KIDS FIRST

Lake County

Community

Health Program

SDMS Document ID

2020190

130 West 9th Street

Leadville, CO 80461

(719) 486-3538

April 29, 2004

Ms. Rebecca Thomas

Remediation Program Manager

U.S. Environmental Protection Agency, Region 8

99918th St.

Denver, CO 80203

Subject: Lake County Community Health Program

Transmittal of the Report prepared by the Independent Review Panel

Dear Rebecca:

On behalf of the Kids First Work Group, please find enclosed the report prepared by the

Independent Review Panel for the Lake County Community Health Program (LCCHP). The

Independent Review of the LCCHP was conducted on October 30 and 31, 2003 and the report

prepared by the Independent Review Panel (IRP), entitled Independent Review Panel Responses

to Key Issues/Questions, was submitted on December 3, 2003. In accordance with the Scope of

Work prepared for the independent review, the Kids First/LCCHP Work Group (Work Group)

has reviewed and discussed this report and is now formally transmitting the report to the EPA

along with Work Group comments and recommendations regarding the ongoing implementation

of the program.

The IRP Report contains the following information: An introduction, briefly explaining the

history and evolution of the LCCHP and the independent review process; summaries of the

qualifications and experience of the panel members and facilitator; a summary of the independent

review process; and responses to the list of key issues/questions, which were provided to the IRP

in advance of the review. Attachment A to the report contains supplemental information

provided by the IRP and referenced in their responses.

As part of the Work Group's review process, the Work Group requested clarification from the

IRP regarding several of the review panel comments presented in their December 2003 report. A

conference call with all of the panel members was conducted on January 29, 2004 to discuss a list

of clarification items, which had been transmitted to the panel members prior to the call. A

document containing the clarifications and comments provided by the IRP was developed. This

document, entitled Work Group Requests for Clarification and Summary of Panel Responses, has

been included as Attachment B to the IRP Report.

The Work Group has now completed their review of the IRP.'s report and is providing comments

and recommendations to the EPA in Attachment C to the IRP Report.

Please note that both Attachments B and C are structured in a format similar to the List of Key

Issues/Questions originally provided as part of the charge to the review panel and reiterated in the

responses provided by the IRP in their December 3, 2003 report. Each question is numbered in

accordance with this format, with a restatement of the original question, followed by a summary

In association with: U.S. Environmental

Protection Agency

Colorado Department of

Public Health and Environment

Lake County

Nursing Service ASARCO
Ms. Rebecca Thomas

April 29, 2004

Page 2

of the panel's response, and the Work Group's comment/recommendation on that topic.

Attachment D to the IRP Report contains the Scope of Work for the independent review and the

List of Key Issues/Questions, both prepared by the Work Group to help guide this review process.

The panel's report provided the program with a number of thoughtful and constructive comments

and recommendations. Although the Work Group comments and recommendations are detailed

in Attachment C, the following points are presented to highlight some of the IRP comments and

suggestions that the Work Group considers to be significant, as we continue the process of

implementation, evaluation and improvement:

Data Management and Statistical Analyses:

• Among the most significant of the IRP's comments was the observation that while

the mean blood lead concentration is declining, the calculated percentage of

participants with blood lead levels greater than 10 and 15 ug/dl (P10 and PI 5),

respectively, has not significantly declined over time, particularly in Statistical Unit

1. As a result of this observation and other comments provided by the IRP regarding

data management and evaluation, the Work Group is developing a step-wise

approach to further evaluate and potentially identify the lead sources, or combination

of lead sources, that may be determinant factors in children's blood lead levels within

the site.

Performance Standards:

• The Work Group is pleased that the IRP concluded that the methodology developed

for evaluating the performance of the program, with respect to the established

Remedial Action Objectives, are appropriate and valid and that the outcome-based

goals established by the program are reasonable.

Annual Report:

• The Work Group recommends adopting several of the IRP's recommendations

regarding improvements to the Annual Report. These recommendations include the

preparation of an executive summary of the report, the presentation of data trends

over multiple years, and the evaluation of additional data, such as hemoglobin versus

blood lead levels.

Outreach and Education:

• The IRP provided many insightful suggestions regarding ways to improve education

and outreach efforts aimed at increasing participation in the program. While the

program is currently enjoying good participation and conducting what the Work

Group considers effective recruitment, the specific strategies recommended by the

IRP will be considered by the program should program participation decline in the

future.

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Ms. Rebecca Thomas

April 29, 2004

PageS

Blood Lead Program:

In addition to evaluating the potential association between hemoglobin and blood

lead levels, the Work Group is also adopting the recommendation of distributing iron

supplements and vitamins to select program participants.

Sampling and Remediation Methods:

• All of the IRP's comments regarding sampling or remediation methods have been

carefully considered by the Work Group. Considering these comments and

reviewing certain procedures contained in the LCCHP Work Plan has resulted in the

development of several proposed revisions to the Work Plan. The Work Group will

transmit to EPA a recommendation to approve these proposed revisions under

separate cover.

Trigger Levels:

• In addition to responding to the list of Key Issues/Questions developed by the Work

Group, the IRP also provided comments regarding the program's trigger levels.

While this issue was outside the scope of the independent review process, the Work

Group has considered and discussed the comments and suggestions provided.

• The program's site specific action levels or trigger levels that guide the Work

Group's recommendations for remedial action for various media, were developed as

a result of site-specific studies, including the Baseline Human Health Risk

Assessment, and established in the Record of Decision. The Work Group

understands that because they were developed specifically for this site that some of

these trigger levels "do not mirror National standards", as stated by the IRP.

Recognition of these differences and the unique nature of this program (with respect

to other Superfund remedies) led to the development of the outcome-based (i.e.,

blood lead-based) performance standards. The Work Group is committed to the

diligent execution of this remedy. Through objective review of the program results

and implementation of additional data evaluation strategies, some developed as a

result of this review process, the Work Group will continue to work towards

identifying the determinant factors affecting children's blood lead levels at this site.

The LCCHP Work Group has tasked the Performance Standards Working Group

with developing a cost-effective, step-wise strategy to investigate determinants of

elevated blood lead levels. Once a proposed strategy has been developed, the Work

Group will present a more detailed recommendation to the EPA on this topic.

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Ms. Rebecca Thomas

April 29, 2004

Page 4

The Work Group respectfully requests that EPA concur with the recommendations, provided as

part of this transmittal, regarding the ongoing implementation of the LCCHP. Finally, the Work

Group would like to thank the members of the IRP, the IRP facilitator, the LCHHP staff, local

community leaders, the CDPHE, and the EPA for their participation in this process and for their

dedication, thoroughness, and constructive comment. We believe the review process and

adoption of the attached recommendations will result in improvements in the LCCHP, and help

expedite achieving the program's public health goals.

Site Manager

ASARCO Incorporated

Russ Allen

Project Manager

Colorado Department of Public Health and Environment

<Jim Martin

Lake County Commissioner

On behalf of Lake County

enclosures

cc: Jane Mitchell, CDPHE

Lake County Board of County Commissioners

Georgine Bogovich, Lake County Department of Human Services

Bud Elliott, Mayor of Leadville

John Faught, John Faught & Associates

Daryl Longwell, MFG

Amy Morrison, MFG

Bill Brattin, Syracuse Research Corporation

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