United States Office of Emergency OSWER 9285.7-50 

Environmental Protection and Remedial Response August 2003 EPAAgency 

Superfund 

Lead-Contaminated 

Residential Sites Handbook 

Final: August 2003 

Prepared by the 

Environmental Protection Agency 

Lead Sites Workgroup (LSW) 

NOTICE 

This document has been reviewed in accordance with U.S. 

EPA policy and is approved for publication. Mention of trade 

names or commercial products does not constitute 

endorsement or recommendation. 
ii 

DISCLAIMER

This document provides guidance to EPA Regions concerning how the Agency intends to 

exercise its discretion in implementing one aspect of the CERCLA remedy selection process. 

The guidance is designed to implement national policy on these issues. 

Some of the statutory provisions described in this document contain legally binding 

requirements. However, this document does not substitute for those provisions or regulations, 

nor is it a regulation itself. Thus, it cannot impose legally-binding requirements on EPA, states, 

or the regulated community, and may not apply to a particular situation based upon the 

circumstances. Any decisions regarding a particular remedy selection will be made based on the 

statute and regulations, and EPA decision makers retain the discretion to adopt approaches on a 

case-by-case basis that differ from this guidance where appropriate. 

Interested parties are free to raise questions and objections about the substance of this guidance 

and the appropriateness of the application of this guidance to a particular situation, and the 

Agency welcomes public input on this document at any time. EPA may change this guidance in 

the future. 
iii 

CONTRIBUTING MEMBERS of 

Lead Sites Workgroup of

U.S. Environmental Protection Agency

Shahid Mahmud, Co-Chair 

U.S. EPA HQ

Bus: (703) 603-8789

E-mail: mahmud.shahid@epa.gov

Monica McEaddy 

U.S. EPA HQ

Bus: (202) 603-0044

E-mail: mceaddy.monica@epa.gov

Ron Morony 

U.S. EPA HQ

Bus: (202) 260-0282

E-mail: morony.ronald@epa.gov

Byron Mah

U.S. EPA Region 1

Bus: (617) 918-1249

E-mail: mah.byron@epa.gov

Mark Maddaloni 

U.S. EPA Region 2

Bus: (212) 637-3765

E-mail: maddaloni.mark@epa.gov

Khai Dao 

U.S. EPA Region 3

Bus: (215) 814-5467

E-mail: dao.khai@epa.gov

Charlie Root 

U.S. EPA Region 3

Bus: (215) 814-3193

E-mail: root.charlie@epa.gov

Beth Walden 

U.S. EPA Region 4

Bus: (404) 562-8814

E-mail: walden.beth@epa.gov

Brad Bradley, Co-Chair 

U.S. EPA Region 5

Bus: (312) 886-4742

E-mail: bradley.brad@epa.gov

Rafael Casanova 

U.S. EPA Region 6

Bus: (214) 665-7437

E-mail: casanova.rafael@epa.gov

Mark Doolan 

U.S. EPA Region 7

Bus: (913) 551-7169

E-mail: doolan.mark@epa.gov

Sara Sparks 

U.S. EPA Region 8

Bus: (406) 782-7415

E-mail: sparks.sara@epa.gov

Shea Jones 

U.S. EPA Region 9

Bus: (415) 972-3148

E-mail: jones.shea@epa.gov

Sean Sheldrake 

U.S. EPA Region 10

Bus: (206) 553-1220

E-mail: sheldrake.sean@epa.gov

Steve Jones 

ATSDR

Bus: (703) 603-8729

E-mail: jones.steve@epa.gov
iv 

CONTENTS

DISCLAIMER ...................................................................... ii

CONTRIBUTING MEMBERS of Lead Sites Workgroup of U.S. Environmental Protection Agency . . iii

CONTENTS ........................................................................ iv

LIST OF TABLES AND FIGURES ..................................................... vi

ACRONYMS ...................................................................... vii

1.0 INTRODUCTION ............................................................ 1

1.1 BACKGROUND ........................................................ 4

1.2 GENERAL DISCUSSION ON CERCLA’S APPLICABILITY TO LEAD SITES ............ 4

1.2.1 Background ..................................................... 4

1.2.2 Response Authorities ............................................. 5

1.2.3 Applicable or Relevant and Appropriate Requirements (ARARs) ........... 6

1.3 DEFINITION AND PURPOSE ............................................... 7

2.0 COMMUNITY INVOLVEMENT .................................................. 9

2.1 EDUCATION ACTIVITIES ................................................ 9

2.2 COMMUNITY ADVISORY GROUPS ........................................ 10

2.3 EPA’S TECHNICAL ASSISTANCE GRANT PROGRAM ........................... 11

2.4 INFORMATIONAL MEETINGS ............................................ 12

2.5 COMMUNITY INVOLVEMENT SPECIALIST/COORDINATOR ...................... 13

3.0 HEALTH EDUCATION ....................................................... 14

3.1 APPROPRIATE USES FOR HEALTH EDUCATION .............................. 14

3.2 PLANNING FOR HEALTH EDUCATION ...................................... 14

3.3 EVALUATION OF HEALTH EDUCATION ACTIVITIES ........................... 15

3.4 AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR) INVOLVEMENT 15

3.5 OUTREACH ......................................................... 16

4.0 SITE CHARACTERIZATION ................................................... 17

4.1 CONTAMINANT ZONE DELINEATION ...................................... 17

4.2 RESIDENTIAL PROPERTIES .............................................. 19

4.2.1 Sampling Access ................................................ 19

4.2.2 Residential Yards ............................................... 21

4.2.3 Drip Zones .................................................... 23

4.2.4 Play Areas, Gardens, and Driveways ................................ 24

4.2.5 Potable Water, Lead-Based Paint and Interior Dust ..................... 24

4.2.6 Backfill and Waste Soil .......................................... 24

4.3 SAMPLING METHOD AND ANALYSIS ...................................... 25

4.3.1 Sample Collection ............................................... 25

4.3.2 Sample Depth .................................................. 25

4.3.3 Sample Preparation .............................................. 27

4.3.4 Sample Analysis ................................................ 27

5.0 CLEAN-UP LEVEL SELECTION ................................................ 29

5.1 PRIORITIZING RESPONSE ACTIONS ....................................... 29

5.2 LONG-TERM REMEDIAL ACTION ......................................... 35

6.0 APPLICATION OF CLEAN-UP NUMBERS/REMEDIATION ............................. 37

6.1 MINIMUM EXCAVATION DEPTH/SOIL COVER THICKNESS ...................... 37

6.2 SOIL CLEAN-UP OPTIONS ............................................... 38

6.3 INTERPRETING SAMPLING RESULTS ....................................... 39

6.4 OTHER CLEANUP CONSIDERATIONS ...................................... 44

6.4.1 Background Lead Concentrations ................................... 45
v 

6.5 YARD CLEANUP SPECIFICS ............................................. 46

6.6 CLEANUP OF OTHER SOURCES OF LEAD ................................... 49

6.6.1 Lead-Based Paint ............................................... 50

6.6.2 Interior Dust ................................................... 50

6.6.3 Lead Plumbing/Tap Water ........................................ 52

6.7 PREVENTION OF RECONTAMINATION ...................................... 53

6.7.1 Early Actions .................................................. 56

6.7.2 Long-term Remedial Action ....................................... 57

6.7.3 Institutional Controls (ICs) ........................................ 58

6.8 CLEAN-UP DOCUMENTATION ............................................ 61

6.9 ENFORCEMENT ...................................................... 62

7.0 FIVE-YEAR REVIEW ....................................................... 64

8.0 FEDERAL FACILITIES ....................................................... 66

REFERENCES ..................................................................... 70

APPENDIX A Title X and EPA’s Toxic Substances Control Act (TSCA) Title IV Lead 

Program .......................................................... A-1

APPENDIX B 1998 OSWER Directive 9200.4-27P (‘Clarification’) ...................... B-1

APPENDIX C Contacts and Software for Sampling Design .............................. C-1

APPENDIX D Examples of Property Access Agreement Forms ........................... D-1

APPENDIX E Example of Dust Abatement Access Form ................................ E-1

APPENDIX F Example of Property Inspection Checklist ................................. F-1

APPENDIX G Examples of Property Closeout Forms ................................... G-1

APPENDIX H Examples of Clean Letters ............................................ H-1
vi 

LIST OF TABLES AND FIGURES

Table 4-1. 

Rationale for Sampling Residential Properties ....................................... 20

Figure 1-1. An Overview to the Clean-up Process .......................................... 3

Figure 4-1a. Recommended minimum soil sampling in yards less than or equal to 5,000 square feet with

small side yard. ................................................................ 21

Figure 4-1b. Recommended minimum soil sampling in yards less than or equal to 5,000 square feet with

substantial side yard. ........................................................... 22

Figure 4-2. Recommended minimum soil sampling in yards greater than 5,000 square feet ......... 23

Figure 5-1. Recommended clean-up process for lead-contaminated residential sites. .............. 30

Figure 6-1. Interpreting Sampling Results. ............................................... 40

Figure 6-2a. Partial cleanup of residential lot less than or equal to 5,000 square feet in size. ........ 42

Figure 6-2b. Partial cleanup of residential lot greater than 5,000 square feet in size ............... 43

Figure 6-3. Implementing Best Management Practices (BMPs) during construction work .......... 55
vii 

ACRONYMS

ARARs Applicable or Relevant and 

Appropriate Requirements 

ASTM American Society for Testing 

and Materials 

ASTSWMO Association of State and 

Territorial Solid Waste 

Management Officials 

ATSDR Agency for Toxic Substances 

and Disease Registry 

BMPs Best Management Practices 

BRAC Base Realignment and Closure 

CAGs Community Advisory Groups 

CERCLA Comprehensive Environmental 

Response, Compensation, and 

Liability Act 

CIC/CIS Community Involvement 

Coordinator/ Specialist 

DOD Department of Defense 

FOSL Finding of Suitability to Lease 

FOST` Finding of Suitability to 

Transfer 

FP-XRF Field-Portable X-Ray 

Fluorescence 

HUD Department of Housing and 

Urban Development 

IC Institutional Control 

LBP Lead-Based Paint 

IEUBK Integrated Exposure Uptake 

Biokinetic Model for Lead in 

Children 

LSCG Lead Sites Consultation Group 

MCL Maximum Contaminant Level 

NCP National Contingency Plan 

NLLAP National Lead Laboratory 

Accreditation Program 

NTCRA Non-Time-Critical Removal 

Action 

OSWER EPA Office of Solid Waste and 

Emergency Response 

PRG Preliminary Remediation Goal 

PRP Potentially Responsible Party 

RCRA Resource Conservation and 

Recovery Act 

SEP Supplemental Environmental 

Project 

TAG Technical Assistance Grant 

TCLP Toxicity Characteristic 

Leaching Procedure 

TCRA Time-Critical Removal Action 

TITLE X Title X of the Housing and 

Community Development Act 

of 1992, 42 U.S.C. 4822 

TRW EPA Technical Review 

Workgroup 

TSCA Toxic Substances Control Act 

UAO Unilateral Administrative Order 
1 

1.0 INTRODUCTION 

This Superfund Lead-Contaminated Residential Sites Handbook (subsequently called the 

Handbook) has been developed by the U.S. Environmental Protection Agency (EPA) to promote a 

nationally consistent decision-making process for assessing and managing risks associated with leadcontaminated residential sites across the country. 

The primary audience for this risk management document is Superfund project managers working 

on the characterization and cleanup of lead-contaminated residential sites; however, Resource 

Conservation and Recovery Act (RCRA) project managers may also find it useful. This information was 

developed primarily for EPA staff, but may prove useful to others working on lead-contaminated 

residential sites, including states, other federal agencies, tribes, local governments, public interest groups, 

and private industry. While this Handbook is not intended to apply to lead-contaminated commercial or 

industrial properties, other non-residential areas, or sites with ecological risks, some of the concepts may 

be useful for such properties. Addressing lead-contaminated properties at federal facilities requires a 

different approach, and this Handbook provides a special section (Section 8) on addressing this universe 

of sites. 

Generally, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 

response actions are undertaken to address a release or threat of release of a hazardous substance such as 

lead into the environment. Lead contamination found inside homes may be caused by deteriorating leadbased paint (LBP), plumbing, or other sources not resulting from a release into the environment, and 

therefore may be more appropriately addressed by authorities and programs other than CERCLA (see 

Appendix A and Section 6.6 of this Handbook). However, it may be appropriate to use CERCLA 

authorities to conduct sampling and site characterization activities to determine the source of the lead 

contamination and to differentiate between various site-related sources. 

The Handbook lays out only the minimum considerations for addressing lead-contaminated 

residential sites and encourages users to refer to appropriate agency guidance and/or policy to conduct 

more stringent investigation and clean-up activities on a site-specific basis, if necessary. In addition, the 

site manager should determine the applicable and relevant or appropriate requirements (ARARs), 

including state laws and regulations, that apply to the site. It should also be noted that this Handbook 

does not, outside the federal facilities universe, apply to lead-contaminated residential sites addressed 

under Title X (HUD, 1992) procedures. 

Lead site characterization and clean-up procedures are unique owing to the ubiquitous nature of 

lead exposures and the reliance on blood lead concentrations to describe lead exposure and toxicity. Lead 
2 

risks are characterized by predicting blood lead levels with computer models and guidance developed by 

EPA, which are available on the internet: http://www.epa.gov/superfund/programs/lead/products.htm. 

Major improvements in the removal of lead from gasoline, paint, and food packaging have significantly 

reduced the incidence of severe lead poisoning. The results of this progress mean that most 

environmental sources of lead exposure are more likely to cause subtle adverse health effects, primarily 

behavioral and learning impairments. 

An overview to the clean-up process is provided as Figure 1-1. Section numbers are provided in 

the figure to help the reader locate information within this document. 
3 

Figure 1-1. An Overview to the Clean-up Process 

Start 

Research site 

history/nature of 

contamination 

(Section 4.1) 

Sampling Goals 

•determine extent of contamination -

interior/exterior 

•risk assessment model inputs 

•prioritize response actions 

(Section 4.0) 

Community Involvement 

(Section 2.0) 

Goals: 

•engage/involve stakeholders 

•buy-in by stakeholders 

•reduce blood lead in children 

5 year review 

(if required) 

(Section 7.0) 

END 

CAGS/TAGS 

(Sections 2.2, 2.3) 

health education 

(Sections 2.1, 3.0) 

blood lead study/survey in children 

(Sections 2.1, 3.4, 7.0) 

Cleanup residential properties: 

TCRA, NTCRA, Remedial 

(Sections 5.0, 6.0) 

Delineate zone(s) of 

contamination 

(Sections 4.1, 4.3.2) 

Prioritize response 

actions 

(Section 5.1) 
4 

1.1 BACKGROUND 

Elevated blood lead concentrations in young children in the United States are still prevalent in 

many areas. Major sources of lead contamination historically included mining and milling sites, primary 

and secondary smelters, battery manufacturing and recycling facilities, pesticide formulators, pesticide 

use in orchards, and paint manufacturers (prior to 1978). Many of the source facilities are located near 

residential areas or have had residential areas develop around them. Fugitive emissions from the facilities 

have resulted in soil contamination in the yards of residences, which in turn can cause high blood lead 

levels in children. 

Although numerous sites of this type exist, EPA has remediated, or overseen the remediation of, 

many of these sites and surrounding residences. Many different clean-up methods have been 

implemented with varying degrees of success. This document is based on the lessons learned from EPA’s 

experience in remediating residential lead sites. It is intended to promote consistency in the 

characterization and cleanup of lead-contaminated residential sites, while retaining the flexibility needed 

to respond to different sites and communities to ensure success of the remedy and provide long-term 

protection of human health. The document also provides guidance on addressing lead sources and media 

that the Superfund does not usually remediate, such as LBP and lead plumbing. It is anticipated that this 

information will be periodically updated as we strive to improve our ability to respond to environmental 

lead hazards. 

1.2 GENERAL DISCUSSION ON CERCLA’S APPLICABILITY TO LEAD SITES 

This section provides a general discussion of the sections of CERCLA that address lead-contaminated sites. A description of Title X and EPA’s Toxic Substances Control Act (TSCA) IV Lead Program 

is provided in Appendix A. The Title X discussion is provided for informational purposes and is 

primarily applicable to federal facilities. Section 4.2.5 also provides useful information for LBP and dust 

sampling. 

1.2.1 Background 

Historically, the CERCLA has been used as a tool to implement clean-up activities at a large 

number of sites across the country. CERCLA authorities have been used for cleanups ranging from the 

removal of drums of hazardous substances from long-abandoned sites, to major privately funded remedial 

actions at sites on the National Priorities List (NPL). 
5 

CERCLA may apply any time there is a release or threatened release of: (1) a hazardous substance 

into the environment, or (2) a pollutant or contaminant "which may present an imminent and substantial 

endangerment to the public health or welfare" (EPA, 2000a). The term "release" is defined broadly in the 

statute and includes discharging or leaking of substances into the environment. This also includes the 

abandonment of closed containers containing hazardous substances, pollutants, or contaminants. 

The definition of hazardous substance is extremely broad, and is defined in CERCLA 

Section 101(14). A comprehensive list of these substances is provided in 40 CFR 302.4. In addition to 

general listings for “lead”, “lead and compounds”, and “lead compounds,” the regulation lists fourteen 

other subcategories of lead. 

Additionally, CERCLA is not media-specific. Thus, it may address releases to air, surface water, 

groundwater, and soils. This multi-media aspect of CERCLA makes it possible to conduct environmental 

assessments and design clean-up projects that address site contaminants in a comprehensive way. 

The Agency has pursued a number of CERCLA response actions involving lead-contaminated soil 

using the abatement authority under Section 106 (which also requires a showing of imminent and 

substantial endangerment). CERCLA covers almost every constituent found at mining and mineral 

processing (primary lead and other metals smelters) sites. Exceptions include petroleum (that is not 

mixed with a hazardous substance) and, in some cases, responses to releases of a naturally occurring 

substance in its unaltered form. It should be noted, however, that the latter exception does not include 

any of the releases typically dealt with at mining sites, such as acid mine drainage, waste rock, or any ore 

exposed to the elements by man. 

1.2.2 Response Authorities 

CERCLA's main strength is its response authorities. EPA can either use the Superfund to perform 

response (removal or remedial) activities (Section 104) or require private parties to perform such 

activities (Section 106). CERCLA gives EPA the flexibility to clean up sites based upon site-specific 

circumstances. EPA's clean-up decisions generally are based upon both risk assessment and consideration 

of ARARs. As long as the jurisdictional prerequisites have been met, CERCLA gives EPA the ability to 

perform virtually any clean-up activity necessary to protect public health and the environment. 

There are potential limitations in CERCLA which may be relevant to lead-contaminated sites. For 

example, Section 104(a)(3) limits EPA’s ability to respond to releases within residential structures as 

follows: 
6 

“Limitations on Response. The President (EPA) shall not provide for removal or remedial action 

under this section in response to a release or threat of release . . . from products which are part of 

the structure of , and result in exposure within, residential buildings or business or community 

structures . . . “ 

The above cited section of CERCLA generally limits EPA’s authority to respond to LBP inside a 

structure or house as written in Section 6.6.1 of this Handbook. However as noted in Section 6.6.1 of the 

Handbook, EPA has the authority to conduct response actions addressing soils contaminated by a release 

of lead-contaminated paint chips from the exterior of homes to prevent recontamination of soils that have 

been remediated. In addition, Section 104(a)(4) provides an exception to the limitations in 

Section 104(a)(3). 

CERCLA provides EPA with the authority to perform "removal" and "remedial" actions. 

Assessments generally are considered “removal” actions and evaluate contaminants of concern, exposure 

pathways, and potential receptors. The assessment process includes the review of available information, 

as well as sampling, to obtain other necessary information. The process is broad in its application and is a 

powerful tool in evaluating environmental risks posed by a site. Removal actions can be performed on 

mining and mineral processing (primary lead and other metals smelters) sites, and other sites with lead 

releases to the environment, of any size. Removal actions are subject to limits on time (12 months) and 

money ($2,000,000) under the statute; however, these limits are subject to exceptions. 

Remedial actions are typically long-term responses performed at those sites placed on the NPL. 

Remedial actions also may be performed at non-NPL sites, through administrative orders on consent 

(AOCs) or consent decrees, if they are privately financed. Remedial actions are not subject to the time or 

dollar limitations imposed on removal actions, but require a more detailed and formal decision process. 

1.2.3 Applicable or Relevant and Appropriate Requirements (ARARs) 

Under Section 121(d) of CERCLA, remedial actions must comply with substantive provisions of 

federal environmental laws and more stringent, timely identified state environmental or facility siting 

laws. Removal actions should comply with ARARs to the extent practicable. “Applicable” requirements 

are those federal or state laws or regulations that specifically address a hazardous substance, pollutant, 

contaminant, remedial action, location, or other circumstance found at a CERCLA site. “Relevant and 

appropriate” requirements are not "applicable," but address problems or situations similar enough to those 

at the CERCLA site that their use is well suited to the site. 
7 

State requirements are not considered ARARs unless they are identified in a timely manner and are 

more stringent than federal requirements. The recently published TSCA §403 Soil Hazard Rule, which 

establishes a soil-lead hazard of 400 ppm for bare soil in play areas and 1,200 ppm for bare soil in nonplay areas of the yard, should not be treated as an ARAR. As recognized in the TSCA §403 Rule, lead 

contamination at levels equal to or exceeding the 400 ppm and 1,200 ppm standards may pose serious 

health risks based upon a site-specific evaluation and may warrant timely response actions. However, the 

soil-lead hazard levels under the TSCA §403 Rule should not be used to modify approaches to addressing 

brownfields, NPL sites, state Superfund sites, federal CERCLA removal actions and CERCLA non-NPL 

facilities. 

EPA has published a manual outlining potential federal ARARs that may be requirements at 

Superfund sites. Published in two parts, the manual is entitled CERCLA Compliance with Other Laws 

Manual, Part I, August 1988, and Part II, August 1989, and is available at EPA libraries (EPA, 1988). 

1.3 DEFINITION AND PURPOSE 

Residential properties are defined in the Handbook as any area with high accessibility to sensitive 

populations, and includes properties containing single- and multi-family dwellings, apartment complexes, 

vacant lots in residential areas, schools, day-care centers, community centers, playgrounds, parks, green 

ways, and any other areas where children may be exposed to site-related contaminated media (EPA, 

1996a, 1997a, 1998a). This document defines sensitive populations as young children (those under 

7 years of age, who are most vulnerable to lead poisoning) and pregnant women. Focus is put on children 

less than 7 years old because blood lead levels typically peak in this age range (EPA, 1986, 1990a; CDC, 

1991). Unfortunately, this age range is also when children are most vulnerable to adverse cognitive 

effects of lead (Rodder, 1995). Pregnant women are included due to the effects of lead on the fetus 

(Gayer, 1990; Graziano et al., 1990; Carbone et al., 1998). Other EPA guidance (EPA, 1995a, 2001b) 

and local zoning regulations should also be consulted prior to determining which properties will be 

treated as residential. 

Lead-contaminated residential sites are defined, for the purposes of this document, as sites where 

lead is the primary contaminant of concern in residential soils. Generally, lead-contaminated sites contain 

other metals of concern, such as cadmium and arsenic. This document, while addressing primarily lead 

contamination, may also be appropriate for use in the remediation of sites contaminated by other metals. 

In all cases, looking at the site history (type of lead site, depositional environment for the lead 

contamination, fill activities, previous epidemiological studies, etc.) is important in the use of the 

Handbook. Typically, the types of sites addressed by the Handbook are sites where the lead 

contamination has resulted primarily from primary or secondary lead smelting, battery cracking, or 
8 

mining and milling operations. Lead paint and dust, along with other sources of lead and other toxic 

metals, may also be present at these sites. 

The Handbook is primarily based on a compilation of the Superfund program knowledge and 

experiences, as well as existing technical and scientific literature addressing lead-contaminated residential 

sites. The Handbook has undergone broad review by the Agency for Toxic Substances and Disease 

Registry (ATSDR), the Association of State and Territorial Solid Waste Management Officials 

(ASTSWMO), and national and regional EPA offices. Because the Handbook is written for use by 

CERCLA program staff, there are frequent references to guidance or other documents developed under 

the Superfund auspices. The Handbook does not supersede or modify any existing EPA guidance or 

policy. This guidance does not suggest that CERCLA authorities are to be applied at all leadcontaminated residential sites. Rather, these references are provided to the reader as resources to be 

considered in developing site characterization and clean-up strategies under whatever regulatory or nonregulatory approach is appropriate at a particular site. However, the NCP should be followed and other 

applicable guidance consulted when addressing lead-contaminated residential sites under CERCLA. The 

Handbook does not address ecological risks from lead and lead sites. 
9 

2.0 COMMUNITY INVOLVEMENT 

The sustainability of a residential clean-up project in many ways is contingent upon support from 

affected residents, elected officials, local public health agencies, municipal and public works staff, state 

government personnel, and other stakeholders. Few sites impact more citizens of a community than large 

residential clean-up projects, with many projects exceeding a thousand homes and several thousand 

residents. If the residents recognize the risks posed to their community and feel involved in the decisionmaking process, they are more likely to accept the need for cleanup. House-to-house personal interaction 

with residents can be useful to learn their concerns (or lack of concerns) and can also be an effective part 

of educating the public regarding risks posed by the site. The project manager should issue bulletins 

and/or fact sheets to help keep the community informed of site activities and should consider establishing 

a toll free number for residents to contact her/him with questions about the site. Likewise, without the 

support of local governments, portions, if not all, of the selected remedy may be more difficult to 

implement. Many remedies rely in part on health education and institutional controls (ICs) as part of the 

actions taken to protect human health, both of which may rely on the active participation of local 

governments and health departments. The following sub-sections provide information on involving the 

community. 

2.1 EDUCATION ACTIVITIES 

This section discusses how to involve the local health departments and community in the education 

activities and the overall benefits and limitations of health education. Section 3 addresses health 

education activities in detail. 

Several studies have shown that a significant short-term reduction in blood lead concentrations can 

be achieved through the education of the public on the dangers of lead exposure and on methods they can 

take to limit their exposure (Kimbrough et al., 1994; Hilts et al., 1998; Schultz et al., 1999). However, 

EPA does not consider health education, as the only action, to be an effective, permanent remedy for 

Superfund sites (Appendix B). Often, in-home education activities have been combined with regular 

house cleaning. One key to begin reduction of elevated blood lead concentrations in children is to initiate 

health education activities, and where appropriate, blood lead screening, as early as possible in the 

process. These activities should be started as soon as elevated blood lead levels or elevated soil levels are 

detected at a site. Education should be sustained throughout the project. If residual contamination, such 

as encapsulated wastes, LBP, or other such potential sources are left on site after completion of the 

remedy, then education activities should be sustained in perpetuity. 
10 

Generally, EPA does not directly conduct the 

majority of education activities. One of the 

responsibilities of the project manager is to educate 

the community on the risks of lead exposure and to 

coordinate with various health agencies in 

establishing lead education programs. These 

programs are often implemented by local health 

districts that, in turn, typically coordinate with 

schools and other community groups working with 

Integrated Exposure Uptake Biokinetic Model 

(IEUBK) – Predicts blood-lead concentrations 

(PbBs) for an individual child, or group of 

similarly exposed children (6 months to 

7 years old), who are exposed to lead in the 

environment. More information is available 

from the Technical Review Workgroup for 

Lead (TRW) web site: 

http://www.epa.gov/superfund/programs/lead/ 

ieubk.htm 

families and children. Initial tasks include educating the community regarding their lead exposure and 

associated health risks. Typically, a significant amount of effort will be required to explain the rationale 

and procedures of the EPA risk assessment method for lead, using the Integrated Exposure Uptake 

Biokinetic Model (IEUBK), and the need to collect data to estimate site-specific values for model 

parameters. It is advisable to obtain input on exposure parameters specific to the community (e.g., how 

often they frequent locations that are not residential). Community input into the risk assessment is not 

relevant to those parameters that require site-specific studies to generate empirical data (e.g., an animal 

feeding study to determine bioavailability). Often, local health officials will be unfamiliar with EPA’s 

risk assessment process and will benefit from education along with the general public. The need for 

community education is heightened by the subtle nature of the low-dose adverse health effects of lead, 

which cannot be diagnosed in an individual because the scientific basis for cognitive impairments caused 

by low to moderate exposures relies on carefully controlled comparisons of large numbers of children 

exhibiting a range of blood lead levels (NRC, 1993; Needleman and Bellinger, 2001). Once the public 

and local health officials are made aware of the potential risks presented by the site, specific programs, 

discussed in detail in Section 3 (Health Education), can be implemented. Education and clean-up 

activities should be easier to implement, more effective, and more widely accepted by the community 

when the citizens understand the risks and believe that the community is at risk. 

2.2 COMMUNITY ADVISORY GROUPS 

Community Advisory Groups (CAGs) 

can be invaluable in assuring the success of 

the project (EPA, 1995b). A supporting and 

active CAG, comprised of a wide cross section 

of the community, has been demonstrated on 

several projects to greatly contribute to the 

success of meeting the remedial goal. 

Establishing an open dialogue with the CAG 

Community Advisory Group (CAG) – Members of the 

community make up a CAG, which serves as the focal 

point for the exchange of information among the local 

community, EPA, the state regulatory agency, and 

other pertinent federal agencies involved in cleanup of 

the Superfund site. Additional information is 

available online: 

http://www.epa.gov/superfund/tools/cag/index.htm 
11 

and understanding and addressing its concerns, leads to increased satisfaction in the community at the 

completion of the project. Concurrent with the establishment of health education activities, formation of 

citizens groups should be encouraged at the very onset of the project. Delay in forming the groups until 

significant progress has occurred may lead to mistrust by the community, as well as delay or loss of the 

valuable contributions they can make in assisting EPA. 

Citizens groups should be representative of the community. Examples include residents, workers, 

and business owners from affected neighborhoods, as well as minority leaders, realtors, bankers or 

lending institution officers, school board members, health officials, elected officials, city public works 

staff, local environmental group members, and other groups in the community. Additionally, the project 

manager should coordinate with other federal and state agencies to attend citizen group meetings. 

Relevant agencies may include the ATSDR, HUD, and state health and environmental departments. 

Citizens groups can create a feeling of ownership that facilitates the long-term success of the 

remedy. They can contribute significantly to education activities in numerous ways. A few examples of 

the successful programs and activities accomplished by citizens groups at sites include: general education 

and awareness of the segment of the community they individually represent; creating site-specific 

education material such as coloring/story books; hosting health fairs; creating health education programs 

for local school districts; establishing lead poisoning prevention merit badges for girl and boy scout 

organizations; developing instructional videos; and establishing pre- and post-natal education programs at 

local hospitals. 

2.3 EPA’S TECHNICAL ASSISTANCE GRANT PROGRAM 

EPA provides assistance grants to communities to help citizens understand site-related information. 

By regulation, EPA must inform communities about the availability of Technical Assistance Grants 

(TAGs) and assist them in applying for these grants (EPA, 1992). EPA also informs citizens about 

obtaining assistance through other programs such as the university-based Technical Outreach Services for 

Communities program and the Department of Defense's Technical Assistance for Public Participation 

(TAPP) program. 

Under the TAG program, initial grants of up to $50,000 are available to qualified groups affected 

by a response action. Additional funding is available for unusually large or complex sites. A group 

applying for a TAG need not be incorporated as a non-profit organization at the time it submits its 

application, but must incorporate as a non-profit organization before EPA can award the grant. 
12 

The group must contribute 20 percent of the total project costs to be supported by the TAG grant. 

This requirement can be met in a number of ways, including with cash, donated supplies, and volunteered 

services. TAG groups must prepare a budget and work plan for using the funds. There may be only one 

TAG award per NPL site. If more than one group applies for the same TAG, they are encouraged to form 

a coalition to apply for the grant. 

TAGs are used to hire a technical advisor, who is an independent expert who can review site-related 

documents, interpret them, and explain technical or health-related information to community members. A 

TAG advisor will often make site visits to gain a better understanding of the clean-up activities. A 

technical advisor can also help communicate the community’s concerns to EPA. TAG funds may not be 

used to generate new data (e.g., to conduct additional sampling) or for lawsuits or other legal actions. For 

further information on TAGs, see the recently revised TAG regulation (EPA, 2000b), which is available 

from the EPA TAG web site. 

2.4 INFORMATIONAL MEETINGS 

As important as the health education activities and the establishment of citizens groups are, the 

project manager should consider holding frequent public meetings to inform the community of current 

and planned EPA activities and to collect feedback and concerns from citizens. If a CAG has been 

formed at the site, meetings with the group should be frequent and open to the general public. It is 

recommended that in the early phases of the project, information sessions should be held at least monthly. 

Once the community becomes aware of the site risks, current site activities, and becomes relatively 

involved in the process, the frequency of the meetings can be reduced. However, it is recommended that 

public informational meetings, separate from the citizens task force meetings, be conducted at least once 

every six months. This frequency can help ensure that the public stays informed of site progress and has 

an opportunity to provide meaningful input to the process. 

In addition to the meetings pursuant to CERCLA (e.g., prior to release of the Record of Decision) 

meetings are helpful at the following points in the process: (1) before sampling is conducted, to explain 

the reason that lead contamination is suspected, how residents can reduce exposure as a safety precaution 

while awaiting sampling results, and the overall goals of the project (e.g., if the goal of the project is to 

reduce exposure by remediating only surface soils and therefore the sampling is designed to evaluate only 

surface soils, the issue of ICs for any contaminated soils remaining at depth should be discussed with the 

property owners early in the process); (2) after sampling is conducted, to explain results, reiterate how 

residents can reduce exposure (if results show elevated levels), explain plans and the schedule for 

conducting remediation, discuss plans for re-landscaping the property, and discuss what sort of ICs may 

be appropriate; and (3) after remediation is completed, to explain what was done, provide documentation 
13 

of the results of the remediation, discuss any problems with the landscaping, and discuss any applicable 

ICs. 

2.5 COMMUNITY INVOLVEMENT SPECIALIST/COORDINATOR 

When the site is large and cleanup is expected 

to last several years, consideration should be given to 

housing a full time community involvement 

specialist/coordinator (CIS/CIC) at the site. The 

roles of the CIS/CIC are (1) to coordinate 

community involvement activities, and (2) to be 

readily accessible to the public to provide 

information and answer questions concerning site 

activities. The CIS/CIC should be intimately 

familiar with all activities at the site, as well as the 

Community Involvement Specialist/ 

Coordinator - is the primary point of contact 

for a community and a Community Advisory 

Group (CAG), if one was formed for the site. 

He or she answers questions and provides 

other assistance directly as well as sees that a 

CAG’s concerns and other issues are 

transmitted to other Regional Office staff who 

can help. 

documented health risks, and should maintain an office with business hours convenient to the public. 

Additionally, the CIS/CIC can use information gained from their constant contact with the local 

community to brief project staff on issues important to the successful remediation of the site. 
14 

3.0 HEALTH EDUCATION 

Health education provides information to the public about the risks associated with exposure to 

contamination and, in turn, how to reduce the exposures. Health education may be considered one of 

many tools the project manager can use at lead-contaminated sites to reduce exposure to humans. 

3.1 APPROPRIATE USES FOR HEALTH EDUCATION 

Health education is an informational device and this type of instrument is largely unenforceable. 

Furthermore, health education has not been demonstrated to be effective over the longer term. Health 

education may be effective when combined with other measures as an overall remedy for a site. Health 

education is not a stand-alone remedy. EPA’s policy is that health education is only appropriate as a 

supplemental component of the permanent, health protective remedy selected at a contaminated lead site. 

For these reasons, EPA advocates that health education be layered or implemented in series with 

ICs and engineered remedies. Layering means using different types of ICs and engineered remedies at 

the same time to enhance the protectiveness of the remedy. Using ICs in series is the use of ICs at 

different points in the investigation and remediation process to ensure the short- and long-term protection 

of human health and the environment. 

3.2 PLANNING FOR HEALTH EDUCATION 

Generally, the specific goals of the health education program should be described in a site-specific 

decision document. A plan that clearly defines the goals and how they should be achieved is also more 

likely to succeed. Health education at large lead sites may have a performance period of several years 

and cost hundreds of thousands of dollars. For these large projects, a clearly defined health education 

program is even more important. 

An early step in any health education planning process includes conducting a community profile 

and assessing the educational needs of the community. A comprehensive health education program for a 

typical large lead site would normally attempt to focus on reaching the general public, with special 

emphasis on schools and other groups involved with young children. Also, it is important to coordinate 

with city, county, and other local governmental entities. The most important target population, though, is 

parents, particularly young parents, and parents with a child whose blood lead tested high. Other means 

of targeted education may include those homes with children that have high dust lead concentrations or 

lead loadings, which have been shown to be highly predictive of homes where a child is likely to have an 

elevated blood lead level during the summer peak (EPA, 1996b; von Lindern and Spalinger, 2001). 
15 

The response plan should describe what actions and activities are necessary to reach the 

community-at-large and the targeted groups. It is very important to consider that there are costs 

associated with the development, implementation, and follow up of health education and that these factors 

should be thoroughly understood and estimated. Other key points to consider are that the responsibilities 

for conducting this work should be clear and agreements should be made in writing in the planning stages 

of site response process. 

3.3 EVALUATION OF HEALTH EDUCATION ACTIVITIES 

It is important to monitor the effectiveness of health education projects that have been implemented 

at lead-contaminated sites. Many sites may include health education activities as a major component of 

the remedy, especially in the early phases of the cleanup. Failure to establish the education part of the 

remedy may trigger reconsideration and imposition of additional requirements, or more extensive and 

costly clean-up efforts. 

The project manager should monitor the organization(s) performing the educational activities for 

proper implementation of the health education program and assess the effectiveness of the program. 

Project managers should ensure that the objectives of the program are being met to protect children’s 

health. If health education is included as part of the final remedy, it should be carefully scrutinized 

during the Five-Year Review process. 

3.4 AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR) 

INVOLVEMENT 

Health education is often implemented through grants from ATSDR to its partners in state health 

departments or directly through agreements with local health departments. When health education is 

specified as a major part of EPA’s clean-up activities, strong consideration should be given to 

establishing an interagency agreement with ATSDR to assist in funding the required activities. ATSDR 

as a federal health agency is well positioned in terms of health education resources to administer such 

grants. ATSDR can provide expertise not only with the CAGs but also with public health assessments, 

health consultations, and health surveillance. An emphasis should be placed on developing the 

collaborative partnerships between EPA, ATSDR, and other federal, state, and local health departments 

for health education activities at contaminated lead sites. 

Health education at lead sites is often accompanied with blood lead screening. Centers for Disease 

Control and Prevention (CDC) has issued guidelines for increasing intensity of health intervention 

activities based on blood lead test results (CDC, 1991). Increased collaboration among the involved 
16 

agencies is important to properly implement a health education/blood lead screening project. 

Additionally, ATSDR and many state and local health departments have ongoing lead screening and 

health education programs. Information from targeted screening is valuable for (1) targeting follow-up 

education to individual families with children identified with elevated blood lead levels; (2) determining 

the areal and demographic extent of the problem; and (3) effectively evaluating the impact of health 

education. 

3.5 OUTREACH 

EPA has had success in health education activities at several sites because the programs were 

tailored specifically for the site by the site team (i.e., project manager, toxicologist, on-scene coordinator, 

CIS/CIC, etc.). These programs have included significant amounts of outreach activities in the 

communities. The success of any health education program generally can be attributed to the amount of 

community outreach that is conducted at the site. As discussed in Section 2, the outreach can consist of a 

wide variety of activities. A few examples include the following: site specific coloring books distributed 

to the parents of young children, scouting merit badges on lead-poisoning prevention, school curriculums 

developed to inform student of the hazards of lead and good hygiene, health and environmental fairs 

conducted in the community, and blood lead testing events held at community celebrations. Consultation 

with local health officials and community groups can provide numerous ideas for outreach, which can be 

incorporated into specific programs to best meet the needs of the community. Typically, the local health 

officials should lead the outreach efforts. Funding should be provided by EPA when other funds, such as 

from ATSDR, are unavailable to support the outreach activities. 
17 

4.0 SITE CHARACTERIZATION 

EPA has reviewed various sampling designs historically employed at lead-contaminated residential 

sites and assessed the ability of these sampling designs to meet risk assessment needs and support the 

development of clean-up levels. Over a 20-year period, several large area lead sites (e.g., Bunker Hill, 

Shoshone County, Idaho; Joplin, Missouri; NL Industries/Taracorp-Granite City, Illinois; Tar Creek, 

Ottawa County, Oklahoma) have used a variety of sampling techniques to characterize residential 

properties. Additionally, many different approaches to applying selected clean-up levels have been taken. 

As stated, this document was developed to promote consistent procedures, criteria and goals in the 

investigation and clean-up activities at Superfund lead-contaminated residential sites. However, a level of 

flexibility is needed to best respond to different site conditions, communities, and uncertainties. 

The overall goals of the sampling effort are to estimate an average soil lead concentration for risk 

assessment purposes and to provide information to determine the scope of any required clean-up actions. 

This information can also be used for public education and intervention. The sampling designs discussed 

in this section are intended to provide, within one sampling effort, the necessary data for all phases of a 

clean-up project so that residents are not inconvenienced by repeated sampling of the same property. 

Project managers should carefully choose the sampling points needed to estimate the average lead 

concentration in a cost-effective manner. Some uncertainty is acceptable to reduce the overall cost of 

sampling at large lead sites. The selection of sample locations within areas with potential for exposure 

has been the subject of recent articles which describe methods to manage decision uncertainty by 

balancing sampling and clean-up costs (Englund & Heravi, 1994; Crumbling et al., 2001). Table C-1 

(Appendix C) lists contacts within the agency who can provide assistance in various aspects of sample 

planning and design, and also lists software that may be used for sample planning and decision support. 

Section 4.0 discusses: (1) delineating the contamination zones; (2) residential property sampling 

locations; (3) sampling method; (4) sampling requirements for backfill material and excavated soil for 

off-site disposal. 

4.1 CONTAMINANT ZONE DELINEATION 

Historical information on site operations and use is crucial for the design of sampling plans that are 

intended to delineate contaminant zone(s), and for the interpretation of data generated from the sampling 

effort. In addition to gathering data on the nature of the source of contamination, information should be 

gathered to identify areas where soils may have been moved or where fill or topsoil may have been 

placed. Guidance on how to gather historical site data is available (EPA, 2001f, 2001g). Sites that have 

been contaminated primarily by airborne-derived lead, such as smelter areas, can initially be sampled in a 
18 

grid pattern. This will usually allow concentration contours to be defined across the community and to 

establish the extent of horizontal contamination for cleanup and costing purposes. If grid sampling is 

used for initial characterization to define the horizontal extent of contamination, follow-up sampling of 

each yard located within the identified clean-up zone should be used to characterize each individual 

property for clean-up requirements. For other sites where the variability is expected to be higher, such as 

mining sites with discrete individual tailings piles located throughout the area, delineating the 

contaminant zones by establishing concentration contours will be more uncertain and consideration 

should be given to sampling every home in the potentially affected area, moving laterally away from the 

source until clean areas of the community have been identified. 

Delineating the zone of contamination generally amounts to distinguishing soil with “background” 

lead concentration from soil that has been impacted by site-related activities. There are basically two 

types of background: naturally occurring and anthropogenic (see insert for definitions) (EPA, 1989, 

1995c, 2002). EPA guidance defines background for inorganics as “...the concentration of inorganics 

found in soils or sediments surrounding a waste site, but which are not influenced by site activities or 

releases” (EPA, 1995c). Natural background concentrations of lead vary widely with the local geology, 

and can be as high as 250 ppm or more in mining areas (SRC, 1999). Local background concentrations, 

which include natural and non-siterelated anthropogenic sources (e.g., 

historic automobile emissions) can 

be substantially higher. Background 

samples should be collected from 

areas near the site that are not 

influenced by site contamination, 

but that have the same basic 

characteristics (e.g., soil type, land 

use). 

Types of Background 

naturally occurring: ambient concentrations of lead present in 

the environment that have not been influenced by humans 

anthropogenic: lead concentrations that are present in the 

environment due to human-made, non-site sources (e.g., 

automobile exhaust) 

Statistical approaches to delineating contaminant zones are useful for some sites. In these cases, the 

project manager should consult with a statistician to design an efficient sampling plan. The Agency is 

developing guidance on characterizing background chemicals in soil that includes statistical methods for 

delineating contaminated areas (EPA, 2001i). Geostatistics is widely recognized for offering graphical 

methods that are ideally suited for delineating contaminant zones (Gilbert and Simpson, 1983; Flatman 

and Yfantis, 1984; Journel, 1984; Englund and Heravi, 1994; Goovaerts, 1997). Geostatistics also 

provides powerful methods for detecting contaminated areas from background when sample locations 

have not been randomly selected (e.g., Quimby, 1986; Borgman and Quimby, 1996), for sampling plan 

design (e.g., Flatman and Yfantis, 1984; Borgman et al., 1996), and for aiding in the design of remedial 
19 

responses (e.g., Ryti, 1993). For smaller sites, rigorous statistical analyses may be unnecessary because 

site-related and non-site-related contamination clearly differ. For these sites, the sampling plan should 

focus on establishing a reliable representation of the extent (in two or three dimensions) of a contaminated 

area (EPA, 1989) . 

4.2 RESIDENTIAL PROPERTIES 

For the purposes of this document, a residential property includes properties that contain single and 

multi-family dwellings, apartment complexes, vacant lots in residential areas, schools, day-care centers, 

playgrounds, parks, and green ways (EPA, 1996a, 1997a). In all cases, historical site information (type of 

lead site, fill activities, previous epidemiological studies, etc.) is important in the application of this 

Handbook. 

Rationale for collecting yard soil samples and water samples on a residential property is provided in 

Table 4-1. The collection of other types of media are important to determine overall risk, however 

CERCLA has limited authority to address these media (e.g., interior paint, dust, and potable water). 

4.2.1 Sampling Access 

Prior to conducting any sampling or clean-up activities at a residential property, access must be 

obtained from the property owner; access obtained from tenants or renters is not sufficient. It is essential 

to begin access procurement as early as possible in the remedial process to avoid potentially lengthy 

delays. It is recommended that access be obtained by going door-to-door. If residents are not home, a 

blank access agreement with instructions for signature and submission to EPA, along with relevant 

contact information should be left at the residence (but not in the mailbox). Examples of access 

agreements are presented in Appendix D, pages D-2 and D-3. If possible, access for remediation should 

be obtained at the same time access for sampling is sought. Examples of combined sampling/remediation 

access agreements are included on pages D-4 and D-5 of Appendix D. Combining sampling and clean-up 

access will avoid potentially lengthy delays. Additionally, access should be obtained for any interior dust 

sampling and/or cleaning that will be performed at the residence (Section 6.6.2). Sample access 

agreements for dust cleanup are presented in Appendix E. 
20

Table 4-1. 

Rationale for Sampling Residential Properties 

Sample 

Location Rationale for Sample Collection 

Residential 

yard soils 

Residential soil may present a direct exposure pathway to persons working, playing, or conducting 

other recreational activities on the property. il samples should be collected and quantitatively 

analyzed to estimate lead concentrations. ntial soils may also present an indirect exposure 

pathway via house dust exposure (see below). 

Gravel 

driveways 

Fine-grained driveway material may present a direct exposure pathway to persons working or 

engaged in recreational activities on driveways. ples should be collected and 

quantitatively analyzed to estimate lead concentrations. 

concentrations may also contribute to the transport of contaminants throughout the community. 

Drip zones 

and soils 

below roof 

gutter 

downspouts 

Rooftops may collect fine-grained sediments that contain high concentrations of lead. 

areas where downspouts discharge during a storm event, the fine-grained material washed from a 

roof may accumulate and result in a localized increase in soil lead concentrations. ples 

should be collected and quantitatively analyzed to estimate lead concentrations. 

may also contain LBP influences and are important to characterize for health intervention 

purposes, as drip zones are often used as play areas. 

Soils in play 

areas 

Play area soils may present a direct exposure pathway to children under the age of seven. 

samples should be collected and quantitatively analyzed to estimate lead concentrations. 

Garden soils Garden soils may present a direct exposure pathway to persons who actively maintain a garden. 

Soil samples should be collected and quantitatively analyzed to estimate lead concentrations. 

Interior lead 

dust 

Lead in household dust may be a significant contributor to elevated blood lead levels, especially in 

younger children. ples should be collected and quantitatively analyzed to estimate lead 

concentrations. inated interior dust can be derived from multiple sources; dust mat 

samples and speciation can be used to identify lead sources. 

Lead-based 

paint 

Deteriorating LBP may contribute lead to household dust, which can be a significant source of 

lead exposure, particularly for young children. If elevated concentrations of lead are found in 

interior dust, samples of interior paint should be collected and quantitatively analyzed to estimate 

lead concentrations. ay contribute to the recontamination of remediated properties. 

Samples of exterior LBP should be collected and quantitatively analyzed to estimate lead 

concentrations. 

First run and 

purged tap 

water 

Groundwater and surface water near the site may contain elevated lead concentrations. e 

residences located within the site may use local groundwater or nearby surface water as a source 

of drinking, cooking, bathing, or irrigation water. ay represent a direct exposure or 

ingestion pathway. ples of both water standing in the pipes (first run sample) and water 

discharged after the system has been flushed (purged sample) should be collected and 

quantitatively analyzed to estimate lead concentrations. 

determine if the drinking water is contaminated with site-related contamination (exceedance in 

purged), or to determine if there is lead in the home’s plumbing (exceedance in first run), or both, 

which may be used for remediation or intervention purposes, respectively. 

Crawl 

Spaces 

Crawl space sampling is recommended if the crawl space is accessible to children or pets. 

some sites (e.g., Bunker Hill) this has been found to be a significant pathway , 2000; 

TerraGraphics, 2000). all for children, pets have been found to 

access these spaces and move significant amounts of fine dust containing elevated lead levels into 

the child’s bedroom (e.g., where a pet may sleep on the child’s bed at night). ation on 

concentrations of lead beneath the structure may be used to document the need to preclude access 

or take other remedial measures. 

Other areas During field work, other potential sources of lead contamination may be identified. 

appear to represent a potential exposure pathway to occupants of a residence, sampling may be 

recommended. ted on a case-by-case basis and could include 

sediment, surface water, or secondary play areas. ed appropriate, samples should be 

collected and quantitatively analyzed to estimate lead concentrations. 

So

Reside

Soil sam

Gravel driveways with elevated soil 

In yard 

Soil sam

Drip zone areas 

Soil 

Dust sam

Lead-contam

Exterior LBP m

Som

The water m

Sam

These results can also be used to help 

At 

(IDHW

Even when spaces are too sm

Inform

If the sources 

Other areas should be evalua

If deem
21 

4.2.2 Residential Yards 

It is recommended that when sampling residential lots with a total surface area less than 

5,000 square feet (a typical urban lot size), five-point composite samples should, at a minimum, be 

collected from each of the following locations: the front yard, the back yard, and the side yard (if the size 

of the latter is substantial). The front, back, and side (if needed) yard composites should be equally 

spaced within the respective portion of the yard, and should be outside of the drip zone and away from 

influences of any other painted surfaces (Figures 4-1a and 4-1b). Composites should consist of aliquots 

collected from the same depth interval. 

Front

Yard

Drip Zone 

Back 

Yard 

Sample aliquots 

Residence 

Figure 4-1a. Recommended minimum soil sampling in yards less than or equal to 

5,000 square feet with small side yard. Five point composite samples should be collected 

from each of the front and back yards. Four point composites should be collected from the 

drip zone; each aliquot should generally be collected from the midpoint along each side of the 

residence. Aliquots for a single composite sample should be collected from the same depth 

interval. Soil samples should also be collected from distinct play areas and gardens if they 

are present, as well as unpaved driveways and minimal use areas such as areas under porches 

and crawl spaces. The locations of the aliquots should be equally spaced within the area of 

the yard the composite is collected from. The figure illustrates one possible arrangement of 

the sample aliquots. Please refer to Section 4.2.2 for further explanation. 
22 

Drip Zone 

Residence 

Front 

Yard 

Back 

Yard 

Side Yard 

Five-point composite sample 

Sample aliquots 

Figure 4-1b. Recommended minimum soil sampling in yards less than or equal to 

5,000 square feet with substantial side yard. Five point composite samples should be 

collected from each of the front, back, and side yards, along with other areas as described in 

Figure 4-1a. The locations of the aliquots should be equally spaced within the area of the 

yard the composite is collected from. The figure illustrates one possible arrangement of the 

sample aliquots Aliquots for a single composite sample should be collected from the same 

depth interval. Please refer to Section 4.2.2 for further explanation. 

For residential lots with a total surface area greater than 5,000 square feet, it is advisable that the 

property be divided into four quadrants of roughly equal surface area. The two quadrants in the front 

yard should encompass one half of the side yard; likewise for the two quadrants in the back yard. One 

five-point composite of aliquots collected at equal spacing and from the same depth interval should be 

obtained from each quadrant. Each aliquot should be collected away from influences of the drip zone and 

any other painted surfaces (Figure 4-2). 

Properties over one acre in size should be divided into 1/4 acre sections. One five-point composite 

sample should be collected from each section. For large properties, consideration should be given to 

whether elevated concentrations trigger partial removal of soils or access restriction (see Section 6.5). 
23 

1 2 

3 4 

Residence 

Drip Zone 

Sample aliquots 

Five-point composite sample 

Figure 4-2. Recommended minimum soil sampling in yards greater than 5,000 square 

feet. Five point composite samples should be collected from each of the four quadrants as 

indicated above. The locations of the aliquots should be equally spaced within each of the 

quadrants. The figure illustrates one possible arrangement of the sample aliquots. Four point 

composites should be collected from the drip zone; each aliquot should generally be collected 

from the midpoint along each side of the residence. Aliquots for a single composite sample 

should be collected from the same depth interval. Additional samples should be collected 

from distinct play areas and gardens if they are present, as well as unpaved driveways and 

minimal use areas such as areas under porches and crawl spaces. Please refer to Section 4.2.2 

for further explanation. 

4.2.3 Drip Zones 

Lead-contaminated soils are frequently found within the drip zone of houses. It is recommended 

that a four-point composite sample be collected from the drip zone of each residential property 

(Figures 4-1a, 4-1b, and 4-2). The composite sample (taken from any size lot) should consist of a 

minimum of four aliquots collected between 6 and 30 inches from the exterior walls of the house. Each 

aliquot should generally be collected from the midpoint of each side of the house. Collection of 

additional aliquots should be considered if other factors exist, such as bare spots, distinct differences in 

the house exterior, and areas where runoff collects. Rooftops may collect fine-grained sediments that 

contain high concentrations of lead. In yard areas where downspouts discharge during a storm event, the 

fine-grained material washed from a roof may accumulate and result in a localized increase in soil lead 
24 

concentrations. Samples of the soil from the downspout discharge area should also be sampled if present. 

4.2.4 Play Areas, Gardens, and Driveways 

Distinct play areas and gardens, if present, should generally be sampled separately as discrete areas 

of the yard. At some sites, collection of a right-of-way/easement composite may also be appropriate, such 

as residential areas with unpaved streets and alleys. Paved surfaces such as asphalt/concrete driveways, 

patios, alleys, and parking lots should, in most cases, not be sampled. Samples should also be collected in 

other locations depending upon the potential for exposure or recontamination, for example, under porches 

and crawl spaces and areas with incomplete barriers such as gravel driveways. 

4.2.5 Potable Water, Lead-Based Paint and Interior Dust 

Drinking water supply samples should be collected to determine if exposure to lead in drinking 

water is occurring. First-run and purged samples of potable water should be collected to differentiate siterelated sources of lead from lead derived from plumbing that is located within the residence. CERCLA 

authority for remedial action may be limited with regard to lead derived from plumbing that is located 

within the residence. 

Deteriorating LBP may contribute lead to household dust. If elevated concentrations of lead are 

found in interior dust, samples of interior paint should be collected. Exterior LBP may contribute to the 

recontamination of remediated properties (Section 6.7). Samples of exterior LBP should be collected and 

analyzed to estimate lead concentrations. Lead in household dust may be a significant contributor to 

elevated blood lead levels, especially in younger children. Lead-contaminated interior dust can be 

derived from multiple sources; dust mat samples and speciation can be used to identify lead sources. Dust 

samples should be collected and analyzed to estimate its potential contribution to lead exposure. 

Guidance on LBP and dust sampling is available from HUD (HUD, 1995). 

4.2.6 Backfill and Waste Soil 

Backfill soil should be sampled to ensure that uncontaminated material is being placed on the site. 

The list of analytes and the frequency of sampling should be based on site-specific factors including the 

location of the source for the backfill material relative to potential sources of contamination, the geology 

of the borrow area, and the heterogeneity of the material. For example, on the Bunker Hill Superfund 

Site, four-point composite samples were collected for each 200 yd3

 of soil (TerraGraphics, 1997a). 

Gravel for driveway backfill was also sampled every 200 yd3

 (TerraGraphics, 1997b). Samples of 

excavated soil should be analyzed by the toxicity characteristic leaching procedure (TCLP) method to 
25 

determine the appropriate method of disposal. The frequency required for TCLP sampling should be 

based on the heterogeneity of the lead and other contaminant(s), if any, on the site. 

4.3 SAMPLING METHOD AND ANALYSIS 

4.3.1 Sample Collection 

Composite samples should consist of discrete aliquots of equal amounts of soil. The soil from each 

aliquot should be collected into one clean container, such as a stainless steel bowl or plastic bag, and 

thoroughly mixed. After mixing, the sample can then be analyzed by X-Ray Fluorescence (XRF) (see 

Section 4.3.4) or sent to the laboratory. Remaining sample volume can then be disposed in the general 

location from where it was collected, or archived, depending on the requirements of the project. In some 

cases, material other than grass and/or soil will be encountered at a sample location, e.g., wood chips and 

sand are often found in recreational areas of day-care and school playgrounds. Samples of the soil below 

the cover material should be collected. 

The use of a dynamic sampling and analysis strategy should be considered (EPA, 2001d). A 

dynamic sampling and analysis strategy takes full advantage of the real-time that data field analytical 

methods provide, which can limit the sampling effort and minimize cost (EPA, 2001d). This document 

suggests the use of field portable X-Ray Fluorescence (FP-XRF) analysis. 

4.3.2 Sample Depth 

The following sampling design is based on the assumption that removal of surficial contaminated 

soils and placement of a cover of clean soil will be protective of human health and the environment (see 

Section 4.0). Furthermore, the sampling design outlined below is based on the assumption that a 

minimum of 12 inch soil cover is adequate. 

Initial sampling for lead contamination in residential soils should be conducted to a depth of at least 

18 inches, but does not need to exceed 24 inches to define the vertical extent of contamination for cleanup purposes. Composite samples should be collected at 6 inch depth intervals, i.e., 0–6 inches, 

6–12 inches, 12–18 inches, and 18–24 inches. Additional sampling may be required at lead sites in cold 

weather regions when contamination is associated with coarse grained material. Stone-sized material, 

such as tailings and crushed battery casings, will, over time, migrate upward through the soil via 

freeze/thaw effects. At such sites, composite sampling should be conducted at 6 inch intervals to the 

approximate maximum frost depth for the region. In all cases, composites should consist of aliquots 

collected from the same depth interval. 
26 

In site-specific situations, deeper sampling may be conducted to determine the total vertical extent 

of contamination for groundwater issues or ICs, and to determine if complete removal of contaminated 

soil is possible. Depth sampling should be conducted until the vertical extent of contamination has been 

adequately defined, but does not need to be conducted on every property. 

In addition to the composite samples collected to define the vertical extent of contamination, fivepoint composite surface soil samples should be collected from 0 to 1 inch for human health risk 

assessment purposes (EPA, 1989, 1996c). The samples should be collected using the procedure described 

in Section 4.3.1. These surface soil samples should be collected from every property within the identified 

zone of contamination; however, after collecting a statistically valid number of both 0–1" and 

1–6" samples, the project manager may want to compare both sample horizons (e.g., paired-sample t-test; 

Wilcoxon Rank Sum test) (Gilbert, 1987; Snedecor and Cochran, 1989) to determine if the 0–1" depth 

can be eliminated (i.e., sample from 0–6"), to further decrease sampling costs. This may be particularly 

useful at mine waste sites where contamination often extends to depth or at sites where lead-contaminated 

soil has been used as fill material; in such cases, the lead concentration may increase with depth. 

Conversely, the 0–1" horizon may be far more contaminated than the 1–6" at smelter sites, making 

individual horizon sampling crucial to remedial decision-making. 

Collection of samples from specified depth intervals serves two primary purposes: risk assessment 

and remedial decision-making. With respect to risk assessment, the top inch of soil best represents 

current exposure to contaminants (EPA, 1989, 1996c) and is the source of data used in the IEUBK model 

to represent exposure from soil. The various depth intervals are used in remedial decision-making to 

determine if a residential yard requires cleanup by evaluating if any of the horizons exceed the sitespecific action level. The lower soil horizons represent possible future exposures, such as homeowner 

projects, children’s play areas, and other home activities that periodically go beneath the top inch of 

vegetation/soil (EPA, 1989). All soil horizons should be used for clean-up decision-making. The 6 inch 

depth intervals recommended in this document are based on the performance that may be reasonably 

expected of operators of small equipment working in relatively small spaces around homes. Specifically, 

a “bobcat” is most efficiently used for soil removal on a property if the soil is removed in 6 inch intervals, 

rather than in smaller increments, which would be far more difficult to achieve in a consistent or costeffective manner. This approach has been developed to ensure a residential yard is cleaned up if it poses 

an immediate or long-term risk to human health in a manner that relates the sampling methodology 

closely to reasonable and cost-effective construction equipment performance. 

A secondary goal of the sample collection effort is to facilitate the implementation of ICs for sites 

where contamination at depth is left in place. 
27 

4.3.3 Sample Preparation 

Residential soil lead samples should represent the exposure potential of young children who are most 

vulnerable to adverse effects of exposure. Children inadvertently ingest lead in soil and dust that adheres 

to their hands (Succop et al., 1998). The smaller particles are more representative of this type of exposure 

(Duggan et al., 1985; Kissel et al., 1996; Mielke et al., 1997). Additionally, smaller particles are 

preferentially brought into the home. Sieving is conducted to better represent the soil fraction that is 

ingested by the typical child. Sieving has also been used in soil ingestion and bioavailability studies 

(Calabrese et al., 1996; Casteel et al., 1997; Stanek et al., 1999). Samples collected from all depth 

intervals should be sieved. Samples should not be ground prior to sieving, as this changes the physical 

structure of the soil and may bias the analytical results. To reduce sampling costs, it may be desirable to 

develop a correlation between sieved and unsieved data, to eliminate the need to sieve all samples. The 

correlation can be used to predict sieved results from 

unsieved samples. The EPA Technical Review 

Workgroup (TRW) and American Society for 

Testing and Materials (ASTM) have issued guidance 

on sieving (ASTM, 1998; EPA, 2000c). The EPA 

TRW guidance addresses appropriate sieve size (No. 

60) and a method for predicting the concentration in 

the fine fraction using concentrations measured in 

unsieved samples. 

Technical Review Workgroup (TRW) – The 

TRW is an interoffice workgroup that consists 

of key scientific experts from various EPA 

regions, labs, and headquarters that supports 

and promotes consistent application of the 

best science in the field of lead (Pb) risk 

assessment at contaminated sites nationwide. 

The presence of paint chips in a soil sample can represent a large proportion of the total lead 

concentration that is measured. On this issue, the Handbook directs the reader to existing HUD guidance, 

which states “If paint chips are present in the soil, they should be included as part of the sample. 

However, there should be no special attempt to over-sample paint chips. The laboratory should be 

instructed to disaggregate (‘break up’) paint chips by forcing them through a sieve in the laboratory. 

Although paint chips should not be oversampled, they should not be excluded from the soil sample, since 

they are part of the soil matrix.” (HUD, 1995). The TRW website should be checked periodically for 

additional sampling guidance. 

4.3.4 Sample Analysis 

EPA’s experience in sample analyses at large residential contamination sites (with several thousand 

homes on a site) shows that both FP-XRF or fixed-site laboratory analyses (acid digestion/Inductively 

Coupled Spectroscopy) provide reliable information (EPA, 1996d, 1998b, 2001c, 2001d; Crumbling et 

al., 2001). The objective of using a FP-XRF is to predict Contract Laboratory Program (CLP) values with 
28 

less expensive real-time data. A sufficient amount of data should be collected to develop a site-specific 

relationship (i.e., correlation) between FP-XRF and CLP lab data. 

The comparison should consider sample preparation (drying and sieving) and analytical methods. 

Typically, a large number of laboratory confirmation samples should be analyzed at the beginning of the 

project to estimate the correlation between the FP-XRF and the CLP results and the FP-XRF precision 

and accuracy. Additional confirmatory samples should then be analyzed at key decision points when the 

FP-XRF results are close to action levels or when the reliability of the FP-XRF unit is in question (EPA, 

2001d). For example, initial sample analyses using an FP-XRF instrument could include 20 percent 

laboratory confirmatory samples to assess the accuracy and precision of the FP-XRF. Once the accuracy 

and precision of the FP-XRF results have been determined (and assuming they satisfy the requirements of 

the project), the number of laboratory confirmatory samples could be reduced (e.g., to 5 percent). 

Additional information on analyzing soil (and other media) in the field with FP-XRF is available on the 

EPA web site: http://www.epa.gov/superfund/programs/dfa/ (EPA, 2001e). 

Proper calibration of the FP-XRF unit is important to obtaining reliable results (EPA, 1996d). 

Correlation between the FP-XRF and laboratory analyses is best achieved with small sample volume. 

Laboratory confirmatory samples should be collected in the specimen cup available from the FP-XRF 

manufacturer. The sample is first analyzed with the FP-XRF and then sent to the laboratory for wet 

chemistry analysis. Soil moisture can introduce error in FP-XRF results to varying degrees, depending on 

the instrument being used (EPA, 1996d). The correlation between the FP-XRF measurements on dried 

and undried samples should be estimated. The correlation analysis should then be used to establish a 

cutoff or ‘soil moisture ceiling’. The ‘soil moisture ceiling’ represents the maximum moisture content at 

which useful results (i.e., of sufficient precision and accuracy) can be obtained with the FP-XRF. Field 

portable instruments capable of measuring moisture content are available and should be used to compare 

sample moisture content to the ‘soil moisture ceiling’. Samples with moisture contents greater than the 

‘soil moisture ceiling’ should be dried prior to analysis with the FP-XRF. 
29 

5.0 CLEAN-UP LEVEL SELECTION 

Generally, the approach to human health risk assessment for lead differs from that of other metals 

and contaminants. Typically, risks from lead exposures are estimated from long-term exposures, although 

elevated blood lead concentrations also result from short-term exposures (CDC, 1991). EPA has 

developed the IEUBK model to predict blood lead (PbB) concentrations in children exposed to lead. The 

model considers several different media through which children can be exposed to lead. 

EPA and the CDC have determined that childhood PbB concentrations at or above 10 micrograms 

of lead per deciliter of blood (:g Pb/dL) present risks to children's health (CDC, 1991). Accordingly, 

EPA seeks to limit the risk that children will have Pb concentrations above 10 :g Pb/dL. The IEUBK 

model predicts the geometric mean PbB for a child exposed to lead in various media (or a group of 

similarly exposed children). The model also calculates the probability that the child’s PbB exceeds 10 :g 

Pb/dL (P10). Preliminary remediation goals (PRGs) generally are determined with the model by adjusting 

the soil concentration term until the P10 is below 5%. Final clean-up level selection for Superfund sites 

generally is based on the IEUBK model results and the nine criteria analysis per the National 

Contingency Plan (NCP) (EPA, 1990b), which includes an analysis of ARARs. More information on the 

IEUBK model is available from the EPA TRW web site. 

Typically at large lead sites, early actions taken to mitigate the identified site risks consist of timecritical removal actions (TCRAs), most often taken as an interim action. These actions are usually 

followed by long-term remedial actions. The following sections describe the different approaches that 

should be used for prioritizing response actions and selecting clean-up levels for both early (interim) and 

long-term (permanent) response actions. 

5.1 PRIORITIZING RESPONSE ACTIONS 

For early, interim actions, a tiered approach should be used for prioritizing clean-up actions. A 

tiered-response approach is recommended when sufficient resources are not available to fully address lead 

risks. The size and complexity of many lead sites often requires implementation of response actions over 

an extended period of time; therefore, it is often necessary to implement interim clean-up actions to 

manage short-term health risk concerns while response actions to address long-term risk are planned and 

implemented. Early removal actions at residential lead sites should contribute to the performance of the 

long-term permanent remedy. 

The tiered approach is depicted in Figure 5-1. Figure 5-1 is a flowchart that provides a roadmap of 

the recommended clean-up process for lead-contaminated residential sites. An overview to the clean-up 

process is provided in Figure 1-1. The first page of Figure 5-1 provides a more detailed overview; the 

subsequent pages provide additional details of the process. 
Start 

history/nature of 

contamination 

(Section 4.1) 

contaminant 

zone delineation 

(Section 4.1) 

Sampling Goals 

•prioritize response actions 

•risk assessment model inputs 

•determine extent of contamination -

interior/exterior 

Community Invo

(Section 2

Goals: •engage/involve stakehold

•buy-in by stakeholders 

•reduce blood lead in child

5 year review? 

perform required 5 year reviews 

(Section 7.0) 

meetings w/federal, state 

governments and public 

IEUBK, risk assess strat

coordinate with ATSDR 

CAGS/TAGS 

(Sections 2.2, 2.3) 

(

community pr

needs/assessm

blood lead study/surve

is there 

a problem

no 

implement education program

videos, comic books, o

evaluate effecti

END 

yes 

yes 

B 

C 

A 

D 

access agreements for sample 

collection (Section 6.5) 

soil dust paint tap water diet 

prioritize response 

actions 

(Section 5.1) 

cleanup residential properties: 

TCRA, NTCRA, Remedial 

(Sections 5.0, 6.0) 

determine which 

neighborhoods need 

further sampling at 

individual homes 

(Section 4.1) 

determine depth 

sampling 0-1”, 1-6”, 

6-12”, 12-18”, 

(Section 4.3.2) 

Figure 5-1. Recommended clean-up process for lead-contaminated residential sites. Refer to Figure 1-1 for an overvi

shaded portions of the figure, labeled A-C, are expanded on the second through the fourth pages of the flowchart. 
Figure 5-1. (continued) 

access agreement for sample 

collection (Sections 4.2.1 and 6.5) 

soil (Section 4.2) 

see Fig. 4-2; 5 sampling 

locations (Section 4.2.1) 

see Figs. 4-1a, b; 3-4 sampling 

locations (Section 4.2.1) 

if play area present, add 

one sampling location 

yes no 

if garden present, add 

one sampling location 

if unpaved driveway present, 

add one sampling location 

for each additional incomplete 

barrier, add one sampling location 

are 0-1” and 1-6” 

samples statistically similar? 

(Section 4.3.2) 

yes 

combine 0-6” together 

no 

use soil data in IEUBK to 

predict PbB concentrations 

tap water 

paint 

dust 

A 

C 

diet 

Property 

size < 5,000 ft2? 
Figure 5-1. (continued) 

access agreement (Section 6.4) 

interior dust 

(Section 6.6.2) 

develop sampling plan 

collect vacuum dust 

samples 

risk assessment: 

risk acceptable? 

no 

yes 

address 

recontamination issues 

(Sections 6.6 and 6.7) 

paint int/ext 

(Sections 4.3 and 8.0) 

develop sampling plan 

collect samples 

no 

yes 

is leadbased int 

waste co-mingled 

with site-related 

waste? 

end 

refer to 

health 

dept 

end 

refer to 

health 

dept 

no 

develop cleanup plan, 

address recontamination issues 

(Section 6.6) 

yes 

tap water 

(Section 6.6.3) 

sample water 

first run / purge 

exceeds 

drinking h2o 

standards? 

no 

site-related? 

no 

refer to 

health 

dept 

develop cleanup plan 

end 

end 

end 

end 

B 

C 

is risk no

siterelated? 

yes 

p

C 

is there a 

lead-based paint 

hazard? 

(Section 8.0) 

yes yes 

Health 

Intervention 

perform dust cleanup 

(Section 6.6) 

pa

C
Figure 5-1. (continued) 

Prioritize response actions (Section 5.1) 

sensitive 

population? 

(Section 5.1) 

Pb in 

surface soil (0-1”) 

≥ 1,200 ppm? 

T

ac

no no

yes 

Pb in surface 

soil (0-1”) ≥ 1,200 ppm 

or child PbB 

≥ 10 ug/dL? 

yes 

no no 

Tier 1 

TCRA 

(Section 5.1) 

Tier 2 

TCRA, NTCRA, or remedial 

(Section 5.1) 

cleaning up residential properties: 

NTCRA, remedial 

public evaluate alternatives

involvement 

(Section 2.0) 

select remedy 

coordinate with 

property owner; access 

agreements; video 

existing conditions; 

photo (Section 2.0) 

perform 

work 

post 

video 

clean 

letter 

c

yes 

C 

Pb in 

surface soil (0-1”) 

≥ 400 ppm? 

yes 

Pb in 

surface soil (0-1”) 

≥ 400 ppm? 

yes 

typically, no 

action 

required 

no 

LBP waste 

present? 

dispose 

according to 

test results 

yes 

no 

child PbB 

≥ 10 ug/dL? 

yes 

immediate 

health 

intervention 

no 

is high PbB site-related? 

yes 

no 
34 

The concentrations that are used to define tiers should not be confused with clean-up numbers, 

which are based on the PRG determined with the IEUBK model and an analysis that includes the nine 

criteria listed in the NCP (EPA, 1990b). The 1,200 ppm concentration is not an action level for TCRAs, 

but is intended to provide an alternative to running the IEUBK model if the project manager believes the 

site poses an urgent threat (EPA, 1997b, 1997c). Certainly, a TCRA could be justified above or below 

this concentration depending on the conditions at the site. The tiers, for the purposes of this guidance, are 

defined below (see also Figure 5-1). (Please note the Agency is considering developing new guidance for 

removal actions.) 

C Tier 1 properties have both sensitive populations (children up to 7 years old or pregnant women) 

and soil concentrations in the surface soils (0–1" depth) at or above 1,200 ppm (EPA, 1997b, 

1997c). Also, Tier 1 sites can be identified based upon a demonstration of children’s blood lead 

levels at or above 10 μg/dL. Generally, TCRAs would be taken at Tier 1 properties. 

C Tier 2 properties have either sensitive populations and soil lead concentrations in surface soils 

between 400 ppm and 1,200 ppm, or no sensitive populations and surface soil lead concentrations 

above 1,200 ppm, but not both. Tier 2 properties can be addressed through TCRAs, or non-timecritical removal actions (NTCRAs), or long-term remedial actions. 

C Tier 3 properties have surface soil concentrations below 1,200 ppm, but above 400 ppm, and no 

sensitive populations present. Tier 3 sites would typically be addressed through long-term remedial 

actions or NTCRAs. 

Tier 1 should be the highest priority for immediate action and Tier 3 should be the lowest priority 

for immediate action. Residential properties can move into a different tier if conditions change (e.g., 

small children or pregnant women move into a house). A typical residential lead site will contain a 

combination of properties that fit into different tiers. The project manager should use judgement to 

determine whether or not to perform a complete cleanup of contaminated residential properties (as 

defined in Section 1.3). 

As discussed below, remedial actions for residential lead sites should use the IEUBK model. The 

IEUBK model should be used to assess risks posed by contaminated soils and to determine PRGs for soils 

at residential lead sites. In order to facilitate TCRAs, a demonstration of elevated blood lead levels or 

elevated soil-lead levels at or above 1,200 ppm will usually be sufficient. If elevated blood lead levels are 

the basis for concern, occupational contributions of lead, elevated lead levels in drinking water, lead from 

LBP, and lead dust in the homes of children or adults with elevated blood lead should be investigated first 

because these sources of lead can be significant (Appendix B). At this stage, consultation with Regional 
35 

risk assessors and public health officials (such as ATSDR) to better understand health impacts is 

encouraged. 

The Agency plans on publishing a future lead removal directive which includes further information 

on site-tier approaches. 

5.2 LONG-TERM REMEDIAL ACTION 

The 1994 Office of Solid Waste and Emergency Response (OSWER) Directive 9355.4-12 states 

OSWER’s risk reduction goal for residential lead sites: “... generally, OSWER will attempt to limit 

exposure to soil lead levels such that a typical (or hypothetical) child or group of similarly exposed 

children would have an estimated risk of no more than 5% exceeding the 10 :g lead/dL blood lead level.” 

(P10<5%) (EPA, 1994b). It is important to note that this recommendation (i.e., P10<5%) is meant to apply 

to a single residential property or another discrete exposure area, not on an area- or community-wide basis 

(i.e., 5 children out of every 100 actually exceed 10 :g/dL). It is also important to note that selecting a 

soil lead concentration in this manner will not guarantee that a given child will not exceed a blood lead 

level of 10 :g/dL. Many factors other than soil concentration cause variance in blood lead levels: pica 

behavior, or other sources of lead not included in the exposure unit, such as paint, diet, etc. (e.g., this 

could include soil at a camping site or other remote site frequented by the child). 

The 1998 OSWER Directive 9200.4-27P (‘Clarification’) (EPA, 1998a) recommends that the 

IEUBK Model be used as the primary tool to generate risk-based soil clean-up levels at lead sites for 

current and future residential use (Appendix B). Additionally, the 1998 Clarification states that response 

actions can be taken using IEUBK predictions alone, and that blood lead studies, while providing useful 

information, should not be used for establishing long-term remedial or non-time-critical removal clean-up 

levels at lead sites. Regarding exposure units at residential lead sites, the 1998 Clarification states: “... it 

is recommended that risk assessments conducted at lead-contaminated residential sites use the individual 

residence as the primary exposure unit of concern” (EPA, 1998a; Appendix B). This document clarifies 

the definition of exposure unit provided in the 1998 Clarification. In addition to the individual residence, 

accessible site-related lead sources outside the residential setting should also be evaluated to understand 

how these other potential exposures contribute to the overall risk to children. When the evaluation 

indicates a significant contribution to risk, clean-up measures should be determined for those areas. 

Empirical blood lead data occasionally deviates significantly from IEUBK Model predictions. This 

can be due to numerous factors, including the implementation of lead exposure-reduction and health 

education programs, and uncertainties in the exposure parameters of the Model as well as uncertainties in 

the blood lead data (Mushak, 1998). Regarding this issue, the 1998 Clarification states: “Where actual 
36 

blood lead data varies significantly from IEUBK Model predictions, the model parameters should not 

automatically be changed. In such a case, the issue should be raised to the TRW to further identify the 

source of those differences” (Appendix B). Basically, model inputs should be changed only when 

defensible, site-specific information that is specifically applicable to the parameters is collected. 

Moreover, these changes should also ensure that model outputs are protective of future residents. 

Examples of such information are dust lead concentration, drinking water concentration, bioavailability 

data (e.g., in vivo pig studies), and soil-to-dust ratio. The predictive capacity of the IEUBK Model 

depends upon the representativeness of the inputs. Section 4 discusses the collection of the data used to 

estimate some of these inputs. 

In summary, there is no national clean-up standard for lead in residential soil on a Superfund site; 

however, there is a consistent process by which residential soil lead clean-up levels are selected. One step 

is to gather site-specific data as recommended in Section 4 of this Handbook and review other guidance 

on the use of the IEUBK Model (EPA, 1994b; TRW web site: http://www.epa.gov/superfund/programs/ 

lead/ieubk.htm). Risk assessors (and other data users) should be consulted early to assist with data 

collection and planning (EPA, 2000d). Another step is to get assistance from the regional risk assessor(s) 

to run the IEUBK Model with applicable site-specific inputs. Running the model should allow the 

determination of a site-specific PRG that corresponds to a P10 for a typical child, or group of similarly 

exposed children, that is no more than 5%. Another step is to select a site-specific residential soil lead 

clean-up level that is based on the model-derived soil lead PRG and an analysis of the nine criteria 

consistent with the NCP (Superfund sites only) (EPA, 1990b). If the proposed clean-up level is outside of 

the range of 400 ppm to 1,200 ppm lead, then the draft decision document for the site is sent to the Lead 

Sites Consultation Group (LSCG) for review (EPA, 1997b). 

Lead Sites Consultation Group (LSCG) – The Lead Sites Consultation Group (LSCG) was 

created in 1997 to promote national consistency in decision-making at lead sites across the country 

(EPA, 1997b). The main purpose of the group is to review key response decisions at lead sites. 

The LSCG is comprised of senior management representatives from the Waste Management 

Divisions in all 10 EPA regions along with senior representatives from the Office of Emergency 

and Remedial Response in EPA headquarters. 

The LSCG is supported by EPA’s Technical Review Workgroup for Lead (TRW) and the national 

Lead Sites Workgroup (LSW). According to Agency policy, there are three triggers that cause the 

review of lead-related proposed plans by the LSCG (EPA, 1997b): 

1) Residential contaminated lead sites with proposed cleanup levels outside a 400 to 

1,200 ppm soil-lead level; 

2) Sites that envision actions to address non-soil lead-contaminated media; 

3) Routine LSW deliberations that identify a unique or precedent setting site issue(s). 
37 

6.0 APPLICATION OF CLEAN-UP NUMBERS/REMEDIATION 

The following section provides a detailed discussion of recommended minimum considerations to 

remediate residential soil and other sources of lead in residential settings. The guidelines stated below 

apply to early/interim actions and long-term remedial actions. However, due to statutory funding 

limitations that apply to time-critical removal actions, site-specific determinations regarding yard size 

limitations, and whether to clean up empty lots and other sources of lead (paint, dust, tap water), should 

be made by the project manager on a site-by-site basis. 

6.1 MINIMUM EXCAVATION DEPTH/SOIL COVER THICKNESS 

Based on Agency experience, it is strongly recommended that a minimum of twelve (12) inches of 

clean soil be used to establish an adequate barrier from contaminated soil in a residential yard for the 

protection of human health. Cover soil can either be placed after excavation as backfill or placed on top 

of the contaminated yard soil. The rationale for establishing a minimum cover thickness of 12 inches is 

that the top 12 inches of soil in a residential yard can be considered to be available for direct human 

contact. With the exception of gardening, the typical activities of children and adults in residential 

properties do not extend below a 12-inch depth. Thus, placement of a barrier of at least 12 inches of 

clean soil will generally prevent direct human contact and exposure to contaminated soil left at depth. 

Removal of lead-contaminated soil to depths greater than 12 inches should be considered at sites in 

cold regions with non-soil lead-contamination sources, such as tailings and crushed battery casings, and 

whenever it is cost-effective. The additional response cost should be compared to future IC and 

monitoring costs associated with leaving the material in place. Full vertical removal of residential soil 

has many advantages, such as reducing or avoiding the costs of maintaining the soil cover, the placement 

of subsurface barriers/markers, and obtaining environmental easements. Full removal of contaminated 

soil also satisfies EPA’s preference for permanent remedies and normally allows the remediated yard to 

return to unrestricted use. 

Twenty-four (24) inches of clean soil cover is generally considered to be adequate for gardening 

areas; however, site specific conditions that may require more soil cover (e.g., presence of burrowing 

animals) should be considered. A 24-inch barrier normally is necessary to prevent contact of 

contaminated soil at depth with plant roots, root vegetables, and clean soil that is mixed via deep 

rototilling. Raised garden beds may be built to obtain 24 inches of clean soil, and may be more cost 

effective than excavating to 24 inches in depth, e.g., excavate 12 inches of contaminated soil, then add 

24 inches of soil to create a 12" raised bed. 
38 

6.2 SOIL CLEAN-UP OPTIONS 

Currently, there are only two remedial actions that generally are considered to be protective, longterm (not interim) remedial actions at residential properties: (1) excavation of contaminated soil followed 

by the placement of a soil cover barrier and (2) placement of a soil cover barrier without any excavation 

of contaminated soils. Excavation followed by the placement of a soil cover is the preferred method and 

is strongly recommended at sites with relatively shallow contamination, such as many smelter sites. In 

most cases, excavation and placement of a soil cover should be performed whenever the specific 

conditions of a site do not preclude it. For example, it may not be feasible to fully excavate a very large 

site cost-effectively, therefore capping, also considered to be protective, may be more appropriate. The 

advantage of the preferred method is that it is a permanent remedy in terms of removal of lead from areas 

where children may be exposed. 

Several treatment technologies are currently under development to reduce the bioavailability of soil 

lead, but have not yet been proven to be protective in the long-term. These include amending the soil 

with phosphorus or high iron biosolids composts. Preliminary results have shown phosphate treatment to 

reduce the bioavailability of lead in soil by as much as 50 percent. This would mean that soil with lead 

concentrations in the range between clean-up levels calculated with the pre- and post-treatment 

bioavailability values could be treated instead of removed (e.g., if the IEUBK model-derived clean-up 

number using the pre-treatment bioavailability were 400 ppm lead, and the calculated post-treatment 

clean-up level were 800 ppm lead, then the yards with lead concentrations between 400 ppm and 800 ppm 

could be treated rather than excavated or capped). 

Over time, the efficacy of the phosphorous treatments appears to increase. This is consistent with 

what is predicted using thermodynamics. To date, the treatability studies have been monitored for 

3–5 years. Additional monitoring will be necessary to assure the long-term stability of the observed 

reduction in bioavailability. 

Some other existing technologies for soil remediation that are not currently considered acceptable 

for residential lead cleanups are rototilling, phytoremediation, and interim controls, such as mulching, 

seeding, and sodding (without prior removal of contaminated soil). Rototilling is not considered a 

permanent, protective remedy in that no lead removal occurs, and adequate mixing of soil is difficult, if 

not impossible, to achieve; additionally, rototilling may increase the volume of soil, which ultimately 

requires remediation. Mulch, sod, or other vegetative covers are generally not considered permanent, 

protective remedies in that no lead removal occurs, and there is no guarantee that grass, mulch, or other 

vegetative cover will be maintained in good condition over time. 
39 

Additionally, land use changes that may occur within a yard, such as starting a garden or putting in 

a swing set, are not precluded in any way by mulch, sod, or other vegetative cover. Lastly, 

phytoremediation is not currently an appropriate technology for residential lead cleanups due to several 

factors: (1) the lead concentrations at many residential sites are not within the optimal performance range 

for the plants; (2) the plants may concentrate lower level lead contamination and present an increased 

disposal cost if the plants fail the TCLP test, but the unremediated yard soil does not fail; (3) the length of 

time required for remediation; (4) the potential conflicts with local regulations pertaining to yard 

maintenance; and (5) the depth of remediation achieved may be inadequate. 

6.3 INTERPRETING SAMPLING RESULTS 

Based upon the results of the sampling efforts (Section 4.0), this section describes the 

implementation of two clean-up options: (1) excavation and backfill (and placement of a visible barrier if 

applicable); or (2) soil cover placement (and placement of a visible barrier if applicable). The options 

should be performed as described below (see also Figure 6-1). The goal should be to remove all 

contaminated soil or provide a minimum 12" clean soil barrier. The following describes the 

implementation of option 1: 

• If the 0–1" horizon exceeds the clean-up level, a 6 or 12" excavation is recommended, 

depending on the 6–12" sample horizon results; 

• If the 1–6" or 0–6" horizon exceeds the clean-up level, a 6 or 12" excavation is 

recommended, depending on the 6–12" sample horizon results; 

• If the 6–12" horizon exceeds the clean-up level, a 12" excavation is recommended. A 

visual barrier is required if the 12–18" horizon exceeds the clean-up level; 

• If the 0–1, 0–6 or 1–6" horizons exceed the clean-up level and the 6–12" horizon does not 

exceed the clean-up level, a 6" excavation is recommended; a visual barrier is not needed. 
40 

0-1” Yes Yes Yes Yes No No No No 

1-6” 

(or 0-6”) 

Yes Yes No No No Yes No Yes 

Remedial Action 

Options 

6-12” Yes No Yes No No No Yes Yes 

Option 1: 

Excavation 

(& Backfill) 

Depth of 

excavation 

12” 6” 12” 6” No action 6” 12” 12” 

Option 2: 

Capping 

Soil cover 

thickness 

12” 12” 12” 12” No action 12” 6” 12” 

Depth Soil Concentration Exceed Action Level?

Figure 6-1. Interpreting Sampling Results. The figure suggests remedial actions based on the results 

of composite soil samples collected for each of the depth intervals shown. The figure includes two 

remedial action options: (1) excavation followed by backfilling, and (2) placement of a clean soil cover 

without removal of soil that exceeds the action level. To use the figure, find the column of the table that 

agrees with the soil sample results for your site, then read down the table to determine the depth of soil to 

remove (option 1: excavation remedies) or the thickness of the soil cover recommended (option 2: 

capping remedies). For example, the heavy border around the third column of the table corresponds to a 

situation where the average lead concentration in the 0–1" and 1–6" depth intervals exceed the action 

level, but the 6–12" interval does not. In this example, it is recommended to remove the top 6" of 

contaminated soil and replace it with clean soil, or to place a 12" clean soil cover (cap). The goal is to 

provide a minimum 12” barrier of clean soil when the underlying soil exceeds the action level. Please 

refer to Section 6.3 for further explanation. 
41 

The following describes the implementation of option 2: 

• If the 0–1" horizon exceeds the clean-up level, a 12" soil cover and visual barrier should 

be used; 

• If the 0–6" or 1–6" horizon exceeds the clean-up level, a 12" soil cover and visual barrier 

should be used; 

• If the 6–12" horizon exceeds the clean-up level (but not the 0–1", 1–6", or 0–6" 

intervals), a 6" soil cover should be used; 

• If only the 12–18" horizon exceeds the clean-up level, no capping is needed. 

The decision to perform soil cleanup to depths greater than 12 inches should be considered on a 

site-by-site basis. Some advantages to full vertical soil cleanup are listed in Section 6.1. However, there 

are many sites where lead contamination is located at depth. Full vertical soil cleanup may not be costeffective and/or feasible at such sites. The depth of excavation and soil cover thickness is an important 

factor to be considered during the analysis of the nine criteria per the NCP (for Superfund sites) (EPA, 

1990b). Potential for freeze/thaw upward migration, groundwater contamination, and the cost, extent, 

and effectiveness of ICs are some of the factors to be considered in this analysis. 

Sampling results obtained for residential lots may indicate that only a portion of the lot contains soil 

that exceeds the selected clean-up level. For properties less than 5,000 square feet, the spatial scale for 

the remedial decision should be one-half of the yard. For properties greater than 5,000 square feet, the 

property should be divided into four quadrants and a remedial decision should be made for each quadrant. 

It is usually protective to excavate only the portion(s) of the lot that exceed the clean-up level 

(Figures 6-2a and 6-2b). However, removal of the sod layer and resodding/reseeding the unexcavated 

portion(s) of the lot is strongly recommended to promote consistency in the vegetative cover of the yard 

for homeowner satisfaction. When interpreting sampling results for a property, the sampling results of 

surrounding properties should also be considered to lessen the probability of mislabeling the property as 

being below the clean-up level, when it is actually above, and to avoid “patchwork clean-up” patterns, 

which are prone to recontamination. 

If the only portion of the yard that exceeds the selected clean-up level is the drip zone, the exterior 

paint should be checked for lead content. If the drip zone contamination does not appear to be paintrelated, the drip zone should generally be cleaned up. If the drip zone contamination appears to be solely 

paint-related, EPA should promote the remediation of the exterior LBP by local health agencies, other 

local government agencies, state health agencies, and/or the homeowner. At a minimum, the resident 

should be notified and informed of the disclosure requirements (Appendix A). Consideration should be 

given to also notifying the relevant local government agencies and informing them about available 

remedies, such as HUD grants. 
42 

Soil concentration greater Soil concentration less than

than selected cleanup level selected cleanup level 

(remedial action required) (remedial action is not required)

Drip Zone 

Back 

Residence Yard

Front 

Yard 

Figure 6-2a. Partial cleanup of residential lot less than or equal to 5,000 square feet in 

size. In this example, the lead concentration measured in the front yard exceeds the selected 

clean-up level while the concentration measured in the backyard does not. Cleanup may be 

limited to the front yard although it is recommended that the sod layer in the entire lot be 

removed to promote consistency in the vegetative cover on the property for homeowner 

satisfaction. The entire drip zone should be cleaned up if the average lead concentration 

exceeds the clean-up level. For example, in the above figure, the drip zone in the back yard 

(as well as the front yard) should be cleaned up if the average concentration in the drip zone 

exceeds the clean-up level. Please refer to Section 6.3 for further explanation. 
43 

Soil concentration is less than 

2 

3 

Residence 

Drip Zone 

1 

Soil concentration is greater 

than selected cleanup level 

(remedial action required) 

4 

selected cleanup level in 

quadrants 2-4 (remedial action 

is not required) 

Figure 6-2b. Partial cleanup of residential lot greater than 5,000 square feet in size. In 

this example, the lead concentration measured in quadrant 1 exceeds the selected clean-up 

level while the concentration measured in quadrants 2–4 do not. Cleanup may be limited to 

quadrant 1 although it is recommended that the sod layer in the entire lot be removed to 

promote consistency in the vegetative cover on the property for homeowner satisfaction. The 

entire drip zone should be cleaned up if the average lead concentration exceeds the clean-up 

level. For example, in the above figure, the drip zone in quadrants 2–4 (as well as quadrant 

1) should be cleaned up if the average concentration in the drip zone exceeds the clean-up 

level. Please refer to Section 6.3 for further explanation. 
44 

6.4 OTHER CLEANUP CONSIDERATIONS 

The area remediated on a single property normally should not exceed one acre. This limitation is 

based on three factors: (1) typical lot sizes in residential areas throughout the country generally do not 

exceed one acre; (2) the portion of a property where the majority of exposure to contaminated soil occurs 

generally does not exceed one acre; and (3) EPA should generally not excavate/cover with soil the 

entirety of very large yards due to cost-effectiveness considerations. 

The goal for cleanup of a yard that exceeds one acre is to excavate or cap the portion of the yard 

that is in frequent use and continue to limit exposure in the unremediated portion of the yard. To this end, 

it is recommended that the unremediated portion of such a yard be fenced to clearly delineate the 

remediated and unremediated areas and to limit the potential for off-site migration of contaminants (e.g., 

vehicle tracking). Exceptions to this general approach may include areas outside the one-acre area that 

are used for recreation and gardening, areas with the potential for residential development, and areas in 

close proximity to other residential areas. As stated in Section 6.5, any unremediated areas of a property 

should be documented on the clean-up documentation letter for such property, and consideration should 

be given to implementing ICs for those areas. 

If contaminated soil is not removed to the full depth of contamination (i.e., where soil concentration 

is greater than clean-up level) on a property, a permanent barrier/marker that is permeable, easily visible 

and not prone to frost heave, should be placed to separate the clean fill from the contamination. This 

applies to both incomplete vertical excavation with placement of a soil cover and placement of a soil 

cover without excavating contaminated soil. Selection of an appropriate permanent barrier/marker should 

be based on the type of contamination left in place, the chemical/physical characteristics of the soil (e.g., 

pH), the potential for upward migration of the contamination, and/or the types of ICs developed for the 

site. Examples of suitable barriers/markers include snow fencing (usually orange), a clean, crushed 

limestone layer, and geofabric. 

Empty lots that are zoned residential and contain soils with lead concentrations greater than the 

clean-up level should be cleaned up when in close proximity to other residential lots. Examples of this 

are lots between two houses and lots that are near occupied lots. A site-specific determination should be 

made for these situations. Also, unpaved lots used for vehicle parking should be sampled, and cleaned up 

if necessary, or access restrictions put in place to prevent recontamination (e.g., vehicle tracking of 

contaminants) even if no current direct exposure exists. However, it is not the intent of EPA to clean up 

tracts of remote, undeveloped, lead-contaminated land that may be developed into residential lots in the 

future. This clean-up responsibility should be borne by the land developer. Institutional controls should 
45 

be developed to ensure safe development in these areas, since under CERCLA developers could be held 

liable for improper cleanup. 

6.4.1 Background Lead Concentrations 

Many of the “Lead Sites” on the NPL are located in areas with high natural background lead 

concentration. Often this problem is exacerbated by the presence of high background concentrations of 

lead in various media (such as soil and groundwater) from anthropogenic sources such as automobile 

emissions, mining, and smelting (the latter two sources would be considered ‘background’ if they are not 

associated with the site). It should be noted that CERCLA 104 (a)(3) limits the Agency from taking 

response actions to address "... naturally occurring substance in its unaltered form, or altered solely 

through naturally occurring processes or phenomena, from a location where it is naturally found” (EPA, 

2000a). Generally, under CERCLA, clean-up levels are not set below natural or anthropogenic 

background concentrations (EPA, 1996c, 1997d, 2002). Cleanup below natural or anthropogenic 

background concentrations is normally not performed because it is not cost-effective, it is technically 

infeasible and there is a high likelihood of recontamination by surrounding areas that have not been 

remediated (EPA, 2002). 

Public education about ubiquitous risks should be incorporated early in the process to help the 

community understand that Superfund actions are designed to address risks from specific releases to the 

environment (EPA, 2002). In situations like these, it may be appropriate to examine land uses that limit 

exposures through implementation of ICs. For more information on this approach, please refer to the 

1998 Clarification to the Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective 

Action Facilities (Appendix B). Site-specific factors should determine what range of alternatives and 

what clean-up levels will achieve a protective remedy satisfying the nine criteria specified in the NCP. 

Remedial decisions often involve a comprehensive response coordinated with other responsible 

authorities, such as a local public health district, state departments of environmental protection, housing 

agencies, and private parties. An effort should be made to identify other programs or regulations that may 

have the authority and capability of addressing risks associated with high natural or anthropogenic 

background (EPA, 2002). Additional guidance is available for developing a risk management-based 

response strategy that is protective of human health and the environment (EPA, 1988). 
46 

6.5 YARD CLEANUP SPECIFICS 

It is important to define the limits of the properties that will be remediated. The use of property 

lines rather than temporary features, such as fence lines, to delineate boundaries is recommended. The 

use of temporary features may result in partial cleanup of some properties. 

Whether remediation consists of excavation and placement of soil cover or just the placement of a 

soil cover, consultation with the property owners is important to the development and implementation of 

response actions and may necessitate property-specific deviations to the guidelines listed in this section. 

Flexibility is essential to a successful residential lead clean-up program. Some residents may want to pay 

for upgrades during the cleanup of their yard, such as paving a driveway after excavation, or to have some 

yard features removed, such as taking out a damaged patio. Within reasonable limits, such requests 

should be entertained on a yard-by-yard basis. Granting such requests can greatly contribute to building 

public trust and satisfaction with the clean-up program. All additional costs associated with special 

requests and considerations must be borne by the homeowner. 

Prior to cleanup of a residential yard, access from the property owner should be obtained; access 

obtained from tenants or renters is not sufficient. It is recommended that access be obtained by going 

door-to-door. If residents are not home, a blank access agreement with instructions for signature and 

submission to EPA, along with relevant contact information should be left at the residence (but not in the 

mailbox). An example access agreement form is presented on page D-6 of Appendix D. As stated in 

Section 4.2.1, it is suggested that access for remediation be obtained at the time access for sampling is 

sought. Examples of combined sampling/remediation access agreements are presented on pages D-4 and 

D-5. An example of a dust cleanup access agreement form is presented on page E-2 of Appendix E. 

Many residents may refuse access for dust cleanup while granting access for yard-soil cleanup. 

Combining dust access agreements with other access agreements is not recommended. 

Prior to initiating clean-up activity, the condition of each property should be documented and 

recorded on videotape. ‘Clean-up activity’ includes any disturbance of the property, including the 

removal of debris and dilapidated structures that may be required prior to initiating the excavation of 

contaminated soil. An example of a property inspection form is provided in Appendix F. EPA should 

enter into a written agreement with the resident regarding any special requests or considerations in 

cleaning up the yard, e.g., replacing concrete walkway with brick. All additional costs associated with 

special requests and considerations must be borne by the homeowner. Any contaminated yard areas that 

will not be cleaned up, special resident concerns, and any deviations from strict soil excavation or 

capping should be noted on this agreement. 
47 

Other possibilities for cleanup-related agreements include sod/lawn watering agreements. A sodwatering agreement basically allows for payment to residents for watering the sod that is placed by the 

remediation contractor. A payment is made before watering is required to cover the water bill and some 

of the time involved. A second payment is made if, at the end of one month, the sod is in good condition. 

A similar agreement should be established for maintaining lawns that have been initiated by 

hydroseeding. This can be a useful incentive program that can also save money. The contract with the 

remediation contractor should require the contractor to establish vegetation on each property, restore the 

pre-construction drainage patterns on each property, and perform repairs for damages to the property. 

Relocation of residents during yard soil remediation is rarely needed and is generally not 

recommended (EPA, 1999b). (Guidance is available online at: http://www.epa.gov/oerrpage/superfund/ 

tools/topics/relocation/index.htm.) 

Specific safety issues during residential yard cleanup, including ingress and egress to the home, 

should be coordinated with the property owner/residents and spelled out in the Health and Safety Plan. 

Incomplete barriers (such as rock or gravel) or minimal use areas (such as areas under porches), 

which exceed the applicable clean-up level, should be cleaned up to the extent practical. Although 

removal is preferred, if it is not feasible to clean up the area, a barrier, which effectively limits access, 

should be constructed. For example, for areas underneath porches, typically the preferred barrier would 

be shot-crete (sprayed concrete that can easily be placed in tight or confined areas). It may be preferable 

to place asphalt rather than gravel on heavily-trafficked roads or driveways, especially those that 

experience severe erosion. 

In all cases, every attempt should be made to clean up the entire yard (subject to cost limitations 

discussed below), however, any residential yard areas without permanent barriers that the resident 

requests to leave unremediated, such as gardens or patios, should be sampled separately to determine if 

the selected clean-up level is exceeded. If the clean-up level is exceeded and the owner refuses to allow 

cleanup of that portion of the yard, then the clean-up documentation letter issued to the owner should note 

the unremediated area. 

The steps of a typical soil cleanup are shown in the text box below. 
48 

Steps of a Typical Soil Response Action 

Step 1 (Access Agreement) - Collect access agreement(s) from each owner and/or tenant before any 

work is conducted. 

Step 2 (Initial Survey) - Interview the resident(s) to determine if there are any specific problems that 

need attention, and if there are any structures or property the owner wants to have disposed, stored, or 

left untouched. The contractor will conduct a thorough documentation of the property using 

drawings, digital photographs, and videotapes. Once documented, the owner is required to sign a 

property agreement which documents any special requests or considerations in cleaning up the yard, 

any contaminated yard areas that will not be cleaned up, provisions for structural concrete and fence 

restoration, and deviations from strict soil excavation and capping. 

Step 3 (Excavation) - Each tract is excavated by the contractor(s), who will also complete 

documentation and provide depth confirmations. 

Step 4 (Backfill) - After excavation of properties where full excavation to depth has been performed, 

the excavated area is backfilled and compacted. After excavation of properties with a vertical 

excavation limit, a permanent, permeable barrier/marker is placed in the excavated area. After 

placement of the barrier/marker, the excavation area is backfilled and compacted. 

Step 5 (Restoration) - Restoration of the property, including landscaping, sod/seeding, fencing, and 

concrete (if needed) is conducted. 

Step 6 (Final Inspection) - After restoration activities are complete, the EPA, PRP, or its agent 

(e.g., Corps of Engineers) will conduct a final inspection. 

Step 7 (Closeout Form) - A property closeout form should be signed by the property owner, which 

documents the owner is satisfied with the remediation of the property. Any outstanding issues 

between the EPA and the homeowner that have not been fully resolved should be documented in the 

closeout form. 

Step 8 (Clean Letter) - After the homeowner signs at property closeout form, the EPA issues a 

“clean” letter, which documents the property has been remediated. Any areas that are not cleaned up 

via the owner’s request, such as gardens, should be noted in the “clean” letter. For properties where 

contamination is not completely removed, the clean letter should also document the presence of 

contamination at depth, and should describe the protective measures that were taken to prevent 

exposure to the remaining contamination (i.e., barriers/markers). 
49 

6.6 CLEANUP OF OTHER SOURCES OF LEAD 

Lead in the environment can originate from many sources. In addition to soil, the main sources to 

consider when performing clean-up activities are interior and exterior LBP, lead-contaminated interior 

dust, drinking water, and occupational exposure resulting in subsequent contamination of homes. 

Generally, sources other than soil, exterior paint, dust, and tap water cannot be remediated by EPA in the 

course of residential lead cleanups. 

Ultimately, the project managers should strive to address any unacceptable lead-exposure risks at 

the residence. Sampling and the establishment of clean-up mechanisms needed to take action, such as 

HUD grants for paint abatement, should be completed as early in the remedial process as possible. Even 

so, it may not be possible to address all sources of lead in the ideal sequence. When this occurs, other 

measures should be taken to minimize the potential for recontamination (i.e., to protect the remedy). For 

example, if deteriorating exterior LBP is present, it is recommended that it be removed prior to initiating 

any soil clean-up activities in the yard. 

Due to transport of lead among media, the preferred sequence of lead clean-up activities at a 

residence with LBP and lead-contaminated soil would be to clean up the paint first, then the yard soil, and 

then the interior dust. Clean-up activities performed counter to this sequence increase the risk of 

recontamination. For example, performing a soil cleanup first at a residence with exterior paint problems 

increases the potential for recontamination of the soil from the exterior paint. Similarly, interior dust can 

be recontaminated by interior LBP. Exterior sources have been shown to cause recontamination of the 

interior when cleaned before community-wide yard cleanup is completed (EPA, 2000e). Accordingly, 

project managers should make every effort to coordinate the sequence of clean-up activities to prevent 

recontamination. 

CERCLA and the NCP limit Superfund Supplemental Environment Project (SEP) – authority to address interior LBP (see Section 1.2) Environmentally beneficial projects which a 

(EPA, 1990b). If a mechanism exists for addressing defendant/respondent agree to undertake in 

settlement of an enforcement action, but the paint, such as a HUD grant or a Supplemental which the defendant/respondent is not 

Environmental Project (SEP), then the timing of the otherwise legally required to perform. 

paint encapsulation or abatement activities may not 

coincide with the soil cleanup. Additionally, residents may be more reluctant to grant access for dust 

remediation since it is more intrusive. On the other hand, EPA actions taken to address lead in drinking 

water from site sources usually can be taken independently from any soil, dust, or paint cleanups, and 

should be done as soon as practical. 
50 

6.6.1 Lead-Based Paint 

The 1998 Clarification presents OSWER’s policy with respect to remediation of interior paint, 

exterior paint, interior dust, and lead plumbing. Regarding interior LBP, the 1998 Clarification states: 

“EPA has limited legal authority to use Superfund to address exposure from interior lead-based 

paint. As a policy matter, OSWER recommends that such exposures not be addressed through 

actual abatement activities. However, EPA Regions should promote addressing interior paint 

risks through actions by others, such as HUD, local governments and health authorities, or 

individual homeowners as a component of an overall site management strategy. Any activities to 

clean up interior lead-based paint by potentially responsible parties (PRPs) or other parties should 

not result in an increase of the risk-based soil clean-up levels” (EPA, 1998a; Appendix B). 

Regarding exterior LBP, the 1998 Clarification indicates that the Regions should avoid using the 

Superfund trust money for removing exterior LBP and soil contaminated from LBP. However, Superfund 

dollars may be used to respond to exterior LBP to prevent recontamination of soils that have been 

remediated, but only after determining that other funding sources are not available (EPA, 1998a; 

Appendix B). The 1998 Clarification states: “As with interior lead-based paint abatement, EPA Regions 

should promote remediation of exterior lead-based paint by others, such as PRPs, local governments, or 

individual homeowners. Clean-up activities of exterior paint conducted by PRPs or other parties should 

not result in an increase of the risk-based soil clean-up levels” (EPA, 1998a; Appendix B). 

As a practical matter, project managers should inform each resident regarding the presence or 

absence of LBP in their home, and options for encapsulation and abatement. The local health agency 

and/or the state health agency should be informed regarding the availability of HUD grants for paint 

assessment and abatement. Additionally, regarding PRP-funded cleanups, if any penalties are being 

considered for non-compliance (Section 6.9), consideration should be given to allowing the PRPs to 

perform a SEP for paint assessment and abatement in lieu of some or all of the penalty amount. 

6.6.2 Interior Dust 

Lead-contaminated interior dust can be derived from multiple sources, including exterior soil, 

interior and exterior paint, homeowner hobbies, workplace, and other exterior sources; thus, it may be 

difficult to differentiate between sources of dust contamination. Household lead dust contamination may 

be a significant contributor to elevated blood lead levels, especially for younger children (under the age of 

three), and may need to be evaluated in determining risks and clean-up actions at residential lead sites. 

However, as pointed out previously, there are limitations on EPA's authority to abate these sources of 

contamination to the extent they are not related to releases or threatened releases to the environment 

(Appendix B). 
51 

Based on the 1998 Clarification, OSWER recommends that Superfund monies should generally not 

be used to take CERCLA response actions for addressing residential dust exposures due solely to interior 

paint or other interior sources. However, Superfund monies can be used to address interior dust if it can 

be shown to be derived from an exterior pollution source (e.g., air lead concentration caused by lead 

smelter, mining, or mineral processing). Dust mat sampling, which was done at the Bunker Hill Site in 

Idaho (EPA, 2000e), is one possible method of lead source identification; speciation, which is costly, is 

another method. (Dust mats are used to measure dust lead concentration and loading rates in residences 

and other structures.) Where interior dust is being addressed by other authorities, the recommendations 

presented here may be helpful to guide the dust cleanup. 

If the lead in interior dust is solely derived from interior paint, EPA should promote addressing 

interior dust risks through the actions of others, such as HUD, state and local governments, PRPs, or 

individual homeowners, as a component of an overall site management strategy. The overall site strategy, 

as outlined below, should also consider the proper phasing/sequencing of actions to address the multiple 

sources of lead risks at residential lead sites, as discussed at the beginning of Section 6.6. 

The baseline risk assessment should document the relative contributions of lead uptake from all 

relevant media including direct soil exposures and secondary exposures to soil in indoor dust. 

Replacement of defaults with a site-specific value for the interior dust concentration, or the soil-to-dust 

relationship (Msd), should be justified through the use of high quality, compelling, site-specific data (EPA, 

1994b, 1998c). Dust sampling is preferred for risk assessment and remedial decisions, but dust modeling 

may be needed to develop or refine soil action levels. 

Lead-contaminated interior residential dust presents a significant exposure pathway that can readily 

be addressed. Consequently, significant health benefit is gained by removal of contaminated interior dust 

as early in clean-up activities as possible. However, exterior contamination sources present a threat of 

recontamination to interior of residences (EPA, 2000e; TerraGraphics, 2001). Therefore, any interior dust 

clean-up actions should be periodic throughout the project and should culminate in a final cleaning of all 

residences exceeding an action level after the exterior sources have been remediated. As a practical 

matter, risk management and reduction may need a phased strategy as recommended below: 

Early-Phase Actions: Public awareness and health education efforts should be initiated 

immediately. Entry way dust mats should be provided to residents. 

HEPA-filter vacuum cleaners should be provided for use by residents. If 

warranted, a program to abate interior lead-contaminated dust in homes 

with acute levels should be initiated to provide temporary risk reduction. 
52 

Establish appropriate public health partnerships with state and local health 

departments, ATSDR, and HUD as early as practical. 

Mid-Phase Actions: The source of the interior dust lead contamination should be identified. 

Monitoring of the changes in lead-contaminated dust (e.g., lead loading in 

dust, lead concentration in dust, exterior-to-interior lead transport) should 

be initiated. The public awareness/health education efforts and availability 

of HEPA-filter vacuum cleaners for use by residents should be continued. 

Assistance to remove and dispose of old carpets should be provided to 

residents after yard cleanup has occurred. 

Final-Phase Actions: Once the exterior lead sources that were found to contribute to interior dust 

have been addressed, the final step should consider the active remediation 

of interior lead-contaminated dust. Actions may include: removal of 

carpeting, cleaning heat and ventilation ducts, wet wiping hard surfaces 

and soft surfaces (furniture, draperies, bedding, clothing, etc.). Most of 

these actions should be limited to living spaces. Areas such as attics, crawl 

spaces, and other non-living spaces need not be addressed unless they are 

shown to be a continued source of contamination to the living areas . It is 

important for dust remediation to be performed as the last phase in the site 

clean-up process to minimize the risk of recontamination. 

6.6.3 Lead Plumbing/Tap Water 

The 1998 Clarification states: “Generally CERCLA does not provide legal authority to respond to 

risks posed by lead plumbing within residential dwellings. It should be noted that the water utility is 

responsible for providing clean water to the residences. As with interior dust, OSWER recommends that 

EPA Regions coordinate with local agencies to establish a health education program to inform residents 

of the hazards associated with lead plumbing and how to protect themselves by regularly flushing, or 

preferably, replacing lead pipes. Soil clean-up levels should not be adjusted to account for possible 

remediation of lead plumbing” (EPA, 1998a; Appendix B). 

With regard to tap water, it should be sampled, and lead levels in the purged sample in excess of the 

maximum contaminant level (MCL) established by the Safe Drinking Water Act should be addressed. In 

general, lead concentrations in the purged sample greater than a removal action level (RAL) of 30 :g/L 

should be addressed through TCRAs; concentrations between the MCL and RAL should be addressed 

through NTCRAs or long-term remedial actions. Actions that could be taken include provision of bottled 
53 

water, connection to a municipal water supply, tap filtration, and installation of deep wells (in remote 

areas and where shallow groundwater is contaminated). Regarding first run exceedance for lead, the 

homeowners should be notified that they may need to address a plumbing or corrosion problem, which is 

outside of the scope of Superfund. 

6.7 PREVENTION OF RECONTAMINATION 

Project managers should take steps to mitigate recontamination. During site closeout and five-year 

reviews, the project manager should also check for recontamination at levels which may threaten the 

remedy. 

At many large-area lead sites, cleanup occurs over a long period of time and through multiple 

phases, throughout which the potential for recontamination exists. During each of these phases, 

windblown dust sources, vehicle tracking, flooding, and other mechanisms can recontaminate previously 

cleaned areas. Although best management practices (BMPs) should minimize the movement of 

contaminated material from each residence being cleaned, vehicle tracking of contamination from areas 

yet to be cleaned up can significantly raise concentrations of contaminants in cleaned areas. During the 

early phase, typically an emergency response action, cleanup is focused towards Tier 1 properties, and 

cleanup favors a “hop scotch” approach to address the worst risks first. This method of remediation can 

result in recontamination of clean properties. Confirmation samples should be collected in any areas that 

have been potentially recontaminated. 

Another aspect of large-area lead sites is that complete cleanup of residential properties does not 

always take place for a variety of reasons (see Sections 6.2 and 6.4); instead a barrier or soil cover is put 

in place over contaminated soils. Flooding can pose a serious problem for these areas in that flood waters 

Best Management Practice (BMP) – In 

general, BMPs are a combination of practices 

that are determined to be the most effective 

and practicable means of controlling point 

and nonpoint pollutants at levels compatible 

with environmental quality goals. In this 

document, BMPs specifically refer to 

measures taken during construction activities 

on properties where contamination has been 

left at depth to prevent the transfer of those 

contaminants to other media. 

can erode away clean materials leaving subsurface 

contamination exposed, and entrained sediments 

bearing contamination may be left on top of newly 

remediated properties. Inadequate drainage of runoff 

can move lead into cleaned areas (e.g., lead particles 

on a crowned road with no curb and gutter may be 

rinsed onto adjacent residential properties with 

normal rainfall). Additionally, the activities of 

burrowing animals can bring contaminated soils to 

the surface. 
54 

Recontamination of clean soil cover can be caused by ongoing homeowner projects, such as 

digging a hole through a clean barrier to install fence posts or a new tree or shrub, if preventative 

measures are not taken. Education and licensing of contractors who work on clean barriers/markers 

should generally be required (e.g., as part of a local ordinance) to ensure the longevity of the remedy. 

Also, at many sites (e.g., Bunker Hill), ICs have been most effective when linked to the “call before you 

dig” program typically operated by many counties to avoid disruption of utility service. In addition, large 

scale residential development projects that may raze old housing in favor of new will frequently 

recontaminate areas where lead-contaminated soil was left at depth, without appropriate BMPs in place. 

BMPs include silt fences, hay bales, etc., to limit movement of contamination off a project site, and 

stockpiling of contaminated soil on a tarp to prevent contamination of underlying soil (Figure 6-3). EPA 

provides guidance on the implementation of BMPs in construction activities at sites where contamination 

is present (EPA, 1997e). Best management practices typically add about 5 percent to project cost 

(TerraGraphics, 2000). Periodic inspections of residential areas should be performed by the local 

government to ensure that projects within the site are implementing BMPs. 

Wind blown dust can pose a significant threat to the health of individuals at a site and can cause 

recontamination. Tailings impoundments that have dried can be large sources of windblown lead dust. 

Most tailings impoundments are large; a wind sweeping across the face of one can carry substantial 

amounts of contaminated dust and then deposit these particles on a downwind residential area, both 

causing increased exposure to contaminants, and recontaminating clean areas. Wind blown dust sources 

are typically a key issue to be addressed early in the sequencing of site activities to minimize this 

migration. 

These are but a few examples of how recontamination can be an ongoing problem that needs to be 

considered at every site during each phase of cleanup. Although mechanisms vary from site to site, the 

types of response actions put in place and the sequence in which these actions take place can play a 

significant role in enhancing the permanence and effectiveness of a remedy. 

A disposal area may be needed to dispose of contaminated soil from the site to support typical 

homeowner projects, as some municipal landfills may not accept contaminated soil. Without free or low 

cost disposal for contaminated soil available to each homeowner and renter, improper disposal is more 

likely, which would result in recontamination. In addition, a disposal area may be needed if certain 

materials at a site, such as carpets, fail TCLP and cannot be commingled with solid waste. It may even be 

appropriate for the remedy to provide free removal of contaminated soil and provision of clean soil to 

homeowners (but contractors may be required to pay for these services, or obtain material from approved 

sources) to encourage maximum compliance and further ensure the longevity of the remedy. The 
55 

Figure 6-3. Implementing Best Management Practices (BMPs) during construction work. The best 

management practices (BMPs) shown in the above figure (e.g., a clean soil barrier) represent one 

component of the ICs which may be put in place by local ordinance to ensure the long-term 

protectiveness of the remedy and to prevent recontamination. The purpose of BMPs is to minimize the 

potential for accidental exposure of humans during construction and maintenance activities on sites where 

wastes have been left in place. The staging of contaminated soil on tarps and/or in small buckets, and the 

installation of silt fences downgradient of the construction area are examples of BMPs intended to prevent 

the migration of contaminated material from the construction site. Please refer to Section 6.7.3 for further 

explanation. 

maximum concentration of lead (and perhaps other constituents) allowed in “clean” soil, and the required 

sampling frequency, should be specified in an IC. 

Over the long term, cleanups may not be possible at every property at the same time. A trust fund 

should be established for the site for the cleanup of properties that are deferred for various reasons, which 

should be implemented by the local government. In this manner, changes in property ownership over 

time may be more closely monitored to determine when cleanup at deferred properties might be 

appropriate (see Section 6.9). Local implementation of the trust fund will ensure that cleanup of these 

properties occurs as soon as possible, further ensuring the protectiveness of the remedy, further ensuring 

the protectiveness of the remedy by minimizing the potential for recontamination to the extent possible. 
56 

6.7.1 Early Actions 

Early response actions (including cleanups for sensitive subpopulations) can be an essential 

aspect of the response action at a site, as discussed above. These actions should be conducted 

simultaneously with source area control. The following are considerations that may reduce the potential 

for recontamination when scoping an early action. 

C Seek permanence in selecting the clean-up alternative(s), if possible, such as complete removal 

to depth of soil contamination at properties where there is an acute risk. 

C Consider cleanup of adjacent properties simultaneously that may threaten the permanence or 

effectiveness of the early action. 

C Control fugitive dust sources, access, tracking, and erosion of contaminants to the extent possible. 

C Perform HEPA street sweeping to minimize tracking of contaminants throughout a community. 

C Evaluate the feasibility of conducting the cleanup of residential areas in their entirety during the 

early removal phase if contamination is widespread. If this is not possible, limit the early 

removal actions to immediate risks (Tier 1 and Tier 2 residential properties, including residences 

with elevated blood lead levels) in order to minimize the potential area where recontamination 

might occur. 

C Provide informational fact sheets to homeowners on how to minimize recontamination on their 

property. 

C Establish an IC to manage cleaned areas. This could involve local and state government 

agencies, and PRPs that are available to recommend best management practices for homeowner 

projects and provide education to the homeowner, as well as utility districts and companies likely 

to breach the barriers/markers put in place. 

C Provide site plans or other documentation of areas that have been cleaned up, as well as 

information on areas that are still contaminated, to the local governmental entity responsible for 

the maintenance of the remedy, i.e., for monitoring ICs and for tracking properties over time. 

• Establish a geographic information system (GIS) for monitoring ICs and properties. 
57 

6.7.2 Long-term Remedial Action 

Some or all of the following measures may be useful to address the risk of recontamination 

during the remedial action (Tiers 2 and 3, if a tiered approach is used) and post-design phase: 

C Evaluate the permanence and effectiveness of the various remedial actions under consideration. 

Consider the economic feasibility of complete contaminated soil removal to minimize reliance on 

ICs. 

C Conduct a cost analysis comparing the cost of long term ICs to those of complete removal (EPA, 

2000f). For example, property depreciation, tax base impact, additional procedures/cost of utility 

work, flooding complications/costs, and long term IC administration cost should be taken into 

account when comparing the cost of a partial removal of contaminants to a complete removal. 

Property depreciation, while possibly subtle for each property, may add up to substantial losses 

for the entire community in reference to a county tax base. Also, losses for an individual property 

over a lifetime of sales could add up to a significant cost. Following cleanup, increases in 

property valuation from source removal or drainage/infrastructure enhancements (and savings/inkind services to municipalities) should be considered. 

C Remedial action should strive to remediate the contamination in the community by segregable 

areas, such as a town, or a divisible segment of town. Each segregable area should be cleaned up 

as quickly as possible (e.g., within one construction season) to minimize recontamination of 

cleaned properties and to compound the protection to human health (EPA, 2000e). Each 

community should be cleaned up block by block within these segregable areas, utilizing BMPs to 

mitigate tracking of contaminants. Site experience suggests that cleanup of up to 800 properties 

per site per year is possible. 

C Fugitive dust that may be a source for recontamination, and access to such sources should be 

controlled. Air monitoring along with depositional modeling may be necessary to determine if 

windblown dust presents a significant threat of recontamination. Significant sources of 

windblown dust should be controlled prior to or simultaneously with cleanup of adjacent 

residential areas. Consider HEPA street sweeping during remediation and immediately following 

completion of cleanup to minimize tracking of contaminants throughout a community. 

C Complete removal of contaminants should be considered in flood prone areas or areas with a high 

groundwater level due to the inherent difficulty in maintaining a soil cover remedy in a flood 

prone area. Drainage-ways containing contamination within their 100-year floodplain, which are 
58 

not addressed in the remedy could also lead to remedy failure if the contaminants are eroded to 

other areas. 

C Remediation of contaminated rights-of-way should occur within segregable areas simultaneously, 

if possible, or as close together in time as possible to minimize vehicle tracking and 

recontamination of driveways from the rights-of-way. 

C Control measures for all remaining sources, such as mining waste piles surrounding the 

community, should be developed to ensure the remediated neighborhoods are kept clean. ICs 

should be established to ensure the control, or proper use and disposal of any wastes remaining on 

site. 

C If the residential remedy includes replacement of soils, removal of deteriorating exterior LBP 

(e.g., by pressure washing) should be considered to minimize the soil recontamination potential. 

• Other sources of residential property recontamination should also be considered. For example, 

homeowners may bring in contaminated soil for fill or other uses on their property. 

C Establish permanent funding for ICs. Unless all contaminants are removed, some level of ICs 

may be necessary. Early establishment of a program is the key to success of a remedy that 

consists of a partial removal of contaminants. 

6.7.3 Institutional Controls (ICs) 

EPA defines ICs as administrative and/or legal mechanisms that: (1) help minimize the potential 

for human exposure to contamination, and (2) protect the integrity of the remedy. ICs accomplish these 

objectives by directly limiting land or resource use, and/or by providing information that modifies 

behavior. ICs are used throughout the remedy pipeline, including (1) when contamination is first 

discovered (i.e., prohibition of excavation of newly discovered soil contamination), (2) when the remedy 

is ongoing (i.e., restrictions on property use until clean-up levels are met), and (3) when hazardous 

substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and 

unrestricted exposure. 

At sites where minimizing exposure is the primary purpose of the IC, it is EPA's policy that if a 

site cannot support "unlimited use and unrestricted exposure" (EPA, 2000f), ICs are generally required. 

The "unlimited use and unrestricted exposure" threshold is a site-specific determination similar to that of 

a five-year review. Essentially, if contamination could result in an unacceptable exposure, ICs would be 
59 

required. This is often the case at lead cleanups because residual contamination is frequently managed 

onsite. Note that the term "residential" is often used interchangeably with the "unlimited use and 

unrestricted exposure" threshold but these are not synonymous terms. For example, a lead cleanup where 

the top layer of soil has been removed and replaced can result in a residential use at a site that includes 

restrictions (e.g., restrictions on digging, requirements for elevated gardens, and an information/outreach 

program, etc.). 

The second common purpose of an IC is to protect the integrity of a remedy. In the lead cleanup context this may mean using institutional controls to prevent penetration of a cap or damage to 

monitoring equipment. An important consideration in this context is what type of IC will provide the 

required remedy protection. For example, the primary concern for protecting a remedy in a lead clean-up 

scenario is typically uncontrolled excavation. For this reason it is important to select ICs that will be 

relevant to excavators. Examples of potentially effective ICs are local digging or drilling permits and 

"One-Call" or "Miss Utility" systems. Examples of potentially ineffective ICs are deed notices, because 

excavators seldom check land records prior to digging. 

To better understand the correct IC approach, it is important to understand what tools are 

available. In general, there are four categories of ICs commonly used in cleanups: governmental controls, 

proprietary controls, enforcement and permit tools with IC components, and informational devices. The 

definitions provided below were taken in large part from the current EPA guidance (EPA, 2000f). 

Governmental controls are usually implemented and enforced by a state or local government. 

Some of the more common examples include things like zoning restrictions, building/excavation permits, 

groundwater drilling and use permits, ordinances, or other provisions that restrict land or resource use at a 

site. These types of mechanisms are popular in remedies because the administrative processes are in 

place and are typically well understood within a particular jurisdiction. The greatest concern with this 

type of control is that it is often implemented, monitored, and enforced by an agency other than EPA or 

the state. 

Proprietary controls are unique in that they have their basis in real property law and that they 

generally create legal property interests. An example of this type of control is an easement that provides 

access rights to a property so that an agency may inspect and monitor a cover system. A proprietary 

control may also be used to restrict certain activities on the property, such as excavating below a certain 

depth. These are powerful tools in that they can be made to "run-with-the-land" (i.e., effective if 

ownership changes), but they provide significant challenges because property interests are often 

transferred. EPA is limited by CERCLA §104(j) with regard to acquiring interests in real property. Prior 

to acquiring an interest in real property the state must provide an assurance that it will accept transfer of 
60 

that interest at completion of the remedial action. This requirement applies at both Fund-lead and 

enforcement-lead sites. Therefore, if a proprietary control involves the transfer of an interest in real 

property, EPA must obtain this assurance and find an appropriate entity to hold the interest following the 

remedial action. At Fund-lead sites this will most likely be the state. At enforcement sites, it may be the 

state, a PRP, or some other interested and qualified party. In addition, proprietary controls are based on 

state law, and EPA and many state environmental agencies have limited real estate or common law 

experience. This can complicate proprietary control enforcement. 

Enforcement and permit tools with IC components under CERCLA Sections 104 and 106(a) 

include unilateral administrative orders (UAOs) and AOCs, which can be issued or negotiated to compel 

the land owner to limit certain site activities at both federal and private sites. In addition, CERCLA 

122(d) authorizes the use of consent decrees at 

privately-owned sites. Enforcement devices are some 

of the more common ICs. The strength of these types 

of tools is that EPA or states can directly enforce 

them (rather than relying on a local agency for 

governmental controls or using real estate common 

law for proprietary controls). The major weakness is 

that they may be enforceable only against the 

signatory, recipient, or permitee (i.e., may not run 

with the land to bind future property owners). 

Unilateral Administrative Order (UAO) – 

When EPA negotiates with a Potentially 

Responsible Party (PRP) to do cleanup work 

at a Superfund site, the agreement may be 

documented in an administrative order on 

consent (AOC). If the negotiations fail, EPA 

has the authority to compel the PRP to do the 

cleanup by issuing a unilateral administrative 

order (UAO). Administrative orders are 

issued under CERCLA sections 104 and 106. 

Informational devices are types of devices that only provide information or notification that 

residual or capped contamination may remain on-site. These types of tools are common at lead cleanups 

to both provide notification of residual contamination and to provide information that may modify 

behavior to minimize the potential for unacceptable exposure. Examples include placing a property on a 

state contaminated properties registry, developing deed notices, and providing periodic lead-education 

advisories to residents. Due to the nature of informational devices and their non-enforceability, it is 

important to carefully consider the objective of this category of ICs. Informational devices are most 

likely to be used as a secondary "layer" to help ensure the overall reliability of other ICs. 

There is typically an inverse relationship between the amount of cleanup and the degree of 

reliance on ICs (i.e., the more cleanup, the less reliance on ICs). EPA tends to focus on a number of 

considerations when evaluating the long-term viability and amount of redundancy required for ICs at a 

particular site. EPA guidance strongly advocates the use of ICs in "layers" and/or in "series" (EPA, 

2000f). Layering ICs means using multiple ICs concurrently (e.g., a consent decree, deed notice, 

educational/informational devices and a covenant). Using ICs in series is appropriate when IC 
61 

mechanisms are removed or changed as site circumstances change, such as reduction in restrictions during 

the clean-up life-cycle. As illustrated in the descriptions of the different categories of ICs, there are 

inherent strengths and weaknesses with each type. The goal is to obtain the best mixture of ICs to 

manage the risk at a site over the long-term. There are many important factors to consider when 

determining how many ICs are required at a site. The following is not intended to be a comprehensive 

list, but rather illustrative of the site-specific nature of these types of decisions. A few common 

considerations include: (1) the type of enforcement mechanism used (consent decree, order, permit, 

ordinance); (2) who will enforce the mechanism (i.e., EPA, the state, local agency, third party, etc.); 

(3) who the intended IC will effect and how; (4) the level of sophistication of the party implementing the 

cleanup and those remaining on the property; (5) the expected property use (likelihood of redevelopment 

and/or resale); and (6) the degree of cooperation exhibited by the parties to the cleanup. Since ICs can 

impact future development at sites, it is important to work cooperatively to determine the appropriate mix 

of ICs. The objective is not to use as many layers of ICs as possible, but rather to strike a balance that 

gives the regulators the certainty that the site remedy will be protective over time while maximizing the 

site's future beneficial use. 

At many large lead sites, GIS systems are used to track the cleanup status of properties located on 

the site. The tracking system facilitates the monitoring of ICs and the maintenance of the remedy. GIS 

systems can be operated by local governments, state governments or PRPs. 

6.8 CLEAN-UP DOCUMENTATION 

Upon confirmation that initial yard sampling indicates a given residential yard does not exceed 

the lead clean-up level for the site, or upon the completion of the cleanup of a residential yard, a letter 

(“clean” letter) should be sent to the property owner documenting that EPA considers the lead level in the 

yard to be below the level of human health concern. Prior to issuing a “clean” letter, a property closeout 

form should be signed by the property owner, which documents the owner is satisfied with the 

remediation of the property. Examples of property closeout forms are proved in Appendix G. Any areas 

that are not cleaned up via the owner’s request, such as gardens, should be noted in the “clean” letter. If 

contamination is not cleaned up to depth, this fact, along with protections (i.e., barriers/markers) that are 

put in place, should be stated in the “clean” letter. The “clean” letter provides official documentation to 

the property owner for use in future property sales or transactions. Sample “clean” letters are provided in 

Appendix H. 
62 

6.9 ENFORCEMENT 

The project manager should strive to characterize all residences within the identified zone of 

contamination, and achieve cleanup at all residences where lead concentrations exceed the clean-up level. 

At all residential clean-up sites, a percentage of homeowners typically will refuse to grant access to EPA 

for sampling and/or for cleanup. In order to meet remedial goals of protecting a community, all 

residences suspected of being located within a zone of contamination should be sampled. It is important 

to work with the landowner and be sensitive to a landowner’s concerns regarding property access. The 

project manager should educate the landowner of the dangers that lead contamination may pose. If a 

landowner still refuses to grant access, the Region should consider issuing an access order for sampling 

(EPA, 1990c). 

An owner of residential property on a Superfund site may be potentially liable under 

CERCLA § 107(a)(1). However, EPA, as an exercise of enforcement discretion, generally will not take 

CERCLA enforcement actions against an owner of residential property unless the residential 

homeowner’s activities lead to a release or threat of release of hazardous substances resulting in the 

taking of a response action at a site. (See Policy Towards Owners of Residential Property at Superfund 

Sites (July 3, 1991)). Additionally, under CERCLA a residential property owner may qualify for 

protection from CERCLA liability as a contiguous property owner, bona fide prospective purchaser, or 

innocent landowner. Under both the statute and EPA’s policy, a residential property owner is expected to 

cooperate with EPA and the person taking the response action. This obligation includes providing access 

and information as requested, agreeing to comply with land use restrictions relied on in connection with 

the remedy, and not impeding the effectiveness the effectiveness or integrity of institutional controls. 

(See CERCLA §§ 101(40)(B)-(H), 107(q)(1)(a), 101(35)(A)-(B)). The project manager should work to 

inform and educate an owner of EPA’s expectations for cooperation in connection with the remedy. If 

necessary, to meet the commitments of the remedy, EPA should consider taking appropriate steps, such as 

issuing a UAO, to secure the cooperation of an uncooperative landowner. 
If some properties are not 

addressed under site response actions 

(e.g., current homeowners with no young 

children or women of child-bearing age), 

then consideration should be given to 

establishing a trust fund (under state 

authority or local law), to be administered 

by a local government, for the cleanup of 

the property at a future date, when the 

property is transferred (e.g., by sale) to a 

new owner (see text box). Buyers of 

contaminated properties could make use 

of the fund to have the property cleaned 

up at their discretion. 

63 

Example Trust Fund – At the Bunker Hill Superfund Site, 

a number of property owners refused to have their 

residential yards cleaned up. Without any obvious need 

to cleanup the property right away, e.g. an unpaved, 

contaminated driveway that threatens to recontaminate 

the neighborhood or a child living at the residence or next 

door, the PRPs for the site were willing to give the State 

funds to set aside in an interest bearing account to clean 

up the properties in the future, when the property changes 

hands. Property status is then monitored by the local 

Health District as part of the institutional controls 

program. The State then manages the funds to ensure 

maximum interest accrual in an irrevocable trust and 

disbursement according to the limitations set up in the 

trust -- for residential property cleanup. Cleanup then 

occurs under State oversight at the time new owners buy 

the property thereby ensuring families with children that 

move into the community are protected. 

In the case of rental properties, EPA should order access for cleanup by UAO to all owners of 

contaminated rental property who refuse access. To ensure the protection of occupants, enforcement of 

the UAO may be necessary to clean up all rental properties with contamination greater than the clean-up 

level. 
64 

7.0 FIVE-YEAR REVIEW 

Five-Year Review – Pursuant to section 121 

of CERCLA and the NCP, remedial actions 

which result in any hazardous substances, 

pollutants, or contaminants remaining at the 

site above levels that allow for unlimited use 

and unrestricted exposure need to be reviewed 

every five years to ensure protection of human 

health and the environment. 

CERCLA §121(c) requires an assessment of 

certain remedial actions every five years on sites 

where contamination has been left on site (EPA, 

2000a). Guidance for conducting five-year reviews 

has been issued (EPA, 2001h). The purpose of a 

five-year review is to evaluate the performance of a 

remedy to determine if the remedy continues to be 

protective of human health and the environment. 

Typically, at large lead sites, such as mining and smelting sites, the volume and areal extent of 

contamination is such that total removal of all contamination above the health-based risk level is 

economically impractical. Contaminated wastes are generally left on site and covered with soil. The 

remedy for these types of sites typically includes some type of IC to address residual or encapsulated 

contamination. A five-year review can determine whether the remedy is stable (i.e., soil covers are 

undisturbed, and clean areas are not being recontaminated from sources remaining on the site). The 

review should also assess the ICs that were established for residual source control to determine their 

effectiveness in protecting human health. As described below, the five-year reviews at large lead sites 

may involve the collection and evaluation of substantial quantities of data and require significant up-front 

planning. Much of the following discussion may not apply to small sites. 

At many sites, an exposure study has been performed prior to any clean-up activities to determine 

blood lead concentrations of children in the community. A follow-up exposure study of residents should 

be conducted during the five-year review to determine if the concentrations have decreased below levels 

of concern. If the blood lead concentrations have not decreased to acceptable levels, additional 

environmental studies and individualized, follow-up exposure investigations should be conducted to 

determine the pathways of exposure that may need to be addressed. Long-term exposure studies can be 

very useful in understanding exposure trends at a site. They also can be useful to ensure that no pathways 

of exposure have been missed and to help identify areas of the site that have been recontaminated. In this 

manner, the project manager can use health data as a means to “double check” the effectiveness of the 

remedy and to corroborate environmental data. However, blood lead data from limited sampling should 

not be used as the only metric for gauging the success of a remedy, even if it can be used to identify 

specific problems. The project manager should coordinate with ATSDR and the local health district with 

respect to planning and funding such a program. 

The five-year review should include resampling at a percentage of each type of property that was 

remediated during the clean-up actions. A baseline level of resampling should be designed to achieve a 
65 

pre-specified level of statistical significance and power. This sampling should assess the potential for 

recontamination that may be occurring, and may help identify any pathways that may have been missed 

during remediation. Any sampling that indicates widespread or clusters of soil levels above clean backfill 

concentrations should be monitored over time to determine if an upward trend exists that may jeopardize 

the remedy. 

Additionally, some level of house dust sampling should occur to determine if levels are rising or 

falling. House dust, being a primary exposure pathway, should be used as one indicator of remedy 

effectiveness and also used to detect the presence of recontamination. Lead concentrations in house dust 

levels often correlate to interior LBP, which is not usually addressed by Superfund (Appendix B). 

Therefore, interior paint sampling should also be conducted as a component of the risk assessment to aid 

in determining the source of the lead loading to dust. 

At large lead sites, remedy protectiveness issues will often relate to the implementation and 

management of ICs and recontamination of areas previously cleaned. The five-year review should 

evaluate the effectiveness of the site ICs and recommend corrections to address any deficiencies that are 

identified. In order for a five-year review to be effective at sites where ICs are a component in ensuring 

the effectiveness of the remedy, there should be: (1) clear documentation of the specific type of ICs that 

were to be implemented, and (2) accurate and complete tracking of subsequent activities and changes in 

property use following completion of the Superfund remedy. 

The following are possible deficiencies for several types of commonly-used ICs and other control 

measures taken to ensure the protectiveness of the remedy:

C HEPA vacuum loan program not being broadly used.

C Information on interior home cleaning not being widely distributed.

C Lack of access control along rights-of-way, and in unremediated areas.

C Inadequate decontamination of vehicles leaving areas of existing contamination.

C Erosion of unremediated areas onto remediated properties.

C Lack of or inadequate disposal area for snow (that contains contaminated soil).

C Lack of drainage infrastructure and maintenance by local entities.

C Uncontrolled utility excavation in areas with contamination at depth.

C Inadequate road maintenance in areas where contamination exists at depth.

C Inadequate disposal capacity to handle IC-generated wastes.

C Discontinuation of, or diminishing, health education program.

C Decrease of blood lead monitoring.

C Complicated/unfounded ICs and/or change in local government acceptance of ICs.
66 

8.0 FEDERAL FACILITIES 

The purpose of this section includes the following: (1) to provide direction to EPA federal facility 

project managers who oversee response actions involving lead contamination of soils from LBP in 

residential areas of federal facilities; (2) to build and elaborate on the joint March 1999 EPA and DOD 

Principles Memorandum (DOD/EPA, 1999a) and the December 1999 Lead-Based Paint Interim Field 

Guide (DOD/EPA, 1999b); (3) to address situations where the DOD service component will conduct the 

response actions and the regulatory agencies will provide oversight; and (4) to address the unique 

considerations that arise when the federal government transfers LBP-contaminated property that is subject 

to CERCLA §120(h) to non-federal parties (e.g., states, local governments, local reuse authorities 

[LRAs], and private entities, etc.). 

While existing policy, guidance, and directives on lead contamination are applicable at federal 

facilities, property transfer issues present unique requirements that necessitate this section. This section 

applies to properties that will be transferred for residential use which are contaminated with lead due to 

LBP or to properties/parcels whose use would expose sensitive populations (e.g., infants, toddlers, small 

children, nursing mothers) to unacceptable exposure to lead after the properties are transferred to nonFederal entities. 

Beginning in 1995, EPA and DOD began to address policy differences on the clean-up levels for 

lead in soils from LBP. In 1998, Sherri Goodman, then Deputy Under Secretary of Defense 

(Environmental Security) and Tim Fields, Assistant Administrator for OSWER, reached agreement on the 

management of LBP at residential and non-residential areas at BRAC properties. In March 1999, this 

agreement was formalized as the ‘Principles Memorandum’ (DOD/EPA, 1999a). The Principles 

Memorandum stated that for residential areas located on BRAC sites, Title X procedures provide an 

efficient, effective, and legally adequate framework for addressing LBP in residential areas, and that as a 

matter of policy, CERCLA/RCRA would apply in limited circumstances. EPA and DOD agreed that 

generally for residential areas that were being transferred, Title X regulations would apply and that 

CERCLA/RCRA would apply in limited circumstances. Residential real property is defined by Title X as 

real property on which there is situated one or more residential dwellings used or occupied, in whole or in 

part, as the home or residence of one or more persons. It is important to note that Title X defines 

residential property differently than the Handbook. 

For federal property transfers subject to CERCLA where there is a concern about lead 

contamination to soils from LBP, EPA Regions, where they are involved, will need to make a 

determination whether the property meets the requirements of CERCLA §120(h)(3). This section of 

CERCLA outlines deed requirements for transferring property and requires covenants indicating that all 
67 

remedial actions have been taken at the site. Federal property contaminated with lead from LBP should 

be evaluated based on its use, or its intended reuse, before the property has been sold or transferred to 

another private entity. EPA’s evaluation of the transfer should be based on an evaluation of lead 

contamination by either relying on existing and available information gathered through a combination of 

file searches and a review of existing data and/or a site risk assessment, which may require the collection 

and analysis of additional soil samples. 

The soil sampling design should be specific to the site. The actual or suspected presence of lead 

contamination in soil does not necessarily require sampling. Factors to be considered before designing a 

sampling plan include, but are not limited to, the nature of the facility’s operations, its operating records, 

the age of the buildings/structures under consideration, the maintenance schedule for the 

buildings/structure, visual inspection, and future use. Based on these factors, it may be reasonable to 

conclude that the potential risks posed by lead may be acceptable and no further evaluation is needed. It 

may also be important to consider the ultimate disposition of the property once it leaves federal control. 

For example, the structures may be scheduled to be demolished, so that the abatement of the hazard may 

be addressed in the demolition process and may negate the need to conduct clean-up activities. 

The EPA project manager and, as appropriate, an EPA risk assessor should work with their 

federal, state, and local government counterparts to develop a sampling design, where required, that 

would be scientifically appropriate, minimize the cost of sampling, and provide the information required 

for risk management decisions. As appropriate, the local redevelopment or reuse authority should be 

consulted as well. Information from the sampling effort could result in different outcomes: a “no further 

action decision”, a conclusion that more extensive sampling is necessary, or, in some cases, a response 

action. All of these potential outcomes should be discussed with the lead federal agency, and others as 

appropriate, prior to the initiation of sampling. 

If there is insufficient knowledge to make a conclusion about the risk at the site or if the initial 

sample results indicate an unacceptable risk from lead, data may be collected by a focused sampling of an 

environmental media to develop an improved understanding of the risk that may be posed by the lead 

exposure. It may be appropriate to determine that after visual inspection and/or focused sampling, and 

after consultation with an EPA risk assessor, the lead from the area may not pose a significant risk that 

requires further evaluation. Risk evaluations should be based upon a number of factors including the 

reasonably anticipated future land use, exposure potential, ICs proposed or in place, and bioavailability. 

The Handbook user is encouraged to obtain detailed information on ICs for federal facilities in the 

document “Institutional Controls and Transfer of Real Property under CERCLA Section 120(h)3(A), (B), 

or (C)” (EPA, 2000g). 
68 

If the property has been used or will be reused as residential real property after transfer, the EPA 

project manager should verify that the lead federal agency has followed the Title X regulations and 

policies regarding sampling and risk assessment. As a guide to assist site managers in understanding Title 

X regulations and policies, EPA and DOD jointly issued a Field Guide (DOD/EPA, 1999b) that is used 

by EPA and DOD field personnel when assessing hazards due to LBP. The field guide contains 

information on performing a Title X paint inspection and risk assessment and outlines the requirements 

for abating soil contaminated by LBP 

The Title X program, through the implementation of the new Title IV of TSCA, establishes 

certification programs and work practice standards to regulate LBP hazard evaluation and abatement in 

target housing and child-occupied facilities. There are two types of evaluations covered by Title X. The 

first evaluation is a paint inspection that includes a surface-by-surface inspection to determine the 

presence of LBP. All painted surfaces with distinct painting histories are sampled. Usually the paint 

inspection is done by a combination of portable XRF devices and paint chip sampling. 

The second evaluation is a risk assessment to determine if LBP hazards exist. A risk assessment 

includes taking samples of all deteriorating paint, dust, and soil. The final report recommends methods to 

deal with all LBP hazards that were found, which could include interim controls or abatement. A 

comprehensive evaluation consists of a combination of a paint inspection and risk assessment. Paint 

inspections and risk assessment conducted in accordance with Title X must be performed by certified 

personnel. All results, whether positive or negative, must be disclosed at the time of sale or rental. 

The final TSCA 403 regulation (EPA/HUD, 2001), defines a soil-lead hazard as bare soil on 

residential real property, or on property of a child-occupied facility, that contains concentrations of lead 

equal to or exceeding 400 ppm in the play area or an average of 1,200 ppm in the rest of the yard. EPA 

and DOD have agreed that as a matter of policy, for bare soil with lead concentration between 400 ppm 

and 1,200 ppm, the Service, in consultation with the EPA, has the option of abatement or interim controls. 

Based on the final HUD 1012/1013 regulations (24 CFR Part 35) (HUD, 2001), federal agencies can 

transfer the control and abatement requirements to the purchaser, but by law the federal agency is 

responsible for performing the LBP inspection and risk assessment and must assure that through 

contractual mechanisms, the purchaser has performed the abatement of the soil in accordance with 

Title X. 
69 

In cases where the EPA project 

manager makes a determination that actions 

taken to address LBP hazards are sufficient 

(following the requirements outlined in the 

Field Guide), EPA should agree with the 

federal agency on the transfer documents and 

the covenant that all remedial action necessary 

to protect human health and the environment 

with respect to any such substances remaining 

on the property has been taken before the date 

Finding of Suitability to Transfer (FOST) – A 

process that has been established to identify 

and prepare property for transfer by deed. 

Such transfers are usually undertaken at a 

property where environmental response is not 

needed or has been taken. However, under 

certain conditions, new authority now permits 

earlier transfer. The FOST process also looks 

at the compatibility of an anticipated reuse 

with completed restoration activities and 

identifies restrictions necessary to protect 

human health and the environment. 

of such transfer . In the case of BRAC sites, the EPA project manager can agree on the Findings of 

Suitability to Transfer (FOST) or Findings of Suitability to Lease (FOSL) language, and/or the operating 

properly and successfully (OPS) determination as required by CERCLA. When an EPA project manager 

Finding of Suitability to Lease (FOSL) – A 

process that has been established for leasing 

of property that cannot be transferred by deed 

because environmental restoration activities 

are still ongoing. The FOSL process also 

looks at the compatibility of a proposed reuse 

with ongoing restoration activities and 

identifies restrictions necessary to protect 

human health and the environment and 

prevent interference with the cleanup. 

has unresolved questions as to whether actions at 

residential areas meet the requirements of 

CERCLA, she/he should raise these issues to the 

federal agency and provide an opportunity for 

response. In the case of BRAC sites, it is proper 

to highlight these concerns in EPA’s comments 

on the FOST/FOSL. Efforts should be made to 

determine that the purchaser is fully aware that 

EPA has questions about the condition of the 

property. 
70 

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September 14. 2001. 
A-1 

APPENDIX A

TITLE X AND EPA’S TOXIC SUBSTANCES

CONTROL ACT (TSCA) TITLE IV LEAD PROGRAM 
A-2 

TITLE X AND EPA’S TOXIC SUBSTANCES CONTROL ACT (TSCA) TITLE IV LEAD PROGRAM 

Background 

The Housing and Community Development Act of 1992 (PL102-550) contained Title X the 

“Residential Lead-Based Paint Hazard Reduction Act of 1992” (HUD, 1992). Even though this was a 

U.S. Department of Housing and Urban Development (HUD) authorization bill, it established a series of 

requirements for EPA. Title X includes a new Title IV of the Toxics Substances Control Act (TSCA). 

The sections that address EPA alone have section numbers in the four hundred (400) series, such as 

Section 403, Health Based Standards, whereas the HUD portions have numbers in the one thousand 

(1000) series, such as Section 1015, Task Force. There is one section, Section 1018, that Congress 

required both HUD and EPA to jointly issue a rule on disclosure. 

Overview 

Title X addresses LBP and LBP hazards and requires EPA and HUD to issue regulations to 

address those items. Title X’s emphasis is on actual hazards such as deteriorating paint, lead in dust, or 

lead in soil versus potential hazards such as intact paint. Generally, Title X does not mandate inspections, 

risk assessments, abatements of LBP, or LBP hazards. The exceptions are HUD program related actions 

(Section 1012) or when a federal agency disposes of a property that will be used for residential purposes 

(Section 1013). However, if you choose to do an inspection, risk assessment, or abatement, Title X 

establishes certification requirements and work practice standards that must be followed. Title X requires 

disclosure at the time of sale or rental (Section 1018) and the provision of a brochure Protect Your Family 

from Lead in Your Home (EPA, 1999a), before rehabilitation (Section 406b). EPA may authorize state 

programs to operate in lieu of the federal program for the 400 series regulations but not Section 1018. 

See Appendix A for a full discussion of Title X. 

Scope of Title X 

Title X contains specific classes of structures that it regulates. The first category is “target 

housing”, which is defined as “...any housing constructed prior to 1978 except housing for the elderly or 

persons with disabilities (unless any child who is less than 6 years of age resides or is expected to reside 

in such housing for the elderly or persons with disabilities) or any 0-bedroom dwelling.” 

The second category is “child occupied facilities”, which are defined as “... a building or a 

portion of a building, constructed prior to 1978, visited regularly by the same child, 6 years of age or 

under, on at least two different days within any week (Sunday through Saturday period), provided that 

each day’s visit lasts at least 3 hours and the combined weekly visit lasts at least 6 hours, and the 

combined annual visits last at least 60 hours. Child-occupied facilities may include, but are not limited 

to, day-care centers, preschools and kindergarten classrooms” (EPA, 2001a). 

As of December 2001 target housing and child occupied facilities are the only classes of 

structures for which EPA has issued final regulations. 

CERCLA 121(e)(1) exempts any response action conducted entirely on-site from having to 

obtain a federal, state, or local permit, where the action is carried out under §121. In general, 

on-site actions need to comply only with the substantive aspects of ARARs and not with the 

corresponding administrative requirements. Therefore, the administrative requirements laid out under 

TSCA 402 and 403 are not considered ARARs for actions conducted entirely on-site. 
A-3 

More Information 

Section 405 requires EPA to establish a Hot Line and Clearing House for lead. This has 

been done and the National Lead Information Center’s toll free number is 1-(800)-424-LEAD. 

Additionally the EPA web site at www.epa.gov/lead has all the rules, fact sheets, and guidance documents 

that the EPA Office of Pollution Prevention and Toxics has developed. 

Description of the Sections of Title X 

Title X Final Rules in Effect for ONLY Target Housing: 

Section 1012. This section establishes the requirements for those who get assistance or mortgage 

insurance from HUD. The requirements are HUD program specific, but only pertain to those who are 

involved with a particular HUD program. 

Section 1013. This section establishes the requirements for federal agencies that dispose of target 

housing that will be used for residential purposes. 

Section 1018. Section 1018 requires that sellers and landlords disclose known LBP and LBP 

hazards and provide available reports to buyers and renters. Sellers and landlords must also provide a 

copy of Protect Your Family from Lead in Your Home (EPA, 1999a). 

This is a joint rule between EPA and HUD. Section 1018 does not include “child occupied 

facilities”; EPA developed the concept of “child occupied facilities” under TSCA Title IV, the term is 

only in effect for TSCA four hundred (400) series rules. 

TSCA Final Rules in Effect for ONLY Target Housing and Child Occupied Facilities: 

Section 402/404 State Certification Programs establishes a nationally consistent federal Program 

for the certification of individuals and firms engaged in training, paint inspections, risk assessments, and 

certification of abatement workers, supervisors and training providers. There are two aspects of the 

program. States and tribes are encouraged to establish a program that as a whole, is at least as protective 

as EPA’s federal program. The state programs can be more protective. When a state program is 

approved, it becomes the federal program in that state. 

If the state or tribe does not establish an acceptable certification program, EPA operates the 

national program in that state. Much of the work is done in the EPA Regional Office. As of December 

2001, 39 states, the District of Columbia, and 2 tribes have EPA authorized programs. Two states with 

large populations, which do not have authorized programs, are New York and Florida. 

Section 403 establishes hazard standards for lead in paint, dust, and soil. Lead-based paint is a 

hazard if (1) it is deteriorated; (2) it is present on a friction surface that is subject to abrasion and the dustlead levels on the nearest horizontal surface are equal to or greater than the applicable dust hazard 

standard; or (3) it is present on any chewable surface on which there is evidence of teeth marks. (Leadbased paint is statutorily defined as paint containing 1.0 milligram or more lead per square centimeter or 

0.5% or more lead by weight.) Dust is a hazard if it contains 40 micrograms or more lead per square foot 

on floors or 250 micrograms or more lead per square foot on window sills. Soil is a hazard if it contains 

400 parts per million or more in play areas or 1,200 parts per million or more in the rest of the yard. 

This regulation also established the following clearance levels for interior dust: 40 micrograms 

lead per square foot for floors, 250 micrograms lead per square foot for window sills, and 

400 micrograms lead per square foot for window troughs. 
A-4 

EPA’s Section 403 rule was intended to prioritize risks as opposed to being inclusive of 

situations in which risks of concern exist. Per the rule preamble, “The hazard standard in this TSCA rule 

was intended as a ‘‘worst first’’ level that will aid in setting priorities to address the greatest lead risks 

promptly at residential and child-occupied facilities affected by lead-based paint” (EPA, 2001a). While 

identification of lead hazards (as defined under TSCA) is a necessary part of the facility reuse process, a 

minimal approach that would insure only that the letter of the hazard standards are met may not protect 

against some important risks. 

Section 405 establishes standards of environmental sampling laboratories. The National Lead 

Laboratory Accreditation Program (NLLAP) is administered by the American Industrial Hygiene 

Association and the American Association for Laboratory Accreditation. All laboratory samples must be 

analyzed by an NLLAP accredited laboratory. 

Section 406b requires that the pamphlet Protect Your Family from Lead in Your Home (EPA, 

1999a) be distributed no more than 60 days before a renovation in the home. 

TSCA Rules Being Developed 

Section 402. Renovation and remodeling requirements for target housing and child occupied 

facilities are being drafted as a proposed rule. Requirements for bridges and structures constructed prior 

to 1978 are being drafted for re-proposal. Both of these could include training, certification, and work 

practice standards. 

Lead-based Paint Debris. This rule was not required by Title X, but the need was clearly there 

to treat portions of the debris from lead-based activities differently than the RCRA requirements. There 

are two categories of waste discussed. First is the paint chips and dust, sludges and filtercakes, wash 

water and contaminated and decontaminated protective clothing equipment that would continue to be 

subject to all the requirements of RCRA. Second is the “lead-based paint architectural component 

debris”, which would be exempt from the Toxicity Characteristics rule including Toxicity Characteristic 

Leaching Procedure (TCLP) testing for lead only. This would allow disposal of these components at 

construction-demolition (CD) landfills. 

Although the Pb Debris Rule is still being developed, in the interim, EPA has issued a 

Memorandum that "Regulatory Status of Waste Generated by Contractors and Residents from 

Lead-Based Paint Activities Conducted in Households" - signed July 31, 2000. This memo clarifies 

the regulatory status of waste generated as a result of LBP activities (including abatement, renovation 

activities, and remodeling) in homes and other residences. This memo explains why LBP generated by 

contractors in households is "household waste" and thus excluded from the RCRA Subtitle C hazardous 

waste regulations. The household exclusion applies only to waste generated by either residents or 

contractors conducting LBP activities in residents. As a result, LBP waste from residences can be 

discarded in a municipal solid waste landfill or a municipal solid waste combustor. 
B-1 

APPENDIX B

1998 OSWER Directive 9200.4-27P (‘Clarification’)
B-2 

9200.4-27 

EPA/540/F-98/030 

PB98-963244 

OSWER Directive # 9200.4-27P 

MEMORANDUM 

SUBJECT: Clarification to the 1994 Revised Interim Soil Lead Guidance for CERCLA Sites and 

RCRA Corrective Action Facilities 

FROM: Timothy Fields, Jr. 

Acting Assistant Administrator 

TO: Regional Administrators I-X 

PURPOSE 

This directive clarifies the existing 1994 Revised Interim Soil Lead Guidance for CERCLA Sites and 

RCRA Corrective Action Facilities, OSWER Directive 9355.4-12. Specifically, this directive clarifies 

OSWER’s policy on (1) using EPA’s Science Advisory Board (SAB) reviewed Integrated Exposure 

Uptake Biokinetic Model (IEUBK) and blood lead studies, (2) determining the geographic area to use in 

evaluating human exposure to lead contamination (“exposure units”), (3) addressing multimedia lead 

contamination and (4) determining appropriate response actions at lead sites. The purpose for clarifying 

the existing 1994 directive is to promote national consistency in decision-making at CERCLA and RCRA 

lead sites across the country. 

BACKGROUND 

OSWER Directive 9355.4-12, issued on July 14, 1994 established OSWER’s current approach to 

addressing lead in soil at CERCLA and RCRA sites. The existing directive established a streamlined 

approach for determining protective levels for lead in soil at CERCLA sites and RCRA facilities as 

follows: 

• It recommends a 400 ppm screening level for lead in soil at residential properties; 

• It describes how to develop site-specific preliminary remediation goals (PRGs) at CERCLA sites 

and media cleanup standards at RCRA Corrective Action facilities for residential land use; and, 

• It describes a strategy for management of lead contamination at CERCLA sites and RCRA 

Corrective Action facilities that have multiple sources of lead. 

The existing interim directive provides direction regarding risk assessment and risk management 

approaches for addressing soil lead contaminated sites. The OSWER directive states that, “ ... 

implementation of this guidance is expected to provide more consistent decisions across the country ...” 

However, since that directive was released, OSWER determined that clarification of the guidance is 

needed. Key areas being clarified by issuance of this directive include: (1) using the IEUBK model and 

blood lead studies, (2) determining exposure units to be considered in evaluating risk and developing risk 

management strategies, (3) addressing multimedia lead contamination and (4) determining appropriate 

response actions at residential lead sites. The existing directive provides the following guidance on these 

areas: 
B-3 

1. The OSWER directive recommends using the Integrated Exposure Uptake Biokinetic (IEUBK) 

Model for Lead in Children (Pub. # 9285.7-15-1, PB93-963510) for setting site-specific 

residential preliminary risk-based remediation goals (PRGs) at CERCLA sites and media cleanup 

standards (MCSs) at RCRA corrective actions Facilities. The directive states that the IEUBK 

model is the best tool currently available for predicting the potential blood lead levels of children 

exposed to lead in the environment. OSWER’s directive also recommends the evaluation of blood 

lead data, where available, and states that well-conducted blood lead studies provide useful 

information to site managers. The directive however recommends that “... blood lead data not be 

used alone to assess risk from lead exposure or to develop soil lead cleanup levels.” 

2. The directive describes OSWER’s risk reduction goal as “...generally, OSWER will attempt to 

limit exposure to soil lead levels such that a typical (or hypothetical) child or group of similarly 

exposed children would have an estimated risk of no more than 5% of exceeding a 10 :g/dl blood 

lead level.” The directive also states that “... EPA recommends that a soil lead concentration be 

determined so that a typical child or group of children exposed to lead at this level would have an 

estimated risk of no more than 5% of exceeding a blood lead of 10 :g/dl.” OSWER generally 

defines an exposure unit as a geographic area where exposures occur to the receptor of concern 

during the time of interest and believes that for a child or group of similarly exposed children, 

this is typically the individual residence and other areas where routine exposures are occurring. 

3. The directive recommends that risk managers assess the contribution of multiple environmental 

sources of lead to overall lead exposure (e.g., consideration of the importance of soil lead levels 

relative to lead from drinking water, paint, and household dust) which promotes development of 

risk reduction strategies that address all sources that contribute significantly to exposure. 

4. The OSWER directive states that the IEUBK model is not the only factor to be considered in 

establishing lead cleanup goals. Rather, the IEUBK model is the primary risk assessment tool 

available for evaluating lead risk and the results of the model are used to guide selection of 

appropriate risk management strategies for each site. 

Since the OSWER directive was issued in 1994, there has been a trend toward a more consistent approach 

to managing risk at residential lead sites, however, OSWER was interested in identifying areas requiring 

additional clarification to facilitate more effective implementation of the directive. As a first step in the 

process, meetings were held with various EPA Regions, States and local governments to discuss how the 

directive has been implemented nationally at lead sites since 1994. By participating in these meetings and 

by reviewing the decisions that are being made across the country, OSWER believed that clarification of 

certain aspects of the 1994 directive would be useful. 

All of the documents and guidance referenced in this directive are available through the National 

Technical Information Service (NTIS) at 703-605-6000 or could be downloaded electronically from: 

http//epa.gov/superfund/oerr/ini_prod/lead/prods.htm. 

OBJECTIVE 

At lead contaminated residential sites, OSWER seeks assurance that the health of the most susceptible 

population (children and women of child bearing age) is protected and promotes a program that 

proactively assesses and addresses risk. OSWER believes that predictive tools should be used to evaluate 

the risk of lead exposure, and that cleanup actions should be designed to address both current and 

potential future risk. 

While health studies, surveys, and monitoring can be valuable in identifying current exposures and 

promoting improved public health, they are not definitive tools in evaluating potential risk from exposure 

to environmental contaminants. In the case of lead exposure, blood lead monitoring programs can be of 

critical importance in identifying individuals experiencing potential negative health outcomes and 
B-4 

directing education and intervention resources to address those risks. However, CERCLA §121(b) 

requires EPA to select cleanup approaches that are protective of human health and the environment and 

that utilize permanent solutions to the maximum extent practicable. To comply with the requirements set 

forth in CERCLA §121(b), OSWER will generally require selection of cleanup programs that are 

proactive in mitigating risk and that do not simply rely on biological monitoring programs to determine if 

an exposure has already occurred. 

To meet these objectives, OSWER will seek actions that limit exposure to soil lead levels such that a 

typical child or group of similarly exposed children would have an estimated risk of no more than 5% of 

exceeding a 10 :g/dl blood lead level. If lead is predicted to pose a risk to the susceptible population, 

OSWER recommends that actions be taken to significantly minimize or eliminate this exposure to lead. 

The principles laid out in the four attached fact sheets (Appendix) support OSWER’s goals by 

encouraging appropriate assessment and response actions at CERCLA and RCRA lead sites across the 

country. 

This clarification directive emphasizes the following key messages regarding the four areas and 

encourages the users of this directive, be they EPA Regions, States, or other stakeholders, to adopt these 

principles in assessing and managing CERCLA and RCRA lead sites across the country. The critical 

elements of the attached papers are as follows: 

I. Using Blood Lead Studies and IEUBK Model at Lead Sites: 

OSWER emphasizes the use of the IEUBK Model for estimating risks for childhood lead exposure from a 

number of sources, such as soils, dust, air, water, and other sources to predict blood lead levels in children 

6 months to 84 (7 years) months old. The 1994 directive also recommended evaluation of available blood 

lead data and stated that data from a well-conducted blood lead study of children could provide useful 

information to site managers. In summary, OSWER’s clarification policy on the appropriate use of the 

IEUBK and blood lead studies is that: 

• OSWER recommends that the IEUBK model be used as the primary tool to generate risk-based 

soil cleanup levels at lead sites for current or future residential land use. If Regions propose an 

alternative method for generating cleanup levels, they are required to submit their approach to the 

national Lead Sites Consultation Group (LSCG)1

 for review and comment; 

• Response actions can be taken using IEUBK predictions alone; blood lead studies are not 

required; and 

• Blood lead studies and surveys are useful tools at lead sites and can be used to identify key sitespecific exposure pathways and to direct health professionals to individuals needing immediate 

assistance in minimizing lead exposure; however, OSWER recommends that blood lead studies 

not be used for establishing long-term remedial or non-time-critical removal cleanup levels at 

lead sites. 

II. Determining Exposure and Remediation Units at Lead Sites 

1

The Lead Sites Consultation Group (LSCG) is comprised of senior management representatives from the 

Waste Management Divisions in all 10 EPA regions along with senior representatives from the Office of Emergency 

and Remedial Response in EPA headquarters. The LSCG is supported by EPA’s Technical Review Workgroup 

(TRW) for lead and the national Lead Sites Workgroup (LSW). The TRW consists of key scientific experts in lead 

risk assessment from various EPA Regions, labs and headquarters. The LSW is comprised of senior Regional Project 

Managers from various Regions and key representatives from headquarters who are experienced in addressing lead 

threats at Superfund sites. 
B-5 

OSWER recommends that cleanup levels at lead sites be designed to reduce risk to a typical or

individual child receiving exposures at the residence to meet Agency guidelines (i.e., no

greaterthan a 5% chance of exceeding a 10 :g/dl blood lead level for a full-time child resident).

Therefore, it is recommended that risk assessments conducted at lead-contaminated residential

sites use the individual residence as the primary exposure unit of concern. This does not mean

that a risk assessment should be conducted for every yard, rather that the soil lead contamination data

from yards and other residential media (for example, interior dust and drinking water) should be input

into the IEUBK model to provide a preliminary remediation goal (PRG) for the residential setting. When

applicable, potential exposure to accessible site-related lead sources outside the residential setting should

also be evaluated to understand how these other potential exposures contribute to the overall risk to

children, and to suggest appropriate cleanup measures for those areas.

III. Addressing Multimedia Contamination at Lead Sites 

EPA generally has limited legal authority to use Superfund to address exposure from interior lead-based 

paint. As a policy matter, OSWER recommends that such exposures not be addressed through actual 

abatement activities. However, EPA Regions should promote addressing interior paint risks through 

actions by others (e.g., potentially responsible parties (PRPs), other government programs, etc.) as a 

component of an overall site management strategy. Because of other competing demands on the 

Superfund Trust Fund, OSWER recommends that EPA Regions avoid using the Superfund Trust Fund for 

removing exterior lead-based paint and soil contaminated from lead-based paint. Superfund dollars may 

however be used in limited circumstances to remediate exterior lead-based paint in order to protect the 

overall site remedy (i.e., to avoid re-contamination of soils that have been remediated) but generally only 

after determining that other funding sources are unavailable. As with interior lead-based paint abatement, 

EPA Regions should promote remediation of exterior lead-based paint by others, such as PRPs, local 

governments or individual homeowners. 

IV. Determining Appropriate Response Actions at Lead Sites 

In selecting site management strategies, it is OSWER’s preference to seek early risk reduction with a 

combination of engineering controls (actions which permanently remove or treat contaminants, or create 

reliable barriers to mitigate the risk of exposure) and non-engineering response actions. All potential lead 

sources should be identified in site assessment activities. Non-engineering response actions, such as 

education and health intervention programs, should be considered an integral part of early risk reduction 

efforts because of their potential to provide immediate health benefits. In addition, engineering controls 

should be implemented early at sites presenting the greatest risk to children and other susceptible 

subpopulations. 

As a given project progresses, OSWER’s goal should be to reduce the reliance on education and 

intervention programs to mitigate risk. The goal should be cleanup strategies that move away from 

reliance on long-term changes in community behavior to be protective since behavioral changes may be 

difficult to maintain over time. The actual remedy selected at each CERCLA site must be determined by 

application of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (55 FR 

8666- 8865, March 8, 1990) remedy selection criteria to site-specific circumstances. This approach also 

recognizes the NCP preference for permanent remedies and emphasizes selection of engineering over 

non-engineering remedies for long-term response actions. 

This directive clarifies OSWER’s policy on four key issue areas addressed in the 1994 OSWER soil lead 

directive in order to promote a nationally consistent decision-making process for assessing and managing 

risks associated with lead contaminated sites across the country. The policy presented in these specific 

issue areas supersedes all existing OSWER policy and directives on these subjects. No other aspects of 

the existing 1994 directive are affected. 
B-6 

IMPLEMENTATION 

The principles laid out in this directive (which includes the four attached factsheets) are meant to apply to 

all residential lead sites currently being evaluated through the CERCLA Remedial 

Investigation/Feasibility Study process and all future CERCLA Sites and RCRA Corrective Action 

Facilities contaminated with lead. The Regions will be required to submit their rationale for deviating 

from the policies laid out in this directive to the Lead Sites Consultation Group. This directive does not 

apply to previous remedy selection decisions. 

Attachments 

cc: Waste Management Policy Managers (Regions I-X) 

Stephen Luftig, OERR 

Elizabeth Cotsworth, OSW 

James Woolford, FFRRO 

Barry Breen, OSRE 

Larry Reed, OERR 

Tom Sheckells, OERR 

Murray Newton, OERR 

Betsy Shaw, OERR 

John Cunningham, OERR 

Paul Nadeau, OERR 

Bruce Means, OERR 

Earl Salo, OGC 

NOTICE: This document provides guidance to EPA staff. The document does not, however, 

substitute for EPA’s statutes or regulations, nor is it a regulation itself. Thus it cannot impose legallybinding requirements on EPA, states, or the regulated community, and may not apply to a particular 

situation based upon the circumstances. EPA may change this guidance in the future, as appropriate. 
B-7 

Factsheet: Using the IEUBK Model and Blood Lead Studies at Residential Lead Sites 

Question: What is OSWER’s policy on using the IEUBK model and blood lead studies in 

conducting risk assessments and setting cleanup standards at residential lead contamination sites? 

Answer: OSWER’s policy on using the IEUBK model and blood lead studies in conducting risk 

assessment and setting cleanup standards is as follows: 

A. Use of the IEUBK Model: 

1. The IEUBK model is a good predictor of potential long-term blood lead levels for children in 

residential settings. OSWER recommends that the IEUBK model be used as the primary tool to 

generate risk-based soil cleanup levels at lead sites for current or future residential land use. If 

Regions propose an alternative method for generating cleanup levels, they are required to submit 

their approach to the National Lead Sites Consultation Group (LSCG) for review and comment. 

2. Blood lead distributions predicted by the IEUBK model illustrate a plausible range of variability 

in children’s physiology, behavior, and household conditions. 

3. Response actions can be taken, and remedial goals developed, using IEUBK predictions alone. 

B. Use of Blood Lead Studies/Data: 

1. Blood lead studies, surveys, and monitoring are useful tools at lead sites and can be used to help 

identify key site-specific exposure pathways and direct health professionals to individuals 

needing immediate assistance in minimizing lead exposure. 

2. The utility of blood lead testing results and studies depends on how representative the 

information is of the population being evaluated, the design of the data collection, and the quality 

of the laboratory analysis. To this end, OSWER recommends that EPA Regions consult with 

ATSDR or CDC to assess or design studies according to their intended use. 

3. Many blood lead screening, monitoring, or testing programs differ from blood lead studies in that 

they do not attempt to identify risk factors for childhood exposure to lead sources. Although these 

programs may be extremely beneficial in identifying children with elevated blood lead levels and 

identifying candidates for referral to medical professionals for evaluation, they may not provide 

an accurate representation of community-wide exposure. 

4. Well-designed blood lead studies may be used to identify site specific factors and pathways to be 

considered in applying the IEUBK model at residential lead sites. However, OSWER 

recommends that blood lead studies not be used to determine future long-term risk where 

exposure conditions are expected to change over time; rather, they should be considered a 

snapshot of ongoing exposure under a specific set of circumstances (including community 

awareness and education) at a specific time. Long-term studies may be helpful in understanding 

exposure trends within a community and evaluating the effectiveness of cleanup strategies over 

time. 

C. IEUBK and Blood Lead Studies/Data: 

1. Blood lead data and IEUBK model predictions are expected to show a general concordance for 

most sites. However, some deviations between measured and predicted levels are expected. On 

some occasions, declines in blood lead levels have been observed in association with lead 

exposure-reduction and health education. However, long-term cleanup goals should be protective 
B-8 

in the absence of changes in community behavior as there is little evidence of the sustained 

effectiveness of these education/intervention programs over long periods of time. 

2. Where actual blood lead data varies significantly from IEUBK Model predictions, the model 

parameters should not automatically be changed. In such a case, the issue should be raised to the 

Lead Technical Review Workgroup (TRW) to further identify the source of those differences. 

Site work need not be put on hold while the issue is being reviewed by the TRW; the site 

manager should review other elements of the lead directive and the “Removal Actions at Lead 

Sites” guidance to determine appropriate interim actions to be taken at the site. 

The Regions will be required to submit their rationale for deviating from the policies laid out in this 

factsheet to the Lead Sites Consultation Group. 
B-9 

Factsheet: Determining Exposure and Remediation Units at Residential Lead Sites 

Question: How does OSWER define an exposure unit, and subsequently apply this definition in 

conducting risk assessment and risk management activities at residential lead sites? 

Answer: OSWER recognizes that defining and characterizing exposure unit(s) for a site is 

critically important in undertaking risk assessment activities and in designing protective cleanup 

strategies. An exposure unit is defined as a geographic area where exposures occur to the receptor of 

concern during the time of interest and that for a child, or group of similarly exposed children, this is 

typically the individual residence and other areas where chronic or ongoing exposures are occurring. 

Various approaches to characterizing and managing risks by exposure units have been examined by 

OSWER. OSWER recognizes that lead ingestion can also cause adverse health effects in adults and 

fetuses but believes that by adequately limiting lead exposures to young children at residential sites, these 

other receptors will generally be likewise protected from adverse health impacts. 

EPA’s goal is to protect human health and the environment under current and future exposure scenarios. 

At lead sites, OSWER wants to assure that children’s health is protected and promotes a program that 

proactively assesses risks rather than relying on biological monitoring to determine if an exposure has 

already occurred. OSWER emphasizes actions be taken at lead sites that will minimize or eliminate 

exposure of children to environmental lead contamination. 

To achieve the above stated goal, OSWER recommends characterizing exposure units as exposure 

potential at the individual residence as the primary unit of concern for evaluating potential risk at 

lead contaminated residential sites. This recognizes that there are children whose domain and activities 

occur principally within the confines of a particular residential property. For determining exposure 

potential (and ultimately developing protective cleanup levels) at the individual home, OSWER 

recommends the scenario to be evaluated (through use of the IEUBK Model) would be a young child in 

full-time residence. This approach helps achieve OSWER’s recommended health protection goal that an 

individual child or group of similarly exposed children would have <5% chance of exceeding a blood lead 

concentration of 10 :g/dl. In designing community wide cleanup strategies, it is essential that nonresidential areas (e.g., parks, day care facilities, playgrounds, etc.), where lead exposure may occur, also 

be characterized with respect to their contribution to soil-lead exposure, and appropriate cleanup actions 

implemented. 

OSWER recommends that risk management decisions for response to residential lead contamination sites 

focus on reducing risk at residences, but also recommends that response strategies be developed for other 

site locations (exposure units) where children receive exposure. Flexibility in determining appropriate 

response actions that provide protection at the individual residence should be considered in context of the 

NCP remedy selection criteria. The lead exposure issues are complex and OSWER recommends that EPA 

Regions try to communicate clearly the risk characterization and risk management decisions to the site 

residents. Affected communities must clearly understand the context of risk management decisions, how 

these decisions affect the health of their children, and how cleanup actions will influence the future 

growth and development of the community. 

The Regions will be required to submit their rationale for deviating from the policies laid out in this 

factsheet to the Lead Sites Consultation Group. 
B-10 

Factsheet: Addressing Multimedia Contamination at Residential Lead Sites 

Question: What is OSWER’s policy on addressing multimedia contamination at residential lead 

sites? 

Answer: OSWER recognizes that several sources of lead-contamination, including soil, ground 

water, airborne particulates, lead plumbing, interior dust, and interior and exterior lead-based paint may 

be present at Superfund sites where children are at risk or have documented lead exposure. These lead 

sources may contribute to elevated blood lead levels and may need to be evaluated in determining risks 

and cleanup actions at residential lead sites. However, there are limitations on the Agency’s statutory 

authority under CERCLA to abate some of these sources, such as indoor lead-based paint and lead 

plumbing because CERCLA responses may be taken only to releases or threatened releases into the 

environment (CERCLA §104 (a)(3) and (4)). 

When EPA’s resources, or authority to respond or to expend monies under Superfund is limited, OSWER 

recommends that EPA Regions identify and coordinate to the greatest extent possible with other 

authorities and funding sources (e.g., other federal agencies and state or local programs). EPA Regions 

should coordinate with these other authorities to design a comprehensive, cost-effective response strategy 

that addresses as many sources of lead as practicable. These strategies should include actions to respond 

to lead-based paint, interior dust, and lead plumbing, as well as ground water sources and leadcontaminated soil. 

Although OSWER will encourage that EPA Regions fully cooperate in the development of a 

comprehensive site management strategy, OSWER realizes that complete active cleanup of these other 

sources may be difficult to complete due to limited funding available to other authorities. Since complete 

cleanups of these sources is not guaranteed, and at most sites may be unlikely, OSWER recommends that 

the soil cleanup levels not be compromised. In other words, the soil cleanup levels should be calculated 

with the IEUBK model using existing pre-response action site specific data. This is due to the fact that 

soil cleanup levels at residential lead sites are generally established to protect individuals, from excess 

exposures to soils, and house dust attributable to those soils, and are not attributable to exposure to other 

sources such as interior lead paint which should be managed on a residence specific basis. Remediation of 

non-soil lead sources to mitigate overall lead exposure at individual residences should therefore not be 

used to modify site-wide soil lead cleanup levels. 

The recommendations provided below represent OSWER’s policy on addressing lead-contaminated 

media and/or sources for which EPA has limited or no authority to remediate. 

Interior Paint: EPA has limited legal authority to use Superfund to address exposure from interior leadbased paint. As a policy matter, OSWER recommends that such exposures not be addressed through 

actual abatement activities. However, EPA Regions should promote addressing interior paint risks 

through actions by others, such as HUD, local governments, or individual home owners as a component 

of an overall site management strategy. Any activities to clean up interior lead-based paint by PRPs or 

other parties should not result in an increase of the risk-based soil cleanup levels. 

Exterior Paint:Because of other competing demands on the Superfund Trust Fund, OSWER 

recommends that EPA Regions avoid using the Superfund Trust Fund for removing exterior lead-based 

paint and soil contaminated from lead-based paint. Superfund dollars may be used to respond to exterior 

lead-based paint for protecting the overall site remedy (i.e., to prevent re-contamination of soils that have 

been remediated) but only after determining that other funding sources are unavailable. Where other 

sources of funding are not available, EPA may utilize the CERCLA monies to remediate exterior leadbased paint on homes/buildings, around which soil contaminated by other sources has been cleaned up to 

prevent recontamination of the soil. The Superfund should not be used to remediate exterior lead-based 

paint where no soil cleanup has occurred. As with interior lead-based paint abatement, EPA Regions 
B-11 

should promote remediation of exterior lead-based paint by others, such as PRPs, local governments or 

individual homeowners. Cleanup activities of exterior paint conducted by PRPs or other parties should 

not result in an increase of the risk-based soil cleanup levels. 

Interior Dust: Lead contaminated interior dust can be derived from several sources, including interior 

paint, home owner hobbies, exterior soil, and other exterior sources. In many cases, it may be difficult to 

differentiate the source(s) for the lead contamination in the dust. In general, EPA Regions should refrain 

from using the Superfund Trust Fund to remediate interior dust. Because of the multi-source aspects of 

interior dust contamination, potential for recontamination, and the need for a continuing effort to manage 

interior dust exposure, OSWER recommends the use of an aggressive health education program to 

address interior dust exposure. Such programs, administered through the local health department (or other 

local agency), should be implemented in conjunction with actions to control the dust source. At a 

minimum, the program should include blood lead monitoring, and personal hygiene and good 

housekeeping education for the residents. OSWER believes that EPA Regions can also support the 

program by providing HEPA vacuums to the health agency for use in thoroughly cleaning home interiors. 

Lead Plumbing: Generally CERCLA does not provide for legal authority to respond to risks 

posed by lead plumbing within residential dwellings. It should be noted that the water purveyor is 

responsible for providing clean water to the residences. As with interior dust, OSWER recommends that 

EPA Regions coordinate with local agencies to establish a health education program to inform residents 

of the hazards associated with lead plumbing and how to protect themselves by regularly flushing, or 

preferably, replacing lead pipes. Soil cleanup levels should not be adjusted to account for possible 

remediation of lead plumbing. 
B-12 

Factsheet: Determining Appropriate Response Actions at Residential Lead Sites 

Question: What is OSWER’s position on the appropriate use of engineering and non-engineering

response actions in developing risk management strategies for lead sites?

Answer: One goal emphasized in the recent third round of Superfund Reforms is for EPA to take a

consistent approach in selecting and implementing both long- and short-term response actions at lead sites

in all regions. One obstacle to achieving this consistency has been differing degrees of reliance on nonengineering response actions in reducing risk.

Site management strategies at lead sites typically include a range of response actions. Alternatives range

from engineering controls that permanently remove or treat the contaminant source to non-engineering

response actions, such as educational programs and land use restrictions. This continuum represents the

range of response options available to risk managers. This position paper clarifies the relationship

between engineering and non-engineering response actions in developing site management strategies.

In selecting site management strategies, OSWER’s policy will be to seek early risk reduction with a

combination of engineering controls (actions which permanently remove or treat contaminants, or which

create reliable barriers to mitigate the risk of exposure) and non-engineering response actions. All

potential lead sources should be identified in site assessment activities. Non-engineering response actions,

such as education and health intervention programs, should be considered an integral part of early risk

reduction efforts due to their potential to provide immediate health benefits.2

 In addition, engineering

controls should be implemented early at sites presenting the greatest risk to children and other susceptible

subpopulations. Community concerns should receive a high priority in site decision-making; local support

is vital to the success of health intervention and education programs.

As the project progresses, OSWER's goal should be to reduce reliance on education and intervention

programs to mitigate risk. The goal should be cleanup strategies that move away from reliance on longterm changes in community behavior to be protective; behavioral changes

may be difficult to maintain over time. The actual remedy selected at each site must be determined by

application of the NCP remedy selection criteria to site-specific circumstances. However, this approach

recognizes the NCP preference for permanent remedies and emphasizes the use of engineering controls

for long-term response actions. This approach also recognizes that well-designed health intervention and

education programs, when combined with deed restrictions and/or other institutional controls, may be

appropriate for reducing future exposure potential and may supplement engineering controls.

In instances where Regions believe that the use of engineering controls is impracticable, and education,

health intervention, or institutional controls are proposed as the sole remedy, Regions will be required to

consult with the LSCG.

2

The actual effectiveness of health intervention and educational programs in reducing risk continues to be a 

subject of discussion. Anecdotal information suggests that such programs can provide short-term benefits in some 

populations. Rigorous statistical studies demonstrating the benefits of educational programs in preventing lead 

exposure are lacking. It is generally recognized that not all segments of the population will be influenced by such 

programs, and that long-term benefits are less certain. Local support for such programs is critical. The active (and 

long-term) participation of local and state public health agencies is needed in implementing institutional controls, 

including health intervention and education programs; without local implementation of such programs their success 

is uncertain. Additional research on the effectiveness of these programs is critical to consideration of their use in 

future cleanups. 
C-1 

APPENDIX C

Contacts and Software for Sampling Design
C-2

Table C-1 

Contacts and Software for Sample Planning Design 

Topic Contact(s) 

Sampling 

plan design/ 

Systematic 

Planning 

General support 

Dynamic Field Activities 

Software 

DEFT: Data Quality Objectives 

Decision Error Feasibility Trials 

FIELDS: Fully Integrated 

Environmental Decision Support 

Geo-EAS: Geostatistical 

Environmental Assessment 

Software 

EPA HQ Quality Staff 

Phone: (202) 564-6830 

FAX: (202) 565-2441 

E-mail: quality@epa.gov 

Internet: 

http://www.epa.gov/superfund/programs/dfa/ 

index.htm 

E-mail: quality@epa.gov 

Internet: 

http://www.ornl.gov/doe_oro/dqo/resdqo.htm 

Internet: 

http://www.epa.gov/region5fields/static/pages/ind 

ex.html 

E-mail: englund.evan@epa.gov 

Internet: http://www.ai-geostats.org/ 

E-mail: sada@tiem.utk.edu 

Internet: http://www.tiem.utk.edu/~sada/ 

E-mail: nell.cliff@pnl.gov 

Internet: http://dqo.pnl.gov/vsp/ 

SADA: Spatial Analysis Decision 

Assistance 

VSP: Visual Sample Plan 
D-1 

APPENDIX D

Examples of Property Access Agreement Forms
D-2 

CONSENT FOR ACCESS TO PROPERTY 

FOR SAMPLING 

Name: Daytime Phone Number: 

Address(es) of Property(ies): 

I consent to officers, employees, and authorized representatives of the United States 

Environmental Protection Agency (EPA) entering and having access to my property for the purpose of 

taking [DESCRIBE NUMBER OF SAMPLING LOCATIONS AND DEPTHS] which are necessary to 

implement the cleanup of lead contamination in the soil. 

This written permission is given by me voluntarily with knowledge of my right to refuse and 

without threats or promises of any kind. I understand that EPA or authorized representatives of EPA will 

contact me at least one week in advance before the soil samples are collected. This agreement is only for 

the purpose of soil sampling and no other work. 

Date 

G I grant 

access to my property 

G I do not grant 

access to my property 

Signature Signature 

G I would also like EPA to have a lead expert contact me to schedule a free inspection to identify 

potential lead hazards in my home and provide safety tips. 
D-3 

United States Environmental Protection Agency Region 6

1445 Ross Avenue, Suite 1200

Dallas, Texas 75202-2733

CONSENT FOR ENTRY AND ACCESS TO PROPERTY FOR SAMPLING

Description of property (including address) for which consent to access is granted: 

Example: XXXX Street, Texarkana, Arkansas, more particularly described as a 

lot measuring approximately 3,000 square feet, including a two-room wood 

structure of approximately 300 square feet 

Name of Signatory: _______________________________ 

Address: _________________________ 

_________________________ 

_________________________ Phone: (_____)______________ 

Relationship to property (e.g., owner, lessee, agent or employee of owner, etc.): 

I HEREBY CONSENT to officers, employees and parties authorized by the U.S. Environmental

Protection Agency (EPA), entering and having continued access to the property described above at

reasonable times for the following purposes (List the activities to be undertaken on the property):

Example:

! Sample collection including: (1) the gathering of soil from the outside area of the property; (2)

drawing water from the tap; and (3) vacuuming the inside area of any inhabitable structure in 

order to collect dust. 

! Taking photographs to record the sampling process. 

I realize that these actions are undertaken pursuant to EPA’s response and enforcement responsibilities 

under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 

U.S.C. Sections 9601-9675. This written permission is given by me voluntarily with the knowledge of 

my right to refuse and without threats or promises of any kind. 

This agreement expires on: ___________________ 

(Date) 

I HEREBY WARRANT that I have authority to make this access agreement. 

_________________________________ ____________________________________ 

Date Signature 

____________________________________ 

Print name 
D-4 

CONSENT FOR ACCESS TO PROPERTY 

FOR SAMPLING AND TO TAKE RESPONSE ACTION 

Name: Daytime Phone Number: 

Address(es) of Property(ies): 

I consent to officers, employees, and authorized representatives of the United States 

Environmental Protection Agency (EPA) entering and having access to my property for the purpose of 

sampling and taking a response action including: (1) preparing for and excavation of soil from my 

property; (2) backfilling the excavated area(s) with clean soil and/or backfill; and (3) restoring any grass 

or other vegetation or structures to their pre-excavation state. These activities are necessary to implement 

the cleanup of lead contamination in the soil. 

This written permission is given by me voluntarily with knowledge of my right to refuse and 

without threats or promises of any kind. I understand that EPA or authorized representatives of EPA will 

contact me approximately two weeks in advance before the removal of soil begins, to discuss the steps 

involved in the excavation and removal program and all measures EPA will take to restore my yard. I 

also understand that if there is any damage to structures such as sidewalks that is caused by the work 

conducted by EPA or authorized representatives of EPA, then EPA or authorized representatives of EPA 

shall repair such damage. 

Date 

G I grant G I do not grant 

access to my property access to my property 

Signature Signature 
D-5 

XXXX TRIBE OF OKLAHOMA 

PROPERTY ACCESS CONSENT AGREEMENT

FOR SAMPLING AND TO TAKE RESPONSE ACTION

The Property which is the subject of this agreement is described as follows: 

NE 1/4 SE 1/4, Section 6, Township 28 North, Range 24 East, Xxxx County, Oklahoma otherwise 

described as Beaver Springs Park and Tribal Office which includes the Pow Wow grounds (hereinafter 

the Property). 

THIS ____ DAY OF _______________, 1999, by authority of the Xxxx Tribal Business Committee, 

permission is hereby granted to officers, employees and parties authorized by the United States 

Environmental Protection Agency (EPA) entering and having continued access to the Property until 

4:30 pm (CST) on ___________________, to conduct the following work (hereinafter the work): 

(1) To perform necessary response actions (e.g., excavation of contaminated soil, backfilling with 

clean soil or gravel, and sodding or seeding) to address lead and other metals from mining waste 

contamination on the above-described lands in accordance with the EPA Record of Decision 

issued August 27, 1997; 

(2) To take necessary samples of environmental media to identify lead and other metals that may be a 

threat to public health or welfare or the environment. 

Nothing contained in this permit shall operate to delay or prevent a termination of Federal trust 

responsibilities with respect to the Property by the issuance of a fee patent or otherwise during the term of 

the work; however, such termination shall not serve to terminate the work. The Xxxx Tribal Business 

Committee shall notify EPA of any change in status or ownership of the Property. 

The Xxxx Tribal Business Committee realizes that the work will be undertaken pursuant to EPA’s 

Superfund authority under the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), 42 U.S.C. Sections 9601-9675. 

This written permission is given by the Xxxx Tribal Business Committee voluntarily with the knowledge 

of its right to refuse and without threats or promises of any kind. 

The Xxxx Tribal Business Committee is the property owner or a responsible representative of the 

property owner and I, Xx Xxxx, as Chairman of that Committee, warrant that I have authority to make 

this access agreement.

_________________________________

Xx Xxxx 

Xxxx Tribal Chairman

Xxxx Tribe of Oklahoma

_________________________________

U.S. Environmental Protection Agency

____________________________________ 

Date 

____________________________________ 

Date 
D-6 

CONSENT FOR ACCESS TO PROPERTY 

TO TAKE RESPONSE ACTION 

Name: Daytime Phone Number: 

Address(es) of Property(ies): 

I consent to officers, employees, and authorized representatives of the United States 

Environmental Protection Agency (EPA) entering and having access to my property for the purpose of 

taking a response action including: (1) preparing for and excavation of soil from my property; (2) 

backfilling the excavated area(s) with clean soil and/or backfill; and (3) restoring any grass or other 

vegetation or structures to their pre-excavation state. These activities are necessary to implement the 

cleanup of lead contamination in the soil. 

This written permission is given by me voluntarily with knowledge of my right to refuse and 

without threats or promises of any kind. I understand that EPA or authorized representatives of EPA will 

contact me approximately two weeks in advance before the removal of soil begins, to discuss the steps 

involved in the excavation and removal program and all measures EPA will take to restore my yard. I 

also understand that if there is any damage to structures such as sidewalks that is caused by the work 

conducted by EPA or authorized representatives of EPA, then EPA or authorized representatives of EPA 

shall repair such damage. 

Date 

G I grant G I do not grant 

access to my property access to my property 

Signature Signature 
E-1 

APPENDIX E

Example of Dust Abatement Access Form
E-2 

CONSENT FOR ACCESS TO PROPERTY 

Name: Daytime Phone Number: 

Address(es) of Property(ies): 

I hereby consent to grant officers, employees, contractors, sub-contractors and authorized representatives

of the United States Environmental Protection Agency (EPA) access to the interior of my home and/or

property for the purpose of interior dust abatement. The home dust abatement program being offered at

this time consists of vacuuming floors and walls with a special vacuuming system. This system is

portable and compact and easy to use. A team of bonded representatives will be providing the service at

no charge to the homeowner. 

Videotaping of the interior of the residence will be necessary to provide backup documentation in the

event of any claims. It will be necessary that someone remain at the residence for one or two days while

it is being vacuumed. This lead abatement program is offered only to homeowners who have or will grant

access to their property for the remediation of in their yards. These activities are necessary to interrupt

the movement of lead through soil dust, house dust, and paint dust.

If you want the process completed in your home and prefer to do it yourself, please note in the

appropriate space and arrangements will be made to schedule the loan of a HEPA-VAC unit to you. 

This written permission is given voluntarily with the knowledge of its right to refuse and without threats

or promises of any kind. I understand that , if any damage to my property results from these activities or

any work conducted by the USEPA or its authorized representatives, then the USEPA or its authorized

representatives shall repair or replace such damage.

Date

‘ I grant access to my property for Representatives of the EPA to video and vacuum.

‘ I wish to make arrangements to vacuum myself.

‘ I do not grant access to my property.

Signature

Please return as soon as possible for scheduling of work. If you should have any questions please contact

[LOCAL CONTACT NAME] at [PHONE NUMBER].
F-1 

APPENDIX F

Example of Property Inspection Checklist
F-2 

TAR CREEK PROJECT 

PROPERTY HOME INSPECTION CHECKLIST 

Address Date 

Property Group Number 

Home Interior Access (check one, see comments):

G Approved by Property Owner G Denied by Property Owner

Property (Yard) Access (check one, see comments):

G Approved by Property Owner G Denied by Property Owner

OK NA 

YARD AREA 

1. 

A. 

B. 

C. 

D. 

E. 

could cause ponding of water) 

F. 

2. 

A. ater Meter 

B. 

C. 

D. 

3. 

A. aged 

B. aged 

C. 

Lawn Area 

Location of Flower/Plant Boxes 

Soil (grade) next to house 

Shrubbery 

Trees 

Low areas near house (that 

Other: 

Utility 

W

Gas Meter 

Sewer Lines 

Other: 

Driveway 

Concrete cracked, dam

Blacktop cracked, dam

Uneven Settling 

PROBLEM/CONDITION 

D. Other: 
F-3

OK NA 

YARD AREA (cont.) 

4. 

A. 

B. 

C. 

D. issing 

E. Other 

5. 

A. Settlement cracks in walls 

B. 

damaged 

C. bs damaged, rotted 

D. 

E. 

6. 

(Above Ground) 

A. 

B. age 

C. 

7. 

(Below Ground) 

A. 

B. age 

C. 

8. Cellar 

A. aged 

B. 

Streetwalk & Walkways 

Concrete cracked, eroded 

Tripping hazards 

Tree roots cracking, lifting slab 

Sections m

Garage 

Concrete floor slab cracked, 

Door jam

Door hard to open, close 

Other: 

Swimming Pool 

Leakage 

Visible dam

Other: 

Swimming Pool 

Leakage 

Visible dam

Other 

Storm

Dam

Indication of Flooding 

PROBLEM/CONDITION 

C. Other: 
F-4

OK NA 

YARD AREA (cont.) 

9. 

A. aged circuit breaker panel 

box 

B. iring hanging outside 

C. aged electric meter 

D. 

EXTERIOR AREA 

10. 9 Brick 9 Siding 

A. 

cracking 

B. 

C. 

D. 

E. aged 

F. 

G. issing 

H. ites 

I. posite shingles worn, 

broken, missing 

J. indows damaged 

K. 

11. 

A. 

B. aged, 

patched 

C. ney broken, leaning 

D. ney & 

exterior wall 

E. ney, 

vents, walls 

Electrical Service 

Dam

W

Dam

Other: 

Brick bulging, spalling, 

Mortar loose, needs repointing 

Lintel needs repair 

Stucco bulging, cracking 

Siding dented, dam

Finish wearing off siding 

Siding loose, not level, m

Siding rotted, term

Com

W

Other: 

Roofing 

Age of covering 

Shingles worn, dam

Brick chim

Joint open between chim

Need flashing at chim

PROBLEM/CONDITION 
F-5

OK NA 

EXTERIOR AREA (cont.) 

F. 

G. 

H. aged, 

missing 

I. 

12. 

9 Yes 9 No 

A. 

damaged 

B. 

C. aged, 

patched 

D. 

E. wall 

F. 9 Yes 9 No 

G. 

deteriorated 

H. 

I. 

13. 

A. 

B. ortar loose 

C. 

D. 

E. 

14. 

A. aged 

B. 

C. eatherstripping 

D. rotted, missing 

Parapet wall leaning 

Roof sagging 

Metal flashing dam

Other: 

Gutters & Leaders 

Copper discolored, greenish, 

Galvanized rusted, patched 

Fascia board rotted, dam

Drain onto foundation wall 

Need to divert water from

Soffit venting 

Concrete slab cracked, 

Concrete slab/splash block need 

Other: 

Entrance Steps 

Concrete cracked 

Brick cracked, m

Structurally sound 

Handrail 

Other: 

Exterior Doors 

Dam

Opens/closes freely 

W

Trim

PROBLEM/CONDITION 
F-6

OK NA 

EXTERIOR AREA (cont.) 

E. bs rotted, damaged 

F. e separation from walls 

G. 

INTERIOR AREA 

15. 

A. /sills rotted 

B. 

C. 

E. e separation from walls 

F. 

16. 

A. 

B. 

C. 

D. ood, tiles on floor damaged 

E. 

F. 

G. 

H. 

I. alls have moisture damage 

J. 

17. s 

A. 

B. 

C. 

D. aged 

Jam

Fram

Other: 

Windows 

Trim

Broken glass 

Open freely 

Fram

Other: 

Kitchen 

Cracked walls, ceiling 

Loose nails, tape on drywall 

Soft, springy floors 

W

Faucet leaks 

Doors don’t close 

Cabinets don’t close 

Moisture in cabinets 

W

Other: 

Interior Room

Cracked walls, ceiling 

Loose nails, tape on drywall 

Soft, springy floor 

Carpeting water dam

PROBLEM/CONDITION 

E. Water stains near windows 
F-7

OK NA 

INTERIOR AREA (cont.) 

F. ildew on walls 

G. 

18. 

A. 

B. 

C. 

D. 

E. 

F. ater leaks at closet flange 

G. issing around tub 

H. aged, missing 

I. aged, missing 

J. 

K. ater stains on ceiling below 

bathroom 

L. 

M. ater stains on floor around hot 

water heater 

N. 

water heater 

O. 

19. 

A. 

B. e separation from walls 

C. 

20. 

A. 

Mold/m

Other: 

Toilet Facility 

Cracked tile, plaster on walls 

Cracked plaster on ceilings 

Loose tiles on walls, floors 

Loose nails, tape on drywall 

Toilet cracked 

W

Grout m

Shower pan dam

Shower door dam

Need new shower door 

W

Hot water heater tank corroded 

W

Moisture present around hot 

Other: 

Interior Doors 

Open freely 

Fram

Other: 

Attic 

Only if visual indicator 

PROBLEM/CONDITION 

B. Other: 
F-8

OK NA 

INTERIOR AREA (cont.) 

21. 

A. 

B. ent cracks at corners, 

walls 

C. all bulging inward 

D. ent/cellar 

E. 

F. 

22. 

A. 

floor/wall 

B. p pump installed 

C. ater pipe leaks 

D. 

E. 

FOUNDATION AREA 

23. 

(Slab on Grade) 

A. ent cracks 

B. 

C. 

D. 

24. 

w/Crawl Space) 

A. 

B. oisture or visible 

moisture in crawl space 

C. ulation 

(e.g., water stains) 

Foundation 

Minor cracks 

Settlem

W

Seepage into basem

Mortar deteriorating 

Other: 

Basement or Cellar 

Seepage, water stains on 

Sum

W

Sewer pipe leaks 

Other: 

Foundation 

Settlem

Joint separation 

Spalding 

Other: 

Foundation (Elevated Slab 

Concrete support integrity 

Evidence of m

Evidence of water accum

PROBLEM/CONDITION 
F-9

OK NA 

FOUNDATION AREA 

(cont.) 

D. 

E. 

F. p pump evident 

G. 

H. 

I. ent 

J. 

K. age 

L. aged 

M. aged, loose 

N. 

O. 

25. 

Only) 

A. bling, 

missing 

B. 

C. ater pipes leaking 

D. 

E. ater pipe condition 

F. Other: 

26. 

A. ater pipe conditions 

B. 

C. 

D. 

E. 

Sagging joist/support girders 

Fungus growth evident 

Sum

Vents present 

Vapor barriers 

Pier settlem

Uneven subgrade 

Insect dam

Sill plate dam

Subfloor dam

Need subfloor 

Other: 

Plumbing (Raised Floors 

Pipe insulation crum

Need to insulate pipes 

W

Sewer pipes leaking 

W

Plumbing 

W

Sewage pipe conditions 

Pipes leaking 

Pipe insulation 

Corrosion on drain lines 

PROBLEM/CONDITION 

F. Other: 
F-10 

OK NA 

FOUNDATION AREA 

(cont.) 

27. 

A. 

B. 

C. 

D. 

Other Area 

PROBLEM/CONDITION 

COMMENTS: 

Topo Survey Requested 9 Yes 9 No 

Inspector Signature Date 
G-1 

APPENDIX G

Examples of Property Closeout Forms
G-2 

USEPA REMEDIATION AGREEMENT FORM 

Name: 

Address: 

Phone: 

This form documents the completion of remedial activity performed on my property. My signature 

will designate that I am satisfied with the restoration of my property, and that no items are in question, 

now, or at any time in the future, except those items listed below, if any. 

Comments: 

Restoration items in question: 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

Chloe Irish 

Date 

Date 

Resident Signature Printed Name 

USEPA Representative Signature 

Brad W. Bradley 

Printed Name 
G-3 

RESIDENTIAL REMEDIATION INSPECTION/AGREEMENT FORM 

Name 

Address 

Phone 

This form documents the completion of remedial activities performed on my property. My signature 

will designate that I am satisfied with the restoration of my property, and that no items are in question, 

now, or at any time in the future, except those items listed below, if any. 

Comments 

Restoration Items in Question: 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

Property Inspection Date 

Lawn Care Instructions Reviewed/Delivered 

Sara O’Mara 

Resident Signature Printed Name 

USEPA Representative Signature 

Brad W. Bradley 

Printed Name 

Date 

Date 
H-1 

APPENDIX H

Examples of Clean Letters
H-2 

EPA LOGO AND ADDRESS

Date

Name

Address

City, State Zip

Dear :

The U.S. Environmental Protection Agency (EPA) has completed the cleanup of the lead contamination

in your yard located at [ADDRESS, CITY, STATE], in connection with the [SITE NAME] site in [CITY,

STATE] (the Site). By way of this letter, U.S. EPA is certifying that your yard has been cleaned up to

less than [CLEAN-UP LEVEL] parts per million lead, the level which U.S. EPA considers protective of

children's health at the Site.

Thank you for your cooperation in this clean-up effort. It has been our pleasure to work with you. If you

have any questions concerning this letter or need further information, please contact me at [PROJECT

MANAGER’S PHONE NUMBER]. 

Sincerely,

[PROJECT MANAGER NAME]

Remedial Project Manager
H-3 

EPA LOGO AND ADDRESS

Date

Name

Address

City, State Zip

Dear :

The United States Environmental Protection Agency (U.S. EPA) has sampled your yard located at

[ADDRESS, CITY, STATE] for lead. The results of this sampling, which are enclosed with this letter, 

indicate that your yard contains less than [CLEAN-UP LEVEL] per million lead, the level which U.S.

EPA considers protective of children’s health at the [SITE NAME, CITY, STATE]. Thus, U.S. EPA will

not need to perform soil clean-up activities in your yard.

If you have any questions concerning this letter or the enclosure, please contact me at [PROJECT

MANAGER’S PHONE NUMBER]. 

Sincerely,

PROJECT MANAGER NAME

Remedial Project Manager

Enclosure

ENCLOSURE 

Analytical results for [ADDRESS] 

in parts per million (ppm) of lead: 

Depth Zone 

(inches) 

Yards 

Front Back 

ppm ppm 

OR Quadrant 

1 2 3 4 

0 to 1 ppm ppm ppm ppm

1 to 6 ppm ppm ppm ppm ppm ppm 

6 to 12 ppm ppm ppm ppm ppm ppm 

18 to 24 ppm ppm ppm ppm ppm ppm 

Deeper 

Zones (if 

applicable) ppm ppm ppm ppm ppm ppm 

Drip Zone 

Composite ppm ppm ppm ppm ppm ppm 
H-4 

Mr. John Smith 

123 N. Main 

Joplin, Missouri 64108 

Dear Mr. Smith, 

This letter serves as written notification that a lead-contaminated soil clean-up action was performed 

under authority of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 

as amended by the Superfund Amendments and reauthorization Act of 1986 on property you have an 

interest in at the Jasper County, National Priorities Listed Superfund site. Our records show that your 

property located at 123 N. Main was included in this action. The clean-up action conducted by the U.S. 

Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (COE) addressed 

residences with soil lead levels over 800 ppm, day care facilities, and residences with children under six 

years of age with blood lead levels over 15 g/dL. 

Briefly, the primary objective of the clean-up action on your property was to remove highly leadcontaminated near-surface yard soils that were located at your residence. In some cases trees, shrubs, 

flowers, and other vegetation were left in place. As a result a small amount of lead-contaminated soils 

may be left near the surface on your property. This small amount of contamination should not cause a 

health threat under normal circumstances. In the future if additional landscaping, or planting requiring 

excavation below six inches are done, care should be exercised to minimize recontamination. 

The excavation criteria for the project was as follows: 

A) From the surface to 12 inches, excavation continued until 500 ppm or less lead levels 

concentrations were achieved; 

B) If the residual lead concentrations at a depth of one foot exceeded 1,500 ppm a “marker 

barrier” was placed at that depth. The marker barrier used was the temporary orange plastic constructiontype fence. This material is permeable, and will allow water and plant roots to pass through it. Only a 

small number of properties required the installation of the barrier. The primary purpose of this marker 

barrier is to inhibit and alert individuals excavating in these areas in future years. 

In general, all areas of the yard that exceeded 500 mg/kg lead at the surface were removed. Soil 

brought in to backfill the excavation contained less than 240 mg/kg lead. 

IF YOU HAVE PLANS TO DO ANY EXCAVATION WORK AT YOUR PROPERTY AND 

YOU ENCOUNTER THE ORANGE BARRIER PLEASE CONTACT YOUR LOCAL HEALTH 

DEPARTMENT, THE MISSOURI DEPARTMENT OF NATURAL RESOURCES, OR THE EPA FOR 

GUIDANCE. 

Please save this document for your permanent records. In the event you sell or transfer the property to 

someone you can show the next owner that a lead cleanup was performed. If you require more specific 

information concerning the excavation on your property, please feel free to contact me at 

(xxx) xxx-xxxx. 

Sincerely, 

(Project Manager)