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UNITE D STATE S ENVIRONMENTA L PROTECTION AGENC Y REGION VIM

9 99 18th STREET - SUITE 500

DENVER , COLORADO 80202-2466

534738

Ref: EPR-SR

FINAL POLLUTION REPORT

CALIFORNIA GULCH , OPERABLE UNIT I X

REMOVAL ACTIONS PERFORMED UNDER THE KID S FIRST PROGRAM

I . HEADIN G

Date: December 15,1998

Subject: California Gulch Superfun d Site , Operable Unit IX, Residential Soil s

Twenty (20) Time-Critical Removals Performed Under the Kids First Program During the Time Period Startin g October 31,1997 thru Novembers, 1998.

From: Rebecca Thomas, Remedial Project Manager

T o: Max H. Dodson Assistant Regional Administrator Office of Ecosystems Protection and Remediation

POLREP No.: POLREP 1 and FINAL

I I . BACKGROUN D

N P L Status: FINA L

Site No. COD980717938

Action Memorandum Status: Approval dates for Action Memorandums, Start Dates and Completion Dates are indicated below

for each property in descriptions of each

response action.

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I l l SIT E INFORMATION

T he California Gulch Site (Site) was listed on the National Priorities List on September 8, 1983. The site is in a historic mining area covering 16 % square

miles of a watershed that drains along California Gulch to the Arkansas River. Startin g in 1859, the area was mined extensively for gold, lead, silver, copper, zinc,

a nd manganese. Six impounded tailings dumps surround the city of Leadville, Colorado. Many smelters, which were located around the City, processed silver,

lead and zinc at various times. Heavy metal residues are present in much of the Site. Approximately 7,400 people live in Leadville and Lake County. As a result of the August 1994 Consent Decree between the United States and

various potentially responsible parties, Asarco, Inc. has assumed the responsibility

to address the Residential Soil s Operable Unit IX (OU IX). The Consent Decree

calls for the formation of the Kids First Program (KFP). T he Kids First Program is designed to reduce young children's exposure to lead. T he Program also provides information to the community about lead found within

the home and environment.

T he Kids First Program was developed by the State of Colorado, EPA and Asarco

with input from the City of Leadville and Lake County. The City of Leadville and Lake County, State of Colorado, EPA and Asarco work together on Kids First as the Kids First Work Group. Thi s program is being implemented as outlined in the Consent Decree with guidance from the Kids First Work Group.

This program is an interim program until a Record of Decision is established for the

residential area.

T he Kids First Program is a voluntary program consisting of:

* Providing an educational program to the Leadville community about staying

safe around lead,

* establishing a loan program of HEPA (High Efficiency Particulate Aerosol)

vacuums to reduce lead dust inside homes,

* conducting environmental assessments of soils, dust, paint and water to

determine those eligible for a response action,

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* recommending appropriate response actions to ERA for approval and

implementation by Asarco, and

* continuing the on-going blood lead monitoring through Lake County Nursin g Services.

I V. RESPONSE INFORMATION

T he Time Critical Removal Actions listed below were performed under the Kids First

program. Exhibits/Figures are provided in each Action Memorandum to depict the

areas to be remediated.

Operable Unit 9, KFP Removal 21

An Action Memorandum for a Time Critical Removal at the Trujillo residence

located at 712 East 6th Street, Leadville, Colorado, was signed on December 1,

1997. Soil s in the front yard of the Trujillo property exceeded the KFP Trigger level

of 3,500 ppm lead.

The action consisted of removal of soil to facilitate grading and drainage

requirements and installation of a 6 inch cover over the entire property. Cover materials consisted of topsoil , sod, gravel, concrete, road base. In addition an

asphalt drainage swale was graded along the south property line (along East 6th Street) to minimize surface water run-on from up-gradient of the property.

The structure located at the Trujillo residence, has been determined to be noncontributing to the Leadville Historic Mining District by the State Historic Preservation Offic e (SHPO). However, archaeological potential has been

identified at this property. A cultural resource professional monitored excavation

of soils at this property.

The Removal Action at the Trujillo residence was completed by October 23,1998.

ACTION MEMORANDUM SIGNED : DECEMBER 1,1997

REMOVAL START: DECEMBER 1,1997

REMOVAL COMPLETE: OCTOBER 23,1998

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Operable Unit 9, KFP Removal 22

An Action Memorandum for a Time Critical Removal at the Vierczhalck residence

located at 322 West 3rd Street, Leadville, Colorado, was signed on December 1,

1997. Soil s in the beds adjacent to the house exceeded the KFP trigger level of

3,500 ppm lead.

The action consisted of removal of material to a depth of 6 inches in the four slag

covered flower beds followed by installation of 6 inches of river-washed gravel in

two of the beds adjacent to the west side of the house. Six inches of top soil was

installed in the third bed adjacent to the house and in the bed adjacent to the south

side of the shed.

The structure located at the Vierczhalck residence has been determined to be noncontributing to the Leadville Historic Minin g District by the State Historic Preservation Offic e (SHPO) . The Removal Action at the Vierczhalck residence was completed by Jun e 11,1998.

ACTION MEMORANDUM SIGNED : DECEMBER 1,1997

REMOVAL START : JUNE 8,1998

REMOVAL COMPLETE: JUNE 11,1998

Operable Unit 9, Kids Firs t Program (KFP) Removal 23

An Action Memorandum for a Time Critical Removal at the Gonzales residence

(815 East 6

th

 Street) was signed on Jun e 8,1998. Samples collected under the Kids First Program determined that lead levels in samples collected from soils in

several areas of the Gonzales property, located at 815 East 6

th

 Street, Leadville, Colorado, exceeded the Kids First trigger value of 3,500 ppm.

T he action consisted of installation of cover materials includin g top soil, sod, clean

backfill , cobbles, roadbase and concrete. A concrete pad and road base was

installed from the existing concrete pad in front of the garage to East 6

th

 Street. A

minimum of six inches of material was removed from the area where the road base

was installed. Top soil was removed to a depth of six inches from the area located

along the east side of the property and was replaced with road base. Top soil was

installed in the front yard from the house to the north fence line. Clean fill material

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and large cobbles were installed from the fence line to East 6

th

 Street. Six inches

of material was removed from the two flower beds (one on the east side of the

house and one on the north side). The area was backfilled with top soil.

T he State Historic Preservation Office (SHPO) has determined that the structure

on the Gonzales property is non-contributing to the Leadville Historic Minin g District. Since archaeological potential was identified at the property, a cultural

resource profession monitored excavation of soils at this property.

The Removal Action at the Gonzales residence (815 East 6

th

 Street) was

completed by July 7,1998.

ACTION MEMORANDUM SIGNED : JUN E 8,1998

REMOVAL START : JUNE 8,1998

REMOVAL COMPLETE : JULY 7,1998

Operable Unit 9, KFP Removal 24

An Action Memorandum for a Time Critical Removal at the Foy residence, located

at 172 South Toledo Street, Leadville, Colorado, was signed on July 7, 1998. Samples collected under the Kids First Program determined that lead levels

in samples collected from the gravel and slag driveway, from the landscaped

area adjacent to the driveway, and from the small flower bed in the front yard

near the driveway at the Foy property exceeded the Kids First trigger value of

3,500 ppm. In addition, the areas are either bare or accessible to the children.

Remediation activities included removal of soil as appropriate to facilitate

grading and drainage requirements; installation of a concrete pad centered on

the sidewalk; removal of six inches of material and installation of a minimum

of six inches of compacted road base on the remainder of the driveway;

installation of a minimum of six inches of top soil in the landscaped area; and

removal of a minimum of six inches of material and replacement with topsoil

in the flower bed.

The structure on this property has been determined to be non-contributing to

the Leadville Historic Mining District by the State Historic Preservation Offic e (SHPO). In addition , because the areas to be remediated have been

disturbed, archaeological potential is not considered significant. Therefore the

response action was not monitored by a cultural resource professional.

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The Removal Action at the Foy residence was completed by July 11,1998

ACTION MEMORANDUM SIGNED : JULY 7,1998

REMOVAL START: JULY 7,1998

REMOVAL COMPLETE : JULY 11,1998

Operable Unit 9, KFP Removal 25

An Action Memorandum for a Time Critical Removal at the Kolakowski residence

located at 813 Spruce Street, Leadville, Colorado, was signed on July 7, 1998. Sample s collected under the Kids First Program determined that lead levels

in samples collected from the soils in the flower bed along the back of the

house and the small back yard at the Kolakowski property exceeded the Kids First trigger value of 3,500 ppm. The grass in the back yard is dense and in

good condition. Therefore, no remediation activities were performed in that

area.

Remediation activities in the flower bed along the west side of the house

included removal of material to a minimum depth of six inches and

replacement with six inches of top soil.

The structure on this property has been determined to be potentially

contributing to the Leadville Historic Minin g District by the State Historic Preservation Offic e (SHPO). SHPO assigned the site number 5LK40.105

to this property. However, because the areas to be remediated have been

disturbed, archaeological potential was not considered to be significant. Therefore, the response action was not monitored by a cultural resource

professional..

The Removal Action at the Kolakowski residence was completed by Jul y 14,1998.

ACTION MEMORANDUM SIGNED : JULY 7,1998

REMOVAL START: JULY 7,1998

REMOVAL COMPLETE : JULY 14,1998

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Operable Unit 9, KFP Removal 26

An Action Memorandum for a Time Critical Removal at the Patti residence , located at 130 West 7

th

 Street, Leadville, Colorado was signed on July 7,1998. Samples collected under the Kids First Program determined that

lead levels in samples collected from the soils in the flower bed along the

west side of the house and the front yard at the Patti property exceeded the Kids First trigger value of 3,500 ppm. The grass in the front yard is dense and

in good condition. No remediation activities were performed in that area.

Remediation activities in the flower bed along the west side of the house

included removal of material to a minimum depth of six inches and

replacement with six inches of top soil.

The structure on this property has been determined to be potentially

contributing to the Leadville Historic Minin g District by the State Historic Preservation Offic e (SHPO). SHPO assigned the site number 5LK40.107

to this property. However, because the areas to be remediated have been

disturbed, archaeological potential is not considered to be significant. Therefore, the response action was not monitored by a cultural resource

professional.

The Removal Action at the Patti residence was completed by July 14,1998.

ACTION MEMORANDUM SIGNED : JULY 7,1998

REMOVAL START: JULY 7,1998

REMOVAL COMPLETE : JULY 14,1998

Operable Unit 9, KFP Removal 27

An Action Memorandum for a Time Critical Removal at the Ramos residence , located at Lake Fork Trailer Park #26, Leadville, Colorado, was signed on July 7,

1998. Samples collected under the Kids First Program determined that lead

levels in samples collected from soils in the bare areas at the front and back

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of the trailer and yard surrounding the trailer at the Ramos property exceeded

the Kids First trigger value of 3,500 ppm. In addition, the grass in yard is

spotty and in poor condition.

Remediation activities included removal of material to a minimum depth of six

inches in the two bare areas and the yard. Top soil and sod were installed in

the area. A five inch strip of topsoil (to allow plantin g of beddin g plants) was

installed along the edges.

The structure on this property has been determined to be non-contributing to

the Leadville Historic Mining District by the State Historic Preservation Offic e (SHPO). In addition , because the areas to be remediated have been

disturbed, archaeological potential is not considered significant. Therefore

response actions were not monitored by a cultural resource professional.

The Removal Action at the Ramos residence was completed by Jul y 17,1998,

ACTION MEMORANDUM SIGNED : JULY 7,1998

REMOVAL START: JULY 7,1998

REMOVAL COMPLETE : JULY 17,1998

Operable Unit 9, KFP Removal 28

An Action Memorandum for a Time Critical Removal at the Alien residence, located

at 203 West 9

th

 St, Leadville, Colorado was signed on August 17,1998. Samples

collected under the Kids First Program determined that lead levels in the

sample collected from soils in the bare area of the back yard at the Alien

property exceeded the Kids First trigger value of 3,500 ppm.

Remediation activities included removal of material to a minimum depth of six

inches and replacement with Class six road base which was installed and

compacted in this area. A border of railroad ties was installed between the

road base and existing grass.

The structure on this property has been determined to be potentially

contributing to the Leadville Historic Landmark District by the State Historic Preservation Offic e (SHPO). SHPO assigned the site number 5LK40.106

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to this property. In addition, archaeological potential has been identified at

this property. Therefore a cultural resource professional monitored excavation

of soils at this property

The Removal Action at the Alien residence was completed by September?, 1998.

ACTION MEMORANDUM SIGNED : AUGUST 17,1998

REMOVAL START: AUGUST 17,1998

REMOVAL COMPLETE : SEPTEMBER 7,1998

Operable Unit 9, KFP Removal 29

An Action Memorandum for a Time Critical Removal at the Cruz-Sanchez

residence was signed on August 17,1998. Samples collected under the Kids First Program determined that lead levels in the samples collected from soils

in the driveway and the yard in front of the trailer at the Cruz-Sanchez property

exceeded the Kids First trigger value of 3,500 ppm and the area is bare. Remediation activities are described below:

The condition of the front yard was evaluated in the field and the area was

prepared for sod and topsoil and sod was installed. Remediation activities for

the driveway, shown on Figure 3, include removal of a minimum of six inches

of material. A six inch reinforced concrete pad will be installed in the driveway

to match surrounding grade and will be graded to drain toward the street.

T he structure on this property does not contribute to the Leadvllle Historic Landmark District because it is a mobile home. Excavation of soils at this

property was not monitored by a cultural resource professional because the

area had been disturbed.

The Removal Action at the Cruz-Sanchez residence was completed by September 2,1998.

ACTION MEMORANDUM SIGNED : AUGUST 17,1998

REMOVAL START: AUGUST 17,1998

REMOVAL COMPLETE : September 2,1998

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Operable Unit 9, KFP Removal 30

An Action Memorandum for a Time Critical Removal at the Daigle residence,

located at 323 West 4

th

 Street, was signed on August 17, 1998. Sample s

collected under the Kids First Program determined that lead levels in the

samples collected from soils in the bare area in the southeast comer of the

property and soils in the flower bed in the backyard at the Daigle property

exceeded the Kids First trigger value of 3,500 ppm. The area in the southeast

comer is in poor condition and soils in the flower bed are accessible to

children.

Remediation activities for the bare area included removal of material to a

minimum depth of six inches and replacement with clean topsoil and sod. An

approximate one foot wide strip of river washed gravel was installed along the

garage. Metal edging was installed between the gravel and the sod. Remediation for the flower bed included removal of a minimum six inches of

soil and replacement with clean topsoil to match the existing grade.

The structure on this property has been determined to be potentially

contributing to the Leadville Historic Landmark District by the State Historic Preservation Offic e (SHPO). SHPO assigned the site number 5LK40.110

to this property. Archaeological potential was not identified at this property. Excavation of soils was not monitored by a cultural resource professional.

The Removal Action at the Daigle residence was completed on September 2,1998.

ACTION MEMORANDUM SIGNED : AUGUST 17,1998

REMOVAL START: AUGUST 17,1998

REMOVAL COMPLETE : SEPTEMBER 2,1998

Operable Unit 9, KFP Removal 31

An Action Memorandum for a Time Critical Removal at the Rhoades residence,

located at 211 East 4

th

 Street, Leadville, Colorado, was signed on September 17,

1998. Samples collected under the Kids First Program determined that lead

levels in the samples collected from soils in the bare area at the at the south

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end of the driveway and within the area of the concrete foundation of the Rhoades property exceeded the Kids First trigger value of 3,500 ppm. The

lead concentrations in samples collected from flower beds along the north and

west sides of the house also exceeded the Kids First trigger value. The lead

concentration in the samples collected from the gravel driveway and the

adjacent east side yard did not exceed the Kids First trigger value.

T he Kids First Work Group (KFWG) recommended remediation of the areas

with lead concentrations that exceeded the Kids First trigger value of 3,500

ppm (the flower beds along the north and west sides of the house and the

bare area at the south end of the driveway and within the area of the concrete

foundation). However, the property owners opted for no action in the flower

beds (which have thick, well established flowers and grasses) along the north

and west sides of the house.

Lead concentrations in the samples collected from the driveway and the

adjacent east side yard did not exceed the Kids first trigger value of 3,500

ppm. However, a child who had an elevated blood lead level (greater than 40

ug/dl) and underwent medical treatment to reduce her blood lead level spends

a significant amount of time at this property. Therefore, due to this special

circumstance, the decision was made to remediate the driveway and east side

yard.

Remediation activities included removal of material, as appropriate, to

facilitate grading and drainage requirements and to allow installation of a

minimum six inch cover in the areas to be addressed. Cover materials

consisted of concrete, compacted road base, topsoil , topsoil and sod, and

gravel.

T he State Historic Preservation Offic e (SHPO) has determined that this

property potentially contributes to the Leadville Historic Landmark District. Archaeological potential was identified at this property. Therefore, a cultural

resource professional monitored excavation of soils at this property.

The Removal Action at the Rhoades residence was completed on September 4,1998.

ACTION MEMORANDUM SIGNED : SEPTEMBER 17,1998

REMOVAL START: AUGUST 26,1998

REMOVAL COMPLETE : SEPTEMBER 4,1998

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Operable Unit 9, KFP Removal 32

An Action Memorandum for a Time Critical Removal at the Sorcic residence,

located at 430 East 8

th

 Street, Leadville, Colorado, was signed on September 17,

1998. Samples collected under the Kids First Program determined that lead

levels in the samples collected from soils in the bare area in the back yard

and from the gravel covered area in the front yard of the Sorcic property

exceeded the Kids First trigger value of 3,500 ppm. Remediation activities for the bare area in the backyard included removal of material to a minimum depth of six inches. Clean topsoil and sod was

installed over the area with the exception of a strip one foot wide strip along

the house where river washed gravel was installed. Metal edgin g was

installed between the gravel and the sod. Remediation for the gravel walk in

the front yard included removal of a minimum six inches of soil and

replacement with a concrete sidewalk graded to match the surrounding

grades. The driveway and drainage swale were excavated, as appropriate,

to allow drainage. An arch corrugated metal pipe (CMP) was installed in the

drainage swale. A six inch reinforced concrete slab was constructed over the C MP for the driveway to match the surrounding grades.

The structure on this property has been determined to be potentially

contributing to the Leadville Historic Landmark District by the State Historic Preservation Office (SHPO). SHPO assigned the site number 5LK1263 to

this property. Archaeological potential was identified in the backyard at this

property. Therefore, a cultural resource professional monitored excavation of

soils in the backyard.

The Removal Action at the Sorcic residence was completed on September 14,1998.

ACTION MEMORANDUM SIGNED : SEPTEMBER 17,1998

REMOVAL START: SEPTEMBER 3,1998

REMOVAL COMPLETE : SEPTEMBER 14,1998

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Operable Unit 9, KFP Removal 33

An Action Memorandum for a Time Critical Removal at the Wohlmuth residence,

located at 214 West 7

th

 Street, Leadville, Colorado was signed on September 17, 1998. Sample s collected under the Kids First Program

determined that lead levels in the samples collected from soils in the grass

area in the front yard; the flower beds on the east and west sides of the front

porch, the quarter circle flower beds in the front yard next to the sidewalk, and

the area in the backyard with thin grass cover of the Wohlmuth property

exceeded the Kids First trigger value of 3,500 ppm.

Remediation activities included removal of soils to a minimum depth of six

inches from the grass area and quarter circle flower beds in the front yard. Clean topsoil was placed in the excavated area and graded to match the

surrounding grade. Sod was then installed. The flower bed on the west side

of the porch was removed and reshaped similar to the flower bed on the east

side of the porch. A minimum of six inches of material was excavated from

the flower beds around the front porch and along the front of the house. Clean

topsoil was then installed in the two flower beds to match the surrounding

grade. A minimum of six inches of material was removed from the areas with

thin grass in the backyard. Clean topsoil was placed in the excavated areas

and graded to match the surrounding grades. Sod was then installed. The structure on this property has been determined to be potentially

contributing to the Leadville Historic Landmark District by the State Historic Preservation Offic e (SHPO). SHPO assigned the site number 5LK1262 to

this property. Archaeological potential was not identified at this property. Therefore, a cultural resource professional did not monitor excavation of soils

at this property.

The Removal Action at the Wohlmuth residence was completed on September 29,1998.

ACTION MEMORANDUM SIGNED : SEPTEMBER 17,1998

REMOVAL START: SEPTEMBER 17,1998

REMOVAL COMPLETE : SEPTEMBER 29,1998

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Operable Unit 9, KFP Removal 34

An Action Memorandum for a Time Critical Removal at the Grant residence,

located at 225 East 9th Street, in Leadville, Colorado was signed on September 24, 1998. Samples collected under the Kids First Program

determined that lead levels in the samples collected from soils in the bare

area in the back yard; from the soils in the front and east yards and from the

soils in the former flower bed along the east side of the house, on the Grant

property, exceeded the Kids First trigger value of 3,500 ppm. Remediation activities included removal of soil to a minimum depth of six

inches from the front and east side yards. Clean topsoil was placed in the

excavated area and graded to match the surrounding grade and to facilitate

drainage away from the house. Sod was then installed. The soils in the

former flower beds were removed to a minimum depth of six inches. A one

foot wide strip of river washed gravel was installed along the house. Metal

edging was be installed between the gravel and the sod. A minimum of six

inches of material was removed from the bare area in the back yard. Road

base was installed and compacted in the excavated area to match the

surrounding grade and to facilitate drainage away from the house and shed.

The structure on this property has been determined to be potentially

contributing to the Leadville Historic Landmark District by the State Historic Preservation Offic e (SHPO). SHPO assigned the site number 5LK1269 to

this property. Archaeological potential was identified in the backyard at this

property. Therefore, a cultural resource professional monitored excavation of

soils in the backyard.

The Removal Action at the Grant residence was completed on September 29,1998.

ACTION MEMORANDUM SIGNED: SEPTEMBER 24,1998

REMOVAL START: SEPTEMBER 24,1998

REMOVAL COMPLETE : SEPTEMBER 29,1998

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Operable Unit 9, KFP Removal 35

An Action Memorandum for a Time Critical Removal at the Lind residence, located

at 229 East 9th Street, in Leadville, Colorado was signed on September 24,1998. Samples collected under the Kids First Program determined that lead levels

in the sample collected from soils in the area covered with spotty grass in the

back yard and the east side yard of the Lind property, exceeded the Kids First

trigger value of 3,500 ppm.

Remediation activities included removal of soil to a minimum depth of six

inches from the back yard. Clean topsoil was placed in the excavated area

and graded to match the surrounding grade and to facilitate drainage away

from the house. Sod was then installed. A one foot wide strip of river washed gravel was installed along the house. Metal edging was installed

between the gravel and the sod. A minimum of six inches of material was

removed from the area between the east side of the house and the adjacent

house and replaced with pea gravel.

The structure on this property has been determined to be potentially

contributing to the Leadville Historic Landmark District by the State Historic Preservation Offic e (SHPO). SHPO assigned the site number 5LK1261 to

this property. Archaeological potential was identified in the backyard at this

property. Therefore, a cultural resource professional monitored excavation of

soils in the backyard.

The Removal Action at the Lind residence was completed on September 28,1998.

ACTION MEMORANDUM SIGNED : SEPTEMBER 24,1998

REMOVAL START: SEPTEMBER 24,1998

REMOVAL COMPLETE : SEPTEMBER 28,1998

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Operable Unit 9, KFP Removal 36

An Action Memorandum for a Time Critical Removal at the Lykins residence

located at 512 !4 East 7

th

 Street, Leadvtlle, Colorado, was signed on September 24,

1998. Samples collected under the Kids First Program determined that lead

levels in the sample collected from soils in the area between the sidewalk and

the house; the area along East 7th Street; the soils in the east side yard; and

the northeast comer of the backyard of the Lykins property, exceeded the Kids First trigger value of 3,500 ppm.

The remediation activities included removal of soil to a minimum depth of six

inches from the areas to be remediated. Clean topsoil was placed in the

excavated area in the east side yard, and graded to match the pre-existing

grade and to facilitate drainage away from the house. Sod was then

installed. A strip of gravel was installed along the house. Metal edging was

installed between the gravel and the sod. Clean topsoil was placed in the "L"

shaped area in the southwest comer of the east side yard. Clean topsoil was

placed in the excavation between the house and the sidewalk to match the

grade of the sidewalk. Road base was installed in the area between the

asphalt driveway and the house and compacted to match the grade of the

driveway and to facilitate drainage away from the house. Reinforced

concrete was installed in the excavation on the slope and the drainage swale

along East 7th Street and matching the grade of the asphalt. Clean sand was

placed in the northeast comer of the backyard. A six by six foot sandbox was

constructed within this area.

T he State Historic Preservation Office (SHPO) determined that the structure

located on this property does not contribute to the Leadville Historic Landmark District. Archaeological potential was identified in the backyard at this

property; therefore, a cultural resource professional monitored excavation of

soils in the backyard. Archaeological potential was not identified in the other

areas to be remediated; therefore, monitoring by a cultural resource

professional was not required in the other areas involved in this response

action.

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The Removal Action at the Lykins residence was completed on October 19,1998.

ACTION MEMORANDUM SIGNED : SEPTEMBER 24,1998

REMOVAL START: SEPTEMBER 24,1998

REMOVAL COMPLETE : OCTOBER 19,1998

Operable Unit 9, KFP Removal 37

An Action Memorandum for a Time Critical Removal at the Quintana residence

located at Lake Fork Trailer Park #115, Leadville, Colorado, was signed on September 24, 1998. Samples collected under the Kids First Program

determined that lead levels in the sample collected from soils from the flower

bed in the front yard; from the soils in the north side yard and from the soils

at the east end of the lot and along the south side of the mobile home of the Quintana property, exceeded the Kids First trigger value of 3,500 ppm.

The remediation activities included removal of soil to a minimum depth of six

inches from the areas to be remediated. Clean topsoil was placed in the

excavated area in the flower bed at the front of the mobile home and graded

to facilitate drainage away from the mobile home. Sod was then installed. Road base was placed and compacted in the excavation along the north side

of the porch. Clean topsoil and sod was installed in the excavation along the

north side of the mobile home to the east end of the lot and graded to facilitate

drainage away from the mobile home. Road base was placed and compacted

in the excavation at the east end of the shed and along the south side of the mobile home and graded to facilitate drainage away from the shed and mobile

home.

The structure located on this property if a mobile home; therefore, it does not

contribute to the Leadville Historic Landmark District Archaeological

potential was not identified; therefore monitoring by a cultural resource

professional was not required.

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The Removal Action at the Quintana residence was completed on Octobers, 1998.

ACTION MEMORANDUM SIGNED : SEPTEMBER 24,1998

REMOVAL START: SEPTEMBER 24,1998

REMOVAL COMPLETE : OCTOBER 8,1998

Operable Unit 9, KFP Removal 38

An Action Memorandum for a Time Critical Removal at the Jauernigg residence

located at 125 East 13th Street, Leadville, Colorado, was signed on Octobers, 1998. Samples collected under the Kids First Program determined

that lead levels in the sample collected from soils in the driveway and the area

adjacent to the east side of the house on the Jauernigg property, exceeded

t he Kids First trigger value of 3,500 ppm.

The remediation activities included removal of soil to a minimum depth of six

inches from the areas to be remediated. A reinforced concrete pad was

installed in the excavation in the driveway and matched the grade of East 13th Street. A strip of gravel was installed along the east side of the concrete. Gravel was placed in the excavation to the east side of the house.

T he State Historic Preservation Offic e (SHPO) determined that the structure

located on this property does not contribute to the Leadville Historic Landmark District. Archaeological potential was not identified at this property; therefore,

a cultural resource professional was not required to monitor excavation of

soils

The Removal Action at the Jauernigg residence was completed on October 19,1998.

ACTION MEMORANDUM SIGNED : OCTOBER 5,1998

REMOVAL START: OCTOBERS, 1998

REMOVAL COMPLETE : OCTOBER 19,1998

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Operable Unit 9, KFP Removal 39

An Action Memorandum for a Time Critical Removal at the Griego residence

located at 618 East 7th Street, Leadville, Colorado, was signed on October 22,1998. Samples collected under the Kids First Program determined

that lead levels in the sample collected from soils in the west side yard of the Griego property, exceeded the Kids First trigger value of 3,500 ppm.

The remediation activities included removal of soil to a minimum depth of six

inches from the area to be remediated. Clean topsoil was placed in the

excavated area in the west side yard and graded to facilitate drainage away

from the house. Native seed mix was then placed.

The structure on this property is a modular home and, therefore, does not

contribute to the Leadville Historic Landmark District. Archaeological

potential was identified at this property; therefore, a cultural resource

professional monitored excavation of soils at this property.

The Removal Action at the Griego residence was completed on November 6,1998.

ACTION MEMORANDUM SIGNED : OCTOBER 22,1998

REMOVAL START: OCTOBER 22,1998

REMOVAL COMPLETE : NOVEMBER 6,1998

Operable Unit 9, KFP Removal 40

An Action Memorandum for a Time Critical Removal at the Lee-Sobal residence

located at 311 East 4th Street, Leadville, Colorado, was signed on October 22,

1998. Samples collected under the Kids First Program determined that lead

levels in the sample collected from soils in the parking area; in the front and

west side yards; in the pile in the northwest comer; in the bare area in the

west side of the back yard; in the east side of the back yard; and in the

flowerbed in the east side yard of the Lee-Sobal property, exceeded the Kids First trigger value of 3,500 ppm.

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The remediation activities included removal of soil from the areas to be

remediated to an adequate depth to allow for replacement of six inches of

clean material and to facilitate drainage away from the house. A six-inch

reinforced concrete pad was constructed in front of the house. A concrete

sidewalk was constructed from the south end of the concrete driveway to the

porch on the east side of the house. A flower bed was constructed east of the

house and filled with clean topsoil. Six inches of river washed gravel was

placed in the excavated area east of the new driveway. Six inches of

compacted road base was placed in the excavation north of the gravel and

new concrete pad, extending west to the fence along Starr Ditch and north to

the edge of the asphalt on East 4th Street. Six inches of clean topsoil was

placed in the excavation in the west side of the front yard and all of the back

yard. Topsoi l only was placed in the center of the west front yard and along

the west and south edges of the back yard. The remainder of the front yard

and west half of the back yard was seeded with Climax native seed mix. Sod

was installed in the east side of the back yard. Six inches of gravel was

placed in the area between the house and the new sidewalk and along the

perimeter of the house.

T he State Historic Preservation Office (SHPO) determined that the structure

located on this property does not contribute to the Leadville Historic Landmark District. Archaeological potential was identified at this property; therefore, a cultural resource professional monitored the excavation of soils.

The Removal Action at the Lee-Sobal residence was completed on October 27,1998.

ACTION MEMORANDUM SIGNED : OCTOBER 22,1998

REMOVAL START: OCTOBER 22, 1998

REMOVAL COMPLETE : OCTOBER 27,1998.

V. COST INFORMATION

Asarco, Inc. is the party that was responsible for performing these removal actions.

V I. DISPOSITION OF WASTES

All wastes removed during the course of these removal actions were disposed on

site as approved by EPA.

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