environmental or facility siting
laws. Removal actions should comply with ARARs to the extent practicable. "Applicable" requirements
are those federal or state laws or regulations that specifically address a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance found at a CERCLA site. "Relevant and
appropriate" requirements are not "applicable," but address problems or situations similar enough to those
at the CERCLA site that their use is well suited to the site.
-------
State requirements are not considered ARARs unless they are identified in a timely manner and are
more stringent than federal requirements. The recently published TSCA §403 Soil Hazard Rule, which
establishes a soil-lead hazard of 400 ppm for bare soil in play areas and 1,200 ppm for bare soil in non-
play areas of the yard, should not be treated as an ARAR. As recognized in the TSCA §403 Rule, lead
contamination at levels equal to or exceeding the 400 ppm and 1,200 ppm standards may pose serious
health risks based upon a site-specific evaluation and may warrant timely response actions. However, the
soil-lead hazard levels under the TSCA §403 Rule should not be used to modify approaches to addressing
brownfields, NPL sites, state Superfund sites, federal CERCLA removal actions and CERCLA non-NPL
facilities.
EPA has published a manual outlining potential federal ARARs that may be requirements at
Superfund sites. Published in two parts, the manual is entitled CERCLA Compliance with Other Laws
Manual, Part I, August 1988, and Part II, August 1989, and is available at EPA libraries (EPA, 1988).
1.3 DEFINITION AND PURPOSE
Residential properties are defined in the Handbook as any area with high accessibility to sensitive
populations, and includes properties containing single- and multi-family dwellings, apartment complexes,
vacant lots in residential areas, schools, day-care centers, community centers, playgrounds, parks, green
ways, and any other areas where children may be exposed to site-related contaminated media (EPA,
1996a, 1997a, 1998a). This document defines sensitive populations as young children (those under
7 years of age, who are most vulnerable to lead poisoning) and pregnant women. Focus is put on children
less than 7 years old because blood lead levels typically peak in this age range (EPA, 1986, 1990a; CDC,
1991). Unfortunately, this age range is also when children are most vulnerable to adverse cognitive
effects of lead (Rodder, 1995). Pregnant women are included due to the effects of lead on the fetus
(Gayer, 1990; Graziano et al., 1990; Carbone et al, 1998). Other EPA guidance (EPA, 1995a, 2001b)
and local zoning regulations should also be consulted prior to determining which properties will be
treated as residential.
Lead-contaminated residential sites are defined, for the purposes of this document, as sites where
lead is the primary contaminant of concern in residential soils. Generally, lead-contaminated sites contain
other metals of concern, such as cadmium and arsenic. This document, while addressing primarily lead
contamination, may also be appropriate for use in the remediation of sites contaminated by other metals.
In all cases, looking at the site history (type of lead site, depositional environment for the lead
contamination, fill activities, previous epidemiological studies, etc.) is important in the use of the
Handbook. Typically, the types of sites addressed by the Handbook are sites where the lead
contamination has resulted primarily from primary or secondary lead smelting, battery cracking, or
-------
mining and milling operations. Lead paint and dust, along with other sources of lead and other toxic
metals, may also be present at these sites.
The Handbook is primarily based on a compilation of the Superfund program knowledge and
experiences, as well as existing technical and scientific literature addressing lead-contaminated residential
sites. The Handbook has undergone broad review by the Agency for Toxic Substances and Disease
Registry (ATSDR), the Association of State and Territorial Solid Waste Management Officials
(ASTSWMO), and national and regional EPA offices. Because the Handbook is written for use by
CERCLA program staff, there are frequent references to guidance or other documents developed under
the Superfund auspices. The Handbook does not supersede or modify any existing EPA guidance or
policy. This guidance does not suggest that CERCLA authorities are to be applied at all lead-
contaminated residential sites. Rather, these references are provided to the reader as resources to be
considered in developing site characterization and clean-up strategies under whatever regulatory or non-
regulatory approach is appropriate at a particular site. However, the NCP should be followed and other
applicable guidance consulted when addressing lead-contaminated residential sites under CERCLA. The
Handbook does not address ecological risks from lead and lead sites.
-------
2.0 COMMUNITY INVOLVEMENT
The sustainability of a residential clean-up project in many ways is contingent upon support from
affected residents, elected officials, local public health agencies, municipal and public works staff, state
government personnel, and other stakeholders. Few sites impact more citizens of a community than large
residential clean-up projects, with many projects exceeding a thousand homes and several thousand
residents. If the residents recognize the risks posed to their community and feel involved in the decision-
making process, they are more likely to accept the need for cleanup. House-to-house personal interaction
with residents can be useful to learn their concerns (or lack of concerns) and can also be an effective part
of educating the public regarding risks posed by the site. The project manager should issue bulletins
and/or fact sheets to help keep the community informed of site activities and should consider establishing
a toll free number for residents to contact her/him with questions about the site. Likewise, without the
support of local governments, portions, if not all, of the selected remedy may be more difficult to
implement. Many remedies rely in part on health education and institutional controls (ICs) as part of the
actions taken to protect human health, both of which may rely on the active participation of local
governments and health departments. The following sub-sections provide information on involving the
community.
2.1 EDUCATION ACTIVITIES
This section discusses how to involve the local health departments and community in the education
activities and the overall benefits and limitations of health education. Section 3 addresses health
education activities in detail.
Several studies have shown that a significant short-term reduction in blood lead concentrations can
be achieved through the education of the public on the dangers of lead exposure and on methods they can
take to limit their exposure (Kimbrough et al., 1994; Hilts et al., 1998; Schultz et al, 1999). However,
EPA does not consider health education, as the only action, to be an effective, permanent remedy for
Superfund sites (Appendix B). Often, in-home education activities have been combined with regular
house cleaning. One key to begin reduction of elevated blood lead concentrations in children is to initiate
health education activities, and where appropriate, blood lead screening, as early as possible in the
process. These activities should be started as soon as elevated blood lead levels or elevated soil levels are
detected at a site. Education should be sustained throughout the project. If residual contamination, such
as encapsulated wastes, LBP, or other such potential sources are left on site after completion of the
remedy, then education activities should be sustained in perpetuity.
-------
10
Integrated Exposure Uptake Biokinetic Model
(IEUBK) - Predicts blood-lead concentrations
(PbBs) for an individual child, or group of
similarly exposed children (6 months to
7 years old), who are exposed to lead in the
environment. More information is available
from the Technical Review Workgroup for
Lead (TRW) web site:
http ://www. epa. gov/superfund/programs/lead/
ieubk.htm
Generally, EPA does not directly conduct the
majority of education activities. One of the
responsibilities of the project manager is to educate
the community on the risks of lead exposure and to
coordinate with various health agencies in
establishing lead education programs. These
programs are often implemented by local health
districts that, in turn, typically coordinate with
schools and other community groups working with
families and children. Initial tasks include educating the community regarding their lead exposure and
associated health risks. Typically, a significant amount of effort will be required to explain the rationale
and procedures of the EPA risk assessment method for lead, using the Integrated Exposure Uptake
Biokinetic Model (IEUBK), and the need to collect data to estimate site-specific values for model
parameters. It is advisable to obtain input on exposure parameters specific to the community (e.g., how
often they frequent locations that are not residential). Community input into the risk assessment is not
relevant to those parameters that require site-specific studies to generate empirical data (e.g., an animal
feeding study to determine bioavailability). Often, local health officials will be unfamiliar with EPA's
risk assessment process and will benefit from education along with the general public. The need for
community education is heightened by the subtle nature of the low-dose adverse health effects of lead,
which cannot be diagnosed in an individual because the scientific basis for cognitive impairments caused
by low to moderate exposures relies on carefully controlled comparisons of large numbers of children
exhibiting a range of blood lead levels (NRC, 1993; Needleman and Bellinger, 2001). Once the public
and local health officials are made aware of the potential risks presented by the site, specific programs,
discussed in detail in Section 3 (Health Education), can be implemented. Education and clean-up
activities should be easier to implement, more effective, and more widely accepted by the community
when the citizens understand the risks and believe that the community is at risk.
2.2
COMMUNITY ADVISORY GROUPS
Community Advisory Groups (CAGs)
can be invaluable in assuring the success of
the project (EPA, 1995b). A supporting and
active CAG, comprised of a wide cross section
of the community, has been demonstrated on
several projects to greatly contribute to the
success of meeting the remedial goal.
Establishing an open dialogue with the CAG
Community Advisory Group (CAG) - Members of the
community make up a CAG, which serves as the focal
point for the exchange of information among the local
community, EPA, the state regulatory agency, and
other pertinent federal agencies involved in cleanup of
the Superfund site. Additional information is
available online:
http://www.epa.gov/superfund/tools/cag/index.htm
-------
11
and understanding and addressing its concerns, leads to increased satisfaction in the community at the
completion of the project. Concurrent with the establishment of health education activities, formation of
citizens groups should be encouraged at the very onset of the project. Delay in forming the groups until
significant progress has occurred may lead to mistrust by the community, as well as delay or loss of the
valuable contributions they can make in assisting EPA.
Citizens groups should be representative of the community. Examples include residents, workers,
and business owners from affected neighborhoods, as well as minority leaders, realtors, bankers or
lending institution officers, school board members, health officials, elected officials, city public works
staff, local environmental group members, and other groups in the community. Additionally, the project
manager should coordinate with other federal and state agencies to attend citizen group meetings.
Relevant agencies may include the ATSDR, HUD, and state health and environmental departments.
Citizens groups can create a feeling of ownership that facilitates the long-term success of the
remedy. They can contribute significantly to education activities in numerous ways. A few examples of
the successful programs and activities accomplished by citizens groups at sites include: general education
and awareness of the segment of the community they individually represent; creating site-specific
education material such as coloring/story books; hosting health fairs; creating health education programs
for local school districts; establishing lead poisoning prevention merit badges for girl and boy scout
organizations; developing instructional videos; and establishing pre- and post-natal education programs at
local hospitals.
2.3 EPA's TECHNICAL ASSISTANCE GRANT PROGRAM
EPA provides assistance grants to communities to help citizens understand site-related information.
By regulation, EPA must inform communities about the availability of Technical Assistance Grants
(TAGs) and assist them in applying for these grants (EPA, 1992). EPA also informs citizens about
obtaining assistance through other programs such as the university-based Technical Outreach Services for
Communities program and the Department of Defense's Technical Assistance for Public Participation
(TAPP) program.
Under the TAG program, initial grants of up to $50,000 are available to qualified groups affected
by a response action. Additional funding is available for unusually large or complex sites. A group
applying for a TAG need not be incorporated as a non-profit organization at the time it submits its
application, but must incorporate as a non-profit organization before EPA can award the grant.
-------
12
The group must contribute 20 percent of the total project costs to be supported by the TAG grant.
This requirement can be met in a number of ways, including with cash, donated supplies, and volunteered
services. TAG groups must prepare a budget and work plan for using the funds. There may be only one
TAG award per NPL site. If more than one group applies for the same TAG, they are encouraged to form
a coalition to apply for the grant.
TAGs are used to hire a technical advisor, who is an independent expert who can review site-related
documents, interpret them, and explain technical or health-related information to community members. A
TAG advisor will often make site visits to gain a better understanding of the clean-up activities. A
technical advisor can also help communicate the community's concerns to EPA. TAG funds may not be
used to generate new data (e.g., to conduct additional sampling) or for lawsuits or other legal actions. For
further information on TAGs, see the recently revised TAG regulation (EPA, 2000b), which is available
from the EPA TAG web site.
2.4 INFORMATIONAL MEETINGS
As important as the health education activities and the establishment of citizens groups are, the
project manager should consider holding frequent public meetings to inform the community of current
and planned EPA activities and to collect feedback and concerns from citizens. If a CAG has been
formed at the site, meetings with the group should be frequent and open to the general public. It is
recommended that in the early phases of the project, information sessions should be held at least monthly.
Once the community becomes aware of the site risks, current site activities, and becomes relatively
involved in the process, the frequency of the meetings can be reduced. However, it is recommended that
public informational meetings, separate from the citizens task force meetings, be conducted at least once
every six months. This frequency can help ensure that the public stays informed of site progress and has
an opportunity to provide meaningful input to the process.
In addition to the meetings pursuant to CERCLA (e.g., prior to release of the Record of Decision)
meetings are helpful at the following points in the process: (1) before sampling is conducted, to explain
the reason that lead contamination is suspected, how residents can reduce exposure as a safety precaution
while awaiting sampling results, and the overall goals of the project (e.g., if the goal of the project is to
reduce exposure by remediating only surface soils and therefore the sampling is designed to evaluate only
surface soils, the issue of ICs for any contaminated soils remaining at depth should be discussed with the
property owners early in the process); (2) after sampling is conducted, to explain results, reiterate how
residents can reduce exposure (if results show elevated levels), explain plans and the schedule for
conducting remediation, discuss plans for re-landscaping the property, and discuss what sort of ICs may
be appropriate; and (3) after remediation is completed, to explain what was done, provide documentation
-------
13
of the results of the remediation, discuss any problems with the landscaping, and discuss any applicable
ICs.
2.5 COMMUNITY INVOLVEMENT SPECIALIST/COORDINATOR
When the site is large and cleanup is expected
to last several years, consideration should be given to
housing a full time community involvement
specialist/coordinator (CIS/CIC) at the site. The
roles of the CIS/CIC are (1) to coordinate
community involvement activities, and (2) to be
readily accessible to the public to provide
information and answer questions concerning site
activities. The CIS/CIC should be intimately
familiar with all activities at the site, as well as the
documented health risks, and should maintain an office with business hours convenient to the public.
Additionally, the CIS/CIC can use information gained from their constant contact with the local
community to brief project staff on issues important to the successful remediation of the site.
Community Involvement Specialist/
Coordinator - is the primary point of contact
for a community and a Community Advisory
Group (CAG), if one was formed for the site.
He or she answers questions and provides
other assistance directly as well as sees that a
CAG's concerns and other issues are
transmitted to other Regional Office staff who
can help.
-------
14
3.0 HEALTH EDUCATION
Health education provides information to the public about the risks associated with exposure to
contamination and, in turn, how to reduce the exposures. Health education may be considered one of
many tools the project manager can use at lead-contaminated sites to reduce exposure to humans.
3.1 APPROPRIATE USES FOR HEALTH EDUCATION
Health education is an informational device and this type of instrument is largely unenforceable.
Furthermore, health education has not been demonstrated to be effective over the longer term. Health
education may be effective when combined with other measures as an overall remedy for a site. Health
education is not a stand-alone remedy. EPA's policy is that health education is only appropriate as a
supplemental component of the permanent, health protective remedy selected at a contaminated lead site.
For these reasons, EPA advocates that health education be layered or implemented in series with
ICs and engineered remedies. Layering means using different types of ICs and engineered remedies at
the same time to enhance the protectiveness of the remedy. Using ICs in series is the use of ICs at
different points in the investigation and remediation process to ensure the short- and long-term protection
of human health and the environment.
3.2 PLANNING FOR HEALTH EDUCATION
Generally, the specific goals of the health education program should be described in a site-specific
decision document. A plan that clearly defines the goals and how they should be achieved is also more
likely to succeed. Health education at large lead sites may have a performance period of several years
and cost hundreds of thousands of dollars. For these large projects, a clearly defined health education
program is even more important.
An early step in any health education planning process includes conducting a community profile
and assessing the educational needs of the community. A comprehensive health education program for a
typical large lead site would normally attempt to focus on reaching the general public, with special
emphasis on schools and other groups involved with young children. Also, it is important to coordinate
with city, county, and other local governmental entities. The most important target population, though, is
parents, particularly young parents, and parents with a child whose blood lead tested high. Other means
of targeted education may include those homes with children that have high dust lead concentrations or
lead loadings, which have been shown to be highly predictive of homes where a child is likely to have an
elevated blood lead level during the summer peak (EPA, 1996b; von Lindern and Spalinger, 2001).
-------
15
The response plan should describe what actions and activities are necessary to reach the
community-at-large and the targeted groups. It is very important to consider that there are costs
associated with the development, implementation, and follow up of health education and that these factors
should be thoroughly understood and estimated. Other key points to consider are that the responsibilities
for conducting this work should be clear and agreements should be made in writing in the planning stages
of site response process.
3.3 EVALUATION OF HEALTH EDUCATION ACTIVITIES
It is important to monitor the effectiveness of health education projects that have been implemented
at lead-contaminated sites. Many sites may include health education activities as a major component of
the remedy, especially in the early phases of the cleanup. Failure to establish the education part of the
remedy may trigger reconsideration and imposition of additional requirements, or more extensive and
costly clean-up efforts.
The project manager should monitor the organization(s) performing the educational activities for
proper implementation of the health education program and assess the effectiveness of the program.
Project managers should ensure that the objectives of the program are being met to protect children's
health. If health education is included as part of the final remedy, it should be carefully scrutinized
during the Five-Year Review process.
3.4 AGENCY FOR Toxic SUBSTANCES AND DISEASE REGISTRY (ATSDR)
INVOLVEMENT
Health education is often implemented through grants from ATSDR to its partners in state health
departments or directly through agreements with local health departments. When health education is
specified as a major part of EPA's clean-up activities, strong consideration should be given to
establishing an interagency agreement with ATSDR to assist in funding the required activities. ATSDR
as a federal health agency is well positioned in terms of health education resources to administer such
grants. ATSDR can provide expertise not only with the CAGs but also with public health assessments,
health consultations, and health surveillance. An emphasis should be placed on developing the
collaborative partnerships between EPA, ATSDR, and other federal, state, and local health departments
for health education activities at contaminated lead sites.
Health education at lead sites is often accompanied with blood lead screening. Centers for Disease
Control and Prevention (CDC) has issued guidelines for increasing intensity of health intervention
activities based on blood lead test results (CDC, 1991). Increased collaboration among the involved
-------
16
agencies is important to properly implement a health education/blood lead screening project.
Additionally, ATSDR and many state and local health departments have ongoing lead screening and
health education programs. Information from targeted screening is valuable for (1) targeting follow-up
education to individual families with children identified with elevated blood lead levels; (2) determining
the areal and demographic extent of the problem; and (3) effectively evaluating the impact of health
education.
3.5 OUTREACH
EPA has had success in health education activities at several sites because the programs were
tailored specifically for the site by the site team (i.e., project manager, toxicologist, on-scene coordinator,
CIS/CIC, etc.). These programs have included significant amounts of outreach activities in the
communities. The success of any health education program generally can be attributed to the amount of
community outreach that is conducted at the site. As discussed in Section 2, the outreach can consist of a
wide variety of activities. A few examples include the following: site specific coloring books distributed
to the parents of young children, scouting merit badges on lead-poisoning prevention, school curriculums
developed to inform student of the hazards of lead and good hygiene, health and environmental fairs
conducted in the community, and blood lead testing events held at community celebrations. Consultation
with local health officials and community groups can provide numerous ideas for outreach, which can be
incorporated into specific programs to best meet the needs of the community. Typically, the local health
officials should lead the outreach efforts. Funding should be provided by EPA when other funds, such as
from ATSDR, are unavailable to support the outreach activities.
-------
17
4.0 SITE CHARACTERIZATION
EPA has reviewed various sampling designs historically employed at lead-contaminated residential
sites and assessed the ability of these sampling designs to meet risk assessment needs and support the
development of clean-up levels. Over a 20-year period, several large area lead sites (e.g., Bunker Hill,
Shoshone County, Idaho; Joplin, Missouri; NL Industries/Taracorp-Granite City, Illinois; Tar Creek,
Ottawa County, Oklahoma) have used a variety of sampling techniques to characterize residential
properties. Additionally, many different approaches to applying selected clean-up levels have been taken.
As stated, this document was developed to promote consistent procedures, criteria and goals in the
investigation and clean-up activities at Superfund lead-contaminated residential sites. However, a level of
flexibility is needed to best respond to different site conditions, communities, and uncertainties.
The overall goals of the sampling effort are to estimate an average soil lead concentration for risk
assessment purposes and to provide information to determine the scope of any required clean-up actions.
This information can also be used for public education and intervention. The sampling designs discussed
in this section are intended to provide, within one sampling effort, the necessary data for all phases of a
clean-up project so that residents are not inconvenienced by repeated sampling of the same property.
Project managers should carefully choose the sampling points needed to estimate the average lead
concentration in a cost-effective manner. Some uncertainty is acceptable to reduce the overall cost of
sampling at large lead sites. The selection of sample locations within areas with potential for exposure
has been the subject of recent articles which describe methods to manage decision uncertainty by
balancing sampling and clean-up costs (Englund & Heravi, 1994; Crumbling et al., 2001). Table C-l
(Appendix C) lists contacts within the agency who can provide assistance in various aspects of sample
planning and design, and also lists software that may be used for sample planning and decision support.
Section 4.0 discusses: (1) delineating the contamination zones; (2) residential property sampling
locations; (3) sampling method; (4) sampling requirements for backfill material and excavated soil for
off-site disposal.
4.1 CONTAMINANT ZONE DELINEATION
Historical information on site operations and use is crucial for the design of sampling plans that are
intended to delineate contaminant zone(s), and for the interpretation of data generated from the sampling
effort. In addition to gathering data on the nature of the source of contamination, information should be
gathered to identify areas where soils may have been moved or where fill or topsoil may have been
placed. Guidance on how to gather historical site data is available (EPA, 200If, 200Ig). Sites that have
been contaminated primarily by airborne-derived lead, such as smelter areas, can initially be sampled in a
-------
18
grid pattern. This will usually allow concentration contours to be defined across the community and to
establish the extent of horizontal contamination for cleanup and costing purposes. If grid sampling is
used for initial characterization to define the horizontal extent of contamination, follow-up sampling of
each yard located within the identified clean-up zone should be used to characterize each individual
property for clean-up requirements. For other sites where the variability is expected to be higher, such as
mining sites with discrete individual tailings piles located throughout the area, delineating the
contaminant zones by establishing concentration contours will be more uncertain and consideration
should be given to sampling every home in the potentially affected area, moving laterally away from the
source until clean areas of the community have been identified.
Delineating the zone of contamination generally amounts to distinguishing soil with "background"
lead concentration from soil that has been impacted by site-related activities. There are basically two
types of background: naturally occurring and anthropogenic (see insert for definitions) (EPA, 1989,
1995c, 2002). EPA guidance defines background for inorganics as "... the concentration of inorganics
found in soils or sediments surrounding a waste site, but which are not influenced by site activities or
releases " (EPA, 1995c). Natural background concentrations of lead vary widely with the local geology,
and can be as high as 250 ppm or more in mining areas (SRC, 1999). Local background concentrations,
which include natural and non-site-
related anthropogenic sources (e.g.,
historic automobile emissions) can
be substantially higher. Background naturallv occumng: ^^^ concentrations of lead present in
samples should be collected from
Types of Background
the environment that have not been influenced by humans
areas near the site that are not , . , . . ,
anthropogenic: lead concentrations that are present in the
environment due to human-made, non-site sources (e.g.,
automobile exhaust)
influenced by site contamination,
but that have the same basic
characteristics (e.g., soil type, land
use).
Statistical approaches to delineating contaminant zones are useful for some sites. In these cases, the
project manager should consult with a statistician to design an efficient sampling plan. The Agency is
developing guidance on characterizing background chemicals in soil that includes statistical methods for
delineating contaminated areas (EPA, 200 li). Geostatistics is widely recognized for offering graphical
methods that are ideally suited for delineating contaminant zones (Gilbert and Simpson, 1983; Flatman
and Yfantis, 1984; Journel, 1984; Englund and Heravi, 1994; Goovaerts, 1997). Geostatistics also
provides powerful methods for detecting contaminated areas from background when sample locations
have not been randomly selected (e.g., Quimby, 1986; Borgman and Quimby, 1996), for sampling plan
design (e.g., Flatman and Yfantis, 1984; Borgman et al., 1996), and for aiding in the design of remedial
-------
19
responses (e.g., Ryti, 1993). For smaller sites, rigorous statistical analyses may be unnecessary because
site-related and non-site-related contamination clearly differ. For these sites, the sampling plan should
focus on establishing a reliable representation of the extent (in two or three dimensions) of a contaminated
area (EPA, 1989) .
4.2 RESIDENTIAL PROPERTIES
For the purposes of this document, a residential property includes properties that contain single and
multi-family dwellings, apartment complexes, vacant lots in residential areas, schools, day-care centers,
playgrounds, parks, and green ways (EPA, 1996a, 1997a). In all cases, historical site information (type of
lead site, fill activities, previous epidemiological studies, etc.) is important in the application of this
Handbook.
Rationale for collecting yard soil samples and water samples on a residential property is provided in
Table 4-1. The collection of other types of media are important to determine overall risk, however
CERCLA has limited authority to address these media (e.g., interior paint, dust, and potable water).
4.2.1 Sampling Access
Prior to conducting any sampling or clean-up activities at a residential property, access must be
obtained from the property owner; access obtained from tenants or renters is not sufficient. It is essential
to begin access procurement as early as possible in the remedial process to avoid potentially lengthy
delays. It is recommended that access be obtained by going door-to-door. If residents are not home, a
blank access agreement with instructions for signature and submission to EPA, along with relevant
contact information should be left at the residence (but not in the mailbox). Examples of access
agreements are presented in Appendix D, pages D-2 and D-3. If possible, access for remediation should
be obtained at the same time access for sampling is sought. Examples of combined sampling/remediation
access agreements are included on pages D-4 and D-5 of Appendix D. Combining sampling and clean-up
access will avoid potentially lengthy delays. Additionally, access should be obtained for any interior dust
sampling and/or cleaning that will be performed at the residence (Section 6.6.2). Sample access
agreements for dust cleanup are presented in Appendix E.
-------
20
Table 4-1.
Rationale for Sampling Residential Properties
Sample
Location
Rationale for Sample Collection
Residential
yard soils
Residential soil may present a direct exposure pathway to persons working, playing, or conducting
other recreational activities on the property. Soil samples should be collected and quantitatively
analyzed to estimate lead concentrations. Residential soils may also present an indirect exposure
pathway via house dust exposure (see below).
Gravel
driveways
Fine-grained driveway material may present a direct exposure pathway to persons working or
engaged in recreational activities on driveways. Soil samples should be collected and
quantitatively analyzed to estimate lead concentrations. Gravel driveways with elevated soil
concentrations may also contribute to the transport of contaminants throughout the community.
Drip zones
and soils
below roof
gutter
downspouts
Rooftops may collect fine-grained sediments that contain high concentrations of lead. In yard
areas where downspouts discharge during a storm event, the fine-grained material washed from a
roof may accumulate and result in a localized increase in soil lead concentrations. Soil samples
should be collected and quantitatively analyzed to estimate lead concentrations. Drip zone areas
may also contain LBP influences and are important to characterize for health intervention
purposes, as drip zones are often used as play areas.
Soils in play
areas
Play area soils may present a direct exposure pathway to children under the age of seven. Soil
samples should be collected and quantitatively analyzed to estimate lead concentrations.
Garden soils
Garden soils may present a direct exposure pathway to persons who actively maintain a garden.
Soil samples should be collected and quantitatively analyzed to estimate lead concentrations.
Interior lead
dust
Lead in household dust may be a significant contributor to elevated blood lead levels, especially in
younger children. Dust samples should be collected and quantitatively analyzed to estimate lead
concentrations. Lead-contaminated interior dust can be derived from multiple sources; dust mat
samples and speciation can be used to identify lead sources.
Lead-based
paint
Deteriorating LBP may contribute lead to household dust, which can be a significant source of
lead exposure, particularly for young children. If elevated concentrations of lead are found in
interior dust, samples of interior paint should be collected and quantitatively analyzed to estimate
lead concentrations. Exterior LBP may contribute to the recontamination of remediated properties.
Samples of exterior LBP should be collected and quantitatively analyzed to estimate lead
concentrations.
First run and
purged tap
water
Groundwater and surface water near the site may contain elevated lead concentrations. Some
residences located within the site may use local groundwater or nearby surface water as a source
of drinking, cooking, bathing, or irrigation water. The water may represent a direct exposure or
ingestion pathway. Samples of both water standing in the pipes (first run sample) and water
discharged after the system has been flushed (purged sample) should be collected and
quantitatively analyzed to estimate lead concentrations. These results can also be used to help
determine if the drinking water is contaminated with site-related contamination (exceedance in
purged), orto determine if there is lead in the home's plumbing (exceedance in first run), or both,
which may be used for remediation or intervention purposes, respectively.
Crawl
Spaces
Crawl space sampling is recommended if the crawl space is accessible to children or pets. At
some sites (e.g., Bunker Hill) this has been found to be a significant pathway (IDHW, 2000;
TerraGraphics, 2000). Even when spaces are too small for children, pets have been found to
access these spaces and move significant amounts of fine dust containing elevated lead levels into
the child's bedroom (e.g., where a pet may sleep on the child's bed at night). Information on
concentrations of lead beneath the structure may be used to document the need to preclude access
or take other remedial measures.
Other areas
During field work, other potential sources of lead contamination may be identified. If the sources
appear to represent a potential exposure pathway to occupants of a residence, sampling may be
recommended. Other areas should be evaluated on a case-by-case basis and could include
sediment, surface water, or secondary play areas. If deemed appropriate, samples should be
collected and quantitatively analyzed to estimate lead concentrations.
-------
21
4.2.2 Residential Yards
It is recommended that when sampling residential lots with a total surface area less than
5,000 square feet (a typical urban lot size), five-point composite samples should, at a minimum, be
collected from each of the following locations: the front yard, the back yard, and the side yard (if the size
of the latter is substantial). The front, back, and side (if needed) yard composites should be equally
spaced within the respective portion of the yard, and should be outside of the drip zone and away from
influences of any other painted surfaces (Figures 4-la and 4-lb). Composites should consist of aliquots
collected from the same depth interval.
Sample aliquots
Front
Yard
O
O
o
o
1
Residence
L
0
Back
Yard
0
Drip Zone
Figure 4-la. Recommended minimum soil sampling in yards less than or equal to
5,000 square feet with small side yard. Five point composite samples should be collected
from each of the front and back yards. Four point composites should be collected from the
drip zone; each aliquot should generally be collected from the midpoint along each side of the
residence. Aliquots for a single composite sample should be collected from the same depth
interval. Soil samples should also be collected from distinct play areas and gardens if they
are present, as well as unpaved driveways and minimal use areas such as areas under porches
and crawl spaces. The locations of the aliquots should be equally spaced within the area of
the yard the composite is collected from. The figure illustrates one possible arrangement of
the sample aliquots. Please refer to Section 4.2.2 for further explanation.
-------
22
Five-point composite sample
A
Drip Zone
-Sample aliquots
r \ i
Front o
Yard
O
0
i i
O O O
Side Yard
O O
0
9
Residence
9
^
^ * /
0+~
o
0
Back
o
Yard
0
Figure 4-lb. Recommended minimum soil sampling in yards less than or equal to
5,000 square feet with substantial side yard. Five point composite samples should be
collected from each of the front, back, and side yards, along with other areas as described in
Figure 4-la. The locations of the aliquots should be equally spaced within the area of the
yard the composite is collected from. The figure illustrates one possible arrangement of the
sample aliquots Aliquots for a single composite sample should be collected from the same
depth interval. Please refer to Section 4.2.2 for further explanation.
For residential lots with a total surface area greater than 5,000 square feet, it is advisable that the
property be divided into four quadrants of roughly equal surface area. The two quadrants in the front
yard should encompass one half of the side yard; likewise for the two quadrants in the back yard. One
five-point composite of aliquots collected at equal spacing and from the same depth interval should be
obtained from each quadrant. Each aliquot should be collected away from influences of the drip zone and
any other painted surfaces (Figure 4-2).
Properties over one acre in size should be divided into 1/4 acre sections. One five-point composite
sample should be collected from each section. For large properties, consideration should be given to
whether elevated concentrations trigger partial removal of soils or access restriction (see Section 6.5).
-------
Five-point composite sample
A
23
Sample aliquots
I \
o
• o
o -1
o
o
o
^
• 1 0"*^
•
Residence
•^ • 4
3
0 I
u
_
J
2
o
o
o
o 4
o
0
Figure 4-2. Recommended minimum soil sampling in yards greater than 5,000 square
feet. Five point composite samples should be collected from each of the four quadrants as
indicated above. The locations of the aliquots should be equally spaced within each of the
quadrants. The figure illustrates one possible arrangement of the sample aliquots. Four point
composites should be collected from the drip zone; each aliquot should generally be collected
from the midpoint along each side of the residence. Aliquots for a single composite sample
should be collected from the same depth interval. Additional samples should be collected
from distinct play areas and gardens if they are present, as well as unpaved driveways and
minimal use areas such as areas under porches and crawl spaces. Please refer to Section 4.2.2
for further explanation.
4.2.3 Drip Zones
Lead-contaminated soils are frequently found within the drip zone of houses. It is recommended
that a four-point composite sample be collected from the drip zone of each residential property
(Figures 4-la, 4-lb, and 4-2). The composite sample (taken from any size lot) should consist of a
minimum of four aliquots collected between 6 and 30 inches from the exterior walls of the house. Each
aliquot should generally be collected from the midpoint of each side of the house. Collection of
additional aliquots should be considered if other factors exist, such as bare spots, distinct differences in
the house exterior, and areas where runoff collects. Rooftops may collect fine-grained sediments that
contain high concentrations of lead. In yard areas where downspouts discharge during a storm event, the
fine-grained material washed from a roof may accumulate and result in a localized increase in soil lead
-------
24
concentrations. Samples of the soil from the downspout discharge area should also be sampled if present.
4.2.4 Play Areas, Gardens, and Driveways
Distinct play areas and gardens, if present, should generally be sampled separately as discrete areas
of the yard. At some sites, collection of a right-of-way/easement composite may also be appropriate, such
as residential areas with unpaved streets and alleys. Paved surfaces such as asphalt/concrete driveways,
patios, alleys, and parking lots should, in most cases, not be sampled. Samples should also be collected in
other locations depending upon the potential for exposure or recontamination, for example, under porches
and crawl spaces and areas with incomplete barriers such as gravel driveways.
4.2.5 Potable Water, Lead-Based Paint and Interior Dust
Drinking water supply samples should be collected to determine if exposure to lead in drinking
water is occurring. First-run and purged samples of potable water should be collected to differentiate site-
related sources of lead from lead derived from plumbing that is located within the residence. CERCLA
authority for remedial action may be limited with regard to lead derived from plumbing that is located
within the residence.
Deteriorating LBP may contribute lead to household dust. If elevated concentrations of lead are
found in interior dust, samples of interior paint should be collected. Exterior LBP may contribute to the
recontamination of remediated properties (Section 6.7). Samples of exterior LBP should be collected and
analyzed to estimate lead concentrations. Lead in household dust may be a significant contributor to
elevated blood lead levels, especially in younger children. Lead-contaminated interior dust can be
derived from multiple sources; dust mat samples and speciation can be used to identify lead sources. Dust
samples should be collected and analyzed to estimate its potential contribution to lead exposure.
Guidance on LBP and dust sampling is available from HUD (HUD, 1995).
4.2.6 Backfill and Waste Soil
Backfill soil should be sampled to ensure that uncontaminated material is being placed on the site.
The list of analytes and the frequency of sampling should be based on site-specific factors including the
location of the source for the backfill material relative to potential sources of contamination, the geology
of the borrow area, and the heterogeneity of the material. For example, on the Bunker Hill Superfund
Site, four-point composite samples were collected for each 200 yd3 of soil (TerraGraphics, 1997a).
Gravel for driveway backfill was also sampled every 200 yd3 (TerraGraphics, 1997b). Samples of
excavated soil should be analyzed by the toxicity characteristic leaching procedure (TCLP) method to
-------
25
determine the appropriate method of disposal. The frequency required for TCLP sampling should be
based on the heterogeneity of the lead and other contaminant(s), if any, on the site.
4.3 SAMPLING METHOD AND ANALYSIS
4.3.1 Sample Collection
Composite samples should consist of discrete aliquots of equal amounts of soil. The soil from each
aliquot should be collected into one clean container, such as a stainless steel bowl or plastic bag, and
thoroughly mixed. After mixing, the sample can then be analyzed by X-Ray Fluorescence (XRF) (see
Section 4.3.4) or sent to the laboratory. Remaining sample volume can then be disposed in the general
location from where it was collected, or archived, depending on the requirements of the project. In some
cases, material other than grass and/or soil will be encountered at a sample location, e.g., wood chips and
sand are often found in recreational areas of day-care and school playgrounds. Samples of the soil below
the cover material should be collected.
The use of a dynamic sampling and analysis strategy should be considered (EPA, 200 Id). A
dynamic sampling and analysis strategy takes full advantage of the real-time that data field analytical
methods provide, which can limit the sampling effort and minimize cost (EPA, 200 Id). This document
suggests the use of field portable X-Ray Fluorescence (FP-XRF) analysis.
4.3.2 Sample Depth
The following sampling design is based on the assumption that removal of surficial contaminated
soils and placement of a cover of clean soil will be protective of human health and the environment (see
Section 4.0). Furthermore, the sampling design outlined below is based on the assumption that a
minimum of 12 inch soil cover is adequate.
Initial sampling for lead contamination in residential soils should be conducted to a depth of at least
18 inches, but does not need to exceed 24 inches to define the vertical extent of contamination for clean-
up purposes. Composite samples should be collected at 6 inch depth intervals, i.e., 0-6 inches,
6-12 inches, 12-18 inches, and 18-24 inches. Additional sampling may be required at lead sites in cold
weather regions when contamination is associated with coarse grained material. Stone-sized material,
such as tailings and crushed battery casings, will, overtime, migrate upward through the soil via
freeze/thaw effects. At such sites, composite sampling should be conducted at 6 inch intervals to the
approximate maximum frost depth for the region. In all cases, composites should consist of aliquots
collected from the same depth interval.
-------
26
In site-specific situations, deeper sampling may be conducted to determine the total vertical extent
of contamination for groundwater issues or ICs, and to determine if complete removal of contaminated
soil is possible. Depth sampling should be conducted until the vertical extent of contamination has been
adequately defined, but does not need to be conducted on every property.
In addition to the composite samples collected to define the vertical extent of contamination, five-
point composite surface soil samples should be collected from 0 to 1 inch for human health risk
assessment purposes (EPA, 1989, 1996c). The samples should be collected using the procedure described
in Section 4.3.1. These surface soil samples should be collected from every property within the identified
zone of contamination; however, after collecting a statistically valid number of both 0-1" and
1-6" samples, the project manager may want to compare both sample horizons (e.g., paired-sample t-test;
Wilcoxon Rank Sum test) (Gilbert, 1987; Snedecor and Cochran, 1989) to determine if the 0-1" depth
can be eliminated (i.e., sample from 0-6"), to further decrease sampling costs. This may be particularly
useful at mine waste sites where contamination often extends to depth or at sites where lead-contaminated
soil has been used as fill material; in such cases, the lead concentration may increase with depth.
Conversely, the 0-1" horizon may be far more contaminated than the 1-6" at smelter sites, making
individual horizon sampling crucial to remedial decision-making.
Collection of samples from specified depth intervals serves two primary purposes: risk assessment
and remedial decision-making. With respect to risk assessment, the top inch of soil best represents
current exposure to contaminants (EPA, 1989, 1996c) and is the source of data used in the IEUBK model
to represent exposure from soil. The various depth intervals are used in remedial decision-making to
determine if a residential yard requires cleanup by evaluating if any of the horizons exceed the site-
specific action level. The lower soil horizons represent possible future exposures, such as homeowner
projects, children's play areas, and other home activities that periodically go beneath the top inch of
vegetation/soil (EPA, 1989). All soil horizons should be used for clean-up decision-making. The 6 inch
depth intervals recommended in this document are based on the performance that may be reasonably
expected of operators of small equipment working in relatively small spaces around homes. Specifically,
a "bobcat" is most efficiently used for soil removal on a property if the soil is removed in 6 inch intervals,
rather than in smaller increments, which would be far more difficult to achieve in a consistent or cost-
effective manner. This approach has been developed to ensure a residential yard is cleaned up if it poses
an immediate or long-term risk to human health in a manner that relates the sampling methodology
closely to reasonable and cost-effective construction equipment performance.
A secondary goal of the sample collection effort is to facilitate the implementation of ICs for sites
where contamination at depth is left in place.
-------
27
4.3.3 Sample Preparation
Residential soil lead samples should represent the exposure potential of young children who are most
vulnerable to adverse effects of exposure. Children inadvertently ingest lead in soil and dust that adheres
to their hands (Succop et al., 1998). The smaller particles are more representative of this type of exposure
(Duggan et al., 1985; Kissel et al., 1996; Mielke et al., 1997). Additionally, smaller particles are
preferentially brought into the home. Sieving is conducted to better represent the soil fraction that is
ingested by the typical child. Sieving has also been used in soil ingestion and bioavailability studies
(Calabrese et al., 1996; Casteel et al., 1997; Stanek et al., 1999). Samples collected from all depth
intervals should be sieved. Samples should not be ground prior to sieving, as this changes the physical
structure of the soil and may bias the analytical results. To reduce sampling costs, it may be desirable to
develop a correlation between sieved and unsieved data, to eliminate the need to sieve all samples. The
correlation can be used to predict sieved results from
unsieved samples. The EPA Technical Review
frrn-.-in j * • o • ^ c Technical Review Workgroup (TRW) - The
Workgroup (TRW) and American Society for rT,r,.... : — ,—^—;—
TRW is an interoffice workgroup that consists
of key scientific experts from various EPA
regions, labs, and headquarters that supports
and promotes consistent application of the
best science in the field of lead (Pb) risk
assessment at contaminated sites nationwide.
Testing and Materials (ASTM) have issued guidance
on sieving (ASTM, 1998; EPA, 2000c). The EPA
TRW guidance addresses appropriate sieve size (No.
60) and a method for predicting the concentration in
the fine fraction using concentrations measured in
unsieved samples.
The presence of paint chips in a soil sample can represent a large proportion of the total lead
concentration that is measured. On this issue, the Handbook directs the reader to existing HUD guidance,
which states "If paint chips are present in the soil, they should be included as part of the sample.
However, there should be no special attempt to over-sample paint chips. The laboratory should be
instructed to disaggregate ('break up') paint chips by forcing them through a sieve in the laboratory.
Although paint chips should not be oversampled, they should not be excluded from the soil sample, since
they are part of the soil matrix." (HUD, 1995). The TRW website should be checked periodically for
additional sampling guidance.
4.3.4 Sample Analysis
EPA's experience in sample analyses at large residential contamination sites (with several thousand
homes on a site) shows that both FP-XRF or fixed-site laboratory analyses (acid digestion/Inductively
Coupled Spectroscopy) provide reliable information (EPA, 1996d, 1998b, 2001c, 2001d; Crumbling et
al., 2001). The objective of using a FP-XRF is to predict Contract Laboratory Program (CLP) values with
-------
28
less expensive real-time data. A sufficient amount of data should be collected to develop a site-specific
relationship (i.e., correlation) between FP-XRF and CLP lab data.
The comparison should consider sample preparation (drying and sieving) and analytical methods.
Typically, a large number of laboratory confirmation samples should be analyzed at the beginning of the
project to estimate the correlation between the FP-XRF and the CLP results and the FP-XRF precision
and accuracy. Additional confirmatory samples should then be analyzed at key decision points when the
FP-XRF results are close to action levels or when the reliability of the FP-XRF unit is in question (EPA,
200Id). For example, initial sample analyses using an FP-XRF instrument could include 20 percent
laboratory confirmatory samples to assess the accuracy and precision of the FP-XRF. Once the accuracy
and precision of the FP-XRF results have been determined (and assuming they satisfy the requirements of
the project), the number of laboratory confirmatory samples could be reduced (e.g., to 5 percent).
Additional information on analyzing soil (and other media) in the field with FP-XRF is available on the
EPA web site: http://www.epa.gov/superfund/programs/dfa/ (EPA, 200le).
Proper calibration of the FP-XRF unit is important to obtaining reliable results (EPA, 1996d).
Correlation between the FP-XRF and laboratory analyses is best achieved with small sample volume.
Laboratory confirmatory samples should be collected in the specimen cup available from the FP-XRF
manufacturer. The sample is first analyzed with the FP-XRF and then sent to the laboratory for wet
chemistry analysis. Soil moisture can introduce error in FP-XRF results to varying degrees, depending on
the instrument being used (EPA, 1996d). The correlation between the FP-XRF measurements on dried
and undried samples should be estimated. The correlation analysis should then be used to establish a
cutoff or 'soil moisture ceiling'. The 'soil moisture ceiling' represents the maximum moisture content at
which useful results (i.e., of sufficient precision and accuracy) can be obtained with the FP-XRF. Field
portable instruments capable of measuring moisture content are available and should be used to compare
sample moisture content to the 'soil moisture ceiling'. Samples with moisture contents greater than the
'soil moisture ceiling' should be dried prior to analysis with the FP-XRF.
-------
29
5.0 CLEAN-UP LEVEL SELECTION
Generally, the approach to human health risk assessment for lead differs from that of other metals
and contaminants. Typically, risks from lead exposures are estimated from long-term exposures, although
elevated blood lead concentrations also result from short-term exposures (CDC, 1991). EPA has
developed the IEUBK model to predict blood lead (PbB) concentrations in children exposed to lead. The
model considers several different media through which children can be exposed to lead.
EPA and the CDC have determined that childhood PbB concentrations at or above 10 micrograms
of lead per deciliter of blood (• g Pb/dL) present risks to children's health (CDC, 1991). Accordingly,
EPA seeks to limit the risk that children will have Pb concentrations above 10 • g Pb/dL. The IEUBK
model predicts the geometric mean PbB for a child exposed to lead in various media (or a group of
similarly exposed children). The model also calculates the probability that the child's PbB exceeds 10 • g
Pb/dL (P10). Preliminary remediation goals (PRGs) generally are determined with the model by adjusting
the soil concentration term until the P10 is below 5%. Final clean-up level selection for Superfund sites
generally is based on the IEUBK model results and the nine criteria analysis per the National
Contingency Plan (NCP) (EPA, 1990b), which includes an analysis of ARARs. More information on the
IEUBK model is available from the EPA TRW web site.
Typically at large lead sites, early actions taken to mitigate the identified site risks consist of time-
critical removal actions (TCRAs), most often taken as an interim action. These actions are usually
followed by long-term remedial actions. The following sections describe the different approaches that
should be used for prioritizing response actions and selecting clean-up levels for both early (interim) and
long-term (permanent) response actions.
5.1 PRIORITIZING RESPONSE ACTIONS
For early, interim actions, a tiered approach should be used for prioritizing clean-up actions. A
tiered-response approach is recommended when sufficient resources are not available to fully address lead
risks. The size and complexity of many lead sites often requires implementation of response actions over
an extended period of time; therefore, it is often necessary to implement interim clean-up actions to
manage short-term health risk concerns while response actions to address long-term risk are planned and
implemented. Early removal actions at residential lead sites should contribute to the performance of the
long-term permanent remedy.
The tiered approach is depicted in Figure 5-1. Figure 5-1 is a flowchart that provides a roadmap of
the recommended clean-up process for lead-contaminated residential sites. An overview to the clean-up
process is provided in Figure 1-1. The first page of Figure 5-1 provides a more detailed overview; the
subsequent pages provide additional details of the process.
-------
30
1)
O
s
o
o«
t-i-H ra
_
O o
-M
If
'S P
T* O
a 8
a I
S 5
»
IB
o
Q
'
S £P
S u
s M
^K G
O
T'l
-------
31
"Tj CH
03 O
II
If
It
£.1
^4-H O
S fl
O O
OJ ~y
&- O
o
fj
u ^3
^> o
•fi &
•« i
13 M
^ s
a °
ll
"d C
""O ^
S 8
8 ™
° ff
g &
1 ^
bO g
^ O
fl
«i O
QJ . rH
HH Q
H "~^
O bO
0 fl
CH ^H
'rt CX
1 1
ch additic
add one s
^
" .2
I
O
O
60
-------
32
u
•o
D
O
U
Sf
£
M
a
00
.3
t
g
ft
_g
>
•S
M
_u
"ft
S
"5
w
"o
o
^•p" " """"^
T3
s
^
'-i—l
1
ffi
a
^0
"S
B
u
.4
\
o
fl
1
•
(N
>d
vd
a
• in °
^H '-S
(L)
•y
.
ft
I
"ft
ft
a
cS /— ,
"o vo
"S a
S u
K GO
^O -— '
u
ft
u P
^ ^d
•2 13
M 2 *
S ta ^
13 I o
11
jj 5£,
-------
33
•o
1)
o
u
-------
34
The concentrations that are used to define tiers should not be confused with clean-up numbers,
which are based on the PRG determined with the IEUBK model and an analysis that includes the nine
criteria listed in the NCP (EPA, 1990b). The 1,200 ppm concentration is not an action level for TCRAs,
but is intended to provide an alternative to running the IEUBK model if the project manager believes the
site poses an urgent threat (EPA, 1997b, 1997c). Certainly, a TCRA could be justified above or below
this concentration depending on the conditions at the site. The tiers, for the purposes of this guidance, are
defined below (see also Figure 5-1). (Please note the Agency is considering developing new guidance for
removal actions.)
• Tier 1 properties have both sensitive populations (children up to 7 years old or pregnant women)
and soil concentrations in the surface soils (0-1" depth) at or above 1,200 ppm (EPA, 1997b,
1997c). Also, Tier 1 sites can be identified based upon a demonstration of children's blood lead
levels at or above 10 (ig/dL. Generally, TCRAs would be taken at Tier 1 properties.
• Tier 2 properties have either sensitive populations and soil lead concentrations in surface soils
between 400 ppm and 1,200 ppm, or no sensitive populations and surface soil lead concentrations
above 1,200 ppm, but not both. Tier 2 properties can be addressed through TCRAs, or non-time-
critical removal actions (NTCRAs), or long-term remedial actions.
• Tier 3 properties have surface soil concentrations below 1,200 ppm, but above 400 ppm, and no
sensitive populations present. Tier 3 sites would typically be addressed through long-term remedial
actions or NTCRAs.
Tier 1 should be the highest priority for immediate action and Tier 3 should be the lowest priority
for immediate action. Residential properties can move into a different tier if conditions change (e.g.,
small children or pregnant women move into a house). A typical residential lead site will contain a
combination of properties that fit into different tiers. The project manager should use judgement to
determine whether or not to perform a complete cleanup of contaminated residential properties (as
defined in Section 1.3).
As discussed below, remedial actions for residential lead sites should use the IEUBK model. The
IEUBK model should be used to assess risks posed by contaminated soils and to determine PRGs for soils
at residential lead sites. In order to facilitate TCRAs, a demonstration of elevated blood lead levels or
elevated soil-lead levels at or above 1,200 ppm will usually be sufficient. If elevated blood lead levels are
the basis for concern, occupational contributions of lead, elevated lead levels in drinking water, lead from
LBP, and lead dust in the homes of children or adults with elevated blood lead should be investigated first
because these sources of lead can be significant (Appendix B). At this stage, consultation with Regional
-------
35
risk assessors and public health officials (such as ATSDR) to better understand health impacts is
encouraged.
The Agency plans on publishing a future lead removal directive which includes further information
on site-tier approaches.
5.2 LONG-TERM REMEDIAL ACTION
The 1994 Office of Solid Waste and Emergency Response (OSWER) Directive 9355.4-12 states
OSWER's risk reduction goal for residential lead sites: "... generally, OSWER will attempt to limit
exposure to soil lead levels such that a typical (or hypothetical) child or group of similarly exposed
children would have an estimated risk of no more than 5% exceeding the 10 • g lead/dL blood lead level."
(P10<5%) (EPA, 1994b). It is important to note that this recommendation (i.e., P10<5%) is meant to apply
to a single residential property or another discrete exposure area, not on an area- or community-wide basis
(i.e., 5 children out of every 100 actually exceed 10 • g/dL). It is also important to note that selecting a
soil lead concentration in this manner will not guarantee that a given child will not exceed a blood lead
level of 10 • g/dL. Many factors other than soil concentration cause variance in blood lead levels: pica
behavior, or other sources of lead not included in the exposure unit, such as paint, diet, etc. (e.g., this
could include soil at a camping site or other remote site frequented by the child).
The 1998 OSWER Directive 9200.4-27P ('Clarification') (EPA, 1998a) recommends that the
IEUBK Model be used as the primary tool to generate risk-based soil clean-up levels at lead sites for
current and future residential use (Appendix B). Additionally, the 1998 Clarification states that response
actions can be taken using IEUBK predictions alone, and that blood lead studies, while providing useful
information, should not be used for establishing long-term remedial or non-time-critical removal clean-up
levels at lead sites. Regarding exposure units at residential lead sites, the 1998 Clarification states: "... it
is recommended that risk assessments conducted at lead-contaminated residential sites use the individual
residence as the primary exposure unit of concern" (EPA, 1998a; Appendix B). This document clarifies
the definition of exposure unit provided in the 1998 Clarification. In addition to the individual residence,
accessible site-related lead sources outside the residential setting should also be evaluated to understand
how these other potential exposures contribute to the overall risk to children. When the evaluation
indicates a significant contribution to risk, clean-up measures should be determined for those areas.
Empirical blood lead data occasionally deviates significantly from IEUBK Model predictions. This
can be due to numerous factors, including the implementation of lead exposure-reduction and health
education programs, and uncertainties in the exposure parameters of the Model as well as uncertainties in
the blood lead data (Mushak, 1998). Regarding this issue, the 1998 Clarification states: "Where actual
-------
36
blood lead data varies significantly from IEUBK Model predictions, the model parameters should not
automatically be changed. In such a case, the issue should be raised to the TRW to further identify the
source of those differences" (Appendix B). Basically, model inputs should be changed only when
defensible, site-specific information that is specifically applicable to the parameters is collected.
Moreover, these changes should also ensure that model outputs are protective of future residents.
Examples of such information are dust lead concentration, drinking water concentration, bioavailability
data (e.g., in vivo pig studies), and soil-to-dust ratio. The predictive capacity of the IEUBK Model
depends upon the representativeness of the inputs. Section 4 discusses the collection of the data used to
estimate some of these inputs.
In summary, there is no national clean-up standard for lead in residential soil on a Superfund site;
however, there is a consistent process by which residential soil lead clean-up levels are selected. One step
is to gather site-specific data as recommended in Section 4 of this Handbook and review other guidance
on the use of the IEUBK Model (EPA, 1994b; TRW web site: http://www.epa.gov/superfund/programs/
lead/ieubk.htm). Risk assessors (and other data users) should be consulted early to assist with data
collection and planning (EPA, 2000d). Another step is to get assistance from the regional risk assessor(s)
to run the IEUBK Model with applicable site-specific inputs. Running the model should allow the
determination of a site-specific PRG that corresponds to a P10 for a typical child, or group of similarly
exposed children, that is no more than 5%. Another step is to select a site-specific residential soil lead
clean-up level that is based on the model-derived soil lead PRG and an analysis of the nine criteria
consistent with the NCP (Superfund sites only) (EPA, 1990b). If the proposed clean-up level is outside of
the range of 400 ppm to 1,200 ppm lead, then the draft decision document for the site is sent to the Lead
Sites Consultation Group (LSCG) for review (EPA, 1997b).
Lead Sites Consultation Group (LSCG) - The Lead Sites Consultation Group (LSCG) was
created in 1997 to promote national consistency in decision-making at lead sites across the country
(EPA, 1997b). The main purpose of the group is to review key response decisions at lead sites.
The LSCG is comprised of senior management representatives from the Waste Management
Divisions in all 10 EPA regions along with senior representatives from the Office of Emergency
and Remedial Response in EPA headquarters.
The LSCG is supported by EPA's Technical Review Workgroup for Lead (TRW) and the national
Lead Sites Workgroup (LSW). According to Agency policy, there are three triggers that cause the
review of lead-related proposed plans by the LSCG (EPA, 1997b):
1) Residential contaminated lead sites with proposed cleanup levels outside a 400 to
1,200 ppm soil-lead level;
2) Sites that envision actions to address non-soil lead-contaminated media;
3) Routine LSW deliberations that identify a unique or precedent setting site issue(s).
-------
37
6.0 APPLICATION OF CLEAN-UP NUMBERS/REMEDIATION
The following section provides a detailed discussion of recommended minimum considerations to
remediate residential soil and other sources of lead in residential settings. The guidelines stated below
apply to early/interim actions and long-term remedial actions. However, due to statutory funding
limitations that apply to time-critical removal actions, site-specific determinations regarding yard size
limitations, and whether to clean up empty lots and other sources of lead (paint, dust, tap water), should
be made by the project manager on a site-by-site basis.
6.1 MINIMUM EXCAVATION DEPTH/SOIL COVER THICKNESS
Based on Agency experience, it is strongly recommended that a minimum of twelve (12) inches of
clean soil be used to establish an adequate barrier from contaminated soil in a residential yard for the
protection of human health. Cover soil can either be placed after excavation as backfill or placed on top
of the contaminated yard soil. The rationale for establishing a minimum cover thickness of 12 inches is
that the top 12 inches of soil in a residential yard can be considered to be available for direct human
contact. With the exception of gardening, the typical activities of children and adults in residential
properties do not extend below a 12-inch depth. Thus, placement of a barrier of at least 12 inches of
clean soil will generally prevent direct human contact and exposure to contaminated soil left at depth.
Removal of lead-contaminated soil to depths greater than 12 inches should be considered at sites in
cold regions with non-soil lead-contamination sources, such as tailings and crushed battery casings, and
whenever it is cost-effective. The additional response cost should be compared to future 1C and
monitoring costs associated with leaving the material in place. Full vertical removal of residential soil
has many advantages, such as reducing or avoiding the costs of maintaining the soil cover, the placement
of subsurface barriers/markers, and obtaining environmental easements. Full removal of contaminated
soil also satisfies EPA's preference for permanent remedies and normally allows the remediated yard to
return to unrestricted use.
Twenty-four (24) inches of clean soil cover is generally considered to be adequate for gardening
areas; however, site specific conditions that may require more soil cover (e.g., presence of burrowing
animals) should be considered. A 24-inch barrier normally is necessary to prevent contact of
contaminated soil at depth with plant roots, root vegetables, and clean soil that is mixed via deep
rototilling. Raised garden beds may be built to obtain 24 inches of clean soil, and may be more cost
effective than excavating to 24 inches in depth, e.g., excavate 12 inches of contaminated soil, then add
24 inches of soil to create a 12" raised bed.
-------
38
6.2 SOIL CLEAN-UP OPTIONS
Currently, there are only two remedial actions that generally are considered to be protective, long-
term (not interim) remedial actions at residential properties: (1) excavation of contaminated soil followed
by the placement of a soil cover barrier and (2) placement of a soil cover barrier without any excavation
of contaminated soils. Excavation followed by the placement of a soil cover is the preferred method and
is strongly recommended at sites with relatively shallow contamination, such as many smelter sites. In
most cases, excavation and placement of a soil cover should be performed whenever the specific
conditions of a site do not preclude it. For example, it may not be feasible to fully excavate a very large
site cost-effectively, therefore capping, also considered to be protective, may be more appropriate. The
advantage of the preferred method is that it is a permanent remedy in terms of removal of lead from areas
where children may be exposed.
Several treatment technologies are currently under development to reduce the bioavailability of soil
lead, but have not yet been proven to be protective in the long-term. These include amending the soil
with phosphorus or high iron biosolids composts. Preliminary results have shown phosphate treatment to
reduce the bioavailability of lead in soil by as much as 50 percent. This would mean that soil with lead
concentrations in the range between clean-up levels calculated with the pre- and post-treatment
bioavailability values could be treated instead of removed (e.g., if the IEUBK model-derived clean-up
number using the pre-treatment bioavailability were 400 ppm lead, and the calculated post-treatment
clean-up level were 800 ppm lead, then the yards with lead concentrations between 400 ppm and 800 ppm
could be treated rather than excavated or capped).
Over time, the efficacy of the phosphorous treatments appears to increase. This is consistent with
what is predicted using thermodynamics. To date, the treatability studies have been monitored for
3-5 years. Additional monitoring will be necessary to assure the long-term stability of the observed
reduction in bioavailability.
Some other existing technologies for soil remediation that are not currently considered acceptable
for residential lead cleanups are rototilling, phytoremediation, and interim controls, such as mulching,
seeding, and sodding (without prior removal of contaminated soil). Rototilling is not considered a
permanent, protective remedy in that no lead removal occurs, and adequate mixing of soil is difficult, if
not impossible, to achieve; additionally, rototilling may increase the volume of soil, which ultimately
requires remediation. Mulch, sod, or other vegetative covers are generally not considered permanent,
protective remedies in that no lead removal occurs, and there is no guarantee that grass, mulch, or other
vegetative cover will be maintained in good condition over time.
-------
39
Additionally, land use changes that may occur within a yard, such as starting a garden or putting in
a swing set, are not precluded in any way by mulch, sod, or other vegetative cover. Lastly,
phytoremediation is not currently an appropriate technology for residential lead cleanups due to several
factors: (1) the lead concentrations at many residential sites are not within the optimal performance range
for the plants; (2) the plants may concentrate lower level lead contamination and present an increased
disposal cost if the plants fail the TCLP test, but the unremediated yard soil does not fail; (3) the length of
time required for remediation; (4) the potential conflicts with local regulations pertaining to yard
maintenance; and (5) the depth of remediation achieved may be inadequate.
6.3 INTERPRETING SAMPLING RESULTS
Based upon the results of the sampling efforts (Section 4.0), this section describes the
implementation of two clean-up options: (1) excavation and backfill (and placement of a visible barrier if
applicable); or (2) soil cover placement (and placement of a visible barrier if applicable). The options
should be performed as described below (see also Figure 6-1). The goal should be to remove all
contaminated soil or provide a minimum 12" clean soil barrier. The following describes the
implementation of option 1:
• If the 0-1" horizon exceeds the clean-up level, a 6 or 12" excavation is recommended,
depending on the 6-12" sample horizon results;
• If the 1-6" or 0-6" horizon exceeds the clean-up level, a 6 or 12" excavation is
recommended, depending on the 6-12" sample horizon results;
• If the 6-12" horizon exceeds the clean-up level, a 12" excavation is recommended. A
visual barrier is required if the 12-18" horizon exceeds the clean-up level;
• If the 0-1, 0-6 or 1-6" horizons exceed the clean-up level and the 6-12" horizon does not
exceed the clean-up level, a 6" excavation is recommended; a visual barrier is not needed.
-------
40
1 Depth
Remedial Action
Options
Option 1:
Excavation
(& Backfill)
Option 2:
Capping
0-1"
1-6"
(or 0-6")
6-12"
Depth of
excavation
Soil cover
thickness
Soil Concentration Exceed Action Level?
Yes
Yes
Yes
12"
12"
Yes
Yes
No
6"
12"
Yes
No
Yes
12"
12"
Yes
No
No
6"
12"
No
No
No
No action
No action
No
Yes
No
6"
12"
No
No
Yes
12"
6"
No
Yes
Yes
12"
12"
Figure 6-1. Interpreting Sampling Results. The figure suggests remedial actions based on the results
of composite soil samples collected for each of the depth intervals shown. The figure includes two
remedial action options: (1) excavation followed by backfilling, and (2) placement of a clean soil cover
without removal of soil that exceeds the action level. To use the figure, find the column of the table that
agrees with the soil sample results for your site, then read down the table to determine the depth of soil to
remove (option 1: excavation remedies) or the thickness of the soil cover recommended (option 2:
capping remedies). For example, the heavy border around the third column of the table corresponds to a
situation where the average lead concentration in the 0-1" and 1-6" depth intervals exceed the action
level, but the 6-12" interval does not. In this example, it is recommended to remove the top 6" of
contaminated soil and replace it with clean soil, or to place a 12" clean soil cover (cap). The goal is to
provide a minimum 12" barrier of clean soil when the underlying soil exceeds the action level. Please
refer to Section 6.3 for further explanation.
-------
41
The following describes the implementation of option 2:
• If the 0-1" horizon exceeds the clean-up level, a 12" soil cover and visual barrier should
be used;
• If the 0-6" or 1-6" horizon exceeds the clean-up level, a 12" soil cover and visual barrier
should be used;
• If the 6-12" horizon exceeds the clean-up level (but not the 0-1", 1-6", or 0-6"
intervals), a 6" soil cover should be used;
• If only the 12-18" horizon exceeds the clean-up level, no capping is needed.
The decision to perform soil cleanup to depths greater than 12 inches should be considered on a
site-by-site basis. Some advantages to full vertical soil cleanup are listed in Section 6.1. However, there
are many sites where lead contamination is located at depth. Full vertical soil cleanup may not be cost-
effective and/or feasible at such sites. The depth of excavation and soil cover thickness is an important
factor to be considered during the analysis of the nine criteria per the NCP (for Superfund sites) (EPA,
1990b). Potential for freeze/thaw upward migration, groundwater contamination, and the cost, extent,
and effectiveness of ICs are some of the factors to be considered in this analysis.
Sampling results obtained for residential lots may indicate that only a portion of the lot contains soil
that exceeds the selected clean-up level. For properties less than 5,000 square feet, the spatial scale for
the remedial decision should be one-half of the yard. For properties greater than 5,000 square feet, the
property should be divided into four quadrants and a remedial decision should be made for each quadrant.
It is usually protective to excavate only the portion(s) of the lot that exceed the clean-up level
(Figures 6-2a and 6-2b). However, removal of the sod layer and resodding/reseeding the unexcavated
portion(s) of the lot is strongly recommended to promote consistency in the vegetative cover of the yard
for homeowner satisfaction. When interpreting sampling results for a property, the sampling results of
surrounding properties should also be considered to lessen the probability of mislabeling the property as
being below the clean-up level, when it is actually above, and to avoid "patchwork clean-up" patterns,
which are prone to recontamination.
If the only portion of the yard that exceeds the selected clean-up level is the drip zone, the exterior
paint should be checked for lead content. If the drip zone contamination does not appear to be paint-
related, the drip zone should generally be cleaned up. If the drip zone contamination appears to be solely
paint-related, EPA should promote the remediation of the exterior LBP by local health agencies, other
local government agencies, state health agencies, and/or the homeowner. At a minimum, the resident
should be notified and informed of the disclosure requirements (Appendix A). Consideration should be
given to also notifying the relevant local government agencies and informing them about available
remedies, such as HUD grants.
-------
42
Soil concentration greater
than selected cleanup level
(remedial action required)
Soil concentration less than
selected cleanup level
(remedial action is not required)
.
'-
Residence
Back
Yard
V^Drip Zone
Figure 6-2a. Partial cleanup of residential lot less than or equal to 5,000 square feet in
size. In this example, the lead concentration measured in the front yard exceeds the selected
clean-up level while the concentration measured in the backyard does not. Cleanup may be
limited to the front yard although it is recommended that the sod layer in the entire lot be
removed to promote consistency in the vegetative cover on the property for homeowner
satisfaction. The entire drip zone should be cleaned up if the average lead concentration
exceeds the clean-up level. For example, in the above figure, the drip zone in the back yard
(as well as the front yard) should be cleaned up if the average concentration in the drip zone
exceeds the clean-up level. Please refer to Section 6.3 for further explanation.
-------
43
Soil concentration is greater
than selected cleanup level
(remedial action required)
Soil concentration is less than
selected cleanup level in
quadrants 2-4 (remedial action
is not required)
Drip Zone
Figure 6-2b. Partial cleanup of residential lot greater than 5,000 square feet in size. In
this example, the lead concentration measured in quadrant 1 exceeds the selected clean-up
level while the concentration measured in quadrants 2-4 do not. Cleanup may be limited to
quadrant 1 although it is recommended that the sod layer in the entire lot be removed to
promote consistency in the vegetative cover on the property for homeowner satisfaction. The
entire drip zone should be cleaned up if the average lead concentration exceeds the clean-up
level. For example, in the above figure, the drip zone in quadrants 2-4 (as well as quadrant
1) should be cleaned up if the average concentration in the drip zone exceeds the clean-up
level. Please refer to Section 6.3 for further explanation.
-------
44
6.4 OTHER CLEANUP CONSIDERATIONS
The area remediated on a single property normally should not exceed one acre. This limitation is
based on three factors: (1) typical lot sizes in residential areas throughout the country generally do not
exceed one acre; (2) the portion of a property where the majority of exposure to contaminated soil occurs
generally does not exceed one acre; and (3) EPA should generally not excavate/cover with soil the
entirety of very large yards due to cost-effectiveness considerations.
The goal for cleanup of a yard that exceeds one acre is to excavate or cap the portion of the yard
that is in frequent use and continue to limit exposure in the unremediated portion of the yard. To this end,
it is recommended that the unremediated portion of such a yard be fenced to clearly delineate the
remediated and unremediated areas and to limit the potential for off-site migration of contaminants (e.g.,
vehicle tracking). Exceptions to this general approach may include areas outside the one-acre area that
are used for recreation and gardening, areas with the potential for residential development, and areas in
close proximity to other residential areas. As stated in Section 6.5, any unremediated areas of a property
should be documented on the clean-up documentation letter for such property, and consideration should
be given to implementing ICs for those areas.
If contaminated soil is not removed to the full depth of contamination (i.e., where soil concentration
is greater than clean-up level) on a property, a permanent barrier/marker that is permeable, easily visible
and not prone to frost heave, should be placed to separate the clean fill from the contamination. This
applies to both incomplete vertical excavation with placement of a soil cover and placement of a soil
cover without excavating contaminated soil. Selection of an appropriate permanent barrier/marker should
be based on the type of contamination left in place, the chemical/physical characteristics of the soil (e.g.,
pH), the potential for upward migration of the contamination, and/or the types of ICs developed for the
site. Examples of suitable barriers/markers include snow fencing (usually orange), a clean, crushed
limestone layer, and geofabric.
Empty lots that are zoned residential and contain soils with lead concentrations greater than the
clean-up level should be cleaned up when in close proximity to other residential lots. Examples of this
are lots between two houses and lots that are near occupied lots. A site-specific determination should be
made for these situations. Also, unpaved lots used for vehicle parking should be sampled, and cleaned up
if necessary, or access restrictions put in place to prevent recontamination (e.g., vehicle tracking of
contaminants) even if no current direct exposure exists. However, it is not the intent of EPA to clean up
tracts of remote, undeveloped, lead-contaminated land that may be developed into residential lots in the
future. This clean-up responsibility should be borne by the land developer. Institutional controls should
-------
45
be developed to ensure safe development in these areas, since under CERCLA developers could be held
liable for improper cleanup.
6.4.1 Background Lead Concentrations
Many of the "Lead Sites" on the NPL are located in areas with high natural background lead
concentration. Often this problem is exacerbated by the presence of high background concentrations of
lead in various media (such as soil and groundwater) from anthropogenic sources such as automobile
emissions, mining, and smelting (the latter two sources would be considered 'background' if they are not
associated with the site). It should be noted that CERCLA 104 (a)(3) limits the Agency from taking
response actions to address "... naturally occurring substance in its unaltered form, or altered solely
through naturally occurring processes or phenomena, from a location where it is naturally found" (EPA,
2000a). Generally, under CERCLA, clean-up levels are not set below natural or anthropogenic
background concentrations (EPA, 1996c, 1997d, 2002). Cleanup below natural or anthropogenic
background concentrations is normally not performed because it is not cost-effective, it is technically
infeasible and there is a high likelihood of recontamination by surrounding areas that have not been
remediated (EPA, 2002).
Public education about ubiquitous risks should be incorporated early in the process to help the
community understand that Superfund actions are designed to address risks from specific releases to the
environment (EPA, 2002). In situations like these, it may be appropriate to examine land uses that limit
exposures through implementation of ICs. For more information on this approach, please refer to the
1998 Clarification to the Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective
Action Facilities (Appendix B). Site-specific factors should determine what range of alternatives and
what clean-up levels will achieve a protective remedy satisfying the nine criteria specified in the NCP.
Remedial decisions often involve a comprehensive response coordinated with other responsible
authorities, such as a local public health district, state departments of environmental protection, housing
agencies, and private parties. An effort should be made to identify other programs or regulations that may
have the authority and capability of addressing risks associated with high natural or anthropogenic
background (EPA, 2002). Additional guidance is available for developing a risk management-based
response strategy that is protective of human health and the environment (EPA, 1988).
-------
46
6.5 YARD CLEANUP SPECIFICS
It is important to define the limits of the properties that will be remediated. The use of property
lines rather than temporary features, such as fence lines, to delineate boundaries is recommended. The
use of temporary features may result in partial cleanup of some properties.
Whether remediation consists of excavation and placement of soil cover or just the placement of a
soil cover, consultation with the property owners is important to the development and implementation of
response actions and may necessitate property-specific deviations to the guidelines listed in this section.
Flexibility is essential to a successful residential lead clean-up program. Some residents may want to pay
for upgrades during the cleanup of their yard, such as paving a driveway after excavation, or to have some
yard features removed, such as taking out a damaged patio. Within reasonable limits, such requests
should be entertained on a yard-by-yard basis. Granting such requests can greatly contribute to building
public trust and satisfaction with the clean-up program. All additional costs associated with special
requests and considerations must be borne by the homeowner.
Prior to cleanup of a residential yard, access from the property owner should be obtained; access
obtained from tenants or renters is not sufficient. It is recommended that access be obtained by going
door-to-door. If residents are not home, a blank access agreement with instructions for signature and
submission to EPA, along with relevant contact information should be left at the residence (but not in the
mailbox). An example access agreement form is presented on page D-6 of Appendix D. As stated in
Section 4.2.1, it is suggested that access for remediation be obtained at the time access for sampling is
sought. Examples of combined sampling/remediation access agreements are presented on pages D-4 and
D-5. An example of a dust cleanup access agreement form is presented on page E-2 of Appendix E.
Many residents may refuse access for dust cleanup while granting access for yard-soil cleanup.
Combining dust access agreements with other access agreements is not recommended.
Prior to initiating clean-up activity, the condition of each property should be documented and
recorded on videotape. 'Clean-up activity' includes any disturbance of the property, including the
removal of debris and dilapidated structures that may be required prior to initiating the excavation of
contaminated soil. An example of a property inspection form is provided in Appendix F. EPA should
enter into a written agreement with the resident regarding any special requests or considerations in
cleaning up the yard, e.g., replacing concrete walkway with brick. All additional costs associated with
special requests and considerations must be borne by the homeowner. Any contaminated yard areas that
will not be cleaned up, special resident concerns, and any deviations from strict soil excavation or
capping should be noted on this agreement.
-------
47
Other possibilities for cleanup-related agreements include sod/lawn watering agreements. A sod-
watering agreement basically allows for payment to residents for watering the sod that is placed by the
remediation contractor. A payment is made before watering is required to cover the water bill and some
of the time involved. A second payment is made if, at the end of one month, the sod is in good condition.
A similar agreement should be established for maintaining lawns that have been initiated by
hydroseeding. This can be a useful incentive program that can also save money. The contract with the
remediation contractor should require the contractor to establish vegetation on each property, restore the
pre-construction drainage patterns on each property, and perform repairs for damages to the property.
Relocation of residents during yard soil remediation is rarely needed and is generally not
recommended (EPA, 1999b). (Guidance is available online at: http://www.epa.gov/oerrpage/superfund/
tools/topics/relocation/index.htm.)
Specific safety issues during residential yard cleanup, including ingress and egress to the home,
should be coordinated with the property owner/residents and spelled out in the Health and Safety Plan.
Incomplete barriers (such as rock or gravel) or minimal use areas (such as areas under porches),
which exceed the applicable clean-up level, should be cleaned up to the extent practical. Although
removal is preferred, if it is not feasible to clean up the area, a barrier, which effectively limits access,
should be constructed. For example, for areas underneath porches, typically the preferred barrier would
be shot-crete (sprayed concrete that can easily be placed in tight or confined areas). It may be preferable
to place asphalt rather than gravel on heavily-trafficked roads or driveways, especially those that
experience severe erosion.
In all cases, every attempt should be made to clean up the entire yard (subject to cost limitations
discussed below), however, any residential yard areas without permanent barriers that the resident
requests to leave unremediated, such as gardens or patios, should be sampled separately to determine if
the selected clean-up level is exceeded. If the clean-up level is exceeded and the owner refuses to allow
cleanup of that portion of the yard, then the clean-up documentation letter issued to the owner should note
the unremediated area.
The steps of a typical soil cleanup are shown in the text box below.
-------
48
Steps of a Typical Soil Response Action
Step 1 (Access Agreement) - Collect access agreement(s) from each owner and/or tenant before any
work is conducted.
Step 2 (Initial Survey) - Interview the resident(s) to determine if there are any specific problems that
need attention, and if there are any structures or property the owner wants to have disposed, stored, or
left untouched. The contractor will conduct a thorough documentation of the property using
drawings, digital photographs, and videotapes. Once documented, the owner is required to sign a
property agreement which documents any special requests or considerations in cleaning up the yard,
any contaminated yard areas that will not be cleaned up, provisions for structural concrete and fence
restoration, and deviations from strict soil excavation and capping.
Step 3 (Excavation) - Each tract is excavated by the contractor(s), who will also complete
documentation and provide depth confirmations.
Step 4 (Backfill) - After excavation of properties where full excavation to depth has been performed,
the excavated area is backfilled and compacted. After excavation of properties with a vertical
excavation limit, a permanent, permeable barrier/marker is placed in the excavated area. After
placement of the barrier/marker, the excavation area is backfilled and compacted.
Step 5 (Restoration) - Restoration of the property, including landscaping, sod/seeding, fencing, and
concrete (if needed) is conducted.
Step 6 (Final Inspection) - After restoration activities are complete, the EPA, PRP, or its agent
(e.g., Corps of Engineers) will conduct a final inspection.
Step 7 (Closeout Form) - A property closeout form should be signed by the property owner, which
documents the owner is satisfied with the remediation of the property. Any outstanding issues
between the EPA and the homeowner that have not been fully resolved should be documented in the
closeout form.
Step 8 (Clean Letter) - After the homeowner signs at property closeout form, the EPA issues a
"clean" letter, which documents the property has been remediated. Any areas that are not cleaned up
via the owner's request, such as gardens, should be noted in the "clean" letter. For properties where
contamination is not completely removed, the clean letter should also document the presence of
contamination at depth, and should describe the protective measures that were taken to prevent
exposure to the remaining contamination (i.e., barriers/markers).
-------
49
6.6 CLEANUP OF OTHER SOURCES OF LEAD
Lead in the environment can originate from many sources. In addition to soil, the main sources to
consider when performing clean-up activities are interior and exterior LBP, lead-contaminated interior
dust, drinking water, and occupational exposure resulting in subsequent contamination of homes.
Generally, sources other than soil, exterior paint, dust, and tap water cannot be remediated by EPA in the
course of residential lead cleanups.
Ultimately, the project managers should strive to address any unacceptable lead-exposure risks at
the residence. Sampling and the establishment of clean-up mechanisms needed to take action, such as
HUD grants for paint abatement, should be completed as early in the remedial process as possible. Even
so, it may not be possible to address all sources of lead in the ideal sequence. When this occurs, other
measures should be taken to minimize the potential for recontamination (i.e., to protect the remedy). For
example, if deteriorating exterior LBP is present, it is recommended that it be removed prior to initiating
any soil clean-up activities in the yard.
Due to transport of lead among media, the preferred sequence of lead clean-up activities at a
residence with LBP and lead-contaminated soil would be to clean up the paint first, then the yard soil, and
then the interior dust. Clean-up activities performed counter to this sequence increase the risk of
recontamination. For example, performing a soil cleanup first at a residence with exterior paint problems
increases the potential for recontamination of the soil from the exterior paint. Similarly, interior dust can
be recontaminated by interior LBP. Exterior sources have been shown to cause recontamination of the
interior when cleaned before community-wide yard cleanup is completed (EPA, 2000e). Accordingly,
project managers should make every effort to coordinate the sequence of clean-up activities to prevent
recontamination.
CERCLA and the NCP limit Superfund
Supplemental Environment Project (SEP) -
authority to address interior LBP (see Section 1.2)
(EPA, 1990b). If a mechanism exists for addressing
TTTTT^ _, , settlement of an enforcement action, but
the paint, such as a HUD grant or a Supplemental which ^ defendant/respondent 1S not
Environmental Project (SEP), then the timing of the
Environmentally beneficial projects which a
defendant/respondent agree to undertake in
otherwise legally required to perform.
paint encapsulation or abatement activities may not
coincide with the soil cleanup. Additionally, residents may be more reluctant to grant access for dust
remediation since it is more intrusive. On the other hand, EPA actions taken to address lead in drinking
water from site sources usually can be taken independently from any soil, dust, or paint cleanups, and
should be done as soon as practical.
-------
50
6.6.1 Lead-Based Paint
The 1998 Clarification presents OSWER's policy with respect to remediation of interior paint,
exterior paint, interior dust, and lead plumbing. Regarding interior LBP, the 1998 Clarification states:
"EPA has limited legal authority to use Superfund to address exposure from interior lead-based
paint. As a policy matter, OSWER recommends that such exposures not be addressed through
actual abatement activities. However, EPA Regions should promote addressing interior paint
risks through actions by others, such as HUD, local governments and health authorities, or
individual homeowners as a component of an overall site management strategy. Any activities to
clean up interior lead-based paint by potentially responsible parties (PRPs) or other parties should
not result in an increase of the risk-based soil clean-up levels" (EPA, 1998a; Appendix B).
Regarding exterior LBP, the 1998 Clarification indicates that the Regions should avoid using the
Superfund trust money for removing exterior LBP and soil contaminated from LBP. However, Superfund
dollars may be used to respond to exterior LBP to prevent recontamination of soils that have been
remediated, but only after determining that other funding sources are not available (EPA, 1998a;
Appendix B). The 1998 Clarification states: "As with interior lead-based paint abatement, EPA Regions
should promote remediation of exterior lead-based paint by others, such as PRPs, local governments, or
individual homeowners. Clean-up activities of exterior paint conducted by PRPs or other parties should
not result in an increase of the risk-based soil clean-up levels" (EPA, 1998a; Appendix B).
As a practical matter, project managers should inform each resident regarding the presence or
absence of LBP in their home, and options for encapsulation and abatement. The local health agency
and/or the state health agency should be informed regarding the availability of HUD grants for paint
assessment and abatement. Additionally, regarding PRP-funded cleanups, if any penalties are being
considered for non-compliance (Section 6.9), consideration should be given to allowing the PRPs to
perform a SEP for paint assessment and abatement in lieu of some or all of the penalty amount.
6.6.2 Interior Dust
Lead-contaminated interior dust can be derived from multiple sources, including exterior soil,
interior and exterior paint, homeowner hobbies, workplace, and other exterior sources; thus, it may be
difficult to differentiate between sources of dust contamination. Household lead dust contamination may
be a significant contributor to elevated blood lead levels, especially for younger children (under the age of
three), and may need to be evaluated in determining risks and clean-up actions at residential lead sites.
However, as pointed out previously, there are limitations on EPA's authority to abate these sources of
contamination to the extent they are not related to releases or threatened releases to the environment
(Appendix B).
-------
51
Based on the 1998 Clarification, OSWER recommends that Superfund monies should generally not
be used to take CERCLA response actions for addressing residential dust exposures due solely to interior
paint or other interior sources. However, Superfund monies can be used to address interior dust if it can
be shown to be derived from an exterior pollution source (e.g., air lead concentration caused by lead
smelter, mining, or mineral processing). Dust mat sampling, which was done at the Bunker Hill Site in
Idaho (EPA, 2000e), is one possible method of lead source identification; speciation, which is costly, is
another method. (Dust mats are used to measure dust lead concentration and loading rates in residences
and other structures.) Where interior dust is being addressed by other authorities, the recommendations
presented here may be helpful to guide the dust cleanup.
If the lead in interior dust is solely derived from interior paint, EPA should promote addressing
interior dust risks through the actions of others, such as HUD, state and local governments, PRPs, or
individual homeowners, as a component of an overall site management strategy. The overall site strategy,
as outlined below, should also consider the proper phasing/sequencing of actions to address the multiple
sources of lead risks at residential lead sites, as discussed at the beginning of Section 6.6.
The baseline risk assessment should document the relative contributions of lead uptake from all
relevant media including direct soil exposures and secondary exposures to soil in indoor dust.
Replacement of defaults with a site-specific value for the interior dust concentration, or the soil-to-dust
relationship (Msd), should be justified through the use of high quality, compelling, site-specific data (EPA,
1994b, 1998c). Dust sampling is preferred for risk assessment and remedial decisions, but dust modeling
may be needed to develop or refine soil action levels.
Lead-contaminated interior residential dust presents a significant exposure pathway that can readily
be addressed. Consequently, significant health benefit is gained by removal of contaminated interior dust
as early in clean-up activities as possible. However, exterior contamination sources present a threat of
recontamination to interior of residences (EPA, 2000e; TerraGraphics, 2001). Therefore, any interior dust
clean-up actions should be periodic throughout the project and should culminate in a final cleaning of all
residences exceeding an action level after the exterior sources have been remediated. As a practical
matter, risk management and reduction may need a phased strategy as recommended below:
Early-Phase Actions: Public awareness and health education efforts should be initiated
immediately. Entry way dust mats should be provided to residents.
HEPA-filter vacuum cleaners should be provided for use by residents. If
warranted, a program to abate interior lead-contaminated dust in homes
with acute levels should be initiated to provide temporary risk reduction.
-------
52
Establish appropriate public health partnerships with state and local health
departments, ATSDR, and HUD as early as practical.
Mid-Phase Actions:
The source of the interior dust lead contamination should be identified.
Monitoring of the changes in lead-contaminated dust (e.g., lead loading in
dust, lead concentration in dust, exterior-to-interior lead transport) should
be initiated. The public awareness/health education efforts and availability
of HEPA-filter vacuum cleaners for use by residents should be continued.
Assistance to remove and dispose of old carpets should be provided to
residents after yard cleanup has occurred.
Final-Phase Actions:
Once the exterior lead sources that were found to contribute to interior dust
have been addressed, the final step should consider the active remediation
of interior lead-contaminated dust. Actions may include: removal of
carpeting, cleaning heat and ventilation ducts, wet wiping hard surfaces
and soft surfaces (furniture, draperies, bedding, clothing, etc.). Most of
these actions should be limited to living spaces. Areas such as attics, crawl
spaces, and other non-living spaces need not be addressed unless they are
shown to be a continued source of contamination to the living areas . It is
important for dust remediation to be performed as the last phase in the site
clean-up process to minimize the risk of recontamination.
6.6.3 Lead Plumbing/Tap Water
The 1998 Clarification states: "Generally CERCLA does not provide legal authority to respond to
risks posed by lead plumbing within residential dwellings. It should be noted that the water utility is
responsible for providing clean water to the residences. As with interior dust, OSWER recommends that
EPA Regions coordinate with local agencies to establish a health education program to inform residents
of the hazards associated with lead plumbing and how to protect themselves by regularly flushing, or
preferably, replacing lead pipes. Soil clean-up levels should not be adjusted to account for possible
remediation of lead plumbing" (EPA, 1998a; Appendix B).
With regard to tap water, it should be sampled, and lead levels in the purged sample in excess of the
maximum contaminant level (MCL) established by the Safe Drinking Water Act should be addressed. In
general, lead concentrations in the purged sample greater than a removal action level (RAL) of 30 • g/L
should be addressed through TCRAs; concentrations between the MCL and RAL should be addressed
through NTCRAs or long-term remedial actions. Actions that could be taken include provision of bottled
-------
53
water, connection to a municipal water supply, tap filtration, and installation of deep wells (in remote
areas and where shallow groundwater is contaminated). Regarding first run exceedance for lead, the
homeowners should be notified that they may need to address a plumbing or corrosion problem, which is
outside of the scope of Superfund.
6.7 PREVENTION OF RECONTAMINATION
Project managers should take steps to mitigate recontamination. During site closeout and five-year
reviews, the project manager should also check for recontamination at levels which may threaten the
remedy.
At many large-area lead sites, cleanup occurs over a long period of time and through multiple
phases, throughout which the potential for recontamination exists. During each of these phases,
windblown dust sources, vehicle tracking, flooding, and other mechanisms can recontaminate previously
cleaned areas. Although best management practices (BMPs) should minimize the movement of
contaminated material from each residence being cleaned, vehicle tracking of contamination from areas
yet to be cleaned up can significantly raise concentrations of contaminants in cleaned areas. During the
early phase, typically an emergency response action, cleanup is focused towards Tier 1 properties, and
cleanup favors a "hop scotch" approach to address the worst risks first. This method of remediation can
result in recontamination of clean properties. Confirmation samples should be collected in any areas that
have been potentially recontaminated.
Another aspect of large-area lead sites is that complete cleanup of residential properties does not
always take place for a variety of reasons (see Sections 6.2 and 6.4); instead a barrier or soil cover is put
in place over contaminated soils. Flooding can pose a serious problem for these areas in that flood waters
can erode away clean materials leaving subsurface
contamination exposed, and entrained sediments
Best Management Practice (BMP) - In
general, BMPs are a combination of practices
that are determined to be the most effective
and practicable means of controlling point
and nonpoint pollutants at levels compatible
with environmental quality goals. In this
document, BMPs specifically refer to
measures taken during construction activities
on properties where contamination has been
left at depth to prevent the transfer of those
contaminants to other media.
bearing contamination may be left on top of newly
remediated properties. Inadequate drainage of runoff
can move lead into cleaned areas (e.g., lead particles
on a crowned road with no curb and gutter may be
rinsed onto adjacent residential properties with
normal rainfall). Additionally, the activities of
burrowing animals can bring contaminated soils to
the surface.
-------
54
Recontamination of clean soil cover can be caused by ongoing homeowner projects, such as
digging a hole through a clean barrier to install fence posts or a new tree or shrub, if preventative
measures are not taken. Education and licensing of contractors who work on clean barriers/markers
should generally be required (e.g., as part of a local ordinance) to ensure the longevity of the remedy.
Also, at many sites (e.g., Bunker Hill), ICs have been most effective when linked to the "call before you
dig" program typically operated by many counties to avoid disruption of utility service. In addition, large
scale residential development projects that may raze old housing in favor of new will frequently
recontaminate areas where lead-contaminated soil was left at depth, without appropriate BMPs in place.
BMPs include silt fences, hay bales, etc., to limit movement of contamination off a project site, and
stockpiling of contaminated soil on atarp to prevent contamination of underlying soil (Figure 6-3). EPA
provides guidance on the implementation of BMPs in construction activities at sites where contamination
is present (EPA, 1997e). Best management practices typically add about 5 percent to project cost
(TerraGraphics, 2000). Periodic inspections of residential areas should be performed by the local
government to ensure that projects within the site are implementing BMPs.
Wind blown dust can pose a significant threat to the health of individuals at a site and can cause
recontamination. Tailings impoundments that have dried can be large sources of windblown lead dust.
Most tailings impoundments are large; a wind sweeping across the face of one can carry substantial
amounts of contaminated dust and then deposit these particles on a downwind residential area, both
causing increased exposure to contaminants, and recontaminating clean areas. Wind blown dust sources
are typically a key issue to be addressed early in the sequencing of site activities to minimize this
migration.
These are but a few examples of how recontamination can be an ongoing problem that needs to be
considered at every site during each phase of cleanup. Although mechanisms vary from site to site, the
types of response actions put in place and the sequence in which these actions take place can play a
significant role in enhancing the permanence and effectiveness of a remedy.
A disposal area may be needed to dispose of contaminated soil from the site to support typical
homeowner projects, as some municipal landfills may not accept contaminated soil. Without free or low
cost disposal for contaminated soil available to each homeowner and renter, improper disposal is more
likely, which would result in recontamination. In addition, a disposal area may be needed if certain
materials at a site, such as carpets, fail TCLP and cannot be commingled with solid waste. It may even be
appropriate for the remedy to provide free removal of contaminated soil and provision of clean soil to
homeowners (but contractors may be required to pay for these services, or obtain material from approved
sources) to encourage maximum compliance and further ensure the longevity of the remedy. The
-------
55
Silt Fence
Fence Post Hole
6" of Clean Back Fill
Barrier
Contaminated Soil
SUt Fence Trench
Clean Soil ^ Covered Contaminated Soil
onlarp
Figure 6-3. Implementing Best Management Practices (BMPs) during construction work. The best
management practices (BMPs) shown in the above figure (e.g., a clean soil barrier) represent one
component of the ICs which may be put in place by local ordinance to ensure the long-term
protectveness of the remedy and to prevent recontamination. The purpose of BMPs is to minimize the
potential for accidental exposure of humans during construction and maintenance activities on sites where
wastes have been left in place. The staging of contaminated soil on tarps and/or in small buckets, and the
installation of silt fences downgradient of the construction area are examples of BMPs intended to prevent
the migration of contaminated material from the construction site. Please refer to Section 6.7.3 for further
explanation.
maximum concentration of lead (and perhaps other constituents) allowed in "clean" soil, and the required
sampling frequency, should be specified in an 1C.
Over the long term, cleanups may not be possible at every property at the same time. A trust fund
should be established for the site for the cleanup of properties that are deferred for various reasons, which
should be implemented by the local government. In this manner, changes in property ownership over
time may be more closely monitored to determine when cleanup at deferred properties might be
appropriate (see Section 6.9). Local implementation of the trust fund will ensure that cleanup of these
properties occurs as soon as possible, further ensuring the protectiveness of the remedy, further ensuring
the protectiveness of the remedy by minimizing the potential for recontamination to the extent possible.
-------
56
6.7.1 Early Actions
Early response actions (including cleanups for sensitive subpopulations) can be an essential
aspect of the response action at a site, as discussed above. These actions should be conducted
simultaneously with source area control. The following are considerations that may reduce the potential
for recontamination when scoping an early action.
• Seek permanence in selecting the clean-up alternative(s), if possible, such as complete removal
to depth of soil contamination at properties where there is an acute risk.
• Consider cleanup of adjacent properties simultaneously that may threaten the permanence or
effectiveness of the early action.
• Control fugitive dust sources, access, tracking, and erosion of contaminants to the extent possible.
• Perform HEPA street sweeping to minimize tracking of contaminants throughout a community.
• Evaluate the feasibility of conducting the cleanup of residential areas in their entirety during the
early removal phase if contamination is widespread. If this is not possible, limit the early
removal actions to immediate risks (Tier 1 and Tier 2 residential properties, including residences
with elevated blood lead levels) in order to minimize the potential area where recontamination
might occur.
• Provide informational fact sheets to homeowners on how to minimize recontamination on their
property.
• Establish an 1C to manage cleaned areas. This could involve local and state government
agencies, and PRPs that are available to recommend best management practices for homeowner
projects and provide education to the homeowner, as well as utility districts and companies likely
to breach the barriers/markers put in place.
• Provide site plans or other documentation of areas that have been cleaned up, as well as
information on areas that are still contaminated, to the local governmental entity responsible for
the maintenance of the remedy, i.e., for monitoring ICs and for tracking properties over time.
• Establish a geographic information system (GIS) for monitoring ICs and properties.
-------
57
6.7.2 Long-term Remedial Action
Some or all of the following measures may be useful to address the risk of recontamination
during the remedial action (Tiers 2 and 3, if a tiered approach is used) and post-design phase:
• Evaluate the permanence and effectiveness of the various remedial actions under consideration.
Consider the economic feasibility of complete contaminated soil removal to minimize reliance on
ICs.
• Conduct a cost analysis comparing the cost of long term ICs to those of complete removal (EPA,
2000f). For example, property depreciation, tax base impact, additional procedures/cost of utility
work, flooding complications/costs, and long term 1C administration cost should be taken into
account when comparing the cost of a partial removal of contaminants to a complete removal.
Property depreciation, while possibly subtle for each property, may add up to substantial losses
for the entire community in reference to a county tax base. Also, losses for an individual property
over a lifetime of sales could add up to a significant cost. Following cleanup, increases in
property valuation from source removal or drainage/infrastructure enhancements (and savings/in-
kind services to municipalities) should be considered.
• Remedial action should strive to remediate the contamination in the community by segregable
areas, such as a town, or a divisible segment of town. Each segregable area should be cleaned up
as quickly as possible (e.g., within one construction season) to minimize recontamination of
cleaned properties and to compound the protection to human health (EPA, 2000e). Each
community should be cleaned up block by block within these segregable areas, utilizing BMPs to
mitigate tracking of contaminants. Site experience suggests that cleanup of up to 800 properties
per site per year is possible.
• Fugitive dust that may be a source for recontamination, and access to such sources should be
controlled. Air monitoring along with depositional modeling may be necessary to determine if
windblown dust presents a significant threat of recontamination. Significant sources of
windblown dust should be controlled prior to or simultaneously with cleanup of adjacent
residential areas. Consider HEP A street sweeping during remediation and immediately following
completion of cleanup to minimize tracking of contaminants throughout a community.
• Complete removal of contaminants should be considered in flood prone areas or areas with a high
groundwater level due to the inherent difficulty in maintaining a soil cover remedy in a flood
prone area. Drainage-ways containing contamination within their 100-year floodplain, which are
-------
58
not addressed in the remedy could also lead to remedy failure if the contaminants are eroded to
other areas.
• Remediation of contaminated rights-of-way should occur within segregable areas simultaneously,
if possible, or as close together in time as possible to minimize vehicle tracking and
recontamination of driveways from the rights-of-way.
• Control measures for all remaining sources, such as mining waste piles surrounding the
community, should be developed to ensure the remediated neighborhoods are kept clean. ICs
should be established to ensure the control, or proper use and disposal of any wastes remaining on
site.
• If the residential remedy includes replacement of soils, removal of deteriorating exterior LBP
(e.g., by pressure washing) should be considered to minimize the soil recontamination potential.
• Other sources of residential property recontamination should also be considered. For example,
homeowners may bring in contaminated soil for fill or other uses on their property.
• Establish permanent funding for ICs. Unless all contaminants are removed, some level of ICs
may be necessary. Early establishment of a program is the key to success of a remedy that
consists of a partial removal of contaminants.
6.7.3 Institutional Controls (ICs)
EPA defines ICs as administrative and/or legal mechanisms that: (1) help minimize the potential
for human exposure to contamination, and (2) protect the integrity of the remedy. ICs accomplish these
objectives by directly limiting land or resource use, and/or by providing information that modifies
behavior. ICs are used throughout the remedy pipeline, including (1) when contamination is first
discovered (i.e., prohibition of excavation of newly discovered soil contamination), (2) when the remedy
is ongoing (i.e., restrictions on property use until clean-up levels are met), and (3) when hazardous
substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and
unrestricted exposure.
At sites where minimizing exposure is the primary purpose of the 1C, it is EPA's policy that if a
site cannot support "unlimited use and unrestricted exposure" (EPA, 2000f), ICs are generally required.
The "unlimited use and unrestricted exposure" threshold is a site-specific determination similar to that of
a five-year review. Essentially, if contamination could result in an unacceptable exposure, ICs would be
-------
59
required. This is often the case at lead cleanups because residual contamination is frequently managed
onsite. Note that the term "residential" is often used interchangeably with the "unlimited use and
unrestricted exposure" threshold but these are not synonymous terms. For example, a lead cleanup where
the top layer of soil has been removed and replaced can result in a residential use at a site that includes
restrictions (e.g., restrictions on digging, requirements for elevated gardens, and an information/outreach
program, etc.).
The second common purpose of an 1C is to protect the integrity of a remedy. In the lead clean-
up context this may mean using institutional controls to prevent penetration of a cap or damage to
monitoring equipment. An important consideration in this context is what type of 1C will provide the
required remedy protection. For example, the primary concern for protecting a remedy in a lead clean-up
scenario is typically uncontrolled excavation. For this reason it is important to select ICs that will be
relevant to excavators. Examples of potentially effective ICs are local digging or drilling permits and
"One-Call" or "Miss Utility" systems. Examples of potentially ineffective ICs are deed notices, because
excavators seldom check land records prior to digging.
To better understand the correct 1C approach, it is important to understand what tools are
available. In general, there are four categories of ICs commonly used in cleanups: governmental controls,
proprietary controls, enforcement and permit tools with 1C components, and informational devices. The
definitions provided below were taken in large part from the current EPA guidance (EPA, 2000f).
Governmental controls are usually implemented and enforced by a state or local government.
Some of the more common examples include things like zoning restrictions, building/excavation permits,
groundwater drilling and use permits, ordinances, or other provisions that restrict land or resource use at a
site. These types of mechanisms are popular in remedies because the administrative processes are in
place and are typically well understood within a particular jurisdiction. The greatest concern with this
type of control is that it is often implemented, monitored, and enforced by an agency other than EPA or
the state.
Proprietary controls are unique in that they have their basis in real property law and that they
generally create legal property interests. An example of this type of control is an easement that provides
access rights to a property so that an agency may inspect and monitor a cover system. A proprietary
control may also be used to restrict certain activities on the property, such as excavating below a certain
depth. These are powerful tools in that they can be made to "run-with-the-land" (i.e., effective if
ownership changes), but they provide significant challenges because property interests are often
transferred. EPA is limited by CERCLA §104(j) with regard to acquiring interests in real property. Prior
to acquiring an interest in real property the state must provide an assurance that it will accept transfer of
-------
60
of tools is that EPA or states can directly enforce
them (rather than relying on a local agency for
governmental controls or using real estate common
law for proprietary controls). The major weakness is
that interest at completion of the remedial action. This requirement applies at both Fund-lead and
enforcement-lead sites. Therefore, if a proprietary control involves the transfer of an interest in real
property, EPA must obtain this assurance and find an appropriate entity to hold the interest following the
remedial action. At Fund-lead sites this will most likely be the state. At enforcement sites, it may be the
state, a PRP, or some other interested and qualified party. In addition, proprietary controls are based on
state law, and EPA and many state environmental agencies have limited real estate or common law
experience. This can complicate proprietary control enforcement.
Enforcement and permit tools with 1C components under CERCLA Sections 104 and 106(a)
include unilateral administrative orders (UAOs) and AOCs, which can be issued or negotiated to compel
the land owner to limit certain site activities at both federal and private sites. In addition, CERCLA
122(d) authorizes the use of consent decrees at
privately-owned sites. Enforcement devices are some
r .1 T/^ -n * ii r ii Unilateral Administrative Order (UAO) -
of the more common ICs. The strength of these types TT71 „_.. . .,„.,/
When EPA negotiates with a Potentially
Responsible Party (PRP) to do cleanup work
at a Superfund site, the agreement may be
documented in an administrative order on
consent (AOC). If the negotiations fail, EPA
has the authority to compel the PRP to do the
. . i r i i i -i cleanup by issuing a unilateral administrative
that they may be enforceable only against the , /TTArk\ AJi • • * *• j
J J J & order (UAO). Administrative orders are
signatory, recipient, or permitee (i.e., may not run issued under CERCLA sections 104 and 106.
with the land to bind future property owners).
Informational devices are types of devices that only provide information or notification that
residual or capped contamination may remain on-site. These types of tools are common at lead cleanups
to both provide notification of residual contamination and to provide information that may modify
behavior to minimize the potential for unacceptable exposure. Examples include placing a property on a
state contaminated properties registry, developing deed notices, and providing periodic lead-education
advisories to residents. Due to the nature of informational devices and their non-enforceability, it is
important to carefully consider the objective of this category of ICs. Informational devices are most
likely to be used as a secondary "layer" to help ensure the overall reliability of other ICs.
There is typically an inverse relationship between the amount of cleanup and the degree of
reliance on ICs (i.e., the more cleanup, the less reliance on ICs). EPA tends to focus on a number of
considerations when evaluating the long-term viability and amount of redundancy required for ICs at a
particular site. EPA guidance strongly advocates the use of ICs in "layers" and/or in "series" (EPA,
2000f). Layering ICs means using multiple ICs concurrently (e.g., a consent decree, deed notice,
educational/informational devices and a covenant). Using ICs in series is appropriate when 1C
-------
61
mechanisms are removed or changed as site circumstances change, such as reduction in restrictions during
the clean-up life-cycle. As illustrated in the descriptions of the different categories of ICs, there are
inherent strengths and weaknesses with each type. The goal is to obtain the best mixture of ICs to
manage the risk at a site over the long-term. There are many important factors to consider when
determining how many ICs are required at a site. The following is not intended to be a comprehensive
list, but rather illustrative of the site-specific nature of these types of decisions. A few common
considerations include: (1) the type of enforcement mechanism used (consent decree, order, permit,
ordinance); (2) who will enforce the mechanism (i.e., EPA, the state, local agency, third party, etc.);
(3) who the intended 1C will effect and how; (4) the level of sophistication of the party implementing the
cleanup and those remaining on the property; (5) the expected property use (likelihood of redevelopment
and/or resale); and (6) the degree of cooperation exhibited by the parties to the cleanup. Since ICs can
impact future development at sites, it is important to work cooperatively to determine the appropriate mix
of ICs. The objective is not to use as many layers of ICs as possible, but rather to strike a balance that
gives the regulators the certainty that the site remedy will be protective over time while maximizing the
site's future beneficial use.
At many large lead sites, GIS systems are used to track the cleanup status of properties located on
the site. The tracking system facilitates the monitoring of ICs and the maintenance of the remedy. GIS
systems can be operated by local governments, state governments or PRPs.
6.8 CLEAN-UP DOCUMENTATION
Upon confirmation that initial yard sampling indicates a given residential yard does not exceed
the lead clean-up level for the site, or upon the completion of the cleanup of a residential yard, a letter
("clean" letter) should be sent to the property owner documenting that EPA considers the lead level in the
yard to be below the level of human health concern. Prior to issuing a "clean" letter, a property closeout
form should be signed by the property owner, which documents the owner is satisfied with the
remediation of the property. Examples of property closeout forms are proved in Appendix G. Any areas
that are not cleaned up via the owner's request, such as gardens, should be noted in the "clean" letter. If
contamination is not cleaned up to depth, this fact, along with protections (i.e., barriers/markers) that are
put in place, should be stated in the "clean" letter. The "clean" letter provides official documentation to
the property owner for use in future property sales or transactions. Sample "clean" letters are provided in
Appendix H.
-------
62
6.9 ENFORCEMENT
The project manager should strive to characterize all residences within the identified zone of
contamination, and achieve cleanup at all residences where lead concentrations exceed the clean-up level.
At all residential clean-up sites, a percentage of homeowners typically will refuse to grant access to EPA
for sampling and/or for cleanup. In order to meet remedial goals of protecting a community, all
residences suspected of being located within a zone of contamination should be sampled. It is important
to work with the landowner and be sensitive to a landowner's concerns regarding property access. The
project manager should educate the landowner of the dangers that lead contamination may pose. If a
landowner still refuses to grant access, the Region should consider issuing an access order for sampling
(EPA, 1990c).
An owner of residential property on a Superfund site may be potentially liable under
CERCLA § 107(a)(l). However, EPA, as an exercise of enforcement discretion, generally will not take
CERCLA enforcement actions against an owner of residential property unless the residential
homeowner's activities lead to a release or threat of release of hazardous substances resulting in the
taking of a response action at a site. (See Policy Towards Owners of Residential Property at Superfund
Sites (July 3, 1991)). Additionally, under CERCLA a residential property owner may qualify for
protection from CERCLA liability as a contiguous property owner, bona fide prospective purchaser, or
innocent landowner. Under both the statute and EPA's policy, a residential property owner is expected to
cooperate with EPA and the person taking the response action. This obligation includes providing access
and information as requested, agreeing to comply with land use restrictions relied on in connection with
the remedy, and not impeding the effectiveness the effectiveness or integrity of institutional controls.
(See CERCLA §§ 101(40)(B)-(H), 107(q)(l)(a), 101(35)(A)-(B)). The project manager should work to
inform and educate an owner of EPA's expectations for cooperation in connection with the remedy. If
necessary, to meet the commitments of the remedy, EPA should consider taking appropriate steps, such as
issuing a UAO, to secure the cooperation of an uncooperative landowner.
-------
63
If some properties are not
addressed under site response actions
(e.g., current homeowners with no young
children or women of child-bearing age),
then consideration should be given to
establishing a trust fund (under state
authority or local law), to be administered
by a local government, for the cleanup of
the property at a future date, when the
property is transferred (e.g., by sale) to a
new owner (see text box). Buyers of
contaminated properties could make use
of the fund to have the property cleaned
up at their discretion.
Example Trust Fund - At the Bunker Hill Superfund Site,
a number of property owners refused to have their
residential yards cleaned up. Without any obvious need
to cleanup the property right away, e.g. an unpaved,
contaminated driveway that threatens to recontaminate
the neighborhood or a child living at the residence or next
door, the PRPs for the site were willing to give the State
funds to set aside in an interest bearing account to clean
up the properties in the future, when the property changes
hands. Property status is then monitored by the local
Health District as part of the institutional controls
program. The State then manages the funds to ensure
maximum interest accrual in an irrevocable trust and
disbursement according to the limitations set up in the
trust ~ for residential property cleanup. Cleanup then
occurs under State oversight at the time new owners buy
the property thereby ensuring families with children that
move into the community are protected.
In the case of rental properties, EPA should order access for cleanup by UAO to all owners of
contaminated rental property who refuse access. To ensure the protection of occupants, enforcement of
the UAO may be necessary to clean up all rental properties with contamination greater than the clean-up
level.
-------
64
7.0 FIVE-YEAR REVIEW
CERCLA §121(c) requires an assessment of
Five-Year Review - Pursuant to section 121
of CERCLA and the NCP, remedial actions certam remedial actions every five years on sites
which result in any hazardous substances,
and unrestricted exposure need to be reviewed
every five years to ensure protection of human
where contamination has been left on site (EPA,
pollutants, or contaminants remaining at the ™™ \ ^ •, c i *.- c
. , , , , ,, r i- • i 2000a). Lruidance tor conducting tive-year reviews
site above levels that allow for unlimited use
has been issued (EPA, 2001h). The purpose of a
five-year review is to evaluate the performance of a
health and the environment.
remedy to determine if the remedy continues to be
protective of human health and the environment.
Typically, at large lead sites, such as mining and smelting sites, the volume and areal extent of
contamination is such that total removal of all contamination above the health-based risk level is
economically impractical. Contaminated wastes are generally left on site and covered with soil. The
remedy for these types of sites typically includes some type of 1C to address residual or encapsulated
contamination. A five-year review can determine whether the remedy is stable (i.e., soil covers are
undisturbed, and clean areas are not being recontaminated from sources remaining on the site). The
review should also assess the ICs that were established for residual source control to determine their
effectiveness in protecting human health. As described below, the five-year reviews at large lead sites
may involve the collection and evaluation of substantial quantities of data and require significant up-front
planning. Much of the following discussion may not apply to small sites.
At many sites, an exposure study has been performed prior to any clean-up activities to determine
blood lead concentrations of children in the community. A follow-up exposure study of residents should
be conducted during the five-year review to determine if the concentrations have decreased below levels
of concern. If the blood lead concentrations have not decreased to acceptable levels, additional
environmental studies and individualized, follow-up exposure investigations should be conducted to
determine the pathways of exposure that may need to be addressed. Long-term exposure studies can be
very useful in understanding exposure trends at a site. They also can be useful to ensure that no pathways
of exposure have been missed and to help identify areas of the site that have been recontaminated. In this
manner, the project manager can use health data as a means to "double check" the effectiveness of the
remedy and to corroborate environmental data. However, blood lead data from limited sampling should
not be used as the only metric for gauging the success of a remedy, even if it can be used to identify
specific problems. The project manager should coordinate with ATSDR and the local health district with
respect to planning and funding such a program.
The five-year review should include resampling at a percentage of each type of property that was
remediated during the clean-up actions. A baseline level of resampling should be designed to achieve a
-------
65
pre-specified level of statistical significance and power. This sampling should assess the potential for
recontamination that may be occurring, and may help identify any pathways that may have been missed
during remediation. Any sampling that indicates widespread or clusters of soil levels above clean backfill
concentrations should be monitored over time to determine if an upward trend exists that may jeopardize
the remedy.
Additionally, some level of house dust sampling should occur to determine if levels are rising or
falling. House dust, being a primary exposure pathway, should be used as one indicator of remedy
effectiveness and also used to detect the presence of recontamination. Lead concentrations in house dust
levels often correlate to interior LBP, which is not usually addressed by Superfund (Appendix B).
Therefore, interior paint sampling should also be conducted as a component of the risk assessment to aid
in determining the source of the lead loading to dust.
At large lead sites, remedy protectiveness issues will often relate to the implementation and
management of ICs and recontamination of areas previously cleaned. The five-year review should
evaluate the effectiveness of the site ICs and recommend corrections to address any deficiencies that are
identified. In order for a five-year review to be effective at sites where ICs are a component in ensuring
the effectiveness of the remedy, there should be: (1) clear documentation of the specific type of ICs that
were to be implemented, and (2) accurate and complete tracking of subsequent activities and changes in
property use following completion of the Superfund remedy.
The following are possible deficiencies for several types of commonly-used ICs and other control
measures taken to ensure the protectiveness of the remedy:
• HEP A vacuum loan program not being broadly used.
• Information on interior home cleaning not being widely distributed.
• Lack of access control along rights-of-way, and in unremediated areas.
• Inadequate decontamination of vehicles leaving areas of existing contamination.
• Erosion of unremediated areas onto remediated properties.
• Lack of or inadequate disposal area for snow (that contains contaminated soil).
• Lack of drainage infrastructure and maintenance by local entities.
• Uncontrolled utility excavation in areas with contamination at depth.
• Inadequate road maintenance in areas where contamination exists at depth.
• Inadequate disposal capacity to handle IC-generated wastes.
• Discontinuation of, or diminishing, health education program.
• Decrease of blood lead monitoring.
• Complicated/unfounded ICs and/or change in local government acceptance of ICs.
-------
66
8.0 FEDERAL FACILITIES
The purpose of this section includes the following: (1) to provide direction to EPA federal facility
project managers who oversee response actions involving lead contamination of soils from LBP in
residential areas of federal facilities; (2) to build and elaborate on the joint March 1999 EPA and DOD
Principles Memorandum (DOD/EPA, 1999a) and the December 1999 Lead-Based Paint Interim Field
Guide (DOD/EPA, 1999b); (3) to address situations where the DOD service component will conduct the
response actions and the regulatory agencies will provide oversight; and (4) to address the unique
considerations that arise when the federal government transfers LBP-contaminated property that is subject
to CERCLA §120(h) to non-federal parties (e.g., states, local governments, local reuse authorities
[LRAs], and private entities, etc.).
While existing policy, guidance, and directives on lead contamination are applicable at federal
facilities, property transfer issues present unique requirements that necessitate this section. This section
applies to properties that will be transferred for residential use which are contaminated with lead due to
LBP or to properties/parcels whose use would expose sensitive populations (e.g., infants, toddlers, small
children, nursing mothers) to unacceptable exposure to lead after the properties are transferred to non-
Federal entities.
Beginning in 1995, EPA and DOD began to address policy differences on the clean-up levels for
lead in soils from LBP. In 1998, Sherri Goodman, then Deputy Under Secretary of Defense
(Environmental Security) and Tim Fields, Assistant Administrator for OSWER, reached agreement on the
management of LBP at residential and non-residential areas at BRAC properties. In March 1999, this
agreement was formalized as the 'Principles Memorandum' (DOD/EPA, 1999a). The Principles
Memorandum stated that for residential areas located on BRAC sites, Title X procedures provide an
efficient, effective, and legally adequate framework for addressing LBP in residential areas, and that as a
matter of policy, CERCLA/RCRA would apply in limited circumstances. EPA and DOD agreed that
generally for residential areas that were being transferred, Title X regulations would apply and that
CERCLA/RCRA would apply in limited circumstances. Residential real property is defined by Title X as
real property on which there is situated one or more residential dwellings used or occupied, in whole or in
part, as the home or residence of one or more persons. It is important to note that Title X defines
residential property differently than the Handbook.
For federal property transfers subject to CERCLA where there is a concern about lead
contamination to soils from LBP, EPA Regions, where they are involved, will need to make a
determination whether the property meets the requirements of CERCLA §120(h)(3). This section of
CERCLA outlines deed requirements for transferring property and requires covenants indicating that all
-------
67
remedial actions have been taken at the site. Federal property contaminated with lead from LBP should
be evaluated based on its use, or its intended reuse, before the property has been sold or transferred to
another private entity. EPA's evaluation of the transfer should be based on an evaluation of lead
contamination by either relying on existing and available information gathered through a combination of
file searches and a review of existing data and/or a site risk assessment, which may require the collection
and analysis of additional soil samples.
The soil sampling design should be specific to the site. The actual or suspected presence of lead
contamination in soil does not necessarily require sampling. Factors to be considered before designing a
sampling plan include, but are not limited to, the nature of the facility's operations, its operating records,
the age of the buildings/structures under consideration, the maintenance schedule for the
buildings/structure, visual inspection, and future use. Based on these factors, it may be reasonable to
conclude that the potential risks posed by lead may be acceptable and no further evaluation is needed. It
may also be important to consider the ultimate disposition of the property once it leaves federal control.
For example, the structures may be scheduled to be demolished, so that the abatement of the hazard may
be addressed in the demolition process and may negate the need to conduct clean-up activities.
The EPA project manager and, as appropriate, an EPA risk assessor should work with their
federal, state, and local government counterparts to develop a sampling design, where required, that
would be scientifically appropriate, minimize the cost of sampling, and provide the information required
for risk management decisions. As appropriate, the local redevelopment or reuse authority should be
consulted as well. Information from the sampling effort could result in different outcomes: a "no further
action decision", a conclusion that more extensive sampling is necessary, or, in some cases, a response
action. All of these potential outcomes should be discussed with the lead federal agency, and others as
appropriate, prior to the initiation of sampling.
If there is insufficient knowledge to make a conclusion about the risk at the site or if the initial
sample results indicate an unacceptable risk from lead, data may be collected by a focused sampling of an
environmental media to develop an improved understanding of the risk that may be posed by the lead
exposure. It may be appropriate to determine that after visual inspection and/or focused sampling, and
after consultation with an EPA risk assessor, the lead from the area may not pose a significant risk that
requires further evaluation. Risk evaluations should be based upon a number of factors including the
reasonably anticipated future land use, exposure potential, ICs proposed or in place, and bioavailability.
The Handbook user is encouraged to obtain detailed information on ICs for federal facilities in the
document "Institutional Controls and Transfer of Real Property under CERCLA Section 120(h)3(A), (B),
or (C)" (EPA, 2000g).
-------
68
If the property has been used or will be reused as residential real property after transfer, the EPA
project manager should verify that the lead federal agency has followed the Title X regulations and
policies regarding sampling and risk assessment. As a guide to assist site managers in understanding Title
X regulations and policies, EPA and DOD jointly issued a Field Guide (DOD/EPA, 1999b) that is used
by EPA and DOD field personnel when assessing hazards due to LBP. The field guide contains
information on performing a Title X paint inspection and risk assessment and outlines the requirements
for abating soil contaminated by LBP
The Title X program, through the implementation of the new Title IV of TSCA, establishes
certification programs and work practice standards to regulate LBP hazard evaluation and abatement in
target housing and child-occupied facilities. There are two types of evaluations covered by Title X. The
first evaluation is a paint inspection that includes a surface-by-surface inspection to determine the
presence of LBP. All painted surfaces with distinct painting histories are sampled. Usually the paint
inspection is done by a combination of portable XRF devices and paint chip sampling.
The second evaluation is a risk assessment to determine if LBP hazards exist. A risk assessment
includes taking samples of all deteriorating paint, dust, and soil. The final report recommends methods to
deal with all LBP hazards that were found, which could include interim controls or abatement. A
comprehensive evaluation consists of a combination of a paint inspection and risk assessment. Paint
inspections and risk assessment conducted in accordance with Title X must be performed by certified
personnel. All results, whether positive or negative, must be disclosed at the time of sale or rental.
The final TSCA 403 regulation (EPA/HUD, 2001), defines a soil-lead hazard as bare soil on
residential real property, or on property of a child-occupied facility, that contains concentrations of lead
equal to or exceeding 400 ppm in the play area or an average of 1,200 ppm in the rest of the yard. EPA
and DOD have agreed that as a matter of policy, for bare soil with lead concentration between 400 ppm
and 1,200 ppm, the Service, in consultation with the EPA, has the option of abatement or interim controls.
Based on the final HUD 1012/1013 regulations (24 CFR Part 35) (HUD, 2001), federal agencies can
transfer the control and abatement requirements to the purchaser, but by law the federal agency is
responsible for performing the LBP inspection and risk assessment and must assure that through
contractual mechanisms, the purchaser has performed the abatement of the soil in accordance with
Title X.
-------
69
Finding of Suitability to Transfer (POST) - A
process that has been established to identify
and prepare property for transfer by deed.
Such transfers are usually undertaken at a
property where environmental response is not
needed or has been taken. However, under
certain conditions, new authority now permits
earlier transfer. The POST process also looks
at the compatibility of an anticipated reuse
with completed restoration activities and
identifies restrictions necessary to protect
human health and the environment.
In cases where the EPA project
manager makes a determination that actions
taken to address LBP hazards are sufficient
(following the requirements outlined in the
Field Guide), EPA should agree with the
federal agency on the transfer documents and
the covenant that all remedial action necessary
to protect human health and the environment
with respect to any such substances remaining
on the property has been taken before the date
of such transfer . In the case of BRAC sites, the EPA project manager can agree on the Findings of
Suitability to Transfer (POST) or Findings of Suitability to Lease (FOSL) language, and/or the operating
properly and successfully (OPS) determination as required by CERCLA. When an EPA project manager
has unresolved questions as to whether actions at
residential areas meet the requirements of
CERCLA, she/he should raise these issues to the
federal agency and provide an opportunity for
response. In the case of BRAC sites, it is proper
to highlight these concerns in EPA's comments
on the FOST/FOSL. Efforts should be made to
determine that the purchaser is fully aware that
EPA has questions about the condition of the
property.
Finding of Suitability to Lease (FOSL) - A
process that has been established for leasing
of property that cannot be transferred by deed
because environmental restoration activities
are still ongoing. The FOSL process also
looks at the compatibility of a proposed reuse
with ongoing restoration activities and
identifies restrictions necessary to protect
human health and the environment and
prevent interference with the cleanup.
-------
70
REFERENCES
American Society for Testing and Materials (ASTM). 1998. Standard Test Method for Particle-Size
Analysis of Soils. D 422-63.
Borgman, LE, Gerow, K and Flatman, GT., Cost-Effective Sampling for Spatially Distributed
Phenomena. In Principles of Environmental Sampling, 2nd Ed. Keith, LH, ed. (American Chemical
Society, 1996)
Borgman, LE and Quimby, WF. 1996. Sampling for Tests of Hypothesis When Data are Correlated in
Space and Time. In Principles of Environmental Sampling, 2nd Ed. Keith, LH, ed. (American Chemical
Society, 1996)
Carbone, R., N. Laforgia, E. Crollo, A. Mautone and A. lolascon. 1998. Maternal and neonatal lead
exposure in southern Italy. Biol. Neonate 73: 362-366.
Centers for Disease Control and Prevention (CDC). 1991. Preventing Lead Poisoning in Young Children.
October 1991. Centers for Disease Control, Atlanta, GA.
Crumbling, D.M., C. Groenjes, B. Lesnik, K. Lynch, J. Shockley, J. Van Ee, R.A. Howe, L.H. Keith, and
J. McKenna. 2001. Applying the concept of effective data to contaminated sites could reduce costs and
improve cleanups. Environmental Science and Technology 35(9):405A-409A.
Englund, E.J. and N. Heravi. 1994. Phased Sampling for Soil Remediation. Env. Ecol. Stats 1:247-263.
Flatman, G.T. and A.A. Yfantis. 1984. Geostatistical Strategy for Soil Sampling: The Survey and the
Census. U.S. EPA EMSL. Env. Mon. Assess 4:335-349.
Gilbert, R.O. and Simpson, J.C. 1983. Kriging for Estimating Spatial Pattern Of Contaminants: Potential
and Problems. Environmental Monitoring and Assessment Vol 4: 113-135.
Gilbert, R.O. 1987. Statistical Methods for Environmental Pollution Monitoring. VanNostrand Reinhold.
New York, New York.
Goovaerts, P. 1997. Geostatistics for Natural Resources Evaluation. Oxford University Press.
Gayer, R.A. 1990. Transplacental transport of lead. Environ. Health Perspect 89:101-105.
Graziano, J.H., D. Popovac, P. Factor-Litvak, P. Shrout, J. Kline, M.J. Murphy, Y. Zhao, A. Mehmeti, X.
Ahmedi, B. Rajovic, Z. Zvicer, D. Nenezic, N. Lolacono and Z. Stein. 1990. Determinants of elevated
blood lead during pregnancy in a population surrounding a lead smelter in Kosovo, Yugoslavia. Environ.
Health Perspect 89:95-100.
Idaho Department of Health and Welfare and Agency for Toxic Substances and Disease Registry,
Division of Health Assessment and Consultation. 2000. Coeur d'Alene River Basin Environmental Health
Assessment. Atlanta, GA.
Journel, A.G. 1984. Indicator Approach to Toxic Chemical Sites; Report of Project No. CR-811235-02-0.
U.S. Environmental Protection Agency, Las Vegas, NV.
Mushak, P. 1998. Uses and limits of empirical data in measuring and modeling human lead exposure.
Environ Health Perspect 106 Suppl 6:1467-84.
-------
71
National Research Council (NRC) Committee on Measuring Lead in Critical Populations, 1993.
Quimby, W.F. 1986. Selected Topics in Spatial Statistical Analysis: Nonstationary Vector Kriging, Large
Scale Conditional Simulation of Three Dimensional Gaussian Random Fields, and Hypothesis Testing in
a Correlated Random Field. PhD Thesis. University of Wyoming, Laramie. December.
Ryti, R.T. 1993. Superfund Soil Cleanup: Developing the Piazza Road Remedial Design. J. Air Waste
Manage. Assoc 43:197-202.
Snedecor, G.W. and Cochran, W.G. 1989. Statistical Methods. Iowa State University Press. Ames, Iowa.
Syracuse Research Corporation (SRC). 1999. Assessment of Background Lead Concentrations for the
Coeur d'Alene, Idaho River Basin Common Use Areas Risk Assessment Report. Prepared for U.S. EPA
Region 10 under Subcontract No. SE-98-A-713. SRC TR-99-001.
TerraGraphics. 1997a. PanHandle Health District Institutional Controls Program Sampling Plan for Soil
Piles and Excavations. November.
TerraGraphics. 1997b. PanHandle Health District Institutional Controls Program Sampling Plan for
Gravel Sources. November.
TerraGraphics. 2000. Final 1999 Five Year Review Report - Bunker Hill Superfund Site. April.
TerraGraphics. 2001. Data Summary Report for Six-Month Sampling Results, House Dust Pilot Project
2000. August.
U.S. Department of Defense/U.S. Environmental Protection Agency (DOD/EP'A). Memorandum, Subject:
Management of Lead-Based Paint in Residential and Non-Residential Areas at Base Realignment and
Closure (BRAC) Properties. March 17. 1999a.
U.S. Department of Defense (DOD)/U.S. Environmental Protection Agency (EPA). Department of
Defense and the Environmental Protection Agency Lead-Based Paint Guidelines for Disposal of
Department of Defense Residential Real Property-A Field Guide. Interim Final. December 1999b.
U.S. Department of Housing and Urban Development (HUD). Housing and Community Development
Act of 1992. Title XResidential Lead-Based Paint Hazard Reduction Act of 1992. Public Law 102-550.
U.S. Housing and Urban Development. Washington, D.C. 1992.
U.S. Department of Housing and Urban Development (HUD). Guidelines for the Evaluation and Control
of Lead-Based Paint Hazards in Housing. June. 1995.
U.S. Department of Housing and Urban Development (HUD). Lead-Based Paint Poisoning Prevention in
Certain Residential Structures. 24 CFR Part 35.
Available online: http://www.access.gpo.gov/nara/cfr/cfr-table-search.html. 2001.
1986 U.S. EPA
U.S. Environmental Protection Agency (EPA). Air Quality Criteria for Lead Volume I-IV. Environmental
Criteria and Assessment Office, Office of Research and Development, RTP, NC. EPA/600/8-83-028.
1986.
1988 U.S. EPA
U.S. Environmental Protection Agency (EPA). CERCLA Compliance with Other Laws Manual: Interim
Final. Office of Emergency and Remedial Response, Washington, DC. EPA 540-G-89-006. August 1988.
-------
72
1989 U.S. EPA
U.S. Environmental Protection Agency (EPA). Human Health Evaluation Manual, Part A, Risk
Assessment Guidance for Superfund, Volume I, Interim Final. Office of Emergency and Remedial
Response, Washington, DC. EPA/540/1-89/002. 1989.
1990 U.S. EPA
U.S. Environmental Protection Agency (EPA). Report of the Clean Air Act Scientific Advisory Committee
on its Review of the OAQPSLead Staff Paper and the ECAO Air Quality Criteria Document Supplement.
EPA-SAB-CASAC-90-002. January 1990a.
U.S. Environmental Protection Agency. National Oil and Hazardous Substances Pollution Contingency
Plan. Final Rule. 40 CFR 300. 55 Federal Register, 8666-8865, March 8. Washington, DC. 1990b.
U.S. Environmental Protection Agency. OSWER Directive 9833.0-la: Guidance on CERCLA Section
106(a) Unilateral Administrative Orders for Remedial Designs and Remedial Actions. (March 1990).
Available online:
http://www.epa.gov/compliance/resources/policies/cleanup/superfund/cercl06-uao-rpt.pdf 1990c
1992 U.S. EPA
U.S. Environmental Protection Agency (EPA). Community Relations. 40 CFR 300.430(c)(2)(iv). 1992.
1994 U.S. EPA
U.S. Environmental Protection Agency (EPA). OSWER Directive: Revised Interim Soil Lead (Pb)
Guidance for CERCLA Sites and RCRA Corrective Action Facilities. EPA/540/F-94/043 PB94-963282.
(August 1994). Available online: http://www.epa.gov/superfund/programs/lead/products/oswerdir.pdf.
1994a.
U.S. Environmental Protection Agency (EPA). Guidance Manual for the Integrated Exposure Uptake
Biokinetic Model for Lead In Children. EPA/540/R-93/081 PB93-963510, (February 1994). 1994b.
1995 U.S. EPA
U.S. Environmental Protection Agency (EPA). Land Use in the CERCLA Remedy Selection Process.
May. OSWER Directive 9355.7-04. 1995a.
U.S. Environmental Protection Agency (EPA). Guidance for Community Advisory Groups at Superfund
Sites. December. OSWER Directive 9230.0-28 PB94-963293 EPA 540-K-96-001.
Available online: http://www.epa.gov/superfund/tools/cag/resource.htm. 1995b.
U.S. Environmental Protection Agency (EPA). Engineering Forum Issue: Determination of Background
Concentrations of Inorganics in Soils and Sediments at Hazardous Waste Sites. Office of Research and
Development. EPA/540/S-96/500. 1995c.
1996 U.S. EPA
U.S. Environmental Protection Agency (EPA). Record of Decision. Bunker Hill Mining & Metallurgical
Complex. Shoshone County, Idaho. Office of Emergency and Remedial Response. Washington, DC.
1996a.
U.S. Environmental Protection Agency (EPA). Urban Soil Lead Abatement Demonstration Project, Vol.
I: Integrated Report. Office of Research and Development. 1996b.
U.S. Environmental Protection Agency (EPA). Soil Screening Guidance. July. Pub 9355.4-23.
Available online: http://www.epa.gov/superfund/resources/soil/ssg496.pdf. 1996c.
-------
73
U.S. Environmental Protection Agency (EPA). Region 1, EPA-New England. Standard Operating
Procedure for Elemental Analysis Using the X-MET 920 Field X-RAY Fluorescence Analyzer. Available
online: http://www.epa.gov/NE/measure/xrav/xravfluor.html. 1996d.
1997 U.S. EPA
U.S. Environmental Protection Agency (EPA). Record of Decision. Tar Creek. Ottawa County,
Oklahoma. Office of Emergency and Remedial Response. Washington, DC. 1997a
U.S. Environmental Protection Agency (EPA). Lead Site Response Decisions: Formation of the Lead
Sites Consultation Group. Memo from Steve Luftig dated May 29, 1997. 1997b.
U.S. Environmental Protection Agency (EPA). OSWER Directive 9200.1-18FS: Consolidated Guide to
Consultation Procedures for Superfund Response Decisions. EPA/540-F-97-009. May 1997. 1997c.
U.S. Environmental Protection Agency (EPA). Rules of Thumb for Superfund Remedy Selection. August.
EPA 540-R-97-013 OSWER Directive 9285.6-07,P PB97-963301.
Available online: http://www.epa.gov/superfund/resources/rules/. 1997d.
U.S. Environmental Protection Agency (EPA). Best Management Practices (BMP S) for Soil Treatment
Technologies: Suggested Guidelines to Prevent Cross-Media Transfer of Contaminants During Clean-Up
Activities. EPA 530/R97/007. 1997e.
1998 U.S. EPA
U.S. Environmental Protection Agency (EPA). OSWER Directive: Clarification to the 1994 Revised
Interim Soil Lead (Pb) Guidance for CERCLA Sites and RCRA Corrective Action Facilities.
EPA/540/F-98/030, OSWER Directive 9200.4-27P, PB98-963244. (August 1998).
Available online: http://www.epa.gov/superfund/programs/lead/products/oswer98.pdf 1998a.
U.S. Environmental Protection Agency (EPA). Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. Vol IA, SW-846, Method 6200, Revision 0, January. 1998b.
U.S. Environmental Protection Agency (EPA). Short Sheet: IEUBK Model Mass Fraction of Soil in
Indoor Dust (MSD) Variable (June 1998). EPA #540-F-00-008, OSWER #9285.7-34.
Available online: http://www.epa.gov/oerrpage/superfund/programs/lead/products/ssmsdcol.pdf 1998c.
1999 U.S. EPA
U.S. Environmental Protection Agency (EPA). Protect Your Family From Lead in Your Home. EPA 747-
K-99-00 I.April 1999a.
U.S. Environmental Protection Agency (EPA). Interim Policy on the Use of Permanent Relocations as
Part of Superfund Remedial Actions. (June 1999). EPA #540-F-98-033, OSWER #9355.0-71P. Available
online: http://www.epa.gov/oerrpage/superfund/tools/topics/relocation/index.htm. 1999b.
2000 U.S. EPA
U.S. Environmental Protection Agency (EPA). Comprehensive Environmental Response, Compensation,
and Liability. 42USC103. Section9621(c). Washington, DC. 2000a.
U.S. Environmental Protection Agency (EPA). Grants for Technical Assistance. 40 CFRPart 35, Subpart
M. Available online: http://www.epa.gov/superfund/tools/tag/resource .htm. 2000b.
U.S. Environmental Protection Agency (EPA). Short Sheet: TRW Recommendations for Sampling and
Analysis of Soil at Lead (Pb) Sites (April 2000). EPA #540-F-00-010, OSWER #9285.7-38.
Available online: http://www.epa.gov/oerrpage/superfund/programs/lead/products/sssiev.pdf 2000c.
-------
74
U.S. Environmental Protection Agency (EPA). Guidance for the Data Quality Objectives Process. EPA
QA/G-4. U.S. Environmental Protection Agency. Washington, D.C. 2000d.
U.S. Environmental Protection Agency (EPA). Bunker Hill Populated Areas Operable Unit First Five
Year Review Report. Volume I, Seattle, WA. September 27, pp. 48. 2000e.
U.S. Environmental Protection Agency (EPA). Institutional Controls: A Site Manager's Guide to
Identifying, Evaluating and Selecting Institutional Controls at Superfund and RCRA Corrective Action
Cleanups. September 29. EPA 540-F-00-005, OSWER Directive 9355.0-74FS-P.
Available online: http://www.epa.gov/oerrpage/superfund/action/ic/guide/guide.pdf. 2000f
U.S. Environmental Protection Agency (EPA). Institutional Controls and Transfer of Real Property
under CERCLA Section 120(h)3(A), (B), or (C). February 2000.
Available online: http://www.epa.gov/swerffrr/documents/fi-icops 106.htm. 2000g.
2001 U.S. EPA
U.S. Environmental Protection Agency (EPA). Lead; Identification of Dangerous Levels of Lead; Final
Rule. FR Vol. 66 No. 4. January 5. Available online : http://www.epa.gov/lead/403 final.pdf 2001a.
U.S. Environmental Protection Agency (EPA). Reuse Assessments: A Tool To Implement The Superfund
Land Use Directive. June. OSWER Directive 9355.7-06P. 2001b
U.S. Environmental Protection Agency (EPA). Abandoned Mine Site Characterization and Cleanup
Handbook. Appendix E "X-Ray Fluorescence". EPA 530-R-01-002, March 2001. 2001c.
U.S. Environmental Protection Agency (EPA). Integrating Dynamic Field Activities Into the Superfund
Response Process: A Guide for Project Managers. Draft Final. December.
Available online: http://www.epa.gov/superfund/programs/dfa/. 200Id.
U.S. Environmental Protection Agency (EPA). Field Analytical Technologies Encyclopedia (FATE).
Accessed on December 17, 2001. Available online: http://fate.clu-in.org/. 2001e.
U.S. Environmental Protection Agency (EPA). Site Assessment Guidance CD.
Available online: http://www.epa.gov/oerrpage/superfund/sites/phonefax/descript/siteassess.htm. 200If
U.S. Environmental Protection Agency (EPA). Site Assessment Web Site. Available online:
http://www.epa.gov/superfund/programs/siteasmt/index.htm. 2001g.
U.S. Environmental Protection Agency (EPA). Comprehensive Five-Year Review Guidance. EPA 540-R-
01-007. OSWER Directive 9355.7-03B-P. June. Available online:
http://www.epa.gov/oerrpage/superfund/sites/phonefax/descript/siteassess.htm. 2001h.
U.S. Environmental Protection Agency (EPA). Guidance for Characterizing Background Chemicals in
Soil at Superfund Sites. External Review Draft. EPA 540-R-01-003. OSWER Directive 9285.7-4-1. June.
Available online: http://www.epa.gov/superfund/programs/risk/background.pdf 200li.
2002 U.S. EPA
U.S. Environmental Protection Agency (EPA). Role of Background in the CERCLA Cleanup Program.
April 26. OSWER Directive 9285.6-07P.
Available online: http://www.epa.gov/superfund/programs/risk/role.pdf. 2002.
von Lindern, I. and Spalinger, S. Memorandum to Lead Remediation Review Group Regarding Interim
Preventative Risk Management Activities Dust Mat Monitoring Proposed Protocol. TerraGraphics.
September 14. 2001.
-------
A-l
APPENDIX A
TITLE X AND EPA's Toxic SUBSTANCES
CONTROL ACT (TSCA) TITLE IV LEAD PROGRAM
-------
A-2
TITLE X AND EPA's Toxic SUBSTANCES CONTROL ACT (TSCA) TITLE IV LEAD PROGRAM
Background
The Housing and Community Development Act of 1992 (PL 102-5 50) contained Title X the
"Residential Lead-Based Paint Hazard Reduction Act of 1992" (HUD, 1992). Even though this was a
U.S. Department of Housing and Urban Development (HUD) authorization bill, it established a series of
requirements for EPA. Title X includes a new Title IV of the Toxics Substances Control Act (TSCA).
The sections that address EPA alone have section numbers in the four hundred (400) series, such as
Section 403, Health Based Standards, whereas the HUD portions have numbers in the one thousand
(1000) series, such as Section 1015, Task Force. There is one section, Section 1018, that Congress
required both HUD and EPA to jointly issue a rule on disclosure.
Overview
Title X addresses LBP and LBP hazards and requires EPA and HUD to issue regulations to
address those items. Title X's emphasis is on actual hazards such as deteriorating paint, lead in dust, or
lead in soil versus potential hazards such as intact paint. Generally, Title X does not mandate inspections,
risk assessments, abatements of LBP, or LBP hazards. The exceptions are HUD program related actions
(Section 1012) or when a federal agency disposes of a property that will be used for residential purposes
(Section 1013). However, if you choose to do an inspection, risk assessment, or abatement, Title X
establishes certification requirements and work practice standards that must be followed. Title X requires
disclosure at the time of sale or rental (Section 1018) and the provision of a brochure Protect Your Family
from Lead in Your Home (EPA, 1999a), before rehabilitation (Section 406b). EPA may authorize state
programs to operate in lieu of the federal program for the 400 series regulations but not Section 1018.
See Appendix A for a full discussion of Title X.
Scope of Title X
Title X contains specific classes of structures that it regulates. The first category is "target
housing", which is defined as "...any housing constructed prior to 1978 except housing for the elderly or
persons with disabilities (unless any child who is less than 6 years of age resides or is expected to reside
in such housing for the elderly or persons with disabilities) or any 0-bedroom dwelling."
The second category is "child occupied facilities", which are defined as "... a building or a
portion of a building, constructed prior to 1978, visited regularly by the same child, 6 years of age or
under, on at least two different days within any week (Sunday through Saturday period), provided that
each day's visit lasts at least 3 hours and the combined weekly visit lasts at least 6 hours, and the
combined annual visits last at least 60 hours. Child-occupied facilities may include, but are not limited
to, day-care centers, preschools and kindergarten classrooms" (EPA, 200la).
As of December 2001 target housing and child occupied facilities are the only classes of
structures for which EPA has issued final regulations.
CERCLA 121(e)(l) exempts any response action conducted entirely on-site from having to
obtain a federal, state, or local permit, where the action is carried out under §121. In general,
on-site actions need to comply only with the substantive aspects of ARARs and not with the
corresponding administrative requirements. Therefore, the administrative requirements laid out under
TSCA 402 and 403 are not considered ARARs for actions conducted entirely on-site.
-------
A-3
More Information
Section 405 requires EPA to establish a Hot Line and Clearing House for lead. This has
been done and the National Lead Information Center's toll free number is l-(800)-424-LEAD.
Additionally the EPA web site at www.epa.gov/lead has all the rules, fact sheets, and guidance documents
that the EPA Office of Pollution Prevention and Toxics has developed.
Description of the Sections of Title X
Title X Final Rules in Effect for ONLY Target Housing:
Section 1012. This section establishes the requirements for those who get assistance or mortgage
insurance from HUD. The requirements are HUD program specific, but only pertain to those who are
involved with a particular HUD program.
Section 1013. This section establishes the requirements for federal agencies that dispose of target
housing that will be used for residential purposes.
Section 1018. Section 1018 requires that sellers and landlords disclose known LBP and LBP
hazards and provide available reports to buyers and renters. Sellers and landlords must also provide a
copy of Protect Your Family from Lead in Your Home (EPA, 1999a).
This is a joint rule between EPA and HUD. Section 1018 does not include "child occupied
facilities"; EPA developed the concept of "child occupied facilities" under TSCA Title IV, the term is
only in effect for TSCA four hundred (400) series rules.
TSCA Final Rules in Effect for ONLY Target Housing and Child Occupied Facilities:
Section 402/404 State Certification Programs establishes a nationally consistent federal Program
for the certification of individuals and firms engaged in training, paint inspections, risk assessments, and
certification of abatement workers, supervisors and training providers. There are two aspects of the
program. States and tribes are encouraged to establish a program that as a whole, is at least as protective
as EPA's federal program. The state programs can be more protective. When a state program is
approved, it becomes the federal program in that state.
If the state or tribe does not establish an acceptable certification program, EPA operates the
national program in that state. Much of the work is done in the EPA Regional Office. As of December
2001, 39 states, the District of Columbia, and 2 tribes have EPA authorized programs. Two states with
large populations, which do not have authorized programs, are New York and Florida.
Section 403 establishes hazard standards for lead in paint, dust, and soil. Lead-based paint is a
hazard if (1) it is deteriorated; (2) it is present on a friction surface that is subject to abrasion and the dust-
lead levels on the nearest horizontal surface are equal to or greater than the applicable dust hazard
standard; or (3) it is present on any chewable surface on which there is evidence of teeth marks. (Lead-
based paint is statutorily defined as paint containing 1.0 milligram or more lead per square centimeter or
0.5% or more lead by weight.) Dust is a hazard if it contains 40 micrograms or more lead per square foot
on floors or 250 micrograms or more lead per square foot on window sills. Soil is a hazard if it contains
400 parts per million or more in play areas or 1,200 parts per million or more in the rest of the yard.
This regulation also established the following clearance levels for interior dust: 40 micrograms
lead per square foot for floors, 250 micrograms lead per square foot for window sills, and
400 micrograms lead per square foot for window troughs.
-------
A-4
EPA's Section 403 rule was intended to prioritize risks as opposed to being inclusive of
situations in which risks of concern exist. Per the rule preamble, "The hazard standard in this TSCA rule
was intended as a ' 'worst first'' level that will aid in setting priorities to address the greatest lead risks
promptly at residential and child-occupied facilities affected by lead-based paint" (EPA, 2001a). While
identification of lead hazards (as defined under TSCA) is a necessary part of the facility reuse process, a
minimal approach that would insure only that the letter of the hazard standards are met may not protect
against some important risks.
Section 405 establishes standards of environmental sampling laboratories. The National Lead
Laboratory Accreditation Program (NLLAP) is administered by the American Industrial Hygiene
Association and the American Association for Laboratory Accreditation. All laboratory samples must be
analyzed by an NLLAP accredited laboratory.
Section 406b requires that the pamphlet Protect Your Family from Lead in Your Home (EPA,
1999a) be distributed no more than 60 days before a renovation in the home.
TSCA Rules Being Developed
Section 402. Renovation and remodeling requirements for target housing and child occupied
facilities are being drafted as a proposed rule. Requirements for bridges and structures constructed prior
to 1978 are being drafted for re-proposal. Both of these could include training, certification, and work
practice standards.
Lead-based Paint Debris. This rule was not required by Title X, but the need was clearly there
to treat portions of the debris from lead-based activities differently than the RCRA requirements. There
are two categories of waste discussed. First is the paint chips and dust, sludges and filtercakes, wash
water and contaminated and decontaminated protective clothing equipment that would continue to be
subject to all the requirements of RCRA. Second is the "lead-based paint architectural component
debris", which would be exempt from the Toxicity Characteristics rule including Toxicity Characteristic
Leaching Procedure (TCLP) testing for lead only. This would allow disposal of these components at
construction-demolition (CD) landfills.
Although the Pb Debris Rule is still being developed, in the interim, EPA has issued a
Memorandum that "Regulatory Status of Waste Generated by Contractors and Residents from
Lead-Based Paint Activities Conducted in Households" - signed July 31, 2000. This memo clarifies
the regulatory status of waste generated as a result of LBP activities (including abatement, renovation
activities, and remodeling) in homes and other residences. This memo explains why LBP generated by
contractors in households is "household waste" and thus excluded from the RCRA Subtitle C hazardous
waste regulations. The household exclusion applies only to waste generated by either residents or
contractors conducting LBP activities in residents. As a result, LBP waste from residences can be
discarded in a municipal solid waste landfill or a municipal solid waste combustor.
-------
B-l
APPENDIX B
1998 OSWER Directive 9200.4-27P ('Clarification')
-------
B-2
9200.4-27
EPA/540/F-98/030
PB98-963244
OSWER Directive # 9200.4-27P
MEMORANDUM
SUBJECT: Clarification to the 1994 Revised Interim Soil Lead Guidance for CERCLA Sites and
RCRA Corrective Action Facilities
FROM: Timothy Fields, Jr.
Acting Assistant Administrator
TO: Regional Administrators I-X
PURPOSE
This directive clarifies the existing 1994 Revised Interim Soil Lead Guidance for CERCLA Sites and
RCRA Corrective Action Facilities, OSWER Directive 9355.4-12. Specifically, this directive clarifies
OSWER's policy on (1) using EPA's Science Advisory Board (SAB) reviewed Integrated Exposure
Uptake Biokinetic Model (IEUBK) and blood lead studies, (2) determining the geographic area to use in
evaluating human exposure to lead contamination ("exposure units"), (3) addressing multimedia lead
contamination and (4) determining appropriate response actions at lead sites. The purpose for clarifying
the existing 1994 directive is to promote national consistency in decision-making at CERCLA and RCRA
lead sites across the country.
BACKGROUND
OSWER Directive 9355.4-12, issued on July 14, 1994 established OSWER's current approach to
addressing lead in soil at CERCLA and RCRA sites. The existing directive established a streamlined
approach for determining protective levels for lead in soil at CERCLA sites and RCRA facilities as
follows:
• It recommends a 400 ppm screening level for lead in soil at residential properties;
• It describes how to develop site-specific preliminary remediation goals (PRGs) at CERCLA sites
and media cleanup standards at RCRA Corrective Action facilities for residential land use; and,
• It describes a strategy for management of lead contamination at CERCLA sites and RCRA
Corrective Action facilities that have multiple sources of lead.
The existing interim directive provides direction regarding risk assessment and risk management
approaches for addressing soil lead contaminated sites. The OSWER directive states that, " ...
implementation of this guidance is expected to provide more consistent decisions across the country ..."
However, since that directive was released, OSWER determined that clarification of the guidance is
needed. Key areas being clarified by issuance of this directive include: (1) using the IEUBK model and
blood lead studies, (2) determining exposure units to be considered in evaluating risk and developing risk
management strategies, (3) addressing multimedia lead contamination and (4) determining appropriate
response actions at residential lead sites. The existing directive provides the following guidance on these
areas:
-------
B-3
1. The OSWER directive recommends using the Integrated Exposure Uptake Biokinetic (IEUBK)
Model for Lead in Children (Pub. # 9285.7-15-1, PB93-963510) for setting site-specific
residential preliminary risk-based remediation goals (PRGs) at CERCLA sites and media cleanup
standards (MCSs) at RCRA corrective actions Facilities. The directive states that the IEUBK
model is the best tool currently available for predicting the potential blood lead levels of children
exposed to lead in the environment. OSWER's directive also recommends the evaluation of blood
lead data, where available, and states that well-conducted blood lead studies provide useful
information to site managers. The directive however recommends that"... blood lead data not be
used alone to assess risk from lead exposure or to develop soil lead cleanup levels."
2. The directive describes OSWER's risk reduction goal as "...generally, OSWER will attempt to
limit exposure to soil lead levels such that a typical (or hypothetical) child or group of similarly
exposed children would have an estimated risk of no more than 5% of exceeding a 10 • g/dl blood
lead level." The directive also states that"... EPA recommends that a soil lead concentration be
determined so that a typical child or group of children exposed to lead at this level would have an
estimated risk of no more than 5% of exceeding a blood lead of 10 • g/dl." OSWER generally
defines an exposure unit as a geographic area where exposures occur to the receptor of concern
during the time of interest and believes that for a child or group of similarly exposed children,
this is typically the individual residence and other areas where routine exposures are occurring.
3. The directive recommends that risk managers assess the contribution of multiple environmental
sources of lead to overall lead exposure (e.g., consideration of the importance of soil lead levels
relative to lead from drinking water, paint, and household dust) which promotes development of
risk reduction strategies that address all sources that contribute significantly to exposure.
4. The OSWER directive states that the IEUBK model is not the only factor to be considered in
establishing lead cleanup goals. Rather, the IEUBK model is the primary risk assessment tool
available for evaluating lead risk and the results of the model are used to guide selection of
appropriate risk management strategies for each site.
Since the OSWER directive was issued in 1994, there has been a trend toward a more consistent approach
to managing risk at residential lead sites, however, OSWER was interested in identifying areas requiring
additional clarification to facilitate more effective implementation of the directive. As a first step in the
process, meetings were held with various EPA Regions, States and local governments to discuss how the
directive has been implemented nationally at lead sites since 1994. By participating in these meetings and
by reviewing the decisions that are being made across the country, OSWER believed that clarification of
certain aspects of the 1994 directive would be useful.
All of the documents and guidance referenced in this directive are available through the National
Technical Information Service (NTIS) at 703-605-6000 or could be downloaded electronically from:
http//epa.gov/superfund/oerr/ini_prod/lead/prods.htm.
OBJECTIVE
At lead contaminated residential sites, OSWER seeks assurance that the health of the most susceptible
population (children and women of child bearing age) is protected and promotes a program that
proactively assesses and addresses risk. OSWER believes that predictive tools should be used to evaluate
the risk of lead exposure, and that cleanup actions should be designed to address both current and
potential future risk.
While health studies, surveys, and monitoring can be valuable in identifying current exposures and
promoting improved public health, they are not definitive tools in evaluating potential risk from exposure
to environmental contaminants. In the case of lead exposure, blood lead monitoring programs can be of
critical importance in identifying individuals experiencing potential negative health outcomes and
-------
B-4
directing education and intervention resources to address those risks. However, CERCLA §121(b)
requires EPA to select cleanup approaches that are protective of human health and the environment and
that utilize permanent solutions to the maximum extent practicable. To comply with the requirements set
forth in CERCLA §121(b), OSWER will generally require selection of cleanup programs that are
proactive in mitigating risk and that do not simply rely on biological monitoring programs to determine if
an exposure has already occurred.
To meet these objectives, OSWER will seek actions that limit exposure to soil lead levels such that a
typical child or group of similarly exposed children would have an estimated risk of no more than 5% of
exceeding a 10 • g/dl blood lead level. If lead is predicted to pose a risk to the susceptible population,
OSWER recommends that actions be taken to significantly minimize or eliminate this exposure to lead.
The principles laid out in the four attached fact sheets (Appendix) support OSWER's goals by
encouraging appropriate assessment and response actions at CERCLA and RCRA lead sites across the
country.
This clarification directive emphasizes the following key messages regarding the four areas and
encourages the users of this directive, be they EPA Regions, States, or other stakeholders, to adopt these
principles in assessing and managing CERCLA and RCRA lead sites across the country. The critical
elements of the attached papers are as follows:
/. Using Blood Lead Studies and IEUBKModel at Lead Sites:
OSWER emphasizes the use of the IEUBK Model for estimating risks for childhood lead exposure from a
number of sources, such as soils, dust, air, water, and other sources to predict blood lead levels in children
6 months to 84 (7 years) months old. The 1994 directive also recommended evaluation of available blood
lead data and stated that data from a well-conducted blood lead study of children could provide useful
information to site managers. In summary, OSWER's clarification policy on the appropriate use of the
IEUBK and blood lead studies is that:
• OSWER recommends that the IEUBK model be used as the primary tool to generate risk-based
soil cleanup levels at lead sites for current or future residential land use. If Regions propose an
alternative method for generating cleanup levels, they are required to submit their approach to the
national Lead Sites Consultation Group (LSCG)1 for review and comment;
• Response actions can be taken using IEUBK predictions alone; blood lead studies are not
required; and
• Blood lead studies and surveys are useful tools at lead sites and can be used to identify key site-
specific exposure pathways and to direct health professionals to individuals needing immediate
assistance in minimizing lead exposure; however, OSWER recommends that blood lead studies
not be used for establishing long-term remedial or non-time-critical removal cleanup levels at
lead sites.
//. Determining Exposure and Remediation Units at Lead Sites
:The Lead Sites Consultation Group (LSCG) is comprised of senior management representatives from the
Waste Management Divisions in all 10 EPA regions along with senior representatives from the Office of Emergency
and Remedial Response in EPA headquarters. The LSCG is supported by EPA's Technical Review Workgroup
(TRW) for lead and the national Lead Sites Workgroup (LSW). The TRW consists of key scientific experts in lead
risk assessment from various EPA Regions, labs and headquarters. The LSW is comprised of senior Regional Project
Managers from various Regions and key representatives from headquarters who are experienced in addressing lead
threats at Superfund sites.
-------
B-5
OSWER recommends that cleanup levels at lead sites be designed to reduce risk to atypical or
individual child receiving exposures at the residence to meet Agency guidelines (i.e., no
greaterthan a 5% chance of exceeding a 10 • g/dl blood lead level for a full-time child resident).
Therefore, it is recommended that risk assessments conducted at lead-contaminated residential
sites use the individual residence as the primary exposure unit of concern. This does not mean
that a risk assessment should be conducted for every yard, rather that the soil lead contamination data
from yards and other residential media (for example, interior dust and drinking water) should be input
into the IEUBK model to provide a preliminary remediation goal (PRG) for the residential setting. When
applicable, potential exposure to accessible site-related lead sources outside the residential setting should
also be evaluated to understand how these other potential exposures contribute to the overall risk to
children, and to suggest appropriate cleanup measures for those areas.
///. Addressing Multimedia Contamination at Lead Sites
EPA generally has limited legal authority to use Superfund to address exposure from interior lead-based
paint. As a policy matter, OSWER recommends that such exposures not be addressed through actual
abatement activities. However, EPA Regions should promote addressing interior paint risks through
actions by others (e.g., potentially responsible parties (PRPs), other government programs, etc.) as a
component of an overall site management strategy. Because of other competing demands on the
Superfund Trust Fund, OSWER recommends that EPA Regions avoid using the Superfund Trust Fund for
removing exterior lead-based paint and soil contaminated from lead-based paint. Superfund dollars may
however be used in limited circumstances to remediate exterior lead-based paint in order to protect the
overall site remedy (/'. e., to avoid re-contamination of soils that have been remediated) but generally only
after determining that other funding sources are unavailable. As with interior lead-based paint abatement,
EPA Regions should promote remediation of exterior lead-based paint by others, such as PRPs, local
governments or individual homeowners.
IV. Determining Appropriate Response Actions at Lead Sites
In selecting site management strategies, it is OSWER's preference to seek early risk reduction with a
combination of engineering controls (actions which permanently remove or treat contaminants, or create
reliable barriers to mitigate the risk of exposure) and non-engineering response actions. All potential lead
sources should be identified in site assessment activities. Non-engineering response actions, such as
education and health intervention programs, should be considered an integral part of early risk reduction
efforts because of their potential to provide immediate health benefits. In addition, engineering controls
should be implemented early at sites presenting the greatest risk to children and other susceptible
subpopulations.
As a given project progresses, OSWER's goal should be to reduce the reliance on education and
intervention programs to mitigate risk. The goal should be cleanup strategies that move away from
reliance on long-term changes in community behavior to be protective since behavioral changes may be
difficult to maintain over time. The actual remedy selected at each CERCLA site must be determined by
application of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (55 FR
8666- 8865, March 8, 1990) remedy selection criteria to site-specific circumstances. This approach also
recognizes the NCP preference for permanent remedies and emphasizes selection of engineering over
non-engineering remedies for long-term response actions.
This directive clarifies OSWER's policy on four key issue areas addressed in the 1994 OSWER soil lead
directive in order to promote a nationally consistent decision-making process for assessing and managing
risks associated with lead contaminated sites across the country. The policy presented in these specific
issue areas supersedes all existing OSWER policy and directives on these subjects. No other aspects of
the existing 1994 directive are affected.
-------
B-6
IMPLEMENTATION
The principles laid out in this directive (which includes the four attached factsheets) are meant to apply to
all residential lead sites currently being evaluated through the CERCLA Remedial
Investigation/Feasibility Study process and all future CERCLA Sites and RCRA Corrective Action
Facilities contaminated with lead. The Regions will be required to submit their rationale for deviating
from the policies laid out in this directive to the Lead Sites Consultation Group. This directive does not
apply to previous remedy selection decisions.
Attachments
cc: Waste Management Policy Managers (Regions I-X)
Stephen Luftig, OERR
Elizabeth Cotsworth, OSW
James Woolford, FFRRO
Barry Breen, OSRE
Larry Reed, OERR
Tom Sheckells, OERR
Murray Newton, OERR
Betsy Shaw, OERR
John Cunningham, OERR
Paul Nadeau, OERR
Bruce Means, OERR
Earl Salo, OGC
NOTICE: This document provides guidance to EPA staff. The document does not, however,
substitute for EPA's statutes or regulations, nor is it a regulation itself. Thus it cannot impose legally-
binding requirements on EPA, states, or the regulated community, and may not apply to a particular
situation based upon the circumstances. EPA may change this guidance in the future, as appropriate.
-------
B-7
|| Factsheet: Using the IEUBK Model and Blood Lead Studies at Residential Lead Sites ||
Question: What is OSWER's policy on using the IEUBK model and blood lead studies in
conducting risk assessments and setting cleanup standards at residential lead contamination sites?
Answer: OSWER's policy on using the IEUBK model and blood lead studies in conducting risk
assessment and setting cleanup standards is as follows:
A. Use of the IEUBK Model:
1. The IEUBK model is a good predictor of potential long-term blood lead levels for children in
residential settings. OSWER recommends that the IEUBK model be used as the primary tool to
generate risk-based soil cleanup levels at lead sites for current or future residential land use. If
Regions propose an alternative method for generating cleanup levels, they are required to submit
their approach to the National Lead Sites Consultation Group (LSCG) for review and comment.
2. Blood lead distributions predicted by the IEUBK model illustrate a plausible range of variability
in children's physiology, behavior, and household conditions.
3. Response actions can be taken, and remedial goals developed, using IEUBK predictions alone.
B. Use of Blood Lead Studies/Data:
1. Blood lead studies, surveys, and monitoring are useful tools at lead sites and can be used to help
identify key site-specific exposure pathways and direct health professionals to individuals
needing immediate assistance in minimizing lead exposure.
2. The utility of blood lead testing results and studies depends on how representative the
information is of the population being evaluated, the design of the data collection, and the quality
of the laboratory analysis. To this end, OSWER recommends that EPA Regions consult with
ATSDR or CDC to assess or design studies according to their intended use.
3. Many blood lead screening, monitoring, or testing programs differ from blood lead studies in that
they do not attempt to identify risk factors for childhood exposure to lead sources. Although these
programs may be extremely beneficial in identifying children with elevated blood lead levels and
identifying candidates for referral to medical professionals for evaluation, they may not provide
an accurate representation of community-wide exposure.
4. Well-designed blood lead studies may be used to identify site specific factors and pathways to be
considered in applying the IEUBK model at residential lead sites. However, OSWER
recommends that blood lead studies not be used to determine future long-term risk where
exposure conditions are expected to change over time; rather, they should be considered a
snapshot of ongoing exposure under a specific set of circumstances (including community
awareness and education) at a specific time. Long-term studies may be helpful in understanding
exposure trends within a community and evaluating the effectiveness of cleanup strategies over
time.
C. IEUBK and Blood Lead Studies/Data:
1. Blood lead data and IEUBK model predictions are expected to show a general concordance for
most sites. However, some deviations between measured and predicted levels are expected. On
some occasions, declines in blood lead levels have been observed in association with lead
exposure-reduction and health education. However, long-term cleanup goals should be protective
-------
B-8
in the absence of changes in community behavior as there is little evidence of the sustained
effectiveness of these education/intervention programs over long periods of time.
2. Where actual blood lead data varies significantly from IEUBK Model predictions, the model
parameters should not automatically be changed. In such a case, the issue should be raised to the
Lead Technical Review Workgroup (TRW) to further identify the source of those differences.
Site work need not be put on hold while the issue is being reviewed by the TRW; the site
manager should review other elements of the lead directive and the "Removal Actions at Lead
Sites" guidance to determine appropriate interim actions to be taken at the site.
The Regions will be required to submit their rationale for deviating from the policies laid out in this
factsheetto the Lead Sites Consultation Group.
-------
B-9
[[Factsheet: Determining Exposure and Remediation Units at Residential Lead Sites
Question: How does OSWER define an exposure unit, and subsequently apply this definition in
conducting risk assessment and risk management activities at residential lead sites?
Answer: OSWER recognizes that defining and characterizing exposure unit(s) for a site is
critically important in undertaking risk assessment activities and in designing protective cleanup
strategies. An exposure unit is defined as a geographic area where exposures occur to the receptor of
concern during the time of interest and that for a child, or group of similarly exposed children, this is
typically the individual residence and other areas where chronic or ongoing exposures are occurring.
Various approaches to characterizing and managing risks by exposure units have been examined by
OSWER. OSWER recognizes that lead ingestion can also cause adverse health effects in adults and
fetuses but believes that by adequately limiting lead exposures to young children at residential sites, these
other receptors will generally be likewise protected from adverse health impacts.
EPA's goal is to protect human health and the environment under current and future exposure scenarios.
At lead sites, OSWER wants to assure that children's health is protected and promotes a program that
proactively assesses risks rather than relying on biological monitoring to determine if an exposure has
already occurred. OSWER emphasizes actions be taken at lead sites that will minimize or eliminate
exposure of children to environmental lead contamination.
To achieve the above stated goal, OSWER recommends characterizing exposure units as exposure
potential at the individual residence as the primary unit of concern for evaluating potential risk at
lead contaminated residential sites. This recognizes that there are children whose domain and activities
occur principally within the confines of a particular residential property. For determining exposure
potential (and ultimately developing protective cleanup levels) at the individual home, OSWER
recommends the scenario to be evaluated (through use of the IEUBK Model) would be a young child in
full-time residence. This approach helps achieve OSWER's recommended health protection goal that an
individual child or group of similarly exposed children would have <5% chance of exceeding a blood lead
concentration of 10 • g/dl. In designing community wide cleanup strategies, it is essential that non-
residential areas (e.g., parks, day care facilities, playgrounds, etc.), where lead exposure may occur, also
be characterized with respect to their contribution to soil-lead exposure, and appropriate cleanup actions
implemented.
OSWER recommends that risk management decisions for response to residential lead contamination sites
focus on reducing risk at residences, but also recommends that response strategies be developed for other
site locations (exposure units) where children receive exposure. Flexibility in determining appropriate
response actions that provide protection at the individual residence should be considered in context of the
NCP remedy selection criteria. The lead exposure issues are complex and OSWER recommends that EPA
Regions try to communicate clearly the risk characterization and risk management decisions to the site
residents. Affected communities must clearly understand the context of risk management decisions, how
these decisions affect the health of their children, and how cleanup actions will influence the future
growth and development of the community.
The Regions will be required to submit their rationale for deviating from the policies laid out in this
factsheetto the Lead Sites Consultation Group.
-------
B-10
[[Factsheet: Addressing Multimedia Contamination at Residential Lead Sites II
Question: What is OSWER's policy on addressing multimedia contamination at residential lead
sites?
Answer: OSWER recognizes that several sources of lead-contamination, including soil, ground
water, airborne particulates, lead plumbing, interior dust, and interior and exterior lead-based paint may
be present at Superfund sites where children are at risk or have documented lead exposure. These lead
sources may contribute to elevated blood lead levels and may need to be evaluated in determining risks
and cleanup actions at residential lead sites. However, there are limitations on the Agency's statutory
authority under CERCLA to abate some of these sources, such as indoor lead-based paint and lead
plumbing because CERCLA responses may be taken only to releases or threatened releases into the
environment (CERCLA §104 (a)(3) and (4)).
When EPA's resources, or authority to respond or to expend monies under Superfund is limited, OSWER
recommends that EPA Regions identify and coordinate to the greatest extent possible with other
authorities and funding sources (e.g., other federal agencies and state or local programs). EPA Regions
should coordinate with these other authorities to design a comprehensive, cost-effective response strategy
that addresses as many sources of lead as practicable. These strategies should include actions to respond
to lead-based paint, interior dust, and lead plumbing, as well as ground water sources and lead-
contaminated soil.
Although OSWER will encourage that EPA Regions fully cooperate in the development of a
comprehensive site management strategy, OSWER realizes that complete active cleanup of these other
sources may be difficult to complete due to limited funding available to other authorities. Since complete
cleanups of these sources is not guaranteed, and at most sites may be unlikely, OSWER recommends that
the soil cleanup levels not be compromised. In other words, the soil cleanup levels should be calculated
with the IEUBK model using existing pre-response action site specific data. This is due to the fact that
soil cleanup levels at residential lead sites are generally established to protect individuals, from excess
exposures to soils, and house dust attributable to those soils, and are not attributable to exposure to other
sources such as interior lead paint which should be managed on a residence specific basis. Remediation of
non-soil lead sources to mitigate overall lead exposure at individual residences should therefore not be
used to modify site-wide soil lead cleanup levels.
The recommendations provided below represent OSWER's policy on addressing lead-contaminated
media and/or sources for which EPA has limited or no authority to remediate.
Interior Paint: EPA has limited legal authority to use Superfund to address exposure from interior lead-
based paint. As a policy matter, OSWER recommends that such exposures not be addressed through
actual abatement activities. However, EPA Regions should promote addressing interior paint risks
through actions by others, such as HUD, local governments, or individual home owners as a component
of an overall site management strategy. Any activities to clean up interior lead-based paint by PRPs or
other parties should not result in an increase of the risk-based soil cleanup levels.
Exterior Paint: Because of other competing demands on the Superfund Trust Fund, OSWER
recommends that EPA Regions avoid using the Superfund Trust Fund for removing exterior lead-based
paint and soil contaminated from lead-based paint. Superfund dollars may be used to respond to exterior
lead-based paint for protecting the overall site remedy (i.e., to prevent re-contamination of soils that have
been remediated) but only after determining that other funding sources are unavailable. Where other
sources of funding are not available, EPA may utilize the CERCLA monies to remediate exterior lead-
based paint on homes/buildings, around which soil contaminated by other sources has been cleaned up to
prevent recontamination of the soil. The Superfund should not be used to remediate exterior lead-based
paint where no soil cleanup has occurred. As with interior lead-based paint abatement, EPA Regions
-------
B-ll
should promote remediation of exterior lead-based paint by others, such as PRPs, local governments or
individual homeowners. Cleanup activities of exterior paint conducted by PRPs or other parties should
not result in an increase of the risk-based soil cleanup levels.
Interior Dust: Lead contaminated interior dust can be derived from several sources, including interior
paint, home owner hobbies, exterior soil, and other exterior sources. In many cases, it may be difficult to
differentiate the source(s) for the lead contamination in the dust. In general, EPA Regions should refrain
from using the Superfund Trust Fund to remediate interior dust. Because of the multi-source aspects of
interior dust contamination, potential for recontamination, and the need for a continuing effort to manage
interior dust exposure, OSWER recommends the use of an aggressive health education program to
address interior dust exposure. Such programs, administered through the local health department (or other
local agency), should be implemented in conjunction with actions to control the dust source. At a
minimum, the program should include blood lead monitoring, and personal hygiene and good
housekeeping education for the residents. OSWER believes that EPA Regions can also support the
program by providing HEPA vacuums to the health agency for use in thoroughly cleaning home interiors.
Lead Plumbing: Generally CERCLA does not provide for legal authority to respond to risks
posed by lead plumbing within residential dwellings. It should be noted that the water purveyor is
responsible for providing clean water to the residences. As with interior dust, OSWER recommends that
EPA Regions coordinate with local agencies to establish a health education program to inform residents
of the hazards associated with lead plumbing and how to protect themselves by regularly flushing, or
preferably, replacing lead pipes. Soil cleanup levels should not be adjusted to account for possible
remediation of lead plumbing.
-------
B-12
[[Factsheet: Determining Appropriate Response Actions at Residential Lead Sites II
Question: What is OSWER's position on the appropriate use of engineering and non-engineering
response actions in developing risk management strategies for lead sites?
Answer: One goal emphasized in the recent third round of Superfund Reforms is for EPA to take a
consistent approach in selecting and implementing both long- and short-term response actions at lead sites
in all regions. One obstacle to achieving this consistency has been differing degrees of reliance on non-
engineering response actions in reducing risk.
Site management strategies at lead sites typically include a range of response actions. Alternatives range
from engineering controls that permanently remove or treat the contaminant source to non-engineering
response actions, such as educational programs and land use restrictions. This continuum represents the
range of response options available to risk managers. This position paper clarifies the relationship
between engineering and non-engineering response actions in developing site management strategies.
In selecting site management strategies, OSWER's policy will be to seek early risk reduction with a
combination of engineering controls (actions which permanently remove or treat contaminants, or which
create reliable barriers to mitigate the risk of exposure) and non-engineering response actions. All
potential lead sources should be identified in site assessment activities. Non-engineering response actions,
such as education and health intervention programs, should be considered an integral part of early risk
reduction efforts due to their potential to provide immediate health benefits.2 In addition, engineering
controls should be implemented early at sites presenting the greatest risk to children and other susceptible
subpopulations. Community concerns should receive a high priority in site decision-making; local support
is vital to the success of health intervention and education programs.
As the project progresses, OSWER's goal should be to reduce reliance on education and intervention
programs to mitigate risk. The goal should be cleanup strategies that move away from reliance on long-
term changes in community behavior to be protective; behavioral changes
may be difficult to maintain over time. The actual remedy selected at each site must be determined by
application of the NCP remedy selection criteria to site-specific circumstances. However, this approach
recognizes the NCP preference for permanent remedies and emphasizes the use of engineering controls
for long-term response actions. This approach also recognizes that well-designed health intervention and
education programs, when combined with deed restrictions and/or other institutional controls, may be
appropriate for reducing future exposure potential and may supplement engineering controls.
In instances where Regions believe that the use of engineering controls is impracticable, and education,
health intervention, or institutional controls are proposed as the sole remedy, Regions will be required to
consult with the LSCG.
2The actual effectiveness of health intervention and educational programs in reducing risk continues to be a
subject of discussion. Anecdotal information suggests that such programs can provide short-term benefits in some
populations. Rigorous statistical studies demonstrating the benefits of educational programs in preventing lead
exposure are lacking. It is generally recognized that not all segments of the population will be influenced by such
programs, and that long-term benefits are less certain. Local support for such programs is critical. The active (and
long-term) participation of local and state public health agencies is needed in implementing institutional controls,
including health intervention and education programs; without local implementation of such programs their success
is uncertain. Additional research on the effectiveness of these programs is critical to consideration of their use in
future cleanups.
-------
C-l
APPENDIX C
Contacts and Software for Sampling Design
-------
C-2
Table C-l
Contacts and Software for Sample Planning Design
Topic
Sampling
plan design/
Systematic
Planning
Software
General support
Dynamic Field Activities
DEFT: Data Quality Objectives
Decision Error Feasibility Trials
FIELDS: Fully Integrated
Environmental Decision Support
Geo-EAS: Geostatistical
Environmental Assessment
Software
SADA: Spatial Analysis Decision
Assistance
VSP: Visual Sample Plan
Contact(s)
EPA HQ Quality Staff
Phone: (202) 564-6830
FAX: (202) 565-2441
E-mail: qualitvigiepa.gov
Internet:
http://www.epa.aov/superfund/proarams/dfa/
index.htm
E-mail: qualitv@epa.aov
Internet:
http : //www . ornl . aov/doe oro/dqo/resdqo .htm
Internet:
http://www.epa.aov/reaion5fields/static/paaes/ind
ex.html
E-mail: englund . evan@epa.aov
Internet: http://www.ai-aeostats.ora/
E-mail: sada@tiem .utk . edu
Internet: http : //www .tiem .utk . edu/~sada/
E-mail: nell .cliff (Sipnl . gov
Internet: http : //dq o .pnl . gov/vsp/
-------
D-l
APPENDIX D
Examples of Property Access Agreement Forms
-------
D-2
CONSENT FOR ACCESS TO PROPERTY
FOR SAMPLING
Name:
Daytime Phone Number:
Address(es) of Property(ies):
I consent to officers, employees, and authorized representatives of the United States
Environmental Protection Agency (EPA) entering and having access to my property for the purpose of
taking [DESCRIBE NUMBER OF SAMPLING LOCATIONS AND DEPTHS] which are necessary to
implement the cleanup of lead contamination in the soil.
This written permission is given by me voluntarily with knowledge of my right to refuse and
without threats or promises of any kind. I understand that EPA or authorized representatives of EPA will
contact me at least one week in advance before the soil samples are collected. This agreement is only for
the purpose of soil sampling and no other work.
Date
D I grant
access to my property
D I do not grant
access to my property
Signature
Signature
D I would also like EPA to have a lead expert contact me to schedule a free inspection to identify
potential lead hazards in my home and provide safety tips.
-------
D-3
United States Environmental Protection Agency Region 6
1445 Ross Avenue, Suite 1200
Dallas, Texas 75202-2733
CONSENT FOR ENTRY AND ACCESS TO PROPERTY FOR SAMPLING
Description of property (including address) for which consent to access is granted:
Example: XXXX Street, Texarkana, Arkansas, more particularly described as a
lot measuring approximately 3,000 square feet, including a two-room wood
structure of approximately 300 square feet
Name of Signatory:
Address:
Phone: (
Relationship to property (e.g., owner, lessee, agent or employee of owner, etc.):
I HEREBY CONSENT to officers, employees and parties authorized by the U.S. Environmental
Protection Agency (EPA), entering and having continued access to the property described above at
reasonable times for the following purposes (List the activities to be undertaken on the property):
Example:
• Sample collection including: (1) the gathering of soil from the outside area of the property; (2)
drawing water from the tap; and (3) vacuuming the inside area of any inhabitable structure in
order to collect dust.
• Taking photographs to record the sampling process.
I realize that these actions are undertaken pursuant to EPA's response and enforcement responsibilities
under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42
U.S.C. Sections 9601-9675. This written permission is given by me voluntarily with the knowledge of
my right to refuse and without threats or promises of any kind.
This agreement expires on:
(Date)
I HEREBY WARRANT that I have authority to make this access agreement.
Date Signature
Print name
-------
D-4
CONSENT FOR ACCESS TO PROPERTY
FOR SAMPLING AND TO TAKE RESPONSE ACTION
Name:
Daytime Phone Number:
Address(es) of Property(ies):
I consent to officers, employees, and authorized representatives of the United States
Environmental Protection Agency (EPA) entering and having access to my property for the purpose of
sampling and taking a response action including: (1) preparing for and excavation of soil from my
property; (2) backfilling the excavated area(s) with clean soil and/or backfill; and (3) restoring any grass
or other vegetation or structures to their pre-excavation state. These activities are necessary to implement
the cleanup of lead contamination in the soil.
This written permission is given by me voluntarily with knowledge of my right to refuse and
without threats or promises of any kind. I understand that EPA or authorized representatives of EPA will
contact me approximately two weeks in advance before the removal of soil begins, to discuss the steps
involved in the excavation and removal program and all measures EPA will take to restore my yard. I
also understand that if there is any damage to structures such as sidewalks that is caused by the work
conducted by EPA or authorized representatives of EPA, then EPA or authorized representatives of EPA
shall repair such damage.
Date
D I grant
access to my property
D I do not grant
access to my property
Signature
Signature
-------
D-5
XXXX TRIBE OF OKLAHOMA
PROPERTY ACCESS CONSENT AGREEMENT
FOR SAMPLING AND TO TAKE RESPONSE ACTION
The Property which is the subject of this agreement is described as follows:
NE 1/4 SE 1/4, Section 6, Township 28 North, Range 24 East, Xxxx County, Oklahoma otherwise
described as Beaver Springs Park and Tribal Office which includes the Pow Wow grounds (hereinafter
the Property).
THIS DAY OF , 1999, by authority of the Xxxx Tribal Business Committee,
permission is hereby granted to officers, employees and parties authorized by the United States
Environmental Protection Agency (EPA) entering and having continued access to the Property until
4:30 pm (CST) on , to conduct the following work (hereinafter the work):
(1) To perform necessary response actions (e.g., excavation of contaminated soil, backfilling with
clean soil or gravel, and sodding or seeding) to address lead and other metals from mining waste
contamination on the above-described lands in accordance with the EPA Record of Decision
issued August 27, 1997;
(2) To take necessary samples of environmental media to identify lead and other metals that may be a
threat to public health or welfare or the environment.
Nothing contained in this permit shall operate to delay or prevent a termination of Federal trust
responsibilities with respect to the Property by the issuance of a fee patent or otherwise during the term of
the work; however, such termination shall not serve to terminate the work. The Xxxx Tribal Business
Committee shall notify EPA of any change in status or ownership of the Property.
The Xxxx Tribal Business Committee realizes that the work will be undertaken pursuant to EPA's
Superfund authority under the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), 42 U.S.C. Sections 9601-9675.
This written permission is given by the Xxxx Tribal Business Committee voluntarily with the knowledge
of its right to refuse and without threats or promises of any kind.
The Xxxx Tribal Business Committee is the property owner or a responsible representative of the
property owner and I, Xx Xxxx, as Chairman of that Committee, warrant that I have authority to make
this access agreement.
Xx Xxxx Date
Xxxx Tribal Chairman
Xxxx Tribe of Oklahoma
U.S. Environmental Protection Agency Date
-------
D-6
CONSENT FOR ACCESS TO PROPERTY
TO TAKE RESPONSE ACTION
Name:
Daytime Phone Number:
Address(es) of Property(ies):
I consent to officers, employees, and authorized representatives of the United States
Environmental Protection Agency (EPA) entering and having access to my property for the purpose of
taking a response action including: (1) preparing for and excavation of soil from my property; (2)
backfilling the excavated area(s) with clean soil and/or backfill; and (3) restoring any grass or other
vegetation or structures to their pre-excavation state. These activities are necessary to implement the
cleanup of lead contamination in the soil.
This written permission is given by me voluntarily with knowledge of my right to refuse and
without threats or promises of any kind. I understand that EPA or authorized representatives of EPA will
contact me approximately two weeks in advance before the removal of soil begins, to discuss the steps
involved in the excavation and removal program and all measures EPA will take to restore my yard. I
also understand that if there is any damage to structures such as sidewalks that is caused by the work
conducted by EPA or authorized representatives of EPA, then EPA or authorized representatives of EPA
shall repair such damage.
Date
D I grant
access to my property
D I do not grant
access to my property
Signature
Signature
-------
E-l
APPENDIX E
Example of Dust Abatement Access Form
-------
E-2
CONSENT FOR ACCESS TO PROPERTY
Name: Daytime Phone Number:
Address(es) of Property(ies):
I hereby consent to grant officers, employees, contractors, sub-contractors and authorized representatives
of the United States Environmental Protection Agency (EPA) access to the interior of my home and/or
property for the purpose of interior dust abatement. The home dust abatement program being offered at
this time consists of vacuuming floors and walls with a special vacuuming system. This system is
portable and compact and easy to use. A team of bonded representatives will be providing the service at
no charge to the homeowner.
Videotaping of the interior of the residence will be necessary to provide backup documentation in the
event of any claims. It will be necessary that someone remain at the residence for one or two days while
it is being vacuumed. This lead abatement program is offered only to homeowners who have or will grant
access to their property for the remediation of in their yards. These activities are necessary to interrupt
the movement of lead through soil dust, house dust, and paint dust.
If you want the process completed in your home and prefer to do it yourself, please note in the
appropriate space and arrangements will be made to schedule the loan of a HEPA-VAC unit to you.
This written permission is given voluntarily with the knowledge of its right to refuse and without threats
or promises of any kind. I understand that, if any damage to my property results from these activities or
any work conducted by the USEPA or its authorized representatives, then the USEPA or its authorized
representatives shall repair or replace such damage.
Date
I grant access to my property for Representatives of the EPA to video and vacuum.
I wish to make arrangements to vacuum myself.
I do not grant access to my property.
Signature
Please return as soon as possible for scheduling of work. If you should have any questions please contact
[LOCAL CONTACT NAME] at [PHONE NUMBER].
-------
F-l
APPENDIX F
Example of Property Inspection Checklist
-------
F-2
TAR CREEK PROJECT
PROPERTY HOME INSPECTION CHECKLIST
Address
Date
Property Group Number
Home Interior Access (check one, see comments):
D Approved by Property Owner D Denied by Property Owner
Property (Yard) Access (check one, see comments):
D Approved by Property Owner D Denied by Property Owner
YARD AREA
1. Lawn Area
A. Location of Flower/Plant Boxes
B. Soil (grade) next to house
C. Shrubbery
D. Trees
E. Low areas near house (that
could cause ponding of water)
F OtVipr-
2. Utility
A. Water Meter
B. Gas Meter
C. Sewer Lines
D OtTipr-
3. Driveway
A. Concrete cracked, damaged
B. Blacktop cracked, damaged
C. Uneven Settling
D OtTipr-
OK
NA
PROBLEM/CONDITION
-------
F-3
YARD AREA (cont)
4. Streetwalk & Walkways
A. Concrete cracked, eroded
B. Tripping hazards
C. Tree roots cracking, lifting slab
D. Sections missing
F Othpr
5. Garage
A. Settlement cracks in walls
B. Concrete floor slab cracked,
damaged
C. Door jambs damaged, rotted
D. Door hard to open, close
F Dthpr
6. Swimming Pool
(Above Ground)
A. Leakage
B. Visible damage
r nthpr-
7. Swimming Pool
(Below Ground)
A. Leakage
B. Visible damage
r nthpr
8. Storm Cellar
A. Damaged
B. Indication of Flooding
C Other
OK
NA
PROBLEM/CONDITION
-------
F-4
YARD AREA (cont)
9. Electrical Service
A. Damaged circuit breaker panel
box
B. Wiring hanging outside
C. Damaged electric meter
r> nthpr-
EXTERIOR AREA
10. • -Brick • -Siding
A. Brick bulging, spalling,
cracking
B. Mortar loose, needs repointing
C. Lintel needs repair
D. Stucco bulging, cracking
E. Siding dented, damaged
F. Finish wearing off siding
G. Siding loose, not level, missing
H. Siding rotted, termites
I. Composite shingles worn,
broken, missing
J. Windows damaged
K Othpr-
11. Roofing
A. Age of covering
B. Shingles worn, damaged,
patched
C. Brick chimney broken, leaning
D. Joint open between chimney &
exterior wall
E. Need flashing at chimney,
vents, walls
OK
NA
PROBLEM/CONDITION
-------
F-5
EXTERIOR AREA (cont)
F. Parapet wall leaning
G. Roof sagging
H. Metal flashing damaged,
missing
T Dthpr-
12. Gutters & Leaders
• 'Yes • «No
A. Copper discolored, greenish,
damaged
B. Galvanized rusted, patched
C. Fascia board rotted, damaged,
patched
D. Drain onto foundation wall
E. Need to divert water from wall
F. Soffit venting • "Yes • 'No
G. Concrete slab cracked,
deteriorated
H. Concrete slab/splash block need
T Dthpr-
13. Entrance Steps
A. Concrete cracked
B. Brick cracked, mortar loose
C. Structurally sound
D. Handrail
F Dthpr
14. Exterior Doors
A. Damaged
B. Opens/closes freely
C. Weatherstripping
D. Trim rotted, missing
OK
NA
PROBLEM/CONDITION
-------
F-6
EXTERIOR AREA (cont)
E. Jambs rotted, damaged
F. Frame separation from walls
n nthpr-
INTERIOR AREA
15. Windows
A. Trim/sills rotted
B. Broken glass
C. Open freely
E. Frame separation from walls
F nthpr-
16. Kitchen
A. Cracked walls, ceiling
B. Loose nails, tape on dry wall
C. Soft, springy floors
D. Wood, tiles on floor damaged
E. Faucet leaks
F. Doors don't close
G. Cabinets don't close
H. Moisture in cabinets
I. Walls have moisture damage
T nthpr-
17. Interior Rooms
A. Cracked walls, ceiling
B. Loose nails, tape on dry wall
C. Soft, springy floor
D. Carpeting water damaged
E. Water stains near windows
OK
NA
PROBLEM/CONDITION
-------
F-7
INTERIOR AREA (cont)
F. Mold/mildew on walls
n nthpr-
18. Toilet Facility
A. Cracked tile, plaster on walls
B. Cracked plaster on ceilings
C. Loose tiles on walls, floors
D. Loose nails, tape on dry wall
E. Toilet cracked
F. Water leaks at closet flange
G. Grout missing around tub
H. Shower pan damaged, missing
I. Shower door damaged, missing
J. Need new shower door
K. Water stains on ceiling below
bathroom
L. Hot water heater tank corroded
M. Water stains on floor around hot
water heater
N. Moisture present around hot
water heater
n nthpr-
19. Interior Doors
A. Open freely
B. Frame separation from walls
r nthpr-
20. Attic
A. Only if visual indicator
R nthpr-
OK
NA
PROBLEM/CONDITION
-------
F-8
INTERIOR AREA (cont)
21. Foundation
A. Minor cracks
B. Settlement cracks at corners,
walls
C. Wall bulging inward
D. Seepage into basement/cellar
E. Mortar deteriorating
F Dthpr-
22. Basement or Cellar
A. Seepage, water stains on
floor/wall
B. Sump pump installed
C. Water pipe leaks
D. Sewer pipe leaks
F Dthpr
FOUNDATION AREA
23. Foundation
(Slab on Grade)
A. Settlement cracks
B. Joint separation
C. Spalding
F) Dthpr-
24. Foundation (Elevated Slab
w/Crawl Space)
A. Concrete support integrity
B. Evidence of moisture or visible
moisture in crawl space
C. Evidence of water accumulation
(e.g., water stains)
OK
NA
PROBLEM/CONDITION
-------
F-9
FOUNDATION AREA
(cont.)
D. Sagging joist/support girders
E. Fungus growth evident
F. Sump pump evident
G. Vents present
H. Vapor barriers
I. Pier settlement
J. Uneven subgrade
K. Insect damage
L. Sill plate damaged
M. Subfloor damaged, loose
N. Need subfloor
n nthpr-
25. Plumbing (Raised Floors
Only)
A. Pipe insulation crumbling,
missing
B. Need to insulate pipes
C. Water pipes leaking
D. Sewer pipes leaking
E. Water pipe condition
F Othpr-
26. Plumbing
A. Water pipe conditions
B. Sewage pipe conditions
C. Pipes leaking
D. Pipe insulation
E. Corrosion on drain lines
F OtTipr-
OK
NA
PROBLEM/CONDITION
-------
F-10
FOUNDATION AREA
(cont.)
27. Other Area
A
R
c
D
OK
NA
PROBLEM/CONDITION
COMMENTS:
Topo Survey Requested • *Yes • «No
Inspector Signature
Date
-------
G-l
APPENDIX G
Examples of Property Closeout Forms
-------
G-2
USEPA REMEDIATION AGREEMENT FORM
Name:
Address:
Phone:
This form documents the completion of remedial activity performed on my property. My signature
will designate that I am satisfied with the restoration of my property, and that no items are in question,
now, or at any time in the future, except those items listed below, if any.
Comments: <(]()/. wiiJiorl,
;oration items in question:
Chloe Irish
Resident Signature
Printed Name
Date
Brad W. Bradley
USEPA Representative Signature Printed Name
Date
-------
G-3
RESIDENTIAL REMEDIATION INSPECTION/AGREEMENT FORM
Name
Address
Phone
This form documents the completion of remedial activities performed on my property. My signature
will designate that I am satisfied with the restoration of my property, and that no items are in question,
now, or at any time in the future, except those items listed below, if any.
Comments
Restoration Items in Question:
7.
Property Inspection Date
Lawn Care Instructions Reviewed/Delivered
fl'T/Uo, Sara O'Mara
Resident Signature Printed Name Date
Brad W. Bradley
USEPA Representative Signature Printed Name Date
-------
-------
H-l
APPENDIX H
Examples of Clean Letters
-------
H-2
EPA LOGO AND ADDRESS
Date
Name
Address
City, State Zip
Dear:
The U.S. Environmental Protection Agency (EPA) has completed the cleanup of the lead contamination
in your yard located at [ADDRESS, CITY, STATE], in connection with the [SITE NAME] site in [CITY,
STATE] (the Site). By way of this letter, U.S. EPA is certifying that your yard has been cleaned up to
less than [CLEAN-UP LEVEL] parts per million lead, the level which U.S. EPA considers protective of
children's health at the Site.
Thank you for your cooperation in this clean-up effort. It has been our pleasure to work with you. If you
have any questions concerning this letter or need further information, please contact me at [PROJECT
MANAGER'S PHONE NUMBER].
Sincerely,
[PROJECT MANAGER NAME]
Remedial Project Manager
-------
H-3
EPA LOGO AND ADDRESS
Date
Name
Address
City, State Zip
Dear:
The United States Environmental Protection Agency (U.S. EPA) has sampled your yard located at
[ADDRESS, CITY, STATE] for lead. The results of this sampling, which are enclosed with this letter,
indicate that your yard contains less than [CLEAN-UP LEVEL] per million lead, the level which U.S.
EPA considers protective of children's health at the [SITE NAME, CITY, STATE]. Thus, U.S. EPA will
not need to perform soil clean-up activities in your yard.
If you have any questions concerning this letter or the enclosure, please contact me at [PROJECT
MANAGER'S PHONE NUMBER].
Sincerely,
PROJECT MANAGER NAME
Remedial Project Manager
Enclosure
ENCLOSURE
Analytical results for [ADDRESS]
in parts per million (ppm) of lead:
Depth Zone
(inches)
Otol
Ito6
6 to 12
18 to 24
Deeper
Zones (if
applicable)
Drip Zone
Composite
Yards
Front
ppm
ppm
ppm
ppm
ppm
ppm
Back
ppm
ppm
ppm
ppm
ppm
ppm
OR Quadrant
1
ppm
ppm
ppm
ppm
ppm
ppm
2
ppm
ppm
ppm
ppm
ppm
ppm
3
ppm
ppm
ppm
ppm
ppm
ppm
4
ppm
ppm
ppm
ppm
ppm
ppm
-------
H-4
Mr. John Smith
123 N. Main
Joplin, Missouri 64108
Dear Mr. Smith,
This letter serves as written notification that a lead-contaminated soil clean-up action was performed
under authority of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
as amended by the Superfund Amendments and reauthorization Act of 1986 on property you have an
interest in at the Jasper County, National Priorities Listed Superfund site. Our records show that your
property located at 123 N. Main was included in this action. The clean-up action conducted by the U.S.
Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (COE) addressed
residences with soil lead levels over 800 ppm, day care facilities, and residences with children under six
years of age with blood lead levels over 15 g/dL.
Briefly, the primary objective of the clean-up action on your property was to remove highly lead-
contaminated near-surface yard soils that were located at your residence. In some cases trees, shrubs,
flowers, and other vegetation were left in place. As a result a small amount of lead-contaminated soils
may be left near the surface on your property. This small amount of contamination should not cause a
health threat under normal circumstances. In the future if additional landscaping, or planting requiring
excavation below six inches are done, care should be exercised to minimize recontamination.
The excavation criteria for the project was as follows:
A) From the surface to 12 inches, excavation continued until 500 ppm or less lead levels
concentrations were achieved;
B) If the residual lead concentrations at a depth of one foot exceeded 1,500 ppm a "marker
barrier" was placed at that depth. The marker barrier used was the temporary orange plastic construction-
type fence. This material is permeable, and will allow water and plant roots to pass through it. Only a
small number of properties required the installation of the barrier. The primary purpose of this marker
barrier is to inhibit and alert individuals excavating in these areas in future years.
In general, all areas of the yard that exceeded 500 mg/kg lead at the surface were removed. Soil
brought in to backfill the excavation contained less than 240 mg/kg lead.
IF YOU HAVE PLANS TO DO ANY EXCAVATION WORK AT YOUR PROPERTY AND
YOU ENCOUNTER THE ORANGE BARRIER PLEASE CONTACT YOUR LOCAL HEALTH
DEPARTMENT, THE MISSOURI DEPARTMENT OF NATURAL RESOURCES, OR THE EPA FOR
GUIDANCE.
Please save this document for your permanent records. In the event you sell or transfer the property to
someone you can show the next owner that a lead cleanup was performed. If you require more specific
information concerning the excavation on your property, please feel free to contact me at
(xxx) xxx-xxxx.
Sincerely,
(Project Manager)
------- |