ARCHIVED REPORTS_ROY'S AUTO - HISTORICAL (2)

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• e level serves as a reasonable current b(-nchmark for the purposes of this guidance . Therefore, the Agency recommends that further evaluation and appropYidEe exposure-reduction activities be undertaken when soil lead concentrations exceed 400 ppm at areas expected or intended to be used by children. 9 (Recommendations for soil sampling and analysis are attached. ) Further evaluation activities may include blood lead screening of children and others in the community. When soil lead levels exceed 400 ppm and children are likely to be present, exposure-reduction responses should focus on interim controls designed to change use patterns and create barriers between children and contaminated soil . This involves taking steps to keep children away from certain areas and to reduce exposure to bare soil in accessible areas . As an example of changing the use pattern, thorny shrubs can be planted to keep children from playing around houses that have elevated soil lead concentrations immediately next to the house . Also, play equipment can be moved from bare soil contaminated areas to encourage children to play elsewhere or, for more highly contaminated areas, access can be restricted by fencing. As an example of the use of barriers to reduce exposure, grass or other croundcover can be estab' ished and maintained or the area can be covered with mulch or gavel. While the effectiveness of many of these interim control actions cannot yet be quantified, the Agency believes that they can reduce exposure . However, whenever interim controls are used, their condition should be monitored to ensure continued effectiveness . For example, the condition of plants, groundcover, etc. , that serve as use-modifying and barrier-type elements s7- juld be visually inspected to ensure that they have become well established and remain effective at preventing exposure in accordance with the upcoming HUD Guidelines . Within the range of 400 - 5000 ppm, the degree of risk reduction activity should be commensurate with the expected risk posed by the bare soil , considering both the severity of exposure (as reflected by the soil lead concentration) and the likelihood of children' s exposure . At concentrations in the lower segment evaluations have been completed, or on another methodology. 9400 ppm is also used as the residential soil lead screening level for corrective Action under the Resource Conservation and :recovery Act (RCRA) and cleanups under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) in the Office of Solid Waste and Emergency Response (OSWER) Interim Soil Directive . OSWER' s screening level is not a "cleanup standard, " nor automatically a "cleanup goal . " Rather, it is a level of contamination above which there is enough concern to warrant site-specific study of risks . 11