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SDMS Document ID

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2020191

Lake County Community Health

Program

Independent Review Panel

Responses to Key Issues/Questions

December 3, 2003

Prepared for:

CDPHE

LCCHP Work Group

Lake County Health Department

U.S. Environmental Protection Agency

Prepared by:

Conlin Associates: Resource Planners

875 Mountain View Dr.

Leadville, CO 80461

(719)486-2772
Lake County Community Health Program

Independent Review Panel

Responses to Key Issues/Questions

Contents

Introduction /

The Panel i

Nelson Ames

Thomas S. Dunlap v

Nick FanJoe Graziano vi

Facilitator

Michael Conlin vii

Panel Preparation viii

Presentations / Site Tour ix

Independent Review Work Session and Report ix

Responses to Key Issues/Questions 1

I. LCCHP Implementation 2

Consistency with Work Plan

Organization & Structure

Program Administration / Work Group 3

Community awareness, education & recruitment 4

Interactions & Coordination 5

Environmental testing program

Blood Lead testing program 6

Data management, evaluation, reporting

Implementation of Response Actions 7

Documentation & Reporting

II. Evaluation of Performance 9

Rationale for Performance Standard

Long Term effectiveness

Type I, Type II Errors 10

Uncertainty P-10.P-15

Representativeness
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Contents, continued

I Test of Proportions 11

' Residual Risk

I HI. Annual Report 12

Compliance with Requirements of the Work Plan

Evaluation of Performance Standards

I Recommended additional data 13

Unnecessary Elements

Streamlining the Annual Report

* IV. Other 14

— Long Term Protection of Human Health

I Tools and Information provided to Panel 15

• Summary of Panel Recommendations 16

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Lake County Community Health Program

Independent Panel Review

INTRODUCTION

In September of 1983, the California Gulch Superfund Site was placed on the National

Priority List for investigation and cleanup under CERCLA. In a settlement between the

Potentially Responsible Parties (PRP's) reached in Federal District Court in 1994, the site

was divided into 12 Operable Units (OU's), and responsibility for "source area" cleanup

was assigned to respective PRP's for each OU. In the settlement, ASARCO Inc. agreed to

conduct clean-up work in OU-9, generally described as the residential areas in and

around the City of Leadville. In that same year, ASARCO established a trust fund to

cover the costs associated with implementing the remedy for OU-9.

In 1995, ASARCO initiated the "Kids First" program as an interim response to lead risk

reduction in OU-9. The pilot program was designed to be voluntary, and to address

multiple potential lead exposure pathways (e.g. soils, household dust, interior and

exterior paint, and water) in residences with young children and/or pregnant women.

In September of 1999, the Record of Decision (ROD) was issued for OU-9, and the

selected remedial action was a continuation and expansion of the Kids First Program,

under the new name, Lake County Community Health Program. While the program

remained voluntary, clean-ups were no longer limited to residences with children and/or

pregnant women. Given the unique aspects of the remedy, a provision of the ROD

required the evaluation of the selected remedy "by a group of outside scientists."

That evaluation took place on October 30th and 31st, 2003. The Independent Panel

consisted of the following experts:

THE PANEL

NELSON G. AMES

Medical Health Officer responsible for population health

Interior Health Authority

Kootenay Health Service Area

Nelson, BC

EDUCATION

MHSc (Master, Health Sciences)

University of British Columbia

Vancouver, BC 1989

FCFP (Fellow, College of Family Physicians)

Honour Award 1982

CCFP (Certification in Family Medicine)
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McMaster University

Hamilton, ON 1975

M.D. McMaster University

Hamilton, ON 1973

B.Sc. McMaster University

Hamilton, ON 1970

EXPERIENCE

January 2002 to present

Medical Health Officer responsible for population health

Interior Health Authority

Kootenay Health Service Area

Nelson, BC

January 2001 to January 2002

Medical Health Officer

Kootenay Boundary Community Health Services Society

Nelson, BC

April 01/97 to January 2001

Chief Executive Officer/Medical Health Officer

Kootenay Boundary Community Health Services Society

Castlegar, BC

September 1989 to March 31, 1997

Director/Medical Health Officer

Central Kootenay Health Unit

Castlegar, BC

Ministry of Health, British Columbia

1976-1988

Family practice

Nelson, BC

Hospital privileges - Kootenay Lake District Hospital

ACTIVITIES WHILE IN PUBLIC SERVICE

Member

City of Trail Health and Environment Committee

2001 to present

Member

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Trail Lead Task Force to Reduce Childhood Lead Exposure

_ Completed in 2001

Chairperson 1998-2000

• Medical Health Officer's Council of BC

Member

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Stage II Research Proposal Review Committee

BC Health Care Research Foundation

1996 - 2000

Adjunct Professor

University of British Columbia

Department of Health Care and Epidemiology

Member

Executive Director's Standing Committee on Environment & Health 1995-97

• Faculty of Medicine

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Chair

Environmental Health Committee

Health Officer's Council of BC 1995-97

' Member

Soil Management Task Force

• Ministry of Environment, BC - completed spring 1992

Member

• Federal/Provincial Advisory Committee on Environmental and Occupational

• Health -

Lead Working Group

• Health and Welfare Canada - completed fall 1991

_ Member

I Canadian Public Health Association and BC Chapter since 1988.

PAST ASSOCIATIONS

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Member

Education Committee - BC Medical Association 1978 -1986

Chairman 1983 -1986

| Canadian Medical Association Council on Education 1983 -1986

Canadian College of Family Physicians

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THOMAS S. DUNLOP

President: Dunlop Environmental Consulting, Inc.

Tom has been involved in Environmental Public Health in Colorado since 1970. His first

job was with Larimer County as an Environmental Health Officer and concluded as

Director of the Pitkin County Environmental Health Department. His retirement in 2001

from public service launched a new career as President of Dunlop Environmental

Consulting, Inc. During his years in public service his accomplishments were recognized

with numerous awards from various local, state and federal agencies. He has spoken on

many public health issues at venues reaching from neighborhood meetings of concerned

citizens to the Congress of the United States. Tom continues to be a champion for public

health through volunteer service to various associations and agencies. The focus for his

company is "Environmental and Public Health Planning for the Future." His motivation

is to continue contributing for the betterment of human health and a sustainable

environment.

Tom was the chief City of Aspen and Pitkin County technical representative for over 18

years working with citizen groups, the scientific community, and all levels of government

to resolve issues surrounding the Smuggler Mountain Superfund Site. This assignment

extended from initial contact with federal officials through de-listing of the Site. He

currently is a peer advisor with the National Association of County and City Health

Officials in their superfund program. Tom visited and advised communities facing

challenges generated by having a superfund site in their jurisdictions. He was a

contributing source to two publications designed to assist response actions of cities and

counties confronted with trials of the superfund program. He testified before Congress by

invitation on superfund reform.

NICK FARR

Executive Director

National Center for Lead-Safe Housing

Columbia Maryland

Nick Farr is the founder and Executive Director of the National Center for Lead-Safe

Housing in Columbia, Maryland. Mr. Farr has had a long and distinguished career in both

the public and private sector. Much of his professional experience has been centered on

housing finance, non-profit housing initiatives, housing and urban development and

rehabilitation, and housing based lead poisoning prevention. A Phi Beta Kappa graduate

of Yale College, Mr. Farr also graduated from Yale Law School, where he served as

editor of the Yale Law Journal.

During the 1950's and early 1960's, Mr. Farr practiced law in New York City and New

Haven Connecticut, focusing on federal taxation and zoning and urban development. He

also was a visiting lecturer at the Yale Law School during the period. In 1962, Mr. Farr

joined the Agency for International Development in the U.S. Department of State as

Deputy Assistant Administrator for the Near East and South Asia economic assistance
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programs. In 1967 President Lyndon Johnson appointed him Director of the Model Cities

Administration in the U.S. Department of Housing and Urban Development.

During the 1970's, Mr. Farr was a Professor at the New York University Law Center

before joining the U.S. Department of Commerce in 1977 as General Counsel to the

Economic Development Administration. In 1979, Mr. Farr was appointed General

Deputy Assistant Secretary for Community Planning and Development in the U.S.

Department of Housing and Urban Development. During the early and mid 1980's, Mr.

Farr was Executive Director of the California Housing and Finance Agency, and then

Executive Vice President of the Wells Fargo Mortgage Company in California.

In 1986, Mr. Farr joined the Enterprise Foundation in Columbia, Maryland, as Vice

President for Field Services. During his tenure with Enterprise, Mr. Farr worked with and

served on the Board of Directors of a local nonprofit housing developer in Baltimore: this

organization was attempting to create affordable housing units that had been treated for

lead based paint hazards. As a result of this affiliation and his accumulated professional

experience, Mr. Farr conceived of and created the National Center for Lead-Safe Housing

in 1992.

The Center, a national nonprofit organization whose mission is to help sharply reduce

childhood lead poisoning and preserve affordable housing, is engaged in research, public

policy advice, and technical assistance aimed at investigating, validating and promoting

lead-safe housing concepts and standards.

Mr. Farr is a nationally recognized expert and has been instrumental in helping

implement a variety of public and private initiatives to protect children from residential

lead hazard exposures. He also served as a committee chairman on the Federal Leadbased Paint Hazard Reduction and Financing Task Force, providing leadership and

guidance for the creation of recommended lead-safe property standards. Mr. Farr was the

recipient of the Huntington S. Williams Award.

JOSEPH H. GRAZIANO, Ph.D

Associate Dean for Research

Professor of Environmental Health Sciences

Mailman School of Public Health

Professor of Pharmacology

College of Physicians & Surgeons

Dr. Graziano's areas of interest include: a new drug for childhood lead poisoning;

environmental lead exposure; pregnancy outcome and infant development; iron, metals

and neurodegenerative diseases.

Many diseases result from gene-environment interactions. Metals - both essential

minerals and non-essential heavy metals - appear to be involved in many disease

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processes, most notably in the central nervous system (CNS). Dr, Graziano's laboratory

is primarily interested in the consequences of metal exposure on the CNS, and is involved

in studies of both early childhood development and neurodegenerative diseases in the

elderly. A basic premise is that drugs and/or diet can be utilized to alter disease process

attributable to metals.

For example, his laboratory developed highly effective oral medication for the treatment

of childhood lead poisoning. The drug, 2,3-dimercaptosuccinic acid (DMSA, or

Succimer), was approved by the Food and Drug Administration in 1991. Other studies

concerning environmental lead exposure encompass a field of environmental

epidemiology, and have elucidated the consequences of lead exposure (and iron

deficiency) on pregnancy outcome and early childhood development. Other work has

utilized the technique of stable isotope dilution to experimentally determine in humans

the bioavailability and toxicokinetics of lead from a variety of dietary and environmental

matrices.

Most recently, the lab turned its attention to the general hypothesis that genetic alterations

in essential mineral metabolism may play a role in neurodegenerative diseases such as

Parkinson's Disease and Alzheimer's Disease. In collaboration with Dr. Richard

Mayeaux, a neuroepidemiologist and Director of the Sergievsky Center, case-control

studies of these diseases are exploring the environmental and genetic components of

disease.

FACILITATOR

Michael Conlin

Principle, Conlin Associates: Resource Planners

Mike Conlin is the Principle of Conlin Associates, a Leadville based consulting firm

specializing in consensus building and environmental planning. Mike commonly

facilitates multi-disciplinary teams and diverse public / private sector groups in projects

ranging from environmental assessments to community based master plans. Mike's

diverse client base has included, but is not limited to:

U.S. Forest Service

U.S. Bureau of Land Management

U.S. Environmental Protection

Agency

US Fish & Wildlife Service

City of Aurora

Lake, Eagle, and Summit Counties

Colorado Department of Natural

Resources

Balcor American Express

Union Pacific Railroad

ASARCO Inc.

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A resident of Leadville, Mike is knowledgeable in the cultural and economic issues

facing the community, and the history of the Superfund process as it has evolved over the

past two decades. His work in the Lake County region has included: Planning and public

facilitation of the Mineral Belt National Recreational Trail project, an 11.6 mile

interpretive bicycle trail located entirely within the California Gulch Superfund Site;

preparation of the tri-county Corridor Management Plan for Top of the Rockies National

Scenic and Historic Byway; and facilitation of the Lake County Open Space Initiative, a

collection of 25 local, state, and federal agencies, municipalities, and organizations

responsible for securing and master planning over 8600 acres of land as open space in

Lake County.

Mike has also worked with Lake County, ASARCO, Resurrection Mining, and the U.S.

EPA in the facilitation of the grassroots participation, and the preparation of the Lake

County Cultural Resource Preservation Plan, Lake County Interpretive Sign Plan, and

the Mineral Belt Trail Interpretive Sign Plan.

PANEL PREPARATION

Prior to convening the Panel, each participant was provided with background

information, including but not limited to:

• Work Plan for the Lake County Community Health Program

Operable Unit 9

Residential Populated Areas

California Gulch Superfund Site

December 2000

• Methods and Standards for Evaluating the Performance

Lake County Community Health Program (LCCHP)

July 2002

• Memorandum: Revised Leadville Kids First Program Report

1994 - 1999 Progress and Results

February 28,2001

• Memorandum: Supplemental Data from the

Lake County Community Health Program

October 17,2003

• 2001 Annual Report

Lake County Community Health Program

OU-9 - California Gulch Superfund Site - Leadville, Colorado

August 19,2002

• Lake County Community Health Program

2002 Annual Report

August, 2003

• Record of Decision for Operable Unit-9, EPA, Sept, 1999

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PRESENTATIONS / SITE TOUR

The Panel met with representatives of the U.S. EPA, ASARCO, Lake County, City of

Leadville, Colorado Department of Health and Human Environment, Lake County Public

Health Department, MFG Inc. (ASARCO's Consultant,) and the Lake County

Community Health Program on October 30th, in Denver Colorado. Presentations made by

representatives of EPA, CDPHE, LCHD, MFG, ASARCO, and the Work Group, covered

the following topics:

• Purpose of the Panel

• Background of the Site Program

• Why this Program? A Regulators Perspective

• Kids First Program: Overview

• Functioning of the WorkGroup

• Education, Community Awareness, and Recruitment

• Data Management

• Program Evaluation

• Environmental Program

On October 31st, participants met with Panel members in Leadville for a site tour of

Operable Unit-9 of the California Gulch Superfund Site, followed by presentations on:

• The Blood Lead Program

• Staffing

• Case Management

Time was allotted for Panel questions and a wrap-up session, after which the Panel and

Facilitator reconvened for the Independent Review Work Session.

INDEPENDENT REVIEW WORK SESSION AND REPORT

The facilitator and Panel met in closed session on the afternoon of October 31st, with the

task of responding to a specific list of questions and issues regarding the implementation

of the Work Plan, the performance of the LCCHP, the adequacy of the annual report, and

the request for any other issues or recommendations that would help to ensure the long

term protection of public health and reduce lead risk sufficiently to meet and maintain the

Remedial Action Objectives (RAO's) of the Work Plan.

Each issue or question was brought to a consensus opinion that represented the expertise

and knowledge of the assembled group.

A First Draft of the Responses to Key Issues / Questions was prepared and circulated

amongst the Panelists. Comments and recommendations were received and incorporated

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into a second, red-line draft, to visually highlight changes suggested by individual Panel

members, and the document was again circulated to participants for review and comment.

Based on the Panel's input to the second draft, a final draft of the Responses to Key

Issues / Questions was prepared and forwarded to all Panel Members for review and

concurrence. Consensus was reached as to the adequacy of the report, and approval was

granted by all members of the Panel to submit the document as written.

The document that follows, entitled Lake County Community Health Plan, Independent

Review Panel Responses to Key Issues / Questions, represents the culmination of that

effort, and compliance with the ROD provision for review of the LCCHP by an

independent panel of experts.

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Independent Review Panel

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LAKE COUNTY COMMUNITY HEALTH PROGRAM

INDEPENDENT REVIEW PANEL

RESPONSES TO KEY ISSUES/QUESTIONS

The Independent Review Panel was tasked with preparing a written report detailing their

findings and recommendations developed through the review of the program. The Lake County

Community Health Program (LCCHP) Work Group prepared a list of questions and issues to

solicit input from the review panel on specific aspects of the program. The Work Group

requested that the panel's final report be divided into sections corresponding to the headings

provided in that document, followed by responses to the specific questions posed, and any other

feedback the review panel would like to provide.

The following report provides a compilation of responses to the questions raised, and the Panel's

recommendations to further improve the implementation and effectiveness of the program.
Lake County Community Health Program

Independent Review Panel

Responses to Key Issues I Questions

I. LCCHP Implementation

Based on the Panel's review of the LCCHP Work Plan and the Program's operations to date,

please address the following:

LI Is the Program being implemented in a manner consistent with the design presented in

the Work Plan?

Panel Response

The Panel was in full agreement that the Program is being implemented in a manner

consistent with the design presented in the Work Plan.

1.2 Please provide any suggestions or recommendations you may have for improving the

structure (i.e., organization, responsibilities and internal communications) of LCCHP

management and administration.

Panel Response

Based on a preliminary review of the written documentation provided to members of the

Panel, there had been an initial concern that the Program was unduly cumbersome as a

result of the number of entities responsible for individual plan elements such as blood

lead testing, environmental sampling, remediation, and work plan oversight. Members of

the panel were prepared to suggest that placing all components of the work plan under a

single entity might streamline the time line from initiation through remediation.

Over the course of the presentations, the Panel gained a better understanding of the

complexities of the process, and of how the various entities interacted in a system of

checks and balances to ensure compliance with the design of the Work Plan.

Panel consensus following the presentations is that the LCCHP has created a lead risk

reduction program that is both unique and effective largely due to: a) effective current

EPA project management; b) the flexibility of EPA Region 8 to allow exploration of new

and innovative approaches; and c) a respect for the local culture and attitudes. The

willingness to look beyond the initial consent decree mandate to address lead in

residential soils, to include investigation of a broader spectrum of potential human health

hazards, provides a greater level of protectiveness for the children and residents of Lake

County.

The Panel also lauds the personal commitment, enthusiasm, and dedication of the key

members of the project implementation team. The success of a plan is often determined

by the day-to-day effort and continuity provided by those on the front line. This effort

should be nurtured and rewarded.
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Conversely, the dependency of the program on the knowledge and experience of key

individuals points out the fragile nature of the team in the event that one of them leaves

and there is no reasonable way for another person to step in without compromising the

project. The results of just such a lag were witnessed with the temporary loss of the

Public Health Nurse, and the commensurate drop in program recruitment.

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• The Panel recommends that cross training and preparing for the inevitable time

when one of the key players leaves the program should be addressed.

• The Panel recommends the extension of the Team approach to more actively

involve members of the local public and increase community "ownership" of both

the problem and its solutions.

o One example could be the use of "Champion Moms", mothers of children

who have been involved in the program and understand, first hand, its

benefits. As part of the outreach effort, they could provide a "neighbor to

neighbor" approach that may be effective within a certain segments of the

community, helping to identify and involve that element of the population

that is currently not being considered in the statistical base.

o Bi-annual or quarterly public meetings could also be held to engage and

involve the Board of Commissioners, Mayor, City Council, Chamber of

Commerce, School Board, student representatives, the press, and parents

in the recruitment and public education process, and to share in the pride

of having responded positively to an identified problem.

1.3 In providing your feedback with respect to the implementation of the Program, please

consider these specific components of the Program design:

L3a Program administration and Work Group operations;

Panel Response

The Panel has observed that the Work Group is clearly dedicated to the task at hand, and

has required, and received, a high level of detail and accuracy from project staff. The

effort is well organized, and has made good use of criteria to set priorities.
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1.3b Community A wareness, education, and recruitment activities

Panel Response

The Panel has observed that Leadville does not appear to be a unified community, but

rather, represents a fragmented population that has evolved in response to changing socio

economic forces, including shifts in economic base, ethnicity, and population

demographics. As such, identification of the key population segments, and specific

tailoring of outreach efforts to engage these segments in the program, would be

considered advantageous.

Community awareness and recruitment efforts appear to be good, but might be improved

by the following recommendations:

• The use of "Champions", or neighborhood volunteers, who are well informed, self

motivated, and empowered with the task of contacting and encouraging friends

and neighbors who have not responded to existing outreach efforts, to participate

in the program.

• The use of trained, temporary paid staff, to go door to door in a concerted effort to

reach every resident of SU-1 on a one-on-one basis, to provide information,

answer questions, and encourage participation in the program. This aspect of the

program should involve consultation with an epidemiologist, such as Dr.

Bornshein, to help design a door-to-door outreach survey.

• Consideration should be given to sending a once a year reminder of the program

to everyone in SU 1, with a one-on-one follow-up visit

• The Panel recommends consultation with people knowledgeable about

community assessments to develop an evaluation of public needs. This

consultation should solicit input to determine whether identified segments of the

population are getting what they want or need out of the program.

• The use of "key informants" who can represent the common needs, concerns, and

desires of identified segments of the population. This can include community

leaders, or trusted individuals within the specific population segment.

From the Panels' experience, public education is a necessary element of an integrated

remediation plan, but in and of itself, is not sufficient to resolve the problem. The Panel

feels that the LCCHP has done a fine job in educating parents on the findings and

implications of the blood lead level sampling. Reliance on efforts to educate parents on

methods of cleaning, personal hygiene etc. are not, however, considered to be an

adequate substitute for aggressive control or elimination of environmental hazards in

lowering blood lead levels. Research has found that such an education program has little

or no effect on children's blood lead levels even if it includes multiple home visits and

provision for cleaning materials.
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The Panel's primary area of concern lies not in LCCHP compliance with the standards, as

written in the work plan, but with the standards themselves, most specifically, the trigger

levels for lead based paint hazards. Since a critique of the Standards is not a part of the

requested Scope of Work, comments will- be reserved for Section IV, which requests

other feedback for ensuring long-term protection of public health.

L3c Interactions with Program participants and coordination between environmental

testing and blood lead programs;

Panel Response

The Panel feels that the Working Group is the appropriate mechanism for merging the

blood lead and environmental elements of the plan, authorizing environmental responses,

and for monitoring the day-to-day interactions. The result has been a seamless and

effective implementation of the Work Plan.

I.3d Environmental testing program and procedures;

Panel Response

The Panel shared a high level of comfort that the methodology and implementation of the

soil-testing program was effective in meeting the standards of the Work Plan, and in

identifying potential health hazards.

• The Panel recommends that drip line testing be emphasized in the soil sampling

regime to help determine the presence and influence of soil lead from deteriorated

external lead based paint sources.

The Panel was similarly comfortable with the approach and methodology of determining

(and responding to) lead in the potable water supply.

With regard to the identification of lead based paint hazards, the Panel is comfortable that

the testing procedures are in compliance with the standards set forth in the work plan. As

previously indicated, the Panel is also in agreement that the trigger level for aggressive

control and elimination of 6mg/cm2, as dictated by the Work Plan, is too high.

Panel members expressed concern that the three-sample method currently in use for

testing house dust is not sufficient to identify hazards or provide house-wide clearance.

• The Panel recommends that the Program follow protocols described in EPA 402

Regulations, and that entryways always be tested.
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1.3e Blood lead testing program and procedures;

Panel Response:

The Panel was comfortable with the methodology and implementation of the blood lead

level testing, and with the procedures for sampling and documentation. Panel members

did not feel that waiting until a child is 12 months of age to begin recruitment into the

LCCHP was ideal, and would encourage blood lead level testing starting at age 9 months.

The Panel recognizes that the act of drawing blood from children under the age of 12

months is difficult and could be perceived as causing trauma and loss of follow-up, but

recognizes that the problem of elevated blood lead levels begins to manifest itself in a

quantifiable manner at about the age of 9 months.

• The Panel recommends the use of a professional phlebotomist to gather samples

on children under the age of 12 months of age. While it can be more expensive, it

is considered to be less painful and time consuming than a heel or finger prick.

Early intervention with newboms is important because parents are generally more

attentive and interested in their new charge. Early detection leads to early

response and remedy.

I.3f 'Data management, evaluation, and reporting practices;

Panel Response:

The Panel believes that the data management procedures practiced by the program are

sound, and provide for a system of checks and balances of key variables.

Given the amount of information being collected, the Panel also feels that the data-base is

being under-utilized, and encourages the Program to make greater use of the full data set

in its analysis and evaluation, in order to better understand which lead hazards are the

principal sources of exposure to children. To this end, the Panel makes the following

recommendations:

• i. Since the percentage of children with blood lead concentrations greater

than 10 and 15 ug/dl has not changed in three years, it appears quite possible that

there may be risk factors that are not currently adequately addressed in the

ongoing remediation strategy. Use of a multi-variate regression method to better

understand the determinants of elevated blood lead in Leadville may lead to

possible modifications of the existing remediation plan to facilitate the

achievement of the plan's objectives. A broader range of variables could be

evaluated using data already collected. Examples include: lead based paint, paint

and floor condition, dust, presence of pets, vinyl mini-blinds, behaviors, etc. This

issue is discussed further in the Panels recommendations for meeting performance

standards criteria in Statistical Unit 1.
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ii. The annual report reflects blood lead levels as a function of a number of

variables, such as age, neighborhoods, etc. Consider linking annual reporting to

previous years to demonstrate trends of blood lead levels over time, as a function

of multiple variables.

iii. GIS is a powerful mapping and analytical tool for graphic and spatial

representation of data. It is strongly urged that a GIS system be implemented by

Lake County, to allow for the special tracking of children with elevated blood

leads. It appears possible that "hot spots" of exposure, possible targets for

recruitment/remediation, may be unveiled in this manner.

iv. Make the results of dust and lead based paint in reports more readily

observable.

v. Split the collected sample base at the mean rather than at the P-10 or P-l 5

levels to increase the statistical power of the analysis, and to provide a reference

group that falls below the mean for comparing and targeting key differences. This

issue is discussed further in the Panels recommendations for meeting performance

standards criteria in Statistical Unit 1.

vi. Consider testing for representativeness of lead based paint hazard .as well

as soil lead.

vii. Use the suggested analytical strategy to evaluate and improve the program

and more effectively target the basic problem areas.

I.3g Implementation of response actions

Panel Response:

The Panel was unanimous that the implementation of response actions was good, and

followed the standards of the work plan.

I.3h Documentation and reporting practices

Panel Response:

The Panel felt that the documentation and reporting practices were satisfactory to meet

the standards of the work plan, and has no additional recommendations.

1.4 Statistical Unit 1 has not met the performance standards criteria; please provide any

additional implementation recommendations that could be considered by the Work Group to

meet these standards.

Panel Response:

Review of trends in P-10 and P-l5 in both Statistical Unit 1 and Statistical Unit 2

indicates that while the mean blood lead concentration in Leadville is declining over
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Responses to Key Issues I Questions

time, as is the national trend, the percentage of participants with blood lead levels greater

that 10 and 15 ug/dl, respectively, has not significantly changed over time. This implies

that there is a "tail" at the high end of the blood lead level distribution that has not

responded to the current interventions.

• The Panel therefore recommends that every effort be made to better understand

the determinants (or predictors) of blood lead; variables of interest might include

housing type, child age, behaviors, pets, and the presence of anemia. Since the

absolute number of children with elevated blood leads is small, one possible

approach would be to divide the overall sample of children into two groups, i.e.,

those with blood leads above and below the mean. The increase in analytical

sample size provided by selecting the mean as a cutoff rather than P-10 or P-15

blood lead level triggers, increases the statistical power and may reveal which

determinants of blood lead in the multi-variate regression are causing the "tail"

that is not responding to the current interventions.

The Panel also refers the reader to the recommendations for increasing public outreach

listed earlier, and the recommendations for ensuring long-term protection of public health

listed under Section IV, Other.
Lake County Community Health Program

Independent Review Panel

Responses to Key Issues I Questions

II. Evaluation of Performance

Based on the Panel's review of the 'Methods and Standards for Evaluating the Performance

of the Lake County Community Health Program' document (the 'Performance Standards

Document') and the evaluation of data from the years 2000, 2001, and 2002, presented in the

2002 Annual Report, please address the following:

II.l Please comment on the appropriateness and applicability of the statistical methods and

standards presented in the Performance Standards Document for evaluating the performance

of the Program with respect to the established Remedial Action Objectives.

La Is the rationale for each performance standard adequately described, appropriate, and

scientifically defensible?

Panel Response:

The Panel believes that the rationale for the establishment of standards has been

adequately described in the Performance Standards Document. The Panel considers the

standards, as described in the document, to be reasonable but arbitrary, as they do not

mirror National standards (e.g. soil lead level of 3500 ppm and lead based paint at

6mg/cm2).

The Panel believes that the performance standards for meeting the Remedial Action

Objectives are appropriate. The Panel does not feel that the term "scientifically

defensible" is appropriate within this context and, therefore, offers no response to this

query.

The Panel also notes the absence of a critical path or timeline for completion as part of

the Performance Standards. Inclusion of a timeline would be considered normal practice

in such a document.

Lb Does the method adequately demonstrate the long-term effectiveness of the remedy and

compliance with RAOs?

Panel Response:

The Panel feels that this is a critical question that cannot be answered at this time, and cites

the following reasons:

1. There is not enough long term data available at this point

2. P-10 and P-15 values have not changed significantly in either SU-1 or SU-2

3. The majority of properties will not necessarily have been remediated if or when the

Performance Standard has been met.
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Lake County Community Health Program

Independent Review Panel

Responses to Key Issues I Questions

JJ.2 Please comment on the data evaluation techniques and statistical methods presented in

the Performance Standards Document and make any suggestions or recommendations for

modification or improvement.

2.a Have Type I and Type II error rates been assessed adequately and in a scientifically

defensible manner?

Panel Response:

The Panel was in agreement that the methods and performance standards formulated by

the work group very carefully and quantitatively addressed Type 1 and Type 2 errors.

The Panel does not believe that the term "scientifically defensible" is appropriate within

this context.

2. b Has the uncertainty in the P10 and PI5 values been assessed adequately and in a

scientifically defensible manner?

Panel Response:

The Panel feels that the Working Group was highly innovative in using the Monte Carlo

Analysis to address uncertainty in P-10 and P-15 values. The approach is considered to

be highly appropriate and astute. Again, the term "scientifically defensible" is considered

inappropriate within the context of the question.

2.c Do the required criteria adequately assess the overall representativeness of the

available blood lead data, used to derive the theoretical blood lead distribution for the

community at large?

Panel Response:

The Panel was in agreement that, given Leadville's long mining history, the selection of

soil lead as an initial criterion for estimating representativeness was appropriate for the

site. However, the Panel also feels quite strongly that other important sources of lead

exposure, most specifically lead based paint hazards, should be assessed for

representativeness. This approach would recognize the novel aspects of the Leadville

Remediation Plan, and how it differs from other site plans.

The Panel would strongly support this approach.

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Lake County Community Health Program

Independent Review Panel

Responses to Key Issues I Questions

2.d Does the test of proportions used in Performance Standard 4 provide reasonable

assurance that blood lead program participants are not from residences that underestimate the

high end of the soil lead distribution for the statistical unit as a whole?

Panel Response:

The Panel is in agreement that the test of proportions used in Performance Standard 4

does provide reasonable assurance that blood lead program participants are not from

residences that underestimate the high end of the soil lead distribution for the statistical

unit as a whole.

2.e Do the methods and standards for evaluating performance provide reasonable

assurance that the Program's goal regarding residual risk - to ensure that whatever residual

risks that remain will be sufficiently low as to not exceed the RAOs (described in section 7.0 of

the Performance Standards Document) - will be achieved?

Panel Response:

The Institutional Controls referenced in the Work Plan, which are intended to provide ongoing

control measures to assure the protection of completed remediation and protection of human

health once the LCCHP performance standards have been met, have not yet been approved or

implemented. The Panel feels that in the absence of details on how the Institutional Controls will

be implemented and enforced, there is insufficient data to respond to this question at this time.

Please see the Panels concerns regarding the importance of Institutional Controls in Section IV,

Other.

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Lake County Community Health Program

Independent Review Panel

Responses to Key Issues I Questions

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Based on the Panel's review of the 2001 and 2002 Annual Reports and the 1994-1999

Progress and Results Report, please address the following:

1II.1 Please comment on whether the LCCHP Annual Reports (2001 and 2002) meet the

requirements and expectations of the Work Plan.

Panel Response:

The Panel felt that the Annual Reports were very thorough, and met the requirements and

expectations of the Work Plan.

• The Panel recommends the Annual Report include a target date to achieve

program objectives.

The Panel also discussed the issue of who the audience for the annual report is, and

whether it is intended for review by the general public or by public officials. If the

document is intended for public distribution, the technical level of expertise required to

understand the document far exceeds the knowledge base of the "man on the street".

• The Panel recommends an executive summary that highlights outcomes in readily

understandable "layman's" terms as an extension of the outreach program. An

example of such a summary from Trail, British Columbia is attached, and

includes the Power Point presentation used in public meetings and the newsletter

mailed to each household

7/7.2 Please comment on whether data presented in the 2002 annual report are adequate to

support evaluation of the program performance standards (Refer to Appendix D of the 2002

Annual Report)?

Panel Response:

The Panel was in agreement that the data presented in the 2002 annual report is adequate

to support evaluation of the program performance standards.

III.3 Please make any suggestions or recommendations for improving the value and

usefulness of future annual reports. However, in making your suggestions and

recommendations, please be mindful that these are produced as public documents and the

confidentiality of program participants must be maintained.

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Lake County Community Health Program

Independent Review Panel

• Responses to Key Issues I Questions

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3.a Do you recommend additional data analysis to support compliance with the RAOs?

| Panel Response:

The Panels experience would indicate a strong relationship between low hemoglobin and

increased lead uptake.

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of hemoglobin concentrations.

With the noted exceptions, the Panel does not feel that additional data analysis to support

compliance with the RAO's is necessary.

I 3, b Are there components of the data analysis presented in the annual report that you feel

~ are not necessary?

I Panel Response:

* The Panel did not feel that any elements of the annual report should be deleted.

TM 3.c Can you identify ways to streamline the annual report?

I Panel Response:

The Panel has no specific recommendations for streamlining the annual report, but felt

that a highly condensed and streamlined version of the report, expressing general trends

I and accomplishments in layman's terms, could be prepared for public distribution and

used to improve community education and recruitment.

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Lake County Community Health Program

Independent Review Panel

Responses to Key Issues I Questions

IV. Other

IV.l Please provide any other feedback or thoughts you feel may be helpful to the Work

Group in managing the ongoing implementation of the Program and ensuring long-term

protection of public health.

Panel Response:

While the Panel recognizes the unique methods and creative response to reducing lead

exposures in Leadville, they did express a concern regarding the need for a perpetual

obligation of the Plan to keep lead exposure down in future generations. The Panel is

aware that the independent panel review "is not intended to address certain fundamental

elements of the program described in the Record of Decision (ROD), including: remedial

action objectives, the voluntary nature of the program, program eligibility, the media

addressed, and trigger criteria for the various media used as the basis for recommending

responses actions." Nevertheless, a unanimous opinion was reached, i.e., that some

protective control measures must be kept in place for years beyond the completion of the

LCCHP.

The Panel is concerned that the long-term protectiveness of the remedy, after the

Statistical Units have achieved the specified performance standards, is not adequately

addressed. A significant discussion about, and commitment to, sustainable remedial

response is important in order to fulfill the public health responsibility of the Plan. If the

LCCHP is no longer a functional organization, post-standard compliance, a worry is that

there will be no effective program for future generations to provide for lead exposure

surveillance, consultation, and intervention.

The only obligation recognized by the Panel as offering this type of sustainable assurance

to the community is the adoption of Institutional Controls. This tool is a tested

responsibility of local government to be responsive to needs of the citizens once the

responsible parties have fulfilled their obligation. Institutional Controls allow for follow

up of completed remedies that may intentionally or unintentionally be compromised in

the future. Without a method for future effective management of the Site post-LCCHP,

the Panel feels that the community of Leadville may face a long-term risk of continued

lead exposure.

Similarly, while not asked to comment on trigger levels for environmental response, the

Panel feels obligated to express its concerns that the P-10 and P-15 levels have not

budged for three years in either Statistical Unit, indicating that the selection of soil lead

as criterion for representativeness may not be targeting the appropriate media; hence, the

reluctance of the statistical "tail" to move downward.

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Lake County Community Health Program

Independent Review Panel

Responses to Key Issues I Questions

The Panel does not presume that lead in water or soils are the only sources of lead

exposure. Rather, the Panel believes that the unique climatological factors specific to

Leadville likely result in a significant amount of indoor play time. This, coupled with the

age of housing where exposure to dust and lead based paint hazard is occurring, is

considered justification for re-examining and focusing on the risks and response levels

within the home environment.

The Panel strongly suggests the use of EPA and HUD standards for lead concentrations

in paint and dust lead loading for risk assessment. It also recommends a more aggressive

response for deteriorated lead based paint hazards >1 and <6 mg/cm2. The Panel feels

that education alone will not resolve the hazard within this range, but that aggressive

control and elimination will be required.

The Panel also recommends testing hard floor surfaces for dust, because of the difficulty

in retrieving adequate samples trapped in carpeted areas, and always testing entry-ways.

The small volumes collected from carpeting are often not sufficient to get an accurate

sample. The use of wipe samples as opposed to air pump sampling for dust is also

recommended. Lead loading, based on the wipe sampling method, has been found to

correlate with children's' blood lead levels better than vacuum samples collected by an

air sampler. In addition, EPA's standard for dangerous levels of lead in dust is based on

wipe sampling.

IV.2 Was the Independent Review Panel provided with the tools and information needed to

complete the Program review in accordance with the Scope of Work?

Panel Response:

The presentations, documentation, and site tour were well prepared, thorough, and

informative. The Panel wishes to express its deep appreciation for the tools they were

provided, and the passion and enthusiasm of the presenters who personalized the data sets

and protocols, and made the point evident that the personal commitment of the whole

team plays an enormous part in the success of this highly innovative program.

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SUMMARY OF PANEL RECOMMENDATIONS

The following Summary of Panel Recommendations is intended to ensure long-term

protection of public health and reduce risk sufficiently to meet and maintain Remedial

Action Objectives:

• Make better use of data currently being collected through the use of a multivariate regression model, to include a wider range of potential determinants of

blood lead.

• Consider linking annual reports to previous years to demonstrate trends of blood

lead levels over time.

• Dichotomize the blood lead level database at the mean to increase statistical

power and allow for a comparison of contributing factors for blood lead levels

above and below the mean.

• Consider testing for representativeness of lead based paint hazard as well as soil

lead.

• Make the results of dust and lead based paint analysis in annual reports more

readily observable.

• Use the suggested analytical strategy to evaluate and improve the program and

more effectively target basic problem areas.

• Include target dates for achieving project objectives.

• Compare outcomes against those obtained at other "comparable" sites.

• Use GIS technology to visually track and represent the spatial relationships in

elevated blood lead levels and their recurrences, as well as to map the completed

remediations.

• Encourage Lake County control of the GIS Data Base following LCCHP

compliance with performance standards.

• Complete Institutional Controls to monitor and protect completed remedies that

may intentionally or unintentionally be compromised or recontaminated in the

future. Assign perpetual responsibility to the Lake County Government to educate

the public and enforce the regulations.

• Modify the access agreement to allow for long-term monitoring and surveillance

of dust lead hazards, maintenance of soil remediations etc. following initial

remediation.

• Initiate follow-up monitoring of the effectiveness of educational efforts in

lowering blood lead levels by observing the condition of lead-based paint and

testing dust lead levels, and interviewing "educated" families.

• Test drip lines as a standard element of soil lead testing.

• Use EPA 402 and HUD standards for deteriorated lead based paint and dust

hazards in risk assessment, and initiate aggressive control and elimination of

hazards for levels >1 and <6 mg/cm2.

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Lake County Community Health Program

Independent Review Panel

Responses to Key Issues I Questions

Use wipe samples to test dust lead loading.

Reduce reliance on HEPA vacuums as an active form of remediation. The filters

may actually reduce suction and decrease efficiency.

Remove references to the use of TSP as an active form of remediation. It has a

tendency to damage paint and has not demonstrated significant effectiveness in

lowering EBL's.

Provide additional training to existing staff, or utilize a professional phlebotomist

to sample blood lead levels of children under the age of 12 months.

Include a hemoglobin frequency distribution as part of the annual report.

Distribute free iron supplements and vitamins at the Health Department, as

appropriate, to simplify availability and enhance recruitment.

Educate and encourage realtors to practice HUD and EPA mandated regulations

regarding representations of condition that are accurate and unbiased.

Provide property owners with a "clean letter" from the EPA once successful

remediation of their property has been accomplished. (Example provided)

Encourage construction and remodeling that incorporates bare floors that are

easier to clean and trap less dust than carpet, especially in entryways.

Extend the team approach to more actively involve members of the public and

increase community ownership of both the problem and its solutions.

Consider bi-annual or quarterly public meetings to involve the School District,

student representatives, the Mayor, City Council, the Chamber of Commerce,

parents etc. to build community pride in their positive response to an identified

problem.

Use "Champion Moms" and neighborhood volunteers to involve the community

in identifying and resolving the problem.

Identify and gather input from "key informants" within the various segments of

the community who can speak for their representative group.

Consider sending a once a year reminder of the program to everyone in SU-1,

with a one-on-one follow-up visit.

Consider the use of trained, temporary paid staff, to go door-to-door to encourage

recruitment.

Consider preparation of a brief executive summary of the annual report that is

suitable for distribution to the general public.

Enlist outside expertise from an Epidemiologist to design a door-to-door survey to

increase participation in the program.

Consult with people knowledgeable about community assessments to develop an

evaluation of whether identified segments of the population are getting what they

want or need out of the program.

Consider cross training and preparing for the inevitable time when one of the key

players leaves the program.

Welcome the press and media to become involved in exercises such as this

Independent Panel Review.

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ATTACHMENT A-l

INFORMATION FROM THE TRAIL COMMUNITY LEAD TASK FORCE

Trail, British Columbia, Canada

Referenced on Page 12 of the "Independent Review Panel Responses to Key

Issues/Questions "
2003 Status Report on the Recommendations of the Trail

Community Lead Task Force
2003 Status Report

on the

Recommendations of the

Trail Community Lead Task Force

Prepared for:

Version 5

July 9, 2003

Steve Hilts, Teck Cominco Metals, Ltd.

Cheryl Yates, Interior Health Authority
TABLE OF CONTENTS

EXECUTIVE SUMMARY 1

HISTORY 2

THE NEXT PHASE 5

GOALS SET BY THE TRAIL COMMUNITY LEAD TASK FORCE 6

BLOOD LEAD ....6

OTHER SMELTER CONTAMINANTS 8

SUMMARY STATUS REPORT TO END OF 2002 9

2003 PROGRAMS/SERVICES 19

1. SOURCE REDUCTION 19

1.1 Teck Cominco Emissions Control and Reduction 19

2. COMMUNITY MONITORING 21

2.1 Blood Lead Testing 21

2.2 Environmental Monitoring 22

3. COMMUNITY EXPOSURE REDUCTION 24

3.1 Dust Control 24

3.2 Smelter Buffer Zone 25

3.3 Work Project Assistance Program 26

4. CASE MANAGEMENT 27

5. EDUCATION 28

5.1 Community Education and Awareness 28

5.2 Early Childhood Education 29

6. OVERSIGHT AND COORDINATION 30

SUMMARY OF 2003 FUNDING COMMITMENTS 32

REFERENCES 33
CONTACT INFORMATION

This report, and additional information, is available on request from the following locations:

City of Trail

1394 Pine Ave

Trail, BCV1R4E6

Phone: (250) 364-1262

Interior Health Authority

lOSlFarwellSt.

Trail, BC V1R4S9

Cheryl Yates or Katarina Edwards

Phone: (250) 368-LEAD (368-5323)

Fax: (250) 364-0580

E-mail:chery l.yates@interiorhealth.ca

Teck Cominco

PO Box 1000

Trail, BC V1R4L8

Steve Hilts

Phone: (250)264-4385

Fax: (250)364-4144

E-mail:steven.hilts@teckcom inco.com

Additional information is also online at: http://mvpage.direct.ca/t/tlp
EXECUTIVE SUMMARY

Trail has been the site of metals smelting and refining facilities for over 100 years. The proximity of the

community to the smelter complex has resulted in elevated levels of some metals in community air, soil

and dust. The main focus of attention since about 1975 has been lead and its possible health effects on

children of pre-school age. Although there has never been a recorded incident of clinical lead poisoning

among children in this community, studies elsewhere have found that subtle health effects can occur at

low levels of exposure. These effects can only be detected by studying large populations of children.

In 1990, the Trail Community Lead Task Force was formed to develop a strategy for reducing

children's lead exposures. This program involved the community, industry and government working

together to study the problem, take actions and recommend long-term solutions. The Task Force

undertook comprehensive community education and lead health intervention programs, and Teck

Cominco1 made several major improvements in emissions control - the most significant by far being the

construction and start-up of the new KTVCET lead smelter.

In 1998, the Task Force reached its first short-term goal of having at least 90 percent of children with

blood lead levels below 15 ug/dl, which was the Task Force's individual level of concern. By 2000, the

next short-term goal of having 95 percent below 15 ug/dl had nearly been reached. When the Task

Force was first formed, there were well over 100 children with blood lead levels of 15 ug/dl or higher.

By 2000, there were only about a dozen.

The Task Force wrapped up its work and submitted its recommendations for long-term actions in

February 2001. The BC Ministry of Water, Land and Air Protection2 has not yet formally reviewed

the Task Force recommendations, which are presented in detail later in this document. However,

Teck Cominco, the Interior Health Authority3 and the City of Trail all committed to implementing

the Task Force's recommendations without delay. Key programs, such as blood lead testing and

case management, have continued without interruption since 2001.

The 2003 case management program consists of: follow-up testing of children who have elevated or

rising blood lead levels; counseling of families with children who have elevated or rising blood lead

levels; and provision of case management services to prevent and/or reduce lead exposure. Education

will continue to play an important role in decreasing childhood lead exposure, with programs aimed at

the prenatal, early childhood, and community levels. Teck Cominco will pursue and report on its

progress toward further emission reductions. Community dust control including greening, dust

suppression on alleys and street cleaning will continue. Teck Cominco will monitor the work it did in

2001 and 2002 to improve the vegetative buffer between its operations and the community along the

boundary with Tadanac. A new Work Project Assistance Program, as recommended by the Task Force,

will be developed in 2003.

1

 Note: In 2001, Cominco merged with another Canadian mining company (Teck Corp.) to form Teck Cominco.

Note: Prior to 2001, the BC Ministry of Water, Land and Air Protection was known variously as BC Environmt

BC Ministry of Environment, or the BC Ministry of Environment, Lands and Parks.

Mote: In 2001, health services delivery regions in BC were also reorganized. 77ie Kootenay Boundary Commit,

Heatlh Service society was superceded at that time by the Interior Health Authority.

2003 Program Strategy, Page 1
The combined three-agency budget for 2003 is approximately $150,000 which does not include

emission control projects at Teck Cominco or salaries of regular staff.

History

Lead has been a fact of life in Trail for the past 100 years. Although there has never been a recorded

incident of clinical lead poisoning among children in this community, studies elsewhere have found that

very subtle health effects can occura t low levels of exposure. These effects can only be detected by

studying large populations of children.

In 1975, Neri et. al. (1978) found that children's blood lead levels in Trail were significantly higher

than those in the nearby comparison community of Nelson, BC. A 1989 study found that soil lead

concentration and, secondarily, house dust lead concentration, were the principal environmental

determinants of elevated blood lead levels in Trail children (Hertzman e.t al., 1991). Although the

average blood lead level had declined from 22.4 ug/dL for 1-3 year olds in 1975 to 13.8 ug/dL for

2-5 year olds in 1989,39.4% of the children tested in 1989 were above the U.S.E nvironmental

Protection Agency's "level of no concern" of 15 ug/dL at the time (US EPA, 1986).

The 1989 study's recommendations prompted the formation of the Trail Community Lead Task

Force in 1990. The Task Force was given responsibility for developing a strategy for reducing Trail

children's lead exposures. Communities with inactive smelters or mine sites have often

implemented large clean-up programs to permanently reduce lead exposures. By contrast, the

strategy for Trail is expected to help the smelter and the community to continue to co-exist by

focussing on actions that will be effective in the midst of ongoing, albeit reduced, emissions.

The Task Force was composed of representatives from numerous community groups, local

government, the Province of British Columbia and the smelter company (Teck Cominco, Limited).

All meetings were open to the public and the media (see Figure 1). Task Force members worked

cooperatively to reach consensus on most issues and Teck Cominco participated voluntarily in all

Task Force programs. Teck Cominco, the BC Ministries of Health and Environment, and the City of

Trail provided a total of approximately $5 million in funding from 1990 to 2000. In addition to

financial contributions, the Province and Teck Cominco provided technical resource people with

health, environment and public relations backgrounds to participate in program planning.

The Trail model of co-operative, multi-stakeholder program planning and shared funding

contributed enormously to the program's effectiveness and efficiency. The program's work is

recognized internationally and the Trail co-operative model has been adopted in several other

jurisdictions.

2003 Program Strategy, Page 2
Figure 1 - Trail Community Lead Task Force Structure: 1990-2000

City of Trail)

(Chair)

Cominco

Community

Member

Funding

United |

Steelworkers

of America J

22%

10% 28%

Ftegional District of |

tootenay/Boundar

&hool

District No.

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Environmental

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Early in its mandate, the Task Force estimated the cost of residential soil replacement in Trail at

about $50,000,000 and expressed concern that excavation and soil transport might result in a

transient increase in lead exposure. In addition to the financial deterrent and questions of efficacy,

soil removal appeared to be socially unacceptable in Trail. Also, the lead smelter in operation in

1990 relied on outdated process technology and, despite efforts to control emissions, the amount of

lead discharged to the environment was about 300 kg/day (Cominco Ltd., 1993). At the time,

Cominco was encountering technical difficulties in implementing new lead smelting technology in

Trail. Smelter emissions, and therefore soil contamination rates, were expected to continue at these

levels for number of years. For all of these reasons, the Task Force chose not to recommend any

immediate soil replacement. Instead, the Task Force embarked on ambitious programs of

community education and case management, as well as environmental assessment aimed at better

understanding lead exposure pathways.

Teck Cominco began operating a new lead smelter in Trail in April, 1997. The state-of-the-art

smelter reduced lead emissions from stacks by about 70%. In addition, the new smelter dramatically

lowered fugitive (non-stack) emissions through the replacement of several existing plants with a

single, enclosed plant.

The reduction in lead emissions has had a significant effect on children's blood lead levels. From

1989 through 1996, average blood lead levels of Trail children tested for the first time declined at

2003 Program Strategy, Page 3
an average rate of 0.6 ug/dL/year. The year-to-year variability in average blood lead levels during

this period appeared to be related to weather conditions during the month preceding the fall blood

testing clinic. Specifically, when August was relatively dry, blood lead levels tended to be higher.

From 1996 to 1999, the average blood lead level of children tested for the first time fell by 54% -

from 11.0 ug/dL to 5.1 ug/dL. The average annual rate of decline during this three-year period was

1.9 ug/dL/year. The rapid decline appears to be attributable to the replacement of the old lead

smelter in May of 1997. Air lead levels in Trail during the summer of 1997 were about 50% lower

than during the summers of 1994-1996. By 1998, summer air lead levels were 75% lower than

during the last years of operation of the old lead smelter. Annual average air lead levels in Trail are

now about 0.25-0.30 ug/m3.

In 2000, the average blood lead level among Trail pre-schoolers tested for the first time increased to

6.3 jig/dl. Air lead levels and dustfall lead levels did not increase during the summer of 2000, so the

increase in blood lead levels in 2000 appears to be due to very dry weather experienced during the

month of August.

Shows the history of average blood lead levels for all children tested from 1975 to 2000.

national average for children aged 1-5 is also presented for comparison.

Hie U.S.

Figure 2 - History of Children's Blood Lead Levels in Trail - Averages for All Children Tested

25

5

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started

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3.6

2.7

2.0

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From 1997 to 1999, the Task Force conducted a human health risk assessment to evaluate in detail

the risk posed by other smelter contaminants, such as arsenic, cadmium and antimony. For

chemicals other than lead, the study found "no imminent (short-term) threat to human health" and

"very limited potential for adverse health effects from long-term residence in Trail".

2003 Program Strategy, Page 4
In 2000, the Task Force completed its evaluation and selection of options for long-term remedial

actions. This process involved in-depth consultation with the community at large. Options for longterm remediation included institutionalizing blood lead monitoring, case management and education

programs to ensure their continuation, as well as various physical actions that might be taken to

further improve environmental conditions.

The Task Force based its recommendations on consideration of the following major factors:

• Estimated health risk levels (based on studies conducted elsewhere that have linked

exposure to metals with health effects in humans and animals)

• Community feedback on the estimated health risk levels

• Effectiveness of options for reducing health risks (based on experiences in Trail and at

other sites)

• Socioeconomic impact of intervention and remediation options (including both monetary

costs and disruption to the community)

The Task Force submitted its final recommendations to the BC Minister of Environment in

February 2001.

The Next Phase

The BC Ministry of Water, Land and Air Protection will now review the Task Force

recommendations, which are presented in detail later in this document. Ultimately, the

recommendations must become part of an approved overall remediation plan for area. However,

Teck Cominco, the Interior Health Authority and the City of Trail all committed to implementing

the Task Force's recommendations without delay. Key programs, such as blood lead testing and

case management, have continued without interruption since 2001.

This report describes the current status of implementation of the Task Force's recommendations and

planned activities for 2003 .

2003 Program Strategy, Page 5
GOALS SET BY THE TRAIL COMMUNITY LEAD TASK

FORCE

Blood Lead

Reco mmendationsi

At least 90% of children aged 6 to 72 months in area 2 and 3 (see drawing

below) should have blood lead levels less than 10 ng/dL by 2005.

At least 99% of children aged 6 to 72 months in area 2 and 3 should have

blood lead levels less than 15 jig/dL by 2005.

Once these goals are achieved, blood lead testing should continue, in order

to provide ongoing protection of young children in Trail.

If these goals are not achieved, the remedial plan should be re-evaluated.

Trends In Percentage of Children

with Blood Lead Levels < 10 pg/dl

100%

90%

80%

c 70%

I

2 80%

O

I 50%

S

1

1 40%

o

%• 30%

20%

10%-I

0%

Pro-KIVCET

(1991-1998)

Poit-KIVCET

(1998-2000)

H 1 1 1 1 1 1 1 1 1 1 1 H

rifn^riAcoh»aomovc4in* t

aioiotcnoiciaiaioooa o

o)o>o>a>oioioioiooao o

Trends In Percentage of Children

with Blood Lead Levels < 15 pg/dl

100%

o

o

90% +

10% +

10% 4-

60% +

Pra-KIVCET

(1991-1998)

H 1 1 1 H H 1 1 H

enoir n

Background:

10 ug/dL is the "community concern" level recommended by the US Centers for

Disease Control (US CDC) and it is intended to apply to children in the 6-72

months age group. An association between children's blood lead levels and IQ

has been observed down to this level in studies involving large numbers of

children. These studies have found that, on average, groups of children with

blood lead levels around 20 ug/dL score about 1-2 points lower on IQ tests than

groups of children with blood lead levels around 10 ug/dL, after controlling for

other factors that affect IQ.

2003 Program Strategy, Page 6
• A Canadian Federal-Provincial Task Force recommended in 1994 that

communities with unusual sources of lead exposure may need special programs

where the percentage of children in those communities with blood lead levels

above 10 ng/dL is double that seen in the general population. Since the

percentage of children above 10 ug/dL in North America is currently about 5%,

this would indicate a target of no more than 10% above 10 ug/dL.

• 15 ug/dL is the "individual concern level" recommended by the US Centers for

Disease Control. The Task Force felt that ideally, children should rarely exceed

this blood lead level (less than 1%).

• Several recent studies involving large numbers of children in the U.S. suggest

that even blood lead levels less than 10 ug/dL may impact on children's IQ

scores. Therefore, the US CDC has convened an expert panel to review its

present guideline for children's blood levels. It's expected that the panel will

complete its review sometime in 2004. The outcome of that review may result in

the Trail Health and Environment Committee revisiting the blood lead goals set

by the Lead Task Force.

Oasis

Lower

Warfleld

2003 Program Strategy, Page 7
Other Smelter Contaminants

Recommendations:

Potential health risks from other smelter contaminants (i.e. cadmium and

arsenic) should be reduced to the levels required by provincial regulations,

without shutting down the smelter or conducting widespread soil

replacement in the area.

Background:

• The BC Cancer Agency and BC Ministry of Health have looked at routine health

data and conducted several specific studies to see whether the incidence rates of

any diseases that may be associated with metals exposure (e.g. lung cancer,

kidney disfunction) are higher than normal in Trail. No measureable increases

in disease rates have been found.

• The Trail Lead Task Force conducted a detailed risk assessment for other smelter

contaminants in 1997-99. The assessment involved first comparing

concentrations of metals in the local soil and air against screening guidelines.

The elements that exceeded screening guidelines were the subject of more

detailed assessment, involving estimation of health risks based on the levels of

contaminants in people's air, water, food and in local soil and dust.

• The detailed assessment focused mainly on antimony, arsenic and cadmium and

found that:

• Estimated exposures to cadmium in the local population are well

below levels that might be associated with kidney disfunction.

• Estimated lifetime cancer risks due to arsenic and cadmium in the

local population exceed the BC "default" standard of 1 in

100,000. However, in the Trail population, exposure to smelterrelated arsenic and cadmium might result in:

• no more than 1 extra case of lung cancer every 60 years or

so

• no more than 1 extra case of skin cancer every 200 year or

so

2003 Program Strategy, Page 8
I

Summary Status Report to End of 2002

Source Reduction

Teck Cominco Emissions and Dust Control

Stack Emissions

• In 2001, Teck Cominco assigned an environmental technician to identify, prioritize

and address opportunities for improvements in air emissions control systems.

• Opportunities for future improvements were identified and prioritized in 2001/02.

Two top priorities were the existing stack emission control systems on the lead

stack, the DRAACO baghouse stack and the silver refinery baghouse stacks.

• Various improvements were made, or are being made, to these three systems. The

performance of the new baghouse on the lead smelter feed preparation plant has

been improved by adjusting the dryer operating temperature. The performance of

the DRAACO baghouse on the #2 Slag Fuming Furnace is now being optimized

through round-the-clock operator coverage, implementation of a tight new Standard

Operating Procedure and inclusion of this baghouse in the plant's Integrated Process

Management System (IPM). The newer ABB baghouse on the new #3 Slag Fuming

Furnace has seen a complete changeover of bags and the adoption of a new cleaning

sequence that better allows any problems with bags to be detected and dealt with.

Comprehensive audits of the silver refinery baghouses led to recommendations for

new instrumentation for real-time monitoring of baghouse performance. The new

instrumentation has been installed and operators are now being trained in how to

optimize the performance of the baghouses using the new instrumentation and best

operating practices.

Fugitive Dust from Property

• In summer 2002, community air lead levels and blood lead levels did not drop as

expected during/following the shutdown in August. The suspected cause was a

prolonged drought and extreme wind events in late July and August. Although

Teck Cominco followed the same dust control procedures used during the longer

shutdown in 2001, more dust seems to have spread into the community in 2002.

• The Trail Health and Environment Committee, at its fall 2002 meeting, asked

that Teck Cominco report to the committee on plans to improve upon its on-site

dust control procedures.

• Teck Cominco made a report to the committee on January 14, 2003 which

reviewed the dust control procedures that were already in place, described the

process that was used in the fall of 2002 to determine which areas and activities

on the property should have priority for improvement and outlined the plans

being developed to improve procedures.

2003 Program Strategy, Page 9
Community Monitoring

Blood Lead Testing

2001

• testing focused on children 6-36 months of age in all Trail neighbourhoods.

• Clinic participation: 76%

• Geometric mean lead level: 4.7 ^g/dL (lowest seen to date in Trail)

• 16 children had lead levels >10 jig/d

• 4 children had levels >15 ug/dL

• 1 child had a level >20 fig/dL.

• There was a significant difference between the geometric mean blood lead in

area 2 (4.1 Ug/dL) and area 3 (5.7 p.g/dL).

2002

• children 6-36 months were again tested

• Clinic participation: 75%

• Geometric mean lead level: 6.0 (ig/dL

• 13 children had lead levels > 10 (i g/dL

• 6 children had blood leads >15 (xg/dL

• 2 children had levels >20 ug/dL

• There was again a significant difference between the mean blood lead level in

area 2 (5.0 u.g/dL) and area 3 (7.8 ng/dL).

• In anticipation of a possible upcoming reduction in the U.S. CDC "level of

concern" from 10 ng/dL, the Trail Lead Program has now adopted 10

as its individual level of concern. (Formerly, it was 15 ug/dL)

2003 Program Strategy, Page 10
I

Environmental Monitoring

Ambient Air - Lead

Annual average air lead levels at the key West Trail monitoring station continue to

be very low. As shown in the graph below, the average air lead level in 2002 was c-ftig/m')

P rS I

| O.W

TJ

a

3

5

 0.10 •

OJO •

Annual Average Air Lead Levels

West Trail Station

^ •

OJ8 0.27 OJ5 ^^ ^^^~-M

\1K__--~'"' ' 0.20

0.11

f99> 1SS9 MOO 3001 2001

— • — WtltTnllSln. ——BCOblactln(AnnuilAvg.l - - - World Htilth Org. OuUtlllnt (Annual Avg.)

the lowest yet recorded, other than during 2001, when Teck Cominco's Trail

Operations were shut down for over 3 months. Prior to installation of the KIVCET

lead smelter in 1997, annual average air lead levels at this station used to be in the

0.80 to 1.20 |ag/m3 range. As shown in the graph, air lead levels in Trail are now

below the WHO's guideline of 0.50 f^g/m3, which a number of European countries

are proposing to adopt over the next several years. The U.S. EPA's current standard

for ambient air lead is 1.5 jig/m3 on a quarterly average basis, (Note that for lead, the

guidelines/standards are based on lead in total airborne particulate - not just a fine

fraction. This is appropriate because we're interested both the direct effect of

airborne lead through inhalation of fine particles and the indirect effect through

ingestion of particles that fall out of the air onto surfaces.)

Ambient Air - Cadmium

Annual average air cadmium levels over the past several years are also looking quite

positive. As shown in the graph below, the annual average cadmium level in

respirable (PMio) particulate at West Trail has hovered around the level which

corresponds to an estimated 1 in 100,000 incremental lifetime cancer risk - the

default acceptable risk level in B.C. The goal is to maintain or improve upon this

level of performance. (Note that for cadmium, we focus on the amount of cadmium

in the respirable fraction of ambient air particulate because we're interested mainly

2003 Program Strategy, Page 11
in the direct effect of airborne cadmium through inhalation of fine particles.

particulate is the fraction that is less than 10 um in size.)

Annual Average PM10 Air Cadmium Levels

West Trail Station

0.05

0.05

0.04

0.03

u

3 0.02 •

o.ot •

0.00

4998 1999 2000 2001 2002

| -»- Wen Trail Data —-BC Ob/aetfya (Annual Avg.) 11n 100,000 Risk Level}

Ambient Air - Arsenic

Annual average arsenic levels in ambient air have shown an improving trend over

the past several years, as shown in the graph below. Arsenic levels in respirable

particulate have declined by about 50% since 1998, making some good progress

toward the level that corresponds with the estimated default acceptable risk level.

Prior to the startup of KTVCET in 1997, the annual average arsenic level in

respirable particulate at West Trail station was about 0.10 |ig/m3.

2003 Program Strategy, Page 12
Annual Average PM10 Air Arsenic Levels

West Trail Station

0.11

0.10

0.09

0.08

l>

 Ol07

 '

1

y o.o3 o

u

•j= 0.05

a

? 0.04

3

0.03 •

0.02

0.01 •

0.00

1998 1899 2000 2001 2002

•West Trail Data —BC Objective (Annual Avg.) 11n 100,000 Risk Level \

Dustfall - Lead

It is clear from the graph below that metal loadings in dustfall are higher in the

winter months, when dispersion of smelter emissions is less effective. In summer

months, the total dustfall increases (not shown on this graph), while the metal

loadings in dustfall decrease. This indicates that the deposition of metals from

airborne particulate is still largely influenced by activities at the smelter site, as

opposed to redistribution of historically-deposited material.

The graph also shows that the dustfall lead loading did drop during Teck Cominco's

August 2002 shutdown, despite the windstorms that were noted that month.

However, the dustfall lead levels recorded in August 20C2 were generally somewhat

higher than those recorded during the 2001 shutdown.

2003-Program Strategy, Page 13
i

Monthly Lead in Dustfall

2001 - 2002

-Downtown

-Glenmony

-Daniel Street

Street Dust - Lead

BOO

700 •

600 •

SOO •

Pb

mg

lm'400 •

300 •

200 •

100 •

0 •

Street Dust Sampling - Average for 6 Stations in Trail

Pb mg/m1 vs Sample Date (September each Year)

/

/

/

A

/ \

\ ,

\/

V

A

/ \

\

Vs

/

V

A/ \ i

V /

V

/

/

/

94-3 95-3 96-3 97-3 98-3 99-3 00-3 01-3 02-3

Sample Y«ar- Quarter

2003 Program Strategy, Page 14
The graph above shows the street dust lead loading (average for 6 stations) measured

in September of each year from 1994 to 2002. The graph shows a decline in lead

loading after 1997, but a return to a relatively high level in 2002. This is perhaps

due to the prolonged drought in 2002 from late July through October, which allows

settled dust to accumulate on roads without being washed away by rain.

Community Exposure Reduction

Dust Control

Greening

• Teck Cominco is has completed various revegetation projects on its

properties in Trail, as well as contributed to greening projects in the

community. Teck Cominco has provided about $20,000 in funding plus

materials for projects carried out by the City of Trail and the Trail Flying

Club over the past several years.

• Teck Cominco retained a consulting team to develop a phased design for

revegetation of the riverbank below Trail Operations. The total project

cost is estimated at over $2,000,000, including terracing of the slope for

stabilization.

Dust Suppression on Roads

• Each year, the City of Trail grades the alleys and arranges/supervises the

contract application of magnesium chloride in mid-June. Teck Cominco

and the City split the costs in Trail and at the Beaver Creek campground

and Teck Cominco pays for additional work in other locations outside the

City limits.

Street Cleaning

• The City of Trail has continued to perform at least two extra

sweeping/flushings after the major spring road cleanup in all residential

areas of Trail. The City tries to ensure that the roads are pre-wetted prior

to the sweeper brush hitting them so that clouds of dust are not stirred up

in the process.

Miscellaneous Dust Control

• Teck Cominco accompanied the BC Ministry of Water, Land & Air

Protection on an inspection of the Trimac reload centre in Waneta in

May. The Ministry was pleased with site housekeeping and new measures

in place for cleaning trucks and controlling dust.

• The graph on the below shows zinc loadings in dustfall collected at the

Trimac facility, compared with those measured at one station in Trail.

The Daniel street station was selected for comparison because that station

is within the area of influence of the smelter, but well off the

transportation path for concentrates coming from Trimac. Since the

facility is mainly handling zinc concentrates, zinc is the best parameter to

look at to estimate dust losses from the site and from the trucks leaving

2003 Program Strategy, Page 15
the site. The graph shows that zinc in dustfall at the Trimac site is

consistently much lower than that at the Daniel St. station. In August

2002, the level at Trimac jumped up to equal the level recorded at Daniel

Monthly Zinc in Dustfall

2001-2002

7.00

6.00

5.00

4.00

= 3.00

2.00

1.00

0.00

A

\ 1 I * ! 1 1 1 ! 1 I

Daniel Street - Trmac

Street during the smelter shutdown, but then it returned to its usual low

level by the following month.

Smelter Buffer Zone

• In May 2001, Teck Cominco planted 80 evergreens trees (12-16 feet tall) in the area

near the old training centre, in the vacant lot at 303 Kootenay Avenue and along the

southwest boundary of the Tadanac soccer pitch, following consultation with the

Tadanac Residents' Association.

• In 2002, 29 additional trees were planted to complete the strip along the Tadanac

Soccer Pitch boundary with Maple Road.

Work Project Assistance Program

• Cheryl Yates and Steve Hilts traveled to Idaho in April 200 1 and Missouri in June

2001 to study the approaches being taken to remediation and risk management at

both inactive and active smelting and mining sites.

• No progress was made toward the WPAP in 200 1 - 2002, due to time

constraints. Follow-up services in association with the case management

program assisted families with contaminated yard materials disposal and

assistance/advice were provided to people doing work projects on an ah-hoc

basis.

2003 Program Strategy, Page 16
Case Management

Follow-up Blood Testing, Home Visits, Environmental Assessments

• Interior Health conducted follow-up winter blood testing clinics in February

2001 and February 2002, doing repeat lead testing on children with elevated or

rising blood leads from the previous fall clinic. Also invited are infants between

the ages of 6 - 11 months, who have not previously been tested.

• Beginning in 2002, children included in the case management group were those

with lead levels > 10 (ig/dL, and for children younger than 12 months of age,

those with lead levels > 7 ug/dL. The case management group also includes

those whose lead levels were noticeably increasing (BLL greater than 3 ug/dL)

over one year.

• In general, the follow-up winter clinics saw reductions in individual children's

blood lead levels from September to February. This is an expected outcome, due

to seasonal variation in weather, less outdoor play and reduced indoor lead dust

levels in Trail.

• Follow-up home visits and in-home environmental assessments were offered to

all families with children who have elevated or increasing lead levels. Home

visits and environmental assessments are done primarily within a week of

reporting an elevated or rising lead level to a parent. In 2001, 12 home visits

were conducted. In 2002, 17 home visits were done in Trail.

Services/Assistance

• Interior Health determined appropriate and required assistance to be offered in

2001/2002, in terms of addressing house dust, bare soil, or deteriorating leadbased paint. Throughout 2001 and 2002, 56 families benefited from assistance to

reduce indoor dust, cover bare soil, and clean up lead-based paint.

• Money spent in 2001-2002 for services/assistance through the case management

program was $40,000,e venly divided between Interior Health and Teck

Cominco.

• The case load, funding levels and assistance policies have been reviewed by

Interior Health and Teck Cominco and the Trail Health and Environment

Committee as well.

Education

Community Education & Awareness

• In the spring of 2001, Interior Health and Teck Cominco, with input from the

City of Trail, developed a new full-colour brochure outlining what services are

available and who to contact about them. The brochure was very well received

by the community.

2003 Program Strategy, Page 17
• Also in 2001, a new logo was created for the Trail Health and Environment

Committee. This logo became the foundation for an annual newsletter mailed to

every household in Trail.

• Interior Health ran a radio and newspaper educational campaign throughout the

spring, summer and fall of 2001 on topics such as: lead and pregnancy, blood

lead testing, and reducing lead in the home and yard.

• In 2002, a new Lead Health brochure was developed which combined and

updated the information found in the original series of Task Force brochures.

This new brochure is available through the Trail Health Center, Dr. clinics, and

Trail Regional Hospital maternity ward. Brochures are also mailed to new

families when they are invited to have their children tested.

Early Childhood Education

• Interior Health staff offer presentations to groups such as Mom & Me, day cares,

nursery schools and the Building Beautiful Babies.

• Storybooks aimed at preschoolers are distributed through day cares and

preschools, as well as materials, such as soap and stickers, to go with the

storybook program.

Oversight and Coordination

• The Trail Health and Environment committee met for the first time on July 11,

2001. At this meeting, the committee:

• made some slight modifications to the terms of reference drafted

by the Lead Task Force and adopted them

• discussed whether the scope of issues dealt with by the committee

might include socio-economic issues

• decided to invite the business community to appoint a

representative to the committee

• At subsequent meetings, the committee has heard reports from the Interior Health

Authority and Teck Cominco on their implementation of Task Force

recommendations and has made requests for additional information or action.

• The committee recently decided that it would like to hear informally about any

environmental issues affecting Trail that the City, Province or Teck Cominco

might become aware of from time to time.

2003 Program Strategy, Page 18
2003 PROGRAMS/SERVICES

This section provides information on how each of the Trail Community Lead Task Force's

recommendations will be addressed in 2003.

1. Source Reduction

1.1 Teck Cominco Emissions Control and Reduction

Purpose:

• Emission reductions are still believed to be the single most effective way to:

• further reduce children's blood lead levels

• further reduce possible health risks from other smelter contaminants

Description:

• The Task Force recommended that:

• Teck Cominco should regularly (at least semi-annually) communicate the

following to the public:

• The process by which opportunities for further emission reductions are

being explored

• Goals, projected timelines and progress on emission control projects

(including plans for reducing stack emissions, fugitive plant emissions

and materials handling losses).

• Teck Cominco should ultimately include its goals and timelines for emission

reductions in the final remedial plan for the area

Implementation/Responsibilities:

• Teck Cominco will continue to report regularly to the Trail Health & Environment

Committee on its plans and progress for further emission reductions

• Teck Cominco will also report on emission reduction plans and progress in media

advertisements and in the joint Trail Health and Environment Committee newsletter

Stack Emissions

• Teck Cominco will continue to optimize the operation of its stack emission control

systems, as described in the Status Report section, and to replace equipment and

instrumentation as needed.

On-site Dust Control

"Beach/Flats" Material Unloading and Mixing

• Over past several months, Teck Cominco has managed to avoid dumping

any drosses at the "Flats" by staying "in balance" with their processes.

2003 Program Strategy, Page 19
However, a water spray system is scheduled to be installed on the bins in

summer 2003 anyway. (-$20,000)

• A wind flag was installed at the Flats so that mixing/screening activities

could be ceased when the wind is blowing away from Trail Operations.

• A "highways type" loc-bloc and tent structure (25' x 60') is being installed in

summer 2003 at the lead mix area so that mixing of secondary lead smelter

feeds can be done under shelter. The structure will be open at only one end.

(-30,000)

• Additional paving is being done at the Beach/Flats to provide a smoother,

easier to clean surface. (-$10,000)

Zinc "Roaster Mix" Area

• A water spray system was installed on the bins in spring 2003, so that the

materials can be wet preventatively, rather than waiting to call a water truck

when the materials appear dry/dusty. (-$20,000)

Effluent Treatment Plant Residue Piles and Other Stockpiles

• Cost of covering the large ETP residue piles with a geomembrane is about

$450,000. This item has been included in the Trail Ops capital planning

process, for consideration along with other possible environmental projects.

• Alternatives to covering this pile are being implemented year - e.g. more

frequent spraying with dust suppressant

• All uncovered stockpiles were sprayed on about May 6,2003.

• Repairs to existing geomembrane covers on stockpiles will be made this

summer. (-$30,000)

Estimated Expenditures: (considered external to the three-agency action budget)

Teck Cominco

Emission control systems operation and improvement >$250,000

Dust control procedures/systems improvement ~$ 110,000

On-site greening projects $38,000

2003 Program Strategy, Page 20
2. Community Monitoring

2.1 Blood Lead Testing

• to identify children with elevated or rising blood lead levels

• to assess community-wide impact of remedial actions

• to determine whether the blood lead goals have been reached

Description:

• Regular annual blood lead testing in late summer/early fall will be recommended for

children aged 6-36 months (older children will not be denied testing if their parents are

concerned).

• Follow-up blood testing will be recommended for children with blood lead levels of 10

ug/dL or higher, and for children under 12 months who have blood lead levels over 7

ug/dL.

• A complete blood lead survey of children aged 6-72 months will be conducted in

September of 2005, then every 5 years.

• Blood samples will be collected by venipuncture and analyzed for lead. In 2003, a portable

blood lead analyzer will be purchased and used during testing clinics. This will allow

Interior Health staff to report blood lead results to families while they are on site. Blood

testing results will be provided to family physicians, if requested.

• Summary results will be presented to the Trail Health and Environment Committee in

November 2003.

• A rigorous quality control program will be followed to ensure accurate and reliable results,

using BC Children's and Women's Hospital laboratory.

Implementation/Responsibilities:

• Interior Health will conduct the blood testing clinics, arrange and pay for laboratory

analyses and report the results.

Funding committed: Interior Health

Equipment, Supplies and Services $ 1,000

Annual Fall Clinic $6,500

Annual Winter Clinic $ 1,500

Support staff S3.5QO

$12,500

2003 Program Strategy, Page 21
2.2 Environmental Monitoring

• To assess the collective, community-wide impact of remedial actions (e.g. emission

reductions, street washing, greening, soil barriers, dust suppression)

2.2.1 Ambient Air Monitoring

Description:

• Ambient (community) air monitoring is one of the best measures for monitoring changes in

community conditions. Teck Cominco operates two main ambient air monitoring stations

that measure metals (lead, zinc, arsenic and cadmium) in the air. These two stations (at

Butler Park and Genelle) sample the air for 24 hours once every 2 days. In addition, Teck

Cominco is continuing to operate its ambient air monitoring station at West Trail at least

until the end of 2003 and its stations at Columbia Gardens and Northport until 2005. Data

from the West Trail station have been relied upon by the Lead Task Force and Trail Health

and Environment Committee for the past 6 years or so. Therefore, the relationship between

data collected at W. Trail and the Butler Park station will be reviewed at the end of 2003.

Implementation/Responsibilities:

• Teck Cominco Environment will collect and analyze samples, with review by the BC

Ministry of Water, Land & Air Protection and Trail Health & Environment Committee.

2.2.2 Dustfall Monitoring Network

Description:

• Dustfall (a measure of particles settling out of the air) is another excellent means of

monitoring changes in community conditions and assessing current rates of contamination.

Teck Cominco has operated a regular network of about 15 dustfall stations in the

community for several decades. From 1992 to 2000, Teck Cominco operated additional

stations for the Lead Task Force, bringing the total network to about 38 stations.

• A memo to Teck Cominco from Trail Lead Program staff on October 5, 2000,

recommended that 6 of the special dustfall stations operated for the Trail Lead Program

be retained and added to Teck Cominco's regular dustfall monitoring network.

• Dustfall jars are changed monthly and analyzed for total dustfall and loading

(mg/dm2/month) of lead, arsenic, cadmium and zinc.

Implementation/Responsibilities:

2003 Program Strategy, Page 22
• Teck Cominco Environment will collect the samples from the network and samples will

continue to be analyzed at Teck Cominco Analytical Services, with review by BC Ministry

of Water, Land & Air Protection and Trail Health & Environment Committee.

2.2.3 Street Dust Monitoring

Description:

• Lead in street dust was monitored by the Trail Lead Program as part of the Sentinel Homes

project. Street dust lead loadings declined by about 50% after 1997.

Implementation/Responsibilities:

• Street dust sampling will be conducted at a density of one sampling station per

neighbourhood, except there will be 2 stations in East Trail. Street dust sampling stations

are located near dustfall monitoring stations.

• Teck Cominco Environment will collect and analyze the samples, with review by the Trail

Health & Environment Committee.

Funding committed: Teck Cominco

Ambient Air Monitoring $22.000

Dustfall Monitoring $ 15,000

Street Dust Monitoring $3.000

$40,000

COMMUNITY MONITORING TOTAL: $60,500

2003 Program Strategy, Page 23
3. Community Exposure Reduction

3.1 Dust Control

• to further reduce children's blood lead levels by reducing dust movement and

accumulation in the community

• to further reduce possible health risks from other smelter contaminants

Description:

Greening:

• The Task Force stated that greening of bare areas is a high priority, and

recommended that Teck Cominco and the City communicate their plans for this.

• An inventory of remaining bare areas will be prepared and used to set priorities

for action. Areas where action is taken will be monitored to ensure success.

Dust Suppression on Roads:

• Dust suppressant will continue to be applied to alleys and other unpaved areas in

Trail at least once per year.

Street Cleaning:

• The Task Force recommended that street flushing and sweeping be performed

according to the correct procedure and at the current frequency in the City of

Trail and Rivervale (highways maintenance contractor responsibility in

Rivervale and on highways through Trail).

Miscellaneous Dust Control

• Trucks transporting concentrates to Teck Cominco from Waneta reload station

should be required to take appropriate steps to reduce losses along the route.

Implementation/Responsibilities:

• Teck Cominco and the City of Trail, with assistance from the Trail Health & Environment

Committee, will identify and prioritize candidate areas for greening.

• The City of Trail will arrange and supervise the spraying of magnesium chloride.

• Teck Cominco will monitor and report on the steps that are being taken by Trimac.

• Teck Cominco will also continue greening on its own properties.

Funding committed: Teck Cominco City of Trail

Greening city lands $ 10,000 $

Dust Suppression on Roads $5,000 $4,400

Street Cleaning (hard to say how much is extra)

$25.000?

2003 Program Strategy, Page 24
$15,000 $29,400

3.2 Smelter Buffer Zone

• to reduce the exposure of residents to dusts from Teck Cominco emissions (primarily

from the intermediate product stockpiles)

Description:

• Teck Cominco will develop, communicate and implement a plan to expand/enhance the

vegetative buffer within and adjacent to the property boundary (e.g. more trees, earth

mounds), commencing in Spring 2001 and continuing as stockpiles are consumed.

• Teck Cominco will endeavor not to remove any additional structures from this zone until

the vegetative buffer is well established and has reached a height of at least 20 feet.

Implementation/Responsibilities:

• In May 2001, Teck Cominco planted 80 evergreens trees (12-16 feet tall) in the area near

the old training centre, in the vacant lot at 303 Kootenay Avenue and along the southwest

boundary of the Tadanac soccer pitch, following consultation with the Tadanac Residents'

Association.

• In May 2002, Teck Cominco planted 29 additional large evergreen trees to complete the

strip along the Tadanac soccer pitch boundary.

• The vegetative buffer strip will now be monitored by Teck Cominco, with replacement of

dead or diseased trees as needed.

Funding committed:

Teck Cominco

Tadanac buffer strip trees project for 2003 $0

2003 Program Strategy, Page 25
3.3 Work Project Assistance Program

to encourage homeowners and contractors to follow precautions when undertaking

excavation, construction, demolition or renovation projects, in order to minimize

dust exposure to workers and residents.

to provide assistance to people who need to dispose of contaminated soil or dust.

this program is not meant to encourage people to undertake projects such as soil

replacement. Instead, it is intended to make it safer and easier for people who, on

their own, have decided to do some work on their properties.

Description:

• A program should be set up to provide assistance with excavation, construction,

demolition or renovation projects.

• The assistance for such projects should address dust control, worker exposure, resident

exposure, neighbours' exposure, and disposal of contaminated materials (e.g. soil, dust,

paint chips, painted materials).

• Assistance offered through the program may include:

• Advice concerning steps to take to minimize exposure to contaminated soil and

dust

• Free disposal of contaminated soil or dust

• Free clean soil to replace the volume of excavated contaminated soil, if

necessary.

• An education program should be set up so that the community (including

contractors) is aware of the WPAP and how it works.

• A training program should be set up for contractors and public works employees

so that they competent in the control of dust and disposal of contaminated

materials.

• Bunker Hill Superfund Site has set up a comprehensive program that has been

studied as a possible model for some elements of Trail's program.

Implementation/Responsibilities:

• Teck Cominco will develop and fund this program. A contractor may be hired to assist with

program development. Program development will begin in 2003.

Funding committed:

Teck Cominco

Program development $20,000

COMMUNITY EXPOSURE REDUCTION TOTAL: $64,400

2003 Program Strategy, Page 26
4. Case Management

• to reduce higher-risk children's exposure to lead in dust, soil and paint.

Description:

• The following services will be provided for families of children with blood lead levels of

10 ug/dL or higher, and families of children under 12 months age with blood lead levels

greater than 7 (ig/dL:

• Home visits to provide counseling/advice on reducing lead exposure

• Blood and environmental results will be reviewed with the family, a

behaviour and lifestyle assessment completed, and practical advice to lower

lead exposure given.

• In-home environmental assessment

• To determine which areas should be targeted for lead hazard control (dust,

soil, paint)

• Assistance in addressing bare soil, house dust, or deteriorating lead-based

paint

• Follow-up monitoring of blood lead levels

• Children's blood lead results will be reviewed at subsequent clinics (winter

or spring) and further assistance/services will be offered if required.

• Assistance to day care and preschool centres in addressing bare soil or indoor dust.

Implementation/Responsibilities:

• Interior Health will conduct follow-up for families of children who have elevated or rising

blood lead levels. Interior Health, with input from Teck Coininco, where requested, will

determine the appropriate and necessary assistance to be offered. Interior Health and Teck

Cominco will each provide up to $10,000 for the 2003 case management program.

• Teck Cominco will provide additional funding if required to address urgent needs of any

child found to have a blood lead level of 40 u-g/dl or higher.

Funding committed:

Interior Health Teck Cominco

Case management materials/services $ 10,000 $ 10,000

2003 Program Strategy, Page 27
5. Education

5.1 Community Education and Awareness

Purpose:

• to inform the public (particularly new parents and new residents) about what they can do to

keep children's blood lead levels low, and to let people know about available services

Description:

• The following community education program elements will be provided:

• brochures

• information for families new to Trail

• display stand at community events such as Teddy Bear Picnic

• radio and newpaper advertising

• newsletters

• information for pregnant women and new mothers

Implementation/Responsibilities:

• Interior Health and Teck Cominco will work together with the Trail Health & Environment

Committee to develop materials and campaigns. Funding will be provided by Interior

Health and Teck Cominco as outlined below.

Funding committed:

Interior Health Teck Cominco

Newsletter $1,500 $1,500

Work Project Assistance Program Brochure $3,000

Advertising $4,000

Community projects $1.000

$6,500 $4,500

2003 Program Strategy, Page 28
5.2 Early Childhood Education

Purpose:

• to encourage pre-schoolers to adopt healthy behaviours in order to:

• keep their lead exposure risk and blood lead levels low

• keep them in good general health

Description:

• The following early childhood education program elements will be provided:

• visits to day cares, nursery schools, Building Beautiful Babies

program, Mom and Me

• provision of storybook to new child care providers

• provision of materials to go with storybook program (e.g. soaps,

stickers)

• This opportunity to reach pre-schoolers will also be used to present other hygiene,

nutrition and health messages.

Implementation/Responsibilities:

• Interior Health will work together with the Trail Health & Environment Committee to

develop materials and campaigns. Funding will be provided by Interior Health.

Funding committed:

Interior Health

Educational and promotional materials $ 1,000

EDUCATION TOTAL: 512,000

2003 Program Strategy, Page 29
I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

6. Oversight and Coordination

• to ensure that the goals are attained in a timely manner

• to ensure effective monitoring, coordination and evaluation of progress toward the goals

• to ensure effective oversight by, and communication with, the community

Description:

• A committee has been established to ensure that the program does not suffer from

fragmentation or loss of credibility and to facilitate public communication and oversight.

• The committee will ensure that there is no discontinuity of service between dissolution

of the Trail Community Lead Task Force and implementation of the final remedial plan

for the area.

• The committee includes representatives from the City of Trail, Interior Health Authority,

BC Ministry of Water, Land & Air Protection, Teck Cominco, United Steelworkers of

America, the Greater Trail Community Health Council and the community (similar to

the current Task Force).

• The committee has been appointed by City of Trail.

• At its first meeting the committee should review the Draft Terms of Reference that was

been prepared by the Trail Community Lead Task Force.

• The initial mandate of the committee should be to monitor, coordinate and advise on the

implementation of the Task Force's recommendations and to participate directly in

development of the final remedial plan. Once the remedial plan has been approved, the

role and reporting responsibility of the committee should be re-evaluated.

Responsibilities/Actions:

• The Trail Health & Environment Committee operates as a committee of the City of Trail.

Membership:

Chair: Dieter Bogs Mayor, City of Trail

Ames, Dr. Nelson Interior Health Authority

Davies, Kate Community Representative

Graham, Al Councillor, City of Trail (alternate)

Dimock, Dr. Barss Community Representative

Hilts, Steve Teck Cominco Metals, Ltd.

Johnson, Carl BC Ministry of Water, Land & Air Protection

Joseph, Ron Community Representative

Kenyon, Graham Community Representative

Homey, Ralph Councillor, Village of Warfield

Rakuson, Marylynn Greater Trail Community Health Council

Yates, Cheryl Interior Health Authority

Wynn, Tom United Steelworkers of America, Local 480

Whitlock, Rosemary Recording secretary

2003 Program Strategy, Page 30
TECHNICAL COMMITTEE

Role: Terms of reference yet to be established.

Meetings: This committee will meet as needed.

Members: Dr. Nelson Ames -Interior Health Authority - Chair

Nelson was involved with the original Trail Lead Study in 1989 as a masters student

with UBC and served as a member of the Lead Task Force throughout its duration.

Nelson is Medical Health Officer for Kootenay Region for Interior Health Authority.

Phone: (250) 354-6853

Fax: (250) 354-6304

E-mail: nelson.ames@interiorhealth.ca

Cheryl Yates -Interior Health Authority

Cheryl served as the research nurse with the original Trail Lead Study in 1989.

Cheryl was Health Coordinator for the Trail Lead Program. Cheryl is now the public

health nurse in charge of Lead Health Services for the Interior Health Authority.

Phone: (250) 368-LEAD (368-5323)

Fax: (250) 364-0580

E-mail: cheryl.yates@interiorhealth.ca

Steve Hilts - Teck Cominco Metals, Ltd.

Steve was Environmental Coordinator for the Trail Lead Program and is now

Superintendent of Environmental Remediation for Teck Cominco Trail Operations.

Phone: (250) 364-4385

Fax: (250) 364-4144

E-mail: steven.hilts@teckcominco.com

Kate Davies - Community Representative

Phone: (250) 368-6078

Fax:

E-mail:

2003 Program Strategy, Page 31
SUMMARY OF 2003 FUNDING COMMITMENTS

Interior Teck

Health Cominco City of Trail Total

SOURCE REDUCTION

Teck Cominco Emissions & Dust Control >$400,000 (not included in totals)

COMMUNITY MONITORING

Blood Lead Testing

Environmental Monitoring

$12,500

$40,000

$52,500

COMMUNITY EXPOSURE REDUCTION

Dust Control

Greening projects

Work Project Assistance Program

$5,000

$10,000

$20,000

$29,400

$64,400

CASE MANAGEMENT

EDUCATION

Community Education & Awareness

Early Childhood Education

$10,000 $10,000

$6,500

$1,000

$4,500

$20,000

$12,000

2003 TOTALS $30,000 $89,500 $29,400 $148,900

2003 Program Strategy, Page 32
References

Cominco Ltd., 1993. Emissions Management Report. Trail Operations, 25 pages.

Hertzman C, Ward H, Ames N, Kelly S and Yates C, 1991. Childhood lead exposure in Trail

revisited. Canadian Journal of Public Health, 82, 385-391.

Ned LC, Johansen HL, Schmitt N, Pagan RT and Hewitt D, 1978. Blood lead levels in children

in two British Columbia communities. In: DD Hemphill (ed.) Trace Substances in

Environmental Health XII; Proceedings of the University of Missouri's 25th Annual Conference

on Trace Substances in Environmental Health, 6-8 June 1978, pp. 403-410. Columbia,

Missouri.

U.S. Environmental Protection Agency, 1986. Air Quality Criteria for Lead. Environmental

Assessment and Criteria Office, Research Triangle Park, N.C.

2003 Program Strategy, Page 33
TRAIL LEAD PROGRAM

Power Point Presentation used in public meetings

"Fall 2003 Blood Lead Results"
Fall 2003 Blood

Lead Results

Presentation Overview
Participation Rates

Breakdown by 2003 Participation

Neighborhoods >/o(No.)

Participating

% Children

Participating

# Children

Contacted

# Children

Participating

AREA 3 (Children <3 years) <3 years)

72% (13)

84% (16)

100% (2)

50% (2)

(< 3 years)

84% (26)

AREA 2 (Children < 3 years)

Glenmerry

Shavers Bench 50% (5)

Sunningdale 68% (13)

AREA 2 TOTAL 73%(44)
Participation Rates (conn)

Group

Area 2/3

Participation

Rate (2003)

Infants not tested 82% (14 of 17)

before

Case Management 100% (9 of 9)

Participation

Rate (2002)

94%

94%

Other (<36 mos.) 81% (59 of 73) 66%
Blood Lead Histogram: Area 2/3

(Age 6 mos. - 36 mos.)

22%^= lOjjg/dL

5%>= 15M9/dL

1%>=20|jg/dL

0%>=25pg/dl

0-12-3 4-5 15-*

" • 1'i'

 13\ ,.,:-:.,,,

Blood Lead Ranges (jjg/dL)

^ 24- 26- 28-

17 19 2f 23 25 27 29
Blood Lead Histograms: 1991-2003 shift

Areas 2 & 3: GHildr6iri?l< 37 rhortths

a, 15% i

o>

1991

1996

2003

Blood Lead Ranges (jjg/dL)
2005 Goal

Trend in Percentage of Children

with Blood Lead Levels < 10 pg/dl

(6-36 months throughout)

100% -

c 90% -

£ 80% -

T3

= 70% -

£ 60% -

? 50% - 0)

§> 40% -

§

 30%

 •

£ 20% <

*• 10% -

0% -

.

M . *

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-* 1

Pre-KIVCET r ' "

(1991-1996) I ''*

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" r I ^^^ Z (1996-2000)

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Comparison with "background"

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History of Children's Blood Lead Levels in Trail

Trail

1975: 1-3 yrs

1989: 2-5 yrs

1991-00: 6-59 mos

200 W3 6-36 mos.

New Lead Smelter

started

US A\£ -6 mos -6yrs

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- Trail: 12-36 mos. Trail: 24-60 mos. •Trail: 6-60 mos. •T rail: G-36 mos. US National Avsrage
2003

30

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Areal

( ) Number of children

Area 2

in range

i

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-s- Average
73

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Blood Lead Geo Mean by Area

(age 6-36 months throughout)

Area 3
Comparison with Other Sites

City/Region Country Nature of site

Port Pirie Australia

Trail Canada

Rouyn-Noranda Canada

Nation-wide U.S.A.

Age of kids

tested

Primary Pb smelter

Primary Pb smelter

Primary Cu smelter

Urban/rural (NHANES)

Year

Average \

Blood Lead

Level

9 mos to 5 yrs 2001

6 mos to 3 yrs 2003

6 mos to 5 yrs 1999

1 to 5 yrs 1996-f99

9.8

5.7

5.2

2.0
Three Distinct Periods

Geometric Mean Blood Pb, 6-36 mos. throughout

11.6

2001 removed because it was

abnormal: 3+ mos. complete

smelter shutdown

1989 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Lead in Air: Month of August

Only, West Trail Station

| Lead (H9/m3)

94-'96

avg.

1.20

1997

0.50

1998

0.22

1999

0.29

2000

0.42

2001

0.03

2002

0.18

2003

0.17
Lead in Dustfall: Month of August

Only, Area 2/3

Lead (mg/m2/day)

94-96

avg.

2.0

1997

1.5

1998

0.6

1999

1.4

2000

1.4

2001

0.23

2002

0.54

2003

0.49
o>

3.

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Trends in Geometric Mean Blood Lead and

August Air Lead

(Children aged 6-36 months)

1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003

•a

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+~

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£

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(£5

Susp. Paitic. Pb in Area 2/3 in August-H—Geo. mean blood Pb
2.4O

Air Lead Levels

West Trail Stn Jan 2001 to present

Lead in Ambient Air (West Trail)

(In total partlculate)

Lead •Quarterly Avg. BC Objective (annual avg.)J
TRAIL LEAD PROGRAM

, Community Newsletter

"Reaching Out - Volume Two, Issue One, Spring 2003'
Lead Levels up Slightly

During Hot, Dry-Summer

Si' -f ?"'^";" ^^^^iSj^®

HEALTH*

ENVIRONMENT

VOLUM E T, W O, I S SUE O-N E, S P' R.I N G 2 0*0 3

Lead Levels Up Slightly During Hot,

Dry Summer

page 2

What isteck Cominco

Doing to^Reduce Emissions?

page 3 !

What is Being Done to

Control Dust Levels out.

In the Community?

page 4 _,_ .

Thallium Levels Low In Trail

Despite a general-downward trend in children's blood

lead levels In Trail, testing in 2002 showed slightly higher

* f

.average levels than the previous year. While the results

are^iio cause for alarm, they-serve as a good reminder of

'.the importance of personal and household habits that

reduce exposure to lead.

Why the increase In lead levels last fall?'"AlthoughTeck

Cominco shut down the smelter in August and followed

the same dust control procedures used during the longer

shutdown In 2001, more dust seems id have spread into

the community in 2002." .

For the past two years, the Trail Lead Program has

foqused its testing on children less than 3 years old.

That's the most vulnerable age

group due to a tendency for little.

explorers to put fingers and other

' objects into their mouths often.

' Participation in the blood lead

testing clinic was down slightly in

. 2002, with 75% of .invited children

attending. The graph to the-..right

shows the history of children's

blood lead levels in Trail compared

to background lead levels in

: the U.S.'

The. range of blood lead levels in 2002 was 1.5.- 22.8

ug/dL. Eighty-three percent of children had levels below.

10 ug/dLand 9'2%.had levels below 15 ug/dL. In 2003 we

hope to come even closer to the goals set for 2005:

i.

• At least 90% of children with 'blood lead levels less

than 10 ug/dL. •

•-At least 99% of children with blood lead levels less

than, 15"ug/dL . "

. While we're making progress toward long-term goals,

infants and toddlers in this community are still vulnerable

to lead exposure. Fortunately, there are easy ways to

minimize their risk. Hand washing [s one of the healthiest

continued to page 2

History of Children's Blood Lead Levels in Trail
"Lead Levels Up Slightly During Hot, Dry Summer" continued from page 1

habits we can teach our youngsters. It's also important

for families to remove shoes at the door and keep floors

clean by vacuuming and damp mopping.

To all the families who participated in the fall 2002 blood

lead testing clinic, we say a big thank you! We can all do

our part to keep children in this community healthy.«

What Is Teck Cominco Doing To Reduce Stack

Emissions And Dust From Its Property?

Why Is it important to reduce

emissions further?

the environment would be to keep

improving air quality. Even though

Folks who've lived'in the Trail area for young children receive most of their

a while know that the air quality has, jead exposure' through hand-toImproved substantially, especially

since the hew Teck Cominco lead

smelter started up'in 1997. Not only

. has the air become visibly cleaner,

but levels of lead, arsenic and cadmium "in community air dropped by

70 - .80% from 1995 to 1999.

mouth activity rather than breathing,

much of the lead in dust in their

environments comes -from recent_

smelter emissions. .

How are stack emissions being

reduced?

Annual Average Air Lead Levels

West Trail Station

1.20

1.00

.o.so_

y

°

13

i- 0.40_j

0.20_

In 2001, Teck Cominco began a

However, the Trail Community Lead project to find the top priorities for

Task' Force recommended in 2001 ' improvements in emission controfs.

'that the best way to further- reduce The project focused first on the

potential health risks from metals In various type's of systems that

capture metals before

they can get up stacks.

The plants that were

releasing the most metals

. were • addressed . first.

Operating procedures for

» the plants and for their

emission control equipment were Improved so

that their performance

would be more consistent.

Environmental monitoring

results are reported daily

to the plants to provide

feedback on performance.,

The graph below shows

that, other than in 2001

when Trail Operations was •

shut down for over • 3

West Trail station . . months, 2002 saw the

BC.Objective.(AnnuaiAvg.) . lo'west.annual average air

_____ World Health Org. Guideline (Annual Avg.

0.60_|

0.26 OI27

0.25

lead level since the new lead smelter

started operating."

How Is dust from the property,

being reduced?

A top priority for. 2003 for .Trail'

Operations is to find ways .to further

reduce the risk of dust losses from

material stockpiles on the property.

Currently, many of the large stockpiles are covered with "tarps" and

others are sprayed with dust sup-,

pressant and monitored regularly.

On-property roads are also cle'aned

frequently.

However, as noted in the story' on

blood lead levels, the.unusually dry

'and windy conditions in the summer1

of 2002 appear to have led to dust

being blown from the smelter

property into the community. Teck

Cominco -has identified the highest •

priority material stockpiles and is

developing an action *p'an tcTput In

place by spring. New actions for -

improved dust control. may include

the' use of water sprays, different

types of dust suppressants, additional "tarps" on some piles or enclosing

some piles-in buildings.

The community of Trail can expect to

see continued Improvements in air

quality and to receive ongoing

reports on Teck Cominco's emission

reduction plans and progress. •

2
What Is Being Done To Control Dust Levels Out In

The Community?

Street Cleaning

The Trail Community Lead Task. Force also recommended that cleaning of city streets should be carried out

regularly using effective methods. In.the 1990s, the Task

Force found that lead levels in street dust were high •

enough to be a potential source .of lead exposure to young

children If dust were to be. blown or tracked into homes.

The Task Force monitored and reviewed the City of Trail's1

street cleaning'program and suggested that not only was

it important to sweep and "flush" the streets several times •

throughout the' summer, but that care must be taken to

avoid stirring up dust when performing the work.

Whereas in many other small towns, .the streets are

cleaned up In the spring and then do not see a street

. sweeper again over the summer, the City.of Trail performs

at least two exfra sweeping/flushings after the major

spring cleanup. The cjowntown core is swept and flushed

weekly. The City also tries

ape'pre-wetted prior to the

sweeper brush hitting

them, so .that clouds of

dust are not. stirred up in

the process. This.is very

difficult to accomplish

during the spring cleanup - '

when there's a lot of sand on the streets. Fortunately, the

sand applied to the streets over the. winter is "clean", so

the lead levels on the streets .during, spring cleanup are

relatively low.

Unpaved Alleys ;

As per Task.Force recommendations,, a long-lasting,

' environmentally-friendly dusf suppressant fs applied 1o

unpaved alleys and other areas in and. around the city in

. June each year. -The cost of this program is split by the

City of Trail and Teck Cominco. The City.also applies'

asphalt milling by-product from its pavipg program onto

'some unpaved roads or.road shoulders each year, to

provide more permanent dust control.

... the City of Trail performs at least two

extra sweeping/flushings after the major

spring cleanup. The downtown core is

swept and flushed weekly. • •:'

City water truck cleans'up.

Greening

The City of Trajl and Teck Cominco also continue to

work together to provide grass cover on bare ground

areas, .such as the

Bench. This work has.

typically Involved applying composted organic

•material mixed with

sand, then hydroseeding with a -drought tolerant grass mixture. ®

Dusf control on city alleys.
Thallium Levels Low In Trail

In an incident .at Teck Cominco in

2001, contract workers were" exposed

to high levels of thallium during

« maintenance on a boiler. Thallium is

a naturally occurring metal 'common-

' ly focind inxthe ores that feed smelters

such as Trail Operations."

The incident prompted Teck Cominco

to review thallium levels Iri air, soil,

and garden produce to ensure there

• was no' hazard for the x:omrhunity 'at

large. The review showed thallium

content of-samples to be slightly

higher than background revels, but

lower than levels associated with a

health risk.

Further to that.review, the Trail Health

and Environment Committee and the

Interior Health Authority recommended a study of urine thallium

levels in Trail residents.

The; study was run in conjunction

with the 2002 blood lead testing

clinic. Researchers Invited 50

parents "of. children attending the

lead, clinic to be tested for thallium

exposure. Subjects Included residents in neighborhoods close to the

smelter. The.re was an equal split

between people who eat produce

grown in'the Trail area, and those

who do not.'

**

'Participants were interviewed' by

phone to make sure they represented the general population. No

one with a possible occupational

exposure was included in the study.

Study participants provided urine

specimens, which were sent to a

hospital in Vancouver for analysis.

The average Urine thallium level was

0.25 micrograms per litre (ug/L), with

all results well below the World

Health Organization guideline for the

.general population of 5.0 ug/L.There

was no.significant difference in urine

thallium levels between- consumers

and non-consumers of locally grown

produce. . - • '

Thank you to all those who participated in the thallium study. It 'is

1

 reassuring to know that the average

urine thallium level 'in Trail is

comparabfe to (hat of the general

population in the US. O •

Educate Yourself About Lead

The Trail Lead Program (through Interior Health 368-5323).

has many education projects ongoing In the community:

• In 2002, a new Lead Health brochure was developed '

which combined and updated the information.found in the •

original series of Task'-Force brochures. This new

brochure is available through: Trail Health Center, Dr. clin-

• ics, TrairRegional Hospital maternity ward, and mailed to

parents. , . •

• Annual newsletter mailed to every household in Trail.

• Radio.and newspaper advertisements throughout .

the spring and summer, on .topics such as: lead "and

nutrition, lead and pregnancy, blood lead testing,

reducing lead in. the home and yard.

.• Storybook aimed at preschoolers - available through

daycares and preschools. • ;. '

• Ongoing presentations to community groups such as

Building Beautiful Babies. . • • . •-

For more Information about the -

Trail Health & Environment Committee,

. contact Trail City Hall, f 394 Pine Avenue. .

Phone 364-1262 * ;

What education'messages do families need to know

about lead?

• Good hygiene is the key. Wash your children's hands

frequently throughout the day and always before snacks

and meals. Keep fingernails short and clean..

B Keep your floors clean by vacuuming and damp

mopping. Leave your shoes at the door.

• Wash children's toys frequently, especially the ones

your child particularly likes to chew. ' *

• Encourage .your.children to eat a well-balar.ced diet

high in calcium and iron. Garden produce should be

washed before it is eaten. Feed young children snacks

and meals irr a high chair (after you have washed their

hands). • . ,

H Keep bare dirt areas in the yard to a minimum.

Sandboxes.are great, especially if they are kept covered

when not in use.' Wash your children's hands after

playing outside.

• When- renovating older homes, take special

precautions to avoid exposure to lead-bearing dust

and paint chips (especially for 'pregnant women and

young children). . . .. .

4
TRAIL LEAD PROGRAM

Informational Brochures

Lead and Your Family's Health

Lead Health and Environment Services - What's Available and Who to Contact
and your

Familys

Trail Lead Program

1051 Farwell St.

Trail, BC V1R 4S9

(250) 368-5323

cheryl .yates@interiorhealth.ca

TRAIL

l£AO PROGRAM

teckcominco

Teck Cominco Metals Ltd.

PO Box 1000

Trail, BC V1R 4L8

(250) 364-4385

steven.hilts@teckcominco.com
and your

Family's

Lead and its compounds are very useful,

but they can be harmful as well, especially

to young children. Exposure to lead may

cause behavioral problems, learning

disabilities or reduced intelligence. Because

lead can be found almost anywhere, you

can't avoid it entirely. However, Canadians

are exposed to much less lead now due to

removal of lead from gasoline additives,

interior paint and solder in tin cans.

People who live in smelter communities

are likely to be exposed to more lead than

people who live in most other areas. Trail

is a great city in which to live and raise a

family, but we are a smelter community,

and therefore we are exposed to some

lead through house dust and soil. However,

the environment now is better than it has

been in decades (a hundred years), and is

continuing to improve every year. Teck

Cominco is committed to making further

reductions in the amount of lead and other

metals released from its Trail Operations.

Community leaders, Teck Cominco,

government experts, the Trail Health and

Environment Committee and residents

are all working together to improve our

environment, and we are making significant

progress. We are continuing to see

considerable improvements in children's

blood lead levels, and we are confident that

the efforts of this group will further reduce

lead exposure in the community.

How does lead get into our

bodies?

In Trail, lead is present in the emissions

and dust from the smelter complex. The

lead particles fall to the ground and

contaminate yards and roads. This soil

and dust gets tracked into our homes on

shoes and clothes, and through windows

and doors. Paint and plumbing in older

homes may also contain lead.

Most lead enters the body through the

mouth such as on food that has lead dust

on it. Because of their habit of putting toys,

fingers and other objects into their mouths,

young children are more likely to get

elevated lead levels than other groups.

What is an acceptable level

of lead in children?

As lead has no beneficial effects on

health, the lower the amount in the body,

the better. The Trail Lead Program uses

guidelines similar to the U.S. Center for

Disease Control to determine acceptable

and elevated blood lead levels in a

community. According to these guidelines,

a lead level less than 10 ug/dL (micrograms

per deciliter) is acceptable. The Trail Lead

program is working to have all children in

Trail with blood leads lower than 10 (Jg/dL.
Does lead affect all children

equally?

No. Studies show we should be most

concerned about the lead levels of children

under the age of 3. Small children are most

likely to put dirty objects into their mouths.

They also absorb lead into the bloodstream

more readily than do older children and

adults.

What are the effects of

elevated levels of lead in

children?

At very high levels, anemia, kidney damage

and digestive problems may occur. Slightly

elevated lead levels may cause learning,

behavioural, or psychological problems.

Often the effects are so subtle that they

cannot be noticed. Any symptoms that do

occur might be mistaken for illnesses such

as flu.

In Trail, any effects are so small that they

are not measurable in individual children.

What are the effects of

elevated levels of lead in

adults?

Adults are not as vulnerable to lead as

young children. However, if levels are

sufficiently elevated, adults may develop

fatigue, high blood pressure, digestive

and reproductive problems, and kidney

dysfunction.

Adults working directly with lead or lead

products, through work or as a hobby,

should have their blood lead level checked

regularly. However, other adults living in

Trail need not be concerned about lead

exposure.

How often should my

children have a blood lead

test?

Children who live in the greater Trail area

should be tested each year until they are

three years old. The first test should be

done when your baby is crawling (between

6 and 11 months). (Most lead exposure

in very young children occurs from lead in

floor dust.) It is important to find out if a

baby's lead level is elevated, as it is much

easier to correct at this young age. Testing

is voluntary.
What should my child and I

expect at the blood-testing

clinic?

A small amount (less than one teaspoon)

of blood is taken from the child's arm.

You are asked to hold your child on your

lap during the test. It is usually a quick and

simple procedure performed by a certified

laboratory technologist. Staff makes the

clinics as child-friendly as possible.

Balloons, stickers, soap and toys are

available for children to take home, and

the waiting room has toys for children to

play with.

When will I get the results?

The level of lead in the blood sample is

analyzed on site, the same day. You will

be phoned with the results. Results will

also be mailed to you and your doctor,

if requested.

What happens if my child

has an elevated lead level?

If your child has a lead level of 10 ug/dL

or higher, the health coordinator of the Trail

Lead Program will request to visit your

home.

You will be offered information and assistance to help reduce your child's lead level,

such as advice about nutrition and hygiene;

testing of your home and yard to determine

why your child's blood lead is elevated; and

services such as removal of lead contaminated material in the home environment.

Your child's blood lead level will be monitored more frequently.

If your child's level is over 20, you are also

referred to your family doctor.

How can I keep my

children's lead levels low?

• Good hygiene is the key. Wash children's

hands frequently and always before snacks

and meals. Keep nails short and clean.

Discourage children from putting non-food

items in their mouths.

• Encourage your children to eat a wellbalanced diet high in calcium and iron.

Garden produce should be washed before

it is eaten. Feed young children snacks

and meals in a high chair.

• Keep your floors clean by vacuuming

and damp-mopping. Leave your shoes

at the door. Control dust by wet-wiping

windowsills, ledges, and flat surfaces.

• Keep bare dirt areas in the yard to a

minimum. Sandboxes are great, especially

if they are kept covered when not in use.

Wash children's hands after playing

outside.

• When renovating older homes, take

special precautions to avoid exposure to

lead-bearing dust and paint chips. •
Ij

>

!

I

Minimizing Our

Exposure to Metals

A Few Key Tips:

« Practice good hygiene by washing children's hands

after playing, before eating and before bedtime

• Keep fingernails clean and short

& Leave outdoor shoes at the door

e Keep floors clean by vacuuming and damp-mopping

© Control dust by wet-wiping ledges, windowsills,

and flat surfaces

e Feed children a healthy diet, high in iron and

calcium

e Keep bare dirt areas in the yard to a minimum

© Carefully wash all fruits and vegetables

© When renovating older homes, take special

precautions to avoid exposure to lead-bearing

dust and paint chips

LEAD HEALTH and '

ENVIRONMENT SERVICES

Other Brochures Available:

(call 368-LEAD)

® Lead and Your Family's Health

e Nutrition, Lead and Children

e Work Project Assistance Program

e Renovation: Lead in Your Home

$m

contributing photographer; Larry Ooell a/id Raeff Mfles
HISTORY

Metal Levels in Trail Have Declined

For children, a blood lead level of 10 ug/dL is the

"community concern level" and 15 ug/dL is the

"individual concern level".

In 1991, only about 15% of Trail children had lead

levels below 10 and about 60% were below 15.

After the new lead smelter started up in 1997:

9 Lead levels in air dropped about 70%

« Lead in dust (dustfall, street dust) dropped

about 40 - 50%.

• The average blood lead in Trail children also

dropped about 40 - 50%.

® Lead levels in soil have not changed

appreciably in several decades.

As of 2000, about 75% of Trail children had lead

levels below 10 and about 93% were below 15.

Lead levels in adults living in Trail (and not

working in a lead-related job) are in the range

currently considered safe.

Arsenic and cadmium are two other metals

emitted by the smelter. They are generally found

where lead is present!

Arsenic and cadmium levels in air dropped

by about 60 - 70% after 1997.

The health risks posed by arsenic and cadmium in the

Trail environment are very low. Although there is

a small calculated risk of adverse health effects, no

evidence of increased disease rates related to metals

exposure has been found in the Trail population.

History of Children's Blood Lead Levels In Trail

Trail Lead New lead

Program Smelter

started 1990 started 1197

'1980 ..'•:'.:' • 1985:
CURRENT SERVICES/PROGRAMS

Public Health

Centre

Cominco

Blood lead testing, focusing on children who

are most at risk (those less than 3 years' of age).

Counseling and services for families with children

who have elevated or rising lead levels.

Community and early childhood education about

preventing lead exposure.

HEPA vacuum cleaner loans.

Contact:

Cheryl Yates,

Kootenay Boundary Health

1051 Farwell St, Trail

(250) 368-LEAD (368-5323)

cheryl.yates@kbchss.hnet.bc.ca

City of Trail

« Flush and sweep the streets according to

recommended protocols.

e Dust control on alleys and other unpaved areas.

• Greening of bare public areas.

Contact:

Public Works Department

City of Trail

(250) 364-0840

trail@cityoftrail.com

® Pursue further reductions in plantsite

emissions, with increased reporting to public

on plans and progress.

• Plant more trees within and adjacent to

Cominco property to improve the dust barrier

and continue other greening efforts around the

property and community.

® Environmental monitoring of air and street dust.

© Address soil as needed on a case-by-case basis

(coordinated with the counseling and services

program operated by public health).

® Advise and assist people doing excavation,

construction, demolition or renovation (Work

Project Assistance Program—full program

available starting 2002).

Contact:

Steve Hilts

Cominco Ltd.

(250) 364-4385

steve.hilts@trail.cominco.com

Coordination

of Services

• The Trail Health and Environment committee,

appointed by the City of Trail, oversees the

work being carried out by Cominco, Kootenay

Boundary Health and the City.

ffl This committee involves the community^

government and industry working together to

protect community health.
Reaching for New Goals

Trail saw huge improvements in children's blood lead

levels and environmental conditions from 1975 to 2000.

As of 2000, the average blood lead level in Trail

children was acceptable. However, there were still

about 7% of Trail children who had elevated blood

lead levels (higher than 15 micrograms per decilitre).

Blood Lead Goals for 2005

® At least 90% of children should have blood lead

levels less than lO^g/dL

© At least 99% of children should have blood

lead levels less than 15 fjg/dL.
ATTACHMENT A-2

Attachments referenced on page 17 of the "Independent Review Panel Responses to Key

Issues/Questions "

Example of a 'clean' letter from the US EPA provided to property owners at the

Smuggler Mountain Superfund Site in Aspen, Colorado
DEC OB 2003 4:33PM DUNLOP ENVIROMMENTH L CONS 37O-323-4820

DUNLOP ENVIRONMENTAL CONSULTING, INC.

~? Environmental and I'ublic Health Planning for the Future

Thomas S. Dunlop

President

November 8, 2001

U.S. Environmental Protection Agency

Region VIII

Armando Saenz

999 IS"1 Street, Suite 500

Denver, Colorado

80202

Re: • "Clean" Letter to Remediated Properties on the Smuggler Mountuiii Supcrfund Site

Dear Mr. Saenz:

As you will notice from the letterhead, this communication is coming from Dunlop

Environmental Consulting, Inc.(DEC,Inc.). The letter is being sent under authority of a

contractual agreement that DEC, Inc. has. with Pitkin County. DEC, Inc. has been retained to

manage teclinical issues involving the Smuggler Mountain Supcrfund Site (Site).

Defined in Section VI (15) (g) of the Consent Decree between Pitkin County and the

U.S. EPA, homeowners within the Smuggler Mountain Superfund Site who have remediated

their property are to receive a "clean" letter from' EPA. The letter will state the property

requires no farther remediation. The basis for the letter is determined by the fact that

property owners must comply with requirements found in the Consent Decree and

Institutional Controls. The landowners shall protect their property by placing

uncontaminated soil over lead containing soil, and revegetate the yard after a construction or

landscaping project has taken place. A proper covering of lead containing soil has nlso been

determined to be 12 inches of gravel, or paving with concrete or asphalt.

Find below a fist of individuals names and addresses that have performed work on

their property resulting in remediation as defined above, or the contaminated soil was

removed to a proper repository and replaced with clean fill. These individuals qualify for a

"clean" letter from EPA because they have taken approved measures to remove contaminated

soil from direct human contact

• Pitkin County (Norm Marrah)530E. Main St. Aspen, Colo. 81611

(For creation of a parking lot along Park Circle at the intersection of Smuggler Mountain

Road)

• Lora J.Lewis 935 Gibson Ave. Aspen, Colo. 81611

• Susan Schlundt 326 Oak Lane Aspen, Colo. 81611

• Rich Wager 517 Park Circle Aspen, Colo.81611

• Stephanie Costcllo 328 Oak Lane Aspen, Colo.81611

Post Office Box 6289 • Snowmass Village, Colorado 816l5 USA » Office and Fax (970) 923-4820

d on recyrkfl ptp«r
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1

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1

1

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DEC 06 2003 4:33PM DUNLOP EHVI RONMENTH L CONS 970-923-4020 P-3

-

__ r|- TTft?"7

A c ic pAct fiiif P1?i£p \ oiislon. '. CXHS / / \j^ * . •

• r* t_ i* ' 1 fOi tu I^(*HMT 1Q thf* r^sOOnSlblC DtUTiY lOT tI\C wiOCRlUl I

Subdivision)

Attached picas. Gad a sample letter » previously written by EPA lo otto property

- owners on the Site.

Thank you for your continued assistance in management of this requirement of the

Conscn^eeAs always, contact me should you have questions or comments swound.ng

. this request.

Sincerely,

^

j$? Qfls* &*/2

Thomas S. Dunlop

President

Cc: Norm Marrah, Pitkin Coimty Env. Health Director

tee Cassin, Aspen Env. Health Director

John Ely, Pitkin County Attorney

John Worcester, Aspen City Attorney

(

"

Csir.ujiln-.UJJl clean lrtler.doc

,;
DEC 06 2003 4:33PM DUNLOP ENVIRQNMENTRL CONS 970-923-4820

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION VIII

999 18th STREET - SUITE 500

DENVER. COLORADO B020Z-2466 ... „.

ReC: 8EPR-SR ,}pc

2737-074-00-aS G :•.- "'"* '' ""'w

Pitkin County •: 'V

130 So, Galena ^C.".•.••

Aspen, CO 81611 .

Dear Pitkin County.

Almost one year ago tha United States Environmental

Protection Agency (EPA) and Pitkin County cams to agreement on a

course o£ action for the residential area of tha Smuggler

Mountain Superfund Site (Operable Unit One) . Aa part of that

agreement, EPA is sending you this letter to notify you aa to the

status of your property. SPA.'has determined that your

property(s), aa identified above, has met one of the following

two criteria:

1) The property does not require cleanup because lead

concentrations that may be on your property are below EPA's

action level at this sice,

o r , .. .

2) Excavation work performed at this property, by you or

the others, assures protection of human health and the

environment.

Because your property meets one of these two conditions), EPA

does not believe that tha lead that may be in the soil will' pose

a risk to human health or the environment.

You may rely on this letter as documentation that-EPA does

not plan to carry out additional Superfund activities at your

property. We thank you very much for your understanding and.

cooperation at this site.

Should you have any questions in this matter, you may

contact Brian Pinkowslci, Remedial Project Manager at

1303) 312-6212. ' • > •

Sincerely,

p.4

Max H. Dodsou

Assistant Regional Administrator

for Ecosystems Protection and

Remediation
ATTACHMENT B

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WORK GROUP REQUESTS FOR CLARIFICATION AND SUMMARY OF PANEL

• RESPONSES

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ATTACHMENT B

WORK GROUP REQUESTS FOR CLARIFICATION

AND SUMMARY OF PANEL RESPONSES

II. Evaluation of Performance

Based on the Panel's review of the 'Methods and Standards for Evaluating the Performance of the Lake

County Community Health Program' document (the 'Performance Standards Document') and the

evaluation of data from the years 2000, 2001, and 2002, presented in the 2002 Annual Report, please

address the following:

Original Question;

IL.l. Please comment on the appropriateness and applicability of the statistical methods and standards

presented in the Performance Standards Document for evaluating the performance of the Program with

respect to the established Remedial Action Objectives.

II. 1.a. Is the rationale for each performance standard adequately described, appropriate, and scientifically

defensible?

Original Panel Response (Part 1 of 3):

Il.l.a.i. The Panel believes that the rationale for the establishment of standards has been adequately

described in the 'Performance Standards Document'. The Panel considers the standards, as described

in the document, to be reasonable but arbitrary, as they do not mirror National standards (e.g. soil

lead level ofSSOOppm and lead based paint at 6mg/cm2).

Work Group Comment/Request:

The LCCHP Work Group recognizes that the site-specific "action levels" or "trigger levels" that

are used to decide when remedial action is warranted for various media such as soil, interior dust,

and paint do not mirror values for soil, dust, or paint that are used at many other sites across the

nation. These trigger levels were selected for use at Leadville based on the results of the baseline

human health risk assessment, which included a multivariate structural equation analysis of all data

available on the relationship between the probability of elevated blood lead in children and the

level of lead in contaminated media in Leadville. Given this background for the trigger levels, the

Work Group does not feel the word "arbitrary" is an appropriate designation for these values, but

recognizes that the baseline human health risk assessment was not submitted to the Panel for

review, and that the Panel would not have the data needed for judging the appropriateness of these

site-specific trigger levels. In any event, it is precisely because these trigger levels are not

"standard" that the outcome-based (i.e., blood lead-based) performance standards were developed.

That is, the LCCHP draws a distinction between "performance standards" (as described in the

performance evaluation methods document) and media "trigger levels", and one of the main

purposes of the performance standards is to determine if the trigger levels selected are actually

adequate to achieve the target reduction in blood lead levels in the community.

Panel Clarification; The panel reiterated that the rationale for the establishment of the

performance standards has been adequately described in the Performance Standards

Document and clarified that the second sentence of their response, characterizing the

standards as arbitrary, was directed at the program's trigger criteria rather than the
methods for evaluating performance. Based on the Work Group Comment/Request

provided above, the panel stated that they now have a better understanding that the trigger

levels in Leadville were based on the best site-specific data available at the time, and

therefore the trigger levels should not be thought of as arbitrary. However, the Panel

reiterated their concern, based on the weight of evidence from more recent studies at other

sites, that the trigger levels for soil and paint are high, relative to standards, or action levels,

applied at other sites. The panel indicated that their concerns on the likely efficacy of the

LCCHP program, specifically given the relatively high trigger criteria for paint, were not

intended as criticisms of the Performance Evaluation method.

Original Panel Response (Part 2 of 3);

Il.l.a.ii. The Panel believes that the performance standards for meeting the Remedial Action

Objectives are appropriate. The Panel does not feel that the term "scientifically defensible " is

appropriate within this context and, therefore, offers no response to this query.

Work Group Comment/Request;

The Work Group is pleased that the Panel considers the basic performance standards to be

appropriate, but would like to request clarification as to why the Panel does not feel that the term

"scientifically defensible" is applicable in this context. More specifically, the Work Group was

hoping the Panel would comment on whether the basic design and strategy of the performance

evaluation approach is expected to be able to provide a reliable or valid (i.e., scientifically

defensible) technical basis for recognizing if and when the health-based Remedial Action

Objectives have been achieved at the site.

Panel Clarification; The panel clarified that the basic data collection strategies and

statistical evaluation methods developed to evaluate the performance of the LCCHP were

appropriate and valid. The response regarding the term "scientifically defensible" was

provided due to uncertainty as to whether the terminology is appropriate. The panel agrees

that the methodology of the established performance standards evaluation is defensible.

Original Panel Response (Part 3 of 3);

Il.l.a.iii. The Panel also notes the absence of a critical path or timeline for completion as part of the

Performance Standards. Inclusion of a timeline would be considered normal practice in such a

document.

Work Group Comment/Request;

The Work Group would like to request clarification from the Panel as to why absence of a timeline

is considered to be important with regard to the performance criteria. As discussed in Section 6.1

of the Methods document, the Work Group recognized the need to track results over time and to

guard against spurious decisions due to short-term variability. As the analysis presented in

Attachment 3 indicates, a minimum of three years of data is judged to be required in order to

capture temporal variability, and after three years of data have been collected, the need to continue

the program is determined by an assessment of whether or not the performance criteria are

satisfied. This includes an assessment both of the P10 and P15 values, and of the uncertainty

around those estimates. Thus, even when the PlO and PI 5 goals have been met, if uncertainty is

too large, additional years of data may be required to increase the number of observations and

decrease uncertainty to acceptable levels. Thus, the duration of the program is dependent on the

values and quality of the data, rather than attaining a prescribed number of years of data. Does the

Panel suggest that a more formal schedule with defined critical events be established as part of the

performance evaluation method?
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Panel Clarification: The panel clarified that a time line, identifying milestones for

achieving program goals, was suggested to ensure that a strategy was in place in case the

LCCHP did not achieve its target objectives within a reasonable time period. More

specifically, the Panel expressed concern that the program objectives may not be achieved

in SU1, without some adjustments to the current program. The panel recommends that the

Workgroup develop a time line for deciding if and when a change in the LCCHP may be

required.

Original Question;

Il.l.b. Does the method adequately demonstrate the long-term effectiveness of the remedy and

compliance with RAOs?

Original Panel Response;

The Panel feels that this is a critical question that cannot be answered at this time, and cites the

following reasons:

• There is not enough long term data available at this point

• P-10 and P-15 values have not changed significantly in either SU-1 or SU-2

• The majority of properties will not necessarily have been remediated if or when the

Performance Standard has been met.

Work Group Response/Request;

The Work Group would like to clarify the intent of this question. It was not our goal to ask the

Panel whether they felt that the data available at this time are adequate to establish that the

program will be effective in the long-term. Rather, it was the intent of this question to determine if

the panel felt that the basic design and strategy of the performance evaluation program would be

adequate to assess long-term effectiveness as data are collected in the future. That is, the intended

focus of the question is on the method, not on the results. Thus, the question could better have

been written as: "Will the performance criteria adequately test or assess the long-term effectiveness

of the remedy and compliance with RAOs?" The Work Group hopes the Panel will offer their

opinions on this issue.

Panel Clarification; As noted above, the panel clarified that they believe the methods

developed for evaluation of the LCCHP program performance are appropriate.

Original Question;

H.2. Please comment on the data evaluation techniques and statistical methods presented in the

Performance Standards Document and make any suggestions or recommendations for modification or

improvement.

n.2.a. Have Type I and Type II error rates been assessed adequately and in a scientifically defensible

manner?

Original Panel Response;

The Panel was in agreement that the methods and performance standards formulated by the work

group very carefully and quantitatively addressed Type 1 and Type 2 errors. The Panel does not

believe that the term "scientifically defensible" is appropriate within this context.
Work Group Response/Request;

As above, the Work Group would like to seek clarification from the Panel as to why they feel the

term "scientifically defensible" is not applicable in this content. More specifically, the Work

Group would like clarification as to whether the Panel perceives any statistical limitations or flaws

in the strategy or method for estimating the probability of decision errors from data that have been

or will be collected during the project.

Panel Clarification; The panel reiterated that they believe the statistical methods developed

to address Type I and Type II error rates are appropriate and valid. Their only concern was

over the appropriateness of the use of the term "scientifically defensible" (See previous

clarification to n.l.a.iifor discussion of this terminology).

Original Question;

II.2.b. Has the uncertainty in the P10 and PI 5 values been assessed adequately and in a scientifically

defensible manner?

Original Panel Response;

The Panel feels that the Working Group was highly innovative in using the Monte Carlo Analysis to

address uncertainty in P-10 and P-15 values. The approach is considered to be highly appropriate

and astute. Again, the term "scientifically defensible " is considered inappropriate within the context

of the question.

Work Group Response/Request;

As above, the Work Group would like to seek clarification from the Panel as to why they feel the

term "scientifically defensible" is not applicable in this context. More specifically, the Work

Group would like clarification as to whether the Panel perceives any statistical limitations or flaws

in the strategy or method for estimating the uncertainty around estimates of P10 and P15 based on

site-specific blood lead data sets that may be available now or may become available in the future.

Panel Clarification; As noted above, the panel clarified that they believe the statistical

methods developed for evaluation of the LCCHP program performance are appropriate.

Original Question:

II.2.e. Do the methods and standards for evaluating performance provide reasonable assurance that the

Program's goal regarding residual risk - to ensure that whatever residual risks that remain will be

sufficiently low as to not exceed the RAOs (described in section 7.0 of the Performance Standards

Document) - will be achieved?

Panel Response;

The Institutional Controls referenced in the Work Plan, which are intended to provide ongoing control

measures to assure the protection of completed remediation and protection of human health once the

LCCHP performance standards have been met, have not yet been approved or implemented. The

Panel feels that in the absence of details on how the Institutional Controls will be implemented and

enforced, there is insufficient data to respond to this question at this time. Please see the Panels

concerns regarding the importance of Institutional Controls in Section IV, Other.

Work Group Response/Request:
The Work Group would like to clarify the intent of this question. It was not our goal to ask the

Panel to evaluate the expected efficacy of various Institutional Controls that are described in the

work plan for the site. Rather, it was the intent of this question to determine if the panel felt that,

if and when the performance criteria are achieved at the site, it will be appropriate to conclude that

residual risks in the community are likely to be below the health-based goals established in the

Remedial Action Objectives. The Work Group hopes the Panel will offer their opinions on this

issue.

Panel Clarification: The Panel agreed that the basic outcome-based stopping rules

established in the LCCHPperformance evaluation plan (a running three-year

average P10 < 5% and PI 5 <1%) are reasonable, and in fact are more rigorous

than at many other locations where programs are underway to reduce lead

exposure. However, the Panel reiterated that the LCCHP will not remove all

sources of lead exposure and that residual risks would remain in the community,

especially from lead paint hazards. As such, the panel expressed the opinion that it

may be difficult to determine whether compliance with the RAOs will be

maintained "now and in the future" (as the RAOs are stated) without effective

Institutional Controls to prevent disturbance of the remedy over time or ongoing

blood-lead monitoring at a minimum. Because of this, the Panel reiterated their

view that is desirable to provide on-going support to the community even after the

LCCHP remedy is considered complete.
ATTACHMENT C

WORK GROUP RECOMMENDATIONS
ATTACHMENT C

WORK GROUP RECOMMENDATIONS

This attachment presents the recommendations of the LCCHP Work Group with respect to the

comments and recommendations provided by the Independent Review Panel in their Responses to

Key Issues/Questions document. Work Group comments regarding specific responses provided

by the IRP are provided and, where appropriate, recommendations to EPA regarding the

implementation of changes to the LCCHP are also discussed.

While a response or recommendation is not being provided by the Work Group for every finding

or recommendation of the IRP, the Work Group desires to provide comments and/or

recommendations to selected IRP responses. These comments and/or recommendations are

provided below, referenced to and numbered according to the structure of the IRP report.

I. LCCHP Implementation

Original Question:

1.2 Please provide any suggestions or recommendations you may have for improving the

structure (i.e., organization, responsibilities and internal communications) of LCCHP

management and administration

Panel Response:

In response to this question, the IRP provided (in part) the following recommendations

(summarized):

The extension of the team approach to more actively involve members of the local public

and increase community "ownership" of both the problem and its solutions, through the

use of "Champion Moms", and bi-annual or quarterly public meetings to engage and

involve community leaders.

Work Group Comment/Recommendation;

The Work Group recognizes that 'word of mouth' referrals, or the "neighbor to neighbor"

approach identified by the IRP in their discussion of "Champion Moms", is an effective

recruiting method. Given that the Leadville community is relatively small, many

referrals are received for both the blood lead program and the environmental program

from friends and relatives of participants. In addition, it is common when a property is

sampled or remediated on a block, multiple inquiries are received from neighbors. The

Program also encourages participation by using yard signs during exterior remediation

activities. The Program will continue to encourage participants to talk with their

neighbors and friends to enhance recruitment.

The Work Group also acknowledges that engaging and involving community leaders

through periodic public meetings may be an effective way of developing a sense of pride

in the achievements of the program and improve the visibility of the program within the

community. The Program has made presentations to community groups including,

schools, the Lions Club, the Lake Interagency Council (LIAR), and the Leadville City

Council. In addition the Leadville Mayor and County Commissioners are routinely

involved in monthly to quarterly meetings regarding the program.
Original Question;

I.3.b (Paraphrased) Provide specific feedback with respect to the community awareness,

education, and recruitment activities component of the program.

Panel Response:

In response to this question, the IRP provided (in part) the following recommendations to

improve community awareness and recruitment (summarized):

The use of "Champions", or neighborhood volunteers (see response to 1.2 above);

The use of trained, temporary paid staff, to go door to door in SU1 in a concerted

recruitment effort. Recommended consulting with an epidemiologist to help design a

door-to-door survey;

Send a yearly reminder of the program to everyone in SU1, with a follow-up one-on-one

visit;

Develop an evaluation of public needs, with consultation with people knowledgeable

about community assessments;

The use of "key informants" who can represent the common needs, concerns, and desires

of identified segments of the population.

Work Group Comment/Recommendation;

At the present time, the program is enjoying excellent participation in the blood lead

testing program and the environmental program is at capacity. The Work Group feels

that the program is effectively recruiting from multiple segments of the community, as

represented in the annual report through the presentation of participation rates by area,

language, and other socio-economic demographics. The IRP has provided some helpful,

specific strategies for community outreach and the Work Group recommends that these

strategies be considered further should program participation decline in the future.

The Work Group would also like to point out that the blood lead program does in fact

send out reminder cards on an annual basis, followed up by a telephone call to the family

to encourage testing.

Original Question:

I.3.d (Paraphrased) Provide specific feedback with respect to the environmental testing

program and procedures component of the program.

Panel Response;

In response to this question, the IRP provided (in part) the following specific

recommendations regarding soil and dust sampling procedures:

The Panel recommends that drip line testing be emphasized in the soil sampling regime to

help determine the presence and influence of soil lead from deteriorating external lead

based paint sources.
Panel members expressed concern that the three sample method currently in use for

testing house dust is not sufficient to identify hazards or provide house-wide clearance

and recommends that the Program follow protocols described in EPA 402 Regulations,

and that entryways always be tested.

Work Group Comment/Recommendation;

The dust sampling methodology and soil sampling procedures were thoroughly discussed

in the development of the LCCHP. With respect to dust sampling, the EPA regulations

cited by the IRP are based on wipe-sampling methodology, which provides lead loading,

rather than lead concentration results, that are not comparable to the established trigger

criteria for lead in dust. As stated in the Work Plan, the main entry is identified as one of

the three sampling locations for dust.

With respect to drip line soil sampling, the Work Group believes the current procedure in

the Work Plan is sufficiently flexible to address lead in soil in the drip line (e.g., adjacent

to the structure), where exterior lead based paint may be a source. The current

procedures require the collection of samples from all bare areas, or when soil or

vegetative cover conditions are different. This procedure ensures that drip line soils are

sampled when the area is bare or different from the surrounding yard (i.e., flower or

vegetable garden). Drip line soils may not be sampled separately if the area is similar to

the adjacent yard, or when covered with gravel or rock, however, these conditions also

limit a child's exposure to the soil. In addition, if the remediation of exterior lead based

paint is required, additional soil sampling is performed per the Work Plan.

Original Question:

L3.e (Paraphrased) Provide specific feedback with respect to the blood lead testing program

and procedures component of the program.

Panel Response;

In response to this question, the IRP provided (in part) the following specific

recommendations regarding blood lead sampling procedures:

Panel members did not feel that waiting until a child is 12 months of age to begin

recruitment into the LCCHP was ideal, and would encourage blood lead testing starting at

age 9 months. The Panel also recommended the use of a professional Phlebotomist to

collect samples in children under the age of 12 months.

Work Group Comment/Recommendation;

The program is following current CDC guidelines, which recommend testing beginning

at the age of 12 months. This is also consistent with Medicaid requirements. Children

younger that 12 months are routinely tested if a sibling has an elevated blood lead, or if

the parents request testing. In addition, the program does have access to a professional

phlebotomist through the hospital.

Original Question:

I.3.f (Paraphrased) Provide specific feedback with respect to the data management, evaluation,

and reporting practices of the program.
Panel Response:

In response to this question, the IRP provided a number of specific suggestions, as

follows:

i. Use of a multi-variate regression method to better understand the determinants of

elevated blood lead in Leadville;

ii. Consider providing previous years results in the Annual Report to demonstrate

trends of blood lead levels over time, as a function of multiple variables;

iii. Consider the use of a GIS system to allow for spatial tracking of children with

elevated blood lead levels, to identify potential "hot spots" of exposure, and

identify targets for recruitment;

v. Split the collected sample base at the mean rather than at the P-10 or P-15 levels

to increase the statistical power of the analysis;

vi. Consider testing for representativeness of lead-based paint hazards as well as soil

lead; and

vii. Use the suggested analytical strategy to evaluate and improve the program and

more effectively target the basic problem areas.

Work Group Comment/Recommendation:

i. The Program has and will continue to evaluate methods of evaluating program

data, such as multi-variate regression analyses, to develop an understanding of

the factors, or sources contributing to elevated blood leads. See response to item

1.4. below for additional discussion.

ii. The Work Group agrees that the presentation of trends for certain data would be

helpful and, based on the IRP's recommendation, is planning to present trends in

participation, mean blood lead levels, and P10 and P15 levels in the next annual

report.

iii. The Work Group understands the potential of GIS technology, however detailed

mapping (i.e., to the property level) is not currently available for Leadville. A

substantial commitment of time and money (that is not currently budgeted)

would be required to generate the information necessary to develop a fully

integrated GIS system for the site. Notwithstanding, spatial analysis tools,

including GIS, may be considered by the Work Group in the future. In addition,

in considering spatial analysis techniques care must be taken to prevent any

potential breach of confidentiality, given the small population of Leadville.

v. See discussion below related to item 1.4.

vi. The representativeness test, using soil concentrations, included in the Methods

and Standards for Evaluating Performance (Standard 4) was not intended to

presume that exposure to lead in soil is the predominant lead exposure pathway.

Rather it was developed as a way to ensure that the program participants
represent the population as a whole. In addition, due to the number of variables

involved in paint sampling, the Work Group believes it would be very difficult to

develop a metric to uniformly quantify lead paint hazards. However, the Work

Group does feel that understanding the significance or contribution of lead-based

paint to blood lead levels is important and continues to be considered. See Item

1.4 below for additional discussion.

vii. As stated in the preceding responses, the Work Group will consider alternate data

evaluation techniques to improve the program and focus on identified 'problem

areas'. See Item 1.4 below for additional discussion.

Original Question;

1.4 Statistical Unit 1 has not met the performance standards criteria; please provide any

additional implementation recommendations that could be considered by the Work Group to meet

these standards.

Panel Response:

In response to this question, the IRP made the observation that while the mean blood lead

concentration is declining, the percentage of participants with blood lead levels greater

than 10 and 15 ug/dl (P10 and P15), respectively, has not significantly changed over

time; implying that there is a "tail" at the high end of the blood lead distribution that has

not responded to the current interventions. To develop a better understanding of the

determinants (or predictors) of blood lead, the panel recommendended dividing the

overall sample of children into two groups, i.e., those with blood lead levels above and

below the mean, and evaluate each group using a multi-variate regression to increase the

statistical power of these evaluations in an attempt to reveal the dominant exposure

pathways.

Work Group Comment/Recommendation:

The Work Group is in agreement that the IRP's observations on this issue are among the

most significant findings of the Independent Review Panel's report. Previous data

evaluation efforts (included in recent Annual Reports) have utilized all paired data to

prepare bi-variate plots to represent the relationship between blood lead and

environmental media data. The Work Group has discussed the possibility of performing

more robust analyses (i.e., to include data from multiple, or more recent, years or to

perform multi-variate regression analyses) and has tasked the Performance Standards

Working Group with developing a cost-effective, step-wise approach to investigate the

determinants of elevated blood lead levels in the persitent upper tail of the distribution.

The Work Group concurs with the IRP's recommendation to develop a specific plan or

strategy following a structured process to investigate additional data evaluation

techniques or efforts to help in determining the factors that contribute to elevated blood

lead levels in Leadville children.

II. Evaluation of Performance
See Attachment B - Work Group Requests for Clarification and Summary of Panel

Responses for additional discussion on the questions posed and responses provided in this

Section.

III. Annual Report

Original Question;

III.l Please comment on whether the LCCHP Annual Reports (2001 and 2002) meet the

requirements and expectations of the Work Plan.

Panel Response;

The Panel felt that the Annual Reports met the requirements and expectations of the

Work Plan but offered the following recommendations for improvement:

i. Include a target date to achieve program objectives; and

ii. Provide an executive summary that highlights outcomes in layman's terms.

Work Group Comment/Recommendation:

i. Please refer to the Work Group Request for Clarification and Summary of Panel

Responses (Attachment B). The Work Group recommends that a timeline

regarding decisions related to program's performance be included in the

structured data evaluation plan referenced in Item 1.4 above.

ii. The Work Group will include an executive summary in future Annual Reports.

Original Question;

III.3.a (Paraphrased) With respect to improving future Annual Reports, do you recommend

additional data analysis to support compliance with the RAOs:

Panel Response;

The Panel recommends that the annual report should include a frequency distribution of

hemoglobin concentrations.

Work Group Comment/Recommendation;

The Blood Lead Program collects hemoglobin data, but has not formally reported this

information in the past. The Work Group has recommended that the Blood Lead

Program provide this information along with blood lead concentration for evaluation by

the Work Group. This information will be incorporated in the next Annual Report.
IV. Other

Original Question;

1V.1 Please provide any other feedback or thoughts you feel may be helpful to the Work Group

in managing the ongoing implementation of the Program.

Panel Response;

The Panel provided (in part) the following recommendations that the Work Group would

like to comment on:

i. In their feedback to this question, the Panel expressed a concern regarding the

long-term effectiveness of the remedy and specifically cited their opinion of the

importance of Institutional Controls.

ii. While not asked to comment on the trigger levels for environmental response

actions, the Panel did recommend a more aggressive response for deteriorated

lead based paint hazards (>1 and <6 mg/cm2) and suggested the use of dust lead

loading (evaluated by wipe sampling) rather than dust concentration (evaluated

by vacuum sampling) for the evaluation of risks related to lead in dust.

Work Group Comment/Recommendation;

i. The Institutional Controls (ICs) program, as required by the ROD to support the

LCCHP, is currently under development with ongoing discussions occurring

between the County, the EPA and the CDPHE. As such, details of the proposed

ICs program were not provided to the Independent Review Panel for their

consideration in their review of the Program. Please refer to the additional

discussion provided in Attachment B.

ii. Please refer to the discussion provided in Attachment B (item Il.l.a.i) for

additional discussion regarding the development of the trigger criteria for the

LCCHP. It should be noted that the Baseline Human Health Risk Assessment

was not provided to the Independent Review Panel because it was not

considered to be within the scope of the program review, consistent with the

requirements for the Independent Review in the Work Plan.

With respect to the comments related to the dust sampling methodology utilized

by the LCCHP, the vacuum sampling method employed by the LCCHP is a HUD

approved method and the only available method to provide results of lead

concentration in dust, which are required for comparison to the lead

concentration trigger criteria enumerated in the ROD.

In addition, the Work Group would like to clarify that while the trigger criteria

cite a preference for education of participants at properties where paint with lead

concentrations between 1 and 6 mg/cm2 are present, more aggressive actions (i.e.,

response actions) are considered, on a case-by-case basis, at properties where

young children reside.

SUMMARY OF PANEL RECOMMENDATIONS
In addition to the Panel responses enumerated above, a number of other comments and

recommendations (not specifically identified in the body of the Panel's report) were

included in the Summary of Panel Recommendations at the end of their report. Work

Group comments and recommendations on these items are listed below:

Panel Recommendation:

Modify the access agreement to allow for long-term monitoring and surveillance of dust

lead levels, maintenance of soil remediation, etc. following initial remediation.

Work Group Comment/Recommendation;

In accordance with the Work Plan, follow-up inspections are routinely conducted

approximately one year following remediation to inspect the condition of completed

actions. Clearance sampling is performed following dust and paint actions and

residents/owners are provided with instructions on maintaining their property to minimize

lead exposures. While long-term monitoring of dust lead levels within a home is not

conducted under the program, some follow-up sampling has been conducted in the past,

and resampling of a property may be performed at the owner/residents request or in

response to an elevated blood lead level. Based on the IRP's comments, the Work Group

recommends that all currently available information related to post remediation or

follow-up dust sampling be reviewed. Based on that review, the Work Group will make

a recommendation to EPA regarding the importance and utility of resampling dust at a

select number of properties as part of the five-year review process for the Superfund Site.

Panel Recommendation:

Initiate follow-up monitoring of the effectiveness of educational efforts in lowering blood

lead levels by observing the condition of lead-based paint and testing dust lead levels,

and interviewing "educated" families.

Work Group Comment/Recommendation;

As stated in the preceding comment, the program does not currently perform long-term

monitoring of paint and dust. The performance of such an effort would require additional

resources and funding. The Work Group recommends that the program continue its

practice of performing additional investigations and interviews to follow-up on EBL

children residing at properties that have been sampled and remediated if blood lead levels

are not observed to decline. The educational subcommittee of the Work Group has

discussed the development of a survey or other method to evaluate the effectiveness of

the educational efforts.

Panel Recommendation:

Reduce reliance on HEPA vacuums as an active form of remediation. The filters may

actually reduce suction and decrease efficiency.

Work Group Comment/Recommendation;

The use of HEPA vacuums through the vacuum loan program administered by the

LCCHP is not considered active remediation. These vacuums are made available to

participants where active remediation is pending, or to residents that may be remodeling

their homes. When a dust removal response action is performed by the program as active

remediation, the use of HEPA vacuums is recommended by the HUD Guidelines and

required under Colorado's Regulation 19. Active dust removal, as described in the Work
Plan, also involves the cleaning of hard surfaces in addition to vacuuming, in accordance

with HUD guidelines and State Regulations.

Panel Recommendation;

Remove references to the use of TSP as an active form of remediation. It has a tendency

to damage paint and has not demonstrated significant effectiveness in lowering EBLs.

Work Group Comment/Recommendation;

The use of TSP as a cleaning agent as part of a dust removal response action was a

standard method referenced in both the HUD guidelines and State regulations, at the time

the Work Plan was developed. The Work Group recommends modifying the Work Plan

to reflect the current HUD Guidelines and State regulations, which have removed the

specific reference to TSP, and replaced it with "a cleaning agent".

Panel Recommendation;

Distribute free iron supplements and vitamins at the Health Department, as appropriate,

to simplify availability and enhance recruitment.

Work Group Comment/Recommendation;

The Lake County Health Department has investigated this issue and has reported to the

Work Group that the vitamins recommended by local doctors contain fluoride and are not

available 'over the counter'. The cost of these vitamins is approximately $16 per 100

tablets. The Work Group is recommending that a voucher for vitamins be provided to all

children with elevated blood leads and low hemoglobin levels. Following further

evaluation of the association between hemoglobin and blood lead data (to be included in

the 2003 Annual Report as recommended in Item Ill.S.a), the Work Group will revisit the

issue of whether to consider broader distribution.

Panel Recommendation;

Educate and encourage realtors to practice HUD and EPA mandated regulations

regarding representations of condition that are accurate and unbiased.

Work Group Comment/Recommendation;

All property owners participating in the program are made aware of these requirements

and realtors are identified as a target group for education and outreach efforts. The

educational subcommittee of the Work Group will redistribute materials to local realtors

regarding these disclosure requirements.

Panel Recommendation;

Provide properly owners with a "clean letter" from the EPA once successful remediation

of their property has been accomplished.

Work Group Comment/Recommendation;

The Work Group believes that the procedures currently in place for the LCCHP provide

the necessary information to property owners regarding the completion of remediation at

their property. The LCCHP provides Property Documentation Reports to all owners who

have entered the program that provide all information on environmental sampling and
remedial actions, if performed, and reference to EPA's approval of the Work Group's

recommendations.

Panel Recommendation;

Encourage construction and remodeling that incorporates bare floors that are easier to

clean and trap less dust than carpet, especially in entryways.

Work Group Comment/Recommendation:

The educational subcommittee of the Work Group discussed the IRP's suggestion of

encouraging bare floors when remodeling. Since there is some controversy around this

topic nationally the group recommends that information be presented in the "Tips for

reducing lead in your home" brochure and that residents be encouraged to contact the

program for information regarding lead hazards prior to remodeling.

Panel Recommendation;

Welcome the press and media to become involved in excercises such as this Independent

Review Panel.

Work Group Comment/Recommendation:

The press and media are not invited to Work Group meetings due to the confidential

nature of the information discussed. However, the press and media can attend public

meetings periodically scheduled with local community leaders to discuss the progress and

achievements of the program(See Item 1.2). In addition the local press is used to

advertise the program and employees of the local newspapers have participated in the

environmental program.

10
ATTACHMENT D

SCOPE OF WORK

And

KEY ISSUES/QUESTIONS
LAKE COUNTY COMMUNITY HEALTH PROGRAM

INDEPENDENT REVIEW PANEL

SCOPE OF WORK

The Lake County Community Health Program (LCCHP) is the remedial action selected by the

U.S. EPA to address human health risks from exposure to sources of lead within Operable Unit 9

(Residential Populated Areas) of the California Gulch Superfund Site (the Site). The Site lies

within Lake County, Colorado, which is a relatively small (380 square miles), predominantly

rural county with a 2000 population of approximately 7,800 (U.S. Bureau of the Census, 2000).

According to records from the Lake County Assessor's Office, there were approximately 3,500

residential units, including multiple-dwelling units, located within OU9 in 1999.

The LCCHP is an innovative remedy that has been designed to reduce overall lead-related risk to

children in Leadville by including responses that address numerous sources of lead exposure,

even sources that would not be addressed under EPA's Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA) authorities. The potential sources of lead exposure

that are addressed by the LCCHP's investigation and remediation programs include soil, house

dust, drinking water and interior and exterior paint. This comprehensive approach was originally

proposed and eventually adopted in response to strong community interest in managing exposures

to lead in lieu of a more conventional, residential-soil removal program. The program was

designed to operate in a manner that minimizes impacts to the community and optimizes the use

of available resources to reduce resident children's lead exposure and ultimately reduce

community-wide blood lead levels to meet EPA's risk-reduction goals for this Site.

The LCCHP has been implemented since May 2000 and currently provides a range of services to

assist residents in reducing their exposure to lead in and around their homes. These services

include routine blood lead testing for resident children and pregnant or nursing women,

environmental lead investigations at residential properties within OU9, remediation of potential

sources of lead exposure identified through those investigations and community education and

awareness programs. Residents' participation in any aspect of the program is voluntary.

The quantitative remedial action objectives (RAOs) of the selected remedy for OU9 were stated

in the EPA's Record of Decision (ROD) (EPA, 2000), as follows:

RAO-1: No more than 5 percent of all children (ages 0 to 72 months) who live at this site,

either now or in the future, will have blood lead values higher than 10 ng/dL.

RAO-2: Health will be adequately protected if the highest risk level at any sub-location is

a probability that no higher than one percent that a population of children (ages 0 to 72

months) residing at that sub-location will exceed a blood lead value of 15 ug/dL.

An additional qualitative RAO was added during the development of the Feasibility Study for

OU9 and also considered during remedy selection:

Reduce the direct exposure of lead incurred by children, which will result in optimal risk

reduction through effective use of resources.

Since selection of the remedy, more detailed performance standards were developed to define the

measures used to evaluate performance of the LCCHP relative to these RAOs.
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Because the LCCHP is distinct in its approach from typical Superfund remedies selected to

address sources of lead in residential areas, the EPA has required that design and implementation

of the program be reviewed and evaluated by a panel of experts who have experience

implementing or evaluating lead risk reduction programs but who are not directly involved in the

LCCHP or its original development.

The independent panel will be tasked with completing a thorough review and evaluation of

LCCHP design and implementation. The goal of this review will be to provide recommendations

for improving the overall effectiveness and efficiency of the program in meeting its stated

objectives and established performance standards. The review will include the following tasks:

• review and comment on the LCCHP Work Plan (MFG, 2000), the 'design' document

and implementation plan for the program;

• review and evaluate the administration and implementation of the program with

respect to the requirements of the Work Plan;

• evaluate and comment on the remedy's performance standards as measures of the

overall effectiveness of the LCCHP;

• evaluate community outreach and education programs and make recommendations

for improving their effectiveness; and

• evaluate resident participation in blood lead monitoring and environmental testing

programs and make recommendations for improving participation, if warranted.

The focus of the independent review panel shall be to evaluate the structure and operation of the

program and the appropriateness of performance standards. The panel will have the opportunity

to make recommendations for improving the design and implementation of the LCCHP, as they

see necessary. This scope of review includes a broad range of program components, including:

program administration and work group operations; recruitment activities; community awareness

and education programs; interactions with program participants; environmental testing program

and procedures; blood lead testing program and procedures; data evaluation practices;

implementation of response actions; and data management and reporting practices. The

independent review is not intended to address certain fundamental elements of the program

described in the Record of Decision (ROD), including: remedial action objectives, the voluntary

nature of the program, program eligibility, the media addressed, and trigger criteria for the

various media used as the basis for recommending response actions.

Members of the independent panel will convene in Leadville, Colorado to observe the functioning

elements of the program and to meet with LCCHP staff, the advisory work group (includes state

and local health department representatives) and a group of program participants. Members of

the review panel will be provided with the following information, prior to visiting the Site, to

assist them in initiating the review process:

• Record of Decision for Operable Unit 9, Residential Populated Areas, California

Gulch Superfund Site, Leadville, Colorado. U.S. EPA, September 1999.

• Work Plan for the Lake County Community Health Program, Operable Unit 9,

Residential Populated Areas, California Gulch Superfund Site. December 2000.
• Methods and Standards for Evaluating the Performance of the Lake County

Community Health Program. July 2002.

• Leadville Kids First Program Report, 1994-1999 Progress and Results. February

2001.

• Lake County Community Health Program, 2001 Annual Report. July 2002.

• Lake County Community Health Program, 2002 Annual Report. June 2003.

• Package of information containing brochures and educational materials distributed as

part of the outreach efforts of the program.

Additional background documents and information regarding the program will be made available

to the review panel, upon request, following the completion of their initial review.

It is anticipated that the review panel will complete its review during a two-day working session

in Denver and Leadville. An agenda for the two-day program review session is attached. Panel

members will be expected to review the above referenced information prior to arriving for the

working session. A list of key issues and/or questions to be answered by the review panel will be

provided to the panel in advance of the working session. The purpose of this list is to provide a

focus for the review and to provide a format for the work product to be developed by the review

panel. A facilitator will be assigned to the review panel to assist them in coordinating their

review and in compiling their work product. The working session will consist of a series of

interactive presentations conducted by program staff and Work 'Group members, focused on

certain aspects of the program, a site tour, and an opportunity to interact with local community

leaders and possibly program participants. The final session of the program review will be

reserved for a private session with the review panel and the facilitator at which time they will

have the opportunity to draft their findings and responses to the list of questions provided, and

compile a list of recommendations. The work product resulting from this independent review

will be a written report detailing the findings and recommendations of the review panel. The

final report of the independent review panel shall be submitted within 30 days of the completion

of the working session. The facilitator will circulate a draft of the report to panel members

following the working session and will coordinate the finalization and submittal of the report.

The report will be submitted directly to the LCCHP's advisory work group, Lake County Health

Department, CDPHE and EPA. After receiving the independent panel's findings and

recommendations, the Work Group will review and discuss this report and make a final

recommendation to the EPA regarding the implementation of any changes to the operation of the

program.

J:\BLDOI\5626\TasklO\PeerReview\IndRevSOW Final.doc
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LAKE COUNTY COMMUNITY HEALTH PROGRAM

INDEPENDENT REVIEW PANEL

KEY ISSUES/QUESTIONS

The Independent Review Panel is being tasked with preparing a written report detailing

their findings and recommendations developed through the review of the program. The

LCCHP Work Group has prepared this list of questions and issues to solicit input from

the review panel on specific aspects of the program. The Work Group is requesting that

the panel's final report be divided into sections corresponding with the headings provided

in this document, followed by responses to the specific questions posed below and any

other feedback the review panel would like to provide. The Work Group does not

anticipate that the final report will contain lengthy background discussion, rather a

compilation of comments and recommendations that the LCCHP Work Group and the

EPA can consider to further improve the implementation and effectiveness of the

program.

I. LCCHP Implementation

Based on the Panel's review of the LCCHP Work Plan and the Program's

operations to date, please address the following:

1. Is the Program being implemented in a manner consistent with the design

presented in the Work Plan?

2. Please provide any suggestions or recommendations you may have for

improving the structure (i.e., organization, responsibilities and internal

communications) of LCCHP management and administration.

3. In providing your feedback with respect to the implementation of the

Program, please consider these specific components of the Program

design:

- Program administration and Work Group operations;

- Community awareness, education, and recruitment activities;

- Interactions with Program participants and coordination between

environmental testing and blood lead programs;

- Environmental testing program and procedures;

- Blood lead testing program and procedures;

- Data management, evaluation, and reporting practices;

- Implementation of response actions; and

- Documentation and reporting practices.

4. Statistical Unit 1 has not met the performance standards criteria; please

provide any additional implementation recommendations that could be

considered by the Work Group to meet these standards.
II. Evaluation of Performance

Based on the Panel's review of the ''Methods and Standards for Evaluating the

Performance of the Lake County Community Health Program' document (the

'Performance Standards Document') and the evaluation of data from the years

2000, 2001, and 2002, presented in the 2002 Annual Report, please address the

following:

1. Please comment on the appropriateness and applicability of the statistical

methods and standards presented in the Performance Standards Document

for evaluating the performance of the Program with respect to the

established Remedial Action Objectives.

a. Is the rationale for each performance standard adequately described,

appropriate, and scientifically defensible?

b. Does the method adequately demonstrate the long-term effectiveness

of the remedy and compliance with RAOs?

2. Please comment on the data evaluation techniques and statistical methods

presented in the Performance Standards Document and make any

suggestions or recommendations for modification or improvement.

a. Have Type I and Type II error rates been assessed adequately and in a

scientifically defensible manner?

b. Has the uncertainty in the P10 and PI5 values been assessed

adequately and in a scientifically defensible manner?

c. Do the required criteria adequately assess the overall

representativeness of the available blood lead data, used to derive the

theoretical blood lead distribution for the community at large?

d. Does the test of proportions used in Performance Standard 4 provide

reasonable assurance that blood lead program participants are not from

residences that underestimate the high end of the soil lead distribution

for the statistical unit as a whole?

e. Do the methods and standards for evaluating performance provide

reasonable assurance that the Program's goal regarding residual risk —

to ensure that whatever residual risks that remain will be sufficiently

low as to not exceed the RAOs (described in section 7.0 of the

Performance Standards Document) - will be achieved?

III. Annual Report

Based on the Panel's review of the 2001 and 2002 Annual Reports and the 1994-

1999 Progress and Results Report, please address the following:

1. Please comment on whether the LCCHP Annual Reports (2001 and 2002)

meet the requirements and expectations of the Work Plan.
2. Please comment on whether data presented in the 2002 annual report are

adequate to support evaluation of the program performance standards

(Refer to Appendix D of the 2002 Annual Report)?

3. Please make any suggestions or recommendations for improving the value

and usefulness of future annual reports. However, in making your

suggestions and recommendations, please be mindful that these are

produced as public documents and the confidentiality of program

participants must be maintained.

a. Do you recommend additional data analysis to support compliance

with the RAOs?

b. Are there components of the data analysis presented in the annual

report that you feel are not necessary?

c. Can you identify ways to streamline the annual report?

IV. Other

1. Please provide any other feedback or thoughts you feel may be helpful to

the Work Group in managing the ongoing implementation of the Program

and ensuring long-term protection of public health.

2. Was the Independent Review Panel provided with the tools and

information needed to complete the Program review in accordance with

the Scope of Work?

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