HRS DOCUMENTATION RECORD COVER SHEET

Name of Site: Former United Zinc & Associated Smelters

EPA ID No.: KSN000705026

Contact Persons

EPA Contact: Michelle Quick 

 U.S. Environmental Protection Agency (EPA), Region 7

 901 North 5th Street

 Kansas City, Kansas 66101

 (913) 551-7335

Documentation Record: Kumud Pyakuryal, Tetra Tech EM Inc.

Pathways, Components, or Threats Not Scored

Ground water is not used as a significant resource in the immediate vicinity of the site; therefore, the 

ground water pathway does not contribute to the overall Hazard Ranking System (HRS) score. No 

releases or impacts to surface water or air have been scored; therefore, the surface water and air pathways 

were not evaluated. The ground water migration, surface water migration, and air migration pathways 

were not evaluated due to lack of analytical data and/or targets, and because these pathways would not 

affect the NPL decision.
1 

HRS DOCUMENTATION RECORD

Name of Site: Former United Zinc & Associated Smelters

EPA Region: 7 

Date Prepared: September 2012

Street Address of Site*: Highway 54 & Kansas Drive

City, County, State, zip: Iola, Allen County, Kansas 66749

General Location in the State: The site is located in and around Iola, Allen County, Kansas (Ref. 3, 

p. 1).

Topographic Map: The location of site is shown on the Iola, Kansas, Quadrangle, 

U.S. Geological Survey, 7.5-Minute Series Topographic Map 

(Ref. 3, p. 1).

Latitude: 37.92228° North (Ref. 3, p. 1) (see Figure 1)

Longitude: 95.38590° West (Ref. 3, p. 1) (see Figure 1)

The latitude and longitude listed above specify the approximate location of the Former United Zinc #1 

facility associated with the Former United Zinc & Associated Smelters site. Figure 1 shows this facility 

property location. 

Scores

Ground Water Pathway Not Scored

Surface Water Pathway Not Scored

Soil Exposure Pathway 100.00

Air Pathway Not Scored

HRS SITE SCORE 50.00

* - The street address, coordinates, and contaminant locations presented in this HRS documentation record 

identify the general area the site is located. They represent one or more locations EPA considers to be 

part of the site based on the screening information EPA used to evaluate the site for NPL listing. EPA 

lists national priorities among the known "releases or threatened releases" of hazardous substances; thus, 

the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous 

substance has been "deposited, stored, placed, or otherwise come to be located." Generally, HRS scoring 

and the subsequent listing of a release merely represent the initial determination that a certain area may 

need to be addressed under the Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of facility boundaries at 

the time of scoring will be refined as more information is developed as to where the contamination has 

come to be located.
2 

WORKSHEET FOR COMPUTING HRS SITE SCORE

 S S2

1. Ground Water Migration Pathway Score (Sgw) Not Scored 

2a. Surface Water Overland/Flood Migration Component

(from Table 4-1, line 30)

Not Scored

2b. Ground Water to Surface Water Migration Component

(from Table 4-25, line 28)

Not Scored

2c. Surface Water Migration Pathway Score (Ssw) 

Enter the larger of lines 2a and 2b as the pathway score.

Not Scored

3. Soil Exposure Pathway Score (Ss) 

(from Table 5-1, line 22)

100.00 10,000

4. Air Migration Pathway Score (Sa) 

(from Table 6-1, line 12)

Not Scored

5. Total of Sgw

2 + Ssw2 + Ss2 + Sa2 10,000

6. HRS Site Score 

Divide the value on line 5 by 4 and take the square root

 50.00
3

SOIL EXPOSURE PATHWAY SCORESHEET

(Ref. 1, Table 5-1)

Factor Categories and Factors Maximum Value Value Assigned

RESIDENT POPULATION THREAT

Likelihood of Exposure 

1. Likelihood of Exposure 550 550

Waste Characteristics

2. Toxicity a 10,000

3. Hazardous Waste Quantity a 10 

4. Waste Characteristics 100 18

Targets

5. Resident Individual 50 45 

6. Resident Population

6a. Level I Concentrations b 0 

6b. Level II Concentrations b 835.04

6c. Resident Population (lines 6a + 6b) b 835.04

7. Workers 15 5

8. Resources 5 0

9. Terrestrial Sensitive Environments c 0

10. Targets (lines 5 + 6c + 7 + 8 + 9) b 885.04

Resident Population Threat Score

11. Resident Population Threat (1 x 4 x 10) b 8,761,896
SOIL EXPOSURE PATHWAY SCORESHEET (Continued)

(Ref. 1, Table 5-1)

4 

Factor Categories and Factors Maximum Value Value Assigned

NEARBY POPULATION THREAT

Likelihood of Exposure

12. Attractiveness/Accessibility 100 NS

13. Area of Contamination 100 NS

14. Likelihood of Exposure 500 NS

Waste Characteristics

15. Toxicity a NS

16. Hazardous Waste Quantity a NS

17. Waste Characteristics 100 NS

Targets

18. Nearby Individual 1 NS

19. Population Within 1 Mile b NS

20. Targets (lines 18 + 19) b NS

Nearby Population Threat Score

21. Nearby Population Threat (lines 14 x 17 x 20) b NS

SOIL EXPOSURE PATHWAY SCORE

22. Soil Exposure Pathway Scored (Sg), (lines 

 [11 + 21] / 82,500, subject to maximum of 100) 100 100.00

a Maximum value applies to waste characteristics category.

b Maximum value not applicable.

c No specific maximum value applies to factor. However, pathway score based solely on terrestrial 

 sensitive environments is limited to maximum of 60.

d Do not round to nearest integer.

NS=Not Scored
Source: USGS Allen County, KS 7.5 Minute Topo Quad, 1984

X:\G\9004\0256\Projects\mxd\Figure1.mxd

Figure 1

Former United Zinc and Associated Smelters

Iola, Kansas

Area Location Map

Date: 7/27/2012 Drawn By: Gustavo Orozco Project No: X9004.L11.0256.000

Allen County

±

0 1,000 2,000

Feet

Former United Zinc #1

IMP Boats Inc.

East Iola Facility

Coberly Facility

Area of Concern (AOC)
169 

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X:\G\9004\0256\Projects\mxd\Figure2_081312.mxd

Source: Allen Co., Kansas DOQQ Tileset, 2003

ESRI Data Maps, Bing Maps Aerial, 2010

Former United Zinc and Associated Smelters

Iola, Kansas

Figure 2

(Lead > 366 parts per million) 

Date: 8/16/2012 Drawn By: Gustavo Orozco Project No: X9004.L11.0256.000 

Allen County

_ ^

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Former United Zinc #1 

Legend !( Background location 

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Highway

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Local Road

Minor Road

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County Locator 

Site Locator 

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Site Location 

0 600 1,200 ±

Scale in Feet 

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!( 

Areas of Observed Contamination
7 

Figure Notes: 

1. The currently identified property boundary for the Former United Zinc #1 facility does not represent 

the historical property boundary for the smelting facility. It is meant to illustrate the approximate portion 

of the historical property that is included for consideration in this evaluation due to the participation of 

relevant properties in the state of Kansas’ voluntary cleanup and redevelopment program. 

2. Parts per million is equal to milligrams per kilogram (mg/kg) provided as units of measurement in the 

analytical data tables in this HRS documentation record.
8 

REFERENCES

Ref.

No. Description of the Reference

1. U.S. Environmental Protection Agency (U.S. EPA). Hazard Ranking System, Final Rule, 40 

Code of Federal Regulations Part 300, Volume 55, No. 241. December 14, 1990. On-Line 

Address: http://www.epa.gov/superfund/sites/npl/hrsres/#HRS%20Rule. 1 page. (A complete 

copy of the Hazard Ranking System can be obtained at the Regional docket upon request.) 

2. U.S. EPA. Superfund Chemical Data Matrix (SCDM). March 2012. Excerpt. 9 pages. A 

complete copy of SCDM is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. 

3. U.S. Geological Survey (USGS). 7.5-Minute Series Topographic Map of Iola, Kansas

Quadrangle. 1966. Photo revised 1984. 1 page. 

4. Tetra Tech EM Inc. 2008. Site Inspection Report for the United Zinc No. 1 Site in Iola, Kansas. 

January 18. 81 pages. U.S. EPA Region 7. 

5. Reference Number Reserved.

6. Tetra Tech EM Inc. 2007. Quality Assurance Project Plan for Additional Removal Site 

Evaluation Activities, United Zinc No. 1, Iola, Kansas. Task Order No. 0038. Superfund 

Technical Assessment and Response Team (START) 3 Contract. February 28. 24 pages.

7. Tetra Tech, EM Inc. 2006. Quality Assurance Project Plan for an Integrated Site Assessment of 

the United Zinc #1 Site, Iola, Allen County, Kansas. Task Order 0011. (Superfund Technical 

Assessment and Response Team ) START Contract. April 7. 16 pages.

8. Maxim Technologies, Inc. (Maxim). 2003. Focused Former Smelter Phase I Report. Group B 

Smelters. United Zinc #1, Iola, Kansas. December 19. Excerpt 24 pages.

9. Burns & McDonnell Engineering Company Inc. (Burns & McDonnell). 2004. Appendix F: 

Phase II Focused Former Smelter Assessment of the Former United Zinc #1 Smelter, Iola, 

Kansas. December. 32 pages.

10. Kansas Department of Health and Environment (KDHE). Bureau of Environmental 

Remediation/Remedial Section. 2006. “A Short History of the Zinc Smelting Industry in 

Kansas.” December 28. 16 pages.

11. Reference Number Reserved.

12. Tetra Tech. 2007. Preliminary Assessment report for the United Zinc #1 Site in Iola, Kansas. 

February 20. 377 pages.

13. U.S. EPA Region 7 (Barry Evans). 2007. HRS Analysis Results Supplement for ASR # 3155 for 

the United Zinc No. 1 Site. March 27. 7 pages.

14. U.S. EPA Region 7 (Barry Evans). 2007. HRS Analysis Results Supplement for ASR # 3156 for 

the United Zinc No. 1 Site. March 27. 8 pages. 
REFERENCES (Continued)

9 

Ref.

No. Description of the Reference

15. U.S. EPA Region 7 (Barry Evans). 2007. HRS Analysis Results Supplement for ASR # 3157 for 

the United Zinc No. 1 Site. March 27. 4 pages.

16. U.S. EPA Region 7 (Barry Evans). 2007. HRS Analysis Results Supplement for ASR # 3158 for 

the United Zinc No. 1 Site. March 27. 3 pages.

17. U.S. EPA Region 7 (Barry Evans). 2007. HRS Analysis Results Supplement for ASR # 3151 for 

the United Zinc No. 1 Site. March 27. 3 pages.

18. U.S. EPA Region 7 (Barry Evans). 2007. HRS Analysis Results Supplement for ASR # 3152 for 

the United Zinc No. 1 Site. March 27. 4 pages.

19. U.S. EPA Region 7(Barry Evans). 2007. HRS Analysis Results Supplement for ASR # 3153 for 

the United Zinc No. 1 Site. March 27. 4 pages.

20. U.S. EPA Region 7 (Barry Evans). 2007. HRS Analysis Results Supplement for ASR # 3154 for 

the United Zinc No. 1 Site. March 27. 6 pages.

21. Reference Number Reserved.

22. Kansas Department of Health and Environment (KDHE). 2005. Preliminary Removal Site 

Evaluation for: United Zinc Smelter #1 Site in Iola, Kansas. September. Excerpt 54 pages.

23. Terranext. 2005. Appendix G: Residential Yard Soil Sampling Report: United Zinc #1 in Iola, 

Kansas. June 27. Excerpt 5 pages.

24. Tetra Tech EM Inc. (Tetra Tech). 2006. Removal Site Evaluation Report for United Zinc #1 

Site, Iola, Kansas. September 26. 510 pages.

25. Kansas Department of Health and Environment (KDHE). 2007. Risk-Based Standards for 

Kansas Manual – 4th Version. June. 52 pages. 

26. United Stated Department of Agriculture. 1978. Soil Survey of Allen County, Kansas. 

November. Excerpt 8 pages. A complete copy of the soil survey is available on-line at: 

http://soils.usda.gov/survey/online_surveys/kansas/KS001/allen.pdf. 

27. Reference Number Reserved.

28. Reference Number Reserved. 

29. U.S Census Bureau. 2012. Allen County, Kansas Census Data. On-line address: 

http://quickfacts.census.gov/qfd/states/20/20001.html. Accessed on April 6. 2 pages. 

30. Reference Number Reserved. 

31. City of Iola. 2008. Official website for City of Iola, Kansas: City History. On-line Address: 

http://www.cityofiola.com/history.html. Accessed on July 1. 6 pages. 
REFERENCES (Continued)

10

Ref.

No. Description of the Reference

32. Reference Number Reserved.

33. Kansas State University (KSU). 2012. Correspondence from Mary Knapp, State Climatologist, 

KSU, to Kumud Pyakuryal, Tetra Tech, Inc. Historical Wind Data/Wind Rose. July 25. Excerpt 

45 pages. 

34. Kansas Department of Health and Environment (KDHE). 2012. Correspondence forwarded from

Michelle Quick, U.S. EPA Region 7 NPL Coordinator, to Tetra Tech regarding Voluntary 

Cleanup Program Sites in Iola, Kansas. March 21. 5 pages. 

35. Chenega Global Services, LLC (Chenega). 2010. Former United Zinc Smelter, Iola, Allen 

County, KS: Potentially Responsible Party (PRP) Report. Prepared for U.S. EPA Region 7. 

July. 35 pages.

36. Chenega Global Services, LLC (Chenega). 2010. East Iola Smelter Site, Iola, Allen County, KS: 

Potentially Responsible Party (PRP) Report. Prepared for U.S. EPA Region 7. August. 40 

pages.

37. Chenega Global Services, LLC (Chenega). 2010. IMP Boats, Iola, Allen County, KS: 

Potentially Responsible Party (PRP) Report. Prepared for U.S. EPA Region 7. August. 35 

pages.

38. Reference Number Reserved.

39. Public School Review. 2012. Statistical Data for Jefferson Elementary School, Iola, Allen 

County, Kansas. On-line Address: 

http://www.publicschoolreview.com/town_schools/stateid/KS/townid/6216. Accessed on April

6. 6 pages

40. Tetra Tech EM Inc. (Tetra Tech). 2008. Removal Action Summary Report, United Zinc #1 Site 

– Iola, Kansas. May 15. 2568 pages (Appendix B – Photographic Documentation CD not 

included). 

41. Claytor, Rick. 2012. Memo to File: Former United Zinc Site, Iola, Kansas post excavation 

details. July 23. 5 pages. 

42. Kansas Department of Health and Environment (KHDE). 2012. Preliminary Assessment 2, IMP 

Boats Site (Lanyon #1 and #2), Iola, KS. June. 206 pages.

43. U.S. EPA Region 7 (Barry Evans). 2012. HRS Analysis Results Supplement for ASR # 3001 for 

the United Zinc No. 1 Site. July 30. 15 pages.

44. U.S. EPA Region 7 (Barry Evans). 2012. HRS Analysis Results Supplement for ASR # 3159 for 

the United Zinc No. 1 Site. July 30. 4 pages.

45. Reference Number Reserved.
REFERENCES (Continued)

11

Ref.

No. Description of the Reference

46. U.S. EPA Region 7 (Barry Evans). 2012. HRS Analysis Results Supplement for ASR # 3279 for 

the United Zinc No. 1 Site. July 30. 4 pages. 

47. U.S. EPA Region 7 (Barry Evans). 2012. HRS Analysis Results Supplement for ASR # 3280 for 

the United Zinc No. 1 Site. July 30. 7 pages. 

48. U.S. EPA Region 7 (Barry Evans). 2012. HRS Analysis Results Supplement for ASR # 3281 for 

the United Zinc No. 1 Site. July 30. 4 pages. 

49. U.S. EPA Region 7 (Barry Evans). 2012. HRS Analysis Results Supplement for ASR # 3282 for 

the United Zinc No. 1 Site. July 30. 2 pages. 

50. U.S. EPA Region 7 (Barry Evans). 2012. HRS Analysis Results Supplement for ASR # 3283 for 

the United Zinc No. 1 Site. July 30. 2 pages. 

51. Reference Number Reserved. 

52. U.S. EPA Region 7 (Barry Evans). 2012. HRS Analysis Results Supplement for ASR # 3285 for 

the United Zinc No. 1 Site. July 30. 2 pages. 

53. Tetra Tech, Inc. 2012. Record of Communication between Kumud Pyakuryal and Rick Claytor, 

United Zinc Removal Action Project Manager (Tetra Tech Region 7 START Team Member). 

August 17. 1 page.

54. Tetra Tech, Inc. 2012. Record of Communication between Kumud Pyakuryal and Courtney 

Orth, School Secretary, McKinley Elementary School, Iola, Kansas. August 17. 1 page.
12

1.0 SITE DESCRIPTION AND GENERAL COMMENTS

1.1 SITE DESCRIPTION

The Former United Zinc & Associated Smelters site is located in and around the city of Iola, Allen 

County, Kansas, west of Highway 169, but excludes any areas that are currently known to be 

uncontaminated or are being addressed by other regulatory programs; a known list of facilities that are 

currently participating in the state voluntary cleanup programs (e.g., Voluntary Cleanup and Property 

Redevelopment Program [VCPRP]) are catalogued and depicted in Reference 34 (Ref. 34, pp. 3-5). For 

HRS purposes the site is therefore defined as comprising the following: the releases of hazardous 

substances to the atmosphere, or other pathways, from all historical smelter operations (including, but not 

limited to those identified below) that operated in and around Iola, Kansas and the resulting contaminated 

soil. Contamination related to past smelters that operated in the area extends into numerous residential 

properties stretching westward from Highway 169 along both sides of Highway 54 up to near State 

Highway 169 (Figure 2 of this HRS documentation record). 

Some of the historical smelters that operated primarily between 1902 and 1925 are known as Former 

United Zinc #1, East Iola, Coberly, and Lanyon #1 and #2 (also referred to as IMP Boats in this HRS 

documentation record). The United Zinc & Chemical Company owned the United Zinc smelter (also 

known as Former United Zinc #1 in this HRS documentation record), depicted on page 18 of Reference 

35, from 1902 until 1925 and operated a smelter at this location from 1902 to 1910 (Ref. 35, pp. 9, 15). 

A smelter operated on the East Iola property, depicted on page 15 of Reference 36, between 1898 and 

1925 (Ref. 36, p. 10). The Coberly property is located adjacent and west of the Former United Zinc #1 

property, on the northeast corner of Kentucky Street and East Street (Highway 54). It is the location of the 

former United Iron Works Company, which operated from approximately 1906 to 1924 and in 1906 was 

noted as operating a steel foundry and iron works facility (Ref. 8, pp. 5, 11, 12). Smelting operations 

occurred at the IMP Boats property, depicted on page 11 of Reference 37, between 1896 and 1918 (Ref.

37, pp. 11-12). 

Past U.S. Environmental Protection Agency (EPA) and Kansas Department of Health and Environment 

(KDHE) investigations have identified elevated levels of lead at former smelter facilities that operated on 

the Former United Zinc #1 property and in the surrounding residential, commercial, and school properties

(Ref. 40, p. 4-6). The primary Former United Zinc #1 facility itself is located on the east side of Iola 

within a mixture of residential and commercial properties (Figures 1 and 2 of this HRS documentation 

record; Ref. 35, pp. 9, 11, 12), in the southwest quarter of Section 25, Township 24 South, Range 18 East, 

north of Highway 54 and east of Kentucky Street. It is comprised of 10 parcels of land, equivalent to 

approximately 17 acres (Ref. 3; Ref. 12, pp. 6, 8-9, 25; Figure 1 of this HRS documentation record). The 

property has been graded, leveled, and developed since the former smelter operations ceased in the 1920s 

(Ref. 8, p. 5). Most of the property where the former smelter was located is vacant but includes the 

following businesses: Brenntag Southwest, Inc. (Chemical Distribution Company), a MFA Distributor, 

the Superflea Flea Market, Tucker’s Flea Market, a portion of a concrete mixing facility, and some 

pastureland (Ref. 12, p. 6; Ref. 22, p. 5). 

The Former United Zinc #1 property is bordered on the north by residential properties; on the east by the 

East Iola property (the location of the former Prime Western Smelting Company Works No. 3 and J.B. 

Kirk Gas and Smelting Company; Ref. 36, p. 10), a car wash, a former Tyson processing facility, and a 

movie theater; on the south by a restaurant, a dry cleaner, a car dealership, and agricultural land; and on 

the west by the Coberly property (the location of the former United Iron Works Company and former Iola 

Brick Company #1 plant), a truck repair facility, and the remaining portion of the concrete mixing facility 
13

(Ref. 8, pp. 11, 12; 12, pp. 6,7). The Former United Zinc #1 property is also surrounded by residential 

neighborhoods and two schools (Ref. 22, p. 5). A preschool is located northeast and an elementary school 

is located southwest of the property (Ref. 23, p. 2). The facility layout is shown in Figure 2 of the Site 

Inspection Report (Ref. 4, p. 34). 

Another former smelter operation within Iola was located on the IMP Boats property, consisting of 

approximately 40 acres in the northeast quarter of the southeast quarter of Section 27, Township 24 

South, Range 18 East, extending to the north into the southeast quarter of the northeast quarter (Ref. 37, 

p. 10; Ref. 42, p. 4). In 1896, the sons of Robert Lanyon constructed the original Lanyon #1 and Lanyon 

#2 smelters on the IMP Boats property, which were the first smelters in the Iola area, which later became 

a part of the largest zinc smelting company in the United States (Ref. 42, p. 5). Although zinc was the 

primary metal processed, lead and other metals were also processed at the smelter. Past research has 

revealed that American Metals Company (AMC) leased Lanyon #1 and 2 smelters from 1910 to an 

unknown date. AMC was later known as AMAX, Cyprus AMAX, and Phelps Dodge Corporation. J.B. 

Kirk Gas and Smelting Company and the U.S. Smelting Company also operated on the IMP Boats 

property. The smelter became inactive in the 1920s, and the property was divided and sold into several 

parcels. IMP Boats operated a boat manufacturing facility on the northern portion of the property until 

1992 (Ref. 42, p. 5). 

The extent of the site generally encompasses the areas of contamination depicted in Figures 1 and 2 of 

this HRS documentation record, including denoted slag piles remaining on the Former United Zinc #1

facility and excluding any areas that are currently known to be uncontaminated or are being addressed by 

other regulatory programs (Ref. 9, pp. 9, 12, 17, 18, 27; 34, pp. 3-5). 

The driving factor for the HRS site score are residential targets associated with properties subject to actual

lead contamination; according to the HRS Rule, Section 5.1.3, residential targets include a person living 

or attending school or day care on a property with an area of observed contamination and whose 

residence, school or day care center, respectively, is on or within 200 feet of the area of observed 

contamination (Ref. 1, Section 5.1.3). Although arsenic was detected widely in past investigations, its

inclusion did not affect the site listing decision. Therefore, arsenic was not used for scoring purposes.

Previous Investigations

Lead soil contamination identified in and around the city of Iola was initially identified during 

investigations conducted at the Former United Zinc #1 facility, as documented in this section of the HRS 

documentation record. Further investigation into the possible sources of lead soil contamination identified 

other smelters in the area of the city of Iola, including but not limited to, former smelters on the East Iola, 

Coberly and IMP Boats properties (Ref. 8, pp. 11, 12; 12, pp. 7, 8, 24; 36, pp. 9-10; 37, pp. 10-12). A 

summary to these investigations is provided in this section. 

A Phase I Focused Former Smelter Assessment (FFSA) was completed on behalf of the KDHE State 

Water Plan (SWP) program in December 2003. The FFSA identified a Recognized Environmental

Condition (REC) at the Former United Zinc #1 facility based on observations of smelter waste during the 

site reconnaissance. The smelter waste appeared to have impacted the vegetative growth in the area of the 

former smelter operations of the Former United Zinc #1 facility. In addition, elevated concentrations of 

lead had been previously documented in the surface soils on the properties immediately adjacent to the 

facility from other documented smelting operations, including the East Iola and the Coberly properties. 

Additionally, it was noted that smelter wastes from the Former United Zinc #1 facility were identified on 

the Coberly property. A Phase II Assessment was recommended at the facility and in the area surrounding 

the smelting activities to investigate the potential risk of human exposure to heavy metal-impacted waste 

and surface soil (Ref. 8, pp. 1, 4, 16-17, 21, 22). 
14

Sampling of the soil, smelter waste, ground water, surface water and sediment was conducted during the 

Phase II FFSA of the Former United Zinc #1 facility in 2004 on behalf of the KDHE. It indicated that 

surface and shallow subsurface soils were contaminated with arsenic and lead. Field screening results 

obtained using an X-Ray Fluorescence (XRF) spectrometer indicated surface soil were above KDHE

Risk-Based Standards for Kansas (RSK) for arsenic in 18 out of 34 unbiased surface soil sample locations 

with concentrations ranging from 9 milligrams per kilogram (mg/kg) to 1,679 mg/kg. Lead 

concentrations exceeded KDHE RSK for lead in 30 unbiased surface soil sample locations with 

concentrations ranging from 412 mg/kg to 30,285 mg/kg. The report recommended further sampling to 

delineate the horizontal and vertical extent of heavy metal contamination at the facility property. The 

Phase II FFSA also indicated potential heavy metal contamination (e.g., arsenic, cadmium, lead) at both 

the McKinley School and the Iola Preschool (Ref. 9, pp. 7, 10, 14, 20-22). 

On behalf of KDHE, soil samples were collected in May and June 2005 from 50 residential yards located 

between the Former United Zinc #1 facility and the McKinley School and the Iola Preschool. Arsenic 

was detected above the KDHE RSK level of 11 mg/kg in 18 of the residential samples. In addition, lead 

was found above its KDHE RSK level of 400 mg/kg in 18 of the residential samples. Cadmium and zinc 

were detected in all of the soil samples at concentrations below their KDHE RSK values (Ref. 23, pp. 2-

4). 

A Preliminary Removal Site Evaluation (RSE) report was completed by the KDHE in September 2005. 

In support of the 2005 RSE, KDHE collected additional samples from sensitive target areas near the 

Former United Zinc #1 smelter facility, including the McKinley Elementary School and Iola Preschool. 

The results exhibited elevated levels of arsenic, cadmium, lead, and zinc at residential and non-residential 

properties. The presence of lead above 400 mg/kg was also identified within the McKinley School 

playground and adjacent areas. The Preliminary RSE recommended further removal site evaluation and 

removal action consideration (Ref. 22, pp. 1, 5, 7-9). 

An EPA directed RSE report was completed in September 2006. The sampling activities for the RSE 

were conducted during April and May 2006. During the RSE, approximately 260 properties were 

screened for lead using an XRF, and approximately 10 percent of the screened samples were submitted 

for laboratory confirmation analyses for arsenic, cadmium, lead, and zinc. Thirty-four properties were 

identified where either the XRF and/or laboratory data indicated lead concentrations warranting a timecritical removal action (400 mg/kg for schools and daycares; 800 mg/kg for residential properties; and 

1,000 mg/kg for commercial properties). The 34 properties included 19 private residences, 10 daycare 

facilities, two elementary schools, and three commercial properties. In addition, 91 residential properties 

contained concentrations of lead between 400 mg/kg and 800 mg/kg (Ref.4, p. 8; 24, pp. 1, 7 - 13). 

In February 2007, a Preliminary Assessment (PA) report was completed. It summarized the sampling 

activities conducted at the Former United Zinc #1 smelter facility property from August to November 

2006. During the PA activities, approximately 500 residential properties were screened for lead using an 

XRF and 180 soil samples were submitted for laboratory confirmatory analyses of arsenic and lead. The 

laboratory results found arsenic detected in 160 of the confirmatory soil samples at concentrations 

exceeding the HRS Cancer Risk (CR) screening concentration of 0.43 mg/kg. In addition, 32 samples

associated with the PA had concentrations that exceeded the HRS non-cancer screening concentration of 

23 mg/kg for arsenic (Ref. 2, pp. 2, 3; 4, pp. 8-9; 12, pp. 1-2, 5, 11-12). However, arsenic was not used 

for scoring purposes, because its inclusion did not affect the site listing decision. In response to the 

finding of elevated concentrations of lead, the EPA began a removal site evaluation of properties in the 

area of Iola (Ref. 41, p. 1). 
15

The Residential Soil Pathway for lead value of 400 mg/kg is found in the June 2007 KDHE Risk-Based 

Standards (Ref. 25, pp. 6, 8, 34). A total of 148 soil samples analyzed by the laboratory during the PA 

contained lead concentrations exceeding the KDHE RSK Residential Soil Pathway value of 400 mg/kg. 

All of these samples also exceeded lead background concentrations defined during the PA that ranged 

from 176 mg/kg to 397 mg/kg; however, the high concentrations of lead were determined not to be 

representative of site specific background conditions and appeared to have been affected by the 

operational history of the Former United Zinc #1 smelter facility. True background samples were 

collected during the CERCLA site inspection (SI) stage of the investigation, when utmost considerations 

were taken to ensure sampling points were located outside of the area impacted by activities attributed to 

the former smelter (Ref. 4, pp. 5, 9, 15-17). 

The sampling plans for the EPA tasked RSE, PA and SI were designed in accordance with U.S. 

Environmental Protection Agency (U.S. EPA) guidance for data quality objectives to ensure that the 

sampling would be cost-effective (Ref. 6, pp. 1, 4-10; 7, pp. 1, 5-9). 

Although arsenic and lead were found at significantly elevated levels in past investigations, only lead has 

been evaluated for scoring purposes in this HRS documentation record. An umbrella area of observed 

contamination (AOC) of lead, composed of individual, discrete areas of observed contamination, was 

documented by the chemical analysis of soil samples collected from the sampling area during the 2006

and 2007 sampling events; please see tables in Section 5.1.1 of this HRS documentation record for 

particular references. Associated field sheets are presented in Appendices D and H of Reference 40. 

5.0 SOIL EXPOSURE PATHWAY 

5.0.1 GENERAL CONSIDERATIONS

According to the HRS, the soil exposure pathway evaluation is based on areas of observed contamination 

(Ref. 1, Sect 5.0.1). The individual areas of observed soil contamination at the site were based on 

analytical evidence of hazardous substances present in concentrations three times or greater than the 

designated background levels and in concentrations greater than the corresponding sample quantitation 

limits (SQLs) (all surface soil samples were collected at a depth of 2 feet of less). The umbrella area of 

observed soil contamination is currently defined based on analytical results for soil samples collected in 

the area during the Preliminary Assessment (PA), Site Inspection (SI), and removal site evaluation field 

activities. 

BACKGROUND LEVEL

Additional sampling characterization and delineation of the site indicated that sampling locations 

considered as background during the PA were later determined to be largely contiguous extensions of

areas impacted by historical and operational activities at the site; the purpose of collection of these 

additional soil samples during the SI was to partly identify site-specific background concentrations of lead

(Ref. 4, pp. 9, 16-17). 

In support of the 2007 SI, five soil samples (presented in the table this section) were collected from five

residential properties 1.25 miles north of the Former United Zinc #1 facility. These sample locations are 

located more than a mile away from the former smelter and, as depicted in Figures 2 and 3 of the 2007 SI. 

Visual inspection of the aerial photographs indicates that background locations are from a subdivision 

outside of the town center (Ref. 4, pp. 16, 35, 36); however, background and release samples were 

collected from the soil type Kenoma-Woodson-Dennis. Soils of the Kenoma-Woodson-Dennis soil type 

occupy approximately 37 percent of the county (Ref. 26, pp. 6, 7, 8). The sampling plan prepared in 

February 2007 established a methodology for collecting background samples; EPA standard operating 
16

procedure (SOP) 4231.2012 was used to collect both release and background samples (Ref. 6, pp. 8, 17-

18; Ref. 7, pp. 9, 12-13). Surface soil samples were collected and screened in the field at five residential 

properties to determine the site-specific background concentrations. At each property, after receiving 

consent from the owner, samples were collected from 0 to 2 inches below ground surface (Ref. 6, pp. 17-

18; 4, pp. 4, 61-62). Lead concentrations in the background samples ranged from 21 to 122 mg/kg. The 

highest lead concentration of 122 mg/kg was found in sample 3396-2 (Ref. 4, pp. 39, 60, 66, 68, 74). The 

lead concentration level of 122 mg/kg was selected for use as the background level for the area, as it was 

the highest of the concentration levels. The background and release samples were collected from a 

similar depth, using the same sampling protocol, and analyzed using the same analytical method (Ref. 4, 

pp. 15-17, 61-62, 66-67, 77-81; 6, pp. 2, 8-10, 17-18; 7, pp. 5-6, 9, 12-14; 40, pp. 4-9, Appendix G). 

TABLE 1: Background Samples

Sample 

ID

Sample 

Medium

Sampling 

Depth (inches 

below surface)

Date Hazardous 

Substance

Concentration 

(mg/kg) 

Sample 

Quantitation 

Limit (mg/kg) 

References

3396-1 Soil 0-2 03/19/07 Lead 41. 7 1.18 4, pp. 38, 60, 66, 68, 74, 77; 

6, p. 8; Figure 2

3396-2 Soil 0-2 03/19/07 Lead 122 1.24 4, pp. 39, 60, 66, 68, 74, 78; 

6, p. 8; Figure 2

3396-3 Soil 0-2 03/19/07 Lead 25.3 1.12 4, pp. 40, 60, 66, 68, 74, 79; 

6, p. 8; Figure 2

3396-4 Soil 0-2 03/19/07 Lead 21.0 1.11 4, pp. 41, 60, 66, 68, 74, 80; 

6, p. 8; Figure 2

3396-5 Soil 0-2 03/19/07 Lead 52.0 1.19 4, pp. 42, 60, 66, 69, 74, 81; 

6, p. 8; Figure 2

Notes:

ID Identification

mg/kg Milligrams per kilogram
17 

AREA OF CONTAMINATION

The EPA is not inferring contamination between sample locations meeting observed contamination 

criteria, due to the length of time since the former smelter operations were active (approximately 1925)

and human development activities. Therefore, an umbrella area of observed contamination comprised of 

discrete, individual sample locations documenting areas of observed contamination was delineated based 

on analytical results for surface soil samples collected from residential and school yards. Only qualifying 

soil samples with lead concentrations greater than or equal to 366 mg/kg (three times the highest 

background concentration level of 122 mg/kg), were considered to be contaminated, meeting observed 

contamination criteria as defined by the Hazard Ranking System (HRS) (Ref. 1, Sections 2.3 and 5.0.1). 

However, all contaminated areas will be further investigated after placement of the site on the National 

Priorities List (Ref. 41, p. 1). Figure 2 depicts the areas of observed contamination associated with the 

site.

Contaminated Samples

For scoring purposes, only contaminated samples obtained from residential yards during the EPA removal 

and assessment sampling events were considered. The samples were collected from depths of 0 to 2 

inches bgs (Ref. 6, pp. 8, 17; 7, pp. 9, 12-13). Soils at background and contaminated sample locations are 

classified as Kenoma-Woodson-Dennis. (Ref. 26, pp. 6, 7, 8; Figure 2 of this HRS documentation 

record). The background and release samples were collected from a similar depth, using the same 

sampling protocol, and analyzed using the same analytical method (Ref. 4, pp. 15-17, 61-62, 66-67, 77-

81; 6, pp. 2, 8-10, 17-18; 7, pp. 5-6, 9, 12-14; 40, pp. 4-9, Appendix G). 

Attribution

The results of sampling events conducted at the Former United Zinc & Associated Smelters site in 2006

and 2007 revealed concentrations of lead in residential and school yards (soils) at greater than or equal to 

366 mg/kg; they are listed in Section 5.1.1 below. After referring to these individual areas of observed 

contamination, the EPA has determined that there is insufficient data available to identify the contribution 

from any individual former smelting facility to the soil contamination present in any particular location 

within the umbrella area of observed contamination. Therefore, a commingled area of soil contamination 

has been identified at this site, which includes the releases from the former smelters that operated in and 

around Iola, Kansas as possible origins of the lead soil contamination. The presence of lead within the 

umbrella area of observed contamination may be due to emissions from the smelter smokestacks or use of 

smelter waste as fill material. Cinders from the smelters that operated in and around Iola were used by the 

city as a road base in 1907 and in 1916, wastes (e.g., cinders) were used as roadbed materials for railroads 

(Ref. 8, p. 17; Ref. 10, p. 5). Zinc smelter waste is known to contain elevated concentrations of heavy 

metals from smelting activities—including arsenic and lead (Ref. 10, pp. 5-6).

As the area surrounding the site was part of the Tri-State Mining District, in the late 1870s the zinc 

smelting industry became an integral part of southeastern Kansas. The Tri-State District lies in 

southwestern Missouri, southeastern Kansas, and northeastern Oklahoma. For nearly 50 years, it was the 

world’s leading producer of lead and zinc ores (Ref. 10, p. 1). In the early 1900s, led by Robert Lanyon 

multiple smelters were operated in Iola and the neighboring cities of La Harpe and Gas (Ref. 10, p. 7). 

Based on the history of smelters documented by KDHE, there were five smelters at four facilities 

operating in and around Iola, Kansas. They included Lanyon Works # 1 and # 2 (IMP Boats) located in 

the western portion of the city; East Iola, Coberly, Hiser Implement, and Former United Zinc # 1 

clustered closely on the eastern edge of the city of Iola, immediately north of Highway 54 (Ref. 8, pp. 5, 

11-12; Ref. 10, pp. 12). 
18 

The East Iola smelter was the former location of the Prime Western Smelting Company Works #3 and 

J.B. Kirk Gas and Smelting Company, a zinc smelter plant which operated from approximately 1899 until 

1925 (Ref. 8, pp. 5, 11). The East Iola smelter was located in Iola, north of Highway 54 and west of 

Highway 169 (Ref. 8, p. 11). In 1910 it was noted that this facility contained 10 zinc furnaces and 3,240 

retorts (Ref. 36, pp. 10, 22). In 1994 smelter wastes were observed at the location of the East Iola smelter. 

Soil samples collected from the East Iola smelter property in 1994 and 1998 contained lead at 

concentrations greater than 400 mg/kg (Ref. 8, p. 16). The Coberly property is the former location of the 

United Iron Works Company which operated from approximately 1906 to 1924 and in 1906 was noted as 

operating a steel foundry and iron works facility (Ref. 8, pp. 5, 11, 12). In 1992 a soil sample collected 

from the Coberly property showed lead at 47,000 mg/kg. Slag material containing lead up to 21,167 

mg/kg has been observed on the Coberly smelter property (Ref. 8, p. 17). 

According to the historic plat maps and fire insurance maps, activities at the Former United Zinc #1 

Smelter property began as early as 1901. At that time, the Former United Zinc #1 facility was the 

location of the Standard Acid Company and included three furnaces, 12 retorts, and a pottery room with 

kilns. Mr. William Lanyon owned the property between 1901 and 1902. The property was transferred to 

United Zinc in 1902. The United Zinc and Chemical Company owned and operated the primary zinc 

smelter at this location until approximately 1912. No known active smelting facilities were documented 

on the property after 1912. Historical documentation indicates that the facility contained four furnaces, 

eight kilns, 14 retorts and several ore crushers and roasters (Ref. 22, pp. 5, 6; 35, pp. 1, 9). This facility 

was designed to capture the sulfur dioxide fumes generated during roasting of the ore to make sulfuric 

acid (Ref. 10, p. 5; 12, p. 7).

The IMP Boats property is located at 500 West Lincoln Road, Iola, Kansas 66749. The property included 

a large vacant lot that contains most of the smelter waste (Ref. 42, p. 4). In 1896 the sons of Robert 

Lanyon constructed the original Lanyon #1 and Lanyon #2 smelters on the IMP Boats property, which 

were the first smelters in the Iola area. American Metals Company leased Lanyon #1 and #2 smelters 

beginning in 1910. Subsequent operators also included J.B. Kirk Gas and Smelting Company and the 

United States Smelting Company. The smelters were inactive in the 1920s, and the property was divided 

and sold into several parcels. In 1991 lead was detected at 42,800 mg/kg during a Phase II in a soil sample 

collected from the smelter property. In September 1993 during a screening site inspection completed for 

EPA, lead was detected at a maximum of 23,800 mg/kg in soil samples collected from the smelter 

property (Ref. 42, p. 5). Other investigations conducted in 1993 and 1997 also identified high 

concentrations of lead in the soil of the IMP Boats property (Ref. 42, p. 6).

The site contamination is likely a result of a combination of air deposition and physical transfer of 

contaminated soils or dust from the Former United Zinc & Associated Smelters operations. This 

conclusion is based on the following:

(1) the operational history of the former smelters identified above; 

(2) the presence of highly contaminated soils at the Former United Zinc #1 facility (and extension into 

nearby properties-see Figure 2 of this HRS documentation record) and the Lanyon #1 and #2 smelter 

properties (IMP Boats property); and 

(3) possibly the height of the smokestacks present at each historical smelting facility, which may have 

caused atmospheric releases of contaminants to be dispersed over a larger area (Ref. 10, p. 5). 

The uneven spatial distribution of lead concentrations at the site is likely due to the length of time since 

contaminant deposition and the variability in deposition areas due to variable wind directions. In the 

eight plus decades since operations ceased at the site, many of the residential yards in the area have been 
19 

disturbed by landscaping, sidewalk placement, gardening, and even total redevelopment. Further, the 

state of Kansas climatologist was contacted to request current and historical wind data around the site for 

5-year periods between 1901 and 1905; between 1951 and 1955; and between 2007 and 2011 to view 

wind speed and direction distribution. The historical wind direction shows significant variability for Allen 

County, Kansas. For example, during the 1901-1905 time period, the wind direction was predominantly

moving in a northeastern direction. While the predominant wind direction appeared to be from the 

south/southwest in the time period between 1951-1955 and 2007 - 2011, the data showed the wind 

traveled to and from all directions; the most recent wind rose data plots for the vicinity of the site are 

presented in pages 42 and 44 of Reference 33 (Ref. 31, p. 1; 33, p. 1-45). This data further supports the 

aerial deposition of lead contamination to the soil within the umbrella area of observed contamination, 

which cannot be attributed to any particular smelter. 
20 

5.1 RESIDENT POPULATION THREAT

5.1.1 Likelihood of Exposure

Individual, discrete areas of observed contamination were delineated based on analysis of surface soil 

samples collected from residential and school yards and within 200 feet of residences or school buildings. 

All soil samples with lead concentrations greater than or equal to 366 mg/kg were considered to be 

contaminated, meeting observed contamination criteria as defined by the Hazard Ranking System (HRS) 

Final Rule (Ref. 1, Sections 2.3 and 5.0.1). Residential property boundaries and sample locations were 

plotted in the residential field screening forms (see Reference 40 pages 5, 7 and Appendix H) and also 

recorded with global positioning system coordinates during sampling events. As per the sampling 

methodology and evidenced by property screening forms (referenced for each sampling location in the 

table below), all the residential and school properties where contaminated samples were collected and 

included for scoring purposes are less than 200 feet from the dwelling or school building (Ref. 4, pp. 76-

81; 12, pp. 27-85; 7, pp. 12-14; 40, pp. 7-8, Appendix H). Therefore, all properties whose soil sample 

analytical results indicate lead contamination significantly above the background level have residents or 

students less than 200 feet from areas of observed contamination. Thus, a likelihood of exposure factor 

category value of 550 was assigned in accordance with the Hazard Ranking System (HRS) Rule (Ref. 1, 

Section 5.1.1, p. 51646). 

The samples listed below, and shown in Figure 2 of this HRS documentation record, meet the 

requirements for establishing observed contamination.
21 

TABLE 2: Area of Observed Contamination Samples

Sample 

Number

EPA Property ID Date and Depth2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References1, 4

3285-008 2 June 2007 (lab analyzed 

sample on 07/13/2007)

1,180 5.5 40, pp. 516, 519, 525; 

52, p. 2 

3152-006 3 8/16/2006 838 (collected 

at 12 inches 

below ground 

surface)

1.07 40, pp. 378, 381, 

549-550; 53, p. 1; 18, 

pp. 1-2 

3001-012 12 4/13/2006 806 5.31 24, pp. 34-35, 476, 

482; 43, p. 3

3001-014 14 4/14/2006 539 5.14 24, pp. 37-38, 476, 

483; 43, p. 3

3001-021 16 4/20/2006 745 6.90 24, pp. 40, 476, 485; 

43, p. 5

3001-022 29 4/20/2006 571 5.16 24, pp. 56, 476, 485; 

43, p. 5

3001-023 30 4/20/2006 681 5.10 24, pp. 57, 476, 485; 

43, p. 5

3001-020 35 4/20/2006 582 5.51 24, pp. 62, 476, 484; 

43, p. 4-5

3001-017 37 4/19/2006 434 5.53 24, pp. 64, 476, 484; 

43, p. 4

3001-019 39 4/19/2006 440 5.31 24, pp. 66, 476, 484; 

43, p. 4

3001-016 42 4/19/2006 420 5.19 24, pp. 69, 476, 483; 

43, p. 4

3152-009 49 8/24/2006 400 (collected 

at 12 inches 

below ground 

surface)

1.09 40, pp. 378, 382, 

565-566; 18, p. 2

3001-024 50 4/21/2006 567 5.95 24, pp. 77, 476, 485; 

43, p. 5

3001-026 58 4/24/2006 769 6.64 24, pp. 90, 476, 486; 

43, p. 6

3281-004 723 3/5/2007 761 1.05 40, pp. 489, 491, 

1340; 48, p. 1

3001-029 80 4/25/2006 490 6.86 24, pp. 117-118, 476, 

487; 43, p. 6

3001-035 89 4/27/2006 417 6.09 24, pp. 131, 476, 488; 

43, p. 7

3001-037 107 5/2/2006 616 6.76 24, pp. 154-155, 476, 

489; 43, p. 8

3001-048 179 5/8/2006 411 7.16 24, pp. 291, 477, 491; 
22 

Sample 

Number

EPA Property ID Date and Depth

2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References

1, 4

43, p. 10

3001-050 185 5/10/2006 397 6.12 24, pp. 297, 477, 492; 

43, p. 10

3001-054 197 5/11/2006 504 6.25 24, pp. 309, 477, 493; 

43, p. 11

3001-052 198 5/10/2006 562 6.64 24, pp. 310, 477, 492; 

43, p. 11

3001-051 201 5/10/2006 764 6.99 24, pp. 313, 477, 492; 

43, p. 10-11

3001-056 216 5/15/2006 496 6.58 24, pp. 329, 477, 493; 

43, p. 11-12

3001-057 218 5/15/2006 494 5.91 24, pp. 331, 477, 494; 

43, p. 12

3001-059 221 5/15/2006 614 6.19 24, pp. 335, 477, 494; 

43, p. 12

3001-062 225 5/16/2006 551 5.78 24, pp. 339, 477, 495; 

43, p. 13

3001-067 236 5/17/2006 509 5.79 24, pp. 350, 477, 496; 

43, p. 14

3001-066 239 5/17/2006 386 6.25 24, pp. 353, 477, 496; 

43, p. 13

3001-069 243 5/17/2006 460 5.44 24, pp. 359, 477, 497; 

43, p. 14

3001-070 244 5/17/2006 554 5.67 24, pp. 360-361, 477, 

497; 43, p. 14

3001-068 248 5/17/2006 628 5.58 24, pp. 365, 477, 496;

43, p. 14

3001-073 249 5/18/2006 585 6.14 24, pp. 366, 477, 498; 

43, p. 15

3151-006 261 8/9/2006 805 5.54 40, pp. 370, 373, 823; 

17, p. 2

3151-010 262 8/9/2006 396 5.42 40, pp. 370, 374, 824; 

17, p. 2-3

3151-009 268 8/9/2006 647 5.16 40, pp. 370, 374, 830; 

17, p. 2

3151-001 270 8/15/2006 552 6.23 40, pp. 370, 372, 832; 

17, p. 1

3152-011 281 8/28/2006 541 1.20 40, pp. 378, 382, 

615-616; 18, p. 2

3152-002 285 8/21/2006 991 1.26 40, pp. 378, 380, 845; 

18, p. 1

3152-010 287 8/25/2006 518 1.14 40, pp. 378, 382, 847; 

18, p. 2
23 

Sample 

Number

EPA Property ID Date and Depth

2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References

1, 4

3152-016 294 8/30/2006 996 1.20 40, pp. 378, 383, 855; 

18, p. 3

3152-003 298 8/22/2006 782 1.25 40, pp. 378, 380, 857; 

18, p. 1

3152-008 299 8/24/20061,130 1.12 40, pp. 378, 381, 858; 

18, p. 2

3152-020 315 8/31/2006 600 1.16 40, pp. 378, 384, 872; 

18, pp. 3-4

3152-014 325 8/30/20061,010 1.27 40, pp. 378, 383, 883; 

18, p. 3

3152-015 326 8/30/2006 582 1.25 40, pp. 378, 383, 

884-885; 18, p. 3

3152-012 328 8/29/20061,050 1.32 40, pp. 378, 382, 886; 

18, p. 2

3153-005 333 9/11/2006 566 5.21 40, pp. 388, 391, 

891-892; 19, p. 2

3152-013 334 8/29/20061,050 1.20 40, pp. 378, 383, 893; 

18, pp. 2-3

3153-007 344 9/12/2006 504 5.40 40, pp. 388, 391, 

905-906; 19, p. 2

3153-008 346 9/12/2006 420 5.40 40, pp. 388, 392, 908; 

19, p. 2; 19, p. 2

3153-012 354 9/13/2006 406 5.69 40, pp. 388, 392, 

918-919; 19, p. 3

3153-010 356 9/12/2006 484 5.39 40, pp. 388, 392, 

922-923; 19, pp. 2-3

3153-001 373 9/6/2006 412 5.60 40, pp. 388, 390, 944; 

19, p. 1

3154-023 387 9/26/2006 461 1.14 40, pp. 398, 405, 959; 

20, p. 4

3153-004 392 9/11/2006 460 5.41 40, pp. 388, 390, 966; 

19, p. 1

3153-014 394 9/14/2006 523 5.06 40, pp. 388, 393, 968; 

19, p. 3

3154-004 396 9/19/2006 509 1.22 40, pp. 398, 400, 

970-971; 20, p. 1

3156-022 400 10/19/20061,360 6.68 40, pp. 426, 434, 

976-977; 14, p. 5

3154-016 404 9/21/2006 748 1.24 40, pp. 398, 403, 980; 

20, p. 3

3154-018 406 9/21/2006 449 1.17 40, pp. 398, 404, 

982-983; 20, p. 3

3154-002 414 9/18/2006 593 1.14 40, pp. 398, 400, 991; 
24 

Sample 

Number

EPA Property ID Date and Depth

2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References

1, 4

20, p. 1

3154-019 431 9/25/2006 380 1.21 40, pp. 398, 404, 

1015; 20, p. 3

3154-017 433 9/21/2006 719 1.22 40, pp. 398, 404, 

1018; 20, p. 3

3154-014 434 9/21/2006 916 1.21 40, pp. 398, 403, 

1019; 20, p. 3

3156-027 446 10/20/2006 921 5.41 40, pp. 426, 435, 

1034; 14, p. 6

3154-015 463 9/21/20061,140 1.17 40, pp. 398, 403, 

1053; 20, p. 3

3154-034 468 9/28/20061,010 1.14 40, pp. 398, 408, 

1060; 20, p. 5-6

3157-003 480 10/31/2006 824 6.47 40, pp. 442, 444, 

1071; 15, p. 1

3156-035 500 10/25/2006 503 5.89 40, pp. 427, 437, 

1098; 14, p. 7

3157-014 505 11/6/20061,520 6.29 40, pp. 442, 447, 

1103; 15, p. 3

3156-036 509 10/25/2060 374 5.98 40, pp. 427, 437, 

1107; 14, p. 8

3155-004 514 10/3/2006 908 5.28 40, pp. 412, 414, 

1112; 13, p. 1

3155-003 515 10/3/2006 683 4.95 40, pp. 412, 414, 

1113; 13, p. 1

3157-002 526 10/30/2006 662 6.19 40, pp. 442, 444, 

1126; 15, p. 1

3154-035 532 9/29/20061,920 1.16 40, pp. 398, 408, 

1134; 20, p. 6

3154-008 541 9/25/2006 568 1.19 40, pp. 398, 401, 

1144-1145; 20, p. 2

3157-004 544 10/31/2006 726 6.71 40, pp. 442, 444, 

1149; 15, p. 1

3154-022 547 9/26/2006 581 1.18 40, pp. 398, 405, 

1154; 20, p. 4

3155-016 553 10/6/2006 507 5.48 40, pp. 412, 417, 

1160; 13, p. 4

3154-029 554 9/27/2006 916 1.13 40, pp. 398, 407, 

1161; 20, p. 5

3154-006 558 9/25/2006 761 1.19 40, pp. 398, 401, 

1164; 20, pp. 1-2

3154-028 567 9/27/20061,190 1.14 40, pp. 398, 406, 

1174; 20, p. 5
25 

Sample 

Number

EPA Property ID Date and Depth

2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References

1, 4

3154-033 591 9/28/20061,230 1.15 40, pp. 398, 408, 812; 

20, p. 5

3154-032 593 9/28/20062,520 1.20 40, pp. 398, 407, 812; 

20, p. 5

3285-002 606 5/30/2007 408 5.4 40, pp. 516, 518, 

687-688; 52, p. 1

3155-008 610 10/4/2006 676 5.37 40, pp. 412, 415, 

1220; 13, p. 2

3157-015 611 11/6/20063,980 6.17 40, pp. 442, 447, 

1221-1222; 15, pp. 3-

4

3155-005 625 10/4/2006 993 5.60 40, pp. 412, 415, 

1234; 13, p. 2

3156-014 632 10/18/2006 746 5.89 40, pp. 426, 432, 

1241; 14, p. 3

3156-013 647 10/18/2006 420 6.45 40, pp. 426, 432, 

1258; 14, p. 3

3156-015 648 10/18/20061,360 6.13 40, pp. 426, 432, 813; 

14, pp. 3-4

3155-010 659 10/5/2006 785 5.39 40, pp. 412, 416, 

1270; 13, pp. 2-3

3157-016 668 11/7/2006 665 5.99 40, pp. 442, 447, 

1277; 15, p. 4

3156-020 692 10/19/20061,470 5.85 40, pp. 426, 433, 

1304-1305; 14, pp. 4-

5

3155-031 694 10/12/2006 521 5.92 40, pp. 412, 421, 

1307; 13, p. 7

3155-033 699 10/13/2006 794 5.64 40, pp. 412, 422; 13, 

p. 7

3155-030 703 10/12/2006 397 5.83 40, pp. 412, 421, 

1318; 13, pp. 6-7

3155-019 710 10/10/2006 789 5.71 40, pp. 412, 418, 

1326; 13, p. 4

3155-027 717 10/12/2006 764 6.23 40, pp. 412, 420, 

1333; 13, p. 6

3156-001 729 10/16/2006 731 5.77 40, pp. 426, 429, 

1348-1349; 14, p. 1

3155-026 725 10/12/2006 482 5.94 40, pp. 412, 420, 

1341-1342; 13, p. 6

3156-004 739 10/16/20061,260 6.78 40, pp. 426, 429, 

1361; 14, p. 1

3156-006 745 10/17/2006 374 5.91 40, pp. 426, 430, 
26 

Sample 

Number

EPA Property ID Date and Depth

2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References

1, 4

1367; 14, p. 2

3156-007 746 10/17/2006 588 5.90 40, pp. 426, 430, 

1368; 14, p. 2

3156-003 748 10/16/2006 458 6.84 40, pp. 426, 429, 

1370; 14, p. 1

3156-025 750 10/19/2006 861 5.87 40, pp. 426, 435, 

1373-1374; 14, pp. 5-

6

3156-008 753 10/17/2006 680 6.16 40, pp. 426, 430, 

1378; 14, p. 2

3156-028 764 10/23/2006 559 6.27 40, pp. 426, 435, 

1390; 14, p. 6

3156-012 781 10/18/2006 515 6.23 40, pp. 426, 431, 

1408; 14, p. 3

3156-034 786 10/25/2006 599 6.66 40, pp. 427, 437, 

1415-1416; 14, p.7

3156-033 787 10/24/2006 825 5.74 40, pp. 426, 437, 

1417-1418; 14, p. 7

3156-024 793 10/20/2006 831 5.66 40, pp. 426, 434, 

1424; 14, p. 5

3156-030 796 10/24/20061,050 5.75 40, pp. 426, 436, 

1428; 14, pp. 6-7

3156-026 810 10/29/2006 774 5.79 40, pp. 426, 435, 

1448-1449; 14, p. 6

3157-012 813 11/2/2006 950 6.00 40, pp. 442, 446, 

1454-1455; 15, p. 3

3157-010 833 11/2/2006 674 6.30 40, pp. 442, 446, 

1481-1482; 15, p. 3

3157-008 844 11/1/2006 748 6.47 40, pp. 442, 445, 

1494; 15, p. 2

3156-037 853 10/26/2006 529 5.93 40, pp. 427, 438, 

1505; 14, p. 8

3157-009 862 11/1/2006 505 6.19 40, pp. 442, 446, 

1517-1518; 15, p. 2

3157-005 877 10/31/2006 542 6.82 40, pp. 442, 445, 

1535; 15, p. 2

3157-007 883 11/1/2006 871 6.33 40, pp. 442, 445, 

1545; 15, p. 2

3156-031 895 10/24/2006 396 5.60 40, pp. 426, 436, 

1559; 14, p. 7

3157-017 907 11/8/2006 687 6.05 40, pp. 442, 448, 

1577; 15, p. 4

3158-006 950 11/27/2006 526 6.43 40, pp. 452, 455, 
27 

Sample 

Number

EPA Property ID Date and Depth

2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References

1, 4

1629-1630; 16, p. 2

3158-003 965 11/17/2006 426 6.03 40, pp. 452, 454, 

1649; 16, p. 1

3158-008 968 11/27/2006 940 6.26 40, pp. 452, 455, 

1653-1654; 16, p. 2

3158-004 982 11/21/2006 483 5.65 40, pp. 452, 454, 

1675-1676; 16, p. 1

3280-023 992 3/1/2007 445 5.2 40, pp. 477, 484, 

1687; 47, p. 5

3280-024 993 3/1/2007 838 5.4 40, pp. 477, 484, 

1688; 47, p. 5

3158-011 998 11/29/2006 961 6.54 40, pp. 452, 456, 

1694; 16, p. 3

3279-017 1002 1/11/2007 602 7.0 40, pp. 468, 474, 

1698; 46, p. 4

3280-016 1007 2/22/2007 806 5.7 40, pp. 477, 482, 

1707-1708; 47, p. 4

3281-001 1020 3/5/2007 459 1.07 40, pp. 489, 491, 

1729; 48, p. 1

3159-001 1026 12/12/2006 692 7.12 40, pp. 460, 462, 

1737; 44, p. 1

3159-003 1027 12/12/2006 851 7.17 40, pp. 460, 462, 

1738; 44, p. 1

3159-009 1028 12/13/2006 606 6.13 40, pp. 460, 464, 

1739; 44, p. 2

3159-010 1029 12/13/20061,020 6.32 40, pp. 460, 464, 

1740; 44, pp. 2-3

3159-006 1034 12/12/2006 443 6.28 40, pp. 460, 463, 

1747; 44, p. 2

3159-007 1036 12/12/2006 978 6.25 40, pp. 460, 463, 

1749-1750; 44, p. 2

3159-014 1062 12/19/2006 904 6.37 40, pp. 460, 465, 

815-816; 44, p. 3

3279-002 1068 1/4/20071,080 7.10 40, pp. 468, 470, 

1788; 46, p. 1

3159-013 1074 12/18/2006 678 6.52 40, pp. 460, 465, 

1794; 44, p. 3

3159-015 1083 12/19/2006 883 6.41 40, pp. 460, 465, 

1807; 44, pp. 3-4

3280-012 1094 2/26/2007 880 5.4 40, pp. 477, 481, 

1819-1820; 47, p. 3

3281-006 1109 3/5/2007 430 1.04 40, pp. 489, 492, 

1838; 48, p. 1-2
28 

Sample 

Number

EPA Property ID Date and Depth

2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References

1, 4

3280-021 1110 3/1/2007 605 5.2 40, pp. 477, 484, 

1839; 47, p. 5

3281-008 1128 3/5/2007 489 1.04 40, pp. 489, 492, 

1862-1863; 48, p. 2

3159-004 1139 12/12/20061,290 6.50 40, pp. 460, 462, 

1877; 44, p. 1

3280-002 1160 2/21/2007 377 6.0 40, pp. 477, 479, 

1897; 47, p. 1

3279-014 1181 1/11/2007 396 5.6 40, pp. 468, 473, 

1922; 46, p. 3

3159-008 1190 12/14/2006 893 6.34 40, pp. 460, 463, 

1937; 44, p. 2

3159-005 1214 12/12/2006 983 6.49 40, pp. 460, 463, 

1962; 44, p. 2

3280-015 1219 2/22/20071,070 5.9 40, pp. 477, 482, 

1967; 47, pp. 3-4

3159-012 1220 12/18/2006 519 5.77 40, pp. 460, 464, 

1968; 44, p. 3

3281-017 1227 3/12/2007 528 1.15 40, pp. 489, 495, 

1974-1975; 48, p. 3

3280-003 1243 2/21/2007 774 5.7 40, pp. 477, 479, 

1997; 47, p. 1

3280-005 1250 2/22/20071,120 5.7 40, pp. 477, 480, 

2005; 47, p. 2

3279-009 1252 1/10/2007 806 6.5 40, pp. 468, 472, 

2006; 46, p. 2

3279-010 1256 1/10/2007 775 5.9 40, pp. 468, 472, 

2012; 46, pp. 2-3

3280-029 1257 3/2/2007 528 6.0 40, pp. 477, 486, 

2013; 47, p. 6

3279-012 1264 1/10/2007 451 6.6 40, pp. 468, 472, 

2021; 46, p. 3

3280-011 1267 2/26/2007 837 5.4 40, pp. 477, 481, 

2025; 47, p. 3

3279-016 1271 1/11/2007 496 6.5 40, pp. 468, 473, 

2030-2031; 46, p. 4

3281-011 1284 3/6/2007 450 1.09 40, pp. 489, 493, 

2044; 48, p. 2

3280-028 1287 3/1/2007 755 5.3 40, pp. 477, 485, 

2047; 47, p. 6

3280-017 1293 2/23/2007 396 5.3 40, pp. 477, 483, 

2051; 47, p. 4

3280-014 1299 2/26/2007 685 5.2 40, pp. 477, 482, 
29 

Sample 

Number

EPA Property ID Date and Depth

2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References

1, 4

2054; 47, p. 3

3279-001 1312 1/4/2007 935 6.3 40, pp. 468, 470, 

2070; 46, p. 1

3280-027 1319 3/1/2007 702 5.3 40, pp. 477, 485, 

2081; 47, p. 6

3285-006 1320 6/7/2007 479 4.8 40, pp. 516, 519, 

777-778; 52, p. 2

3281-009 1352 3/5/2007 481 1.10 40, pp. 489, 493, 

2114; 48, p. 2

3280-025 1324 3/1/2007 998 5.2 40, pp. 477, 485, 

2085; 47, pp. 5-6

3281-015 1389 3/6/2007 391 1.04 40, pp. 489, 494, 

2160-2161; 48, p. 3

3279-013 1404 1/2/2007 378 6.4 40, pp. 468, 473, 

2190-2191; 46, p. 3

3279-004 1406 1/8/2007 777 6.2 40, pp. 468, 470, 

2194-2195; 46, p. 1

3279-005 1412 1/9/2007 744 6.0 40, pp. 468, 471, 

2204-2205; 46, p. 2

3279-008 1419 1/10/2007 380 6.6 40, pp. 468, 471, 

2211; 46, p. 2

3279-006 1434 1/9/20071,600 6.5 40, pp. 468, 471, 

2233; 46, p. 2

3280-019 1440 2/23/2007 805 5.3 40, pp. 477, 483, 

2242; 47, p. 4

3281-019 1445 3/13/2007 553 1.31 40, pp. 489, 495, 

2248; 48, p. 3

3280-010 1456 2/26/2007 482 5.2 40, pp. 477, 481, 

2258-2259; 47, pp. 2-

3

3281-010 1462 3/5/20071,270 1.06 40, pp. 489, 493, 

2265-2266; 48, p. 2

3281-007 1471 3/5/2007 953 1.05 40, pp. 489, 492, 

2277-2278; 48, p. 2

3280-030 1478 3/2/2007 576 5.3 40, pp. 477, 486, 

2285; 47, pp. 6-7

3281-003 1489 3/5/2007 592 1.04 40, pp. 489, 491, 

2299-2300; 48, p. 1

3281-014 1496 3/6/2007 895 1.04 40, pp. 489, 494, 

2309; 48, p. 3

3280-031 1553 3/2/20071,260 5.4 40, pp. 477, 486, 

2382; 47, p. 7

3282-004 1589 4/2/2007 931 6.7 40, pp. 498, 500, 
30 

Sample 

Number

EPA Property ID Date and Depth2 Lead Result 

(mg/kg)

Sample Quantitation Limit 

(mg/kg)3 

References1, 4

2431; 49, p. 1

3283-004 1593 4/23/2007 755 6.2 40, pp. 504, 506, 

2436; 50, p. 1

3283-008 1631 4/26/2007 671 6.0 40, pp. 504, 507, 

2485-2486; 50, p. 2

3285-003 1663 5/31/2007 613 6.3 40, pp. 516, 518, 

2533-2534; 52, p. 1

3285-001 1672 5/29/2007 1,340 6.3 40, pp. 516, 518, 

2549; 52, p. 1

Notes:

EPA U.S. Environmental Protection Agency

ID Identification

mg/kg Milligrams per kilogram

1. References for chains of custody (COCs) for Analytical Service Requests (ASR) that correspond with the first four digits of the sample identification number are as 

follows: ASR 3001 (Ref. 24, p. 453-458), ASR 3151 (Ref. 40, p. 37), ASR 3152 (Ref. 40, p. 50), ASR 3153 (Ref. 40, p. 71), ASR 3154 (Ref. 40, pp. 89-90), ASR 3155 

(Ref. 40, pp. 126-127), ASR 3156 (Ref. 40, pp. 161-162), ASR 3157 (Ref. 40, pp. 200), ASR 3158 (Ref. 40, p. 219), ASR 3159 (Ref. 40, p. 231), ASR 3279 (Ref. 40, p. 

247), ASR 3280 (Ref. 40, pp. 266-267), ASR 3281 (Ref. 40, p. 299), ASR 3282 (Ref. 40, p. 320), ASR 3283 (Ref. 40, p. 328), and ASR 3285 (Ref. 40, p. 345). 

2. All samples were collected between 0 and 2 inches, unless otherwise noted (please refer to section 5.1.1 of this HRS documentation record). 

3. The sample quantitation limit (SQL) is shown as the report limit (RL) in the HRS Analytical Results Supplement provided by the laboratory. The laboratory's reporting 

limit is adjusted for the dilution factor, volume adjustment, or percent solids for that sample analysis and is equivalent to a SQL (see page 1 of References 13 to 20, 43, 

44, 46, 47, 48, 50, and 52).

4. The sampling dates and times, as well as the property cell where a sample was collected are documented in Reference 24, Appendix C and Attachment 1 respectively and 

Reference 40, Appendices D and G respectively for relevant samples. 
TABLE 3: School and Residential Samples

Sample 

Number Date Collected3 

Distance of 

Population/Resources from 

Area of Observed 

Contamination (feet)2 

Number of 

Resident 

Targets1

References

3285-008 

(McKinley 

Elementary 

School)

June 2007 (lab 

analyzed sample on 

07/13/2007)

<200 136 (students)

8 (teachers)1 39, pp. 1; 54, p. 1 

3152-006

(Jefferson 

Elementary 

School)

8/16/2006 <200 253 (students)

16 (teachers) 39, pp. 1 

3001-012 4/13/2006 <200 2.36 29, p. 1

3001-014 4/14/2006 <200 2.36 29, p. 1

3001-021 4/20/2006 <200 2.36 29, p. 1

3001-022 4/20/2006 <200 2.36 29, p. 1

3001-023 4/20/2006 <200 2.36 29, p. 1

3001-020 4/20/2006 <200 2.36 29, p. 1

3001-017 4/19/2006 <200 2.36 29, p. 1

3001-019 4/19/2006 <200 2.36 29, p. 1

3001-016 4/19/2006 <200 2.36 29, p. 1

3152-009 8/24/2006 <200 2.36 29, p. 1

3001-024 4/21/2006 <200 2.36 29, p. 1

3001-026 4/24/2006 <200 2.36 29, p. 1

3281-004 3/5/2007 <200 2.36 29, p. 1

3001-035 4/27/2006 <200 2.36 29, p. 1

3001-037 5/2/2006 <200 2.36 29, p. 1

3001-048 5/8/2006 <200 2.36 29, p. 1

3001-050 5/10/2006 <200 2.36 29, p. 1

3001-054 5/11/2006 <200 2.36 29, p. 1

3001-052 5/10/2006 <200 2.36 29, p. 1

3001-051 5/10/2006 <200 2.36 29, p. 1

3001-056 5/15/2006 <200 2.36 29, p. 1

3001-057 5/15/2006 <200 2.36 29, p. 1

3001-059 5/15/2006 <200 2.36 29, p. 1

3001-062 5/16/2006 <200 2.36 29, p. 1

3001-067 5/17/2006 <200 2.36 29, p. 1

3001-066 5/17/2006 <200 2.36 29, p. 1

3001-069 5/17/2006 <200 2.36 29, p. 1

3001-070 5/17/2006 <200 2.36 29, p. 1

3001-068 5/17/2006 <200 2.36 29, p. 1

3001-073 5/18/2006 <200 2.36 29, p. 1

3151-006 8/9/2006 <200 2.36 29, p. 1

3151-010 8/9/2006 <200 2.36 29, p. 1

3151-009 8/9/2006 <200 2.36 29, p. 1

3151-001 8/15/2006 <200 2.36 29, p. 1

3152-011 8/28/2006 <200 2.36 29, p. 1

3152-002 8/21/2006 <200 2.36 29, p. 1

3152-010 8/25/2006 <200 2.36 29, p. 1

3152-016 8/30/2006 <200 2.36 29, p. 1

3152-003 8/22/2006 <200 2.36 29, p. 1

3152-008 8/24/2006 <200 2.36 29, p. 1

3152-020 8/31/2006 <200 2.36 29, p. 1

3152-014 8/30/2006 <200 2.36 29, p. 1

3152-015 8/30/2006 <200 2.36 29, p. 1

3152-012 8/29/2006 <200 2.36 29, p. 1

3153-005 9/11/2006 <200 2.36 29, p. 1

3152-013 8/29/2006 <200 2.36 29, p. 1

3153-007 9/12/2006 <200 2.36 29, p. 1

31
32

Sample 

Number Date Collected3 

Distance of 

Population/Resources from 

Area of Observed 

Contamination (feet)2 

Number of 

Resident 

Targets

1

References

3153-008 9/12/2006 <200 2.36 29, p. 1

3153-012 9/13/2006 <200 2.36 29, p. 1

3153-010 9/12/2006<200 2.36 29, p. 1

3153-001 9/6/2006 <200 2.36 29, p. 1

3154-023 9/26/2006 <200 2.36 29, p. 1

3153-004 9/11/2006 <200 2.36 29, p. 1

3153-014 9/14/2006 <200 2.36 29, p. 1

3154-004 9/19/2006 <200 2.36 29, p. 1

3156-022 10/19/2006 <200 2.36 29, p. 1

3154-016 9/21/2006 <200 2.36 29, p. 1

3154-018 9/21/2006 <200 2.36 29, p. 1

3154-002 9/18/2006 <200 2.36 29, p. 1

3154-019 9/25/2006 <200 2.36 29, p. 1

3154-017 9/21/2006 <200 2.36 29, p. 1

3154-014 9/21/2006 <200 2.36 29, p. 1

3156-027 10/20/2006<200 2.36 29, p. 1

3154-015 9/21/2006 <200 2.36 29, p. 1

3154-034 9/28/2006 <200 2.36 29, p. 1

3157-003 10/31/2006 <200 2.36 29, p. 1

3156-035 10/25/2006 <200 2.36 29, p. 1

3157-014 11/6/2006 <200 2.36 29, p. 1

3156-036 10/25/2060 <200 2.36 29, p. 1

3155-004 10/3/2006 <200 2.36 29, p. 1

3155-003 10/3/2006 <200 2.36 29, p. 1

3157-002 10/30/2006 <200 2.36 29, p. 1

3154-035 9/29/2006 <200 2.36 29, p. 1

3154-008 9/25/2006 <200 2.36 29, p. 1

3157-004 10/31/2006 <200 2.36 29, p. 1

3154-022 9/26/2006<200 2.36 29, p. 1

3155-016 10/6/2006 <200 2.36 29, p. 1

3154-029 9/27/2006 <200 2.36 29, p. 1

3154-006 9/25/2006 <200 2.36 29, p. 1

3154-028 9/27/2006 <200 2.36 29, p. 1

3154-033 9/28/2006 <200 2.36 29, p. 1

3154-032 9/28/2006 <200 2.36 29, p. 1

3285-002 5/30/2007 <200 2.36 29, p. 1

3155-008 10/4/2006 <200 2.36 29, p. 1

3157-015 11/6/2006 <200 2.36 29, p. 1

3155-005 10/4/2006 <200 2.36 29, p. 1

3156-014 10/18/2006 <200 2.36 29, p. 1

3156-013 10/18/2006 <200 2.36 29, p. 1

3156-015 10/18/2006 <200 2.36 29, p. 1

3155-010 10/5/2006 <200 2.36 29, p. 1

3157-016 11/7/2006 <200 2.36 29, p. 1

3156-020 10/19/2006 <200 2.36 29, p. 1

3155-031 10/12/2006 <200 2.36 29, p. 1

3155-033 10/13/2006 <200 2.36 29, p. 1

3155-030 10/12/2006 <200 2.36 29, p. 1

3155-019 10/10/2006 <200 2.36 29, p. 1

3155-027 10/12/2006 <200 2.36 29, p. 1

3156-001 10/16/2006 <200 2.36 29, p. 1

3155-026 10/12/2006 <200 2.36 29, p. 1

3156-004 10/16/2006 <200 2.36 29, p. 1

3156-006 10/17/2006 <200 2.36 29, p. 1

3156-007 10/17/2006 <200 2.36 29, p. 1
33

Sample 

Number Date Collected3 

Distance of 

Population/Resources from 

Area of Observed 

Contamination (feet)2 

Number of 

Resident 

Targets

1

References

3156-003 10/16/2006 <200 2.36 29, p. 1

3156-025 10/19/2006 <200 2.36 29, p. 1

3156-008 10/17/2006 <200 2.36 29, p. 1

3156-028 10/23/2006 <200 2.36 29, p. 1

3156-012 10/18/2006 <200 2.36 29, p. 1

3156-034 10/25/2006 <200 2.36 29, p. 1

3156-033 10/24/2006 <200 2.36 29, p. 1

3156-024 10/20/2006 <200 2.36 29, p. 1

3156-030 10/24/2006 <200 2.36 29, p. 1

3156-026 10/29/2006 <200 2.36 29, p. 1

3157-012 11/2/2006 <200 2.36 29, p. 1

3157-010 11/2/2006 <200 2.36 29, p. 1

3157-008 11/1/2006 <200 2.36 29, p. 1

3156-037 10/26/2006 <200 2.36 29, p. 1

3157-009 11/1/2006 <200 2.36 29, p. 1

3157-005 10/31/2006 <200 2.36 29, p. 1

3157-007 11/1/2006 <200 2.36 29, p. 1

3156-031 10/24/2006 <200 2.36 29, p. 1

3157-017 11/8/2006 <200 2.36 29, p. 1

3158-006 11/27/2006 <200 2.36 29, p. 1

3158-003 11/17/2006 <200 2.36 29, p. 1

3158-008 11/27/2006 <200 2.36 29, p. 1

3158-004 11/21/2006 <200 2.36 29, p. 1

3280-023 3/1/2007 <200 2.36 29, p. 1

3280-024 3/1/2007 <200 2.36 29, p. 1

3158-011 11/29/2006 <200 2.36 29, p. 1

3279-017 1/11/2007 <200 2.36 29, p. 1

3280-016 2/22/2007 <200 2.36 29, p. 1

3281-001 3/5/2007 <200 2.36 29, p. 1

3159-001 12/12/2006 <200 2.36 29, p. 1

3159-003 12/12/2006 <200 2.36 29, p. 1

3159-009 12/13/2006 <200 2.36 29, p. 1

3159-010 12/13/2006 <200 2.36 29, p. 1

3159-006 12/12/2006 <200 2.36 29, p. 1

3159-007 12/12/2006 <200 2.36 29, p. 1

3159-014 12/19/2006 <200 2.36 29, p. 1

3279-002 1/4/2007 <200 2.36 29, p. 1

3159-013 12/18/2006 <200 2.36 29, p. 1

3159-015 12/19/2006 <200 2.36 29, p. 1

3280-012 2/26/2007 <200 2.36 29, p. 1

3281-006 3/5/2007 <200 2.36 29, p. 1

3280-021 3/1/2007 <200 2.36 29, p. 1

3281-008 3/5/2007 <200 2.36 29, p. 1

3159-004 12/12/2006 <200 2.36 29, p. 1

3280-002 2/21/2007<200 2.36 29, p. 1

3279-014 1/11/2007 <200 2.36 29, p. 1

3159-008 12/14/2006 <200 2.36 29, p. 1

3159-005 12/12/2006 <200 2.36 29, p. 1

3280-015 2/22/2007 <200 2.36 29, p. 1

3159-012 12/18/2006 <200 2.36 29, p. 1

3280-003 2/21/2007 <200 2.36 29, p. 1

3280-005 2/22/2007 <200 2.36 29, p. 1

3279-009 1/10/2007 <200 2.36 29, p. 1

3279-010 1/10/2007 <200 2.36 29, p. 1

3280-029 3/2/2007 <200 2.36 29, p. 1
34

Sample 

Number Date Collected3 

Distance of 

Population/Resources from 

Area of Observed 

Contamination (feet)2 

Number of 

Resident 

Targets1

References

3279-012 1/10/2007 <200 2.36 29, p. 1

3280-011 2/26/2007 <200 2.36 29, p. 1

3279-016 1/11/2007 <200 2.36 29, p. 1

3281-011 3/6/2007 <200 2.36 29, p. 1

3280-028 3/1/2007 <200 2.36 29, p. 1

3280-017 2/23/2007 <200 2.36 29, p. 1

3280-014 2/26/2007 <200 2.36 29, p. 1

3279-001 1/4/2007 <200 2.36 29, p. 1

3280-027 3/1/2007 <200 2.36 29, p. 1

3285-006 6/7/2007 <200 2.36 29, p. 1

3281-009 3/5/2007 <200 2.36 29, p. 1

3280-025 3/1/2007 <200 2.36 29, p. 1

3281-015 3/6/2007 <200 2.36 29, p. 1

3279-013 1/2/2007 <200 2.36 29, p. 1

3279-004 1/8/2007 <200 2.36 29, p. 1

3279-005 1/9/2007 <200 2.36 29, p. 1

3279-008 1/10/2007 <200 2.36 29, p. 1

3279-006 1/9/2007 <200 2.36 29, p. 1

3280-019 2/23/2007 <200 2.36 29, p. 1

3281-019 3/13/2007 <200 2.36 29, p. 1

3280-010 2/26/2007 <200 2.36 29, p. 1

3281-010 3/5/2007 <200 2.36 29, p. 1

3281-007 3/5/2007 <200 2.36 29, p. 1

3280-030 3/2/2007 <200 2.36 29, p. 1

3281-003 3/5/2007 <200 2.36 29, p. 1

3281-014 3/6/2007 <200 2.36 29, p. 1

3280-031 3/2/2007 <200 2.36 29, p. 1

3282-004 4/2/2007 <200 2.36 29, p. 1

3283-004 4/23/2007 <200 2.36 29, p. 1

3283-008 4/26/2007 <200 2.36 29, p. 1

3285-003 5/31/2007 <200 2.36 29, p. 1

3285-001 5/29/2007 <200 2.36 29, p. 1

Total Number of Residents and Students:

Total Number of Workers:

835.04

24

Not Applicable

Note – 

1 Worker population calculated based on the student to teacher ratio provided on page 1 of Reference 39, 

resulting in a total of 24 teachers for a factor value for workers of 5 (Ref. 1, pp. Table 5-4, 51647). 

2 Please refer to section 5.1.1 of this HRS documentation record.

3 Please refer to the previous table identifying samples meeting observed contamination criteria.

Resident Population Threat Likelihood of

Exposure Factor Category Value: 550
35

5.1.2 WASTE CHARACTERISTICS

5.1.2.1 Toxicity

As previously explained in this HRS documentation record, lead concentrations greater than or equal to 

three times the highest background concentration level have been detected in residential soils in all areas 

of observed contamination (please see pp. 20-30 of this HRS documentation record). 

Hazardous Substance Toxicity Factor Value Reference

Lead 10,000 2, pp. 8, 9

Toxicity Factor Value: 10,000

(Ref. 1, Sections 2.4.1.1 and 5.1.2.1) 

5.1.2.2 Hazardous Waste Quantity

Hazardous Constituent Quantity 

The mass of CERCLA hazardous substances contained in areas of contamination is not known. The 

information available is not sufficient to evaluate Tier A, hazardous constituent quantity, as required by 

Reference 1, Sections 2.4.2.1.1 and 5.1.2.2. 

Hazardous Constituent Quantity Assigned Value: NS 

Hazardous Wastestream Quantity 

The mass of CERCLA hazardous substances, pollutants, and contaminants contained in the areas of 

contamination A is not known. The information available is not sufficient to evaluate Tier B, hazardous 

wastestream quantity, as required by Reference 1, Sections 2.4.2.1.2 and 5.1.2.2. 

Hazardous Wastestream Quantity Assigned Value: NS 

Volume 

The area of observed contamination is not a surface impoundment, drums, or tanks and containers other 

than drums, as required to evaluate Tier C, volume, by Reference 1, Sections 2.4.2.1.3 and 5.1.2.2, and 

Table 5-2. 

Volume Assigned Value: 0

Area

The surface area covered by contaminated soil was not adequately determined for the area of observed 

contamination, but it is greater than zero. As contamination between individual areas of observed 

contamination were not inferred to occur, each sampling location identified as contaminated represents an 

undefined area and an area measurement for the areas of observed contamination could not be 

determined. Therefore, the areas of observed contamination are assigned a value of greater than zero, but 

undetermined.

Area Assigned Value: >0
36

The areas of contamination are assigned a hazardous waste quantity value of greater than zero, but 

undetermined. Thus, a value of 10 was assigned as stated in the HRS Rule (Ref. 1, Sections 2.4.2, 

2.4.2.1, 2.4.2.1.4, 2.4.2.2 and 5.1.2.2).

Hazardous Waste Quantity Factor Value: 10 

(Ref. 1, Section 2.4.2.2)

5.1.2.3 Calculation of Waste Characteristics Factor Category Value

Toxicity Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 10

Toxicity Factor Value x Hazardous Waste Quantity Factor Value: 10,000 x 10 = 1 x 105

Waste Characteristics Factor Category Value: 18

(Ref. 1, Sections 2.4.3 and 5.1.2.3; pp. 51592 (Table 2-7), 51647)
37

5.1.3 TARGETS

Only those individuals whose residence or school is both within said property boundary and within 200 

feet of documented contamination meeting observed release criteria were counted as targets. 

5.1.3.1 Resident Individual

As previously stated in the HRS documentation record, the samples were collected from depths of 0 to 2 

inches below ground surface (bgs) (Ref. 6, p. 8; 7, p. 9). Because typical residential properties in the area 

of concern are less than 200 feet in length and width; all residential properties where soil sample 

analytical results indicate lead contamination significantly above the background level have residents 

living less than 200 feet from areas of observed contamination (confirmed by samples presented in 

section 5.1.1 of this HRS documentation record). While the KDHE RSK for lead (residential scenarios) 

is 400 mg/kg, there is no HRS health-based benchmark for lead in the soil exposure pathway. (Ref. 2, p. 

9; 25, pp. 2, 34). Therefore, due to the absence of a benchmark for lead in soil, Level II was assigned 

(Ref. 1, Sections 5.1.3.1 and 5.1.3.2).

Level of Contamination (Level I/Level II): Level II 

Resident Individual Factor Value: 45

5.1.3.2 Resident Population

5.1.3.2.1 Level I Concentrations

All residents and students located on or within 200 feet of an area of observed contamination, which is 

also located within the property boundary of that residence or school, were counted as Level II targets, as 

no samples were at or above a health-based benchmark. Thus, a Level I Concentrations Factor Value of 0 

was assigned (Ref. 1, Sections 5.1.3.2 and 5.1.3.2.1). 

Level I Concentrations Factor Value: 0 
38

5.1.3.2.2 Level II Concentrations

Areas of observed contamination were established based on a lead concentration of greater than or equal 

to 366 mg/kg (three times the highest background level of 122 mg/kg). Therefore, any residences and 

schools located on or within 200 feet of an area of observed contamination, which is also within the 

property boundary of that residence or school, are subject to Level II concentrations. The resident 

population was determined by tabulating the number of residences and students located on or within 200 

feet of an area of observed contamination, which is also within the property boundary of that residence or 

school, confirmed by samples presented in section 5.1.1 of this HRS documentation record. 

The resident population is based on the average number of persons per household for Allen County, 

which according to the 2010 U.S. Census is 2.36 persons per household (Ref. 29, p. 1). The student 

populations at McKinley Elementary School and Jefferson Elementary School are 136 and 253, 

respectively (Ref. 39, p. 1; 54, p. 1). The summary of targets is presented in the abovementioned tables 

(Ref. 1, Section 5.1.3.2). 

Level II Concentrations Factor Value: 835.04

5.1.3.3 Workers

As stated earlier, the number of workers was calculated on the student to teacher ratio provided in 

Reference 39, page 1 and Reference 54, page 1. Therefore, a value of 5 was assigned (Ref. 1, Section 

5.1.3.3). 

Workers Factor Value: 5 

5.1.3.4 Resources

Description of Resource(s): No resources were identified.

Resources Factor Value: 0

5.1.3.5 Terrestrial Sensitive Environments

No terrestrial sensitive environments were identified.

Terrestrial Sensitive Environments Factor Value: 0

5.2 NEARBY POPULATION THREAT

Nearby population threat was not scored.