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Appendix A-2 <br /> Suggested Decision Logic for Lead-based Paint <br /> for CERCLA and RCRA Corrective Action <br /> (If soil lead levels are below screening levels, lead-based <br /> paint could be addressed by authorities other than RCRA or <br /> CERCLA. ) <br /> If soil lead levels are above screening levels: <br /> Step 1. Examine condition of exterior paint and determine <br /> its lead content, if any. <br /> • If paint is deteriorated, assess contribution <br /> or potential contribution of paint to <br /> elevated soil lead levels through speciation <br /> studies, structural equation modelling, or <br /> other statistical methods. <br /> Step 2 . Evaluate potential for recontamination of soil by <br /> exterior paint. <br /> Step 3. Remediate exterior paint only in conjunction with <br /> soil. <br /> • Determine appropriate remediation based on <br /> i <br /> risk management factors (e.g. , applying the <br /> nine criteria) , remediating the major <br /> contributor first. i <br /> Step 4 . Examine condition of indoor paint and determine i <br /> its lead content, if any. <br /> • If indoor dust lead concentration is greater <br /> than outdoor soil lead concentration (because <br /> of contamination from both interior paint and <br /> outdoor soil) , remediate indoor dust (e.g. , <br /> through a removal action, or making HEPA-VACS <br /> available to community) . <br /> Step 5. Once the risk from indoor paint has been assessed, <br /> examine options to abate indoor paint (e.g. , PRP, <br /> State, local, HUD) and consult TSCA Section 403 <br /> program for additional information and/or <br /> guidance. <br /> Step 6. While RCRA and CERCLA have very limited authority <br /> regarding the cleanup of interior paint, the <br /> remedy may take into account the reduction of <br /> A-4 <br />