ARCHIVED REPORTS_ROY'S AUTO - HISTORICAL (2)

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r. a At low to moderate levels of lead in soil and dust, and where paint deterioration is not extensive nor substrAtf, failures or moisture problems present, EPA believes that interim controls' can be an effective way to temporarily reduce exposures . Interim control of lead in dust, soil , or painted surfaces must be predicated upon demonstrated ability to maintain and monitor such management strategies, based upon condition of the environment, expected use and contact , and reasonably anticipated changes in condition and/or use . At higher lead levels in soil and dust, and under deteriorated conditions of lead-based painted surfaces, more rigorous and long-term exposure reduction interventions should be taken. Under certain conditions related to extremely high soil concentrations or structural damage to painted surfaces, interim controls may not be appropriate for particular areas or components and only complete abatement of the component by an adequately trained professional will ensure adequate protection. EPA policymakers do not believe that they are in a position to identify these levels and conditions as regulatory standards at this time . However, the Agency has developed this guidance based on consideration of estimated health impacts from lead exposure, the need to prioritize residences that would benefi from abatement, and comparison of risk reduction benefits anc. cost allocation projected for various control measures . Sequence of Source Control Activities Because of the interrelationship between lead-based paint, lead-contaminated dust, and lead-contaminated soil (e.g. , le& i in paint can contribute lead to dust and soil , lead in soil can contribute lead to interior dust, etc. ) , it is important that the sources of lead be considered in proper order when conducting response activities . For example, if soil is being contaminated by deteriorating exterior lead-based paint , it is preferable to address the paint first, immediately followed by the soil . If the soil were addressed first, it may become recontaminated during work on the paint . In general, exterior paint should be addressed prior to soil, while soil and interior paint should be addressed prior to interior dust . This best avoids potential recontamination problems among the three . Exceptions should be made when there will be delays in addressing a source or when levels in one medium (such as interior dust) are clearly hazardous and immediate actions are needed to protect health. If , in the previous example, the exterior paint could not be '" Interim controls" means a set of measures designed to reduce temporarily human exposure or likely exposure to lead- based paint hazards, such as paint repair, specialized cleaning, temporary containment and ongoing monitoring of lead-based paint hazards or potential hazards . 3