### 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 Haza rd 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

a ffect the NPL decisi on.

### 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 Ser ies 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 S 2



### 1. Ground Water Migration Pathway Score (S gw 

### ) 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 (S

sw 

### ) Enter the larger of lines 2a and 2b as the pathway score. Not Scored

3. Soil Exposure Pathway Score (S

s 

### ) (from Table 5

- 1, line 22) 100.00 10,000

4. Air Migration Pathway Score (S

a 

### ) (from Table 6

- 1, line 12) Not Scored

5. Total of S gw 2 

### + S

sw 2 

### + S

s 2 

### + S

a 2 

### 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 EX POSURE 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 Score d 

## (S g 

## ), ( 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 ScoredSource: USGS Allen County, KS 7.5 Minute Topo Quad, 1984X:\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 State

54

East

Madison West 1400Th

Washington 54

54 169

1St Miller

4Th

3Rd Walnut Kentucky

Vine Buckeye 1300Th

Chestnut Dakota

Sycamore

Nevada Broadway Jackson

Spruce

Irwin t

South Garfield Jim

Carpenter

Bruner Ks

1200Th Neosho Lincoln North

Douglas 1600Th

Elm Oak

Washington Cottonwood

Patterson

Edwards

Madison

Rock Willow

Davis West Pryor

Jefferson

Breckenridge Redbud

Calhoun Vermont Henry

High

Tennessee Industrial

Kennedy

Acers Briarwood

Wheeler Clarence

Bennett Benton

Ohio Dewitt

Canary

1700Th Eisenhower

Scott

Park Peach

C a m p b e l l Dewey Cardinal

C o l bo r n F u n s t o n

M e a d o w

b

r o o k Alamosa

Wilson Northrup

Buchanan

Martin Industial Kenwood

Cameron Pra r i ie

Mustang

Buchanan

Colborn

2Nd North

Elm

Spruce Lincoln

Washington White

Spruce

Rock Breckenridge

Vermont Jefferson

Neosho Scott 2Nd

Douglas

Elm

Vine North

Jefferson 1600Th

Oak Tennessee

Monroe 

### ! ( 3396-5 3396-4


### ( ! ! (

3396-3



# n m

White

3281-006



### ( 3280-025

3280-028 

### !

3280-027



# n m 3279-008 

### ! (

3279-009

3001-024



### IMP Boats Inc. 

### ! (

3157-017 3156-034 

### ! (

3283-008

3280-011 

### ! (

! ( 3281-007

3280-002 3280-014 

### ! (

3280-005 3281-009 

### ! (

! ( ! (
! 3156-022 

### ! 3285-003 

### ( (

3001-026 

### ! ( ! ( 3156-031 

### ! ( ! (

3280-019 3279-013 

### ! (

3157-012 

### ! ( ! ( 3155-027 

### ! (

! ( 

# n m 3280-024

3001-070 

### ! (

3001-012 

### ! ( ! ( 3280-010 

### ! ( 3153-001



### ! ( ! (

3156-014 3156-020 

### ! (

3157-007 

### ! (

3280-012 3280-017 

### ( ! ! ( 3155-004 

### ! (

! ( ! ( ! 3279-006 

### ( ! ( 3157-014

3156-028 3001-069 3155-031 3155-003 

### ! ( ! ( 3281-019

3001-037 

### ( ! 3279-017



### ! ( ! ( ! (

! (

3156-027 

### ( 3281-010 3157-015 

### ! (

! ! (

3154-033 3154-032 3156-013

3280-003 3156-015 

### ! (

3158-003 

### ! ( ! (

! (

! ( ! ( ! ( 3158-008 

### ! (

! (

3154-014 3285-001 

### ! (

3280-030 

### ! ( ! ( 3279-004

3153-012

3156-004

3001-073 

### ! (

! ( ! ( ( ! 3152-012



# £ ¤ 54 3281-008 3157-016 3157-005 

### ! ( ! ( ( ! 

# n m

3154-035 3154-019 3156-030 

### ! ( ! ( ! ( ! ( 3001-068 3152-008 3155-026 

### ! ( ! (

3157-002 3155-016 

# n m Eas

3154-029

3282-004



### ! (



# n m 3157-009 3152-006 3156-012 3152-013

3152-010 3155-005 

### ! ( ! ( ! (

3153-008 3154-022 3154-008

3280-015 

### ! ( 3157-010 3281-017 3001-048 

### ! 3281-003 

### ( ! ( ! ( 3153-007 

### ! ( 3156-007



### ! ( ! (

! ( ! (

3283-004 3156-008 

# n m
! ( ( !

3280-031 

### ! ( ! (

! ( 3280-023 3154-023 

### ! ( ! (

! ( 3152-003 

### ! (
! ( ! ( ! ( ! (

! ( ! ( ! (

3152-015 3152-014 3001-056 

### ! (

3001-062 

### ! (

! ( ( !

3157-008

3281-011 3001-016 3151-010 

### ! ( ! ( ! ( ! (

3154-002

3280-016 

### ! (

3280-021 3154-034 3151-001 

### ! ( 3152-016 

### ( ! 3001-059 3001-057



### ! ( ! ( ! ( 3151-009 

### ! ( 3153-005



### ! ! ( ( ! ( ! (

! ( ! (

3153-014 

### ! ( 3152-002 3154-017 

### ! ( 3156-026

3159-015 

### ( 3001-017 

### ! 3001-050 

### ( !

3158-011 3151-006 3154-028


### ! (

3001-019 3153-004 

### ! (

! ( 3152-020 

### ! (

3156-003 3154-006



### ! ( 3156-024 

### ! ( 3159-010 

### ! (

! (

3281-004

3159-003

3154-016

3159-001



### ! (

3159-007

3158-004

3154-004 3157-003

3158-006

3156-025

3156-037

2Nd 3396-2

3396-1 

### ! (

! (



# £ ¤ 169

3155-033 

### ! (

! (

3279-002 

### ! ( ! (
! (

3279-001

3159-009

3156-033 

### ! (
3156-036 

### ! ( 3279-014 3001-051



### ! (

! (

3154-015 

### ! ! ( ( ! (

3279-016



### ! ( ! (

! ( ! ( 3157-004

3001-067 

### ! ( 3001-066 

### ! (
! (

3159-012 

### ! ( ! (

! ( !

(

3279-005 

### ! (
!

! ( 

# n m

( ! (

3155-008 

### ! ( 3159-006

3159-013 

### ! ( 3159-005

3001-029

3285-008

3281-014 3001-021 

### ! ( ( !

! (

3153-010



### ! (

3155-019 

### ! (

3159-014 

### ! ( ! ( ! (

3279-012 

### ! ( 3159-008

3001-020

3159-004 

### ! (

3156-001 

### ! ( ! (

3279-010 

### ! ( Coberly Facili 3001-052

3280-029 Ohio

3001-054

3156-035 

### ! (

! (

Monroe



### ty



# D D

3001-014

3001-022 

### ! ( ! ( 3001-023

3155-010

3001-035 

### ! ( 3154-018 

### ( !

3281-015 K n a a s s 

# n m

3155-030 

### ! (



# D D East Iola Facility

3156-006 

### ! (



# U V 269X:\G\9004\0256\Projects\mxd\Figure2_081312.mxd 

# Source: Allen Co., Kans as 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



# _ ^ ! 

# Lead Resu ts > 366 ppm 

# n m Schools

Former United Zinc #1 Legend

! ( 

# Background location

( 

# l

D 

# Slag Pile
Highway
Major Road

Local Road

Minor Road

Other Road ppm parts per million

County Locator

Site Locator

Allen County

Site Location



# ±

0 600 1,200

Scale in Feet

3281-001 

### ! ( 

# A reas 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 f or 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 pag e. (A complete copy of the Hazard Ranking System can be obtained at the Regional docket upon request. )

2. U.S. EPA. Superfu nd Chemical Data Matrix (SCDM)

. March 2012 . Excerpt. 9 page s. 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. 1 966 . Photo revised 1984. 1 page

.

4. Tetra Tech EM Inc . 2008. Site Inspection R eport for the United Zinc No. 1 Site in Iola, Kansas. January 18. 81 pages. U.S. E PA 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

, Io la, 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 # 3 156 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. EP A 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. Marc h 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. 20 12 . 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. C ity 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 pa ges.

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, Io la, 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. Prepare d 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 pa ges (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. Prelimin ary 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 R esults 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 R esults 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 R esults 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 # 3 280 for the United Zinc No. 1 Site. July 30. 7 pages

.

48. U.S. EPA Region 7 (Barry Evans) . 2012. HRS Analysis R esults 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 R esults 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 R esults 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 R esults 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 an d around the city of Iola, Allen County, Kansas, west of Highway 169, but exclud es 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 t he 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 relat ed 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 historic al 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 Zi nc 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 Io la property , depicted on page 15 of Reference 36, between 1898 and 1925 (Ref. 36, p. 10). T he 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 prope rty, depicted on page 11 of Reference 37, between 1896 and 1918 (R ef. 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, p p

. 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, p p. 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 1920 s (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 Wes tern 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 Inspecti on 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 smelter s 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 th e site generally encompasses the areas of contamination depicte d in Figure s 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 c ity 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 possi ble sources of lead soil contamination identified

other smelters in the area of the c ity 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, p p

. 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 Decemb er 2003. The FFSA identified a Recognized Environmental Condition (REC) at the F ormer United Zinc #1 facility based on observation s 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 Unit ed Zinc #1 facility . In addition, elevated concentrations of lead had been previously documented in the surface soils on the propert ies 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 w ere 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 a nd sediment was conducted during the

Phase II FFSA of the F ormer 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. T he report recommended further sampling to

delineate the horizontal and vertical exte nt 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 F ormer 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 1 8 of the residential samples. In addition, lead

was found above its KDHE RSK level of 4 00 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 complet ed by the KDHE in September 2005. In support of the 2005 RSE, KDHE collected additional samples from sensitive target areas near the

F ormer 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 Mc Kinley 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 a n 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 time

critical 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 a n 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 ran ged 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 appear ed 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 ) stag e 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 plan s 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 200 7 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 PATHWA Y

5.0.1 GENERAL CONSIDERATIO NS

According to the HRS, the soil exposure pathway evaluation is based on areas of observed contamination (Ref. 1, Sect 5.0.1). The individual area s of observed soil contamination at the site w ere 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) , S ite Inspection (S I) , and removal site evaluation field

activities

.

BACKGROUND LEVEL

Additiona l sampling characterization and delineation of the site indicated that sampling locations considered as background during the PA were later determined to be largely contiguous extension s 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 F ormer 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

. V isual 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

. Soi ls 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) 42 31.2012 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 t he background level for the area , as it was the highest of the concentration level s. 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 Mil ligrams 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, a n 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 w ith 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 area s of observed contamination associated with the

site.

Contaminated Samples

For scoring purposes, only c ontaminated 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, p p . 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, t he 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 smelter s that operated in and around Iola, Kansas as possible origins of the lead soil contamination. T he 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 le ad (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, s outheastern 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 document ed 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 o f 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 Hig hway 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 s melter 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

o perating 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 contain ing lead up to 21,167 mg/kg has been observed on the Coberly smelter prope rty (Ref. 8, p. 17).

Accordin g 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 own ed 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, p p. 5, 6 ; 35, p p . 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. T he 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. 4 2 , p. 5). Other investigations conducted in 1993 and 1997 also identified high

concentrations of lead in the soil of th e IMP Boats property (Ref. 4 2 , p. 6).

T he 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 b ased on the following:

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

(2) the presence of highly contaminated soils at the F ormer United Zinc #1 facility (and extension into nearby properties

- see Figure 2 of this HRS documentation r ecord ) and the Lanyon #1 and #2 smelter properties (IMP Boats property) ; and

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

cause d 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

. I n 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 contact ed 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 variabi lity for Allen County, Kansas . For example, during the 1901

- 1905 time period , the wind direction was predominantly moving in a northeastern direction. W hile 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 o f Exposure

Individual, discrete area s of observed contamination w ere 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 s ample locations were plotted in the residential field screening form s (see Reference 40 pages 5, 7 and Appendix H) a nd also

recorded with global positioning system coordinates during sampling events

. As per the sampling methodology and evidenced by proper ty screening forms (referenced for each sampling location in the table below), a ll 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 requirement s for establishing observed contamination.

## 21 TABLE 2: Area of Observed Contamination Samples

Sample

Number EPA Property ID Date and Depth 2 Lead Result (mg/kg) S ample Q uantitation L imit (mg/kg) 3 References 1 , 4

3285

- 008 2 June 2007 (lab analyzed sample on 07/13/2007) 1

, 180 5.5 40, pp. 516, 519, 52 5 ; 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) S ample Q uantitation L imit (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) S ample Q uantitation L imit (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 8/24/2006 1

, 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 8/30/2006 1

, 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 8/29/2006 1

, 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 8/29/2006 1

, 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, p p

. 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 10/19/2006 1

, 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) S ample Q uantitation L imit (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 9/21/2006 1

, 140 1.17 40, pp. 398, 403, 1053; 20, p. 3

3154

- 034 468 9/28/2006 1

, 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 11/6/2006 1

, 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 9/29/2006 1

, 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, p p

. 1

- 2

3154

- 028 567 9/27/2006 1

, 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) S ample Q uantitation L imit (mg/kg) 3 References 1 , 4

3154

- 033 591 9/28/2006 1

, 230 1.15 40, pp. 398, 408, 812; 20, p. 5

3154

- 032 593 9/28/2006 2

, 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 11/6/2006 3

, 980 6.17 40, pp. 442, 447,

1221

- 1222; 15, p p

. 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 10/18/2006 1

, 360 6.13 40, pp. 426, 432, 813; 14, p p

. 3

- 4

3155

- 010 659 10/5/2006 785 5.39 40, pp. 412, 416, 1270; 13, p p

. 2

- 3

3157

- 016 668 11/7/2006 665 5.99 40, pp. 442, 447, 1277; 15, p. 4

3156

- 020 692 10/19/2006 1

, 470 5.85 40, pp. 426, 433,

1304

- 1305; 14, p p . 4

- 5

3155

- 031 694 10/12/2006 521 5.92 40, pp. 412, 421, 1307; 1 3 , 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, p p . 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 10/16/2006 1

, 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) S ample Q uantitation L imit (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, p p . 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 10/24/2006 1

, 050 5.75 40, pp. 426, 436, 1428; 14, p p . 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) S ample Q uantitation L imit (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 12/13/2006 1

, 020 6.32 40, pp. 460, 464, 1740; 44, p p

. 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 1/4/2007 1

, 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, p p . 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) S ample Q uantitation L imit (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 12/12/2006 1

, 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 2/22/2007 1

, 070 5.9 40, pp. 477, 482, 1967; 47, p p . 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 2/22/2007 1

, 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, p p

. 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) S ample Q uantitation L imit (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, p p

. 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 1/9/2007 1

, 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, p p

. 2-

3

3281

- 010 1462 3/5/2007 1

, 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, p p . 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 3/2/2007 1

, 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 Depth 2 Lead Result (mg/kg) S ample Q uantitation L imit (mg/kg) 3 References 1 , 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

- 45 8 ), 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 315 7 (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, Appendi ces D and G respectively for relevant samples

.

### TABLE 3: School and Residential Samples

Sample

Number Date Collected 3 Distance of Population/Resources from

Area of Observed Contamination (feet) 2 Number of

Resident Targets 1 References

3285

- 008 (McKinley Elementary School) June 2007 (lab analyzed sample on 07/13/2007) <200 1 36 (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 Collected 3 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 Collected 3 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 Collected 3 Distance of Population/Resources from

Area of Observed Contamination (feet) 2 Number of

Resident Targets 1 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

2 4 Not Applicable



### Note
– 1 Worker p opulati on calculate d 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, p p. 8, 9

Toxicity Factor Value: 10,000 (Ref. 1, Section s 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, Section s 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 k nown. The information available is not sufficient to evaluate Tier B, hazardous wastestream quantity, as required by Reference 1, Section s 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, Section s 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 area s of observed contamination could not be

determined. Therefore, the areas of observed contamination are assigned a value of greater than zero, but

undeter mined.

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 10 5



### Waste Characteristics Factor Category Value: 18 ( Ref. 1, Section s 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 document ed 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 samp le 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, p p . 2, 34). Therefore, due to the absence of a benchmark for lead in soil, Level I I was assi gned (Ref. 1, Section s 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 Val ue of 0 was assigned (Ref. 1, Section s 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 20 1 0 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 1 36 and 2 53

, 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.