Laserfiche WebLink
exposure pathway (intervention) . These combinations of measures <br /> might include but not be limited to: <br /> Abatement - Soil removal or interior and exterior lead paint <br /> abatement. <br /> Intervention - Institutional controls, education/public outreach, <br /> gardening restrictions, indoor cleaning and dust <br /> removal, or additional cover. <br /> Generally, the most appropriate CERCLA or RCRA response <br /> action or combination of actions will be based, in part, on the <br /> estimated level of threat posed at a given site. However, as <br /> mentioned earlier, key decision criteria also include the overall <br /> protectiveness of response options, attainment of Applicable or <br /> Relevant and Appropriate Requirements (for CERCLA) , a preference <br /> for perma-nent remedies, implementability, cost-effectiveness, and <br /> public acceptance. Intervention measures may be more appropriate <br /> than abatement (e.g. , soil excavation) at many sites, especially <br /> in areas where soil lead levels fall at or near the site-specific <br /> PRG or MCS. <br /> Addressing exposure from other sources of lead may reduce <br /> risk to a greater extent and yet be less expensive than directly <br /> remediating soil. In some cases, cleaning up the soil to low <br /> levels may, by itself, provide limited risk reduction because <br /> other significant lead sources are present (e.g. , contaminated <br /> drinking water or lead-based paint in residential housing) . If <br /> it is possible to address the other sources, the most cost- <br /> effective approach may be to remediate the other sources as well <br /> as, or (if exposures to lead in soil are relatively low) instead <br /> of full soil lead abatement. <br /> Lead-based paint can be a significant source of lead <br /> exposure and needs to be considered when determining the most <br /> appropriate response action. Interior paint can contribute to <br /> elevated indoor dust lead levels. In addition, exterior paint <br /> can be a significant source of recontamination of soil. Appendix <br /> A-3 of this document contains more information on how to evaluate <br /> and address the contribution of paint. <br /> Certain legal considerations arise in considering <br /> remediation of sources other than soil. In particular, interior <br /> exposures from interior paint generally are not within the <br /> jurisdiction of RCRA or CERCLA. In addition, where other sources <br /> are addressed, issues may arise regarding the recoverability of <br /> costs expended by the Agency, or the possibility of claims being <br /> asserted against the Fund where other parties are ordered to do <br /> the work. <br /> As discussed above, in considering whether to address <br /> sources other than soil, it is necessary to consider the risk <br /> -13- <br />