1161221-R8 SDMS 

PROCEEDINGS OF THE BOARD QF COUNTY COMMISSIONERS 

COUNTY OF LAKE AND STATE OF COLORADO 

RESOLUTION X^-Q^ 

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A RESOLUTION APPROVING THE LAKE COUNTY COMMUNITY 

HEALTH PROGRAM PHASE 2 WORK PLAN TO SERVE AS THE 

INSTITUTIONAL CONTROL FOR OPERABLE UNIT 9 OF THE 

CALIFORNIA GULCH SUPERFUND SITE 

WHEREAS, on September 2, 1999, the U.S. Environmental Protection >< | 

Agency (EPA) issued its Record of Decision (ROD) for Operable Unit 9 (0U9) of 

the Califomia Gulch Superfund Site, which selected the Lake County Community 

Health Program (or "LCCHP") as the remedy for 0U9; and 

WHEREAS, in March 2005, performance standards set by EPA in the 

September 1999 ROD for the initial Lake County Community Health Program 

were met, as outlined in the 2005 LCCHP Annual Report; and 

WHEREAS, EPA, The Colorado Department of Public Health and 

Environment (CDPHE) and Lake County determined that it was appropriate to 

continue certain functions ofthe initial LCCHP to serve as the institutional control 

for Operable Unit 9 and to continue efforts to reduce risks to resident children from 

exposure to lead from various sources; and 

WHEREAS, Lake County developed and CDPHE and EPA have approved 

the LCCHP Phase 2 Work Plan, dated 2009, which sets forth the framework, 

structure and administration ofthe LCCHP Phase 2; and 

WHEREAS, The LCCHP Phase 2 Work Plan transitions LCCHP 

management responsibilities from Asarco and EPA to Lake County and CDPHE; 

and 

WHEREAS, the Board of County Commissioners has carefully reviewed the 

provisions ofthe said Lake County Community Health Program Phase 2 Work 

Plan, (Exhibit "A"), and finds that it would be in the best interests ofthe county 

and its citizens to approve and to implement the same; and 

WHEREAS, the Board finds that it is authorized to approve said Work Plan 

pursuant to the provisions of § 30-11-101, C.R.S. 

Page 1 of 3 
NOW, THEREFORE, BE IT RESOLVED by the Board of County 

Commissioners of Lake County, Colorado: 

Section 1. The Lake County Community Health Program Phase 2 Work 

Plan, a copy of which is attached hereto, be and the same is hereby approved by 

this Board. 

Section 2. The Lake County Community Health Program Phase 2 Work 

Plan will serve as the institutional control for Operable Unit 9 ofthe Califomia 

Gulch Superfiind Site until such time it is determined that the LCCHP Phase 2 is 

no longer needed pursuant to the process set forth in the Work Plan. 

Section 3. This Resolution shall become effective upon its adoption. 

ADOPTED this //da y of /f/^c^rc-k. 2010. 

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BOARD OF COUNTY COMMISSIONERS 

OF LAKE COUNTY, COLORADO 

Kenneth L. Olsen, Chair 

Cari F. Schaefer, Vice 

Michael J. Bordogna, Commissioner 

ATTEST; 

•k4<d,{..{.^ ^ u 

Patricia A. Berger 

Clerk and Recorder 

Lake County, Colorado 

Ex-officio Clerk of said Board 

Page 2 of 3 
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3 of 82 CRS RSO.OO DSO 00 

Patricia Berger 

Lake County Recorder 

EXHIBIT "A" 

FOR 

RESOLUTION NO. 10 -t^ 

(The final draft ofthe Lake County Community Health Program Phase 2 

Work Plan to be marked and attached as this Exhibit.) 

2.10.09 LCG Resolution No. 09.... Swimming Pool 

Page 3 of 3 
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Pauicia Berger 

Lake County Recorder 

"Exhibit A" 

WORKPLAN 

FOR THE 

LAKE COUNTY 

COMMUNITY HEALTH PROGRAM 

PHASE 2 

February, 2009 

LAKE COUNTY BOARD OF COUNTY COMMISSIONERS 

LAKE COUNTY PUBLIC HEALTH AGENCY 

COLORADO DEPARTMENT OF PUBLIC HEALTH & ENVIRONMENT 

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION vni 
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Patricia Berger 

Lake Countv Recorder 

LCCHP Phase 2 Work Plan March, 2009 

TABLE OF CONTEIVTS 

1.0 INTRODUCTION 1 

1.1 PURPOSE AND SCOPE OF THE WORKPLAN 1 

2.0 LAKE COUNTY COMMUNITY HEALTH PROGRAM PHASE 2 CONCEPT AND DESIGN.. 1 

2.1 IDENTIFYING AND EVALUATING POTENTIAL SOURCES OF LEAD EXPOSURE 2 

2.2 LCCHP OBJECTIVES AND ELEMENTS 2 

2.2.1 Community Awareness and Education Programs 4 

2.2.2 Blood Lead Monitoring 4 

2.2.3 Environmental Sampling 5 

2.2.4 Identifying the Need for Response Actions 5 

2.2.5 Data Management/Record Keeping 6 

2.2.6 Program Review and Evaluation 7 

3.0 OPERATION OF THE LCCHP PHASE 2 7 

3.1 PROGRAM ADMINISTRATION 7 

3.2 CONTACT AND RECRUITMENT 8 

3.3 COMMUNITY AWARENESS AND EDUCATION PROGRAMS 9 

3.3.1 Educational Materials 9 

3.3.2 Distribution of Educational Materials 10 

3.4 LAKE COUNTY BLOOD LEAD MONITORING 12 

3.4.1 Gathering Demographic Information 13 

3.4.2 Blood Lead Test Methods and Data Management 13 

3.4.3 Results Reporting 13 

3.4.4 Evaluation of Results 14 

3.5 ENTRY INTO THE ENVIRONMENTAL TESTING PROGRAM J4 

3.5.1 Family Surveys/Information Gathering 15 

3.5.2 Consent for Access 16 

3.5.3 Scheduling Environmental Sampling and Remedial Response Actions 16 

4.0 ENVIRONMENTAL TESTING AND EVALUATION PROGRAM 18 

4.1 RESIDENTIAL PROPERTIES ENVIRONMENTAL INVESTIGATIONS 18 

4.1.1 Soil Sampling and Analysis 18 

4.1.2 Exterior/Interior Paint 22 

4.1.3 Dust 24 

4.2 DATA EVALUATION FOR INDIVIDUAL PROPERTIES 25 
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Patricia Berger 

Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

4,2.1 Prioritization of Response Actions 27 

4.3 RESPONSE ACTION OPTIONS 27 

4.3.1 Elevated Blood Lead 28 

4.3.2 Soil 29 

4.3.3 House Dust 31 

4.3.4 Exterior and Interior Paint 32 

4.4 CULTURAL AND HISTORICAL RESOURCE EVALUATIONS 33 

5.0 ENVIRONMENTAL RESPONSE ACTIONS 37 

5.1 RESPONSE ACTION PLAN 37 

5.2 CONSENT FOR ACCESS 38 

5.3 OVERSIGHT AND REPORTING 38 

5.4 SOIL RESPONSE ACTIONS 39 

5.4.1 Contractor Requirements 40 

5.4.2 Yard Preparation and Site Controls 40 

5.4.3 General Remediation Procedures 42 

5.5 DUST RESPONSE ACTIONS 47 

5.5.1 Contractor Requirements 48 

5.5.2 Site Controls 48 

5.5.3 Dust Removal Actions 49 

5.5.4 Dust Abatement Actions 49 

5.5.5 Dust Clearance SampUng 50 

5.6 INTERIOR/EXTERIOR PAINT RESPONSE ACTIONS 51 

5.6.1 Contractor Requirements 52 

5.6.2 Site Controls and Containment Procedures 52 

5.6.3 Interior/Exterior Paint Remediation Procedures 54 

5.6.4 Interior Paint Clearance Sampling 59 

5.6.5 Exterior Paint Clearance Sampling 60 

5.6.6 Soil Response Actions Related to Exterior Paint Action 61 

5.7 MAINTENANCE AND FOLLOW UP 61 

5.8 TEMPORARY WORK STOPPAGES 62 

5.9 DECONTAMINATION 62 

5.11 SITE INSPECTION 63 

6.0 WASTE MANAGEMENT AND DISPOSAL 64 

6. ] RESIDENTIAL SOIL REPOSITORY 64 

6.2 LEAD-BASED PAINT, DUST AND ASSOCIATED DEBRIS 64 

7.0 DATA MANAGEMENT 65 

7.1 DATA IMPORT/ENTRY 66 

7.2 DATA EXPORT AND TRANSFER 67 
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7 of 82 CRS RSO 00 DSO 00 Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

7.3 DATABASE REPORTS 67 

8.0 PROGRAM REVIEW AND EVALUATION 69 

8.1 ANNUAL REPORTS 70 

9.0 REFERENCES 72 

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Patricia Berger 

Lake Courty Recorder 

LCCHP Phase 2 Work Plan March, 2009 

Table 

3-1 

3-2 

3-3 

5-1 

8-1 

LIST OF TABLES 

Title 

Education Target Groups 

Educational Materials and Distribution Methods 

Evaluation of Capillary-Test Blood Lead Monitoring Results 

Clean Replacement Soil Requirements 

Property File Structure 

LIST OF FIGURES 

Figure 

1-1 

1-2 

4-1 

4-2 

4-3 

4-4 

Title 

Califomia Gulch Site Location Map 

Operable Unit 9 Residential Populated Areas 

Environmental Investigation and Response Flow Diagram 

Residential Soil Sampling Plan 

Decision Flow Diagram 

Leadville Historic Landmark District 

LIST OF APPENDICES 

Appendix 

A 

B 

C 

D 

E 

F 

Title 

Standard Operating Procedures 

Family and Child Questionnaires 

Quality Assurance Plan 

Community Educational Materials 

Consent for Access 

Database Documentation 
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LCCHP Phase 2 Work Plan March, 2009 

LO INTRODUCTION 

This document presents the Lake County Community Health Program Phase 2 work plan 

(LCCHP Phase 2) that will continue to function as the primary blood lead reduction program for 

Lake County, and the institutional control for Operable Unit 9 ofthe Califomia Gulch Superfund 

site. The performance standards for the initial LCCHP were met in 2005, as outlined in the 2005 

LCCHP Annual Report. The LCCHP Phase 2 will continue efforts to reduce the risks to resident 

children resulting from exposure to lead from various potential sources, including school, 

playground, and yard soil, house dust, interior and exterior house paint and miscellaneous other 

sources. The LCCHP Phase 2 provides a range of services to assist residents in reducing their 

exposure to lead in and around their homes. Lead educational services are offered to owners and 

occupants of residences within Lake County, and additional services are available to children 

and pregnant and nursing mothers with elevated levels of lead in their blood. 

L1 Pu rpose and Scope of the Work Plan 

TTiis work plan presents the framework for the structure and administration ofthe 

LCCHP Phase 2, as well as specific procedures for implementing various components of that 

program. The overall concept and design ofthe LCCHP Phase 2 is described in Section 2. 

Section 3 describes the organization and administrative responsibilities for the program and its 

outreach and education and blood lead monitoring components. Sections 4 and 5 provide 

specific procedures for performing environmental investigations and response actions, 

respectively. Waste management, disposal and soil-consolidation protocols are described in 

Section 6. Data management, record keeping, and reporting requirements are addressed in 

Section 7, and plans for review and evaluation ofthe LCCHP Phase 2 are outlined in Section 8. 

2.0 LAKE COUNTY COMMUNITY HEALTH PROGRAM PHASE 2 CONCEPT AND 

DESIGN 

The purpose ofthe LCCHP Phase 2 is to provide reduction in lead exposure from a wide 

range of potential sources for young children and pregnant or nursing women and thereby reduce 

blood lead levels in children who reside within the County. This program follows the Center for 

Disease Control (CDC) guidance from Preventing Lead Poisoning in Young Children (CDC, 

2005) and Screening Young Children for Lead Poisoning (CDC, 1997), along with programspecific procedures, to address properties where elevated blood lead levels occur. The plan to 

reduce childhood lead exposure addresses various sources of lead in the environment and 

provides remediation for media that exceed program action levels. 
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10 of 82 CRS RSO.OO DSO.tX) Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

2.1 Identifying and Evaluating Potential Sources of Lead Exposure 

Lead is widely distributed throughout the environment as a result of industrialization, and 

both children and adults can be exposed to lead from a number of different media (e.g., 

contaminated soil, dust, water, air, food, consumer products) and pathways (ingestion, dermal 

contact, inhalation). Children typically have higher intake rates of environmental media and 

tend to absorb a higher fraction of ingested lead from their gastrointestinal tract and be more 

susceptible to some ofthe adverse effects of lead than do adults. Exposure to lead via food, 

water and air has been greatly reduced in recent years as a result of federal regulations restricting 

or banning lead in solder, gasoline and paint. Even so, exposure to lead contaminated media 

continues to be of concem to regulators nationwide (CDC, 1991), especially in older urban areas. 

In Leadville, there are currently a number of pathways by which children may come into 

contact with lead originating from mining activities, including ingestion of and dermal contact 

with contaminated soil, mine wastes, dust, ingestion of contaminated soil or garden-grown food; 

and inhalation of particulates. Groundwater has not been shown to be a significant contributing 

factor. Leadville children may also be exposed to lead from non-mining sources in and around 

their homes, such as lead-based paint, occupational and hobby exposures, and consumer 

products. 

2.2 LCCHP Objectives and Elements 

The LCCHP Phase 2 has been designed to reduce overall lead-related risk to children in 

Leadville through education of parents and blood lead monitoring of children, and for those with 

elevated levels of blood lead, additional responses that investigate and address numerous 

sources. The potential sources of lead exposure that are addressed include contaminated soil, 

house dust, and interior and exterior paint. 

The LCCHP Phase 2 blood lead program will be administered and operated by Lake 

County. CDPHE will perform the environmental testing and remediation portion ofthe LCCHP 

Phase 2 program, as recommended by the LCCHP Phase 2 Work Group ( as defined in Section 

3.1 ofthis work plan). The Lake County Public Health Agency monitors blood lead 

concentrations in individual children who reside within the County and provides educational 

material to families regarding proper hygiene to control lead intake. For those children with 

elevated blood lead levels, additional remedial services are available through the program. 

Objectives ofthe program are as follows: 

• Continue a strong educational program, which is vital to reducing risk from lead 

exposure. 
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if of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

• Obtain participation from a large proportion ofthe residential population with 

children under the age of 6 years. 

• Reduce the level of lead exposure and intake by children in a manner that results in 

optimal risk reduction through efficient use of resources. 

• Provide for maximum flexibility in identifying sources of lead and selecting leadrisk-reduction actions at individual properties, thereby avoiding unnecessary or 

ineffective actions. 

• Investigate the sources of lead that may contribute to a child's exposure and address 

sources having the greatest potential impact on a child's blood lead level. 

• Conduct environmental testing to identify and remediate potential sources of lead 

exposure when a child has an elevated blood lead level at or above lOug/dL, where 

recommended by the Work Group,. 

• Identify and remediate potential sources of lead exposure when a child does not have 

a blood lead level oflO ug/dl or higher, but the potential for exposure through 

environmental and/or commercial sources may exist. This action may be taken at the 

discretion ofthe Lake County Public Health Agency, or upon recommendation ofthe 

LCCHP Phase 2 Work Group. 

To meet these objectives, the LCCHP Phase 2 integrates a variety of services and 

intervention methods and combines the following elements: 

• Community awareness and education programs; 

• Voluntary blood lead monitoring with appropriate follow-up for young children (12 

to 72 months) and pregnant and nursing women; 

• Voluntary environmental testing for lead in the residences of children with blood lead 

levels at or above 10 ug/dl, when recommended by the Work Group. 

• Environmental investigation and remedial response actions to reduce the risk of lead 

exposure to children with elevated blood lead levels, when recommended by the 

Work Group; 

• Use ofthe LCCHP soil repository for contaminated soil removed from residential, 

school, playground properties and/or parks and recreational facilities ; 

• Data management and record-keeping program; 

• On-going coordination and program review through the LCCHP Phase 2 Work 

Group. 
lilMiiiN 

LCCHP Phase 2 Work Plan March, 2009 

Of these elements, the blood lead monitoring and environmental sampling programs are the 

primary mechanisms for obtaining information regarding the need for remedial actions. The 

LCCHP Phase 2 is fimded through a Trust Fund to be administered by a trustee appointed by the 

parties to the LCCHP Amended and Re-stated Tmst Agreement. Lake County, CDPHE, and 

EPA are parties to the Trust Agreement. Results from the environmental and blood lead 

monitoring programs are used jointly to select appropriate response actions, when needed. 

Environmental response actions are performed as needed, at those participating properties at 

which children with elevated blood lead levels reside, or as recommended by the Work Group. 

The various elements ofthe LCCHP Phase 2 are briefly described below. More detailed 

procedures for implementing these elements are provided in the following sections ofthis work 

plan. 

Appendices A through F include specific requirements for program outreach and 

education and for sample collection, handling, and analysis. These appendices will be updated, 

as recommended by the Work Group, as other federal or state guidance becomes available that 

supersedes the attached Standard Operating Procedures (SOP's), quality objectives, or other 

general information about lead exposure. 

2.2.1 Community Awareness and Education Programs 

Data collected as part ofthe Kids First Program and the LCCHP Phase 1 has documented 

the importance of community education in reducing blood lead levels in children living in the 

Leadville area. Therefore an extensive community awareness and education program will 

continue to be an integral part ofthe LCCHP Phase 2. The LCCHP Phase 2 Community 

Education and Awareness Program will focus on two primary objectives to help manage 

potential lead exposures at the site. The primary focus ofthe program will be to encourage 

participation in the blood lead monitoring program and provide specific education to participants 

ofthe program, especially in the case ofa child with an elevated blood lead level. The 

educational program will also provide general information regarding lead hazards, potential 

sources of lead exposure, and methods of reducing potential exposures to the community at 

large. 

A variety of media and outreach methods are utilized to maximize program participation and 

promote the availability and use of program information. The Community Education and 

Outreach Program is further defined in Section 3.3 ofthis work plan. 

2.2.2 Blood Lead Monitoring 

The LCCHP Phase 2 includes voluntary blood lead monitoring (with financial incentives, 

as appropriate) for all children age 12 to 72 months and voluntary blood lead monitoring for 
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f?:^fs 13 o rR<^ RSn no DSO.OO Lake County Recorder of 82 CRS RSO.OO DSO.OO^ ^ 

LCCHP Phase 2 Work Plan March, 2009 

pregnant and nursing women. The Lake County Public Health Agency will provide blood lead 

monitoring and will staff a telephone information line regarding this program. Blood lead data 

are used to identify individuals who presently have blood lead levels at or above 10 micrograms 

per deciliter (ng/dL). Ifthe blood lead level ofa child or a pregnant or nursing woman is greater 

than or equal to 10 pg/dL then appropriate actions are recommended to identify and address the 

source of lead exposure and to reduce the blood lead level. These potential range of actions are 

more fully discussed in section 3.4.2 ofthis work plan 

2.2.3 Environmental Sampling 

The environmental sampling and investigation program will address lead from residential 

soil and dust, interior and exterior paint, and other potential sources beyond an individual 

residence. Where reconuncnded by the Work Group, residents or owners ofa residential 

property with a pregnant or nursing mother or a child having a blood lead level equal to or 

greater than 10 ng/dL will be strongly encouraged to participate in the environmental testing 

program to assess lead levels in soil, dust, and paint at that property. At the recommendation of 

the LCCHP Phase 2 Work Group or the discretion ofthe Lake County Public Health Agency, the 

environmental testing program will be made available in cases when a child does not have a 

blood lead level of 10 ug/dl or higher, but the potential for environmental exposures exist. 

Over the long term, environmental investigation and remediation should be handled 

promptly af^er the need to do them is established, and with proper written consent. 

2.2.4 Identifying the Need for Response Actions 

Results from the blood lead monitoring and environmental testing programs are 

compared to the lead action levels, or trigger criteria. The trigger criteria for LCCHP Phase 2 to 

conduct an environmental investigation at a residence are: 

Blood Lead: greater than or equal to 10 ng/dL in children age 12 to 72 months and in 

pregnant and nursing women. 

The trigger criteria for performing environmental remediation, based on the results ofa 

residential environmental investigation are as follows: 

Soil: greater than or equal to 3,500 mg/Kg 

House Dust: greater than or equal to 2,000 mg/Kg 

Interior or Exterior Paint: Interior or exterior paint in poor condition: with lead 

concentration greater than or equal to 1 milligram/square centimeter (mg/cm^) -
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LCCHP Phase 2 Work Plan March, 2009 

education provided; with lead concentration greater than or equal to 6 mg/cm^- active 

remediation. 

Detection of an elevated blood level will trigger an evaluation ofthe data to determine if 

environmental investigation ofa residence will be recommended. Environmental invesdgation 

will generally be recommended unless data and other information clearly show that the source of 

lead exposure is solely related to consumer products such as toys and candy. 

When results of an environmental investigation show that one or more ofthe trigger criteria is 

exceeded, the Work Group will evaluate a range of different response actions. The appropriate 

response actions are determined considering the blood lead level ofthe child or nursing or 

pregnant mother and the preferences ofthe property owner and residents in making the 

recommendations. No response action will be taken without the permission ofthe property 

owner and residents. 

CDPHE will design and implement response actions at individual properties as 

recommended by the Work Group. Each response action design is subject to review and 

approval by the individual property owner and the current residents (if different). CDPHE will 

provide construction services and oversight, and prepare final construction reports to document 

remedial actions at each property. Lake County may assume operation ofthe environmental 

testing and remediation program upon request by the County and agreement of CDPHE and 

EPA. 

Residential Soil Repository Wastes generated during any environmental response 

action are handled in accordance with applicable State and Federal regulations, and any soil 

removed from individual properties is consolidated at the residential soil repository, as outlined 

in the separate soil repository plan document as discussed in section 6.1 ofthis work plan. 

2.2.5 Data Management/Record Keeping 

Lake County will maintain a data management and tracking system to maintain blood 

lead testing program results. CDPHE will maintain environmental testing and response action 

information along with other records related to individual lots and residential properties within 

residential areas. The data management system will be accessible by the Work Group for use in 

evaluating and developing response actions at individual properties and to track progress of 

investigations and response actions, and will be available to CDPHE and EPA for evaluating 

program effectiveness. The environmental data and response action information managed by the 

CDPHE will also be available to the Lake County Building/Land Use Department, and will be 

available for public review. Information will include the address of all properties investigated, a 

summary of environmental sampling results at each property, and remedial action taken. 
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15 of 82 CRS RSO.OO DSO 00 Lake Countv Recorder 

LCCHP Phase 2 Work Plan March, 2009 

2.2.6 Program Review and Evaluation 

The LCCHP Phase 2 will be evaluated through the EPA five-year review process. In 

addition, CDPHE will conduct an annual statistical evaluation ofthe program in order to 

determine if remedial action objectives outlined in the Operable Unit 9 Record of Decision 

continue to be achieved. The statistical review ofthe program will continue until the next fiveyear review, scheduled for September 2012, or until altemative performance standards for the 

program are developed. Thereafter, reviews ofthe program will occur at intervals as CDPHE 

and EPA may find necessary. Specific components ofthe statistical analysis will be developed 

through the LCCHP Work Group to support the annual program review, and will be dependent 

on the data available for a given year. 

3.0 OPERATION OF THE LCCHP PHASE 2 

Lake County Public Health Agency will accomplish the blood lead testing, community 

education, and clinical management portion ofthe LCCHP Phase 2. Lake County will provide 

data management in support of that program, and will also have primary responsibility for the 

educational program. CDPHE will perform the environmental testing and remediation portion of 

the program. The CDPHE and EPA will provide recommendations and collaboration on data 

analysis and program evaluation. The obligations of Lake County and CDPHE to continue to 

operate the LCCHP shall end when the trust fund becomes inadequate to fund the program, or 

when Lake County, the State and EPA mutually agree that there is no longer a need for the 

program in Lake County, or ifthe parties mutually agree to amend or end the program. 

Should Lake County determine that they are no longer willing or able to operate the LCCHP 

Phase 2, the County may withdraw from operating the program. Lake County will notify both 

EPA and the CDPHE of their intent to cease operation ofthe LCCHP Phase 2 to be effective 60 

days following receipt ofthe County's notification. 

3.1 Prograin Administration 

Lake County will operate the blood lead testing, community education and clinical 

management portion of the program. The Lake County Public Health Agency is open to the 

public and is staffed with qualified individuals at hours convenient to the public. A licensed, 

registered nurse employed by Lake County will continue to operate the blood lead program. 

CDPHE will arrange for certified lead paint inspectors and qualified soil sampling personnel to 

be contracted for environmental sampling and remediation work. 

Coordination of program activities will occur through the LCCHP Phase 2 Work Group. 

The Work Group, (comprised of Lake County, CDPHE, and EPA) will meet or confer whenever 
3 53903 3/16/2010 9:44 AM Patncia Berger 

16 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

a child with an elevated blood lead is identified. The Work Group may also meet at the request 

ofthe Lake County Public Health Agency, EPA or CDPHE when there is a potential for 

exposure to lead, but a child's blood lead level is below 10 u g/dl. 

Funding for the LCCHP Phase 2 is from a trust fund established by ASARCO under the 

conditions ofthe 1994 Consent Decree (USDC, 1994). The trust fund will be the source of 

funding for all elements ofthe LCCHP Phase 2. Funds deposited in the frust will be 

administered to the LCCHP Phase 2, by a trustee, according to the conditions described in the 

LCCHP Amended and Re-stated Trust Agreement. 

In the event the Parties cannot reach agreement as to any issue arising out of implementation of 

this work plan, any party may demand dispute resolution as outlined in Paragraph 19 ofthe 

LCCHP Amended and Re-stated Trust Agreement. 

3.2 Contact and Recruitment 

Participation by eligible residents in the LCCHP Phase 2 is critical to its effectiveness. 

For this reason, special efforts will be made to contact and recmit participants. These efforts will 

be coordinated with community awareness and education programs, as described in Section 3.3. 

Whenever possible, the educational materials, advertisements, and other information available 

from the program will encourage participation. The telephone numbers for the program will be 

given on educational materials for questions regarding participation in the program. 

The LCCHP Phase 2, through the Lake County Public Health Agency, will coordinate 

with other community outreach efforts, such as the Head Start program for young children, 

Medicaid, Immunization, and WIC programs, in providing information about the LCCHP Phase 

2 and encouraging participation. 

Participation in any aspect ofthe program is at no cost to the participants, and financial 

incentives may be offered, as appropriate, to encourage blood lead monitoring. A U.S. Savings 

Bond in the amount of $50 or a Safeway gift card in the amount of $25 each is offered to each 

child participating in the County's blood lead monitoring program. The bonds or gift cards may 

be offered on an annual basis for each child tested. In addition, an additional gift card of $25 

from Safeway is offered to each family participating. The gift certificates are offered to families 

on an annual basis. These incentives are intended to encourage ongoing monitoring of children 

even when the children are not initially identified as having elevated blood lead concentrations. 

The incentive program is routinely reviewed so that any necessary changes can be made. 

If these methods of contact and recmitment are not effective in bringing residents into the 

environmental testing program, then additional methods may be adopted such as mass mailings 

or door-to-door recruitment. If particular areas ofthe County are indicated as areas of 

consistently higher blood lead values in children, then more intensive contact and recruitment 

efforts may be implemented for those areas. The need for changes to recruitment approaches or 
353903 3/16/2010 9:44 AM Patncia Berger 

17 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

for additional recmitment efforts will be periodically re-evaluated in conjunction with ongoing 

program reviews. 

3.3 Community Awareness and Education Programs 

The LCCHP Phase 2 works to raise and maintain the community's awareness ofthe 

health risks from lead exposures. The objectives of these efforts are to provide information to 

the community about: 

• the LCCHP Phase 2 and the services available to residents and property owners; 

• the potential for children to be exposed to lead at levels that could have adverse 

health effects; 

• basic hygiene and adequate nutrition to reduce contact with or risk from lead 

exposures; 

• dust-suppression and remodeling methods, recommended procedures for soil 

excavation; 

• general education about ways to prevent exposure and tracking from bare soil areas; 

and 

• general education about ways to ensure that past response actions are not disturbed; 

As described below, the community awareness and education program involves 

cooperative efforts with local govemment agencies, including the Lake County Public Health 

Agency, Lake County School District, Lake County Department of Social Services and Lake 

County Building/Land Use Department and City of Leadville. 

In addition to the community-based program, the LCCHP Phase 2 also provides 

individual counseling and education to manage lead exposure in and around the home. 

Individualized education is provided to residents through their participation in the Lake County 

blood lead-monitoring program. 

3.3.1 Educational Materials 

Educational materials have been developed for several different target groups. Some of 

the target groups and their individual needs for information about lead are given in Table 3-1, 

and copies of most ofthe educational materials used by the program are contained in Appendix 

D. 
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18 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

Future educational materials will be reviewed and prepared with cooperation from the 

Lake County Public Health Agency, Lake County Building/Land Use Department, and the City 

of Leadville Planning and Zoning Department, CDPHE, and EPA for distribution to the public. 

Specific educational tools will be developed and provided in both English and Spanish for each 

aspect ofthe program, as needed. In some cases brochures will need to be updated to 

accommodate changes to the program. 

On an annual basis, the Work Group will review all educational materials and evaluate if such 

materials should be replaced, updated, or discontinued. 

The materials disfributed by Lake County Public Health Agency and CDPHE in support 

ofthe LCCHP Phase 2 include: 

• initial mailing for all property owners and residents within the former 0U9 

introducing the new LCCHP Phase 2; 

• brochures for local realtors and brokers regarding disclosure requirements and the 

LCCHP Phase 2 program; 

• training materials for local soil excavation contractors and utility companies; and 

• Brochures for property owners and contractors regarding reducing lead exposures 

during remodeling or renovation. 

The County in cooperation with CDPHE and EPA will periodically review, evaluate and 

improve the educational materials and outreach programs. 

3.3.2 Distribution of Educational Materials 

A number of different distribution methods will be used to provide information to the 

various target groups. Specific outreach and education methods may change over time. The 

County will periodically review and may make recommendations to the Work Group for changes 

to the current educational tools and distribution methods. A summary ofthe outreach methods 

that may be used is provided on Table 3-2. Copies of current educational material and mailings 

utilized by the LCCHP Phase 2 are provided in Appendix D. 

Following the public comment period on the LCCHP Phase 2 work plan and upon 

completion ofthe final work plan, EPA will notify all residents in the Leadville area ofthe new 

LCCHP Phase 2 program in a mass mailing. The mailing will provide information about the 

potential health risks associated with exposure to sources of lead and a full description ofthe 

services offered to residents, especially families with young children and pregnant/nursing 

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women. The initial mailing will also explain how to contact the program directly to request 

these services. Additional mailings may be conducted periodically, following the initial mailing 

as determined appropriate by the Work Group. 

Educational materials describing the LCCHP Phase 2 program will be provided to all 

parents whose children are seen at the Lake County Public Health Immunization Clinics and 

EPSDT Outreach clinics. All children seen in the Immunization Clinics and EPSDT Outreach 

clinics also will be evaluated for their eligibility to participate in the LCCHP Phase 2 program. 

Because the Immunization Clinics are the only sources of childhood immunization in the 

Leadville area, it is expected that education about the LCCHP Phase 2 program will reach the 

parents of most children residing in Lake County at these clinics. The Lake County Public 

Health Agency will develop a methodology for documenting that parents of each child seen at 

the clinics receive the information and blood testing opportunity. In addition. The LCCHP Phase 

2 program will coordinate as needed with adjacent counties (Eagle, Summit) and Leadville area 

physicians to ensure that Leadville parents whose children they see are given information about 

the LCCHP Phase 2 program and that documentation is of such notification is provided to the 

LCCHP Phase 2 program. 

Should the Immunization Clinics cease to be the sole providers of childhood 

immunization in the Leadville area, the work group will identify a verifiable means to reach the 

children who do not receive immunizations from the clinics. 

General information will be available in the community through a variety of media. 

Weekly advertisements during the summer months may be mn in the newspaper discussing the 

availability of program services and information. Advertisements may change periodically 

depending on the time of year and feedback from the Work Group. 

Program information will also be kept on file at the Lake County Public Library, and will 

also available through the CDPHE Hazardous Materials and Waste Management Division 

Records Center at 303-692-3333. 

Special emphasis will be made to reach families with children under 72 months old and 

pregnant/nursing women. Educational information will be given at public and private daycares, 

at the elementary school and to other groups that focus around young children. Periodic updates 

will continue at these facilities and educational brochures will be available. 

Residents can call the Lake County Public Health Agency for information about the 

LCCHP Phase 2. The objectives ofthe information line is to: 

• provide parents or caretakers of young children with information about lead risk 

reduction activities including Lake County's blood lead testing program; 

• provide residents with information and guidance about reducing the exposure to lead 

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• monitor citizens' concems and make referrals to the appropriate personnel. 

The most effective education is individual face-to-face consultations with participants . 

The program will provide education, counseling and intervention to families with young 

children. Specific recommendations can be made based on an individual family's situation. For 

those with elevated blood lead levels, the environmental investigation program through CDPHE 

can often make customized recommendations for specific actions that will reduce the residents' 

risk to lead exposure based on the results of environmental lead sampling at their homes and 

specific information collected by the program about their daily habits and activities. 

3.4 Lake County Blood Lead Monitoring 

The Lake County Public Health Agency will conduct the voluntary blood lead 

monitoring program. The program will continue to be available to Lake County residents who 

are (1) children between the ages of 12 months and 72 months (6 years old), (2) pregnant and/or 

nursing women, or (3) older children previously enrolled in the program who continue to exhibit 

elevated blood lead levels. Blood lead monitoring will be available at the Lake County Public 

Health Agency in Leadville at convenient times for participants. The County personnel staffing 

the blood lead program will be able to work with other programs such as immunizations. Head 

Start, and Women, Infants, and Children (WIC) to identify young children who reside in and 

around Leadville. Spanish interpretation will also be available to Spanish-speaking families. 

Families with children ages 6 to 72 months will be encouraged to have their children tested 

annually unless a child's blood lead level is at or above 10 ^ig/dL in which case more frequent 

monitoring will be recommended. More frequent monitoring may also be recommended, under 

special circumstances, for children with a blood lead level below 10 ng/dL at the discretion of 

the County nurse. Ifa child's blood lead level exceeds 20 ug/dL, a zinc protoporphyrin (ZPP) 

test will also be conducted. ZPP tests can be helpful in the assessment ofthe chronicity of 

exposures. Additional information on ZZP testing can be found in Table 3-3. Financial 

incentives to participate in the blood lead monitoring program may be offered as appropriate 

(Section 3.2). Reminder cards will be mailed to all families either annually or as needed to have 

their children's blood lead levels re-tested. 

The blood lead program will initially screen most children using the capillary (finger 

stick) collection method. The standard operating procedure (SOP) used by Lake County to 

collect blood samples by the capillary method is included in Appendix A. The Health 

Department may choose to collect the sample using the venous method ifthe child's sibling or a 

close friend tests above 10 ng/dL or ifthe parent requests the venous method (i.e., venipuncture). 

The participant will also have their hemoglobin checked at the same time the blood lead sample 

is drawn. Ifa child's blood lead level is at or above 10 fxg/dL, then a follow-up venous sample 

will be collected as soon as possible. All adult participants will have a venous sample collected 

and analyzed when possible. 

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A discussion ofthe effects of lead on children and basic educational information will be given to 

each participating family. At the discretion ofthe health nurse, either telephone calls or followup appointments will be used to review the results ofthe testing. Typically, the health nurse will 

mail results to participants when blood lead levels are less than 5 ug/dL. Follow-up telephone 

calls will be made when blood lead levels are between 5 and 10 ug/dL, and follow-up 

appointments will be used to communicate BLLs at or above 10 ug/dL. 

3.4.1 Gathering Demographic Information 

Demographic information will be gathered from survey questionnaires (Appendix B) and 

entered into the project database. Each participating family will complete the questionnaires 

each time monitoring tests are performed and they will provide information regarding possible 

exposures to lead. Lake County Public Health Agency staff will review them, and any risk 

factors will be identified and discussed with families. 

The questionnaire asks for family information and information on each child tested who 

is less than 72 months old. Ifa child has previously been tested in the Lake County blood lead 

program then the family will be given the questionnaire previously filled out to update the 

questionnaire instead of completing another. The questionnaire is similar to the questionnaire 

filled out during the initial environmental investigation; thus the answers can be compared to 

assist in the evaluation of results. The Lake County Public Health Agency questionnaire is 

shown in Appendix B. 

3.4.2 Blood Lead Test Methods and Data Management 

All blood lead samples will be sent to an analytical laboratory that satifies requirements 

ofthe Clinical Laboratory Improvement Act (CLIA), by participating in nationally recognized 

proficiency testing programs such as those sponsored by the College of American Pathology 

(CAP), the Wisconsin State Laboratory of Hygiene (WSLH), the New York State Department of 

Health, or the Pennsylvania Department of Heahh. Portable screening methods such as 

LeadCarell may be acceptable, if approved by the Work Group, in which case the provider 

becomes the "analytical laboratory" and must adhere to state disease reporting requirements and 

CDC-recommended proficiency testing procedures.. The laboratory will use CDC-approved 

methods for blood analysis and conform to CDC's recommended holding times for blood 

samples (refer to Appendix C, Quality Assurance Plan). 

3.4.3 Results Reporting 

After receiving the blood lead results from the laboratory, the Lake County Public Health 

Agency will either telephone the results to the parent or schedule a follow-up appointment to 

inform the family. Typically, the health nurse will mail results to participants when blood lead 

levels are less than 5 ug/dL. Follow-up telephone calls will be made when blood lead levels are 

between 5 and 10 ug/dL, and follow-up appointments will be used to communicate BLLs above 

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LCCHP Phase 2 Work Plan March, 2009 

10 Ug/dL. A computer printout with the child's blood lead level and hemoglobin results will be 

mailed. Ifa child's blood lead level is below 10 jig/dL the family will be encouraged to have 

their child re-tested annually until the child is 72 months old. Ifa child's blood lead level is at or 

above 10 ^ig/dL, then the CDPHE guidelines for retesting and clinical management, as shown in 

Table 3-3, will be followed, and more intensive counseling will be offered. 

3.4.4 Evaluation of Results 

When the Lake County Public Health Agency receives an initial blood lead test result at or above 

10 ug/dL, the Health Department will send an e-mail notification to the LCCHP Phase 2 Work 

Group. Upon venous confirmation ofthe initial elevated blood level (EBL) results, results will 

again be forwarded to the Work Group, and the Lake County Public Health Agency will 

recommend an appropriate course of clinical management. Clinical management provided to an 

EBL household may include an initial home visit to provide education and counseling to the 

family and to evaluate potential sources of lead exposure present in the household. Following 

initial clinical management by the Lake County Public Health Agency, the Work Group will 

meet or confer to determine whether or not an EBL should be referred to the environmental 

testing program. The work group will review the need to develop protocols for recommending 

environmental investigations after one year of operation ofthe LCCHP Phase 2. Such protocols 

may be developed thereafter as the work group deems necessary. 

Once referred to the testing program, CDPHE will provide environmental sampling and testing 

with the consent ofthe resident and/or property owner. The purpose ofthe envhonmental testing 

program is to identify potential sources of lead exposure in and around the home and to provide 

residents with information regarding potential lead hazards on their property. 

3.5 Entry Into the Environmental Testing Program 

Following clinical management by the Lake County Public Health Agency of an EBL, if 

no household source ofthe lead exposure is cleariy identified, the Health Department will 

coordinate with the Work Group to determine that it is appropriate to make available residential 

environmental sampling and testing services for any County children or pregnant and nursing 

women with elevated blood lead levels. The purpose ofthe environmental testing program is to 

identify potential sources of lead exposure in and around the home and to provide residents with 

information regarding potential lead hazards on their property. Generally, homes that have been 

previously remediated under the LCCHP or LCCHP Phase 2 will not be eligible for 

environmental testing. However, the Work Group will evaluate every EBL case and make 

recommendations based upon available information. 

Once the Work Group has recommended a property for the Environmental Testing 

Program, participation in the program will be voluntary with no cost to the participants. At 

properties previously tested where no changes have been made, retesting will not be performed 

unless recommended by the Work Group. 

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For properties entered into the Environmental Testing Program, CDPHE will evaluate 

homes for the presence of lead in paint, soil, and dust. Paint will be tested in situ. Soil and dust 

samples will be collected for off-site analysis. Each sample type will be analyzed for lead. 

CDPHE will perform all testing, sampling and sample analyses and will also report the result of 

environmental investigations to the individual property owner, residents, the Work Group and 

Lake County Building and Land Use Department. Sampling personnel will be appropriately 

trained for collecting and testing samples. Detailed sampling and analysis plans for 

environmental investigations are provided in Section 4. 

Ifthe findings of environmental investigations indicate the potential for risks to residents 

due to the presence of lead in one or more environmental media then the LCCHP Phase 2 Work 

Group will also recommend response actions to reduce the risk of lead exposure. The remedial 

response actions will depend on a variety of factors, which are discussed in detail in Section 4. 

3.5.1 Family Surveys/Information Gathering 

Following initial clinical management by the Lake County Public Health Agency, if it is 

determined by the Work Group that the EBL should be referred to the environmental testing 

program certain general property information about the family will be gathered prior to visiting 

the home. This information will typically be obtained by reviewing information obtained by the 

Lake County Public Health Agency and gathering additional information by phone at the same 

time that an appointment for meeting with the resident at their home is made. This information 

includes: 

• Physical address of property and owner mailing address (if different) 

• Ownership of dwelling and contact information for owner 

• Telephone numbers of resident 

• Language for contact with resident 

• Number and age of children under 72 months old residing at property 

• Pregnant or nursing woman residing at property 

An appointment will be made for an initial face-to-face interview at a time convenient to 

the resident and as soon as possible. The purpose ofthe inhial interview is to explain the 

LCCHP Phase 2 sampling program components and services and collect additional information 

about the family and their residence. The environmental program administrator works with the 

resident to fill out a "family survey" (questionnaire), which asks questions about possible 

exposures to lead. The questions focus on remodeling activities, cleaning habits and work and 

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LCCHP Phase 2 Work Plan March, 2009 

hobby exposures. A "child survey" will also be filled out for each young child. The child 

survey asks questions about an individual child's mouthing behaviors, possible exposures 

outside ofthe home, and ethnic background. The Lake County blood lead program and the 

CDPHE envirorunental program use similar surveys so that the responses given to both programs 

can be compared and evaluated over time. At the end ofthe initial meeting the condition ofthe 

property will be visually siuAfeyed and recorded. 

The information gathered on the questionnaires will then be entered into a project 

database and also copied to a project file. 

The LCCHP Phase 2 Work Group will use the information collected on the 

questionnaires, along with blood lead and environmental testing resuhs, to evaluate possible lead 

exposures at the property and to an individual child. If there is a possible exposure to lead, the 

Lake County Public Health Agency will notify the family and provide information on ways to 

reduce risks related to that exposure. 

3.5.2 Consent for Access 

Residents who participate in the LCCHP Phase 2 environmental testing program must 

sign a "Consent for Access" form. (Appendix E). CDPHE will be responsible for obtaining 

access from the homeowner. The agreement grants the LCCHP Phase 2 permission to use 

demographic information obtained through the questionnaires, sample the property and obtain 

information needed to evaluate cultural resources on the property. The consent for access also 

indicates that environmental investigation results will be recorded with Lake County. Before 

environmental testing is performed the property owner and current residents must sign the 

consent for access (if different). 

At the same time that the consent for access is explained and presented to residents, a 

form authorizing release of medical information will also be requested to release blood lead 

records and limited family questionnaire information from the Lake County Public Health 

Agency to the CDPHE and EPA for use in evaluating health risks. 

3.5.3 Scheduling Environmental Sampling and Remedial Response Actions. 

The sampling program will be implemented in a manner that minimizes disruption and 

inconvenience at each residence investigated. CDPHE will schedule sampling at convenient 

times to residents. Whenever possible, all sampling will be performed during a single visit. The 

collection of outdoor samples will be dependent on weather conditions. None ofthe sampling 

procedures causes damage to stmctures or painted surfaces. Soil sampling may cause minimal 

disturbance over a very limited area. 

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Patricia Berger 

Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

Environmental sampling visits will be scheduled at specified times based upon the 

availability of environmental sampling teams and the convenience and availability ofthe 

participants. Some flexibility should exist in the scheduling to accommodate unexpected 

changes in the plans ofthe program participants. 

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LCCHP Phase 2 Work Plan March, 2009 

4.0 ENVIRONMENTAL TESTING AND EVALUATION PROGRAM 

4.1 Residential Properties Environmental Investigations 

The primary purpose ofthe environmental testing program is to identify potential sources 

of lead exposure in and around the home and to focus response actions on those sources that 

present significant risks to resident children. Media sampled that exceed site action levels will 

be remediated. However, a single source or primary source of lead exposure may be very 

difficult to identify. For this reason, information collected during environmental investigations 

will be used in conjunction with family survey information and blood lead test results to identify 

the need for response actions and focus on the appropriate response actions for the types of 

exposures that may be taking place. Elements ofthe environmental investigation and evaluation 

approach are illustrated on Figure 4-1 and described in this section. Whenever contractors are 

used to perform environmental testing or remediation work for the LCCHP Phase 2, there will be 

a preference for hiring local contractors from Lake County to perform the work, to the extent this 

is allowable under State Procurement Rules. In order that local contractors may have the 

opportunity to provide services related to the LCCHP Phase 2, CDPHE will notify the Lake 

County Board of Commissioners prior to advertising to procure such services. 

At each property investigated, yard soil, interior and exterior paint and house dust will be 

sampled and/or tested for lead content. The sampling and analysis approach for each media type 

investigated will be based on the sampling plans described in this section. Consistent with the 

goals ofthe LCCHP Phase 2, each ofthe sampling plans allows for site-specific modifications to 

target sources of lead most likely to be encountered by children residing at the property under 

investigation. 

4.1.1 Soil Sampling and Analysis 

Representative samples of yard soil will be collected from a number of areas around the 

residence, as shown on Figure 4-2 and described below. The samples will be submitted to an 

off-site laboratory for analyses of lead. 

4.1.1.1 Sampling Plan 

At each property a site-specific sampling plan will be developed based on the following 

guidelines: 

• At a minimum, samples will be collected from each ofthe following areas: front, side 

and back yards; exterior driplines, vegetable garden area(s), if any; other garden areas 

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LCCHP Phase 2 Work Plan March, 2009 

(e.g., flower beds, etc.), if any; areas of bare soil; and distinct play areas (e.g., swing 

set or sandbox area) or other area of typical heavy use by children where soil is bare. 

• For each area sampled, one composite sample will be prepared from a minimum of 

three subsamples that are representative ofthe soil conditions within the area. 

• For each area sampled, one composite sample will be collected from the 0 to 2 inch, 2 

to 6 inch and 6 to 12 inch depth intervals, except in garden areas where the depth of 

sampling will be from the ground surface to at least 6 inches and at most 12 inches 

such that sampling extends to the base of tilled or worked soil. 

• In cases where undisturbed native materials, such as glacial till or bedrock, comprise 

the soil below 6 inches no sample will be required for the 6 to 12 inch depth interval. 

Prior to sampling, the sampling team will prepare a sketch plan ofthe house and 

surrounding property showing all bare areas, gardens and play areas. At this time a sampling 

plan will be developed for the property to meet the following sample requirements. 

Front/Back/Side Yard samples: 

Separate samples will be collected from the front and back yards. A separate sample(s) 

will also be collected from side yards ifthe soil characteristics are distinct from those in the front 

and back yards or if it is deemed that the side yard poses a potential exposure pathway. Each 

yard sample will be a composite comprised of at least three subsamples. One composite sample 

will be collected from each of three depth intervals: 0 to 2 inches, 2 to 6 inches, and 6 to 12 

inches below ground surface. 

Garden area samples: 

Within each distinct garden area of at least 30 square feet, such as a vegetable garden or a 

series of similar flower beds, a minimum of three subsamples will be collected from a depth 

interval representing the depth of worked soil and composited to obtain a single representative 

sample. The number of subsamples collected will depend on the total area sampled up to a 

maximum of 6 subsamples per garden area. The depth of sampling will depend on the extent of 

soil that appears to be routinely worked or tilled in gardening activities. Typically, depths of 

worked soil in garden areas extend 6 to 8 inches below ground surface. The maximum depth of 

sampling will be 12 inches. 

Bare area samples: 

Bare areas of at least 9 square feet — including bare piles of soil, gravel driveways and 

walkways will be identified visually and up to three distinct bare areas from a single property 

will be sampled. Within each separate bare area, three subsamples will be collected from the 0 

to 2,2 to 6 and 6 to 12 inch depth intervals. For each bare area and each depth interval, the three 

subsamples will be composited to obtain one sample. 

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LCCHP Phase 2 Work Plan March, 2009 

Play area samples: 

Additional samples will be collected from bare-soil play areas, if any exist at the property 

(i.e., such as around swing sets or sand boxes, or other bare areas known to be frequented by 

children). The sampling procedures used for bare areas will also be used in each bare play area, 

except in the case of sand boxes where one composite sample will be collected from the total 

depth of sand present, regardless of thickness. 

4.1.1.2 Sampling Procedures 

A detailed Standard Operating Procedure (SOP) for Soil Sampling is included in 

Appendix A and is summarized here. The SOP will serve as the primary reference for LCCHP 

Phase 2 soil samplers. 

The soil will be collected using a stainless steel trowel for scooping soil from the top 0 to 

2 inches and a coring device such as a drive sampler for collecting soil from deeper intervals. At 

each subsample location, loose debris and any sod or dense vegetative cover will be removed 

and the top 0 to 2 inches of soil will be excavated using a scoop or trowel. The top 2 inches of 

soil from each location will be removed from a circular area approximately 4 inches in diameter 

and placed in a plastic bag (e.g., Ziploc bag) with other subsamples from the 0 to 2 inch depth 

interval. A sample will then be collected from the 2 to 6 inch depth using a 2-inch diameter by 

4-inch long coring device, such as a drive sampler. The 6 to 12 inch sample will then be 

collected using a 1.5-inch diameter by 6-inch long coring device. Ifthe drive sampler collection 

tubes or core liners are re-used at separate locations, the equipment must be decontaminated 

between locations to prevent cross contamination between depth intervals at each location. 

For each depth interval within a single sampling area, subsamples will be combined 

together in a large Ziploc bag and disaggregated by hand in the sealed bag. The bag will be 

labeled to identify the property number, sample area (e.g., back yard), sample number, depth 

interval and date of collection. The sampling team will also record this information before 

samples are removed from the site. More information regarding sample documentation, labeling 

and tracking is included in the Quality Assurance Project Plan, Appendix C. The 

decontamination procedures for all sampling equipment are also provided in an SOP in 

Appendix A. 

Samples will be double bagged and stored in a box or cooler prior to shipping. It will not 

be necessary to refrigerate samples during storage or shipping. 

4.1.1.3 Field Documentation 

The locations of all individual subsamples will be marked on a site sketch map with 

associated composite sample numbers. All sampled areas will also be delineated on the site 

sketch map. Sample numbers, depths and location descriptions will also be recorded on a soil 

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2090 onf 8S2- CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

sampling worksheet (included in Appendix A, SOP for Soil Sampling). The sampling team will 

complete these records at the time of sampling. Copies of site maps and soil sampling 

worksheets will be included in hard-copy property files (refer to Section 8). 

4.1.1.4 Sample Analyses 

All soil samples from the 0 to 2 and 2 to 6 inch depth intervals will be shipped to an 

offsite laboratoty for analyses of lead. The lead concentration in the 0 to 2 inch depth interval 

and weighted average lead concentration in the 0 to 6 inch depth interval will be considered 

when developing recommendations for response actions. 

Samples from the 6 to 12 inch depth interval will remain in storage for possible future 

analysis. The decision to analyze a sample collected from the 6 to 12 inch interval will be based 

on the lead concentrations measured in the samples from the 0 to 6 inch depth interval at the 

cortesponding location. Ifthe weighted average lead concentration in the 0 to 6 inch depth 

sample exceeds the trigger value for lead (3,500 mg/Kg), then the 6 to 12 inch depth sample, 

corresponding to that location, will be submitted for lead analysis. 

Soil analyses for lead will be performed in accordance with USEPA SW-846 Method 

6200, x-ray fluorescence (XRF) analysis. For each composite sample, the entire sample volume 

submitted will be disaggregated, dried and sieved by the laboratory to homogenize prior to 

analysis. The less than 250-micron size fraction (passing 60-mesh sieve) will be used for 

analysis. Analyses for lead content will be performed on a laboratory XRF instmment calibrated 

using site-specific soil calibration standards. The detailed quality assurance and quality control 

requirements for laboratory XRF analyses, including instmctions for initial calibration, are 

provided in Appendix A. When the XRF result is within 10 percent ofthe trigger criterion for 

soil (3,500 mg/kg ± 350 mg/Kg), then the sample will be reanalyzed using the ICP method 

(USEPA SW-846 Method 6010) to confirm the result before it is used for comparison to the 

trigger level. Quality control methods for laboratory analyses of soil samples are provided in the 

Quality Assurance Plan (Appendix C). 

4.1.1.5 Altemate Sampling Plans for Multiple Dwelling Unit Properties 

Altemate sampling plans may be developed for properties under single ownership but 

where multiple dwelling units are present, e.g., trailer parks. On these properties, individual lots 

may be investigated under the LCCHP Phase 2 one at a time as elevated blood levels are 

encountered.. Common areas of such a property may also be investigated using an altemate 

sampling plan. Altemate sampling plans will be developed on an as-needed basis. The Work 

Group will be review and approval each plan prior to implementation. 

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3inJ^-^m 0 ^ RSO 00 DSO.OO Lake County Recorder of 82 CRS RSO.OO DSO.OO 

LCCHP Phase 2 Work Plan March, 2009 

4.1.1.6 Sampling of Playgrounds and Common Areas 

The environmental testing program will also allow sampling of non-residential areas such 

as playgrounds of other common areas that could be a source of lead exposure to children. 

Where the County elects to sample such common areas, the procedure outlined in Section 4.1.1.5 

will be followed. 

4.1.2 Exterior/Interior Paint 

The procedures for testing exterior and interior paint are based on the U.S. Department of 

Housing and Urban Development (HUD) guidelines (HUD, 1995) and requirements ofthe State 

of Colorado's Air Pollution Prevention and Control Act Regulation 19, Lead-Based Paint 

Abatement. In cases where the LCCHP Phase 2 paint testing procedures vary from those 

included in Regulation 19 the procedures will provide equivalent methods for identification and 

evaluation of lead-based paint hazards. 

The paint inspection and testing protocols presented in the work plan have been 

developed to meet the specific data needs ofthe LCCHP Phase 2. Those data needs are as 

follows: locate paint in poor condition to identify potential sources of direct lead exposure and 

lead in house dust; identify paint with lead content greater than 6 mg/cm^ so that remediation 

may be recommended; identify paint in poor condition with lead content greater than 1 mg/cm^ 

so that remediation may be recommended when children or pregnant or nursing women with 

elevated blood lead levels reside at the property. These data needs are consistent with the action 

levels for lead in paint presented in the 0U9 ROD. 

Lead-based paint hazards will only be evaluated in homes built before 1978. The year 

built will be obtained from Lake County Assessor's Office. If no building date is recorded with 

the Assessor, then the paint evaluation will be performed. Because mobile homes are typically 

not painted and were constructed after 1978, mobile homes will not typically be evaluated for 

lead-based paint hazards unless there are portions ofthe mobile home that are painted or the 

mobile home was constmcted prior to 1978. Ifthe date of constmction is unknown, it will be 

assumed that the mobile home was constmcted prior to 1978. 

A lead-based-paint risk assessor who is trained and certified in accordance with 

Colorado's Regulation 19 requirements will perform all paint assessment. A State-certified leadbased-paint inspector may also perform paint testing. 

At each property investigated, the paint hazard evaluation begins with family and child 

survey questionnaires (see Section 3.5), which provide the risk assessor with information 

regarding resident use pattems, child's principal play areas and habits, and other potential 

sources of lead exposure within and outside ofthe home. A visual assessment of paint 

conditions is then performed using the visual inspection procedures included in HUD's 

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LCCHP Phase 2 Work Plan March, 2009 

Guidelines for Evaluating Lead-Based Paint Hazards in Housing (HUD, 1995) and detailed in 

the SOP for Paint Testing and Assessment (Appendix A). After the questionnaires and visual 

assessment have been completed interior and exterior paint testing will be performed. 

A comprehensive paint investigation will be conducted in all homes where a child (or 

pregnant or nursing woman) with an elevated blood lead level resides, consistent with Chapters 

5, 7 and 16 ofthe HUD Guidelines (HUD, 1995) and as described below. 

The lead content of paint will be tested in situ using a portable XRF spectrometer. The 

paint testing method is non-desfructive to paint and will not damage painted surfaces or 

underlying substrates. Detailed procedures for calibrating, operating and maintaining the XRF 

instrument are provided in the SOP for Paint Testing and Assessment (Appendix A). 

4.1.2.1 Interior Paint Testing Plan 

HUD's risk assessment protocols include gathering information on resident use 

pattems, visual assessment and paint testing. The information gathering and visual assessment 

help the risk assessor select locations for environmental sampling. 

Interior paint will be tested in at least three areas ofthe home. The areas ofthe home to 

be tested will depend on the results ofthe visual assessment and family and child questionnaires. 

If deteriorated paint is present, then the deteriorated paint will be tested in at least three areas of 

the home. In cases where no deteriorated paint is present, testing will be performed in the three 

areas ofthe home most frequently or most likely to be used by young children. These areas will 

typically include the main living area, bedroom(s) and kitchen. The areas where testing is 

performed will be determined by the risk assessor. 

In each room tested, the lead content of paint on painted walls (up to four walls per room) 

window trim, doors and moldings will be determined. One XRF measurement will be obtained 

from each wall in the room up to four walls per room. If walls show distinct painting history 

each wall with distinct paint will be tested. Paint will also be tested on the oldest appearing 

painted working window in the room. If there are no working windows in the room, either the 

oldest appearing window will be tested or a window selected at random will be tested. Paint on 

the window casing, sash and ulterior sill will be tested. One door assembly will be tested in each 

room and it will be the door likely to receive the most use. The lead content will be measured 

for the casing, the jamb (a possible friction surface) and the door. Molding or decorative trim 

that is accessible to young children (less than 4 feet above the floor level) will be tested. The 

lead content of paint on molding will be measured for each type of molding in the room, such as 

baseboard and chair rail types. Ifthe paint on crown molding is in poor condition, it will also be 

tested. Other painted areas that may represent a source of exposure for young children, such as 

painted cabinets, may also be tested. Although the same general plan will be followed at each 

property, the risk assessor will determine the paint condition in other locations and determine the 

need for additional paint testing. 

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32 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March. 2009 

For homes where young children or a pregnant or nursing woman have elevated blood 

lead levels, deteriorated paint present in any area ofthe home frequented by young children will 

be tested and any painted flimiture, cribs, toy closets or other areas that a young child may 

routinely and frequently come in contact with may also be tested when the paint is in poor 

condition. In addition, paint will also be tested in the main living area, child's bedroom and 

kitchen, regardless of paint condition. If paint in these areas is in poor condition, testing will be 

performed to evaluate the lead content ofthe deteriorated paint. This approach will allow for 

identification of lead-based paint hazards throughout the home. In addition, when a child with 

an elevated blood lead level resides at the home, the lead-based paint risk assessment will always 

be accompanied by additional investigation of other potential sources of lead exposure (e.g., 

contaminated soil, hobbies, consumer products, etc.). 

4.1.2.2 Exterior Paint Testing Plan 

Paint on the exterior ofthe house and other stmctures (e.g., garage, storage shed, etc.) on 

the same property will also be visually assessed and tested when necessary. 

The visual assessment will be performed first to identify any areas of deteriorated paint. 

If deteriorated paint is present, it will be tested for lead content. If no deteriorated paint is 

present on or around the home, testing will be performed on one side ofthe home. Testing will 

include one wall, the main entry door assembly, a representative window assembly and the 

horizontal and/or vertical trim components on one side ofthe house. Ifa more extensive 

investigation is warranted, XRF measurements will be obtained from each painted side ofthe 

house for up to four sides in addition to the locations described above. Results from the family 

questionnaire and visual assessment may be used by the risk assessor to select locations for 

exterior paint testing. 

For the window, measurements will be obtained from the sill, casing and sash. For the 

main entry door, the casing, jamb (possible friction surface) and door will be tested. Horizontal 

and/or vertical trim components will be tested on one side ofthe house and that side will be 

either the front ofthe house or the side with the largest number of architectural features 

(typically the front ofthe house). In addition, painted fences and painted storage sheds or other 

outbuildings on the property will be tested ifthe paint is in poor condition. 

4.1.3 Dust 

Interior house dust will be collected for lead analysis at every home evaluated, regardless 

of age. Sources of lead to interior house dust include outside sources such as contaminated soil 

and mine waste and inside sources such as lead-based paint. The amounts of dust and lead 

concentration in dust will vary throughout a house. For this reason, dust will be collected from 

at least three areas ofthe home, including (1) heavy traffic areas such as main entries where 

tracking from outdoors may result in elevated lead levels in dust, (2) areas that are most 

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33 of 82 CRS RSO 00 DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

accessible to children such as play areas and (3) areas where the paint is in poor condition (if 

any). The risk assessor will always select locations for dust sampling based on the results of 

visual paint assessment, family and child surveys and family use patterns. A risk-assessor or 

inspector will collect dust samples once the risk assessor has selected locations. 

A minimum of three dust samples will be collected in each home. Typically, the areas 

sampled will include the main entry, the primary entry to the main living area and the entry to a 

young child's bedroom. Ifa pregnant or nursing mother resides at the home, then heavy traffic 

areas such as entries and hallways may be tested instead of bedrooms. When a young child 

residing at the property has an elevated blood lead level, dust samples may also be collected 

from other areas ofthe home frequented by that child and areas where paint is in poor condition. 

At each ofthe dust sampling locations, dust will be collected either from carpeted areas 

using a battery-operated air pump to collect dust in a pre-weighed filter cartridge or from 

uncarpeted areas using wipe samples. The exact location and type (carpeted, uncarpeted) of 

sample will be described in field notes and recorded with other sample information in the 

property file and the electronic database. If there are two separate carpets in a room, such as an 

area mg overlying wall-to-wall carpeting, the area mg will be sampled since it is the most likely 

source of exposure for a child, 

Using a sampling template, a one-square-foot area will be completely vacuumed using 

the air pump to collect the dust present. This procedure is documented in USEPA's Residential 

Sampling for Lead: Protocols for Dust arul Soil Sampling (\JSE? A, 1995) and included in 

LCCHP's SOP for Dust Sampling (Appendix A). Dust samples will be shipped to an offsite 

laboratory for analysis of lead by flame atomic absorption spectrometry (USEPA SW-846 

Method 7420), as described by the Quality Assurance Plan (QAP) in Appendix C. 

The trigger criterion for lead in dust is expressed as the lead concentration, or the mass of 

lead per unit mass of dust (mg/Kg). In order to provide the results of dust analysis in 

concentration-based units, a known mass of dust must be collected and analyzed. For this 

reason, the LCCHP Phase 2 uses the vacuum dust collection method (USEPA, 1995), which is 

the only documented methodology from Colorado's Regulation 19 that allows for analysis and 

reporting of results in concentration units. These results may also be used to determine the lead 

loading per unit area (^ig/ft^), if necessary to further evaluate lead exposure in the home. 

Dust wipe samples will also be collected. One dust wipe sample will be collected from a 

windowsill in each room where a floor dust sample is collected. The methods for collecting dust 

wipe samples are described in the SOP for Wipe Dust Sampling included in Appendix A. The 

dust wipes will be analyzed for lead and results will be reported as a lead load ijer unit area (e.g., 

mg/ft^). 

4.2 Data Evaluation for Individual Properties 

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LCCHP Phase 2 Work Plan March, 2009 

Once the results of an environmental investigation are available, they will be released to 

the property owner and the current residents. The results from the property-specific 

environmental investigation, released blood-lead data and family information survey will be 

reviewed and evaluated. This information will be used to identify the properties where response 

actions may be warranted. Response actions will be offered when the blood lead level of a 1 to 6 

year old child and pregnant or nursing mother exceeds 10 ug/dL, and any ofthe following 

environmental lead concentration levels are exceeded: 

Soil: greater than or equal to 3,500 mg/Kg 

Dust: greater than or equal to 2,000 mg/Kg 

Interior or Exterior Paint: for paint in poor condition with lead concentration greater 

than or equal to 1 mg/cm^- education provided; for paint in poor condition with lead 

concentration greater than or equal to 6 mg/cm^- active remediation. 

When one or more ofthe trigger criteria is exceeded the Work Group will evaluate a 

range of response actions appropriate to the potential sources of lead exposure identified. The 

appropriate types of response actions will be presented to the property owner and residents for 

their consideration, and the property owner/residents will describe their preferences. CDPHE 

will follow procedures established in this work plan to select response actions and make 

recommendations to the property owner/residents. No response actions will be taken without the 

prior permission ofthe property owner and residents. 

Results of blood lead testing will be released to the family by a Lake County Public 

Health Agency health-care professional. The results will be explained to the family and 

compared to the trigger level. The family will receive educational information discussing 

common sources of lead exposure and their associated health risks. This information will also 

include recommendations on hygiene, nutrition and home cleaning. Ifa child has an elevated 

blood lead level, and the Work Group has recommended that the property be entered into the 

Environmental Testing Program, then CDPHE will contact the resident and property owner to 

encourage environmental testing of their home. Specific risk factors for children will also be 

discussed and evaluated for each child tested based on the responses provided to the Lake 

County Public Health Agency's questionnaire. Further investigation into possible sources of 

lead — including mini-blinds, dishware, other consumer products, or childcare provider's homes 

may also be recommended ifthe results of environmental testing are inconclusive with respect to 

a potential source (or sources) of lead exposure in the home. Analytical testing of consumer 

products or other potential sources may be conducted, where practical and recommended by the 

Work Group to better determine the potential contribution to exposure. 

The CDPHE will also provide residents with the results of environmental testing and 

response action recommendations in person, whenever possible. The Property Summary Table 

will be provided and results will be discussed and compared to the trigger levels for each media 

26 
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LCCHP Phase 2 Work Plan March, 2009 

tested. If trigger levels are exceeded, then the types of response actions recommended by the 

LCCHP Phase 2 Work Group will be reviewed with the property owner and residents. Ifthe 

house was built before 1978 or if paint with a lead content greater than 1 mg/cm^ is reported, 

residents and property owners will also receive information on ways to reduce lead exposure 

during renovation and remodeling activities and information describing monitoring and 

maintenance of paint in good condition. Property owners will also receive information on the 

HUD disclosure requirements for lead-based paint. 

Based on the property owner's and residents' preferences, CDPHE will prepare a 

Response Action Plan for review and approval by property owner and residents. 

4.2.1 Prioritization of Response Actions 

Response actions will be prioritized, as practical, by maximum blood lead levels of 

children and pregnant or nursing women . 

4.3 Response Action Options 

The following section outlines the range of possible response actions that will be 

considered in developing recommendations for action at each property. As described in Section 

4.2, environmental testing results will be reviewed with the property owner/resident and the 

response action recommendations will be explained. As this program is voluntary, the entire 

range of options, including "No Action," will be explained to the owner/resident In cases where 

a property owner or resident elects no action or a response action that is potentially less 

protective than the LCCHP Phase 2 Work Group's recommendations, the potential risks will be 

discussed with the property owner/resident, and recommendations will be provided on ways to 

minimize these potential risks. 

Since the program is voluntary, no actions will be taken without the permission ofthe 

residents and property owner. In the event that the resident's opinion is different than the 

property owner's and either the resident and/or owner chooses not to continue with the 

recommended response action, the final investigation results will be provided to the property 

owner and its residents and retained on file by CDPHE, and the potential risks of not proceeding 

with the recommended action(s) will be explained. If there is disagreement between the property 

owner and resident, efforts will be made to resolve the disagreement and reach a consensus on an 

appropriate action as part of gaining consent for access from these parties. If these efforts fail 

and no action is taken, the property will be considered "not remediated" but remediation may be 

performed at a later date if requested by the property owner. 

The following sections describe in general the range of response actions identified in the 

Operable Unit 9 Record Of Decision to be considered when any ofthe trigger criteria are 

exceeded for the media investigated (e.g., soil, dust, paint). In some cases, general preferences 

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36 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

for response action recommendations are established and other considerations to be evaluated 

relative to specific options are discussed. The comprehensive response action developed for 

each property will consist of one or more options for each media for which trigger criteria 

exceedances are observed. The response actions selected will give consideration to the property 

owner's and residents' preferences. 

The development ofa Response Action Plan and related attachments is the last step in the 

response action design process, as discussed in detail in Section 5. The general procedures and 

specific requirements for implementing the selected response action components at individual 

properties are included in Section 5 as well. 

4.3.1 Elevated Blood Lead 

When a young child is identified with an elevated blood lead level (>10 jtg/dL) the Lake 

County Public Health Agency will work with the family to develop a plan to reduce the child's 

blood lead level. The Health Department will follow the response procedures outlined in Section 

3.4 and CDPHE guidelines for retesting and clinical management. The program will review the 

responses from the child questionnaire with the child's parents to identify any possible risk 

factors unrelated to the environmental media evaluated. Further investigation into other possible 

lead sources may be needed, such as sampling mini-blinds or pottery or other consumer 

products. 

Information about the child will also be reviewed and evaluated, including: 

• responses to the child and family questionnaires; 

• possible exposures at daycare, playgrounds, or other dwellings frequented by the 

child; 

• adult/family member work- or hobby-related exposures; 

• exposure related to remodeling activities; 

• paint condition; and 

• yard condition. 

All information available from the environmental sampling program will be evaluated to 

identify potential sources and develop a response action. The response actions to be considered 

for identified potential sources of lead exposure resulting in blood lead concentrations greater 

than or equal to 10 |ig/dL shall include any ofthe actions described below for soils, dust and 

paint. In addition, other potential lead sources beyond an individual residence and within Lake 

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37 of 82 CRS RSO 00 DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

County may be considered by the LCCHP Phase 2 Work Group for remediation and/or education 

to address exposure. 

When a young child (or pregnant or nursing woman) has an elevated blood lead level, 

actions may be recommended even though none ofthe environmental media sampled at the 

home have a lead concentration exceeding the trigger criteria. In response to an elevated blood 

lead level, soil response actions may be considered even when soil lead concentrations do not 

exceed 3,500 mg/Kg and paint response actions may be considered when lead-based paint (>1 

mg/cm^) in poor condition is present. The Work Group will have the ability to recommend such 

response actions for any property where a child or pregnant or nursing woman with an elevated 

blood lead resides. 

In every case where a child with an elevated blood lead is identified, education about 

strategies for reducing exposure to lead will be provided to the family. In cases where the 

program is not able to identify a source of lead exposure for such children, continued frequent 

blood lead monitoring will be strongly recommended and educational support will be offered to 

the family on a continuing basis. The Health Department will also provide for continued 

monitoring of children with elevated blood lead concentrations beyond the age of six, although 

those children would be beyond the age group at highest risk from exposure to lead. As new 

information becomes available, the Health Department in consultation with the Work Group, 

will re-evaluate the case. 

4.3.2 Soil 

The trigger criterion for residential soil response actions under the LCCHP Phase 2 is: 

soil-lead concenfration greater than or equal to 3,500 mg/Kg. The following response actions 

could be taken for residential soils: 

No Action 

No action may be selected when soil lead concentrations do not exceed the trigger 

criterion of 3,500 mg/Kg.. 

Education 

Appropriate educational materials will be provided to the owner regarding maintaining 

areas of existing soil cover, including vegetated areas; safe methods for soil excavation and 

disposal; and information about reducing risk through good hygiene and nutrition. Annual blood 

lead monitoring for young children will also be strongly recommended. 

Containment 

This option includes the following installation altematives to contain contaminated soils. 

Alternatives listed here may be used in combination on any given property. 

• Soil cap: Borrow soil placed over impacted areas. 

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38 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

• In situ mixing: Mixing of surficial soils having lead concentration above 3,500 

mg/Kg with underlying unimpacted soils could be performed to reduce lead 

concentrations to acceptable levels. Homes with soil-lead concentrations greater the 

3,500 mg/Kg in the 6-12 inch depth interval are not considered amenable to this 

altemative due to the difficulty in mixing to the depths required to achieve the 

objective. 

• Sod placement: Sod placed over impacted soils. 

• Compacted clay cap: Compacted clay placed over impacted areas with a minimum 

one-foot silty or sandy protective layer to maintain cap integrity. 

• Sprayed asphalt: Sprayed asphalt placed over impacted areas and covered with soil or 

opaque reflective paint to protect the asphalt from ultraviolet light and retard 

oxidation. 

• Asphaltic concrete: Asphalt for paving grades or special blends mixed with well 

graded, crushed aggregate, placed over impacted areas. 

• Concrete cap: Concrete placed over prepared impacted areas. 

• Multi-layered cap: Cap composed of some combination of natural soils, soil 

admixtures, clay, asphalt, asphaltic concrete, or Portland cement and placed over 

impacted areas. 

The capping material selected depends on the type of cover that exists at the property, drainage 

pattems, the needs ofthe property owners and the local availability of capping materials. The 

types of cover materials to be used may include topsoil, sod, gravel, road base, concrete and/or 

asphalt. Compacted clay caps and sprayed asphalt will not be routinely considered and are not 

described in Section 5. 

Diversion Ditch Constmction 

Constmction of diversions and/or culverts may prevent mn-on to source areas and reduce 

both erosional and leaching release of metals from a source to a residential property. Diversion 

ditches or culverts are typically included in a response action in conjunction with other soil 

actions and are intended to increase the long-term effectiveness ofthe selected remedy. 

Removal 

Removal of soil would be accomplished through hand excavation with the aid of 

mechanical excavation equipment. The removal depth would be decided on a case-by-case basis 

based on site-specific information, but would be no more than 12 inches. During excavation and 

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LCCHP Phase 2 Work Plan March, 2009 

fransport, dust suppression will probably be necessary. After excavation, borrow materials 

would be transported to the residence and placed. Yards would be revegetated, generally with 

sod. Excavated materials could be put to beneficial reuse as approved by the County and the 

regulatory agencies or could be removed to the LCCHP soil repository. Cap or cover materials 

used in response actions will be similar to the materials currently in place at the property. For 

example a gravel driveway will be replaced with new gravel or road-base material. 

Soil removal to a depth of either 6 inches or 12 inches will be considered based on the 

results of soil sampling and analysis. Any soil response action performed by the CDPHE and/or 

its contractors will include family and property owner education and appropriate disposal of soil. 

4.3.3 House Dust 

Potential sources of lead for in-residence dust are: lead-based paint in poor condition, 

bare soil areas, gardens, streets, alleys, tailings and mine waste, hobbies and work activities. 

Dust may be transported into the home by wind or on items taken outside and then retumed 

inside. The response actions available to address elevated lead levels in interior dust are: 

No Action 

No action may be recommended when dust lead concenfrations are less than 2,000 

mg/Kg or for an interim period when another primary source, such as yard soil or interior paint, 

is addressed. 

Education 

Appropriate educational materials will be provided and annual blood lead monitoring for 

young children will be strongly recommended. 

Physical Protective Measures 

This response action includes sealing off unfinished basements, attics or crawl space 

areas to limit exposure to dust from these areas. As these sources for dust are not typically 

evaluated, these types of actions will be considered only in cases where the blood lead frigger 

level has been exceeded in young children who reside at the property. 

Removal and Disposal 

One or a combination ofthe following methods may be considered for removing interior 

lead-dust: 

• Vacuum interior living spaces with a HEPA vacuum. Dust can be disposed of in a 

RCRA Subtitle D landfill as it is considered a household waste. 

• Damp mop all floors, window wells and other wood work with a trisodium phosphate 

(JS?) cleaning solution (or other appropriate cleaning fluid). 

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LCCHP Phase 2 Work Plan March, 2009 

• Wet wash walls, floors and wood work with TSP cleaning solution (or other 

appropriate cleaning fluid). 

• Clean fiimace ducts using the USEPA-approved program for duct cleaning. 

• Place mats at entry doorways so that shoes may be appropriately shaken or wiped 

before entering, reducing the amount of soil entering the residence. 

• Remove settled dust from horizontal surfaces. 

Dust abatement is always performed following a paint removal or abatement action that 

generates dust inside the home (see below) but may also be performed in response to lead 

concentrations in dust above the trigger level of 2,000 mg/Kg. Dust abatement specifically 

includes a HEPA vacuuming and wet washing of all surfaces within the work area, as defined in 

HUD's Guidance for the Evaluation and Control of Lead-Based Paint Hazards (HUD, 1995). 

When no response actions are performed to address lead-based paint, other dust removal actions 

can be selected to address elevated lead concentrations in dust, as appropriate to the conditions at 

the property. 

Following completion ofa dust removal or abatement action, a set of clearance samples 

will be collected to confirm that dust remaining in the work area no longer represents a lead 

hazard. Methods for collecting these clearance samples are described in Section 5. Ifthe results 

from such samples do not meet the clearance criteria, then the removal action will be repeated 

until the clearance level is achieved. 

4.3.4 Exterior and Interior Paint 

Residences may have interior and/or exterior paint that is lead-based. Lead-based paint 

in poor condition may contribute to lead exposure through inhalation and ingestion of dust or 

direct consumption of paint chips. 

Before response actions are initiated, repairs may be required. For example, repairs to 

leaking pipes that contributed to paint degradation and lead-based paint hazards. These repairs 

may be provided by the program as part ofthe response action for the affected area only. Some 

repairs may be required to be completed by the owner or resident before response actions are 

continued. 

Depending on the paint's lead concentration and condition the following response actions 

may be considered: 

No Action 

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4fnf82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

No action will be taken if no lead-based paint (at or above 1 mg/cm^) is identified 

through the environmental testing program. 

Education 

If paint contains lead at or above 1 mg/cm^ and is in poor condition (peeling, chipping, 

chalking) or coating a friction surface, education, risk counseling and information on actions 

they may take themselves will be provided to residents. Appropriate educational materials, 

including information regarding risks related to renovation and remodeling activities and ways to 

maintain paint in good condition, will be provided and annual blood lead monitoring for young 

children will be strongly recommended. 

Source Control. Containment. Covering or Removal 

If paint has lead levels either greater than or equal to 6 mg/cm^, active remediation would 

be recommended. Source controls may be implemented to minimize deterioration of lead-based 

paint and include repair of defective substrates, paint encapsulation, repair of friction surfaces 

for smooth operation, enclosure ofa painted area or component (e.g., with drywall). If either 

encapsulation or removal is chosen for remediation, the remediated areas will have a surface 

paint-lead level no greater than 1 mg/cm^. 

Paint Removal and Replacement 

Removal and replacement actions may involve individual painted components, such as 

doorframes, or paint removal from an area ofthe home. Paint removal without replacement 

involves removal and refinishing. Removal could also include component removal, replacement 

and refinishing. The materials used in removal and replacement actions will be similar to those 

existing on the property. 

For homes where lead-based paint is known present based on the results of paint testing, 

information will be available to property owners involved in renovation or remodeling activities 

requiring a building permit (refer to Section 7). In addition, the Federal lead-based paint 

disclosure law (Residential Lead Based Paint Hazard Reduction Act and 24 CFR Part 35 and 40 

CFR Part 745) requires property owners to provide any available information regarding the 

presence of lead-based paint to interested purchasers ofthe property prior to any property 

transfer. 

After any action that leads to the disturbance of lead-based paint, dust abatement will be 

performed to remove dust potentially containing lead-based paint. Dust abatements will be 

performed in accordance with procedures included in Colorado's Air Pollution Prevention and 

Control Act, Regulation 19 - Lead-Based Paint Abatement. Clearance sampling to confirm that 

dust abatement has been effective will be performed at the completion of dust abatement actions 

(refer to Section 5.6). 

4.4 Cultural and Historical Resource Evaluations 

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LCCHP Phase 2 Work Plan March, 2009 

Portions ofthe County lie within the Leadville National Historic Mining District 

(National Register of Historic Places No. 5LK846) and some portions lie within the Leadville 

Historic Landmark District (NHLD) (No. 5LK40). Properties within these districts may be 

individually listed on the National Register of Historic Places (NRHP), determined eligible for 

individual listing, or determined to be contributing elements of either ofthe disfricts. For this 

reason, planned response actions that address physical conditions on a property need to be 

developed with consideration for historic preservation. These actions fall within the definition of 

a federal action, and as such, require participation from the State Historic Preservation Officer 

(SHPO) in evaluating properties and developing response actions that mitigate adverse effects to 

cultural resources. Therefore, Lake County will work directly with SHPO to evaluate 

architectural resources at properties within the NHLD where response actions are planned and to 

evaluate potential archaeological resources at all properties participating in the LCCHP Phase 2 

where soil response actions are planned. For each property entering the program, the location 

will be compared to the boundary ofthe NHLD to determine whether the property lies within 

that district, and this information will be recorded in the property file. 

For properties within the NHLD where buildings or other structures built prior to 1950 

are present, the buildings and stmctures will be photographed and a Preliminary Cultural 

Resource Evaluation Form will be completed by Lake County. The Preliminary Cultural 

Resource Evaluation Form, photographs and information describing the location ofthe property 

will be supplied to SHPO along with information describing the location ofthe property and a 

request for determination ofthe property's contribution to the historic district, according to the 

following criteria: 

• Contributing elements: elements that retain a sufficient degree of integrity as related 

to the district. 

• Potentially contributing elements: elements that may retain a sufficient degree of 

integrity as related to the district. Further review and evaluation will be necessaty to 

determine the status. 

• Non-contributing elements: elements that have been substantially altered and/or 

constructed within the last 50 years (after 1950). Consequently, they do not represent 

the period of historic use. 

In short, in order to be considered contributing to the NHLD the property must retain 

sufficient physical integrity to convey the characteristics for which die historic district is 

significant. Physical integrity means that the property must in fact date to the period(s) and 

retain the physical appearance to convey the period. For the Historic Mining District, the same 

criteria apply except that any type of property associated with the historic mining periods may 

contribute, such as mine waste piles, roads, rail grades and other landscape features and 

resources that may have potential to contribute additional information (archaeology) such as 

town sites and trash dumps. 

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LCCHP Phase 2 Work Plan March, 2009 

The SHPO has accepted certain types of response actions as actions resulting in no 

adverse effects to cultural resources. The list of actions accepted as having no adverse effects 

and other actions that may be routinely performed as part ofthe LCCHP Phase 2, the "no 

adverse effect" actions, follows: 

• Residential Soil: education and institutional controls; replacement of driveways or 

walkways following existing configuration and with in-kind materials; containment, 

diversion ditches and soil removal are considered to have no adverse effect when 

monitoring is performed, as needed, during these activities (refer to discussion below) 

• House Dust: education; physical protective measures; dust removal and disposal by 

cleaning and decontamination 

• Interior/Exterior Paint: education; containment and covering when historic 

architectural features remain in place; encapsulation; painting with lead-free paint; 

removal or replacement of non-historic components; historic component removal 

when replacement is with like-kind or compatible materials; paint removal and 

repainting; cleaning. 

Ifthe planned response action at a property includes only the "no adverse effect" actions listed 

above, then a detailed resource evaluation will not be necessary. If, however, the response 

actions needed at a property have the potential for adverse effects on historical resources then a 

preliminary evaluation ofthe property and a determination of its architectural significance and 

contributing status to one ofthe historic districts will be conducted. 

SHPO will notify Lake County of their determination regarding contributing status 

within 14 days of receipt of these materials. Lake County will then notify the Lake County 

Historic Preservation Advisory Board (LCHPAB) of each property's contribution status with 

respect to the historic district. The SHPO determination will also be recorded in the project's 

electronic database. 

For properties determined to be non-contributing, no additional cultural resource 

evaluation or consideration will be necessary to develop and implement final designs. 

At properties determined to be contributing or potentially confributing to the NHLD and 

where response actions with potential adverse effects are planned, SHPO must be consulted 

conceming the effects ofany proposed actions, after the types of response actions needed have 

been identified. In order to comment on effects, SHPO may need information in addition to the 

Preliminary Form previously submitted. Additional information would be in the form of 

completed Colorado Historical Society Management Data Forms and Historic Architectural 

and/or Historic Archaeological Component Forms, as appropriate. The completed information 

will be provided to SHPO and LCHPAB prior to final design ofthe appropriate response actions. 

No final response actions will be implemented until the additional information has been 

reviewed. 

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44 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March 2009 

Any property, regardless of age of buildings and other structures on the property, has the 

potential to contain archaeological resources that contribute to the Leadville Historic Mining 

District. For this reason, additional measures will be taken to observe, document and describe 

features of potential archaeological significance prior to and during any soil response actions. 

Because even the most invasive soil response action will be limited to removal or other 

disturbance ofthe top 6 to 12 inches of soil, large-scale disturbance or destmction of significant 

archaeological features is not expected. In addition, based on experience monitoring soil 

response actions at more than 625 residential properties so far, it appears unlikely that significant 

cultural resources will be encountered. If concentrations/deposits of historic materials (artifacts) 

and/or evidence of intact features or stmctural remains are encountered during a soil response 

action, work will be stopped until a cultural resources professional, i.e., archaeologist, can 

examine and evaluate the significance ofthe resource or remains encountered. The presence of 

sparse or scattered artifacts or the disturbed remains of features within the work area is not cause 

for work to be halted; the materials should be set aside for examination by the archaeologist at a 

later date. If there is any question as to the nature ofthe materials discovered (density of 

materials, intactness of features), the professional archaeologist will be notified. This approach 

will apply to all properties where soil response actions are planned, regardless of NHLD or 

Historic Mining District contributing status. 

Mitigation of disturbance of significant archaeological features, as recognized by a 

professional archaeologist, will be achieved through onsite monitoring of soil disturbance 

activities and documentation ofany features observed. When monitoring is performed or when 

artifacts, features or remains are identified and later examined, the archaeologist will complete 

the Management Data Form, and if necessary, Historical Archaeological Component Forms. 

This information will be provided to SHPO and LCHPAB. 

In unusual cases where a child with an elevated blood lead level has been relocated 

during a response action, the response action must be completed as quickly as possible to protect 

the health ofthe child and to clear the property for child occupancy. In these cases, the response 

action is considered critical and must be expedited to the extent possible. Most ofthe response 

actions required under the LCCHP are those listed as having no adverse effects on cultural 

resources. In those cases where actions with potential for adverse effects are performed as 

emergency response actions, SHPO will be notified ofthe selected remedy and the time-critical 

nature ofthe action. In these cases only, SHPO concurrence with the selected response action 

will not be necessary to initiate and complete work at the property. 

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45 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

5.0 ENVIRONMENTAL RESPONSE ACTIONS 

Following the evaluation of environmental and blood lead data and the coordinated effort 

between the CDPHE and the individual property owners and residents to develop a site-specific 

Response Action Plan discussed in previous sections, the recommended and accepted plan will 

be formalized with the appropriate level of detail needed to facilitate implementation ofthe 

remedy. Response Action Plans will be sufficiently detailed to provide the property owner and 

resident with a detailed understanding ofthe work to be performed and guide the actual 

performance ofthe work. This section addresses the development ofthe Response Action Plans, 

and related attachments, as well as providing the general requirements and more specific 

procedures and specifications that will be followed in implementing response actions. This 

information is provided in the following sections by media type and is organized by providing 

the general requirements necessary to prepare and control work areas followed by more specific 

requirements or material or procedural specifications that may govem certain aspects ofa 

selected response action. Because the specific details of remediation will be developed on a 

property-by-property basis, with a priority placed on accommodating the preferences ofpreperty 

owners and residents, the information contained in this work plan may not specifically address 

every component ofa selected remedy. 

5.1 Response Action Plan 

As discussed in Section 4.3, a Response Action Plan will be prepared to document the 

recommended response actions and obtain necessary approvals from the property owner and 

resident. The Response Action Plan will include the environmental test results and a written 

description ofthe corresponding response action components and will be provided to the 

property owner and residents for review. 

A Soil Remediation Site Plan (Site Plan) will also be prepared for properties where a soil 

response action is planned. The Site Plan is a drawing that will identify the areas to be 

remediated and the associated response action(s) for those areas. More specifically, it will 

illustrate the boundary ofthe developed property, locations ofthe main residence and other 

stmctures, driveways, sidewalks, flower beds, garden areas, bare areas, and any other pertinent 

property features. The Site Plan will indicate the existing types of vegetation, landscape 

materials, and other ground cover (e.g., concrete, asphalt, gravel, etc.) present. For containment 

or removal actions, the Site Plan will outline the areas to be excavated and/or covered and the 

type of replacement and/or cover materials (i.e., topsoil, road base, sod, concrete, asphalt, etc.) to 

be used, and will identify vegetation to be removed or left in place and fences or other landscape 

features to be removed and replaced, if necessary, to complete the remediation. The property 

boundary indicated on the Site Plan will be based on visual observations ofthe property and 

discussions with the property owner, but will not necessarily be based on the legal description of 

the property, unless provided by the property owner. 

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4V^7Vn 6 of 82^ CR ^wSi R^nn RSO.OOn DSO.O DSO.OO O Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

Prior to remediation, both the Response Action Plan and the Soil Remediation Site Plan 

(if any) will be submitted to the property owner/resident for final approval. The property owner 

and resident will be required to initial both documents indicating their acceptance ofthe 

remediation activities to be performed. 

5.2 Consent for Access 

Property owners/residents must grant access to their property before remedial activities can 

begin. A consent for access form will be prepared for each property requiring remedial action (the 

Consent for Access for Remediation Activities is included in Appendix E). The Response Action 

Plan and the Soil Remediation Site Plan (if any) will be Included as attachments to the consent for 

access form. 

The Response Action Plan will contain the property owner/tenant and contractor 

responsibilities. Residents and visitors will be requested to limit travel, to the extent possible, 

through the affected areas during remediation activities and will be asked to adhere to all safety 

precautions outlined in the agreement. The property owner/resident will also be responsible for 

removing obstmctions within the work area that may hinder activities. 

After the consent for access has been signed and dated (by both the property owner and 

the resident), the program will develop the remediation schedule and coordinate work with the 

contractor(s). Property owners/residents will be given notification before the work begins. 

53 Oversight and Reporting 

Response actions will be performed under the direction and oversight of CDPHE or their 

designated representatives. Oversight activities will include: monitoring response action 

activities and ensuring adherence to the Response Action Plan, Site Plan (if applicable) and 

project specifications; maintaining appropriate records and documentation ofthe work 

performed; and coordination with the property owner and/or resident as work progresses. Photo 

documentation, by still photographs and/or videotapes, will be used to document pre-remediation 

and post-remediation conditions of each property. In addition, condition of buildings and other 

fixtures will be noted, and photographically documented, as necessary, including verification of 

the integrity of structures and foundations with respect to the anticipated depth of excavation. 

Post-remediation photographs and/or videos will be taken within a week of completion of 

response action activities. 

A Property Documentation Report (PDR) will be prepared for each property upon 

completion ofthe response action(s). The PDR will include information on the property 

description and location, the environmental investigation, the development of remedial actions, 

remedial actions performed, changes or problems encountered during constmction activities and 

any completion information required (i.e., any clearance sampling, replacement soil sampling 

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47 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

and educational materials distributed). The Property Summary Table and Soil Remediation Site 

Plan (if any) for each property will be included as attachments to the PDR. A PDR will also be 

completed for properties where no action was performed, based either on the LCCHP 

recommendation or owner preference, and will included property information and results of 

environmental sampling. 

Copies ofthe PDR will be provided to the property owner for his/her records. Copies 

will also be maintained at the Lake County Building/Land Use Department files for public 

access. Copies will also be sent to the LCCHP Phase II Work Group via e-mail. 

5.4 Soil Response Actions 

This section outlines the requirements and procedures common to all soil response 

actions and provides general requirements or specifications specific to each type of action 

selected. The general categories of action options available, other than no action, are as follows: 

• Removal and Replacement 

• Containment (Capping and In-Situ Mixing) 

• Constmction of Diversion Stmctures 

The objective ofa soil response action is to either remove the source of lead or to eliminate 

the pathway of exposure through covering or other means of containment. In general, the 

replacement or cover material utilized will be similar in kind to the existing materials to be 

removed or covered, with consideration given to property owner/resident preferences. In the 

process of identifying appropriate options and making recommendations for soil response 

actions, the condition of existing vegetation, the use pattems ofthe property, and current 

drainage pattems within and adjacent to a property will be evaluated. In general, removal and 

replacement will be the preferred soil response action option. 

Containment options such as soil cover will be recommended, as appropriate, considering 

property owner/resident preference, where excavation is not practicable, or where additional soil 

is necessary to provide proper drainage (e.g., replacement soil thickness greater than the removal 

thickness). Containment utilizing asphalt or concrete, may be recommended for driveway, 

sidewalk, or walk-way areas if replacing an existing concrete/asphalt surface which is in poor 

condition, allowing a pathway to underlying lead contaminated soils, or in situations where 

removal is not practicable and the placement of concrete or asphah is a cost-effective alternative. 

The placement of sod as a cover can provide an effective barrier to limit exposure to lead 

contaminated soil ifthe sod is properly maintained. However, the use of sod alone as a 

containment option will not be recommended. In-situ mixing may be used as a containment 

option in situations where lead concentrations above 3,500 mg/Kg are observed in the 0-2 inch 

depth interval only and lead concentrations in the underlying soils are relatively low. 

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48 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March. 2009 

Constmction of properiy placed diversion structures (i.e., diversion ditches, berms, or 

culverts) may be necessary to protect a remedy or to prevent re-contamination ofthe property 

from other sources. Surface water diversion options will be recommended, as needed, as a 

component ofthe soil response action but will not typically be the primary response action at a 

property, 

5.4.1 Confractor Requirements 

Soil remediation personnel must have successfully completed the Occupational Safety 

and Health Administration (OSHA) 40-hour HAZWOPER training in accordance with 40 CFR 

1910.120. 

5.4.2 Yard Preparation and Site Confrols 

Certain preparatory and site-control activities, common to all soil response action options, 

will be conducted at each property as generally described in the following sections. 

5.4.2.1 Access Controls 

During remediation activities, clean access will be provided to the resident at all times. 

Clean access means the resident will not have to walk through soil prior to entering their home. 

Sidewalks will be thoroughly bmshed and washed off with water after each workday to provide 

as clean an entry as possible to the residence. If there is no sidewalk to the residence, a clean 

pathway to the residence will be provided by laying down plywood, pallets, plastic, or using 

other temporary measures to prevent exposure and tracking of contaminated soils. All residents 

(especially children) will be asked to stay away from the constmction area during remediation 

activities. Unsafe excavation areas or stockpiled soils will be fenced to prevent accidents and 

exposure. 

5.4.2.2 Utilities and Surface Obstacles 

Prior to beginning any work, the remediation contractor will be responsible for 

coordinating with local utility companies to locate electrical, water, sewer, gas, cable, and phone 

lines. The property owner/resident will be asked to provide any information they may have on 

the location of subsurface obstacles (i.e., septic systems and abandoned utility lines). Should 

excavation/mixing activities impinge upon any known buried utilities/obstacles, the remediation 

contractor will be required to hand-excavate the area. 

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LCCHP Phase 2 Work Plan March, 2009 

Surface obstacles to be removed prior to remediation will be identified by the CDPHE 

and the remediation contractor. The property owner/resident will be asked to move such 

obstacles and any personal possessions away from the area to be remediated. In special cases, 

where the property owner/resident is physically unable to move the identified obstacles, the 

contractor will be available to assist them in the removal process. Fences and gates will be 

removed, if necessary, to facilitate access to the work area. All fences and gates will be replaced 

at the end of remediation activities. 

5.4.13 Dust Control 

Water application will be used to minimize the potential for fiigitive dust emissions. 

Application rates will be regulated to control dust during excavation yet not result in the 

development of mud. The objective is to minimize airbome dust and, at the same time, minimize 

production of mud that could be transported off-site on haul tmcks and other mobile equipment. 

Dust suppression equipment will consist of standard garden hoses and spray regulators. Outdoor 

faucets and hydrants from private residences and public areas will be used as water supply 

sources. The CDPHE and their contractors will coordinate with residents and the local 

municipalities regarding water use. At properties where water sources are not available, a tanker 

tmck or trailer will provide the water supply. 

The remediation contractor will provide water applications during the course of remediation 

and restoration operations on an as-needed basis, as follows: 

• Prior to excavation activities and prior to travel of equipment and work crew on the 

site on a daily basis; 

• During soil removal operations by heavy equipment and by hand crews; 

• At work intervals where wind and/or dry weather require such actions to prevent 

airbome emissions; 

• During stockpiling and/or loading of soils for transport; 

• To wash down sidewalks, alleys, or streets impacted by soil handling and 

transportation activities (these areas may be swept if it can be accomplished without 

dust); 

• Prior to the placement of fill or cover materials during the restoration process; and 

• Prior to leaving the premises at the end of each workday. 

5.4.2.4 Protection of Structures and Plants 

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50 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

Excavation by hand will be required for all areas susceptible to potential damage from 

heavy equipment operations. Areas of concern include stmctures (i.e., houses, garages, sheds, 

paved driveways and sidewalks) and landscaping vegetation (i.e., trees, hedges, and large 

shmbs). Oversight personnel will periodically inspect structures and buildings for evidence of 

damage resulting from remediation activities. If remediation activities do result in any damages, 

the CDPHE will inunediately contact the property owner to determine and discuss the extent of 

the damage and any repair work needed. 

5.4.3 General Remediation Procedures 

This section outlines the constmction procedures and specifications to be followed when 

implementing each ofthe soil response action options. Soil response action activities will be 

planned to minimize both physical and lead-related hazards for workers and residents. This 

includes sound safety measures, operating heavy equipment in a safe manner and performing 

actions at each property quickly and efficiently to limit disturbance to the residents. The 

requirements for clean replacement soil and capping materials are provided in Section 5.4.3.7. 

5.4.3.1 Removal and Replacement 

The extent of removal will be based on the results of soil sampling efforts and will be 

identified in the Response Action Plan and on the Soil Remediation Site Plan. Individual areas 

selected for excavation will generally encompass, at a minimum, the entire area represented by a 

single composite sample unless another type of action is selected for a portion ofthe area. Yard 

soils will be excavated to a minimum depth of 6 inches and a maximum depth of 12 inches. 

Vegetable garden areas identified during the sampling efforts would typically be excavated to 

depths of 12 inches, depending on the results ofthe soil sampling in these areas. In general, the 

following areas may be excavated (subject to the results of sampling in these areas): sod areas; 

landscaped areas; roadway shoulders (if curb and gutter are not present) to the edge ofthe road 

and to the lateral extent ofthe property lines; garden areas; play areas; unpaved driveways; 

garages with earthen floors; unpaved storage areas; and areas under temporaty stmctures such as 

storage sheds, landscape timbers, stepping stones, etc. Excavation will not occur in areas that 

are paved or otherwise covered (such as concrete pads, patios, sidewalks, paths, and driveways) 

or in areas where permanent stmctures are present, which preclude exposure (such as houses, 

garages with paved floors). Larger trees and shrubs will be left in place. Excavation around 

shmbs and tree roots will be performed by a combination of equipment and handwork to remove 

as much contaminated soil as practical without undue damage to the plant's root system. 

Smaller shrubs can be removed if required. Ifa property owner/resident wishes to save any 

small plants, shmbs, or bulbs in the removal areas they will be required to remove them prior to 

the initiation of excavation activities. Once excavation around plants is completed, backfill will 

be initiated as soon as possible using dampened replacement soils to reduce plant stress. 

42 
l<;^Om 3/16/2010 9.44 AM Patricia Berger 

51 of 82 CRS RSO.OO DSO.OO Lake County Re^or^er 

LCCHP Phase 2 Work Plan March, 2009 

Existing contaminated soil and sod can be removed using a variety of powered equipment 

and hand tools, as necessary. Primary equipment will consist of skid steer loaders, front-end 

loaders and small backhoes. Clean replacement material may consist of topsoil, road base, 

gravel, decorative rock or other landscape materials (decorative bark or mulch) and will be 

selected to match the existing materials or other suitable material based on the property 

owner's/resident's preference. Replacement soil material will meet the requirements specified in 

Section 5.4.3.7. 

Oversight personnel will perform inspections to verify the depth of removal. 

Replacement fill shall be placed to depths to match surrounding grade or to greater depths if 

necessary to correct drainage problems. Prior to placing fill material in the excavated area, the 

contractor should establish final grade lines to ensure the required amount of fill will be placed. 

The area should be sloped to keep drainage away from the house and other stmctures. 

Compaction ofthe replacement soil in areas to be vegetated will be accomplished using the 

loader bucket ofthe placement equipment to back-blade the material to the required thickness 

prior to the application of sod or seeding. Gravel or road base used as fill material for driveway 

or walkway areas will be compacted, as appropriate, using suitable equipment to avoid future 

settlement and drainage problems. Garden soils, flowerbed soils and sand for play areas will be 

placed loose and left uncompacted. 

Sprinkler systems encountered will be either excavated by hand and saved or removed 

and disposed of with other debris. Generally the sprinkler heads will be removed and saved 

along with major components such as manifolds, valves and controllers. The pipes will be 

removed and disposed. Upon backfill the pipes will be replaced and the saved or usable 

components re-installed. 

5.4.3.2 Soil Cover/Capping 

The extent of areas selected to receive soil cover will be identified in the Response 

Action Plan and Soil Remediation Site Plan. Cover soil consisting of general fill, topsoil, or 

gravel road base will be placed to a minimum depth of 6 inches or to greater depth as needed to 

match surrounding grades or to correct an identified drainage problem. The selection ofthe 

appropriate type of cover material will be based on the existing materials currently in-place and 

the property owner's/resident's preference. Decorative rock or landscape materials (i.e., 

decorative bark or mulch) will not be suitable for use as the sole cover material. Cover soil 

material will meet the general requirements identified in Section 5.4.3.7. Compaction ofthe 

cover material will be accomplished using the same procedures identified in Section 5.4.3.1 for 

replacement soils. 

5.4.3.3 Concrete and Asphah Caps 

Concrete and asphalt caps are generally constmcted in high traffic areas such as 

driveways, porches and sidewalks. The use of asphalt or concrete as a cover material will be 

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52 of 82 CRS RSO 00 DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

limited to special circumstances, which may include: situations requiring the removal of existing 

concrete or asphalt, and where removal is not practicable and the placement of concrete or 

asphalt is a more cost-effective altemative. 

Prior to placing concrete or asphalt, subgrade soils shall be excavated to the appropriate 

grade, leveled (if needed) and compacted. Ifthe existing subgrade soil is determined to be 

unsuitable (material with a high organic matter content or which may exhibit swell potential or is 

otherwise difficult to compact) by the oversight personnel, a 2- to 4-inch-thick, compacted, 

gravel road-base material may be placed to provide adequate support. 

Concrete utilized for sidewalks, walkways, or porches will be designed to achieve a 28-

day compressive strength of 3,000 pounds per square inch (psi), will include standard admixtures 

for air entrainment and will be placed with a nominal slab thickness of 4 inches. Control Joints 

will be placed approximately every 8 linear feet. Concrete utilized for driveways will be 

designed to achieve a 28-day compressive sfrength of 4,000 psi, will include standard admixtures 

for air entrainment and will be placed with a nominal slab thickness of 4 inches. Control joints 

will be placed a minimum of 15 feet in all directions. Ten-gauge, welded-wire steel fabric will 

be placed as reinforcement for crack control in driveway concrete. Concrete testing will not be 

routinely performed. 

Asphalt utilized as cover material will be a locally available, plant-mixed, asphaltic 

concrete pavement designed as a standard hot-laid roadway mix and will be placed at a nominal 

thickness of 2 inches, or greater depending on subgrade conditions. 

5.4.3.4 In-Situ Mixing 

As identified in the ROD, mixing of surficial soils having lead concentrations above 

3,500 mg/Kg with underlying unimpacted soils could be performed to reduce lead concentrations 

to acceptable levels. In-situ mixing, or deep tilling, ofthe upper 6 inches of soil may be 

performed in some situations where soil-lead concentrations in the 0 to 2 inch depth interval 

exceed 3,500 mg/Kg, lead concenfrations in underlying soils are relatively low and the weightedaverage lead concentration for the top 6 inches of soil is below 3,500 mg/kg. Properties with 

lead concentrations greater than 3,500 mg/Kg in the 6 to 12 inch depth interval are not 

considered amenable to this altemative due to the difficulty in mixing to the depths required to 

achieve a reduction in lead concenfration below the trigger level. 

Deep tilling will be performed using equipment capable of completely turning and 

mixing soil to a minimum depth of 6 inches. Tilling will be performed by making a minimum of 

two passes with the tilling equipment, in perpendicular directions, to achieve adequate soil 

mixing. Following tilling/mixing the area will be graded and prepared for vegetation 

establishment or other actions per the Response Action Plan. Verification sampling will be 

performed to ensure surficial soils are below response trigger levels. 

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^?^f«- 53 r PRS RSO 00 DSO.OO Lake County Recorder of 82 CRS RSO.OO DSO.OO 

LCCHP Phase 2 Work Plan March, 2009 

5.4.3.5 Seeding and Sod Placement 

Vegetation will be established by either seeding or sod placement only where previously 

existing vegetation was removed, and will typically be performed only after a yard area has been 

remediated (i.e., in-situ mixing, soil capping or removal and replacement) as indicated on the 

Soil Remediation Site Plan. The selection of seeding or sod placement will be based primarily 

on the pre-remediation conditions ofthe property but may also be influenced by other site 

conditions that could preclude sod application. The use of sod alone as a cover material (without 

removal or capping), while listed in the ROD as an appropriate containment option, will not 

usually be recommended due to the uncertainties with maintaining the sod in good condition. 

Prior to seeding or sod placement and in conjunction with fertilizer application, the area 

will be prepared by lightly raking or discing (to a 2-inch depth) the surface. Typically, an 

inorganic fertilizer will be applied using the following mix: nifrogen (as N), 60 lb/acre; 

phosphorous (as P2O5), 60 lb/acre; and potassium (as K2O), 30 lb/acre (i.e., N-P-K of 60-60-30). 

Altemate organic fertilizer blends may also be considered. 

Companies specializing in sod production will supply sod. The sod shall be a blend of 

grass types suitable for the growing conditions at the site. Success has been achieved in the past, 

under the Kids First Program, utilizing a blend of 60% bluegrass, 30% rye, and 10% fine fescue. 

Sod will be placed as soon as possible after delivery. Sod will be installed with tight 

seams and joints to meet with adjoining lawns, walks, fences or borders and no overlapping. The 

remediation confractor will water areas of new sod immediately after installation and will lightly 

roll the sod to achieve a good bond between the sod and soil. The property owner or resident 

will be responsible for maintaining sod once the installation and initial watering is completed. 

Maintenance includes the necessary fertilizing and watering required according to the grower's 

specifications. Information on the proper care and maintenance of sod will be provided to all 

residents receiving new sod. 

Seeding will be performed utilizing a native-grass seed mixture suitable for the growing 

conditions at the site and acceptable to the property owner/resident. Seed may be applied by dry 

broadcast, hydroseed or drill methods. If dty broadcasting is used, the surface shall be lightly 

raked following seed application. Mulch will not typically be applied for seeded yard areas. 

5.4.3.6 Surface Water Diversions 

As discussed previously, surface water diversions may be implemented as a component 

ofa soil response action, but they will not typically be the primary response action at a property. 

In some cases, diversion ditches or berms may be consfructed or culverts placed to reroute mnon from adjacent areas if necessary to protect a remedy or to prevent future contamination. 

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LCCHP Phase 2 Work Plan March, 2009 

Specific details of appropriate surface water diversions will be developed on a property-byproperty basis and will be included in the Response Action Plan and Soil Remediation Site Plan. 

5.4.3.7 Cover and Replacement Fill Requirements 

Soils used as replacement fill or cover material will be obtained from local borrow 

sources and will be tested to verify compliance with the program's "clean fill" standard. All 

sources of fill material (i.e., general fill, topsoil, or road base) will be tested to confirm that the 

concentrations of lead, arsenic and cadmium are below the standards established for the program, 

as listed on Table 5-1. The fill material will also be submitted for paste pH and gradation 

analysis for comparison to the requirements listed on Table 5-1. With respect to soil texture or 

gradation, material used for general fill or topsoil will generally be a sandy silt material with less 

than 10 percent by weight made up of material sized greater than 2 inches in diameter. Gravel 

road-base material used for driveway, walkway or other areas at the request ofthe property 

owner/resident shall generally meet the requirements ofa Class 6 (3/4-inch maximum) or Class 5 

(1.5-inch maximum) aggregate as specified by the Colorado Department of Transportation and 

will most likely be obtained from a commercially operated gravel pit. 

Gravel road base or other general fill material obtained from a commercial source will be 

sampled and tested once prior to use at any residential properties within 0U9. Fill materials 

obtained from borrow areas or other sources within the Califomia Gulch Superfund Site will be 

sampled and tested once prior to use and periodically thereafter at the minimum frequency of 

approximately one sample per 1,000 cubic yards of material used. Clean fill material may be 

stockpiled at a central location and delivered for use at individual properties as the need arises. 

When sampled, a composite sample will be collected from a stockpile or original source of fill 

material and analyzed for the parameters listed in Table 5-1. 

Composite samples representafive ofthe material in use at the time of sampling will be 

analyzed for the parameters listed in Table 5-1 in accordance with the SOP for Fill Sampling 

(Appendix A). Each fill sample will be analyzed for lead at an off-site laboratoty by USEPA 

SW-846 Method 601 OB (refer to QAP, Appendix C). In addition to lead, samples will be 

analyzed for arsenic, cadmium, pH, organic content and particle size retained on the No. 200 

sieve (>0.075 mm). Table 5-1 specifies the requirements for fill materials placed on residential 

properties. If these requirements are not met, the materials will not be used. 

For each sampled stockpile the properties receiving the material will be fracked and the 

lead concentration as well as other physical characteristics ofthe sample will be recorded in the 

property file. The lead concenfration of fill used at each property will also be recorded in the 

electronic database. 

5.4.3.8 Soil Transport and Disposal 

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LCCHP Phase 2 Work Plan March, 2009 

Excavated soil, sod and related yard debris will be transported to the LCCHP soil repository, 

as discussed in Section 6. Excavated soils will be removed from the property at the earliest 

opportunity. Transport to the soil repository will require travel on public roads, will generally be 

limited to daylight hours and will be performed in a safe and controlled manner in accordance with 

State and local rules and regulations. Loads will be kept below the upper edges ofthe tmck bed and 

moistened with a water spray, as necessaty, to minimize the dispersal of excavated soils through 

airbome emission or spillage. 

5.5 Dust Response Actions 

This section outlines the requirements and procedures common to all dust response 

actions and provides general requirements or specifications for each type of action selected. 

The general categories of action options available, other than no action, are as follows: 

• Education 

• Physical Protective Measures 

• Removal and Disposal 

The most commonly recommended and implemented dust response options, for situations 

where dust-lead concentrations exceed the trigger criterion of 2,000 mg/Kg, will be removal 

options. For the purposes ofthe LCCHP Phase 2 there are two categories of removal response 

actions. One is defined as a dust removal action and the other as a dust abatement action. A dust 

removal will typically be recommended in situations where there are no exceedances of trigger 

criteria for lead in interior paint and the paint is in good condition. A dust abatement, which 

includes some additional activities, will typically be recommended if paint is identified as a 

potential contributor to lead in dust and will always be implemented following the completion of 

a paint removal or abatement action which potentially generates lead-containing dust inside the 

home. Where dust lead levels are found between 500 and 2,000 mg/Kg, residents will also be 

informed about lead dust abatement methods. 

Educational support will always be provided to residents where lead in dust is a concem. 

Residents will be provided educational materials on how to effectively reduce lead-dust through 

cleaning activities (e.g., regular cleaning routines, wet dusting, etc.). Annual blood lead 

monitoring for young children will be sfrongly recommended. 

Physical protective measures such as sealing off unfinished attic, crawlspace or cellar 

areas, as referenced in the ROD, will not constitute a typical dust response action. These areas 

of a home are not sampled during LCCHP Phase 2 dust sampling efforts as described in Section 

4.1.3. These types of actions will be considered only in cases where the blood lead frigger has 

been exceeded in a young child who resides at the property and after all other media have been 

47 
, •j/i^noinQ-44 AM Patricia Berger 

n^^^ CRS ^Smm^ __}^^^ _ county Recorder 

LCCHP Phase 2 Work Plan March, 2009 

addressed. Specific physical protective measures to be considered will be developed and 

evaluated on a property specific basis using the results of additional investigative and sampling 

efforts. 

5.5.1 Confractor Requirements 

All personnel performing dust abatement or dust removal activities must have 

successfully completed an accredited training course for lead-based paint abatement workers, in 

accordance with Section III.B. of Regulation 19. Supervisors are required to complete an 

accredited supervisor fraining course and be certified by the State ofColorado, in accordance 

with Section III.B. of Regulation 19. Evidence of appropriate training and required certifications 

for all personnel will be kept on record with CDPHE. 

5.5.2 Site Confrols 

The following general site confrols and containment procedures will be followed during 

dust removal and dust abatement response actions. 

• Whenever dust removal/dust abatement activities are conducted, residents (especially 

children) will be asked to stay out ofthe house. If residents must stay inside the 

house during remediation, the appropriate barrier systems will be erected. 

• "Lead Hazard" waming signs will be posted at the entty to each area being treated. A 

physical barrier is required to prevent access to the work area by the resident(s). 

• The ventilation system will be tumed off during cleaning activities. 

• A State-certified supervisor is required to be on the site during work-site preparation 

and abatement activities and during post-abatement cleaning activities. 

• A site Health and Safety Plan, including a Lead Compliance Plan, will be developed 

to address worker health and safety at properties where dust removal and abatement 

actions are performed. 

• Prior to performing remediation activities, the abatement supervisor will determine 

the appropriate work-site containment level (based on the requirements specified by 

Regulation 19). The work-site containment level is based on the size ofthe area to be 

disturbed and the type of remediation activities performed. For dust abatement 

actions following a paint action, the containment established for the paint action 

(refer to Section 5.6) will be maintained during dust abatement actions. 

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• All waste generated by removal/abatement activities should be removed from the 

house and stored in a secure, locked area. Disposal will be performed as discussed in 

Section 6. 

5.5.3 Dust Removal Actions 

Dust removal response actions will be conducted to remove the lead dust accumulation 

generated by lead-containing soils and other materials that have been tracked into a residence 

from an on-site or off-site source. In general, on-site sources of lead dust come from the 

property's lead-containing soils. Dust removal for an on-site source of lead can be conducted as 

an interim control measure or after soil remediation activities have been performed. 

Dust removal actions consist of thoroughly cleaning all horizontal surfaces with the 

exception of ceilings. The detailed procedures for dust removal activities as described in 

Chapter 11, Section IV.b.2. of HUD's 1995 Guidelines for the Evaluation and Confrol of LeadBased Paint Hazards in Housing (HUD Guidelines) will be followed. All hard surfaces will be 

cleaned with a minimum of two passes with a HEPA-filter-equipped vacuum cleaner (HEPA 

vacuum) and then wet-washed with a fri-sodium phosphate (TSP) detergent and rinsed with 

clean water. Cleaning should begin with the highest horizontal surface and end with the lowest. 

Tops of windows would be cleaned first followed by tops of sashes, mullions, interior window 

sills and froughs. Areas that tend to trap dust should also be cleaned (i.e., radiators, baseboards, 

vents/registers, and all horizontal components of ventilation ducts). 

Wall-to-wall carpeting and area mgs are cleaned with a HEPA vacuum equipped with a 

beater bar or agitation attachment. Area mgs are first vacuumed on the pile side at a rate no 

faster than one (1) minute for evety 10 square feet. The rug is then folded in half, exposing the 

backing. The backing is vacuumed at the same rate as before without using the beater bar. The 

mg is unfolded and folded in half the other direction exposing the backing on the other half of 

the mg. The vacuuming procedure is repeated on the second half The top or pile side ofthe rug 

is then vacuumed again using the beater bar at a rate no faster than 2 minutes for evety 10 square 

feet. Wall-to-wall carpeting is vacuumed in two segments using the beater bar attachment. The 

two segments are in perpendicular directions. The vacuum rate is no faster than 2 minutes for 

each 10 square feet. 

After all cleaning activities have been completed, a State-certified lead-based-paint 

inspector or risk assessor will perform a visual inspection and conduct clearance sampling, as 

described in Section 5.5.6. and the SOP for Clearance Dust Sampling (Appendix A). 

5.5.4 Dust Abatement Actions 

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LCCHP Phase 2 Work Plan March, 2009 

Dust abatement actions are generally associated with lead-based-paint abatement 

activities. The procedures for dust abatement activities, as described in Chapter 14, Section V of 

the HUD Guidelines and Section V.H. of Colorado's Regulation 19, will be followed. All 

surfaces (horizontal and vertical) are cleaned during dust abatement. Procedures are generally 

the same as those for dust removal actions. Cleaning begins with the highest surface and ends 

with the lowest surface. Ceilings are cleaned first, then the tops of walls and so on working 

downward to the floor. The surfaces are first cleaned with a HEPA vacuum then wet-washed 

with TSP detergent and then rinsed with clean water. The rinsed surfaces are allowed to dty and 

one final pass is made with the HEPA vacuum. Wall-to-wall carpeting and area mgs will be 

cleaned using the same procedures outlined above for dust removal actions. After all cleaning 

activities have been completed, a State-certified inspector or risk assessor will perform a visual 

inspection that will then be followed up by clearance sampling, as described in Section 5.5.6. 

and the SOP for Clearance Dust Sampling (Appendix A). 

A dust abatement should be performed a minimum of one hour after all paint-related 

activities have ceased to let dust particles settle. All containment plastic placed prior to 

remediation activities should be misted with water and cleaned. Plastic used to isolate 

contaminated rooms from non-contaminated rooms should be left in place and are the last to be 

removed. 

5.5.5 Dust Clearance Sampling 

Following response actions to address lead-dust, samples will be collected to confirm that 

the actions performed have been effective in reducing the exposure to identified lead-dust 

hazards. A visual inspection will also be performed to confirm that all areas adjacent to the work 

area and used to access the work area are visibly free of dust, debris or residue and to confirm 

that work was conducted as specified in the Response Action Plan. The clearance samples will 

be collected from within the work area at least one hour after the completion of remediation and 

cleaning activities. Clearance dust samples are collected using the wipe method described in the 

SOP for Clearance Dust Sampling (Appendix A). 

Clearance samples will be collected by a frained and State-certified lead-based-paint 

inspector or risk assessor. One wipe sample will be collected from the floor and one from a 

windowsill, if present, in each room ofthe work area. If any paint sealants were used as part of 

the response action, then the clearance samples will be collected at least one hour after the 

sealant has dried. All clearance samples will be submitted to a National Lead Laboratoty 

Accreditation Program (NLLAP)-recognized laboratoty for analysis of lead. 

Each wipe sample must meet the following clearance levels for lead in order for work to 

be considered complete: floor samples<100 ng/ft and window samples<500 jig/ft^. Ifa 

clearance sample exceeds these levels, dust response actions will be repeated and clearance 

samples will be collected again. 

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.59 of 82 CRS RSO.OO DSO.OO Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

5.6 Interior/Exterior Paint Response Actions 

The objective ofa paint response action is to provide an appropriate level of risk 

reduction from potential exposure to lead in paint. A wide range of options may be considered 

in response to lead in paint and, as with other media responses, an appropriate action will be 

determined on a case-by-case basis considering the preferences ofthe property owner/resident. 

This section outiines the requirements and procedures common to most paint response actions 

and provides general requirements or specifications for each type of action selected. References 

are provided, as appropriate, to specific requirements contained in other guidance or regulations. 

The general categories of action options available and sub-categories are as follows: 

• Education 

• Source Confrol, Containment, or Covering 

Paint film stabilization 

Encapsulation 

Enclosure ofa painted area 

Friction and impact surface treatments 

• Paint Removal and Replacement 

Paint removal 

Because ofthe dual trigger criteria for paint, education is an important component of all paint 

response actions. In situations where paint contains lead above 1 mg/cm^ and is in poor 

condition or coating a friction surface, education will be the primaty intervention provided to 

help reduce potential risks associated with lead-based paint. In situations where paint has lead 

levels greater than 6 mg/cm^ and is in poor condition, active remediation will be recommended, 

but education will continue to play an important role in overall risk reduction. 

Active remediation may consist of one or more ofthe source confrol and paint removal 

options listed above. Several options provide risk reduction through 'source control' (i.e., 

through actions other than removal) including paint film stabilization, encapsulation, enclosure, 

and friction and impact surface freatments. Paint film stabilization is the process of applying a 

protective coating over existing lead-based paint surfaces. Encapsulation is the process of 

applying a liquid coating or adhesively bonded covering material to act as a barrier between 

lead-based paint and the environment. Enclosure is the installation ofa rigid barrier over leadbased paint surfaces in order to prevent access and exposure. The freatment of friction and 

impact surfaces by repairing, replacing or covering the affected components may also be 

implemented. Removal options consist of either removing the paint alone or the entire painted 

component (e.g., door, window, or trim). 

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LCCHP Phase 2 Work Plan March, 2009 

Certain activities or work practices, as described in Section V.B.I of Colorado's 

Regulation 19, will be prohibited for use in activities related to lead-based paint. In general 

these restricted activities include: open-flame buming or torching; dty sanding or scraping; 

machine sanding, grinding, abrasive blasting, sandblasting; drilling or cutting; and high-pressure 

water washing. Machine sanding, grinding or abrasive blasting may only be used if equipped 

with HEPA exhaust confrol devices which are capable of continually capturing all particulates 

generated. Similarly, high-pressure water washing, or hydro blasting, may only be used ifthe 

point of operation is completely self-contained and the water is captured within a local shroud. 

Chemical stripping methods will be used only to remove paint from highly decorative or ornate 

components or surfaces that are otherwise difficult to abate by any other method, and to 

acconunodate the preference ofthe homeowner. 

For properties investigated by CDPHE, paint testing and assessment results will be 

available on request to fiiture property owTiers. In addition, any information provided by 

CDPHE or the Work Group, to a property owner regarding the presence of lead-based paint must 

be disclosed to future purchasers of that property in accordance with HUD's lead-based-paint 

disclosure rules. Educational materials targeting homeowners and remodelers will provide 

relevant information about methods to reduce exposure to lead from lead-based paint in the 

home (refer to Section 3.3 above). 

5.6.1 Confractor Requirements 

All personnel performing lead-based paint remediation activities must have successfully 

completed an accredited training course for lead-based paint abatement workers, in accordance 

with Regulation 19. Supervisors are required to complete the accredited supervisor training and 

be certified by the State ofColorado as described in Section III.B. of Regulation 19. Evidence of 

appropriate training and required certifications for all personnel will be kept on record with 

CDPHE. Personnel performing work not directly involved in lead-based paint abatement (e.g., 

the installation of enclosures or the replacement of building components) must be skilled in their 

respective frade but will not be required to have specific training for lead-based paint activities. 

A State-certified lead-based paint abatement supervisor will supervise such personnel. 

5.6.2 Site Confrols and Containment Procedures 

This section addresses general site confrols and containment procedures that will be 

implemented prior to and during paint abatement activities. 

As part ofthe Response Action Plan for response actions addressing lead-based paint, 

measures to be taken during the response action to protect the residents from exposure to any 

lead-based paint hazards will be identified, consistent with the requirements of an "Occupant 

Protection Plan," described in Section V.A.6 of Regulation 19. At a minimum, residents will be 

required to stay out of work and containment areas and asked to stay out ofthe house during 

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61 of 82 CRS RSO 00 DSO.OO Lake County Recorder 

LCCHP Phase 2 Work P\sm March, 2009 

active operations. The need for temporaty relocation ofthe residents during interior paint 

response actions will be considered on a case-by-case basis, depending on the area ofthe home 

affected by activities, the level of containment required, the anticipated duration of activities, and 

the preferences ofthe residents. 

Prior to performing remediation activities, the abatement supervisor will determine the 

appropriate worksite containment level based on the type of activities to be performed, the size 

ofthe area affected, and other requirements specified by Regulation 19. The appropriate level of 

containment will be selected in accordance with the following sections of Regulation 19: 

Section V.C. for interior abatement (excluding window abatements); Section V.D. for exterior 

abatement; and Section V.E. for window abatements. In general, the containment activities 

addressed will include the following items: 

1. Waming Signs 

2. Waming Barriers 

3. Ventilation System Shutdown (interior abatements only) 

4. Protection of Objects 

5. Floor or Ground Protection 

6. Cleanup Activities 

7. Special Work Area Egress Requirements (if any) 

8. Conditions Requiring the Use of a Negative Air Flow Machine 

The integrity of all containment systems will be inspected regularly and maintained to 

prevent the potential spread of lead contamination outside the work area. In the event ofa 

breach or malfunction ofany containment component, appropriate measures will be taken to 

remedy the situation and the area potentially contaminated will be cleaned in accordance with 

the procedures described in Section 5.5.4 ofthis work plan as soon as the condition is observed. 

A State-certified lead-abatement supervisor is required to be on site during remediation 

activities. The abatement supervisor will ensure that work is conducted in accordance with the 

Health and Safety Plan and Lead Compliance Plan developed for the project. Oversight will be 

performed by CDPHE or their representative,certified as an inspector or risk assessor to monitor 

the performance ofthe work in accordance with the Response Action Plan and applicable 

provisions of Regulation 19. 

During remediation or abatement activities, all horizontal surfaces in the work area will 

be cleaned of visible dust and debris prior to ceasing work each day. Following the completion 

of activities, dust abatement will be performed as described in Section 5.5.4 ofthis work plan 

and in accordance with Section V.H, of Regulation 19. Waste generated by remediation 

activities will be handled in accordance with Section V.K. of Regulation 19. In general, leadcontaminated waste will be wrapped and sealed in 6-mil polyethylene sheeting prior to removing 

the waste from the work area and will be stored in a covered container in a locked area if not 

fransported off-site immediately for disposal. Disposal activities are addressed in Section 6. 

53 
•^5^Qm 3'16/2ni0 9:44AM Patricia Berger 

^ir'fs- 62" r rR-? RSn on DSO.OO Lake County Recorder of 82 CRS RSO.OO DSO.OO 

LCCHP Phase 2 Work Plan March, 2009 

5.6.3 Interior/Exterior Paint Remediation Procedures 

Lead-based paint response actions utilize the same basic techniques for performing both 

interior and exterior remediation. Following are general procedures for each type of remedial 

response listed above in Section 5.6. 

5.6.3.1 Education 

When lead-based paint is present, CDPHE will provide educational materials to the 

property owner and current residents (if different) to explain the risks related to lead-based paint 

and ways to reduce exposure to lead originating from lead-based paint. Relevant educational 

materials provided by CDPHE may include USEPA publications such as: Reducing Lead 

Hazards When Remodeling Your Home (USEPA, 1994) and Protect Your Family from Lead in 

Your Home (USEPA, 1999a). At the same time that educational materials are provided, LCCHP 

staff will explain risks and methods to reduce those risks to the family. 

In addition, before starting any response actions that are likely to disturb lead-based paint, 

the owner and/or residents will be informed ofthe dangers associated with these types of activities 

due to the potential for increased exposure during these activities. 

5.6.3.2 Source Control, Containment, or Covering 

This section describes the general procedures and references relevant specific regulations 

and guidelines for source control actions, including paint film stabilization, encapsulation, 

enclosure, and friction and impact surface freatments. 

Paint Film Stabilization 

Paint film stabilization is the process of painting over existing lead-based painted 

surfaces with a non-toxic, protective coating and will be performed in accordance with Section 

V.I.I of Regulation 19. The types of finish coats to be used for lead-based paint stabilization 

include varnish, actylic latex, polyurethane and deck enamel. Prior to coating, the substrate will 

be inspected and items such as loose wall or ceiling plaster, loose trim or wallpaper, missing 

hinges or doorknobs, etc. should be repaired or replaced. In addition, the source ofany water 

damage should be identified and repaired. All surfaces will be prepared, as necessaty, to help 

ensure adequate adhesion or bonding. Steps to be taken to prepare the surface may include: (1) 

removing all loose surface material by wet scraping or wet sanding; (2) removing all surface 

contaminants that will reduce the adhesion ofthe paint with degreasers or detergents; (3) freating 

(roughening) glossy surfaces by wet sanding, HEPA-vacuum-assisted sanding or chemical 

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Patricia Berger 

Lake County Recorder 

LCCHP Phase 2 Work Plan March, 2009 

etching; and (4) enhancing substrate adhesion by chemical etching, wet sanding, spot sealing and 

applying mst inhibitors. After the affected surface has been prepared for painting, it will be 

vacuumed with a HEPA-filter-equipped vacuum cleaner to eliminate any lead dust. To 

maximize the life ofthe paint cover, a system of compatible coatings is necessaty. In selecting 

an appropriate coating or paint, the following factors will be considered; the type of subsfrate 

involved, type ofthe existing subsfrate coating, type of primer to be used, whether it will be 

applied inside or outside and the type of topcoat. 

Encapsulation 

Encapsulation is a process that makes lead-based paint inaccessible by providing a barrier 

between the lead paint and the environment. The requirements for encapsulation systems 

provided in Section V.G. of Regulation 19 will be followed. The barrier is formed using a 

reinforced or non-reinforced liquid-applied coating (e.g., LeadMaster, L-B-C Lead Barrier 

Compound and Insl-Cap Lead Encapsulating Compound) or an adhesively bonded covering 

material (e.g., sheet vinyl systems, floor tile, wall systems and other adhesively bonded systems). 

Liquid encapsulants are usually applied with bmshes, rollers, sprayers or frowels. Only surfaces 

with non-deteriorated subsfrates may be considered for encapsulation. Deteriorated 

components or paint films (i.e., rotten wood, rusted steel, spalled plaster, masonty in need of 

repainting, and areas that are subject to moisture problems) are not recommended for 

encapsulation. Friction surfaces, such as window jambs, interior floors, exterior wood flooring 

and stairs, are also unsuitable for encapsulation. The surface preparation procedures described 

above for paint film stabilization will be performed prior to applying an encapsulant. 

Because most lead-based paint films are made up of many paint layers, a measure of how 

well these layers adhere to each other and to the base subsfrate will be a good indicator of 

whether or not the surface should be encapsulated. The paint film must demonsfrate adequate 

adhesion between the layers and to the substrate, as determined by a certified inspector, using 

appropriate methods in accordance with HUD Guidelines. 

To determine whether or not an existing painted surface is a viable candidate for 

encapsulation and to determine the proper encapsulant, a "patch test" will be perfonned. A 

patch test is a field test procedure in which a small area ofthe existing lead-based paint surface is 

prepared and the encapsulant applied. At least one patch test should be performed for each type 

of component in each room or exterior location where the encapsulant is to be used. Patch tests 

should also be performed on those surfaces that are the most likely to fail. For instance, patch 

tests should be performed in areas that have been identified with potential adhesion problems 

due to moisture or on load-bearing walls because they are subject to higher stresses. 

In general, encapsulants must not be applied over dirt, rust, oil, grease, mildew, chalk or 

other surface contaminants. The painted surface should be cleaned with a tri-sodium phosphate 

(TSP) detergent. After washing, the surface is rinsed with clean water. Some lead-based paint 

films are glossy and should be deglossed to improve adhesion with the selected encapsulant. 

Special deglossing materials are usually suggested by the encapsulant manufacturer. In some 

cases, wet sanding may be the only effective method of deglossing. All loose paint should be 

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LCCHP Phase 2 Work Plan March, 2009 

removed from the surface by wet-scraping. The area prepared for the patch test should be at 

least 2 inches larger in each direction than the area to be encapsulated for the test. For liquidapplied encapsulants, a patch test will be conducted on a 6-inch by 6-inch area on one wall of 

each room being freated unless it is has been established that both rooms have the same paint 

histoty. For fiber-reinforced encapsulants, a smaller 3-inch by 3-inch area may be used. After 

the surface has been prepared, the encapsulant is applied and cured according to the 

manufacturer's recommendations. After the encapsulant has cured, the patch is examined for 

adhesion and compatibility with the existing lead-based paint. There are a number of tests that 

may be employed to evaluate encapsulant adhesion, as described in Chapter 13, Section V.I.C of 

the HUD Guidelines, including the X-Cut Adhesion Method, the Patch Edge Method or the 

Soundness Method. The decision to proceed with an encapsulation response action and selection 

ofthe encapsulant may depend on the results of such a patch test. 

Enclosure 

Enclosure is the installation of a rigid, durable barrier that is mechanically attached to 

building components. Surfaces with lead-based paint are enclosed in order to prevent access and 

exposure and to provide a "dust-tight" system. Enclosure is normally implemented for large 

surfaces such as walls, ceilings, floors and siding. Enclosure systems will be installed following 

the procedures presented in Section V.G. of Regulation 19 and Chapter 12, Section III ofthe 

HUD Guidelines. 

All unsound subsfrates and structural members that will support the enclosure will be 

repaired prior to constmcting the enclosure. All lead-based painted surfaces to be enclosed will 

be labeled with waming signs ("Danger: Lead-Based Paint") evety 2 feet, both vertically and 

horizontally. A drawing ofthe building's floor plan that shows where the lead-based paint has 

been enclosed will be prepared and included with the Property Documentation Report provided 

to the property owner. A copy ofthis drawing, covered with plastic, will be placed within the 

building in an easily accessible area such as a utility room or closet. 

The following materials can be used to constmct interior surface enclosures: wood 

paneling, gypsum drywall/fiberboard and certain types of laminated wall sheeting products. 

Wood paneling is commonly used for wall enclosures but cannot be used for ceiling enclosures. 

There should be no gaps in seams, around outlets, boxes and registers, All seams should be 

caulked. Drywall/fiberboard may be used for wall and ceiling enclosures. The drywall is 

usually glued directly onto the affected surface with constmction adhesives and then 

mechanically fastened to the studs or stmcture behind the plaster. All joints will be taped and 

sealed with joint compound. In areas where moisture is a problem, moisture-resistant dtywall 

should be installed. Wherever the dtywall meets wood framing or any other finish material, the 

seams should be sealed with caulk or other sealant. 

Lead-based painted floors should be enclosed with 14-inch-thick or thicker plywood (or 

other underlayment). The plywood is then covered with the desired floor covering. Wooden 

steps with lead-based paint should be completely covered with vinyl or mbber freads and risers. 

Painted pipes can be enclosed with the same kind of tape that is used to make plaster casts. The 

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LCCHP Phase 2 Work Plan March, 2009 

wrapped tape should overlap itself so that it is not dependent on adhering to the painted surface. 

Frame covers may be used to enclose both wood and metal doors. 

The following materials can be used to constmct exterior surface enclosures: vinyl or 

aluminum siding, board products made of synthetic fiberboard or wood composites, natural or 

synthetic brick and stone veneers and stucco. Vinyl or aluminum siding may be used to enclose 

exterior painted surfaces. Any defective substrates must be repaired or replaced prior to 

attaching siding. Siding may not provide an airtight enclosure; to ensure that dust doesn't "leak" 

through enclosure systems, a breathable cloth material such as Tyvek (or an equivalent material) 

can be installed prior to placing siding. Aluminum coil stock can be used to cover soffits, facia, 

decorative crown molding, door and window frames, parapets and other moldings. 

All enclosures should be designed to be dust-tight for at least 20 years. All crevices, 

holes, seams, edges, joints and cracks shall be caulked. The underside of all enclosures shall be 

back-caulked to fiirther prevent leaded dust and lead residues from escaping the abated surface. 

Friction and Impact Surface Treatment 

Friction surfaces are those surfaces usually subjected to abrasion, which creates the 

potential to generate dust from lead-based painted surfaces. Common friction surfaces include 

parts ofa window that are rubbed when the window is opened and closed, tight-fitting doors, 

cabinet doors, drawers, stairway freads, and railings. Floors may also be considered friction 

surfaces, however, the methods described in this section typically apply only to the components 

listed above. 

Impact surfaces are those that protmde outward and tend to be bumped and banged. The 

most common impact surfaces are doors, doorjambs, door trim, door stops, outside comers of 

walls, baseboards, shoe moldings, stair risers and chair-rail moldings. 

Subject to the preferences ofthe property owner and an evaluation of cost, the most 

effective option may be to remove and replace the friction or impact component or to perform a 

paint removal. Ifthe components or paint are removed, the procedures described below in 

Section 5.6.3.3 will be followed. However in some cases, friction or impact surfaces may be 

covered/enclosed, or otherwise treated, to adequately eliminate or control potential dust 

generation caused by abrasion. For window systems, it is possible to install replacement window 

channels or slides made of aluminum, vinyl and polyvinyl chloride (PVC). These components 

will be back-caulked and nailed into place to provide an adequate seal. For door systems, where 

the door mbs or sticks, the simplest solution is to remove the door and plane down all friction 

points using appropriate dust-control methods (e.g., wet methods or HEPA-filter-equipped 

tools). Installation of mbber tread guards, carpet or tile is recommended to lessen the fViction on 

stair freads, provided that the lead-based paint is in good condition or is adequately sealed or 

encapsulated. 

5.6.3.3 Paint Removal and Replacement 

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LCCHP Phase 2 Work Plan March, 2009 

This section describes the general procedures and references relevant specific regulations 

and guidelines for removal and replacement actions, including paint removal and painted 

component removal. 

Paint Removal 

Paint removal involves separating the lead-based paint from the substrate using heat 

guns, chemicals or certain contained abrasive measures. Paint removal must be conducted using 

appropriate methods and confrol technologies, as described in Secfion V.B. of Regulation 19 and 

Chapter 12, Section FV ofthe HUD Guidelines, to contain particulate matter and dust which may 

be generated. 

Removing lead-based paint with a heat gun works well on wood surfaces but will usually 

damage dtywall and plaster surfaces. Heat guns should be operated at a maximum heat setting 

of 1,100 degrees Fahrenheit. For most heat guns, the optimal distance from the end ofthe heat 

gun to the working surface is 3 to 6 inches. Heat should be applied to just soften the paint, not 

allowing the paint film to scorch or smoke. At the vety first sign of paint softening, blistering or 

bubbling, the use ofthe heat gun will be discontinued and the loose paint will be scraped off the 

surface. When performing lead-based paint removal with a heat gun, a fully charged, ABC-tj^je, 

20-pound fire extinguisher must be available within 100 feet ofthe work area. Abatement 

personnel are required to wear powered air-purifying respirators with HEPA-filtered cartridges 

and organic-vapor cartridges when performing abatement activities with a heat gun. 

Paint may be removed from most surfaces by wet scraping. Wet scraping can be 

accomplished by using a spray bottle or sponge attached to a paint scraper. The surface may also 

be misted with water and scraped with a putty knife or similar instmment. Wet scraping is 

generally used to remove flaking paint prior to paint-film stabilization or encapsulation. Wet 

scraping will not be performed around live elecfrical circuits/outlets. If elecfrical outlets are 

present within a building component to be removed, the circuits must be tumed off and 

disconnected prior to wet-misting. Dry scraping of lead-based paint is allowed only when 

working with heat guns. 

HEPA sanding uses traditional electric sanders (disc, orbital or vibrating sanders) 

equipped with a specially designed containment system that is placed under a partial vacuum. 

All exhaust air is passed through a HEPA filter to reduce the amount of airbome lead dust and 

particulates. 

As discussed previously, chemical stripping methods shall only be used to remove lead-based 

paint from highly decorative or omate components or surfaces that are otherwise difficult to 

abate by any other method. If chemical removal is the desired action, on-site or off-site paint 

stripping may be performed. 

General procedures for using chemical removers are as follows. The paint remover is 

applied with a spatula, trowel or brush and allowed to sit for the required period of time 

following all manufacturers' directions. The remover should not be allowed to dty out during 

this process. After waiting the required period of time, the softened paint is removed with a 

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scraper or putty knife and deposited into a watertight and corrosion-proof container. The waste 

will be disposed of in accordance with Section 6.2 ofthis work plan. The sfripped surface is 

then thoroughly cleaned to remove lead and paint-remover residues. The freated surfaces must 

then undergo a neufralization process (this must be accomplished immediately for wood surfaces 

before they dty out). After the neutralization process, the damp surface is cleaned with a highphosphate detergent or cleaner and followed up with a clean water rinse. Ifthe rinse water 

exhibits a pH greater than 8, the neufralization process should be repeated. After neutralization 

is achieved, the surface may be repainted. Surfaces that have undergone the removal process 

should be repainted using latex paint only. Cleanup and clearance sampling are performed after 

removal activities. When using chemical paint removers: (1) products that contain methylene 

chloride will be avoided and (2) a portable eyewash station capable of providing a 15-minute 

flow will be available on site. Personal protective equipment required for this method includes 

chemically resistant clothing; long neoprene, nifrile, mbber or PVC gloves; and face shields. 

Off-site stripping may be performed, provided that the off-site stripper is qualified to 

handle lead-based paint. For off-site stripping, the component will be removed and tagged to 

indicate its original location within the house, wrapped in 6-mil plastic and sent to the off-site 

sfripping location. The freated item should be cleaned using a HEPA vacuum, washed with a 

phosphate-containing detergent, allowed to dty and cleaned again with the HEPA vacuum prior 

to replacement. 

Removal and Replacement ofa Building Component 

Component replacement may involve the removal of items such as doors, windows, frim, 

baseboards, chair-rail molding, exterior fascia, soffits, shutters, crown moldings and other 

components that represent lead-based-paint hazards. All replacement components shall be free 

of lead-based paint. 

The building component to be removed will be misted with water to minimize the amount 

of lead dust generated during removal activities. Frequent vacuuming with a HEPA-filterequipped vacuum cleaner is recommended during the removal process. 

After removal, the component will be wrapped in 6-mil plastic and sealed with tape. 

Smaller debris generated by replacement activities will be wet-misted and placed into 6-mil 

plastic bags and sealed with tape. Waste management and disposal will be performed as outlined 

in Section 6.2, Lead-Based Paint, Dust and Associated Debris. 

5.6,4 Interior Paint Clearance Sampling 

As discussed previously, all interior paint response actions will be followed by dust 

abatement as described in Section 5.5.4 to meet the cleaning requirements of Section V.H. of 

Regulation 19. Both a visual clearance inspection and clearance sampling will be performed 

following response actions for interior paint and subsequent dust abatement. The final visual 

inspection will be performed to confirm the completion of paint abatement and subsequent 

cleaning activities and to confirm that work was conducted as specified in the Response Action 

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LCCHP Phase 2 Work Plan March, 2009 

Plan. A certified inspector or risk assessor for lead-based paint activities will perform the 

inspection. The work area and adjacent areas used for access to the work area will be inspected 

to identify the remains ofany deteriorated paint, visible dust and/or debris. If problems are 

noted during the visual inspection, clearance sampling will be postponed until additional 

cleaning has been performed. 

Because component and paint removal and replacement and/or encapsulation activities 

can create dust containing lead-based paint, dust samples will be used for clearance sampling 

after paint actions. The clearance samples will be collected using the same wipe methods as 

used for clearance sampling following dust confrol and abatement actions, as described in 

Section 5.5.4 and in the SOP for Dust Clearance Sampling (Appendix A). One wipe sample will 

be collected from the floor and one from a windowsill, if present, in each room ofthe work area. 

If any paint sealants were used as part ofthe response action, then the clearance samples will be 

collected at least one hour after the sealant has dried. All clearance samples will be submitted to 

an NLLAP-recognized laboratoty for analysis of lead. 

Each wipe sample must meet the following clearance levels for lead in order for work to 

be considered complete: floor samples less than 100 fig/ft^ and window samples less than 500 

^g/fl^. Ifthe results ofthe clearance sampling exceed these levels, dust abatement procedures 

will be repeated and clearance samples will be collected again. 

5.6.5 Exterior Paint Clearance Sampling 

Following exterior paint abatement actions, both visual inspection and clearance 

sampling will be performed. Clearance samples will include dust wipe samples and soil samples 

which will be collected in accordance with the SOPs for Clearance Dust Sampling and Clearance 

Soil Sampling (Appendix A), respectively. 

The clearance dust samples will be collected using the wipe method. A minimum of two 

clearance samples will be collected from the work area. One sample will be collected from an 

exterior windowsill and one from a hard surface such as a patio, walkway, or deck, if present, 

within the work area. The wipe samples will be submitted to an NLLAP-recognized laboratoty 

for lead analysis. 

Each wipe sample must meet the following clearance levels for lead in order for work to 

be considered complete: exterior window sill samples less than 500 ng/ft^ and exterior surface 

samples less than 800 ^g/ft^. Ifthe result for a clearance sample exceeds these levels, additional 

cleaning will be performed and clearance samples will be collected again. 

Clearance soil samples will also be collected. Whenever an exterior paint response 

action is taken, soil samples will be collected both prior to and following that action to confirm 

that the response action does not result in higher lead concenfrations in soil around the work 

area. Both the pre-abatement and post-abatement soil samples will be taken using procedures 

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that are consistent with Colorado's Regulation 19, as described in Section V.J.I.e.(2) and the 

SOP for Clearance Soil Sampling (Appendix A). 

At least one pre-abatement soil sample will be collected from the planned work area by 

obtaining a composite sample consisting of at least 5 and no more than 10 subsamples collected 

along the building perimeter/dripline within the designated work area. The lead concenfration in 

the pre-abatement soil sample will be used as the basis for comparison with the post-abatement 

samples. The post-abatement samples will be collected following completion of all paint 

abatement and associated clean-up activities. At least two post-abatement soil samples will be 

collected from within the designated work area by obtaining composite samples of at least 5 and 

no more than 10 subsamples collected along the building perimeter/dripline. Both pre- and 

post-abatement samples will be analyzed for lead by an NLLAP-recognized laboratoty. 

The exterior abatement work will be considered complete when the lead concentration of 

the post-abatement soil is less than or equal to the lead concenfration ofthe pre-abatement soil. 

Ifthe soil clearance level is not met, then a response action to address the residual lead level in 

soil may be required. Any response action taken to address residual lead levels in 

dripline/foundation soils will be in accordance with Section V.F. of Regulation 19. 

5.6.6 Soil Response Actions Related to Exterior Paint Action 

Ifthe results of soil sampling performed following an exterior paint response action 

indicate an increased soil-lead concentration, soil abatement will be performed in accordance 

with Section V.F of Regulation 19. 

5.7 Maintenance and Follow Up 

At the completion of response actions, property owners and current residents will be 

provided with instmctions for maintaining components ofthe remedy such as sod areas, 

landscaping, paint encapsulants, etc. The maintenance activities associated with each response 

action will be fully explained to the property owner (and resident, when appropriate) during 

discussion of recommended actions and upon completion ofthe selected action. The oversight 

representative for CDPHE will retum approximately I year after remediation to evaluate the 

condition ofany lawn, landscaping, concrete, asphalt or architectural/stmctural components 

placed or freated during the original response action(s). Remedies may also be re-evaluated as 

part of EPA's Five Year Reviews ofthe Califomia Gulch Superfund Site. 

If this inspection reveals that placement of sod or grass was not successful (i.e., plant 

materials did not survive) due to circumstances beyond the control ofthe property owner or 

resident, the program will have them replaced. If such placement was not successful due to 

neglect (e.g., lack of water) or as a result of damage caused by any other person (e.g., vehicle 

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LCCHP Phase 2 Work Plan March. 2009 

traffic), the program will not repair the damage or be held responsible. Any drainage problems 

and associated prcperty damage that resulted from remediation activities will also be corrected at 

this time. If any concrete or asphalt component placed during a response action exhibits 

excessive cracking or requires repair due to inadequate quality control procedures during 

placement, the program will repair or replace the defective areas. The program will also repair 

or replace damaged architectural or stmctural components if it is detennined that they were not 

properly installed or treated during the response action. 

5.8 Temporary Work Stoppages 

If conditions are encountered which are beyond the control ofthe remediation contractor 

that delay or prevent the implementation of response actions, the contractor will stop work and 

immediately inform CDPHE who will, in tum, inform the property owner. These conditions 

include: 

• Artesian wells or other subsurface flow phenomena; 

• Residential building or stmctural impairments; 

• Unknown utilities or subsurface features such as abandoned septic systems or utility 

lines; 

• Any significant archaeological findings; and 

• Any unforeseen conditions within the home, which may affect the completion ofa 

paint response action such as building code violations or unsound stmctural 

condhions. 

These conditions will be evaluated and those within the confrol of CDPHE will be remedied as 

soon as possible to allow activities to resume at the property. Stmctural conditions or obvious 

building code violations discovered during remediation will be the responsibility ofthe 

individual property owner to resolve prior to resuming remediation. 

5.9 Decontamination 

Heavy equipment and tools used in the remediation process will be decontaminated prior 

to leaving the work area site. Decontamination will first involve a bmsh down of remediation 

equipment in the yard to remove visible accumulation from body and tires. Use of water will be 

avoided whenever possible. Water will be used if visible contamination is evident after dty 

bmshing and prior to moving equipment from the site for any reason. In these cases, equipment 

will be washed while on the premises to minimize the migration of mud and water to the sfreets. 

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Workers will be required to decontaminate daily or whenever leaving a site where soil 

removal activities are being performed. Personal decontamination protocols will be included in 

the site Health and Safety Plan and instituted by the remediation contractor's site manager. 

Sfreets, rights-of-way and access routes shall be cleaned of noticeable accumulations of soil, 

dust, or debris that are atfrlbutable to yard remediation activities. 

5.11 Site Inspection 

Once the response action(s) and any associated repairs are completed and all disputes 

associated with the actions are resolved, CDPHE will inspect the site with the property owners. 

At this inspection, the Soil Remediation Site Plan will be finalized and the property 

owners/residents will be asked for their sign-off, attesting that the work was performed as 

agreed. For soil response actions, the final signed Site Plan (as-built) will be included as an 

attachment to the Property Documentation Report. 

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6.0 WASTE MANAGEMENT AND DISPOSAL 

Waste materials generated during implementation ofthe LCCHP Phase 2, whether 

hazardous or non-hazardous, will be disposed of in accordance with all Federal, State and local 

regulations and guidelines. The types of waste materials generated may include excavated 

contaminated soil, lead-based paint debris and other constmction, demolition and investigationderived wastes. 

6.1 Residential Soil Repository 

Soil, landscape materials and vegetation removed from residential yards and properties 

shown to contain lead at concenfrations greater than 3500 mg/Kg (based on the results of 

investigative sampling) will be consolidated in the residential soil repositoty. The details ofthe 

residential soil repositoty will be contained in a separate repositoty plan document. 

6.2 Lead-Based Paint, Dust and Associated Debris 

Current USEPA policy (USEPA, 2000) allows for management and disposal of leadbased paint debris generated by residents and confractors as "household waste". Under 40 CFR 

261.4(l3)(I) household wastes are excluded from the hazardous waste management requirements 

ofthe Resource Conservation and Recovety Act (RCRA) and can be disposed in a municipal 

solid-waste landfill. Wastes generated by the LCCHP Phase 2 containing lead-based paint and 

other wastes associated with lead-based paint activities, including disposable cleaning 

equipment, containment materials and personal protective clothing, will be disposed as 

household wastes. These types of wastes will be managed prior to disposal as follows: 

• Wooden components coated wholly or in part by lead-based paint will be wrapped in 

6-mil polyethylene sheeting and sealed prior to removing the waste from the 

containment or work area. 

• Other wastes will be managed using safe work practices for lead-based paint debris. 

Lead-based paint debris and associated materials generated by the LCCHP Phase 2 will 

be disposed in the Lake County solid-waste landfill. 

Wastes generated as part ofa dust response action are also considered household wastes 

and may be disposed of in a municipal solid-waste landfill. These wastes may include HEPAvacuum waste, plastic sheeting, tape and other materials used for containment during response 

actions, wash water, rags, sponges, mops, disposable work clothes and respirator filter cartridges. 

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7.0 DATA MANAGEMENT 

Data collected by the blood lead monitoring and environmental testing programs are used 

to evaluate the performance ofthe program. Blood lead and environmental testing data will 

remain accessible beyond active implementation ofthe LCCHP Phase 2. Both hard-copy record 

keeping and electronic data management systems will be operated and maintained as part ofthe 

LCCHP Phase 2. Data management will require coordination with the Lake County Public 

Health Agency, Lake County Building/Land Use Department and Assessor's Office. CDPHE 

will have primaty responsibility for maintenance of records describing the results of 

environmental investigations and response actions at individual properties, with copies being 

maintained at the Lake County Building and Land Use Department. Lake County maintains 

information regarding property ownership through the Lake County Assessor's Office. The 

Lake County Public Health Agency maintains blood lead data and will be responsible for 

maintaining the existing LCCHP database to facilitate linkage of property and blood lead data. 

The Lake County Land Use Department maintains their own records regarding property 

descriptions and area zoning but relies on records maintained by CDPHE for information 

regarding environmental sampling and remediation status of individual properties. 

The elecfronic database is the primaty tool for fracking properties and their remediation 

status and serves the following data management needs for the program: 

store blood lead data for numerous children and for multiple test results; 

store environmental test results for individual properties; 

link paired blood-lead and environmental test results for individual residents; 

maintain integrity of existing and future data; 

protect confidentiality of blood lead data; 

allow generation of output reports in usable formats; 

integrate Assessor's Office information for individual properties; 

provide for accurate and efficient import or input of data; 

allow flexibility in data export and retrieval; and 

provide readily accessible data for reference by Land Use Department. 

provide readily accessible data to CDPHE and EPA for program oversight purposes. 

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LCCHP Phase 2 Work Plan March, 2009 

The primaty function ofthe electronic database will be to efficiently store data collected 

by the LCCHP Phase 2 and to maintain that data in a readily accessible and usable format. The 

elecfronic database will include the following minimum information, by property: address and 

ownership, area designation within the Site, dates and results of all environmental testing, 

decisions regarding the need for remediation and dates of those decisions, response actions taken 

and dates completed. For all families participating in the LCCHP Phase 2, elecfronic data will 

also include, at a minimum: family name and residence, number and ages of children in family; 

date of entty into program and any blood lead test results and dates of tests for each participant. 

The property files will include all ofthe information stored elecfronically but will also 

manage other records such as laboratoty data reports and quality assurance documentation; 

relevant conespondence with property owners, residents and regulatoty agencies; family 

questionnaires; photographs ofthe property; field notes, design drawings; Site Plans; Response 

Action Plans; and final Property Documentation Reports. A file structure for each property is 

provided in Table 8-1. The hard-copy property files will be maintained for the life span ofthe 

LCCHP Phase 2 and will either be stored in perpetuity thereafter or otherwise recorded, with 

appropriate technology (e.g., microfilm, scan to CD, etc.), for long-term storage. Archived files 

for properties where remediation work has been completed may be moved to a Lake County 

records center. 

The LCCHP Phase 2 database is used to store and frack all property, environmental, 

family and blood lead data collected. The electronic database may be modified or improved as 

necessaty at any time during implementation ofthe LCCHP Phase 2, subject to review and 

concurrence by CDPHE and EPA. Elecfronic data will be updated and maintained for the life 

span ofthe LCCHP Phase 2. Database maintenance will include routine backup and systematic 

error checking, as described in Appendix F. 

The database cunentiy works from a Microsoft Access® file whose stmcture is described 

in detail in Appendix F. The Lake County Public Health Agency maintains the blood lead 

database that includes information about individual families and children. Lake County will 

continue to maintain the existing database that includes property ownership records and links 

residents to properties. This design ensures the confidentiality of un-released blood lead tests 

but maximizes the amount of elecfronic information available for use by the Health Department 

and Lake County. 

7.1 Data Import/Entry 

New information will be entered into the database on an ongoing basis using a 

combination of methods. Property address and ownership information will be obtained in 

electronic format from the Lake County Assessor's Office and transmitted electronically for 

import to the database. New blood lead test results, environmental sampling resuhs and 

questionnaire responses will generally be input by hand using a series of data entty screens. The 

data entty screens are designed to facilitate efficient, accurate and consistent data enfry and 

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include pull-down lists of valid entries for many ofthe data fields. All manual data enfries will 

be reviewed and checked to ensure accuracy. Quality confrol procedures for data entty, review 

and conections will be established by Lake County Public Health Agency for their intemai use. 

Enfries that have been checked will be distinguished from those that have not, and only those 

enfries that have been reviewed and verified will be considered usable by the LCCHP Phase 2. 

7.2 Data Export and Transfer 

Data stored in the electronic database may be refrieved using pre-designed refrieval forms 

and reports or through custom queries and reports developed by a data user. Using the data 

refrieval forms developed for the database, a user may generate reports for specific properties, 

such as the Property Summaty Table, or specific time frames, such as annual Blood Lead Data 

reports. 

Although two separate databases are maintained in two separate locations, the database 

has been designed to allow electronic fransfer of information from one database to the other. 

The transfer functions ofthe database have been preprogrammed to allow for exchange of nonconfidential data, such as property and family information, while preserving the confidentiality 

of unreleased blood lead test results. Confidential data are tracked by the database and automated 

retrieval and transfer functions are designed to maintain confidentiality, as necessaty for the 

various data users. 

7.3 Database Reports 

A number of reports will be routinely generated from the electronic database to assist in 

reviewing resuhs, managing various LCCHP Phase 2 elements and tracking progress at 

individual properties or for individual participants. For each property with environmental 

investigation results, a Property Summaty Table report will be generated. The Property 

Summaty Table will be used to report environmental testing results property owner and 

residents, A hard copy ofthe table will be included in the property file maintained by Lake 

County. 

The database will also be used to periodically generate the Master Summaty Table. This 

summaty report provides information about the investigation and remediation status at each 

participating property. The Master Summaty Table is primarily a tool for the LCCHP Phase 2 

Work Group to use in tracking remediation progress and may also be used by the Lake County 

Land Use Department in identifying properties investigated and/or remediated through the 

LCCHP Phase 2 (or the preceding LCCHP). 

The Lake County Public Health Agency will be able to generate a series of reports to 

summarize blood lead test results for the Site, periodically review results from various areas 

within the Site and frack retest schedules and results for children who require ongoing 

monitoring. The Lake County Public Health Agency will also use the report generator to 

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compile summaty statistics that describe population blood lead levels for specified time frames 

or areas ofthe site. Summaty statistics will be available to Lake County, EPA, and CDPHE for 

use in evaluating the performance ofthe LCCHP Phase 2. In addition, the database will be made 

available to CDPHE for periodic program review and oversight. CDPHE will make a written 

request to Lake County for any database updates, accompanied by a signed confidentiality 

statement for blood lead data. The database will also be available to EPA during its five-year 

review process, subject to appropriate confidentiality protections. 

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8.0 PROGRAM REVIEW AND EVALUATION 

The LCCHP Phase 2 is transitioning to an opwration and maintenance program. During 

the next scheduled five-year review, cunentiy scheduled for September 2012, the parties will 

evaluate the need to modify to LCCHP Phase 2. The community education, blood lead testing, 

and clinical management portions ofthe program will be operated by the County, with the 

environmental testing and remediation components ofthe program being performed by CDPHE. 

At any time, the parties can agree for the County to assume this portion ofthe program and 

become completely responsible for the operation ofthe LCCHP Phase 2 program. 

During program operation, coordination among the parties will consist of quarterly Work Group 

meetings or conference calls, to be attended by EPA, CDPHE, and Lake County Public Health 

Agency staff. The Work Group will also hold annual meetings to review and evaluate the annual 

report described in Section 8.1 ofthis work plan. The Work Group may decide to meet less 

frequently or on as-needed basis. The intent ofthe Work Group meetings is to provide an 

informal setting for exchange of program information, status of participation and oufreach 

efforts, problems encountered, and proposed changes in program protocols. 

To assist program review and help monitor the effectiveness ofthe LCCHP Phase 2, 

CDPHE, Lake County and EPA may evaluate and provide data summaries for consideration by 

the Work Group for the following: 

• Participation of area residents in the blood lead monitoring and environmental testing 

programs. 

• Efforts to collect paired blood lead and environmental lead data, whenever possible 

for elevated blood levels. 

Documented quality assurance plans and procedures to ensure that blood lead and 

environmental data are collected and analyzed in the proper manner, and that the data 

are accurately entered into an ongoing database suitable for scientific evaluation. 

Annual reporting of summaty statistics for participation, remediation status and blood 

lead levels in young children. 

The implementation and effectiveness of community oufreach efforts. 

Periodic updates ofthe program database, including paired environmental and blood 

lead data. 

Blood lead test results and trends over time. 

Supplemental statistical analysis and program evaluation, as provided by CDPHE or 

EPA. 

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EPA will also conduct five-year reviews, as mandated by CERCLA, to ensure that the 

remedy is protective of human health and the environment. The next five-year review is 

scheduled for September of 2012 and will include the results ofa statistical analysis to determine 

ifthe remedy performance standards are being maintained. Following the next five-year 

review, the LCCHP will be reviewed and evaluated at intervals as CDPHE and EPA may find 

necessaty. Five-year and other program reviews will include, with input from Lake County, an 

evaluation ofthe need to continue the program in its cunent form. 

The program will remain in place as long as wastes are left in place ot until an altemate 

mechanism is created to serve as the institutional control required by the OU 9 ROD, or until 

EPA, CPDHE and Lake County agree that operation ofthe LCCHP Phase 2 program is no longer 

necessaty 

8.1 Annual Reports 

Annual reports will be prepared by the work group for calendar years 2008 through 2012 

to describe the LCCHP Phase 2 activities over the year and to evaluate the performance ofthe 

program. The annual reports will include information as described in the following outline, with 

additional detail to be developed in subsequent Work Group meetings. Responsibilities for the 

annual report will be shared by Lake County, CDPHE, and other entities as outlined below: 

I. Infroduction 

II. Summaty of Activities Undertaken During the Reporting Period 

- Quarterly Work Group Meetings (Lake County) 

III. Educational Oufreach (Lake County) 

IV. LCCHP Phase II Incentive Program (Lake County) 

V. Blood Lead Case Management (Lake County) 

VI. Environmental Characterization (CDPHE) 

VII. Environmental Remediation (CDPHE) 

VIII. Soil Repositoty (Lake County) 

IX. Cultural and Historic Resource Evaluations (CDPHE) 

X. Data Management (Lake County provides raw data) (County/CDPHE) 

XI. Summaty of Community Education Program (Lake County) 

XII. Blood Lead Monitoring Program Participants 

XIII. Summaty of Blood Lead Monitoring Results (Lake County) 

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LCCHP Phase 2 Work Plan March, 2009 

XIV. Summaty of Environmental Testing (CDPHE) 

XV. Summaty of Environmental Remediation Undertaken (CDPHE) 

XVI. Current and Historical Trends in Blood Lead Concentrations (CDPHE) 

XVII. Progress in Achieving Interim O&M Performance Standards (CDPHE) 

XVIII. Issues Encountered (Lake County Health, CDPHE, BOCC, or Work Group) 

XIX. Recommendations (Lake County Health, CDPHE, BOCC, or Work Group) 

XX. Actions Forthcoming in the Next Year (Lake County Health, CDPHE, BOCC, or Work 

Group) 

Appendix A - Educational Materials 

Appendix B - Property Documentation Reports 

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9.0 REFERENCES 

Camp, Dresser and McKee, Incorporated (CDM), 1993. Soils Investigation Data Report, 

Califomia Gulch Superfund Site, Leadville, Colorado. Prepared for Resunection Mining 

Company, July. 

CDC, 1997. Screening Young Children for Lead Poisoning: Guidance for State and Local 

Public Health Officials, U.S. Department of Health and Human Services, Public Health 

Service, Atlanta. November. 

CDC, 2005. Preventing Lead Poisoning in Young Children. U.S. Department of Health and 

Human Services, Public Health Service, Atlanta. August. 

Colorado Air Pollution Prevention and Confrol Act, Regulation 19, The control of Lead Hazards 

[23], Part A: Lead-Based Paint Abatement arui Part B: Pre-Renovation Education in 

Target Housing Colorado Revised Statutes §§25-7-1101-II07. amended (12/20/07, 

effective 01/30/08). 

Denver and Rio Grande Westem Railroad Company (D&RG), 1992. Final Report for Lead Slag 

Pile Remedial Investigation at the Califomia Gulch Site, Leadville, Colorado. Prepared 

by Monison Knudsen Corporation, July. 

Golder and Associates, 1995. Engineering Evaluation/Cost Analysis for Mine Waste Piles, 

Operable Unit 9, California Gulch NPL Site, Leadville, Colorado. Prepared for 

ASARCO, Incorporated, Denver, CO. December. 

Golder and Associates, 1998. Final Residential Soils Feasibility Study, California Gulch 

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