Exposure Assessment for Lead Dust Generated During
Renovation, Repair, and Painting in Residences and
Child-Occupied Facilities
Draft for CASAC Consultation on February 5, 2007
December 2006
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C.
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DISCLAIMER
This report is being furnished to the U.S. Environmental Protection Agency (EPA) by
ICF International in partial fulfillment of Contract No. 68-W-03-008, Work Assignment
No. 4-07. This document is being circulated for the Clean Air Scientific Advisory
Committee (CASAC) consultation which is scheduled for a public meeting, to be held in
Research Triangle Park (RTP), NC, on Monday, February 5, 2007.
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TABLE OF CONTENTS
1. Introduction 1-1
1.1 Overvi ew of Approach 1-1
1.2 Universe of Included Building Types 1-2
1.3 Sources and Exposure Pathways 1-3
1.4 Exposure Duration 1-3
2. Exposure Scenarios 2-1
2.1 Types of Activities 2-1
2.2 Types of Controls 2-2
3. Exposures to Indoor Dust and Outdoor Soil 3-1
3.1 Background Media Concentrations 3-1
3.1.1 Indoor Dust 3-1
3.1.2 Outdoor Soil 3-2
3.2 Methodology 3-2
3.2.1 Indoor Dust 3-3
3.2.2 Outdoor Soil 3-3
3.3 Estimated Media Concentrations 3-4
3.3.1 Remodeling Kitchen 3-5
3.3.2 Three Cutouts 3-6
3.3.3 Replacing Windows 3-7
3.3.4 Replacing Exterior Doors 3-8
3.3.5 Scraping Lead-Based Paint, Interior Flat Component 3-9
3.3.6 Scraping Lead-Based Paint, Interior Door 3-10
3.3.7 Exterior Lead-Based Paint Removal 3-11
3.3.8 Summary of Results 3-11
3.4 Sensitivity Analysis 3-12
3.4.1 Approach 3-12
3.4.2 Results 3-12
3.4.3 Conclusions 3-15
3.4.4 Considerations for Revised Exposure Assessment 3-15
4. Exposures to Other Sources 4-1
5. References 5-1
Appendix A. Methodology for Calculating Indoor Dust and Outdoor Soil
Concentrations A-l
Appendix B. Inputs Used for Estimating Media Concentrations for Baseline and Full Rule
Implementation Control Scenarios B-l
Appendix C. Description of Approach for Converting Lead Loadings to Lead
Concentrations C-l
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Appendix D. Detailed Exposure Concentration Results D-l
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1. Introduction
This report describes the approach and initial results for the exposure assessment performed in
support of the final Lead Renovation, Repair, and Painting (LRRP) rule. This exposure
assessment is designed to characterize the children's lead exposures associated with LRRP
activities, and will include the estimation of the potential exposures with current conditions and
with the LRRP rule in place. This assessment will also consider exposures resulting from LRRP
activities in child-occupied facilities.
Chapter 1 provides an overview of the approach, describes the types of buildings covered in this
exposure assessment, identifies the relevant sources and pathways for lead exposures associated
with renovation, repair, and painting (RRP) activities in these buildings, and describes the
exposure durations for the assessment. Chapter 2 describes the selected exposure scenarios,
including the RRP activities and control types considered. Chapters 3 and 4 describe the
approaches and initial results for the assessment of lead exposures to RRP activity-relevant
media (i.e., indoor dust and outdoor soil) and background sources (i.e., diet, drinking water, and
air), respectively. Chapter 5 provides the references for the report.
1.1 Overview of Approach
The approach for this draft exposure assessment is focused on developing a scientifically sound
analysis framework and characterizing a reasonable range of results (considering both
uncertainty and variability) using this framework. For this draft, readily available data sources
were identified and the best inputs and assumptions, given the available time, were identified.
Throughout the report, it is noted where inputs and assumptions should be reconsidered in
subsequent drafts of the exposure assessment.
For this draft, exposure concentrations were estimated for a series of scenarios. Each scenario is
defined by a unique combination of activity type (e.g., replacing windows) and control strategy.
The scenarios evaluated in this draft were limited by the available data sources; some of the
identified scenarios could not be included in this draft due to data gaps. It is expected that EPA's
Office of Pollution Prevention and Toxics (OPPT) dust study will be available for use in the
revised exposure assessment and should aid in filling some of these gaps. This study is expected
to include additional information on lead dust and soil loadings associated with different RRP
activities and is expected to be used in revising and expanding this exposure assessment.
A recent study which includes data on lead dust levels during RRP activities is available and will
be used in developing the exposure assessment if appropriate. In November, 2006, the Lead-
Safe Work Practices Survey Project Report was provided to the Agency. The Lead-Safe Work
Practices Survey was conducted by the National Association of Home Builders to measure the
amount of lead dust generated during typical RRP activities and assess whether routine RRP
activities increase lead dust levels in the work area and property. Both air samples and surface
dust wipe samples were collected during RRP activities conducted in five separate residential
properties included in the study. This study will be evaluated for its relevance in developing the
RRP exposure assessment and may be included in future drafts of the exposure assessment.
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The results of this assessment include a complete set of exposure concentration results for each
scenario, based on best estimate or central tendency (CT) assumptions. In addition, a sensitivity
analysis was conducted where each input varied from a low-end estimate to a high-end estimate
(one input value at a time) to characterize the sensitivity of estimated exposure concentrations to
changes in each input, given a reasonable range of values for the input. The results of this
sensitivity analysis provide insight into which inputs are most important and help in determining
which inputs should be the focus of additional analysis for the revised exposure assessment.
1.2 Universe of Included Building Types
This exposure assessment is focused on lead exposures in two types of buildings: residences
with children under six years of age, and COFs. For the purposes of this assessment, COFs are
defined as a building, or a portion of a building, constructed prior to 1978, visited regularly by
the same child, under age 6, on at least two different days within any week, provided that each
day's visit lasts at least 6 hours and the combined weekly visit lasts at least 6 hours, and the
combined annual visits last at least 60 hours. Examples of COFs are day-care centers,
preschools, and kindergarten classrooms.
There is potentially some overlap between the buildings covered under the "residences" category
and those categorized as COFs.
This draft exposure assessment focuses on a set of exposure scenarios that was developed to
address exposures in residences. Exposures associated with COFs are not explicitly addressed in
this draft assessment because the potential RRP activities for these types of buildings have not
yet been fully characterized. Note, however, that the exposure scenarios included in this draft
assessment may indirectly characterize exposures for some types of COFs, particularly where
there is overlap between the definitions of "residence" and "COF " COFs will be more
comprehensively characterized in the revised exposure assessment.
For all building types, the exposure assessment will consider the age of the building (i.e.,
vintage) when calculating exposures. The building's vintage plays an important role in several
elements of the exposure assessment, including estimating lead loadings with different types of
RRP activities and estimating background concentrations, because older homes may contain
older lead-based paints, which often have higher lead concentrations. Data were not available
for the draft exposure assessment to consider vintage; however, this will be considered in the
revised exposure assessment.
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1.3 Sources and Exposure Pathways
Without understanding all of the different types of lead sources and their contributions to blood
lead levels, it is difficult to characterize how changes in lead exposures associated with RRP
activities would affect children's IQ, given the non-linearity in blood lead models and exposure-
response relationships. For this assessment, lead sources are divided into two categories:
sources impacting indoor dust and outdoor soil lead concentrations, and all other sources (i.e.,
air, drinking water, and diet). This distinction is made because RRP activities are expected to
contribute to lead concentrations in indoor dust and outdoor soil, and these contributions will
vary depending on the types of controls being used (see Section 2.2 for more details). Exposures
to air, drinking water, and diet are characterized using a single, constant "background"
concentration that is assumed to be unaffected by any RRP activities (see Chapter 4 for more
details on these exposure concentrations).
In the draft exposure assessment, inhalation exposures are assumed to be unaffected by RRP
activities, and are included in the "other sources" category. This assumption may underestimate
the impacts of RRP activities on lead exposures because these activities may result in elevated
air concentrations of lead, which could contribute to the overall health impacts. Due to a lack of
available data characterizing air concentrations associated with RRP activities, the impact of this
assumption could not be evaluated in this exposure assessment. However, the OPPT dust study
is expected to provide this type of data and may allow for the evaluation of this assumption in the
revised exposure assessment. If subsequent analyses indicate that inhalation exposures have the
potential to impact overall risk estimates, they will be characterized in a manner similar to that
used to characterize indoor dust and outdoor soil concentrations (i.e., not characterized using a
single, constant "background" concentration), to extent feasible given the available data.
1.4 Exposure Duration
For this exposure assessment, environmental media concentrations will be estimated over time
for the exposure duration, and then provided as inputs to a blood lead model. For each scenario,
the period of exposure considered in this assessment is six years. For interior dust exposures,
this period is divided into five phases (as illustrated in Exhibit 1): pre-activity (background),
activity, post-activity (initial cleanup), post-activity (routine cleaning), and post-activity
(background). Exposure concentrations are estimated for each phase separately. During the pre-
activity (background) phase, exposures will be represented by the estimated constant background
indoor dust concentrations. During the activity phase, exposure concentrations will be
represented by the sum of the background dust concentrations and the estimated activity-related
dust concentrations. The post-activity (initial cleanup) phase refers to the one-time cleaning
conducted by the contractor immediately following completion of the activity. Exposure
concentrations for the post-activity (initial cleanup) phase will be represented by a one-time
reduction in the activity phase concentration calculated using the initial cleaning efficiency
(described in more detail in Chapter 3). The post-activity (routine cleaning) phase refers to the
regular (repeated) cleaning performed by the resident. Exposure concentrations for the post-
activity (routine cleaning) phase will be represented by time-varying estimates of dust
concentrations calculated using the activity concentration and the routine cleaning efficiency
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(described in more detail in Chapter 3). The final phase, post-activity (background), begins
when the post-activity (routine cleaning) dust concentrations are approximately equal to the
background dust concentrations, and continues until the end of the exposure period. For this
phase, exposure concentrations will be represented by the estimated constant background indoor
dust concentrations.
Exhibit 1. Phases of the Exposure Period, Indoor Dust
For outdoor soil exposures, this period is divided into two phases (as illustrated in Exhibit 2):
pre-activity (background), and activity. Exposure concentrations are estimated for each phase
separately. During the pre-activity (background) phase, exposures will be represented by the
estimated constant background outdoor soil concentrations. During the activity phase, exposure
concentrations will be represented by the sum of the background soil concentrations and the
estimated activity-related soil concentrations. Unlike for indoor dust, there are no assumed loss
processes that result in a reduction of the activity-related soil concentrations and thus soil
concentrations are assumed to remain at activity phase levels for the remainder of the exposure
period.
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Exhibit 2. Phases of the Exposure Period, Outdoor Soil
Activity
"O
c
o
c
Pre-activity
(background)
Time
For the blood lead modeling, individual simulations will be performed using ages between 0 and
5 as the starting points for the activity (the number of simulations will be based on the shape of
the estimated exposure distributions). For each of these simulations, the length of the different
phases may be different; in some cases, one or more of the phases may not be included based on
the time the activity starts and the length of the different periods (e.g., if activity starts at age 0,
the pre-activity phase would not be included). In addition, blood lead levels associated with
RRP activities will be estimated for women of child-bearing age and used to characterize fetal
exposures.
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2. Exposure Scenarios
This draft exposure assessment uses a scenario-based approach, where each scenario consists of
a unique combination of RRP activity type and control type. A separate set of exposure
concentration results were generated for each scenario to evaluate the range of exposure
conditions possible both with and without implementation of the LRRP rule. Section 2.1
describes the RRP activity types addressed in this assessment and Section 2.2 describes the
control types considered.
2.1 Types of Activities
Exhibit 3 presents the types of activities for residential exposures covered by this draft exposure
assessment.1 Each activity is associated with a different combination of tasks, such as drilling
and sawing. This exhibit indicates the relevant exposure media for each activity - indoor dust
for inside activities and outdoor soil for outside activities. For some of these activities, it is
possible that there are contributions to lead concentrations in both indoor dust and outdoor soil.
This assessment is limited in this regard because the data identified to date only include lead
loadings for either indoor dust or outdoor soil for each activity. This is recognized as a limitation
of this assessment and may be revisited if sufficient data are identified.
The list of activities included in Exhibit 3 is based on the types of RRP activities expected to be
included in OPPT's dust study. Given that the results of the dust study are not yet available,
activity-based exposure concentrations were estimated for this draft exposure assessment based
on other available sources, primarily OPPT's Environmental Field Sampling Study (USEPA
1997) (see Chapter 3 for more details). Some of these activities (as indicated in Exhibit 3) were
not included in the draft exposure assessment because there were not sufficient data to
characterize lead loadings in the workspace associated with these activities. These activities will
be included in the revised exposure assessment, provided sufficient data are available in OPPT's
dust study to fully characterize them.
1 Activities associated with exposures in COFs are not explicitly addressed in the draft exposure assessment, as
discussed in Section 1.2. Additional activities will be included in the revised exposure assessment to address
activities associated with COFs.
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Exhibit 3. RRP Activities Included in Exposure Assessment3
Activity
Relevant Media
Included in
Draft EA?
Description
Indoor
dust
Outdoor
soil
Renovating kitchen
V
V
Complete replacement of
kitchen (cabinets, appliances,
etc.)
Three cutouts
V
V
2 ft each of painted surface
Replacing windows
V
V
6 ft2 of painted surface
Replacing exterior doors
V
V
a
25-50 ft of painted surface
Scraping LBP, interior flat
component
V
V
50-75 ft2 of painted surface
Scraping LBP, interior door
V
V
20-40 ft2 of painted surface
Replacing fascia boards
V
a
50 ft of painted surface
Exterior LBP removalb
V
V
Removal of LBP through a
variety of techniques
a LBP = lead-based paint; EA = exposure assessment
b The range of exterior LBP removal practices considered in the draft exposure assessment include activities such as
dry scraping, chemical removal, and heat gun removal. Additional scenarios may be added to the refined
assessment for individual LBP removal techniques if supported by the data provided in the forthcoming OPPT dust
study.
2.2 Types of Controls
There are methods for control of lead released during RRP activities being considered for the
LRRP Rule: plastic sheeting and workspace cleaning. The following four control combinations
are included in this exposure assessment:
• No plastic sheeting, basic cleaning (baseline controls);
• No plastic sheeting, full rule cleaning;
• Plastic sheeting, basic cleaning; and
• Plastic sheeting, full rule cleaning (full rule implementation controls).
Only the baseline controls and full rule implementation controls are addressed in this draft
exposure assessment. Sufficient data were not available to evaluate the effectiveness of the other
two combinations for this assessment. The results of the OPPT dust study are expected to be
used to revise this exposure assessment as it pertains to these control combinations. In addition,
the revised exposure assessment will also examine exposures with different degrees of partial
compliance, as well as the use of control techniques in the absence of a LRRP Rule.
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3. Exposures to Indoor Dust and Outdoor Soil
This chapter presents the methodology used to estimate exposure concentrations in indoor dust
and outdoor dust and summarizes the results of the analysis. Section 3.1 presents the
background concentrations used for indoor dust and outdoor soil and how they were derived.
Section 3.2 presents the approaches for estimating indoor dust and outdoor soil concentrations
with both baseline and full rule implementation controls for the seven activity types analyzed in
this draft exposure assessment. Section 3.3 presents the estimated indoor dust or outdoor soil for
each scenario. Section 3.4 describes the sensitivity analysis and presents a summary of its
results.
3.1 Background Media Concentrations
A child's exposure to lead over the first six years of life consists of both exposure to lead
released as a result of RRP activities and exposure to background lead concentrations in the
home. It is necessary to know these background concentrations for accurate estimation of blood
lead levels and to allow for the determination of the portion of the blood lead levels attributable
to RRP activities with and without implementation of the rule.
3.1.1 Indoor Dust
For indoor lead background dust concentrations, two different sources of lead loading data were
used. The default lead loading value (2.0 jug/ft2) is the 75th percentile of background lead
loading values in the U.S. housing stock across all floor types as reported in HUD (2002). The
75th percentile was selected as a reasonable default estimate because these data represent all
housing in the United States (i.e., they are not specific to housing with lead-based paint). HUD
(2002) estimates that 40 percent of all homes have lead-based paint (LBP) and homes with LBP
are expected to have higher lead loading values; therefore, the 75th percentile value for the entire
U.S. housing stock was used to capture the effect of the higher typical loading in homes with
LBP. The low lead loading value (0.375 jug/ft2) is the 25th percentile of U.S. housing stock
background lead loading values across all floor types as reported in HUD (2002). This value
was chosen as a reasonable low-end estimate because it was the lowest floor load presented in
HUD (2002), which includes all U.S. housing and likely provides relatively low loadings
compared to those for houses with LBP. It is important to note that the reporting of 0.375 jug/ft2
as the 25th percentile in HUD (2002) was influenced significantly by HUD's decision to
represent all non-detects in their sampling with 0.375 jug/ft2 (the detection limit was reported as
1.5 jug/ft2). The high lead loading value (520 jug/ft2) is the highest background loading reported
in the Staes and Rinehart (1995) summary of studies examining mean pre-abatement floor dust
levels in houses with lead contamination. The value was deemed a reasonable high-end estimate
because the report pertains to homes in which lead levels are elevated sufficiently to necessitate
abatement activities and thus should be on the high end of loading levels in houses with LBP.
Each of these indoor lead loading values was converted to lead concentrations using a conversion
function discussed in Appendix C.
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3.1.2 Outdoor Soil
The outdoor soil lead background concentration range is derived from HUD (2002), which
presents empirical data from a survey of all U.S. housing at the main entrance, dripline and
midyard positions associated with one wall, and dripline and midyard positions associated with a
second wall. The soil lead concentration chosen as a reasonable default value (103.7 ppm) was
the smaller of the 75th percentile concentrations for the two dripline locations. A 75th percentile
concentration was used because, as mentioned in Section 3.1.1, this data set is representative of
all housing in the United States and therefore likely underestimates the background
concentrations for housing with LBP. The same rationale applies to using a dripline value rather
than a midyard value, but the smaller 75th percentile concentration for dripline locations was
used to prevent overcorrection. The low lead concentration value (7.8 ppm), which is the 25th
percentile value for one of the midyard locations in HUD (2002), was deemed a reasonable low
value given that it is the smallest 25th percentile value reported in HUD (2002). The largest
reported 95th percentile concentration across the locations (1,445 ppm) in HUD (2002) was
selected as a reasonable estimation of the high background lead concentration in soil.
3.2 Methodology
This section describes the methodology used to estimate indoor dust and outdoor soil
concentrations for the selected scenarios. As presented in Exhibit 3, either indoor dust or
outdoor soil concentrations, but not both, were estimated for each of the seven selected
scenarios. For scenarios associated with indoor activities, indoor dust concentrations were
estimated; for scenarios associated with outdoor activities, outdoor soil concentrations were
estimated. The methodology applied for estimating both indoor dust and outdoor soil
concentrations is described in detail in Appendix A. This methodology is similar to the approach
used in the Economic Analysis (USEPA 2006a). The primary differences between the approach
used in the Economic Analysis and that used in this assessment are:
• This assessment examined the time-varying nature of exposure concentrations, from pre-
activity through six years after completion of the activity. The Economic Analysis used
annual average indoor dust and outdoor soil exposure concentrations to represent
exposures for the entire exposure duration.
• This assessment reconsidered many of the input values used in the Economic Analysis
and revised these values where appropriate and supported by available data.
Many of the inputs used in this analysis, particularly those used to estimate lead concentrations
in the workspace for each activity, will be revisited in the revised exposure assessment based on
the results of OPPT's dust study. This study is expected to evaluate additional control options
and provide additional datasets that can be used to characterize workspace lead concentrations
for a wider range of activity types.
The remainder of this section briefly describes the steps involved in estimating indoor dust and
outdoor soil concentrations for the baseline and full rule implementation control scenarios. Refer
to Appendix A for a more detailed description of the methodology and to Appendix B for a
description of the inputs used to calculate these concentrations.
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3.2.1 Indoor Dust
3.2.1.1 Baseline
For the baseline control scenarios, indoor dust concentrations were estimated by completing the
following steps:
• Estimated lead loading in the workspace based on the tasks required for the scenario's
activity.
• Converted lead loading to activity lead concentration using a regression model developed
by ICF based on the 1997 HUD National Survey data that established house dust loading-
house dust concentration relationships for unremediated housing units (refer to Appendix
C for more information about this regression model). Added background indoor dust
concentration to activity lead concentration to estimate total indoor dust lead
concentration in the workspace.
• Estimated lead concentration in rooms adjacent to the workspace by applying a
conversion factor that relates workspace dust concentrations to adjacent room
concentrations (see Appendix A for more details). All adjacent rooms were assumed to
have the same concentration.
• Estimated overall house Pb concentration in indoor dust by summing the area-weighted
workspace, adjacent room, and remainder of house (assumed to have background only)
concentrations.
• Estimated the change in overall house Pb concentration in indoor dust over time based on
the estimated household cleaning frequency and cleaning efficiency. When the estimated
concentration reached background concentrations, it was assumed that the indoor dust
concentrations are equal to background for the remainder of the exposure period.
3.2.1.2 Full Rule Implementation
For the full rule implementation control scenarios, indoor dust concentrations were estimated
using the same approach used for the baseline controls, with one exception. For the full rule
implementation scenarios, lead loadings in the workspace were estimated by assuming they are
equal to the EPA floor lead hazard level of 40 jug/ft2 from initiation of the activity through its
completion. This value accounts for the reduction in lead loading associated with the LRRP
Rule controls.
3.2.2 Outdoor Soil
3.2.2.1 Baseline
For the baseline control scenarios, outdoor dust concentrations were estimated by completing the
following steps:
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• Estimated lead loading within the area surrounding the house that will be impacted by the
RRP activity (i.e., within 18" of house). The 18" distance was chosen based on a
University of Illinois (2002) study that found that 94 to 99.8% of lead loading from five
methods of exterior lead paint removal fell between 6" and 18" of the building's
perimeter.
• Converted lead loading to lead concentration based on an assumed soil mixing depth and
soil density and added background to estimate lead concentration in area surrounding
house.
• Estimated overall area-weighted yard concentration of lead using estimated concentration
for area of activity within 18" of house and assuming the remainder of the yard has only
background concentrations. This estimated concentration was assumed to remain until
the end of the exposure period (i.e., no loss processes or cleanup were estimated).
3.2.2.2 Full Rule Implementation
For the full rule implementation control scenarios, outdoor soil concentrations were estimated
using the same approach used for the baseline controls, with one exception. For the full rule
implementation scenarios, it was assumed that the implemented controls were 100 percent
effective in controlling lead loadings to soil. Thus, for these scenarios, soil concentrations were
assumed to be equivalent to background for the entire exposure period. The sensitivity analysis
(described in Section 3.4) assessed the impact of this assumption.
3.3 Estimated Media Concentrations
This section presents the estimated indoor dust or outdoor soil concentrations (depending on the
scenario) for the baseline and full rule implementation control options. For each scenario, the
estimated concentrations fall into the four phases described in Section 1.4: pre-activity, activity,
post-activity (cleanup), and post-activity (background). The concentrations for these phases are
presented in time-series graphs below. In these graphs, negative times on the X-axis refer to
times prior to completion of the activity (i.e., the pre-activity and activity phases). In each graph,
2 to 4 weeks of pre-activity is assumed for presentation purposes; in actual duration of this
period will depend on the assumed starting time for the activity in the blood lead modeling.
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Remodeling Kitchen
The estimated indoor dust concentrations for the "Remodeling Kitchen" scenario are presented in
Exhibit 4. For baseline controls, the estimated indoor dust concentration during the activity is
6,242 |ig/g. After completion of the activity, this concentration returns to background within
approximately 25 weeks. For full rule implementation, the estimated indoor dust concentration
during the activity is 112 |ig/g. After completion of the activity, this concentration returns to
background within five weeks.
Exhibit 4. Indoor Dust Concentrations for "Remodeling Kitchen":
Baseline and Full Rule Implementation Controls
Time Following Completion of Activity (Weeks)
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3.3.1 Three Cutouts
The estimated indoor dust concentrations for the "Three Cutouts" scenario are presented in
Exhibit 5. For baseline controls, the estimated indoor dust concentration during the activity is
768 |ig/g. After completion of the activity, this concentration returns to background within
approximately 16 weeks. For full rule implementation, the estimated indoor dust concentration
during the activity is 108 |ig/g. After completion of the activity, this concentration returns to
background within approximately five weeks.
Exhibit 5. Indoor Dust Concentrations for "Three Cutouts":
Baseline and Full Rule Implementation Controls
900 i
800
0 -I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
-4 -2 0 2 4 6 8 10 12 14 16 18 20 22 24
Time Following Completion of Activity (Weeks)
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3.3.2 Replacing Windows
The estimated indoor dust concentrations for the "Replacing Windows" scenario are presented in
Exhibit 6. For baseline controls, the estimated indoor dust concentration during the activity is
1,003 |ig/g. After completion of the activity, this concentration returns to background within
approximately 17 weeks. For full rule implementation, the estimated indoor dust concentration
during the activity is 108 |ig/g. After completion of the activity, this concentration returns to
background within approximately five weeks.
Exhibit 6. Indoor Dust Concentrations for "Replacing Windows":
Baseline and Full Rule Implementation Controls
1,200 i
Time Following Completion of Activity (Weeks)
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3.3.3 Replacing Exterior Doors
The estimated indoor dust concentrations for the "Replacing Exterior Doors" scenario are
presented in Exhibit 7. For baseline controls, the estimated indoor dust concentration during the
activity is 3,709 |ig/g. After completion of the activity, this concentration returns to background
within approximately 19 weeks. For full rule implementation, the estimated indoor dust
concentration during the activity is 157 |ig/g. After completion of the activity, this concentration
returns to background within approximately six weeks.
Exhibit 7. Indoor Dust Concentrations for "Replacing Exterior Doors":
Baseline and Full Rule Implementation Controls
Time Following Completion of Activity (Weeks)
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3.3.4 Scraping Lead-Based Paint, Interior Flat Component
The estimated indoor dust concentrations for the "Scraping Lead-Based Paint, Interior Flat
Component" scenario are presented in Exhibit 8. For baseline controls, the estimated indoor dust
concentration during the activity is 6,299 |ig/g. After completion of the activity, this
concentration returns to background within approximately 21 weeks. For full rule
implementation, the estimated indoor dust concentration during the activity is 157 |ig/g. After
completion of the activity, this concentration returns to background within approximately six
weeks.
Exhibit 8. Indoor Dust Concentrations for "Scraping Lead-Based Paint, Interior Flat
Component": Baseline and Full Rule Implementation Controls
Time Following Completion of Activity (Weeks)
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3.3.5 Scraping Lead-Based Paint, Interior Door
The estimated indoor dust concentrations for the "Scraping Lead-Based Paint, Interior Door"
scenario are presented in Exhibit 9. For baseline controls, the estimated indoor dust
concentration during the activity is 6,299 |ig/g. After completion of the activity, this
concentration returns to background within approximately 21 weeks. For full rule
implementation, the estimated indoor dust concentration during the activity is 157 |ig/g. After
completion of the activity, this concentration returns to background within approximately six
weeks.
Exhibit 9. Indoor Dust Concentrations for "Scraping Lead-Based Paint, Interior Door":
Baseline and Full Rule Implementation Controls
Time Following Completion of Activity (Weeks)
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3.3.6 Exterior Lead-Based Paint Removal
The estimated outdoor soil concentrations for the "Exterior Lead-Based Paint Removal" scenario
are presented in Exhibit 10. For baseline controls, the estimated outdoor soil concentration
during the activity is 441 |ig/g. For full rule implementation, the estimated outdoor soil
concentration during the activity is 131 |ig/g (i.e., background). These concentrations do not
change after completion of the activity because it was assumed there was no cleanup or
degradation over time.
Exhibit 10. Outdoor Soil Concentrations for "Exterior Lead-Based Paint Removal":
Baseline and Full Rule Implementation Controls
500 n
450
O) 400
O)
=L
350
Q
k_
3 300
"D
O 250
C
o
2 200
£
CD
^ 150
O
o
£ 100
50
0 J 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ,
-4 -2 0 2 4 6 8 10 12
Time Following Completion of Activity (Weeks)
3.3.7 Summary of Results
With baseline controls, the "Scraping Lead-Based Paint, Interior Flat Component" and "Scraping
Lead-Based Paint, Interior Door" activities were associated with the highest indoor dust
concentrations during the activity. The concentrations for both of these activities returned to
background within approximately 21 weeks, which was four weeks sooner than the "Remodeling
Kitchen" activity, which had the next highest indoor dust concentration during the activity. The
overall lead loading in the workspace for the "Remodeling Kitchen" activity was much higher
(more than double) than any other activity, but due to the smaller assumed workspace and
adjacent room sizes, the overall average house concentrations were lower than the "Scraping
Lead-Based Paint" activities during the activity. By the third week, the overall average house
Baseline control:
J
Full rule implementation
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concentrations for the "Remodeling Kitchen" activity are the highest among all activities. The
"Three Cutouts" and "Replacing Windows" activities were associated with the lowest activity
indoor dust concentrations, a result primarily of their lower relative lead loadings. The
"Replacing Exterior Doors" activity was associated with substantially higher (roughly four times
higher) activity concentrations than the "Three Cutouts" and "Replacing Windows" activities,
but lower concentrations (roughly half) than the other three activities. As expected, the full rule
implementation indoor dust concentrations did not vary much across activities, which is largely a
result of the assumption that all workspaces, regardless of activity, will achieve dust loadings of
40 jug/ft2 post-activity. The only differences in the estimated indoor dust concentrations across
activities are driven by the different assumptions about the size of the workspace and adjacent
rooms.
For outdoor soil, only one activity type was considered. The estimated soil concentrations for
baseline controls were over three times higher than the estimated concentration with full rule
implementation. This difference is a direct result of the assumption that the implemented
controls will be 100 percent effective, leaving only background soil concentrations for the full
rule implementation.
3.4 Sensitivity Analysis
3.4.1 Approach
Given the number of inputs involved in calculating indoor dust and soil concentrations for the
selected scenarios, as well as the significant uncertainty associated with many of these inputs, a
sensitivity analysis was performed to evaluate the sensitivity of these calculations to changes in
inputs within a reasonable range. For each input included in the analysis, this range was
represented by a "low" and a "high" value (see Appendix B). These values were not intended to
capture the full range of theoretically possible values; instead, they were selected to represent a
range of values that can be reasonably expected to occur in the types of buildings included in this
assessment. The results of this analysis should not be interpreted as the range of possible
exposure concentrations; instead, they indicate the sensitivity of the exposure concentration
calculations to reasonable changes in these inputs. This analysis will be important in
determining where to focus additional analysis for the revised exposure assessment.
For this analysis, each selected input was changed to its "low" value, and the resulting exposure
concentrations recalculated. Next, the input was changed to its "high" value, and the resulting
exposure concentrations again recalculated. This process was repeated for all selected inputs. In
addition, for the inputs involved in calculating routine cleaning efficiencies, this analysis
examined the impact of varying several of these inputs simultaneously to better capture the
overall range of impacts associated with different routine cleaning assumptions. The results of
this analysis are presented in Appendix D, and discussed in the following sections.
3.4.2 Results
Given the number of inputs considered, the presentation of these results is separated into a series
of tables. In each table, the "Default" column refers to the results calculated using all of the
values in Appendix B in the "Default" column. These results represent the "best guess" results
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for this analysis. The results in the "Low" and "High" columns represent the results when a
particular input was changed from the "Default" value to the "Low" or "High" value.
3.4.2.1 Indoor dust
The first six tables in Appendix D contain the sensitivity results for scenario for the following
parameters:
• Background concentration;
• Conversion from workspace to adjacent room;
• Post-activity cleanup efficiency;
• Percent house workspace;
• Percent house adjacent room; and
• Lead loading.
Each of these tables presents the sensitivity results for a specific input parameter, with each row
of the tables presenting the results for one of the six scenarios. The following inputs had the
widest associated ranges of indoor dust concentrations for baseline controls:
• Percent house workspace;
• Lead loading;
• Post-activity cleanup efficiency.
For the full rule implementation scenario, only one input, "Background soil concentration," had a
significant range. This was expected, as the lead loadings associated with this control scenario
are fairly limited and thus the selected background concentration has a significant impact on the
estimated exposure concentrations. Three of these inputs, "Post-activity Cleanup Efficiency,"
Percent House Adjacent Room," and "Lead Loading," did not have any differences between the
default and sensitivity simulations. In all three cases, this was a result of the methodology used
to estimate activity concentrations for the full rule implementation controls, which assumed a
constant loading based on the lead hazard level instead of using data on actual levels. These
inputs should be reexamined in the revised exposure assessment if data on post-activity
concentrations are available for this control type.
Of the inputs with significant ranges for baseline scenarios, "Percent House Workspace" for the
"Remodeling Kitchen" scenario had the widest range of estimated indoor dust concentrations,
primarily because the default value for this scenario was lower than for the other scenarios and
this scenario had the highest loading, which resulted in higher overall concentrations when the
size of the workspace was increased. This was also the case for the "Scraping LBP, Interior Flat
Component" and "Scraping LBP, Interior Door" scenarios for this input, but to a lesser extent
due to the slightly smaller range of input values and the lower lead loading associated with the
activities. The "Lead Loading" input was associated with a wide range of concentrations for all
six scenarios. This is expected, as this is the input that provides lead loadings to the workspace
based on the activity. Likewise, "Post-activity Cleanup Efficiency" had a wide range of
concentrations across all activities, which was expected based on the fact that this input is
inversely proportional to estimated concentrations.
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To analyze the overall impact of routine cleaning on exposures to lead in indoor dust, values for
the weekly cleaning frequency and routine cleaning efficiency parameters were varied
simultaneously, with one set of exposure estimates for each unique combination of input values
(with the possible values including the "low," "high," and "default" values presented in
Appendix B). The results of these analyses are presented in Exhibit D-7. These calculations
were only performed for a single activity type, "Remodeling Kitchen," to limit the required
analysis. It is expected that the results for other activity types will be consistent with these
results. A summary of the time required for the estimated indoor dust concentrations to reach
background is provided in Exhibit 11. Given the importance of exposure duration in estimating
overall risks, changes in this time are very important to understanding the overall impact of an
input value on estimated risks. As illustrated in this exhibit, there is a wide range of times
associated with the different cleaning frequencies and efficiencies, for both the baseline (from 6
to 112 weeks) and full rule implementation controls (from 1 to 32 weeks).
Exhibit 11. Summary of Sensitivities to Routine Cleaning Input Parameters
Routine
Cleaning
Frequency
Routine
Cleaning
Efficiency
Time Before Background Concentration is Reached
(weeks)
Baseline Controls
Full Rule Implementation
Default
Default
25
5
Default
Min
29
8
Default
Max
11
2
Min
Default
100
20
Min
Min
116
32
Min
Max
44
8
Max
Default
13
3
Max
Min
15
4
Max
Max
6
1
3.4.2.2 Outdoor soil
Exhibit D-l 1 provides the sensitivity results for the "Exterior Paint Removal" scenario for the
following parameters:
• Area within 18 inches of perimeter of home;
• Background soil concentration;
• Efficiency of control;
• Lead loading;
• Percent of house perimeter involved in proj ect;
• Soil density;
• Soil depth; and
• Yard size.
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The following inputs had the widest associated ranges of outdoor soil concentrations:
• Background soil concentration;
• Lead loading;
• Percent of house perimeter involved in activity; and
• Soil depth.
For the full rule implementation scenario, only "Background soil concentration" had a significant
range. This was expected as the lead loadings associated with this control scenario are zero (due
to the assumption of 100 percent control efficiency) and thus the selected background
concentration drives the estimated exposure concentrations. The "Efficiency of Control" had a
small impact, but it was limited by the small range of efficiencies considered. None of the
remaining inputs had any impact, due to the assumption of 100 percent control efficiency in the
default scenario.
For the baseline control scenarios, the widest range of estimated exposure concentrations was
associated with the "Background soil concentration." This input was significant because the
range of values for this input was fairly wide. The "Lead Loading" and "Percent of house
perimeter involved in activity" were influential because they contribute directly to the amount of
lead entering the soil from the activity. "Soil Depth" was somewhat influential due to its use in
converting lead loading into lead concentration.
3.4.3 Conclusions
Given the results of this analysis, it is clear that the uncertainty and variability associated with
several of the input parameters has a significant impact on the estimated indoor dust exposure
concentrations. The values selected for the "Percent House Workspace" and "Lead Loading"
parameters are highly uncertain and, given the sensitivity of the calculations to this input, this
clearly has an impact on the results. Additional data may be available from OPPT's dust study to
refine the loading estimates, but additional data sources would be useful in understanding the
size of workspaces for different types of activities. In addition, all of the values for the cleaning-
related inputs, particularly those associated with routine cleaning, are highly uncertain and have
a substantial impact on the results.
With the exception of "Background Soil Concentration," the inputs used in calculating outdoor
soil concentrations have a relatively smaller impact on estimated exposure concentrations.
3.4.4 Considerations for Revised Exposure Assessment
Although the sensitivity analysis approach used in this draft exposure assessment is useful for
understanding which inputs have the potential to be most influential, it is limited by the range of
input values considered and by the overall methodology. The approach applied for the draft
exposure assessment did not separately consider the relative impact of each input on estimated
exposure concentrations, independent of the range of possible values. It also potentially places
too much emphasis on the selected range of values, which have significant uncertainty.
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In light of these limitations, the revised exposure assessment will consider revising the
distributions of inputs and implementing a more sophisticated sensitivity analysis approach.
Specifically, two additional measures of sensitivity, the elasticity and the sensitivity score, will
be considered for the revised exposure assessment. Elasticity indicates "structural" sensitivity,
while sensitivity score indicates "actual" sensitivity after accounting for the estimated variability
in an input property. The elasticity provides information useful for understanding how the model
operates and is used to compare with expected results, given knowledge of the model and the
processes being simulated. The sensitivity score is useful in the context of assessing the
influence of input properties, or how the variability of the input property affects the variability of
the results.
Elasticity is the percent change in a model output value resulting from a one percent change in
the value of a particular property, with all other properties unchanged. A positive value of
elasticity results from an increase in an input value giving an increased output value, or a
decrease in an input value giving a decreased output value. A negative value of elasticity means
that an input increase resulted in an output decrease, or vice-versa.
The sensitivity score is the elasticity weighted by a normalized measure of the variability and/or
uncertainty of the model input property, which takes the form of a normalized range or
normalized standard deviation of the input property. It provides a measure of the variation in the
output value resulting from the natural variability and uncertainty of the input property by
weighting the elasticity by the coefficient of variation (CV) of the input property. The CVs
quantify the degree of natural variability of the input property and the uncertainty of the estimate
of the input property. It is equal to the standard deviation divided by the mean of the property,
where the standard deviation reflects both variability and uncertainty.
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4. Exposures to Other Sources
As discussed in Section 1.3, exposures via sources other than indoor dust and outdoor soil were
characterized in this assessment. Three sources were identified as relevant for this assessment:
drinking water, non-water diet, and air. For purposes of this assessment, ingestion exposures
associated with these sources were assumed not to be related to soil or indoor dust Pb
concentrations, and all of the exposed children are assumed to receive the same age-specific
background exposures.
All of the exposed populations (i.e., children under six years of age) are assumed to consume
drinking water with the same "typical" Pb exposure concentration. While there is a rather large
amount of data in the literature, in many cases, the data are from "first-draw" samples, non-
random ("priority") samples, or from communities where Pb levels were known to be elevated.
After reviewing the literature, the average drinking water concentration exposure was estimated
to be 4.61 |ig/L, based on data from two recent studies of residential water concentrations in U.S.
and Canadian homes and apartments (Moir et al. 1996, Clayton et al. 1999). The range of values
seen in these studies (0.84 to 16 |ig/L) was considered to be representative of randomly sampled
residential water in houses constructed since Pb pipe and solder were banned for residential use.
The selected value is close to the "default" value (4.0 (J,g/L) recommended for use with the
IEUBK model when evaluating the blood Pb impacts of soil contamination (USEPA 1994).
Much higher values have been encountered in homes with Pb piping and/or very corrosive water.
In addition to drinking water, it is expected that young children will be exposed to Pb in the
foods they consume. In this assessment, all exposed children are assumed to receive the age-
specific estimates of dietary Pb intake developed by EPA's Office of Solid Waste and
Emergency Response (USEPA 2006b). EPA developed these estimates by analyzing food
consumption data from the NHANES III survey conducted by the National Center for Health
Statistics, and food residue data from the U.S. Food and Drug Administration's (FDA) Total
Dietary Study. The daily intake values shown in Exhibit 11 are considerably lower than those
developed using the same methodology in the 1980s and 1990s. Pb concentrations in food have
decreased dramatically since the prohibition of Pb solder in food containers in 1982.
Exhibit 11. Summary of Non-Water Dietary Pb Intake Estimates
Age
Category
(months)
Updated Dietary
Pb Intake
Estimate
(Mg/day)
0-11
3.16
12-23
2.6
24-35
2.87
36-47
2.74
48-59
2.61
60-71
2.74
72-84
2.99
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There is some potential for double-counting of water and dietary Pb intake because some food
categories (e.g., baby formula, soup) are prepared using domestic water. This double-counting is
minimized by limiting the estimated intake of domestic water to "direct ingestion" (i.e.,
consumption direct from the tap).
Background inhalation exposures were also considered in this assessment. As discussed in
Chapter 1, sufficient data were not available to characterize inhalation exposures associated with
different RRP activities and therefore these exposures were not characterized separately for each
activity. Instead, a "typical" ambient air concentration of Pb in the U.S was estimated based on a
review of the 2005 annual average total suspended particulate (TSP) monitoring data for Pb
contained in EPA's Air Quality Systems (AQS) database (USEPA 2006c). The range of
concentrations in this database is quite large, with a 5th percentile concentration of 0.002 |ig/m3
and a 95th percentile concentration of 0.37 |ig/m3. Based on these data, the median concentration
(0.025 |ig/m3) was selected as the inhalation exposure concentration. This value is likely biased
high because lead monitors are often located in areas with nearby lead emission sources. If the
blood lead modeling indicates that inhalation exposures are significant contributors to overall
blood lead levels, this value may need to be reconsidered.
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5. References
Battelle. 2005. Using the IEUBK Model to Predict Geometric Mean Blood-Lead Concentration
in Children Aged 1-2 Years as a Function of Hand Dust-Lead Concentration.
Clayton, C. A.; Pellizzari, E. D.; Whitmore, R. W.; Perritt, R. L., Quackenboss, J. J. (1999)
National human exposure assessment survey (NHEXAS): distributions and associations of lead,
arsenic, and volatile organic compounds in EPA Region 5. J. Exposure Anal. Environ.
Epidemiol. 9: 381-392.
Clemson Environmental Technologies Laboratory (CETL). 2001. A Comparison of Post-
Renovation and Remodeling Surface Cleaning Techniques. Prepared for EPA's Office of
Pollution Prevention and Toxics. December 14.
U.S. Department of Housing and Urban Development (HUD). 2002. National Survey of Lead
and Allergens in Housing, Volume I: Analysis of Lead Hazards. Prepared by Westat, Inc
(Rockville, MD) for the Office of Healthy Homes and Lead Hazard Control (Washington, D.C.).
October 31.
HUD. 2004. Evaluation of the HUD Lead-Based Paint Hazard Control Grant Program.
Prepared by the National Center for Healthy Housing and The University of Cincinnati
Department of Environmental Health for the Office of Healthy Homes and Lead Hazard Control.
May.
ICF. 2006. Lead Human Exposure and Health Risk Assessments and Ecological Risk
Assessment for Selected Areas, Pilot Phase: External Review Draft Technical Report. Prepared
for EPA's Office of Air Quality Planning and Standards (Research Triangle Park, NC).
December.
Jacobs DE, Clickner RP, Zhou JY, Viet SM, Marker DA, Rogers JA, Zeldin DC, Broene P,
Friedman W. 2002. The prevalence of lead-based paint hazards in U.S. housing. Environ.
Health Perspect. 110(10):A599-A606.
Moir, C. M.; Freedman, B.; McCurdy, R. (1996) Metal mobilization from water-distribution
systems of buildings serviced by lead-pipe mains. Can. Water Resour. J. 21: 45-52.
Staes, C. and R. Rinehart. 1995. Does Residential Lead-Based Paint Hazard Control Work? A
Review of Scientific Evidence. Prepared for the National Center for Lead-Safe Housing. April
4.
University of Illinois at Urbana-Champaign. 2002. Comparative Analysis of Exterior Paint
Removal Methods: Lead Exposures and Production When Preparing Exterior Clapboard Siding.
University of Illinois at Urbana-Champaign, Building Research Council, School of Architecture.
EPA Grant Agreement. (Unpublished grant report, as cited in USEPA 2006a).
U.S. Census Bureau. 1995. Property Owners and Managers Survey (POMS).
http://www.census.gov/hhes/www/housing/poms/poms.html
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U.S. Census Bureau. 1997 and 2003. American Housing Survey (AHS).
http://www.census.gov/hhes/www/housing/ahs/ahs.html
U.S. Environmental Protection Agency (USEPA). 1994. Technical Support Document:
Parameters and Equations Used in the Integrated Exposure Uptake Biokinetic Model for Lead in
Children (v.099d). Office of Solid Waste. EPA 540/R-94/040.
USEPA. 1997. Lead Exposure Associated with Renovation and Remodeling Activities:
Environmental Field Sampling Study, Volume I: Technical Report. Prepared by Battelle
(Columbus, OH) for the Office of Pollution Prevention and Toxics (Washington, D.C.). EPA
747-R-96-007. May.
USEPA. 1998. Risk Analysis to Support Standards for Lead in Paint, Dust, and Soil. Office of
Pollution Prevention and Toxics. EPA 747-R-97-006.
USEPA. 2001. Economic Analysis of Toxic Substances Control Act Section 403: Lead-Based
Paint Hazard Standards. EPA's Office of Pollution Prevention and Toxics. Economics,
Exposure, and Technology Division. Economic and Policy Analysis Branch. December 21.
USEPA. 2006a. Economic Analysis for the Renovation, Repair, and Painting Program Proposed
Rule. Office of Pollution Prevention and Toxics, Washington, D.C. February.
USEPA. 2006b. Specific estimates of dietary Pb intake developed by EPA's Office of Solid
Waste and Emergency Response. Available at:
http://www.epa.gOv/superfund/lead/ieubkfaq.htm#FDA.
USEPA. 2006c. U.S. Environmental Protection Agency (USEPA). AirData: Access to Air
Pollution Data through the Air Quality Systems (AQS) database. Available at
http://www.epa.gov/air/data.
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Appendix A. Methodology for Calculating Indoor Dust and
Outdoor Soil Concentrations
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Appendix A describes the calculations used to estimate Pb concentrations prior to, during, and
after each activity for each control option, as described in Section 1.4. Sections A.l, A.2, A.3,
A.4, and A.5, respectively, identify the calculations and assumptions associated with pre-activity
concentrations (background), concentrations during activity, post-activity concentrations (initial
cleanup), post-activity concentrations (routine cleanup), and post-activity concentrations
(background).
A. 1 PRE-ACTIVITY BACKGROUND PB CONCENTRATIONS
A.l.l Indoor Dust
As described in Section 3.1.1, background indoor dust levels were derived from the literature in
terms of lead loading (|ig/ft2). In order to calculate background indoor dust concentrations, these
loadings were converted to concentrations using the regression equation described in Appendix
C, which is summarized below.
(4.028687+0.608317 (ln(DLOADBG )))
Regression Equation: DCONCbg = ^ (Eq. 1)
where: DCONCbg = background indoor dust concentration, in |ig/g
DLOADbg = background indoor dust loading, in jug/ft2
This concentration was assumed to represent indoor dust concentrations for the period prior to
initiation of the activity.
A. 1.2 Outdoor Soil
The selected values for background outdoor soil lead concentrations, described in Section 3.1.2,
are in terms of concentration and thus did not require any additional calculations. The selected
concentration was assumed to represent outdoor soil concentrations for the period prior to
initiation of the activity.
A.2 PB CONCENTRATIONS DURING ACTIVITY
A.2.1 Indoor Dust - Baseline Controls
As presented in Exhibit 3, there are seven RRP activities included in this draft exposure
assessment. Six of these activities are assumed to contribute to indoor dust Pb concentrations.
These concentrations are estimated based on the lead loading associated with the activity, the
size of the house and workspace, and the background concentration. For this draft exposure
assessment, indoor dust concentrations are calculated as whole house averages and therefore
need to account for not only dust concentrations in the workspace, but also in adjacent rooms and
in the rest of the house. Concentrations in the workspace are calculated based on the activity,
concentrations in adjacent rooms are calculated as a percentage (16 percent, see Appendix B for
further explanation) of the concentrations in the workspace, and concentrations in the remainder
of the house are assumed to be at background (see Section A. 1.1). The total area-weighted Pb
concentration in indoor dust for a housing unit is calculated as:
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DCONCh,bl,a = (PAW)*(DCONCwork) + (PAA)*(DCONCAd]) + (PAR)*(DCONCBG) (Eq. 2)
or
DCONChbla = (PA W) *(DCONCWork)+(PAA) *(WS-to-ADJ) *(DCONCWork)+(l-PA W-PAA) *(DCONCBG)
(Eq. 3)
where: DCONCh
BL,A
PAW
DCONCwork
PAA
DCONCAdj
PAR
DCONCbg
WS-to-ADJ
Average indoor dust Pb concentration in housing unit with
baseline controls during the activity, in |ig/g
Percent area workspace (see Exhibit B-3)
Indoor dust Pb concentration in the workspace, in |ig/g (see
below)
Percent area adjacent room (see Exhibit B-3)
Indoor dust Pb concentration in the adjacent room, in |ig/g
(calculated as WS-to-ADJ * CONCwork)
Percent area rest of house (calculated as 1-PAW-PAA)
Background indoor dust Pb concentration, in |ig/g (see
Section A. 1.1)
Conversion from workspace lead concentration to adjacent
room lead concentration (see Exhibit B-2)
The only input whose values are not provided in Appendix B or calculated as described above is
DCONCwork. The values for this input are a function of the types of work the activity involves,
the amount of loading each type of work produces, and the number of times which a specific task
is performed. DCONCwork is calculated as:
(4.0425+0.5848(ln (DLOADWork)))
DCONCwork = e (Eq. 4)
where:
DLOADwork
NUMi
DLOAD,
Y,{NUM1 * DLOAD,)
Number of times task i is performed for this activity
Lead loading associated with one instance of task
in jug/ft2 (see Exhibit B-l)
Exhibit A-l provides the types and number of tasks each activity involves.
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Exhibit A-l. Tasks Associated with Each Type of Activity
Number of times tasks performed
Activity
s
5 &
a 5
s a
© 4>
U
=
©
0)
p
S3
>
•- ©
§ S
p Si
01)
e
p
*°
1 i
a. u
o/j
=
£
(Z3
Remodeling Kitchen
10
1
12
Scraping LBP, Interior Flat Component
Scraping LBP, Interior Door
Three Cutouts
Replacing Windows
1
1
Replacing Exterior Doors
1
1
Source: ICF estimates, based on data provided in U.S. Census Bureau 1995, 1997, and
2003
A.2.2 Indoor Dust - Full Rule Implementation
Indoor dust concentrations with full rule implementation are calculated in much the same way as
those with baseline controls. There are two primary differences, however. First, instead of
defining DCONCWork as a function of the activity, it is defined as a constant loading that is
independent of the activity. This loading is set to EPA's floor Pb hazard threshold of 40 jug/ft2 to
account for the reduction in Pb loading associated with the LRRP controls. Second, it is
assumed that Pb loading is fully contained within the workspace. Therefore, the post-activity Pb
concentration in any adjacent room (DCONCadj) is assumed to be equivalent to the pre-activity
background concentration (DCONCbg) The total area weighted indoor dust Pb concentration
within a housing unit for full rule implementation is calculated as follows:
DCONCh,fr,a = (PAW)*(DCONCFloor) + (PAA)*(DCONCbg) + (PAR)*(DCONCBG) (Eq. 5)
where: DCONCFioor = ^
DCONCh,fr,a
DLOADpioor
DCONC,,oor
PAW
PAA
PAR
(4.028687+0.608317 (In (DLOADFhor)))
(Eq. 6)
Average indoor dust Pb concentration in housing unit with
full rule implementation during the activity, in |ig/g
Lead loading in the workspace with full rule
implementation, based on EPA floor hazard threshold (40
l-ig/ft2)
Indoor dust Pb concentration in the workspace based on
EPA floor Pb hazard threshold, in |ig/g (see below)
Percent area workspace (see Exhibit B-3)
Percent area adjacent room (see Exhibit B-3)
Percent area rest of house (calculated as 1-PAW-PAA)
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A-3
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
DCONCbg = Background indoor dust Pb concentration, in |ig/g (see
Section A. 1.1)
A.2.3 Outdoor Soil - Baseline Controls
Only one of the seven RRP activities presented in Exhibit 3 is assumed to contribute to outdoor
soil concentrations, "Exterior Lead-Based Paint Removal." Average lead concentrations in soil
across the yard for this activity were calculated using the following equation:
SCONCy s a = (1 - PercImpactYard) * SCONCBG + PercImpactYard * (SCONCAct + SCONCBG)
(Eq. 7)
where:
SCONC
Y,S,A
PercImpactYard =
SCONCbg
SCONC
Act
Average outdoor soil concentration in yard for
baseline controls during the activity, |ig/g
Percent of yard impacted by activity
Background outdoor soil Pb concentration, in |ig/g
(see Section A. 1.2)
Outdoor soil concentration in area surrounding
house that is impacted by activity, in |ig/g
The area of impact of this activity is assumed to be the dripline, which is assumed to extend 18
inches from the house (see Section 3.2.2.1). PercImpactYard is calculated based on the following
equation:
PercImpactYard = (ArealnDripline * PercHouselmpact) / YardSize (Eq. 8)
where: ArealnDripline
PercHouselmpact
YardSize
Area surrounding the house that falls within
the dripline (assumed to be 18"), in m2
Percent of the house impacted by the activity
(see Exhibit B-4)
size of yard, in m2
SCONCAct is calculated based on the estimated loading from the activity, the size of the yard, the
percentage of the yard impacted by the activity, soil characteristics, and the efficiency of the
controls. These concentrations were estimated using the following equation:
SLOADAct * 0.001
fi2
SCONCAct =
cm
SoilDepth * SoilDensity
1,000-^- * ControlEfficiency (Eq. 9)
mg
where:
SLOAD
Act
SoilDepth
SoilDensity
ControlEffi ci ency
Lead loading associated with activity, mg/ft
(see Exhibit B-4)
Soil mixing depth, in cm (see Exhibit B-4)
Density of soil, in g/cm3 (see Exhibit B-4)
Efficiency of control (see Exhibit B-4)
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A-4
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
A.2.4 Outdoor Soil - Full Rule Implementation
Outdoor soil concentrations with full rule implementation are calculated in the same way as the
baseline control concentrations. The only differences in concentrations are a result of different
control efficiency assumptions.
A.3 LEAD CONCENTRATIONS POST-ACTIVITY (INITIAL CLEANUP)
There are no differences in how baseline and full rule implementation concentrations are
calculated for the post-activity (initial cleanup) period. The only differences in the estimated
concentrations result from differences in input values.
A.3.1 Indoor Dust
Lead concentrations in indoor dust immediately after the post-activity initial cleanup are
calculated using the following equation:
A.3.2 Outdoor Soil
It is assumed that there is no cleanup or degradation of Pb in outdoor soil; therefore, the post-
activity (initial cleanup) concentrations are identical to the activity concentrations.
A.4 LEAD CONCENTRATIONS POST-ACTIVITY (ROUTINE CLEANUP)
A.4.1 Indoor Dust
Lead concentrations in indoor dust following the post-activity initial cleanup are a function of the
frequency and efficiency of routine cleaning. After each cleaning, the lead concentration in
indoor dust is estimated using the following equation:
DCONCh,pa,o = DCONCila * PostActCleanEfficiency (Eq. 10)
where: DCONCn. ,PA,0
DCONCha
PostActCleanEfficiency
DCONCh,rc,t = DCONCh,rc,t-i * RoutineCleanEfficiency (Eq. 11)
where: DCONCh,rc,x
Average indoor dust Pb concentration in
housing unit after cleaning X after completion
of activity, in |ig/g
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AS
December 2006
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DCONCn. rc,x-i — Average indoor dust Pb concentration in
housing unit after cleaning (X-l) after
completion of activity, in |ig/g
RoutineCleanEfficiencyx = Post-activity cleanup efficiency for the Xth
cleaning (see Exhibit B-l)
RoutineCleanEfficiencyx is assumed to change with each subsequent cleaning through the 10th
cleaning (after the 10th, it is assumed to remain constant), as described in Exhibit B-l. To
estimate the indoor dust concentration at any single time, the time (in weeks) is multiplied by the
weekly cleaning frequency to calculate the number of cleanings that have occurred to that point.
Based on the number of cleanings, the indoor dust concentration is calculated based on Equation
11. It is assumed that indoor dust concentrations do not change between cleanings.
A.4.2 Outdoor Soil
It is assumed that there is no cleanup or degradation of Pb in outdoor soil; therefore, the post-
activity (routine cleanup) concentrations are identical to the activity concentrations.
A.5 LEAD CONCENTRATIONS POST-ACTIVITY (BACKGROUND)
A.5.1 Indoor Dust
Post-activity Pb concentrations will gradually decrease until they have reached the background
concentrations which existed prior to initiation of the activity. These values are calculated by
applying the post-activity initial and routine cleanup efficiencies over time. Background
concentrations in indoor dust are calculated as described in Section A. 1.1.
A.5.2 Outdoor Soil
It is assumed that there is no cleanup or degradation of Pb in outdoor soil; therefore, the post-
activity (background) concentrations are identical to the activity concentrations.
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December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Appendix B. Inputs Used for Estimating Media Concentrations for
Baseline and Full Rule Implementation Control Scenarios
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This appendix presents the input parameter values used in this assessment. Appendix A
describes how each of these parameters is used. This appendix presents the input values in five
tables. The first table, Exhibit B-l, presents all of the input values used to calculate indoor dust
exposures that are not specific to a particular activity or control type. Exhibit B-2 presents all of
the input values used to calculate indoor dust exposures that are specific to the control type and
independent of activity type. Exhibit B-3 presents that input values used to calculate indoor dust
exposures that are specific to activity type and independent of control type. There are no input
parameters that are specific to both the activity type and control type. Exhibit B-4 presents all of
the input values used to calculate outdoor soil exposures that are not specific to a particular
control type, and Exhibit B-5 presents all of the input values used to calculate outdoor soil
exposures that are specific to a particular control type. Only one activity type was estimated to
contribute to outdoor soil exposures and thus there were no activity type-specific input values.
DRAFT—DO NOT CITE OR QUOTE
B-l
December 2006
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Exhibit B-
. Inputs for Indoor Dust Exposure Concentration Calculal
ions - All Control Options and Activity Types
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Background
indoor dust
concentration
86
31
2,522
Mg/g
V
HUD 2002
See Section 3.1.1
Cleaning
frequency
1
0.25
2
cleanings/
week
V
HUD 2002
These values are estimated based
on the following inferences from the
HUD 2002 data: 57% of homes are
cleaned at least weekly, 25% of
homes are cleaned at least once
every two weeks, 10% of homes
are cleaned every 3 weeks, 3% of
homes are cleaned at least once
per month, and 5% of homes are
cleaned less than once per month.
These inferences were used to
estimate that the high number of
cleanings is twice per week, the
default number of cleanings is once
per week, and the low number of
cleanings is once every four weeks.
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B-2
December 2006
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INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Loading -
Component
removal
549
549
592
|jg/ft2
USEPA 1997
The maximum air concentration for
one unit or hour (139 |jg/m3,
USEPA 1997) was divided by the
average concentration for one unit
or hour (129 |jg/m3, USEPA 1997)
to get 1.08. This was multiplied by
the default loading value (549
|jg/ft2, USEPA 1997) to get a high
value of 592 |jg/ft2. No low-end air
concentrations were provided, so
the default loading factor was used.
Loading -
Demolition
1,505
1,505
5,570
|jg/ft2
USEPA 1997
The maximum air concentration for
one unit or hour (396 |jg/m3,
USEPA 1997) was divided by the
average concentration for one unit
or hour (107 |jg/m3, USEPA 1997)
to get 3.70. This was multiplied by
the default loading value (1,505
|jg/ft2, USEPA 1997) to get a high
value of 5,570 )jg/ft2. No low-end
air concentrations were provided,
so the default loading factor was
used.
Loading -
Door removal
5,912
5,912
44,856
|jg/ft2
USEPA 1997
The maximum air concentration for
one unit or hour (3,953 |jg/m3,
USEPA 1997) was divided by the
average concentration for one unit
or hour (521 |jg/m3, USEPA 1997)
to get 7.59. This was multiplied by
the default loading value (5,912
|jg/ft2, USEPA 1997) to get a high
value of 44,856 )jg/ft2. No low-end
air concentrations were provided,
so the default loading factor was
used.
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B-3
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Loading -
Drilling
112
112
1,945
|jg/ft2
USEPA 1997
The maximum air concentration for
one unit or hour (191 |jg/m3,
USEPA 1997) was divided by the
average concentration for one unit
or hour (11 |jg/m3, USEPA 1997) to
get 17.36. This was multiplied by
the default loading value (112
|jg/ft2, USEPA 1997) to get a high
value of 1,945 |jg/ft2. No low-end
air concentrations were provided,
so the default loading factor was
used.
Loading -
Paint
removal
9,118
9,118
50,547
|jg/ft2
USEPA 1997
The maximum air concentration for
one unit or hour (3,110 |jg/m3,
USEPA 1997) was divided by the
average concentration for one unit
or hour (561 |jg/m3, USEPA 1997)
to get 5.54. This was multiplied by
the default loading value (9,118
|jg/ft2, USEPA 1997) to get a high
value of 50,547 )jg/ft2. No low-end
air concentrations were provided,
so the default loading factor was
used.
Loading -
Sawing
6,539
6,539
40,534
|jg/ft2
USEPA 1997
The maximum air concentration for
one unit or hour (2,151 |jg/m3,
USEPA 1997) was divided by the
average concentration for one unit
or hour (347 |jg/m3, USEPA 1997)
to get 6.20. This was multiplied by
the default loading value (6,539
|jg/ft2, USEPA 1997) to get a high
value of 40,534 )jg/ft2. No low-end
air concentrations were provided,
so the default loading factor was
used.
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B-4
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Routine
cleaning
efficiency
1st: 49%
2nd: 25%
3rd: 23%
4th: 22%
5th: 22%
6th: 22%
7th: 20%
8th: 20%
9th: 15%
10th: 20%
11+: 20%
1st: 21%
2nd: 21%
3rd: 20%
4th: 19%
5th: 20%
6th: 20%
7th: 19%
8th: 18%
9th: 16%
10th: 19%
11+: 19%
1st: 76%
2nd: 40%
3rd: 38%
4th: 36%
5th: 38%
6th: 40%
7th: 33%
8th: 50%
9th: 0%
10th: 50%
11+: 50%
%
V
Yiin 2002;
USEPA 1997
Values developed based on
cleaning efficiency data for multiple
cleanings for carpet (Yiin 2002) and
non-carpeted surfaces (USEPA
1997). The efficiencies were area-
weighted based on an assumption
of 36% carpet and 64% non-
carpeted surfaces (from USEPA
2006a, Chapter 5, page 12).
Default values are based on the
midpoint of the ranges presented in
Yiin 2002 and USEPA 1997, low
values are based on the minimums,
and high values are based on the
maximums.
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B-5
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit B-2.
nputs for Indoor Dust Exposure Concentration Calculations - Contro
Scenario-Specific, All Activity Types
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
No plastic, basic cleanup (baseline controls)
Conversion
from
workspace lead
concentration
to adjacent
room lead
concentration
0.16
0.095
0.225
unitless
USEPA 1997
Calculated the conversion factor based on
comparison of average airborne lead
concentrations (from USEPA 1997) for
window replacements for the same room
(7.5 |jg/m3) and the adjacent room (1.2
|jg/m3). This ratio was calculated as 1.2
|jg/m3 / 7.5 |jg/m3 = 0.16 and is expected
according to the analysis to be
characteristic of the "workroom-adjacent
room" floor lead loadings relationship for
other work components. The low-end
value is based on the maximum measured
airborne lead concentrations for window
replacements provided in the same table
for the workroom (44.3 |jg/m3) and the
adjacent room (4.2 |jg/m3). There was no
high-end value provided, so one was
estimated by taking the difference between
the default and low values and adding that
to the default.
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B-6
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Post-activity
cleanup
efficiency
53%
0%
89%
%
V
Yiin 2002;
USEPA 1997;
USEPA
2006a (Chp 5,
P9 12);
CETL2001
The default value was calculated based on
the midpoint of the range of carpet cleaning
efficiencies from Yiin 2002 (25.3%) and the
non-carpeted surface cleaning efficiency of
68.4% from USEPA (1997), weighted by
the percentage of house that is carpeted
(36%) vs. not carpeted (64%) (from
USEPA 2006a, Chapter 5, page 12). The
low value assumes no cleanup occurs
post-activity. The high value was
calculated based on the maximum
carpeted cleaning efficiency (84%) and the
maximum non-carpeted cleaning efficiency
reported in CETL 2001, weighted by the
percentage of house that is carpeted (36%)
vs. not carpeted (64%) (from USEPA
2006a, Chapter 5, page 12).
Plastic, full cleanup (full rule implementation)
Conversion
from
workspace lead
concentration
to adjacent
room lead
concentration
0
0
0.16
unitless
Assumption;
USEPA 1997
Assumed that the control measures will
completely prevent the transfer of lead out
of the workspace. Therefore, the default
and low conversion factors are assumed to
be zero. The high conversion factor is
assumed to equal the default conversion
factor for the baseline scenario.
Total lead dust
(loading plus
background)
40
40
40
ng/ft2
Assumption,
based on
USEPA 2001
Assumed that the proposed containment,
cleaning and cleaning verification of the
rule cumulatively results in floor lead dust
levels below the USEPA clearance level of
40 |jg/ft2, as reported in USEPA 2001. It is
assumed that this refers to total lead dust
and not lead dust loading only.
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B-7
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit B-3. Inputs for Indoor Dust Exposure Concentration Calculations - All Controls, Activity Type-Specific
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
REMODELING KITCHEN
Lead loading
180,158
180,158
1,021,397
ng/ft2
Calculated
See Appendix A
Percentage of
house that is
workspace
6.0%
3.0%
30.0%
%
V
US Census
Bureau
1997,
2003;
USEPA
2006a
Based on calculations performed in USEPA
2006a (which are based on data from US
Census Bureau 1997, 2003) that provide the
percentage of the house that is work area for
kitchen projects. There is no explicit range
provided for this type of project, but a range of
percentages is provided across project types,
from 3% for bathrooms to 30% for non-room-
specific events.
Percentage of
house that is
adjacent room
6.0%
3.0%
30.0%
%
Assumption
Assumed that the percentage of the home
constituted by the adjacent rooms is equal to
the percentage constituted by the workspace.
THREE CUTOUTS
Lead loading
6,539
6,539
40,534
ng/ft2
Calculated
See Appendix A
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B-8
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Percentage of
house that is
workspace
5%
3%
30%
%
V
US Census
Bureau
1997,
2003;
USEPA
2006a
Based on calculations performed in USEPA
2006a (which are based on data from US
Census Bureau 1997, 2003) that provide the
percentage of the house that is work area for a
range of different types of projects. None of
these types match this activity type. Given the
relatively small scale of this activity, the size for
the "Addition" activity was selected as the
default because it was relatively small and
considered reasonably similar to this activity.
There is no explicit range provided for that type
of project, but a range of percentages is
provided across project types, from 3% for
bathrooms to 30% for non-room-specific events.
Percentage of
house that is
adjacent room
5%
3%
30%
%
V
Assumption
Assumed that the percentage of the home
constituted by the adjacent rooms is equal to
the percentage constituted by the workspace.
REPLACING WINDOWS
Lead loading
10,623
10,623
56,117
ng/ft2
Calculated
See Appendix A
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B-9
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Percentage of
house that is
workspace
5%
3%
30%
%
V
US Census
Bureau
1997,
2003;
USEPA
2006a
Based on calculations performed in USEPA
2006a (which are based on data from US
Census Bureau 1997, 2003) that provide the
percentage of the house that is work area for a
range of different types of projects. None of
these types match this activity type. Given the
relatively small scale of this activity, the size for
the "Addition" activity was selected as the
default because it was relatively small and
considered reasonably similar to this activity.
There is no explicit range provided for that type
of project, but a range of percentages is
provided across project types, from 3% for
bathrooms to 30% for non-room-specific events.
Percentage of
house that is
adjacent room
5%
3%
30%
%
V
Assumption
Assumed that the percentage of the home
constituted by the adjacent rooms is equal to
the percentage constituted by the workspace.
REPLACING EXTERIOR DOORS
Lead loading
15,030
15,030
95,403
ng/ft2
Calculated
See Appendix A
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B-10
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Percentage of
house that is
workspace
16%
3%
30%
%
V
US Census
Bureau
1997,
2003;
USEPA
2006a
Based on calculations performed in USEPA
2006a (which are based on data from US
Census Bureau 1997, 2003) that provide the
percentage of the house that is work area for
the average household event across event
types. None of these types match this activity
type. The uncertainty associated with this value
is significant as the percentage would vary
depending on how many doors were replaced
and in how many rooms. The range for this
parameter was set based on the range of
percentages provided for across project types,
from 3% for bathrooms to 30% for non-room-
specific events. The average of this range is
selected as the default.
Percentage of
house that is
adjacent room
16%
3%
30%
%
V
Assumption
Assumed that the percentage of the home
constituted by the adjacent rooms is equal to
the percentage constituted by the workspace.
SCRAPING LEAD-BASED PAINT, INTERIOR FLAT COMPONENT
Lead loading
36,472
36,472
202,188
ng/ft2
Calculated
See Appendix A
Percentage of
house that is
workspace
16%
3%
30%
%
US Census
Bureau
1997,
2003;
USEPA
2006a
Based on calculations performed in USEPA
2006a (which are based on data from US
Census Bureau 1997, 2003) that provide the
percentage of the house that is work area for
the average household event across event
types. None of these types match this activity
type. The range for this parameter was set
based on the range of percentages provided for
across project types from 3% for bathrooms to
30% for non-room-specific events. The
average of this range is selected as the default.
DRAFT—DO NOT CITE OR QUOTE
B-ll
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Percentage of
house that is
adjacent room
16%
3%
30%
%
V
Assumption
Assumed that the percentage of the home
constituted by the adjacent rooms is equal to
the percentage constituted by the workspace.
SCRAPING LEAD-BASED PAINT, INTERIOR DOOR
Lead loading
36,472
36,472
202,188
ng/ft2
Calculated
See Appendix A
Percentage of
house that is
workspace
16%
3%
30%
%
V
US Census
Bureau
1997,
2003;
USEPA
2006a
Based on calculations performed in USEPA
2006a (which are based on data from US
Census Bureau 1997, 2003) that provide the
percentage of the house that is work area for
the average household event across event
types. None of these types match this activity
type. The range for this parameter was set
based on the range of percentages provided for
across project types from 3% for bathrooms to
30% for non-room-specific events. The
average of this range is selected as the default.
Percentage of
house that is
adjacent room
16%
3%
30%
%
Assumption
Assumed that the percentage of the home
constituted by the adjacent rooms is equal to
the percentage constituted by the workspace.
DRAFT—DO NOT CITE OR QUOTE
B-12
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit B-4. Inputs for Outdoor Soil Exposure Concentration Calculations - All Control Types
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
Background outdoor
soil concentration
103.7
7.8
1,445
ng/g
V
HUD 2002
See Section 3.1.2
Lead Loading
34,145
10,071
58,218
mg/ft2
V
University of
Illinois 2002 (as
cited in USEPA
2006a)
The low value is based on paint shaver
exterior paint removal, while the high
value is based on heat gun exterior
paint removal. The default value was
calculated as the average of these two
values.
Soil mixing depth
3.5
5.0
2.0
cm
V
USEPA 1986
Soil density
1.36
1.10
1.60
g/cm3
V
USEPA 1986
1.1 is dry density for clay, 1.6 is dry
density for sand, and 1.36 is for loam
soil.
Size of Yard
4,703
2,988
6,417
ft2
V
USEPA 2001
Area within 18 inches
of perimeter of house
302
202
402
ft2
V
US Census
Bureau 1997,
2003; USEPA
2006a
Calculation (presented in USEPA
2006a) based on data from US Census
Bureau 1997 and 2003.
Percentage of house
perimeter impacted by
activity
63%
25%
100%
%
V
USEPA 2006a
DRAFT—DO NOT CITE OR QUOTE
B-13
December 2006
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DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibi
B-5. Inputs for Outdoor Soil Exposure Concentration Calculations -
Control Type-Specific
INPUTS
DEFAULT
LOW
HIGH
UNITS
IN
SENSITIVITY
ANALYSIS?
SOURCE
NOTES
No plastic, basic cleanup (baseline controls)
Efficiency of control
0.0%
0.0%
0.0%
%
X
Assumption
Based on the assumption that there is
no cleaning or soil replacement for
exterior renovations for baseline
controls and that there is no
degradation of lead overtime.
Plastic, full cleanup (full rule implementation)
Efficiency of control
100%
94%
100%
%
X
Assumption,
based on
USEPA 2006a
(p. 15)
Based on the assumption that under
the full rule implementation controls,
plastic would be rolled out to 10 ft from
the foundation and removed at the
completion of the activity. 94% was
determined to be the high value as a
University of Illinois study concluded
that 94 to 99% of lead falls on a 12" by
12" plate centered on the work area
and placed 6" from the perimeter. It is
unclear whether the remaining lead
would also fall within the drip line (e.g.,
in the 6" between the plate and
perimeter or to the left or right of the
centered plate) or beyond.
Presumably, the 10 ft of plastic from
the perimeter would catch the
remainder as long as it did not settle
beyond 10 ft. It is important to note
that it is unclear when the study
measurements were taken.
Measurements one hour after stripping
vs. at the end of repainting could
produce different values if contractors
walk on the plastic and then on the
remainder of the yard or the lead dust
on the plastic becomes windblown.
DRAFT—DO NOT CITE OR QUOTE
B-14
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Appendix C. Description of Approach for Converting Lead
Loadings to Lead Concentrations
DRAFT—DO NOT CITE OR QUOTE
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
The relationship between house dust loading and lead concentration for this report comes from
the ICF (2006) analysis of a data set developed as part of HUD's 1997 National Survey. The
analysis was used because it appears to use the largest, most nationally representative source of
both house dust loading and concentration data taken simultaneously from the same households
completed to date. To the extent that these data do not reflect the dust loading-dust
concentration relationship in the types of buildings included in this assessment, the indoor dust
lead concentrations will be biased (ICF 2006).
The data consisted of 305 wipe sample and dust concentration measurements taken from 284
households (USEPA 1998, Appendix C). The data were stratified into four vintage ranges from
pre-1940 to post-1979. The data from all four ranges were pooled for the analysis. Log-Log
regression provided the best fit and regression diagnostics. Two dust concentration data points,
one with a value about five-fold below the next lowest, and one with a value more than 10-fold
above the next highest concentration, were excluded from the analysis. The dust concentration
model derived in this manner is displayed in the formula below and Exhibit C-l (ICF 2006). The
statistics associated with this model are presented in Exhibit C-2.
In (House dust lead concentration, |ig/g) = 4.028687 + 0.608317 * In (Dust loading, |ig/ft2)
Exhibit C-l. Regression Analysis of HUD National Survey
House Dust Lead Loading and Concentration Data
ln(Dust Loading, Wipe Sample), ug/sq. ft
DRAFT—DO NOT CITE OR QUOTE
C-l
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit C-2. Statistics for Regression Analysis of HUD National Survey
House Dust Lead Loading and Concentration Data
Adjusted R2
Standard error of
the estimate
F-statistic
F-significance
0.521
0.747
328.871
3.46E-50
T-value (intercept)
P-value (intercept)
T-value (x variable)
P-value (x variable)
50.151
3.5E-148
18.135
3.46E-50
The regression analysis relating lead loading and lead dust concentrations in this report differs
from the Battelle (2005) regression analysis cited in USEPA (2006a). It is important to note that
the ICF (2006) analysis was not complete prior to the development of the USEPA (2006a) report.
There are a number of reasons that the ICF (2006) regression analysis was used in place of
Battelle (2005). First, ICF (2006) uses a data set developed as part of HUD's 1997 National
Survey largest, which is currently the most nationally representative source of house dust loading
and concentration data taken simultaneously from the same households. Second, the Battelle
(2005) regression is based off of only three data points compared to the 307 data points used in
ICF (2006). As noted in Battelle (2005), the analysis only represented a rough investigation of
the mathematical relationship between loading and concentration and was "primarily meant to
prompt discussion for further investigation" (Battelle 2005). Third, it is unclear whether the
three Battelle (2005) data points, which are pairs of geometric floor dust lead loadings and
geometric mean hand-lead levels, are based off of data where the loadings and hand-lead levels
were collected simultaneously from the same households. Fourth, the Battelle (2005) is not a
direct comparison of floor lead loading and lead dust concentrations, but rather a relationship
between hand-lead concentrations (|ig/hand) and floor dust-lead loadings. In order to
approximate lead concentrations (|ig/g dust), the authors had to make a number of assumptions
that were not documented (e.g., a child is assumed on average to lick one-third of a hand).
DRAFT—DO NOT CITE OR QUOTE
C-2
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Appendix D. Detailed Exposure Concentration Results
DRAFT—DO NOT CITE OR QUOTE
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-l. Area-Weighted Indoor Dust Lead Concentration Results (jig Pb/g dust) for
the "Background Dust Concentration" Input Parameter, Immediately after Initial Cleanup
(No Routine Cleaning Considered)
Scenario
Indoor Dust Pb concentrations (jig Pb/g dust)
Baseline
Full rule implementation
Default
Low
High
Default
Low
High
Remodeling Kitchen
3,433
3,380
5,792
112
61
2,403
Scraping LBP, Interior Flat
Component
3,459
3,409
5,690
157
111
2,204
Scraping LBP, Interior Door
3,459
3,409
5,690
157
111
2,204
Three Cutouts
455
401
2,827
108
56
2,423
Replacing Windows
582
529
2,955
108
56
2,423
Replacing Exterior Doors
2,050
2,000
4,281
157
111
2,204
Exhibit D-2. Area-Weighted Indoor Dust Lead Concentration Results (jig Pb/g dust) for
the "Conversion from Workspace to Adjacent Room" Input Parameter, Immediately after
Initial Cleanup (No Routine Cleaning Considered)
Scenario
Indoor Dust Pb concern
trations (jug Pb/g dust)
Baseline
Full rule implementation
Default
Low
High
Default
Low
High
Remodeling Kitchen
3,433
3,088
3,778
112
112
117
Scraping LBP, Interior Flat
Component
3,459
3,111
3,807
157
157
170
Scraping LBP, Interior Door
3,459
3,111
3,807
157
157
170
Three Cutouts
455
416
493
108
108
112
Replacing Windows
582
531
634
108
108
112
Replacing Exterior Doors
2,050
1,847
2,253
157
157
170
DRAFT—DO NOT CITE OR QUOTE
D-l
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-3. Area-Weighted Indoor Dust Lead Concentration Results (jig Pb/g dust) for
the "Post-Activity Cleanup Efficiency" Input Parameter, Immediately after Initial Cleanup
(No Routine Cleaning Considered)
Scenario
Indoor Dust Pb concern
trations (jug Pb/g dust)
Baseline
Full rule implementation
Default
Low
High
Default
Low
High
Remodeling Kitchen
3,433
6,242
1,493
112
112
112
Scraping LBP, Interior Flat
Component
3,459
6,299
1,498
157
157
157
Scraping LBP, Interior Door
3,459
6,299
1,498
157
157
157
Three Cutouts
455
768
238
108
108
108
Replacing Windows
582
1,003
292
108
108
108
Replacing Exterior Doors
2,050
3,709
904
157
157
157
Exhibit D-4. Area-Weighted Indoor Dust Lead Concentration Results (jig Pb/g dust) for
the "Percent House Workspace" Input Parameter, Immediately after Initial Cleanup
(No Routine Cleaning Considered)
Scenario
Indoor Dust Pb concent
trations (jig Pb/g dust)
Baseline
Full rule implementation
Default
Low
High
Default
Low
High
Remodeling Kitchen
3,433
2,184
13,425
112
99
219
Scraping LBP, Interior Flat
Component
3,459
1,415
5,661
157
99
219
Scraping LBP, Interior Door
3,459
1,415
5,661
157
99
219
Three Cutouts
455
345
1,829
108
99
219
Replacing Windows
582
434
2,433
108
99
219
Replacing Exterior Doors
2,050
860
3,331
157
99
219
DRAFT—DO NOT CITE OR QUOTE
D-2
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-5. Area-Weighted Indoor Dust Lead Concentration Results for the "Percent
House Adjacent Room" Input Parameter, Immediately after Initial Cleanup
(No Routine Cleaning Considered)
Scenario
Indoor Dust Pb concentrations (jig Pb/g dust)
Baseline
Full rule implementation
Default
Low
High
Default
Low
High
Remodeling Kitchen
3,433
3,008
6,830
112
112
112
Scraping LBP, Interior Flat
Component
3,459
2,763
4,209
157
157
157
Scraping LBP, Interior
Door
3,459
2,763
4,209
157
157
157
Three Cutouts
455
417
925
108
108
108
Replacing Windows
582
532
1215
108
108
108
Replacing Exterior Doors
2,050
1,644
2,487
157
157
157
Exhibit D-6. Area-Weighted Indoor Dust Lead Concentration Results for the "Lead
Loading" Input Parameter, Immediately after Initial Cleanup
(No Routine Cleaning Considered)
Scenario
Indoor Dust Pb concentrations (jig Pb/g dust)
Baseline
Full rule implementation
Default
Low
High
Default
Low
High
Remodeling Kitchen
3,433
3,433
9,708
112
112
112
Scraping LBP, Interior
Flat Component
3,459
3,459
9,661
157
157
157
Scraping LBP, Interior
Door
3,459
3,459
9,661
157
157
157
Three Cutouts
455
455
1,210
108
108
108
Replacing Windows
582
582
1,456
108
108
108
Replacing Exterior
Doors
2,050
2,050
6,146
157
157
157
DRAFT—DO NOT CITE OR QUOTE
D-3
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-7. Indoor Dust Concentrations for "Kitchen Renovation" Activity
with Varied Routine Cleaning Efficiency (RCE) and Cleaning Frequency (CF), Baseline Controls3
Week
CF-default
RCE-default
CF-default
RCE-min
CF-default
RCE-max
CF-min
RCE-default
CF-min
RCE-min
CF-min
RCE-max
CF-max
RCE-default
CF-max
RCE-min
CF-max
RCE-max
0
3433
3433
3433
3433
3433
3433
3433
3433
3433
1
1804
2726
880
3433
3433
3433
1367
2173
559
2
1367
2173
559
3433
3433
3433
849
1428
269
3
1065
1751
378
3433
3433
3433
547
946
148
4
849
1428
269
1804
2726
880
376
653
100
5
678
1159
196
1804
2726
880
279
470
90
6
547
946
148
1804
2726
880
205
334
86
7
451
778
124
1804
2726
880
158
245
86
8
376
653
100
1367
2173
559
128
187
86
9
331
562
100
1367
2173
559
109
149
86
10
279
470
90
1367
2173
559
97
123
86
11
238
395
86
1367
2173
559
91
107
86
12
205
334
86
1065
1751
378
87
96
86
13
179
285
86
1065
1751
378
86
91
86
14
158
245
86
1065
1751
378
86
87
86
15
141
213
86
1065
1751
378
86
86
86
16
128
187
86
849
1428
269
86
86
86
17
117
166
86
849
1428
269
86
86
86
18
109
149
86
849
1428
269
86
86
86
19
102
135
86
849
1428
269
86
86
86
20
97
123
86
678
1159
196
86
86
86
21
93
114
86
678
1159
196
86
86
86
22
91
107
86
678
1159
196
86
86
86
23
89
101
86
678
1159
196
86
86
86
24
87
96
86
547
946
148
86
86
86
25
86
93
86
547
946
148
86
86
86
26
86
91
86
547
946
148
86
86
86
27
86
89
86
547
946
148
86
86
86
28
86
87
86
451
778
124
86
86
86
29
86
86
86
451
778
124
86
86
86
30
86
86
86
451
778
124
86
86
86
DRAFT—DO NOT CITE OR QUOTE
D-4
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-7. Indoor Dust Concentrations for "Kitchen Renovation" Activity
with Varied Routine Cleaning Efficiency (RCE) and Cleaning Frequency (CF), Baseline Controls3
Week
CF-default
RCE-default
CF-default
RCE-min
CF-default
RCE-max
CF-min
RCE-default
CF-min
RCE-min
CF-min
RCE-max
CF-max
RCE-default
CF-max
RCE-min
CF-max
RCE-max
31
86
86
86
451
778
124
86
86
86
32
86
86
86
376
653
100
86
86
86
33
86
86
86
376
653
100
86
86
86
34
86
86
86
376
653
100
86
86
86
35
86
86
86
376
653
100
86
86
86
36
86
86
86
331
562
100
86
86
86
37
86
86
86
331
562
100
86
86
86
38
86
86
86
331
562
100
86
86
86
39
86
86
86
331
562
100
86
86
86
40
86
86
86
279
470
90
86
86
86
41
86
86
86
279
470
90
86
86
86
42
86
86
86
279
470
90
86
86
86
43
86
86
86
279
470
90
86
86
86
44
86
86
86
238
395
86
86
86
86
45
86
86
86
238
395
86
86
86
86
46
86
86
86
238
395
86
86
86
86
47
86
86
86
238
395
86
86
86
86
48
86
86
86
205
334
86
86
86
86
49
86
86
86
205
334
86
86
86
86
50
86
86
86
205
334
86
86
86
86
51
86
86
86
205
334
86
86
86
86
52
86
86
86
179
285
86
86
86
86
53
86
86
86
179
285
86
86
86
86
54
86
86
86
179
285
86
86
86
86
55
86
86
86
179
285
86
86
86
86
56
86
86
86
158
245
86
86
86
86
57
86
86
86
158
245
86
86
86
86
58
86
86
86
158
245
86
86
86
86
59
86
86
86
158
245
86
86
86
86
60
86
86
86
141
213
86
86
86
86
61
86
86
86
141
213
86
86
86
86
DRAFT—DO NOT CITE OR QUOTE
D-5
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-7. Indoor Dust Concentrations for "Kitchen Renovation" Activity
with Varied Routine Cleaning Efficiency (RCE) and Cleaning Frequency (CF), Baseline Controls3
Week
CF-default
RCE-default
CF-default
RCE-min
CF-default
RCE-max
CF-min
RCE-default
CF-min
RCE-min
CF-min
RCE-max
CF-max
RCE-default
CF-max
RCE-min
CF-max
RCE-max
62
86
86
86
141
213
86
86
86
86
63
86
86
86
141
213
86
86
86
86
64
86
86
86
128
187
86
86
86
86
65
86
86
86
128
187
86
86
86
86
66
86
86
86
128
187
86
86
86
86
67
86
86
86
128
187
86
86
86
86
68
86
86
86
117
166
86
86
86
86
69
86
86
86
117
166
86
86
86
86
70
86
86
86
117
166
86
86
86
86
71
86
86
86
117
166
86
86
86
86
72
86
86
86
109
149
86
86
86
86
73
86
86
86
109
149
86
86
86
86
74
86
86
86
109
149
86
86
86
86
75
86
86
86
109
149
86
86
86
86
76
86
86
86
102
135
86
86
86
86
77
86
86
86
102
135
86
86
86
86
78
86
86
86
102
135
86
86
86
86
79
86
86
86
102
135
86
86
86
86
80
86
86
86
97
123
86
86
86
86
81
86
86
86
97
123
86
86
86
86
82
86
86
86
97
123
86
86
86
86
83
86
86
86
97
123
86
86
86
86
84
86
86
86
93
114
86
86
86
86
85
86
86
86
93
114
86
86
86
86
86
86
86
86
93
114
86
86
86
86
87
86
86
86
93
114
86
86
86
86
88
86
86
86
91
107
86
86
86
86
89
86
86
86
91
107
86
86
86
86
90
86
86
86
91
107
86
86
86
86
91
86
86
86
91
107
86
86
86
86
92
86
86
86
89
101
86
86
86
86
DRAFT—DO NOT CITE OR QUOTE
D-6
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-7. Indoor Dust Concentrations for "Kitchen Renovation" Activity
with Varied Routine Cleaning Efficiency (RCE) and Cleaning Frequency (CF), Baseline Controls3
Week
CF-default
RCE-default
CF-default
RCE-min
CF-default
RCE-max
CF-min
RCE-default
CF-min
RCE-min
CF-min
RCE-max
CF-max
RCE-default
CF-max
RCE-min
CF-max
RCE-max
93
86
86
86
89
101
86
86
86
86
94
86
86
86
89
101
86
86
86
86
95
86
86
86
89
101
86
86
86
86
96
86
86
86
87
96
86
86
86
86
97
86
86
86
87
96
86
86
86
86
98
86
86
86
87
96
86
86
86
86
99
86
86
86
87
96
86
86
86
86
100
86
86
86
86
93
86
86
86
86
101
86
86
86
86
93
86
86
86
86
102
86
86
86
86
93
86
86
86
86
103
86
86
86
86
93
86
86
86
86
104
86
86
86
86
91
86
86
86
86
105
86
86
86
86
91
86
86
86
86
106
86
86
86
86
91
86
86
86
86
107
86
86
86
86
91
86
86
86
86
108
86
86
86
86
89
86
86
86
86
109
86
86
86
86
89
86
86
86
86
110
86
86
86
86
89
86
86
86
86
111
86
86
86
86
89
86
86
86
86
112
86
86
86
86
87
86
86
86
86
113
86
86
86
86
87
86
86
86
86
114
86
86
86
86
87
86
86
86
86
115
86
86
86
86
87
86
86
86
86
116
86
86
86
86
86
86
86
86
86
a Cells in grey indicate concentrations above background.
DRAFT—DO NOT CITE OR QUOTE
D-7
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-8. Indoor Dust Concentrations for "Kitchen Renovation" Activity
with Varied Routine Cleaning Efficiency (RCE) and Cleaning Frequency (CF), Full Rule Implementation Controls3
Week
CF-default
RCE-default
CF-default
RCE-min
CF-default
RCE-max
CF-min
RCE-default
CF-min
RCE-min
CF-min
RCE-max
CF-max
RCE-default
CF-max
RCE-min
CF-max
RCE-max
0
112
112
112
112
112
112
112
112
112
1
97
106
88
112
112
112
93
100
86
2
93
100
86
112
112
112
88
93
86
3
90
96
86
112
112
112
86
89
86
4
88
93
86
97
106
88
86
86
86
5
86
91
86
97
106
88
86
86
86
6
86
89
86
97
106
88
86
86
86
7
86
87
86
97
106
88
86
86
86
8
86
86
86
93
100
86
86
86
86
9
86
86
86
93
100
86
86
86
86
10
86
86
86
93
100
86
86
86
86
11
86
86
86
93
100
86
86
86
86
12
86
86
86
90
96
86
86
86
86
13
86
86
86
90
96
86
86
86
86
14
86
86
86
90
96
86
86
86
86
15
86
86
86
90
96
86
86
86
86
16
86
86
86
88
93
86
86
86
86
17
86
86
86
88
93
86
86
86
86
18
86
86
86
88
93
86
86
86
86
19
86
86
86
88
93
86
86
86
86
20
86
86
86
86
91
86
86
86
86
21
86
86
86
86
91
86
86
86
86
22
86
86
86
86
91
86
86
86
86
23
86
86
86
86
91
86
86
86
86
24
86
86
86
86
89
86
86
86
86
25
86
86
86
86
89
86
86
86
86
26
86
86
86
86
89
86
86
86
86
27
86
86
86
86
89
86
86
86
86
28
86
86
86
86
87
86
86
86
86
29
86
86
86
86
87
86
86
86
86
30
86
86
86
86
87
86
86
86
86
DRAFT—DO NOT CITE OR QUOTE
D-8
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-8. Indoor Dust Concentrations for "Kitchen Renovation" Activity
with Varied Routine Cleaning Efficiency (RCE) and Cleaning Frequency (CF), Full Rule Implementation Controls3
Week
CF-default
RCE-default
CF-default
RCE-min
CF-default
RCE-max
CF-min
RCE-default
CF-min
RCE-min
CF-min
RCE-max
CF-max
RCE-default
CF-max
RCE-min
CF-max
RCE-max
31
86
86
86
86
87
86
86
86
86
32
86
86
86
86
86
86
86
86
86
33
86
86
86
86
86
86
86
86
86
34
86
86
86
86
86
86
86
86
86
35
86
86
86
86
86
86
86
86
86
a Cells in grey indicate concentrations above background.
DRAFT—DO NOT CITE OR QUOTE
D-9
December 2006
-------
DRAFT FOR CASAC CONSULTATION ON FEBRUARY 5, 2007
Exhibit D-9. Area-Weighted Outdoor Soil Lead Concentration Results
Immediately after Activity Initiation Using the "Exterior Lead-Based Paint
Removal" Scenario
Input Parameter
Outdoor soil Pb concentrations (jig Pb/g soil)
Jaseline
Full rule implementation
Default
Low
High
Default
Low
High
Area within 18 inches of
perimeter
441
338
544
131
131
131
Background soil concentration
441
318
1,755
131
8
1,445
Efficiency of control
441
441
441
131
149
131
Lead Loading
441
222
660
131
131
131
Percent of house perimeter
involved in activity
441
255
627
131
131
131
Size of yard
441
619
358
131
131
131
Soil density
441
514
394
131
131
131
Soil depth
441
348
673
131
131
131
DRAFT—DO NOT CITE OR QUOTE
D-10
December 2006
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