lake county community health program independent review panel · haven connecticut, focusing on...

SDMS Document ID

2021721

Lake County Community HealthProgram

Independent Review PanelResponses to Key Issues/Questions

December 3, 2003

Prepared for:

CDPHELCCHP Work Group

Lake County Health DepartmentU.S. Environmental Protection Agency

Prepared by:

Conlin Associates: Resource Planners875 Mountain View Dr.

Leadville, CO 80461(719)486-2772

Lake County Community Health ProgramIndependent Review Panel

Responses to Key Issues/Questions

Contents

Introduction z

The Panel zNelson AmesThomas S. Dunlap vNick FarrJoe Graziano vz

FacilitatorMichael Conlin vzz

Panel Preparation vz'z'z

Presentations / Site Tour ix

Independent Review Work Session and Report ix

Responses to Key Issues/Questions 1

I. LCCHP Implementation 2

Consistency with Work PlanOrganization & StructureProgram Administration / Work Group 3Community awareness, education & recruitment 4Interactions & Coordination 5Environmental testing programBlood Lead testing program 6Data management, evaluation, reportingImplementation of Response Actions 7Documentation & Reporting

II. Evaluation of Performance 9

Rationale for Performance StandardLong Term effectivenessType I, Type II Errors 10Uncertainty P-10, P-15Representativeness


Responses to Key Issues/Questions

Contents, continued

Test of Proportions 11Residual Risk

III. Annual Report 12Compliance with Requirements of the Work PlanEvaluation of Performance StandardsRecommended additional data 13Unnecessary ElementsStreamlining the Annual Report

IV. Other 14Long Term Protection of Human HealthTools and Information provided to Panel 15

Summary of Panel Recommendations 16

Lake County Community Health ProgramIndependent Panel Review

INTRODUCTION

In September of 1983, the California Gulch Superfund Site was placed on the NationalPriority List for investigation and cleanup under CERCLA. In a settlement between thePotentially Responsible Parties (PRP's) reached in Federal District Court in 1994, the sitewas divided into 12 Operable Units (OU's), and responsibility for "source area" cleanupwas assigned to respective PRP's for each OU. In the settlement, ASARCO Inc. agreed toconduct clean-up work in OU-9, generally described as the residential areas in andaround the City of Leadville. In that same year, ASARCO established a trust fund tocover the costs associated with implementing the remedy for OU-9.

In 1995, ASARCO initiated the "Kids First" program as an interim response to lead riskreduction in OU-9. The pilot program was designed to be voluntary, and to addressmultiple potential lead exposure pathways (e.g. soils, household dust, interior andexterior paint, and water) in residences with young children and/or pregnant women.

In September of 1999, the Record of Decision (ROD) was issued for OU-9, and theselected remedial action was a continuation and expansion of the Kids First Program,under the new name, Lake County Community Health Program. While the programremained voluntary, clean-ups were no longer limited to residences with children and/orpregnant women. Given the unique aspects of the remedy, a provision of the RODrequired the evaluation of the selected remedy "by a group of outside scientists."

That evaluation took place on October 30th and 31st, 2003. The Independent Panelconsisted of the following experts:

THE PANEL

NELSON G. AMESMedical Health Officer responsible for population healthInterior Health AuthorityKootenay Health Service AreaNelson, BC

EDUCATION

MHSc (Master, Health Sciences)University of British ColumbiaVancouver, BC 1989

FCFP (Fellow, College of Family Physicians)Honour Award 1982CCFP (Certification in Family Medicine)


McMaster UniversityHamilton, ON 1975

M.D. McMaster UniversityHamilton, ON 1973

B.Sc. McMaster UniversityHamilton, ON 1970

EXPERIENCEJanuary 2002 to presentMedical Health Officer responsible for population healthInterior Health AuthorityKootenay Health Service AreaNelson, BC

January 2001 to January 2002Medical Health OfficerKootenay Boundary Community Health Services SocietyNelson, BC

April 01/97 to January 2001Chief Executive Officer/Medical Health OfficerKootenay Boundary Community Health Services SocietyCastlegar, BC

September 1989 to March 31,1997Director/Medical Health OfficerCentra] Kootenay Health UnitCastlegar, BCMinistry of Health, British Columbia

1976-1988Family practiceNelson, BCHospital privileges - Kootenay Lake District Hospital

ACTIVITIES WHILE IN PUBLIC SERVICE

MemberCity of Trail Health and Environment Committee2001 to present

Member

11


Trail Lead Task Force to Reduce Childhood Lead ExposureCompleted in 2001

Chairperson 1998-2000Medical Health Officer's Council of BC

MemberStage II Research Proposal Review CommitteeBC Health Care Research Foundation1996-2000

Adjunct ProfessorUniversity of British ColumbiaFaculty of MedicineDepartment of Health Care and Epidemiology

MemberExecutive Director's Standing Committee on Environment & Health 1995-97

ChairEnvironmental Health CommitteeHealth Officer's Council of BC 1995-97

MemberSoil Management Task ForceMinistry of Environment, BC - completed spring 1992

MemberFederal/Provincial Advisory Committee on Environmental and OccupationalHealth -Lead Working GroupHealth and Welfare Canada - completed fall 1991

MemberCanadian Public Health Association and BC Chapter since 1988.

PAST ASSOCIATIONS

MemberEducation Committee - BC Medical Association 1978 -1986Chairman 1983 -1986

Canadian Medical Association Council on Education 1983 -1986

Canadian College of Family Physicians

in


BC Board of Directors 1984 -1988National Board representative 1988

Chief of Staff 1980Kootenay Lake District HospitalNelson, BC

PRESENTATIONS AND PUBLICATIONS

a) Childhood Lead Exposure in Trail RevisitedCo-author with Dr. Clyde Hertzman (Canadian Journal of Public Health)Volume 82, #6 Nov/Dec 1991

b) Living in Trail - Making the Right ChoicesA Trail Community Lead Task Force Video

c) J. Toews, N. Ames"Central Kootenay Tri-City Health Promotion Project"BC Disease Surveillance Vol. 12 #9 August 1991

d) Canadian Public Health Association Annual Meeting - Regina, SK"Central Kootenay Tri-City Health Promotion Demonstration Project" -June 1991

e) Risk Communication "The Canadian Experience"Co-authored with Steve Hilts -1994International Conference on Lead Abatement and Remediation -Newcastle, Australia

f) The Trail Lead Program - Workshop on Mine and Smelter sitesCo-authored with Steve Hilts -1994International Conference on Lead Abatement and Remediation -Newcastle, Australia

g) Canadian Public Health Annual Meeting - July 1996"Lead: A Community Concern" - A Review of Health PromotionStrategies to Reduce Childhood Lead Exposure in Trail, BC"

h) "Acceptable Level of Human Health Risks Resulting from SmelterContaminants In the Trail Area", a report prepared for the Ministry ofEnvironment, Lands and Parks in compliance with the BC ContaminatedSites Regulation, May 2001

IV


THOMAS S. DUNLOPPresident: Dunlop Environmental Consulting, Inc.

Tom has been involved in Environmental Public Health in Colorado since 1970. His firstjob was with Larimer County as an Environmental Health Officer and concluded asDirector of the Pitkin County Environmental Health Department. His retirement in 2001from public service launched a new career as President of Dunlop EnvironmentalConsulting, Inc. During his years in public service his accomplishments were recognizedwith numerous awards from various local, state and federal agencies. He has spoken onmany public health issues at venues reaching from neighborhood meetings of concernedcitizens to the Congress of the United States. Tom continues to be a champion for publichealth through volunteer service to various associations and agencies. The focus for hiscompany is "Environmental and Public Health Planning for the Future." His motivationis to continue contributing for the betterment of human health and a sustainableenvironment.

Tom was the chief City of Aspen and Pitkin County technical representative for over 18years working with citizen groups, the scientific community, and all levels of governmentto resolve issues surrounding the Smuggler Mountain Superfund Site. This assignmentextended from initial contact with federal officials through de-listing of the Site. Hecurrently is a peer advisor with the National Association of County and City HealthOfficials in their superfund program. Tom visited and advised communities facingchallenges generated by having a superfund site in their jurisdictions. He was acontributing source to two publications designed to assist response actions of cities andcounties confronted with trials of the superfund program. He testified before Congress byinvitation on superfund reform.

NICK FARRExecutive DirectorNational Center for Lead-Safe HousingColumbia Maryland

Nick Fair is the founder and Executive Director of the National Center for Lead-SafeHousing in Columbia, Maryland. Mr. Farr has had a long and distinguished career in boththe public and private sector. Much of his professional experience has been centered onhousing finance, non-profit housing initiatives, housing and urban development andrehabilitation, and housing based lead poisoning prevention. A Phi Beta Kappa graduateof Yale College, Mr. Farr also graduated from Yale Law School, where he served aseditor of the Yale Law Journal.

During the 1950's and early 1960's, Mr. Farr practiced law in New York City and NewHaven Connecticut, focusing on federal taxation and zoning and urban development. Healso was a visiting lecturer at the Yale Law School during the period. In 1962, Mr. Fan-joined the Agency for International Development in the U.S. Department of State asDeputy Assistant Administrator for the Near East and South Asia economic assistance

Lake County Community Health Programindependent Panel Review

programs. In 1967 President Lyndon Johnson appointed him Director of the Model CitiesAdministration in the U.S. Department of Housing and Urban Development.

During the 1970's, Mr. Fair was a Professor at the New York University Law Centerbefore joining the U.S. Department of Commerce in 1977 as General Counsel to theEconomic Development Administration. In 1979, Mr. Farr was appointed GeneralDeputy Assistant Secretary for Community Planning and Development in the U.S.Department of Housing and Urban Development. During the early and mid 1980's, Mr.Farr was Executive Director of the California Housing and Finance Agency, and thenExecutive Vice President of the Wells Fargo Mortgage Company in California.

In 1986, Mr. Farr joined the Enterprise Foundation in Columbia, Maryland, as VicePresident for Field Services. During his tenure with Enterprise, Mr. Farr worked with andserved on the Board of Directors of a local nonprofit housing developer in Baltimore: thisorganization was attempting to create affordable housing units that had been treated forlead based paint hazards. As a result of this affiliation and his accumulated professionalexperience, Mr. Farr conceived of and created the National Center for Lead-Safe Housingin 1992.

The Center, a national nonprofit organization whose mission is to help sharply reducechildhood lead poisoning and preserve affordable housing, is engaged in research, publicpolicy advice, and technical assistance aimed at investigating, validating and promotinglead-safe housing concepts and standards.

Mr. Farr is a nationally recognized expert and has been instrumental in helpingimplement a variety of public and private initiatives to protect children from residentiallead hazard exposures. He also served as a committee chairman on the Federal Lead-based Paint Hazard Reduction and Financing Task Force, providing leadership andguidance for the creation of recommended lead-safe property standards. Mr. Farr was therecipient of the Huntington S. Williams Award.

JOSEPH H. GRAZIANO, Ph.DAssociate Dean for ResearchProfessor of Environmental Health SciencesMailman School of Public Health

Professor of PharmacologyCollege of Physicians & Surgeons

Dr. Graziano's areas of interest include: a new drug for childhood lead poisoning;environmental lead exposure; pregnancy outcome and infant development; iron, metalsand neurodegenerative diseases.

Many diseases result from gene-environment interactions. Metals - both essentialminerals and non-essential heavy metals - appear to be involved in many disease

VI


processes, most notably in the central nervous system (CNS). Dr, Graziano's laboratoryis primarily interested in the consequences of metal exposure on the CNS, and is involvedin studies of both early childhood development and neurodegenerative diseases in theelderly. A basic premise is that drugs and/or diet can be utilized to alter disease processattributable to metals.

For example, his laboratory developed highly effective oral medication for the treatmentof childhood lead poisoning. The drug, 2,3-dimercaptosuccinic acid (DMSA, orSuccimer), was approved by the Food and Drug Administration in 1991. Other studiesconcerning environmental lead exposure encompass a field of environmentalepidemiology, and have elucidated the consequences of lead exposure (and irondeficiency) on pregnancy outcome and early childhood development. Other work hasutilized the technique of stable isotope dilution to experimentally determine in humansthe bioavailability and toxicokinetics of lead from a variety of dietary and environmentalmatrices.

Most recently, the lab turned its attention to the general hypothesis that genetic alterationsin essential mineral metabolism may play a role in neurodegenerative diseases such asParkinson's Disease and Alzheimer's Disease. In collaboration with Dr. RichardMayeaux, a neuroepidemiologist and Director of the Sergievsky Center, case-controlstudies of these diseases are exploring the environmental and genetic components ofdisease.

FACILITATOR

Michael ConlinPrinciple, Conlin Associates: Resource Planners

Mike Conlin is the Principle of Conlin Associates, a Leadville based consulting firmspecializing in consensus building and environmental planning. Mike commonlyfacilitates multi-disciplinary teams and diverse public / private sector groups in projectsranging from environmental assessments to community based master plans. Mike'sdiverse client base has included, but is not limited to:

U.S. Forest ServiceU.S. Bureau of Land ManagementU.S. Environmental ProtectionAgencyUS Fish & Wildlife ServiceCity of Aurora

Lake, Eagle, and Summit CountiesColorado Department of NaturalResourcesBalcor American ExpressUnion Pacific RailroadASARCO Inc.

vn


A resident of Leadville, Mike is knowledgeable in the cultural and economic issuesfacing the community, and the history of the Superfund process as it has evolved over thepast two decades. His work in the Lake County region has included: Planning and publicfacilitation of the Mineral Belt National Recreational Trail project, an 11.6 mileinterpretive bicycle trail located entirely within the California Gulch Superfund Site;preparation of the tri-county Corridor Management Plan for Top of the Rockies NationalScenic and Historic Byway; and facilitation of the Lake County Open Space Initiative, acollection of 25 local, state, and federal agencies, municipalities, and organizationsresponsible for securing and master planning over 8600 acres of land as open space inLake County.

Mike has also worked with Lake County, ASARCO, Resurrection Mining, and the U.S.EPA in the facilitation of the grassroots participation, and the preparation of the LakeCounty Cultural Resource Preservation Plan, Lake County Interpretive Sign Plan, andthe Mineral Belt Trail Interpretive Sign Plan.

PANEL PREPARATION

Prior to convening the Panel, each participant was provided with backgroundinformation, including but not limited to:

• Work Plan for the Lake County Community Health ProgramOperable Unit 9Residential Populated AreasCalifornia Gulch Superfund SiteDecember 2000

• Methods and Standards for Evaluating the PerformanceLake County Community Health Program (LCCHP)July 2002

• Memorandum: Revised Leadville Kids First Program Report1994 - 1999 Progress and ResultsFebruary 28, 2001

• Memorandum: Supplemental Data from theLake County Community Health ProgramOctober 17,2003

• 2001 Annual ReportLake County Community Health ProgramOU-9 - California Gulch Superfund Site - Leadville, ColoradoAugust 19,2002

• Lake County Community Health Program2002 Annual ReportAugust, 2003

• Record of Decision for Operable Unit-9, EPA, Sept, 1999

Vlll

Lake County Community Health ProgramIndependent Pane! Review

PRESENTATIONS / SITE TOUR

The Panel met with representatives of the U.S. EPA, ASARCO, Lake County, City ofLeadville, Colorado Department of Health and Human Environment, Lake County PublicHealth Department, MFG Inc. (ASARCO's Consultant,) and the Lake CountyCommunity Health Program on October 30th, in Denver Colorado. Presentations made byrepresentatives of EPA, CDPHE, LCHD, MFG, ASARCO, and the Work Group, coveredthe following topics:

• Purpose of the Panel• Background of the Site Program• Why this Program? A Regulators Perspective• Kids First Program: Overview• Functioning of the Work Group• Education, Community Awareness, and Recruitment• Data Management• Program Evaluation• Environmental Program

On October 31st, participants met with Panel members in Leadville for a site tour ofOperable Unit-9 of the California Gulch Superfund Site, followed by presentations on:

• The Blood Lead Program• Staffing• Case Management

Time was allotted for Panel questions and a wrap-up session, after which the Panel andFacilitator reconvened for the Independent Review Work Session.

INDEPENDENT REVIEW WORK SESSION AND REPORT

The facilitator and Panel met in closed session on the afternoon of October 31st, with thetask of responding to a specific list of questions and issues regarding the implementationof the Work Plan, the performance of the LCCHP, the adequacy of the annual report, andthe request for any other issues or recommendations that would help to ensure the longterm protection of public health and reduce lead risk sufficiently to meet and maintain theRemedial Action Objectives (RAO's) of the Work Plan.

Each issue or question was brought to a consensus opinion that represented the expertiseand knowledge of the assembled group.

A First Draft of the Responses to Key Issues / Questions was prepared and circulatedamongst the Panelists. Comments and recommendations were received and incorporated

IX


into a second, red-line draft, to visually highlight changes suggested by individual Panelmembers, and the document was again circulated to participants for review and comment.

Based on the Panel's input to the second draft, a final draft of the Responses to KeyIssues / Questions was prepared and forwarded to all Panel Members for review andconcurrence. Consensus was reached as to the adequacy of the report, and approval wasgranted by all members of the Panel to submit the document as written.

The document that follows, entitled Lake County Community Health Plan, IndependentReview Panel Responses to Key Issues / Questions, represents the culmination of thateffort, and compliance with the ROD provision for review of the LCCHP by anindependent panel of experts.


Responses to Key Issues / Questions

LAKE COUNTY COMMUNITY HEALTH PROGRAMINDEPENDENT REVIEW PANEL

RESPONSES TO KEY ISSUES/QUESTIONS

The Independent Review Panel was tasked with preparing a written report detailing theirfindings and recommendations developed through the review of the program. The Lake CountyCommunity Health Program (LCCHP) Work Group prepared a list of questions and issues tosolicit input from the review panel on specific aspects of the program. The Work Grouprequested that the panel's final report be divided into sections corresponding to the headingsprovided in that document, followed by responses to the specific questions posed, and any otherfeedback the review panel would like to provide.

The following report provides a compilation of responses to the questions raised, and the Panel'srecommendations to further improve the implementation and effectiveness of the program.

IIIIIII


Responses to Key Issues I Questions

I. LCCHP Implementation

Based on the Panel's review of the LCCHP Work Plan and the Program's operations to date,please address the following:

LI Is the Program being implemented in a manner consistent with the design presented inthe Work Plan?

Panel Response

The Panel was in full agreement that the Program is being implemented in a mannerconsistent with the design presented in the Work Plan.

1.2 Please provide any suggestions or recommendations you may have for improving thestructure (Le., organization, responsibilities and internal communications) of LCCHPmanagement and administration.

Panel Response

Based on a preliminary review of the written documentation provided to members of thePanel, there had been an initial concern that the Program was unduly cumbersome as aresult of the number of entities responsible for individual plan elements such as bloodlead testing, environmental sampling, remediation, and work plan oversight. Members ofthe panel were prepared to suggest that placing all components of the work plan under asingle entity might streamline the time line from initiation through remediation.

Over the course of the presentations, the Panel gained a better understanding of thecomplexities of the process, and of how the various entities interacted in a system ofchecks and balances to ensure compliance with the design of the Work Plan.

Panel consensus following the presentations is that the LCCHP has created a lead riskreduction program that is both unique and effective largely due to: a) effective currentEPA project management; b) the flexibility of EPA Region 8 to allow exploration of newand innovative approaches; and c) a respect for the local culture and attitudes. Thewillingness to look beyond the initial consent decree mandate to address lead inresidential soils, to include investigation of a broader spectrum of potential human healthhazards, provides a greater level of protectiveness for the children and residents of LakeCounty.

The Panel also lauds the personal commitment, enthusiasm, and dedication of the keymembers of the project implementation team. The success of a plan is often determinedby the day-to-day effort and continuity provided by those on the front line. This effortshould be nurtured and rewarded.



Conversely, the dependency of the program on the knowledge and experience of keyindividuals points out the fragile nature of the team in the event that one of them leavesand there is no reasonable way for another person to step in without compromising theproject. The results of just such a lag were witnessed with the temporary loss of thePublic Health Nurse, and the commensurate drop in program recruitment.

• The Panel recommends that cross training and preparing for the inevitable timewhen one of the key players leaves the program should be addressed.

• The Panel recommends the extension of the Team approach to more activelyinvolve members of the local public and increase community "ownership" of boththe problem and its solutions.

o One example could be the use of "Champion Moms", mothers of childrenwho have been involved in the program and understand, first hand, itsbenefits. As part of the outreach effort, they could provide a "neighbor toneighbor" approach that may be effective within a certain segments of thecommunity, helping to identify and involve that element of the populationthat is currently not being considered in the statistical base.

o Bi-annual or quarterly public meetings could also be held to engage andinvolve the Board of Commissioners, Mayor, City Council, Chamber ofCommerce, School Board, student representatives, the press, and parentsin the recruitment and public education process, and to share in the prideof having responded positively to an identified problem.

L3 In providing your feedback with respect to the implementation of the Program, pleaseconsider these specific components of the Program design:

L3a Program administration and Work Group operations;

Panel ResponseThe Panel has observed that the Work Group is clearly dedicated to the task at hand, andhas required, and received, a high level of detail and accuracy from project staff. Theeffort is well organized, and has made good use of criteria to set priorities.



L3b Community A wareness, education, and recruitment activities

Panel ResponseThe Panel has observed that Leadville does not appear to be a unified community, butrather, represents a fragmented population that has evolved in response to changing socioeconomic forces, including shifts in economic base, ethnicity, and populationdemographics. As such, identification of the key population segments, and specifictailoring of outreach efforts to engage these segments in the program, would beconsidered advantageous.

Community awareness and recruitment efforts appear to be good, but might be improvedby the following recommendations:

• The use of "Champions", or neighborhood volunteers, who are well informed, selfmotivated, and empowered with the task of contacting and encouraging friendsand neighbors who have not responded to existing outreach efforts, to participatein the program.

• The use of trained, temporary paid staff, to go door to door in a concerted effort toreach every resident of SU-1 on a one-on-one basis, to provide information,answer questions, and encourage participation in the program. This aspect of theprogram should involve consultation with an epidemiologist, such as Dr.Bornshein, to help design a door-to-door outreach survey.

• Consideration should be given to sending a once a year reminder of the programto everyone in SU 1, with a one-on-one follow-up visit

• The Panel recommends consultation with people knowledgeable aboutcommunity assessments to develop an evaluation of public needs. Thisconsultation should solicit input to determine whether identified segments of thepopulation are getting what they want or need out of the program.

• The use of "key informants" who can represent the common needs, concerns, anddesires of identified segments of the population. This can include communityleaders, or trusted individuals within the specific population segment.

From the Panels' experience, public education is a necessary element of an integratedremediation plan, but in and of itself, is not sufficient to resolve the problem. The Panelfeels that the LCCHP has done a fine job in educating parents on the findings andimplications of the blood lead level sampling. Reliance on efforts to educate parents onmethods of cleaning, personal hygiene etc. are not, however, considered to be anadequate substitute for aggressive control or elimination of environmental hazards inlowering blood lead levels. Research has found that such an education program has littleor no effect on children's blood lead levels even if it includes multiple home visits andprovision for cleaning materials.



The Panel's primary area of concern lies not in LCCHP compliance with the standards, aswritten in the work plan, but with the standards themselves, most specifically, the triggerlevels for lead based paint hazards. Since a critique of the Standards is not a part of therequested Scope of Work, comments will be reserved for Section IV, which requestsother feedback for ensuring long-term protection of public health.

L3c Interactions with Program participants and coordination between environmentaltesting and blood lead programs;

Panel ResponseThe Panel feels that the Working Group is the appropriate mechanism for merging theblood lead and environmental elements of the plan, authorizing environmental responses,and for monitoring the day-to-day interactions. The result has been a seamless andeffective implementation of the Work Plan.

/. 3d Environmental testing program and procedures;

Panel ResponseThe Panel shared a high level of comfort that the methodology and implementation of thesoil-testing program was effective in meeting the standards of the Work Plan, and inidentifying potential health hazards.

• The Panel recommends that drip line testing be emphasized in the soil samplingregime to help determine the presence and influence of soil lead from deterioratedexternal lead based paint sources.

The Panel was similarly comfortable with the approach and methodology of determining(and responding to) lead in the potable water supply.

With regard to the identification of lead based paint hazards, the Panel is comfortable thatthe testing procedures are in compliance with the standards set forth in the work plan. Aspreviously indicated, the Panel is also in agreement that the trigger level for aggressivecontrol and elimination of 6mg/cm2, as dictated by the Work Plan, is too high.

Panel members expressed concern that the three-sample method currently in use fortesting house dust is not sufficient to identify hazards or provide house-wide clearance.

• The Panel recommends that the Program follow protocols described in EPA 402Regulations, and that entryways always be tested.



L3e Blood lead testing program and procedures;

Panel Response:The Panel was comfortable with the methodology and implementation of the blood leadlevel testing, and with the procedures for sampling and documentation. Panel membersdid not feel that waiting until a child is 12 months of age to begin recruitment into theLCCHP was ideal, and would encourage blood lead level testing starting at age 9 months.The Panel recognizes that the act of drawing blood from children under the age of 12months is difficult and could be perceived as causing trauma and loss of follow-up, butrecognizes that the problem of elevated blood lead levels begins to manifest itself in aquantifiable manner at about the age of 9 months.

• The Panel recommends the use of a professional phlebotomist to gather sampleson children under the age of 12 months of age. While it can be more expensive, itis considered to be less painful and time consuming than a heel or finger prick.Early intervention with newborns is important because parents are generally moreattentive and interested in their new charge. Early detection leads to earlyresponse and remedy.

L3f "Data management, evaluation, and reporting practices;

Panel Response:The Panel believes that the data management procedures practiced by the program aresound, and provide for a system of checks and balances of key variables.

Given the amount of information being collected, the Panel also feels that the data-base isbeing under-utilized, and encourages the Program to make greater use of the full data setin its analysis and evaluation, in order to better understand which lead hazards are theprincipal sources of exposure to children. To this end, the Panel makes the followingrecommendations:

• i. Since the percentage of children with blood lead concentrations greaterthan 10 and 15 ug/dl has not changed in three years, it appears quite possible thatthere may be risk factors that are not currently adequately addressed in theongoing remediation strategy. Use of a multi-variate regression method to betterunderstand the determinants of elevated blood lead in Leadville may lead topossible modifications of the existing remediation plan to facilitate theachievement of the plan's objectives. A broader range of variables could beevaluated using data already collected. Examples include: lead based paint, paintand floor condition, dust, presence of pets, vinyl mini-blinds, behaviors, etc. Thisissue is discussed further in the Panels recommendations for meeting performancestandards criteria in Statistical Unit 1.



ii. The annual report reflects blood lead levels as a function of a number ofvariables, such as age, neighborhoods, etc. Consider linking annual reporting toprevious years to demonstrate trends of blood lead levels over time, as a functionof multiple variables.iii. GIS is a powerful mapping and analytical tool for graphic and spatialrepresentation of data. It is strongly urged that a GIS system be implemented byLake County, to allow for the special tracking of children with elevated bloodleads. It appears possible that "hot spots" of exposure, possible targets forrecruitment/remediation, may be unveiled in this manner.iv. Make the results of dust and lead based paint in reports more readilyobservable.v. Split the collected sample base at the mean rather than at the P-10 or P-15levels to increase the statistical power of the analysis, and to provide a referencegroup that falls below the mean for comparing and targeting key differences. Thisissue is discussed further in the Panels recommendations for meeting performancestandards criteria in Statistical Unit 1.vi. Consider testing for representativeness of lead based paint hazard as wellas soil lead.vii. Use the suggested analytical strategy to evaluate and improve the programand more effectively target the basic problem areas.

/. 3g Implementation of response actions

Panel Response:The Panel was unanimous that the implementation of response actions was good, andfollowed the standards of the work plan.

L3h Documentation and reporting practices

Panel Response:The Panel felt that the documentation and reporting practices were satisfactory to meetthe standards of the work plan, and has no additional recommendations.

1.4 Statistical Unit 1 has not met the performance standards criteria; please provide anyadditional implementation recommendations that could be considered by the Work Group tomeet these standards.

Panel Response:Review of trends in P-10 and P-15 in both Statistical Unit 1 and Statistical Unit 2indicates that while the mean blood lead concentration in Leadville is declining over



time, as is the national trend, the percentage of participants with blood lead levels greaterthat 10 and 15 ug/dl, respectively, has not significantly changed over time. This impliesthat there is a "tail" at the high end of the blood lead level distribution that has notresponded to the current interventions.

• The Panel therefore recommends that every effort be made to better understandthe determinants (or predictors) of blood lead; variables of interest might includehousing type, child age, behaviors, pets, and the presence of anemia. Since theabsolute number of children with elevated blood leads is small, one possibleapproach would be to divide the overall sample of children into two groups, i.e.,those with blood leads above and below the mean. The increase in analyticalsample size provided by selecting the mean as a cutoff rather than P-10 or P-15blood lead level triggers, increases the statistical power and may reveal whichdeterminants of blood lead in the multi-variate regression are causing the "tail"that is not responding to the current interventions.

The Panel also refers the reader to the recommendations for increasing public outreachlisted earlier, and the recommendations for ensuring long-term protection of public healthlisted under Section IV, Other.



II. Evaluation of Performance

Based on the Panel's review of the 'Methods and Standards for Evaluating the Performanceof the Lake County Community Health Program' document (the 'Performance StandardsDocument') and the evaluation of data from the years 2000, 2001, and 2002, presented in the2002 Annual Report, please address the following:

IL1 Please comment on the appropriateness and applicability of the statistical methods andstandards presented in the Performance Standards Document for evaluating the performanceof the Program with respect to the established Remedial Action Objectives.

La Is the rationale for each performance standard adequately described, appropriate, andscientifically defensible?

Panel Response:The Panel believes that the rationale for the establishment of standards has beenadequately described in the Performance Standards Document. The Panel considers thestandards, as described in the document, to be reasonable but arbitrary, as they do notmirror National standards (e.g. soil lead level of 3500 ppm and lead based paint at6mg/cm2).

The Panel believes that the performance standards for meeting the Remedial ActionObjectives are appropriate. The Panel does not feel that the term "scientificallydefensible" is appropriate within this context and, therefore, offers no response to thisquery.

The Panel also notes the absence of a critical path or timeline for completion as part ofthe Performance Standards. Inclusion of a timeline would be considered normal practicein such a document.

Lb Does the method adequately demonstrate the long-term effectiveness of the remedy andcompliance with RAOs?

Panel Response:The Panel feels that this is a critical question that cannot be answered at this time, and citesthe following reasons:

1. There is not enough long term data available at this point2. P-10 and P-15 values have not changed significantly in either SU-1 or SU-23. The majority of properties will not necessarily have been remediated if or when the

Performance Standard has been met.



II.2 Please comment on the data evaluation techniques and statistical methods presented inthe Performance Standards Document and make any suggestions or recommendations formodification or improvement.

2.a Have Type I and Type II error rates been assessed adequately and in a scientificallydefensible manner?

Panel Response:The Panel was in agreement that the methods and performance standards formulated bythe work group very carefully and quantitatively addressed Type 1 and Type 2 errors.The Panel does not believe that the term "scientifically defensible" is appropriate withinthis context.

2.b Has the uncertainty in the P10 and PIS values been assessed adequately and in ascientifically defensible manner?

Panel Response:The Panel feels that the Working Group was highly innovative in using the Monte CarloAnalysis to address uncertainty in P-10 and P-15 values. The approach is considered tobe highly appropriate and astute. Again, the term "scientifically defensible" is consideredinappropriate within the context of the question.

2.c Do the required criteria adequately assess the overall representativeness of theavailable blood lead data, used to derive the theoretical blood lead distribution for thecommunity at large?

Panel Response:The Panel was in agreement that, given Leadville's long mining history, the selection ofsoil lead as an initial criterion for estimating representativeness was appropriate for thesite. However, the Panel also feels quite strongly that other important sources of leadexposure, most specifically lead based paint hazards, should be assessed forrepresentativeness. This approach would recognize the novel aspects of the LeadvilleRemediation Plan, and how it differs from other site plans.

The Panel would strongly support this approach.

10



2.d Does the test of proportions used in Performance Standard 4 provide reasonableassurance that blood lead program participants are not from residences that underestimate thehigh end of the soil lead distribution for the statistical unit as a whole?

Panel Response:The Panel is in agreement that the test of proportions used in Performance Standard 4does provide reasonable assurance that blood lead program participants are not fromresidences that underestimate the high end of the soil lead distribution for the statisticalunit as a whole.

2.e Do the methods and standards for evaluating performance provide reasonableassurance that the Program's goal regarding residual risk - to ensure that whatever residualrisks that remain will be sufficiently low as to not exceed the RAOs (described in section 7.0 ofthe Performance Standards Document) - will be achieved?

Panel Response:The Institutional Controls referenced in the Work Plan, which are intended to provide ongoingcontrol measures to assure the protection of completed remediation and protection of humanhealth once the LCCHP performance standards have been met, have not yet been approved orimplemented. The Panel feels that in the absence of details on how the Institutional Controls willbe implemented and enforced, there is insufficient data to respond to this question at this time.Please see the Panels concerns regarding the importance of Institutional Controls in Section IV,Other.

11



III. Annual Report

Based on the Panel's review of the 2001 and 2002 Annual Reports and the 1994-1999Progress and Results Report, please address the following:

IIL1 Please comment on whether the LCCHP Annual Reports (2001 and 2002) meet therequirements and expectations of the Work Plan.

Panel Response:The Panel felt that the Annual Reports were very thorough, and met the requirements andexpectations of the Work Plan.

• The Panel recommends the Annual Report include a target date to achieveprogram objectives.

The Panel also discussed the issue of who the audience for the annual report is, andwhether it is intended for review by the general public or by public officials. If thedocument is intended for public distribution, the technical level of expertise required tounderstand the document far exceeds the knowledge base of the "man on the street".

• The Panel recommends an executive summary that highlights outcomes in readilyunderstandable "layman's" terms as an extension of the outreach program. Anexample of such a summary from Trail, British Columbia is attached, andincludes the Power Point presentation used in public meetings and the newslettermailed to each household

7/7.2 Please comment on whether data presented in the 2002 annual report are adequate tosupport evaluation of the program performance standards (Refer to Appendix D of the 2002Annual Report)?

Panel Response:The Panel was in agreement that the data presented in the 2002 annual report is adequateto support evaluation of the program performance standards.

III.3 Please make any suggestions or recommendations for improving the value andusefulness of future annual reports. However, in making your suggestions andrecommendations, please be mindful that these are produced as public documents and theconfidentiality of program participants must be maintained.

12



3.a Do you recommend additional data analysis to support compliance with the RAOs?

Panel Response:The Panels experience would indicate a strong relationship between low hemoglobin andincreased lead uptake.

• The Panel recommends that annual report should include a frequency distributionof hemoglobin concentrations.

With the noted exceptions, the Panel does not feel that additional data analysis to supportcompliance with the RAO's is necessary.

3.b Are there components of the data analysis presented in the annual report that you feelare not necessary?

Panel Response:The Panel did not feel that any elements of the annual report should be deleted.

3.c Can you identify ways to streamline the annual report?

Panel Response:The Panel has no specific recommendations for streamlining the annual report, but feltthat a highly condensed and streamlined version of the report, expressing general trendsand accomplishments in layman's terms, could be prepared for public distribution andused to improve community education and recruitment.

13

IIIIIIIII



IV. Other

IV. 1 Please provide any other feedback or thoughts you feel may be helpful to the WorkGroup in managing the ongoing implementation of the Program and ensuring long-termprotection of public health.

Panel Response:

While the Panel recognizes the unique methods and creative response to reducing leadexposures in Leadville, they did express a concern regarding the need for a perpetualobligation of the Plan to keep lead exposure down in future generations. The Panel isaware that the independent panel review "is not intended to address certain fundamentalelements of the program described in the Record of Decision (ROD), including: remedialaction objectives, the voluntary nature of the program, program eligibility, the mediaaddressed, and trigger criteria for the various media used as the basis for recommendingresponses actions." Nevertheless, a unanimous opinion was reached, i.e., that someprotective control measures must be kept in place for years beyond the completion of theLCCHP.

The Panel is concerned that the long-term protectiveness of the remedy, after theStatistical Units have achieved the specified performance standards, is not adequatelyaddressed. A significant discussion about, and commitment to, sustainable remedialresponse is important in order to fulfill the public health responsibility of the Plan. If theLCCHP is no longer a functional organization, post-standard compliance, a worry is thatthere will be no effective program for future generations to provide for lead exposuresurveillance, consultation, and intervention.

The only obligation recognized by the Panel as offering this type of sustainable assuranceto the community is the adoption of Institutional Controls. This tool is a testedresponsibility of local government to be responsive to needs of the citizens once theresponsible parties have fulfilled their obligation. Institutional Controls allow for followup of completed remedies that may intentionally or unintentionally be compromised inthe future. Without a method for future effective management of the Site post-LCCHP,the Panel feels that the community of Leadville may face a long-term risk of continuedlead exposure.

Similarly, while not asked to comment on trigger levels for environmental response, thePanel feels obligated to express its concerns that the P-10 and P-15 levels have notbudged for three years in either Statistical Unit, indicating that the selection of soil leadas criterion for representativeness may not be targeting the appropriate media; hence, thereluctance of the statistical "tail" to move downward.

14



The Panel does not presume that lead in water or soils are the only sources of leadexposure. Rather, the Panel believes that the unique climatological factors specific toLeadville likely result in a significant amount of indoor play time. This, coupled with theage of housing where exposure to dust and lead based paint hazard is occurring, isconsidered justification for re-examining and focusing on the risks and response levelswithin the home environment.

The Panel strongly suggests the use of EPA and HUD standards for lead concentrationsin paint and dust lead loading for risk assessment. It also recommends a more aggressiveresponse for deteriorated lead based paint hazards >1 and <6 mg/cm2. The Panel feelsthat education alone will not resolve the hazard within this range, but that aggressivecontrol and elimination will be required.

The Panel also recommends testing hard floor surfaces for dust, because of the difficultyin retrieving adequate samples trapped in carpeted areas, and always testing entry-ways.The small volumes collected from carpeting are often not sufficient to get an accuratesample. The use of wipe samples as opposed to air pump sampling for dust is alsorecommended. Lead loading, based on the wipe sampling method, has been found tocorrelate with children's' blood lead levels better than vacuum samples collected by anair sampler. In addition, EPA's standard for dangerous levels of lead in dust is based onwipe sampling.

IV.2 Was the Independent Review Panel provided with the tools and information needed tocomplete the Program review in accordance with the Scope of Work?

Panel Response:The presentations, documentation, and site tour were well prepared, thorough, andinformative. The Panel wishes to express its deep appreciation for the tools they wereprovided, and the passion and enthusiasm of the presenters who personalized the data setsand protocols, and made the point evident that the personal commitment of the wholeteam plays an enormous part in the success of this highly innovative program.

15



SUMMARY OF PANEL RECOMMENDATIONS

The following Summary of Panel Recommendations is intended to ensure long-termprotection of public health and reduce risk sufficiently to meet and maintain RemedialAction Objectives:

• Make better use of data currently being collected through the use of a multi-variate regression model, to include a wider range of potential determinants ofblood lead.

• Consider linking annual reports to previous years to demonstrate trends of bloodlead levels over time.

• Dichotomize the blood lead level database at the mean to increase statisticalpower and allow for a comparison of contributing factors for blood lead levelsabove and below the mean.

• Consider testing for representativeness of lead based paint hazard as well as soillead.

• Make the results of dust and lead based paint analysis in annual reports morereadily observable.

• Use the suggested analytical strategy to evaluate and improve the program andmore effectively target basic problem areas.

• Include target dates for achieving project objectives.• Compare outcomes against those obtained at other "comparable" sites.• Use GIS technology to visually track and represent the spatial relationships in

elevated blood lead levels and their recurrences, as well as to map the completedremediations.

• Encourage Lake County control of the GIS Data Base following LCCHPcompliance with performance standards.

• Complete Institutional Controls to monitor and protect completed remedies thatmay intentionally or unintentionally be compromised or recontaminated in thefuture. Assign perpetual responsibility to the Lake County Government to educatethe public and enforce the regulations.

• Modify the access agreement to allow for long-term monitoring and surveillanceof dust lead hazards, maintenance of soil remediations etc. following initialremediation.

• Initiate follow-up monitoring of the effectiveness of educational efforts inlowering blood lead levels by observing the condition of lead-based paint andtesting dust lead levels, and interviewing "educated" families.

• Test drip lines as a standard element of soil lead testing.• Use EPA 402 and HUD standards for deteriorated lead based paint and dust

hazards in risk assessment, and initiate aggressive control and elimination ofhazards for levels >1 and <6 mg/cm2.

16



Use wipe samples to test dust lead loading.Reduce reliance on HEPA vacuums as an active form of remediation. The filtersmay actually reduce suction and decrease efficiency.Remove references to the use of TSP as an active form of remediation. It has atendency to damage paint and has not demonstrated significant effectiveness inlowering EBL's.Provide additional training to existing staff, or utilize a professional phlebotomistto sample blood lead levels of children under the age of 12 months.Include a hemoglobin frequency distribution as part of the annual report.Distribute free iron supplements and vitamins at the Health Department, asappropriate, to simplify availability and enhance recruitment.Educate and encourage realtors to practice HUD and EPA mandated regulationsregarding representations of condition that are accurate and unbiased.Provide property owners with a "clean letter" from the EPA once successfulremediation of their property has been accomplished. (Example provided)Encourage construction and remodeling that incorporates bare floors that areeasier to clean and trap less dust than carpet, especially in entryways.Extend the team approach to more actively involve members of the public andincrease community ownership of both the problem and its solutions.Consider bi-annual or quarterly public meetings to involve the School District,student representatives, the Mayor, City Council, the Chamber of Commerce,parents etc. to build community pride in their positive response to an identifiedproblem.Use "Champion Moms" and neighborhood volunteers to involve the communityin identifying and resolving the problem.Identify and gather input from "key informants" within the various segments ofthe community who can speak for their representative group.Consider sending a once a year reminder of the program to everyone in SU-1,with a one-on-one follow-up visit.Consider the use of trained, temporary paid staff, to go door-to-door to encouragerecruitment.Consider preparation of a brief executive summary of the annual report that issuitable for distribution to the general public.Enlist outside expertise from an Epidemiologist to design a door-to-door survey toincrease participation in the program.Consult with people knowledgeable about community assessments to develop anevaluation of whether identified segments of the population are getting what theywant or need out of the program.Consider cross training and preparing for the inevitable time when one of the keyplayers leaves the program.Welcome the press and media to become involved in exercises such as thisIndependent Panel Review.

17

ATTACHMENT A-l

INFORMATION FROM THE TRAIL COMMUNITY LEAD TASK FORCETrail, British Columbia, Canada

Referenced on Page 12 of the "Independent Review Panel Responses to KeyIssues/Questions "

2003 Status Report on the Recommendations of the TrailCommunity Lead Task Force

2003 Status Reporton the

Recommendations of theTrail Community Lead Task Force

Prepared for:

Version 5

July 9, 2003

Steve Hilts, Teck Cominco Metals, Ltd.

Cheryl Yates, Interior Health Authority

TABLE OF CONTENTS

EXECUTIVE SUMMARY 1

HISTORY 2THE NEXT PHASE 5

GOALS SET BY THE TRAIL COMMUNITY LEAD TASK FORCE 6

BLOOD LEAD 6OTHER SMELTER CONTAMINANTS 8

SUMMARY STATUS REPORT TO END OF 2002 9

2003 PROGRAMS/SERVICES 19

1. SOURCE REDUCTION 191.1 TeckCominco Emissions Control and Reduction 19

2. COMMUNITY MONITORING 212.1 Blood Lead Testing 212.2 Environmental Monitoring 22

3. COMMUNITY EXPOSURE REDUCTION 243.1 Dust Control 243.2 Smelter Buffer Zone 253.3 Work Project Assistance Program 26

4. CASE MANAGEMENT 275. EDUCATION 28

5.1 Community Education and Awareness 285.2 Early Childhood Education 29

6. OVERSIGHT AND COORDINATION 30

SUMMARY OF 2003 FUNDING COMMITMENTS 32

REFERENCES 33

CONTACT INFORMATION

This report, and additional information, is available on request from the following locations:

City of Trail1394 Pine AveTrail, BC VIR4E6

Phone: (250) 364-1262

Interior Health Authority1051FarwellSt.Trail, BC V1R4S9

Cheryl Yates or Katarina Edwards

Phone: (250) 368-LEAD (368-5323)Fax: (250) 364-0580E-mail:chery [email protected]

Teck ComincoPO Box 1000Trail, BC V1R4L8

Steve Hilts

Phone: (250)264-4385Fax: (250)364-4144E-mail:steven.hilts@teckcom inco.com

Additional information is also online at: http://mvpage.direct.caA/tlp

EXECUTIVE SUMMARY

Trail has been the site of metals smelting and refining facilities for over 100 years. The proximity of thecommunity to the smelter complex has resulted in elevated levels of some metals in community air, soiland dust. The main focus of attention since about 1975 has been lead and its possible health effects onchildren of pre-school age. Although there has never been a recorded incident of clinical lead poisoningamong children in this community, studies elsewhere have found that subtle health effects can occur atlow levels of exposure. These effects can only be detected by studying large populations of children.

In 1990, the Trail Community Lead Task Force was formed to develop a strategy for reducingchildren's lead exposures. This program involved the community, industry and government workingtogether to study the problem, take actions and recommend long-term solutions. The Task Forceundertook comprehensive community education and lead health intervention programs, and TeckCominco1 made several major improvements in emissions control - the most significant by far being theconstruction and start-up of the new KTVCET lead smelter.

In 1998, the Task Force reached its first short-term goal of having at least 90 percent of children withblood lead levels below 15 |ig/dl, which was the Task Force's individual level of concern. By 2000, thenext short-term goal of having 95 percent below 15 .̂g/dl had nearly been reached. When the TaskForce was first formed, there were well over 100 children with blood lead levels of 15 |ig/dl or higher.By 2000, there were only about a dozen.

The Task Force wrapped up its work and submitted its recommendations for long-term actions inFebruary 2001. The EC Ministry of Water, Land and Air Protection2 has not yet formally reviewedthe Task Force recommendations, which are presented in detail later in this document. However,Teck Cominco, the Interior Health Authority3 and the City of Trail all committed to implementingthe Task Force's recommendations without delay. Key programs, such as blood lead testing andcase management, have continued without interruption since 2001.

The 2003 case management program consists of: follow-up testing of children who have elevated orrising blood lead levels; counseling of families with children who have elevated or rising blood leadlevels; and provision of case management services to prevent and/or reduce lead exposure. Educationwill continue to play an important role in decreasing childhood lead exposure, with programs aimed atthe prenatal, early childhood, and community levels. Teck Cominco will pursue and report on itsprogress toward further emission reductions. Community dust control including greening, dustsuppression on alleys and street cleaning will continue. Teck Cominco will monitor the work it did in2001 and 2002 to improve the vegetative buffer between its operations and the community along theboundary with Tadanac. A new Work Project Assistance Program, as recommended by the Task Force,will be developed in 2003.

Note: In 2001. Cominco merged with another Canadian mining company (Teck Corp.) to form Teck Cominco.

Note: Prior to 2001, the BC Ministry of Water, Land and Air Protection was known variously as BC Environment, theBC Ministry of Environment, or the BC Ministry of Environment, Lands and Parks.

Note: In 2001, health services delivery regions in BC were also reorganized. Tlie Kootenay Boundary CommunityHealth Service society was superceded at that time by the Interior Health Authority.

2003 Program Strategy, Page 1

The combined three-agency budget for 2003 is approximately $150,000 which does not includeemission control projects at Teck Cominco or salaries of regular staff.

HistoryLead has been a fact of life in Trail for the past 100 years. Although there has never been a recordedincident of clinical lead poisoning among children in this community, studies elsewhere have found thatvery subtle health effects can occura t low levels of exposure. These effects can only be detected bystudying large populations of children.

In 1975, Neri et. al. (1978) found that children's blood lead levels in Trail were significantly higherthan those in the nearby comparison community of Nelson, BC. A 1989 study found that soil leadconcentration and, secondarily, house dust lead concentration, were the principal environmentaldeterminants of elevated blood lead levels in Trail children (Hertzman e.t al., 1991). Although theaverage blood lead level had declined from 22.4 ug/dL for 1-3 year olds in 1975 to 13.8 ug/dL for2-5 year olds in 1989, 39.4% of the children tested in 1989 were above the U.S.E nvironmentalProtection Agency's "level of no concern" of 15 ug/dL at the time (US EPA, 1986).

The 1989 study's recommendations prompted the formation of the Trail Community Lead TaskForce in 1990. The Task Force was given responsibility for developing a strategy for reducing Trailchildren's lead exposures. Communities with inactive smelters or mine sites have oftenimplemented large clean-up programs to permanently reduce lead exposures. By contrast, thestrategy for Trail is expected to help the smelter and the community to continue to co-exist byfocussing on actions that will be effective in the midst of ongoing, albeit reduced, emissions.

The Task Force was composed of representatives from numerous community groups, localgovernment, the Province of British Columbia and the smelter company (Teck Cominco, Limited).All meetings were open to the public and the media (see Figure 1). Task Force members workedcooperatively to reach consensus on most issues and Teck Cominco participated voluntarily in allTask Force programs. Teck Cominco, the BC Ministries of Health and Environment, and the City ofTrail provided a total of approximately $5 million in funding from 1990 to 2000. In addition tofinancial contributions, the Province and Teck Cominco provided technical resource people withhealth, environment and public relations backgrounds to participate in program planning.

The Trail model of co-operative, multi-stakeholder program planning and shared fundingcontributed enormously to the program's effectiveness and efficiency. The program's work isrecognized internationally and the Trail co-operative model has been adopted in several otherjurisdictions.


IIIIIiiiiiiiiiiiiii

Figure 1 - Trail Community Lead Task Force Structure: 1990-2000

Qty of Trail |(Chair) j

CbmincoMinistry of

Environment

Community ^ \Member J \

Funding CommunityMember

[ United |3eelworkersI of America J

10%

Regional Q'strict ofKbotenay/Boundar

SthoolDistrict No.

11

Trail & (District jEnvironmental I

Network J

Qty of TrailMinistry of

Health

CommunityMember

Early in its mandate, the Task Force estimated the cost of residential soil replacement in Trail atabout $50,000,000 and expressed concern that excavation and soil transport might result in atransient increase in lead exposure. In addition to the financial deterrent and questions of efficacy,soil removal appeared to be socially unacceptable in Trail. Also, the lead smelter in operation in1990 relied on outdated process technology and, despite efforts to control emissions, the amount oflead discharged to the environment was about 300 kg/day (Cominco Ltd., 1993). At the time,Cominco was encountering technical difficulties in implementing new lead smelting technology inTrail. Smelter emissions, and therefore soil contamination rates, were expected to continue at theselevels for number of years. For all of these reasons, the Task Force chose not to recommend anyimmediate soil replacement. Instead, the Task Force embarked on ambilious programs ofcommunity education and case management, as well as environmental assessment aimed at betterunderstanding lead exposure pathways.

Teck Cominco began operating a new lead smelter in Trail in April, 1997. The state-of-the-artsmelter reduced lead emissions from stacks by about 70%. In addition, the new smelter dramaticallylowered fugitive (non-stack) emissions through the replacement of several existing plants with asingle, enclosed plant.

The reduction in lead emissions has had a significant effect on children's blood lead levels. From1989 through 1996, average blood lead levels of Trail children tested for the first time declined at


an average rate of 0.6 ug/dL/year. The year-to-year variability in average blood lead levels duringthis period appeared to be related to weather conditions during the month preceding the fall bloodtesting clinic. Specifically, when August was relatively dry, blood lead levels tended to be higher.

From 1996 to 1999, the average blood lead level of children tested for the first time fell by 54% -from 11.0 |ig/dL to 5.1 [ig/dL. The average annual rate of decline during this three-year period was1.9 ug/dL/year. The rapid decline appears to be attributable to the replacement of the old leadsmelter in May of 1997. Air lead levels in Trail during the summer of 1997 were about 50% lowerthan during the summers of 1994-1996. By 1998, summer air lead levels were 75% lower thanduring the last years of operation of the old lead smelter. Annual average air lead levels in Trail arenow about 0.25-0.30 |ig/m3.

In 2000, the average blood lead level among Trail pre-schoolers tested for the first time increased to6.3 (ig/dl. Air lead levels and dustfall lead levels did not increase during the summer of 2000, so theincrease in blood lead levels in 2000 appears to be due to very dry weather experienced during themonth of August.

Shows the history of average blood lead levels for all children tested from 1975 to 2000. The U.S.national average for children aged 1-5 is also presented for comparison.

Figure 2 - History of Children's Blood Lead Levels in Trail - Averages for All Children Tested

25

•o"Sir 201

•ora 15•ao_o

2 10raio'-5 su 5

Ov(3

22.4

15.0

3.62.7

2.0

inooen O)o>

inO)01

[—Trail US National Average [

From 1997 to 1999, the Task Force conducted a human health risk assessment to evaluate in detailthe risk posed by other smelter contaminants, such as arsenic, cadmium and antimony. Forchemicals other than lead, the study found "no imminent (short-term) threat to human health" and"very limited potential for adverse health effects from long-term residence in Trail".


In 2000, the Task Force completed its evaluation and selection of options for long-term remedialactions. This process involved in-depth consultation with the community at large. Options for long-term remediation included institutionalizing blood lead monitoring, case management and educationprograms to ensure their continuation, as well as various physical actions that might be taken tofurther improve environmental conditions.

The Task Force based its recommendations on consideration of the following major factors:

• Estimated health risk levels (based on studies conducted elsewhere that have linkedexposure to metals with health effects in humans and animals)

• Community feedback on the estimated health risk levels• Effectiveness of options for reducing health risks (based on experiences in Trail and at

other sites)• Socioeconomic impact of intervention and remediation options (including both monetary

costs and disruption to the community)

The Task Force submitted its final recommendations to the BC Minister of Environment inFebruary 2001.

The Next PhaseThe BC Ministry of Water, Land and Air Protection will now review the Task Forcerecommendations, which are presented in detail later in this document. Ultimately, therecommendations must become part of an approved overall remediation plan for area. However,Teck Cominco, the Interior Health Authority and the City of Trail all committed to implementingthe Task Force's recommendations without delay. Key programs, such as blood lead testing andcase management, have continued without interruption since 2001.

This report describes the current status of implementation of the Task Force's recommendations andplanned activities for 2003 .


GOALS SET BY THE TRAIL COMMUNITY LEAD TASKFORCE

Blood Lead

Recommendations:

At least 90% of children aged 6 to 72 months in area 2 and 3 (see drawingbelow) should have blood lead levels less than 10 jig/dL by 2005.

At least 99% of children aged 6 to 72 months in area 2 and 3 should haveblood lead levels less than 15 jig/dL by 2005.

Once these goals are achieved, blood lead testing should continue, in orderto provide ongoing protection of young children in Trail.

If these goals are not achieved, the remedial plan should be re-evaluated.

Trends In Percentage of Childrenwith Blood Lead Levels < 10 |ig/dl

100% T~

Trends In Percentage of Childrenwith Blood Lead Levels < 15 pg/dl

100%

90%

33

70% • •

80% • •

50%

Pn-KIVCET(1991-1998)

H 1 1 1 1- -) 1 1 1 1 1 1-

Background;

10 |ig/dL is the "community concern" level recommended by the US Centers forDisease Control (US CDC) and it is intended to apply to children in the 6-72months age group. An association between children's blood lead levels and IQhas been observed down to this level in studies involving large numbers ofchildren. These studies have found that, on average, groups of children withblood lead levels around 20 (ig/dL score about 1 -2 points lower on IQ tests thangroups of children with blood lead levels around 10 ug/dL, after controlling forother factors that affect IQ.


• A Canadian Federal-Provincial Task Force recommended in 1994 thatcommunities with unusual sources of lead exposure may need special programswhere the percentage of children in those communities with blood lead levelsabove 10 (ig/dL is double that seen in the general population. Since thepercentage of children above 10 u,g/dL in North America is currently about 5%,this would indicate a target of no more than 10% above 10 u.g/dL.

• 15 |ig/dL is the "individual concern level" recommended by the US Centers forDisease Control. The Task Force felt that ideally, children should rarely exceedthis blood lead level (less than 1%).

• Several recent studies involving large numbers of children in the U.S. suggestthat even blood lead levels less than 10 ug/dL may impact on children's IQscores. Therefore, the US CDC has convened an expert panel to review itspresent guideline for children's blood levels. It's expected that the panel willcomplete its review sometime in 2004. The outcome of that review may result inthe Trail Health and Environment Committee revisiting the blood lead goals setby the Lead Task Force.

Oasis

LowerWarfleld


Other Smelter Contaminants

Recommendations:.

Potential health risks from other smelter contaminants (i.e. cadmium andarsenic) should be reduced to the levels required by provincial regulations,without shutting down the smelter or conducting widespread soilreplacement in the area.

Background:

• The BC Cancer Agency and BC Ministry of Health have looked at routine healthdata and conducted several specific studies to see whether the incidence rates ofany diseases that may be associated with metals exposure (e.g. lung cancer,kidney disfunction) are higher than normal in Trail. No measureable increasesin disease rates have been found.

• The Trail Lead Task Force conducted a detailed risk assessment for other smeltercontaminants in 1997-99. The assessment involved first comparingconcentrations of metals in the local soil and air against screening guidelines.The elements that exceeded screening guidelines were the subject of moredetailed assessment, involving estimation of health risks based on the levels ofcontaminants in people's air, water, food and in local soil and dust.

• The detailed assessment focused mainly on antimony, arsenic and cadmium andfound that:

• Estimated exposures to cadmium in the local population are wellbelow levels that might be associated with kidney disfunction.

• Estimated lifetime cancer risks due to arsenic and cadmium in thelocal population exceed the BC "default" standard of 1 in100,000. However, in the Trail population, exposure to smelter-related arsenic and cadmium might result in:

• no more than 1 extra case of lung cancer every 60 years orso

• no more than 1 extra case of skin cancer every 200 year orso


Summary Status Report to End of 2002

Source ReductionTeclc Cominco Emissions and Dust Control

Stack Emissions• In 2001, Teck Cominco assigned an environmental technician to identify, prioritize

and address opportunities for improvements in air emissions control systems.

• Opportunities for future improvements were identified and prioritized in 2001/02.Two top priorities were the existing stack emission control systems on the leadstack, the DRAACO baghouse stack and the silver refinery baghouse stacks.

• Various improvements were made, or are being made, to these three systems. Theperformance of the new baghouse on the lead smelter feed preparation plant hasbeen improved by adjusting the dryer operating temperature. The performance ofthe DRAACO baghouse on the #2 Slag Fuming Furnace is now being optimizedthrough round-the-clock operator coverage, implementation of a tight new StandardOperating Procedure and inclusion of this baghouse in the plant's Integrated ProcessManagement System (IPM). The newer ABB baghouse on the new #3 Slag FumingFurnace has seen a complete changeover of bags and the adoption of a new cleaningsequence that better allows any problems with bags to be detected and dealt with.Comprehensive audits of the silver refinery baghouses led to recommendations fornew instrumentation for real-time monitoring of baghouse performance. The newinstrumentation has been installed and operators are now being trained in how tooptimize the performance of the baghouses using the new instrumentation and bestoperating practices.

Fugitive Dust from Property

• In summer 2002, community air lead levels and blood lead levels did not drop asexpected during/following the shutdown in August. The suspected cause was aprolonged drought and extreme wind events in late July and August. AlthoughTeck Cominco followed the same dust control procedures used during the longershutdown in 2001, more dust seems to have spread into the community in 2002.

• The Trail Health and Environment Committee, at its fall 2002 meeting, askedthat Teck Cominco report to the committee on plans to improve upon its on-sitedust control procedures.

• Teck Cominco made a report to the committee on January 14, 2003 whichreviewed the dust control procedures that were already in place, described theprocess that was used in the fall of 2002 to determine which areas and activitieson the property should have priority for improvement and outlined the plansbeing developed to improve procedures.


Community MonitoringBlood Lead Testing

2001

• testing focused on children 6-36 months of age in all Trail neighbourhoods.

• Clinic participation: 76%

• Geometric mean lead level: 4.7 |ig/dL (lowest seen to date in Trail)

• 16 children had lead levels > 10 fig/d

• 4 children had levels >15 ug/dL

• 1 child had a level >20 ug/dL.

• There was a significant difference between the geometric mean blood lead inarea 2 (4.1 ug/dL) and area 3 (5.7 ug/dL).

2002

• children 6-36 months were again tested

• Clinic participation: 75%

• Geometric mean lead level: 6.0 ug/dL

• 13 children had lead levels > 10 u. g/dL

• 6 children had blood leads > 15 (Ag/dL

• 2 children had levels >20 ug/dL

• There was again a significant difference between the mean blood lead level inarea 2 (5.0 u.g/dL) and area 3 (7.8 Ug/dL).

• In anticipation of a possible upcoming reduction in the U.S. CDC "level ofconcern" from 10 ng/dL, the Trail Lead Program has now adopted 10 u.g/dLas its individual level of concern. (Formerly, it was 15 (ig/dL)


I

Environmental Monitoring

Ambient Air - Lead

Annual average air lead levels at the key West Trail monitoring station continue tobe very low. As shown in the graph below, the average air lead level in 2002 was

Annual Average Air Lead LevelsWest Trail Station

1.00

o.eo

0.40

O.ltt

o.oo

OJS

0.11

(999 2000 200f 2002

WtitTnllSln. BC Ob/uctln (Annual Avg.) - - • World HtilthOrg.aulittlllnt (Annual Avg.)

the lowest yet recorded, other than during 2001, when Teck Cominco's TrailOperations were shut down for over 3 months. Prior to installation of the KTVCETlead smelter in 1997, annual average air lead levels at this station used to be in the0.80 to 1.20 |ig/m3 range. As shown in the graph, air lead levels in Trail are nowbelow the WHO's guideline of 0.50 |ig/m3, which a number of European countriesare proposing to adopt over the next several years. The U.S. EPA's current standardfor ambient air lead is 1.5 (ig/m3 on a quarterly average basis. (Note that for lead, theguidelines/standards are based on lead in total airborne particulate - not just a finefraction. This is appropriate because we're interested both the direct effect ofairborne lead through inhalation of fine particles and the indirect effect throughingestion of particles that fall out of the air onto surfaces.)

Ambient Air - Cadmium

Annual average air cadmium levels over the past several years are also looking quitepositive. As shown in the graph below, the annual average cadmium level inrespirable (PMio) particulate at West Trail has hovered around the level whichcorresponds to an estimated 1 in 100,000 incremental lifetime cancer risk - thedefault acceptable risk level in B.C. The goal is to maintain or improve upon thislevel of performance. (Note that for cadmium, we focus on the amount of cadmiumin the respirable fraction of ambient air particulate because we're interested mainly


in the direct effect of airborne cadmium through inhalation of fine particles.particulate is the fraction that is less than 10 um in size.)

Annual Average PM10 Air Cadmium LevelsWest Trail Station

0.06

0.05

0.04

0.03

13n(J

0.02

O.Of •

0.00

1998 1999 2000 7001 2002

\~m- Wett Trail Otla — BC Otyectfya (Annual Avg.) 11n 100,000 Risk Laval \

Ambient Air - Arsenic

Annual average arsenic levels in ambient air have shown an improving trend overthe past several years, as shown in the graph below. Arsenic levels in respirableparticulate have declined by about 50% since 1998, making some good progresstoward the level that corresponds with the estimated default acceptable risk level.Prior to the startup of KIVCET in 1997, the annual average arsenic level inrespirable particulate at West Trail station was about 0.10 |ig/m3.


Annual Average PM10 Air Arsenic LevelsWest Trail Station

0.11

0.10 •

0.03 •

0.08

sr-•ft "-07

g 0.08

7J 0.05u

? 0.04 •3

0.01

0.02

0.01

0.00

1398 200O 1001 3002

|-«- West Trail Data -—-BC ObleeUve (Annual Avg.) 11n 100,000 Risk Level \

Dustfall - Lead

It is clear from the graph below that metal loadings in dustfall are higher in thewinter months, when dispersion of smelter emissions is less effective. In summermonths, the total dustfall increases (not shown on this graph), while the metalloadings hi dustfall decrease. This indicates that the deposition of metals fromairborne participate is still largely influenced by activities at the smelter site, asopposed to redistribution of historically-deposited material.

The graph also shows that the dustfall lead loading did drop during Teck Cominco'sAugust 2002 shutdown, despite the windstorms that were noted that month.However, the dustfall lead levels recorded in August 20C2 were generally somewhathigher than those recorded during the 2001 shutdown.


Monthly Lead in Dustfall2001-2002

-Downlown

-Glenmerty

•Daniel Street

Street Dust - Lead

800 •

700 •

500 •

Pbmg/m'400-

300

200

100 -

0

Street Dust Sampling - Average for 6 Stations In TrailPb mg/m1 vs Sample Date (September each Year)

/

/./

A/ \

\ ,vV

A/ \\V,

s /V

A/ \ /

/V

///

94-3 95-3 96-3 97-3 98-3 99-3 00-3 01-3 02-3

Sample Yiar • Quarter


IIIIIIIIIIIIIIiiiii

The graph above shows the street dust lead loading (average for 6 stations) measuredin September of each year from 1994 to 2002. The graph shows a decline in leadloading after 1997, but a return to a relatively high level in 2002. This is perhapsdue to the prolonged drought in 2002 from late July through October, which allowssettled dust to accumulate on roads without being washed away by rain.

Community Exposure ReductionDust Control

Greening• Teck Cominco is has completed various revegetation projects on its

properties in Trail, as well as contributed to greening projects in thecommunity. Teck Cominco has provided about $20,000 in funding plusmaterials for projects carried out by the City of Trail and the Trail FlyingClub over the past several years.

• Teck Cominco retained a consulting team to develop a phased design forrevegetation of the riverbank below Trail Operations. The total projectcost is estimated at over $2,000,000, including terracing of the slope forstabilization.

Dust Suppression on Roads• Each year, the City of Trail grades the alleys and arranges/supervises the

contract application of magnesium chloride in mid-June. Teck Comincoand the City split the costs in Trail and at the Beaver Creek campgroundand Teck Cominco pays for additional work in other locations outside theCity limits.

Street Cleaning• The City of Trail has continued to perform at least two extra

sweeping/flushings after the major spring road cleanup in all residentialareas of Trail. The City tries to ensure that the roads are pre-wetted priorto the sweeper brush hitting them so that clouds of dust are not stirred upin the process.

Miscellaneous Dust Control

• Teck Cominco accompanied the BC Ministry of Water, Land & AirProtection on an inspection of the Trimac reload centre in Waneta inMay. The Ministry was pleased with site housekeeping and new measuresin place for cleaning trucks and controlling dust.

• The graph on the below shows zinc loadings in dustfall collected at theTrimac facility, compared with those measured at one station in Trail.The Daniel street station was selected for comparison because that stationis within the area of influence of the smelter, but well off thetransportation path for concentrates coming from Trimac. Since thefacility is mainly handling zinc concentrates, zinc is the best parameter tolook at to estimate dust losses from the site and from the trucks leaving

2003 Program Strategy, Page IS

the site. The graph shows that zinc in dustfall at the Trimac site isconsistently much lower than that at the Daniel St. station. In August2002, the level at Trimac jumped up to equal the level recorded at Daniel

Monthly Zinc in Dustfall2001 • 2002

7.00

6.00

5.00

4.00

3.00

2.00

1.00

0.00

P • • Daniel Street Trimac I

Street during the smelter shutdown, but then it returned to its usual lowlevel by the following month.

Smelter Buffer Zone• In May 2001, Teck Cominco planted 80 evergreens trees (12-16 feet tall) in the area

near the old training centre, in the vacant lot at 303 Kootenay Avenue and along thesouthwest boundary of the Tadanac soccer pitch, following consultation with theTadanac Residents' Association.

• In 2002,29 additional trees were planted to complete the strip along the TadanacSoccer Pitch boundary with Maple Road.

Work Project Assistance Program• Cheryl Yates and Steve Hilts traveled to Idaho in April 200land Missouri in June

2001 to study the approaches being taken to remediation and risk management atboth inactive and active smelting and mining sites.

• No progress was made toward the WPAP in 2001 - 2002, due to timeconstraints. Follow-up services in association with the case managementprogram assisted families with contaminated yard materials disposal andassistance/advice were provided to people doing work projects on an ah-hocbasis.


Case ManagementFollow-up Blood Testing, Home Visits, Environmental Assessments

• Interior Health conducted follow-up winter blood testing clinics in February2001 and February 2002, doing repeat lead testing on children with elevated orrising blood leads from the previous fall clinic. Also invited are infants betweenthe ages of 6 - 11 months, who have not previously been tested.

• Beginning in 2002, children included in the case management group were thosewith lead levels > 10 ug/dL, and for children younger than 12 months of age,those with lead levels > 7 ug/dL. The case management group also includesthose whose lead levels were noticeably increasing (BLL greater than 3 ug/dL)over one year.

• In general, the follow-up winter clinics saw reductions in individual children'sblood lead levels from September to February. This is an expected outcome, dueto seasonal variation in weather, less outdoor play and reduced indoor lead dustlevels in Trail.

• Follow-up home visits and in-home environmental assessments were offered toall families with children who have elevated or increasing lead levels. Homevisits and environmental assessments are done primarily within a week ofreporting an elevated or rising lead level to a parent. In 2001,12 home visitswere conducted. In 2002,17 home visits were done in Trail.

Services/Assistance• Interior Health determined appropriate and required assistance to be offered in

2001/2002, in terms of addressing house dust, bare soil, or deteriorating lead-based paint. Throughout 2001 and 2002,56 families benefited from assistance toreduce indoor dust, cover bare soil, and clean up lead-based paint.

• Money spent in 2001-2002 for services/assistance through the case managementprogram was $40,000,e venly divided between Interior Health and TeckCominco.

• The case load, funding levels and assistance policies have been reviewed byInterior Health and Teck Cominco and the Trail Health and EnvironmentCommittee as well.

EducationCommunity Education & Awareness

• In the spring of 2001, Interior Health and Teck Cominco, with input from theCity of Trail, developed a new full-colour brochure outlining what services areavailable and who to contact about them. The brochure was very well receivedby the community.


Iiiiiiiiiiiiiiiiiii

• Also in 2001, a new logo was created for the Trail Health and EnvironmentCommittee. This logo became the foundation for an annual newsletter mailed toevery household in Trail.

• Interior Health ran a radio and newspaper educational campaign throughout thespring, summer and fall of 2001 on topics such as: lead and pregnancy, bloodlead testing, and reducing lead in the home and yard.

• In 2002, a new Lead Health brochure was developed which combined andupdated the information found in the original series of Task Force brochures.This new brochure is available through the Trail Health Center, Dr. clinics, andTrail Regional Hospital maternity ward. Brochures are also mailed to newfamilies when they are invited to have their children tested.

Early Childhood Education• Interior Health staff offer presentations to groups such as Mom & Me, day cares,

nursery schools and the Building Beautiful Babies.

• Storybooks aimed at preschoolers are distributed through day cares andpreschools, as well as materials, such as soap and stickers, to go with thestorybook program.

Oversight and Coordination• The Trail Health and Environment committee met for the first time on July 11,

2001. At this meeting, the committee:• made some slight modifications to the terms of reference drafted

by the Lead Task Force and adopted them• discussed whether the scope of issues dealt with by the committee

might include socio-economic issues• decided to invite the business community to appoint a

representative to the committee• At subsequent meetings, the committee has heard reports from the Interior Health

Authority and Teck Cominco on their implementation of Task Forcerecommendations and has made requests for additional information or action.

• The committee recently decided that it would like to hear informally about anyenvironmental issues affecting Trail that the City, Province or Teck Comincomight become aware of from time to time.


2003 PROGRAMS/SERVICES

This section provides information on how each of the Trail Community Lead Task Force'srecommendations will be addressed in 2003.

1. Source Reduction

1.1 Teck Cominco Emissions Control and Reduction

Purpose:

• Emission reductions are still believed to be the single most effective way to:• further reduce children's blood lead levels• further reduce possible health risks from other smelter contaminants

Description:

• The Task Force recommended that:

• Teck Cominco should regularly ( at least semi-annually) communicate thefollowing to the public:

• The process by which opportunities for further emission reductions arebeing explored

• Goals, projected timelines and progress on emission control projects(including plans for reducing stack emissions, fugitive plant emissionsand materials handling losses).

• Teck Cominco should ultimately include its goals and timelines for emissionreductions in the final remedial plan for the area

Implementation/Responsibilities:

• Teck Cominco will continue to report regularly to the Trail Health & EnvironmentCommittee on its plans and progress for further emission reductions

• Teck Cominco will also report on emission reduction plans and progress in mediaadvertisements and in the joint Trail Health and Environment Committee newsletter

Stack Emissions

• Teck Cominco will continue to optimize the operation of its stack emission controlsystems, as described in the Status Report section, and to replace equipment andinstrumentation as needed.

On-site Dust Control

"Beach/Flats" Material Unloading and Mixing

• Over past several months, Teck Cominco has managed to avoid dumpingany drosses at the "Flats" by staying "in balance" with their processes.


However, a water spray system is scheduled to be installed on the bins insummer 2003 anyway. (-$20,000)

• A wind flag was installed at the Flats so that mixing/screening activitiescould be ceased when the wind is blowing away from Trail Operations.

• A "highways type" loc-bloc and tent structure (25' x 60') is being installed insummer 2003 at the lead mix area so that mixing of secondary lead smelterfeeds can be done under shelter. The structure will be open at only one end.(-30,000)

• Additional paving is being done at the Beach/Flats to provide a smoother,easier to clean surface. (-$10,000)

Zinc "Roaster Mix" Area

• A water spray system was installed on the bins in spring 2003, so that thematerials can be wet preventatively, rather than waiting to call a water truckwhen the materials appear dry/dusty. (-$20,000)

Effluent Treatment Plant Residue Piles and Other Stockpiles

• Cost of covering the large ETP residue piles with a geomembrane is about$450,000. This item has been included in the Trail Ops capital planningprocess, for consideration along with other possible environmental projects.

• Alternatives to covering this pile are being implemented year - e.g. morefrequent spraying with dust suppressant

• All uncovered stockpiles were sprayed on about May 6,2003.

• Repairs to existing geomembrane covers on stockpiles will be made thissummer. (-$30,000)

Estimated Expenditures: (considered external to the three-agency action budget)Teck Cominco

Emission control systems operation and improvement >$250,000Dust control procedures/systems improvement ~$ 110,000On-site greening projects $38,000


2. Community Monitoring

2.1 Blood Lead Testing

• to identify children with elevated or rising blood lead levels• to assess community-wide impact of remedial actions• to determine whether the blood lead goals have been reached

Description:

• Regular annual blood lead testing in late summer/early fall will be recommended forchildren aged 6-36 months (older children will not be denied testing if their parents areconcerned).

• Follow-up blood testing will be recommended for children with blood lead levels of 10ug/dL or higher, and for children under 12 months who have blood lead levels over 7ug/dL.

• A complete blood lead survey of children aged 6-72 months will be conducted inSeptember of 2005, then every 5 years.

• Blood samples will be collected by venipuncture and analyzed for lead. In 2003, a portableblood lead analyzer will be purchased and used during testing clinics. This will allowInterior Health staff to report blood lead results to families while they are on site. Bloodtesting results will be provided to family physicians, if requested.

• Summary results will be presented to the Trail Health and Environment Committee inNovember 2003.

• A rigorous quality control program will be followed to ensure accurate and reliable results,using BC Children's and Women's Hospital laboratory.


• Interior Health will conduct the blood testing clinics, arrange and pay for laboratoryanalyses and report the results.

Funding committed: Interior Health

Equipment, Supplies and Services $ 1,000Annual Fall Clinic $6,500Annual Winter Clinic $ 1,500Support staff $3.500

$12,500


2.2 Environmental Monitoring

• To assess the collective, community-wide impact of remedial actions (e.g. emissionreductions, street washing, greening, soil barriers, dust suppression)

2.2.1 Ambient Air Monitoring

Description:

• Ambient (community) air monitoring is one of the best measures for monitoring changes incommunity conditions. Teck Cominco operates two main ambient air monitoring stationsthat measure metals (lead, zinc, arsenic and cadmium) in the air. These two stations (atButler Park and Genelle) sample the air for 24 hours once every 2 days. In addition, TeckCominco is continuing to operate its ambient air monitoring station at West Trail at leastuntil the end of 2003 and its stations at Columbia Gardens and Northport until 2005. Datafrom the West Trail station have been relied upon by the Lead Task Force and Trail Healthand Environment Committee for the past 6 years or so. Therefore, the relationship betweendata collected at W. Trail and the Butler Park station will be reviewed at the end of 2003.


• Teck Cominco Environment will collect and analyze samples, with review by the BCMinistry of Water, Land & Air Protection and Trail Health & Environment Committee.

2.2.2 Dustfall Monitoring Network

Description:

• Dustfall (a measure of particles settling out of the air) is another excellent means ofmonitoring changes in community conditions and assessing current rates of contamination.Teck Cominco has operated a regular network of about 15 dustfall stations in thecommunity for several decades. From 1992 to 2000, Teck Cominco operated additionalstations for the Lead Task Force, bringing the total network to about 38 stations.

• A memo to Teck Cominco from Trail Lead Program staff on October 5, 2000,recommended that 6 of the special dustfall stations operated for the Trail Lead Programbe retained and added to Teck Cominco's regular dustfall monitoring network.

• Dustfall jars are changed monthly and analyzed for total dustfall and loading(mg/dm2/month) of le;


(mg/dm2/month) of lead, arsenic, cadmium and zinc.


Teck Cominco Environment will collect the samples from the network and samples willcontinue to be analyzed at Teck Cominco Analytical Services, with review by BC Ministryof Water, Land & Air Protection and Trail Health & Environment Committee.

2.2.3 Street Dust Monitoring

Description:

• Lead in street dust was monitored by the Trail Lead Program as part of the Sentinel Homesproject. Street dust lead loadings declined by about 50% after 1997.


• Street dust sampling will be conducted at a density of one sampling station perneighbourhood, except there will be 2 stations in East Trail. Street dust sampling stationsare located near dustfall monitoring stations.

• Teck Cominco Environment will collect and analyze the samples, with review by the TrailHealth & Environment Committee.

FundingLCommitted: Teck ComincoAmbient Air Monitoring $22.000Dustfall Monitoring ' $15,000Street Dust Monitoring $3,000

$40,000

COMMUNITY MONITORING TOTAL: $60,500


3. Community Exposure Reduction

3.1 Dust Control

Purpose:

• to further reduce children's blood lead levels by reducing dust movement andaccumulation in the community

• to further reduce possible health risks from other smelter contaminants

Description:

Greening:

• The Task Force stated that greening of bare areas is a high priority, andrecommended that Teck Cominco and the City communicate their plans for this.

• An inventory of remaining bare areas will be prepared and used to set prioritiesfor action. Areas where action is taken will be monitored to ensure success.

Dust Suppression on Roads:

• Dust suppressant will continue to be applied to alleys and other unpaved areas inTrail at least once per year.

Street Cleaning:

• The Task Force recommended that street flushing and sweeping be performedaccording to the correct procedure and at the current frequency in the City ofTrail and Rivervale (highways maintenance contractor responsibility inRivervale and on highways through Trail).

Miscellaneous Dust Control

• Trucks transporting concentrates to Teck Cominco from Waneta reload stationshould be required to take appropriate steps to reduce losses along the route.


• Teck Cominco and the City of Trail, with assistance from the Trail Health & EnvironmentCommittee, will identify and prioritize candidate areas for greening.

• The City of Trail will arrange and supervise the spraying of magnesium chloride.

• Teck Cominco will monitor and report on the steps that are being taken by Trimac.

• Teck Cominco will also continue greening on its own properties.

Funding committed: Teck Cominco City of TrailGreening city lands $10,000 $Dust Suppression on Roads $5,000 $4,400Street Cleaning (hard to say how much is extra)

$25.000?


$15,000 $29,400

3.2 Smelter Buffer Zone

• to reduce the exposure of residents to dusts from Teck Cominco emissions (primarilyfrom the intermediate product stockpiles)

Description:

• Teck Cominco will develop, communicate and implement a plan to expand/enhance thevegetative buffer within and adjacent to the property boundary (e.g. more trees, earthmounds), commencing in Spring 2001 and continuing as stockpiles are consumed.

• Teck Cominco will endeavor not to remove any additional structures from this zone untilthe vegetative buffer is well established and has reached a height of at least 20 feet.


• In May 2001, Teck Cominco planted 80 evergreens trees (12-16 feet tall) in the area nearthe old training centre, in the vacant lot at 303 Kootenay Avenue and along the southwestboundary of the Tadanac soccer pitch, following consultation with the Tadanac Residents'Association.

• In May 2002, Teck Cominco planted 29 additional large evergreen trees to complete thestrip along the Tadanac soccer pitch boundary.

• The vegetative buffer strip will now be monitored by Teck Cominco, with replacement ofdead or diseased trees as needed.

Funding committed:Teck Cominco

Tadanac buffer strip trees project for 2003 $0


3.3 Work Project Assistance Program

to encourage homeowners and contractors to follow precautions when undertakingexcavation, construction, demolition or renovation projects, in order to minimizedust exposure to workers and residents.

to provide assistance to people who need to dispose of contaminated soil or dust.

this program is not meant to encourage people to undertake projects such as soilreplacement. Instead, it is intended to make it safer and easier for people who, ontheir own, have decided to do some work on their properties.

Description:

• A program should be set up to provide assistance with excavation, construction,demolition or renovation projects.

• The assistance for such projects should address dust control, worker exposure, residentexposure, neighbours' exposure, and disposal of contaminated materials (e.g. soil, dust,paint chips, painted materials).

• Assistance offered through the program may include:

• Advice concerning steps to take to minimize exposure to contaminated soil anddust

• Free disposal of contaminated soil or dust

• Free clean soil to replace the volume of excavated contaminated soil, ifnecessary.

• An education program should be set up so that the community (includingcontractors) is aware of the WPAP and how it works.

• A training program should be set up for contractors and public works employeesso that they competent in the control of dust and disposal of contaminatedmaterials.

• Bunker Hill Supertund Site has set up a comprehensive program that has beenstudied as a possible model for some elements of Trail's program.


• Teck Cominco will develop and fund this program. A contractor may be hired to assist withprogram development. Program development will begin in 2003.

Funding committed:

Teck ComincoProgram development $20,000

COMMUNITY EXPOSURE REDUCTION TOTAL: $64,400


IIIIIIIIIIIIIIIIIII

4. Case Management

• to reduce higher-risk children's exposure to lead in dust, soil and paint.

Description:

• The following services will be provided for families of children with blood lead levels of10 ug/dL or higher, and families of children under 12 months age with blood lead levelsgreater than 7 ng/dL:

• Home visits to provide counseling/advice on reducing lead exposure• Blood and environmental results will be reviewed with the family, a

behaviour and lifestyle assessment completed, and practical advice to lowerlead exposure given.

• In-home environmental assessment• To determine which areas should be targeted for lead hazard control (dust,

soil, paint)• Assistance in addressing bare soil, house dust, or deteriorating lead-based

paint

• Follow-up monitoring of blood lead levels

• Children's blood lead results will be reviewed at subsequent clinics (winteror spring) and further assistance/services will be offered if required.

• Assistance to day care and preschool centres in addressing bare soil or indoor dust.


• Interior Health will conduct follow-up for families of children who have elevated or risingblood lead levels. Interior Health, with input from Teck Cominco, where requested, willdetermine the appropriate and necessary assistance to be offered. Interior Health and TeckCominco will each provide up to $ 10,000 for the 2003 case management program.

• Teck Cominco will provide additional funding if required to address urgent needs of anychild found to have a blood lead level of 40 u,g/dl or higher.

Funding committed:Interior Health Teck Cominco

Case management materials/services $ 10,000 $ 10,000


5. Education

5.1 Community Education and Awareness

Purpose:

• to inform the public (particularly new parents and new residents) about what they can do tokeep children's blood lead levels low, and to let people know about available services

Description:

• The following community education program elements will be provided:• brochures• information for families new to Trail• display stand at community events such as Teddy Bear Picnic• radio and newpaper advertising• newsletters• information for pregnant women and new mothers


• Interior Health and Teck Cominco will work together with the Trail Health & EnvironmentCommittee to develop materials and campaigns. Funding will be provided by InteriorHealth and Teck Cominco as outlined below.

Funding committed:Interior Health Teck Cominco

Newsletter $1,500 $1,500Work Project Assistance Program Brochure $3,000Advertising $4,000Community projects $1.000

$6,500 $4,500


II

5.2 Early Childhood Education

Purpose:

• to encourage pre-schoolers to adopt healthy behaviours in order to:• keep their lead exposure risk and blood lead levels low• keep them in good general health

Description:

• The following early childhood education program elements will be provided:• visits to day cares, nursery schools, Building Beautiful Babies

program, Mom and Me• provision of storybook to new child care providers• provision of materials to go with storybook program (e.g. soaps,

stickers)• This opportunity to reach pre-schoolers will also be used to present other hygiene,

nutrition and health messages.


• Interior Health will work together with the Trail Health & Environment Committee todevelop materials and campaigns. Funding will be provided by Interior Health.

Funding committed:Interior Health

Educational and promotional materials $ 1,000

EDUCATION TOTAL: $12,000


IIIi

• iu ciiiuic 11 id I 111C guilts me aucuucu 111 a. uuiciy uiaiuit,!

I « to ensure effective monitoring, coordination and evaluation of progress toward the goals

• to ensure effective oversight by, and communication with, the community

I

I

I

I

I

I

I

I

I

I

I

I

I

I

6. Oversight and CoordinationPurpose:

to ensure that the goals are attained in a timely manner

Description:

• A committee has been established to ensure that the program does not suffer fromfragmentation or loss of credibility and to facilitate public communication and oversight.

• The committee will ensure that there is no discontinuity of service between dissolutionof the Trail Community Lead Task Force and implementation of the final remedial planfor the area.

• The committee includes representatives from the City of Trail, Interior Health Authority,BC Ministry of Water, Land & Air Protection, Teck Cominco, United Steelworkers ofAmerica, the Greater Trail Community Health Council and the community (similar tothe current Task Force).

• The committee has been appointed by City of Trail.

• At its first meeting the committee should review the Draft Terms of Reference that wasbeen prepared by the Trail Community Lead Task Force.

• The initial mandate of the committee should be to monitor, coordinate and advise on theimplementation of the Task Force's recommendations and to participate directly indevelopment of the final remedial plan. Once the remedial plan has been approved, therole and reporting responsibility of the committee should be re-evaluated.

Responsibilities/Actions:

• The Trail Health & Environment Committee operates as a committee of the City of Trail.

Membership:

Chair: Dieter Bogs Mayor, City of TrailAmes, Dr. Nelson Interior Health AuthorityDavies, Kate Community RepresentativeGraham, Al Councillor, City of Trail (alternate)Dimock, Dr. Barss Community RepresentativeHilts, Steve Teck Cominco Metals, Ltd.lohnson, Carl BC Ministry of Water, Land & Air ProtectionJoseph, Ron Community RepresentativeKenyon, Graham Community RepresentativeHomey, Ralph Councillor, Village of WarfieldRakuson, Marylynn Greater Trail Community Health CouncilYates, Cheryl Interior Health AuthorityWynn, Tom United Steelworkers of America, Local 480

Whitlock, Rosemary Recording secretary


TECHNICAL COMMITTEE

Role: Terms of reference yet to be established.

Meetings: This committee will meet as needed.

Members: Dr. Nelson Ames -Interior Health Authority - ChairNelson was involved with the original Trail Lead Study in 1989 as a masters studentwith UBC and served as a member of the Lead Task Force throughout its duration.Nelson is Medical Health Officer for Kootenay Region for Interior Health Authority.

Phone: (250) 354-6853Fax: (250)354-6304E-mail: [email protected]

Cheryl Yates -Interior Health AuthorityCheryl served as the research nurse with the original Trail Lead Study in 1989.Cheryl was Health Coordinator for the Trail Lead Program. Cheryl is now the publichealth nurse in charge of Lead Health Services for the Interior Health Authority.

Phone: (250) 368-LEAD (368-5323)Fax: (250)364-0580E-mail: [email protected]

Steve Hilts - Teck Cominco Metals, Ltd.Steve was Environmental Coordinator for the Trail Lead Program and is nowSuperintendent of Environmental Remediation for Teck Cominco Trail Operations.

Phone: (250) 364-4385Fax: (250) 364-4144E-mail: [email protected]

Kate Davies - Community Representative

Phone: (250) 368-6078Fax:E-mail:


SUMMARY OF 2003 FUNDING COMMITMENTS

Interior TeckHealth Cominco City of Trail Total

SOURCE REDUCTIONTeck Cominco Emissions & Dust Control >$400,000 (not included in totals)

COMMUNITY MONITORINGBlood Lead TestingEnvironmental Monitoring

$12,500$40,000

$52,500

COMMUNITY EXPOSURE REDUCTIONDust ControlGreening projectsWork Project Assistance Program

$5,000$10,000$20,000

$29,400$64,400

CASE MANAGEMENT

EDUCATIONCommunity Education & AwarenessEarly Childhood Education

$10,000 $10,000

$6,500$1,000

$4,500

$20,000

$12,000

2003 TOTALS $30,000 $89,500 $29,400 $148,900


References

Cominco Ltd., 1993. Emissions Management Report, Trail Operations, 25 pages.

Hertzman C, Ward H, Ames N, Kelly S and Yates C, 1991. Childhood lead exposure in Trailrevisited. Canadian Journal of Public Health, 82, 385-391.

Neri LC, Johansen HL, Schmitt N, Pagan RT and Hewitt D, 1978. Blood lead levels in childrenin two British Columbia communities. In: DD Hemphill (ed.) Trace Substances inEnvironmental Health XII; Proceedings of the University of Missouri's 25th Annual Conferenceon Trace Substances in Environmental Health, 6-8 June 1978, pp. 403-410. Columbia,Missouri.

U.S. Environmental Protection Agency, 1986. Air Quality Criteria for Lead. EnvironmentalAssessment and Criteria Office, Research Triangle Park, N.C.


TRAIL LEAD PROGRAMPower Point Presentation used in public meetings

"Fall 2003 Blood Lead Results "

Fall 2003 BloodLead Results

Presentation Overview

Participation Rates

2003 ParticipationBreakdown byNeighborhoods # Children

Contacted# Children

Participating% Children

Participating ParticipatingAREAS (Children <3 years)

72% (13)East Trail84% (16)West Trail100% (2)50% (2)

(< 3 years)AREA 2 (Children < 3 years)84% (26)Glenmerry50% (5)Shavers Bench

68% (13)Sunningdale73%(44)AREA 2 TOTAli

•'̂ 4'-\K-'--J ''X-<5~ *"• V/j£?s5J!J*t

Participation Rates (conn)

GroupArea 2/3

ParticipationRate (2003)82% (14 of 17)Infants not tested

before

Case Management 100% (9 of 9)

ParticipationRate (2002)

94%

94%

Other (<36 mos.) 81% (59 of 73) 66%

Blood Lead Histogram: Area 2/3(Age 6 mos. - 36 mos.)

Ge metric itiilH 5Range = 10|jg/ciL

= 15|jg/dL1%>=20|ig/dL0%>=25jjg/dl

2 6/ ; 'I'OA..'1/o ••• :Jj /a • .--.

o% o% 0% 0%

2-3 4-5 6^7 8-9 10- 12^14r 16- 18- 2a|; 22- 24- 26- 28-11 13 15:^17 19 21? 23 25 27 29

Blood Lead Ranges (|jg/dL)

Blood Lead Histograms: 1991-2003 shift

c 30%

2 25%

O 20%

Areas 2 & 3: Gmldr£ri< 37imonths

199119962003

Blood Lead Ranges (Ug/dL)... .-L ' ..'— . f^^- .1 - tu \ .^ •' \ ^^ -:-.•*.--•• »

2005 Goal

Trend in Percentage of Children

C

with Blood Lead Levels < 10 |jg/dl

100% -i

c 90% -

£ 80% -T3]E 70% -

U 60% -

£ 50%-

j? 40% -^j ̂ §0/

/i \ *^ ̂ ^ /O

S 20%:^ 10% -

0% -

(6-36 months throughout)

Pre-KIVCET(1991-1996) J

•̂

H

II

E^JI

iI

[ X

i —I

j«»

I

)» 0

s ....{.-I-..,

Post-KIVCET(1996-2000)

l l li i i

[

Ii

^ ("4^

Comparison with "background"

25

-a(0

T3O£

co0)O>CO

Q)

20

15

History of Children's Blood Lead Levels in Trail

10

5 -

US Avg -6 mos -6yrs

Trail1975: 1-3yrs1989: 2-5 yrs1991-00: 6-59 mos200103 6-36 mos.

New Lead Smelterstarted

cor-.r-co

<ni*. ooCD

COoo

toooo>

h-ooCO

COooCO

COCO

COCDCO

vnCOCO

COCO

COCOCO

6-0 5.7

OOCM

eoOO<M

Trail: 12-36 mos. Trail: 24-60 mos. •Trail: 6-60 mos. "rail: G-36 mos. • US National Average

2003

30

25_JT3

IE 2°~oCB dcS 15

E 10O

DO

0 ..

(0)(0)(0)

(0)

(0)(1)(1)(4)

(0)

(0)(2)

(10)

„——-—•• ~~ "

T I

Area 1

( ) Number of children

Area 2

in range

i

Area3

-a- Average

g£!iflia

i gI H-l

oo

I—<

PQcCJO)

O>

O

O!I

Blood Lead Geo Mean by Area(age 6-36 months throughout)

Comparison with Other Sites

City/Region Country Nature of sitePort Pirie AustraliaTrail CanadaRouyn-Noranda CanadaNation-wide U.S.A.

Age of kidstested

Primary Pb smelterPrimary Pb smelterPrimary Cu smelterUrban/rural (NHANE8)

Year9 mos to 5 yrs 20016 mos to 3 yrs 20036 mos to 5 yrs 1999

1to5yrs 1996-'99

Average;Blood Lead

Level(ug/dL)

9.85.75.22.0

Three Distinct PeriodsGeometric Mean Blood Pb, 6-36 mos. throughout

14 -

f

"8 10CD

T3O£CO£03CD

O'L.+jCD£oCDO

8

6

4

2

0

11.6

2001 removed because it wasabnormal: 3+ mos. completesmelter shutdown

1989 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003

Lead in Air: Month of AugustOnly, West Trail Station

Lead (|jg/m3)94-'96avg.1.20

1997

0.50

1998

0.22

1999

0.29

2000

0.42

2001

0.03

2002

0.18

2003

0.17

Lead in Dustfall: Month of AugustOnly, Area 2/3

Lead (mg/m2/day)

94-'96avg.

2.0

1997

1.5

1998

0.6

1999

1.4

2000

1.4

2001

0.23

2002

0.54

2003

0.49

•"**;

T3CO0)

Trends in Geometric Mean Blood Lead andAugust Air Lead

(Children aged 6-36 months)

T 14

1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003

;o

zi

"rt

T3O_oCO

o

Io0CD

Susp. Partic. Pb in Area 2/3 in August B Geo. mean blood Pb

2.40 -i

Air Lead LevelsWest Trail Stn Jan 2001 to present

Lead in Ambient Air (West Trail)(In total partlculate)

\ Lead Quarterly Avg. BC Objective (annual avg.)

TRAIL LEAD PROGRAM, Community Newsletter

"Reaching Out-Volume Two, Issue One, Spring 2003"

Lead Levels up Slightly

During Hot, Dry -Summer

HEALTH*ENVIRONMENT What is Teck Cominco

Doing to Deduce Emissions?

V O L U M E T..W O, I S S U E ON E, S P R I N G 2 O.<0 3

Lead Levels Up Slightly During Hot,Dry Summer

What is Being .Done to

Control Dust Levels out.

In the Community? •

page 4 ^ _ .Thallium Levels Low In Trail

Despite a general-.downward trend in children's blood

lead levels in Trail, testing in 2002 showed slightly higher.»

.average levels than the previous year. While the results

arevho cause for alarm, they-serve as a good reminder of

•the importance of personal and household habits that

reduce exposure to lead.

Why the increase in lead levels last fall? "Although Teck

Cominco shut down the smelter in August and followed

the same dust control procedures used during the longer

shutdown in 2001, more dust seems 1o have'spread into

the community in 2002." • '

For the past two years, the Trail Lead Program has

focused its testing on children less than 3 years old.

That's the most vulnerable age

group due to a tendency for little,

explorers to put fingers and other

objects Into their mouths often.

Participation in the blood lead

testing clinic was down slightly in

2002, with 75% of invited children

attending. The graph to the-..right

shows the history of children's

blood lead levels in Trail compared

to background lead levels in

the U.S.'.

The. range of blood lead levels in 2002 was 1.5 - 22.8-

ug/dL. Eighty-three percent of children had levels below.

10 ug/dL'and 9'2%.had levels below 15 ug/dL. In 2003 we

hope to corrie even closer to the goals set for 2005:I •

B At least 90% of children with 'blood lead levels less

than 10 ug/dL. . -

•-At least 99% of children with blood lead levels less

than 15"-ug/dL . " '

While we're making progress toward long-term goals,

infants and toddlers in this community are still vulnerable

to lead exposure. Fortunately, there are easy ways to

minimize their risk. Hand washing [s one of the healthiest

continued to page 2

History of Children's Blood Lead Levels In Trail

"Lead Levels Up Slightly During Hot, Dry Summer" continued from page 1

habits we can teach our youngsters. It's also important

for families to remove shoes at the door and keep floors

clean by vacuuming and damp mopping.

To all the families who' participated in the fall 2002 blood

lead testing clinic, we say a big thank you! We can all do

our part to keep children in this community healthy. 0

What Is Teck Cominco Doing To Reduce StackEmissions And Dust From Its Property?Why is it important to reduceemissions further?

Folks' who've Hved'in the Trail area for

a while know that the air quality has.,improved substantially, especiallysince the hew Teck Cominco leadsmelter started up'in 1997. Not only

. has the air become visibly cleaner,

but levels of lead, arseni.c and cadmi-

/ um -in community air dropped by

70 - .80% from 1995 to 1999.

However, the Trail Community Lead

Task' Force recommended in 2001

'that the best way to further- redgce

potential health risks from metals in

Annual Average Air Lead LevelsWest Trail Station .

the environment would be to keep

improving air quality. Even thoughyoung children receive most of their

lead -exposure' through hand-to-mouth activity rather than breathing,much of' the lead in dust In theirenvironments comes -from recent,

smelter emissions:

How are stack emissions beingreduced?

1.20-

1.00.

Io§

.o13

o.ao_

0.60_

<=. 0.40J

0.20_

0.27 0.25

West Trail Station

_.._„ BC.Obj?ctive (Annual Avg.)

____ World Health Org. Guideline (Annual Avg.

In 2001, Teck Cominco began aproject to find the top priorities for

improvements in emission controfs.

The project focused first on the

various type's of systems that

capture metals beforethey can get up stacks.The plants that were

releasing the most.metals

. were • addressed . first.Operating procedures for

1 the plants and for their

emission control equip-ment were improved so

that their performance

would be more consistent.Environmental monitoring

results are reported dailyto the plants to provide

feedback on performance.The graph below shows

that, other than in 2001

when Trail Operations was •

shut down for. over 3

months, 2002 Saw the

lowest.annual average air

lead level since the new lead smelter

started operating.'

How is dust from the property

being reduced?

A top priority for. 2003 for .Trail'

Operations is to find ways .to further

reduce the risk of dust losses from

material stockpiles on the property.

Currently, many of the large stock-

piles are covered with "tarps" and

others are sprayed with dust sup-,pressant and monitored regularly.

On-property roads are also cle'aned

frequently. • :

However, as noted in the story onblood lead levels, the. unusually dry

'and windy conditions in the summer'

of 2002 appear to have led to dust

being blown from the smelter

property into the commuriity. TeckCominco ifias identified the highest •

priority material stockpiles and isdevelpping an action Van to*"put In

place by spring. New actions for -

improved dust control may includethe' use of water sprays, different

types of dust suppressants, addition-

al "tarps" on some piles or enclosing

some piles-in buildings.

The community of Trail can expect to

see continued improvements in air

quality, and to receive ongoing

reports on Teck Cominco's emission ,• *

reduction plans and progress.«

2

What Is Being Done To Control Dust Levels Out InThe Community?Street Cleaning

The Trail Community Lead Task. Force also recommend-

ed that cleaning of city streets should be carried out

regularly using effective methods. In.the 4990s, the Task

Force found that .lead levels in street dust were high -

enough to be a potential source,of lead exposure to young

children if dust were to be. blown or tracked into homes. vThe Task Force monitored and reviewed the City of Trail's1

street cleaning 'program and suggested that not only was

it important to sweep and "flush" the street's several times

throughout the" summer, but that care must be taken to

.'avoid stirring up dust when performing the work.

Whereas in many other small towns, .the streets are

cleaned up in the spring and then do not see a street

sweeper again over the summer, the City.of Trail performs

at least two extra swe'eping/flushings after the major

spring cleanup. The cjowntown core is swept and flushed

weekly. The City also tries '

to ensure that the roads HfflHBnBBBHHRB

are'pre-wetted prior to the

sweeper brush hitting

'them, so that clouds of

dust are not. stirred up in

. the process. This.is- verydifficult to accomplish

during the spring cleanup • • "

when there's a lot of sand on the streets. Fortunately, the

sand applied to the streets over the. winter is "clean", so

the lead levels on the streets .during,spring cleanup are

relatively low.

Unpaved Alleys

As per Task. Force recommendations,, a Ipng-lasting,

' environmentally-friendly dust suppressant is applied 1o

unpaved alleys and other areas In and around the city in

June each year. -The cost of this program is split by trie

City of Trail and Teck Cominco. The City-also applies'

asphalt milling by-product from its pavipg program onto

'some unpaved roads or.road shoulders each year, to

provide more permanent dust control.

... the City of Trail performs at least twoextra sweeping/flushings after the majorspring cleanup. The downtown core isswept and flushed weekly. • ;'

City water truck cleans'up.

Greening . .

The City of Trail and Teck Cominco also continue to

work together to provide grass cover on bare ground

areas, .such as the

BBHBBBHBRHHHB hillside below Shavers

Bench. This work has

typically involved apply?

ing composted organic

material mixed with

sand, then hydroseed-

ing with a .drought toler-

ant grass mixture. ®

Dust control on city alleys.

3

Thallium Levels Low In TrailIn an incident .at Teck Cominco in

2001, contract workers were" exposed

to high levels of thallium during

' maintenance on a boiler. Thallium is

a haturajly occurring metal •common-

' ly found in~the ores that feep1 smelters

such as Trail Operations." •

The incident prompted Teck Cominco

to review thallium levels in air, soil,

and garden produce to ensure there

• was no1 hazard for the'community-a*.

large. The review showed thallium

• content of -samples to be slightly

higher than background levels, but

lower than levels associated with a

health risk.

Further to that.review, the Trail Health

and Environment Committee and the

Interior Health Authority recom-

mended a study of urine thallium

levels in Trail residents.

The; study wa"s run in conjunction

with the 2002 blood lead testing

clinic. Researchers Invited 50

parents "of. children attending the

lead, clinic to be tested for thallium

exposure. Subjects Included resi-

dents in neighborhoods close to the

smelter. Theje was an equal split

between people who eat produce

grown in the Trail area.and those

who do not."

Participants were interviewed' by

phone to make sure they represent-

ed the general population. No

one with a possible occupational

exposure was included in the study.

Study participants provided urine

specimens, which were sent to a

hospital in Vancouver for analysis.

The average Urine thallium level was

0.25 micrograms per litre (ug/L), with

all results well below the World

Health Organization guideline for the

general population of 5.0 ug/L. There

was no.significant difference in urine

thallium levels between- consumers

and non-consumers of locally grown

produce. . • '

Thank you to all those who participat-

ed in the thallium study. It 'is

' reassuring to know that the average

urine thallium level "in 'Trail is

comparable to that of the general

population in the US. C •

Educate Yourself About LeadHie Trail Lead Program (through Interior Health 368-5323)has many education projects ongoing In the community:• In 2002, a new Lead Health brochure was developed

which combined and updated the information found in the

original series of Task' Force brochures. This new

brochure is available through: Trail Health Center, Dr. clin-

ics, TrairRegional Hospital maternity ward, and mailed to

parents. . . •

• Annual newsletter mailed to every household in Trail.

• Radio.and newspaper advertisements throughout

the spring and summer, on -topics such as: lead'and

nutrition, lead and pregnancy, blood'lead testing,

reducing lead iath'e Home and yard.

.• Storybook aimed at preschoolers - available through

daycares and preschools. • .. '

• Ongoing presentations to community groups such as

Building Beautiful Babies. . • •

' • • • . . ' • • - * • " . ' - ' 'For more Information about the -Trail Health & Environment Committee,

. contact Trail City Hall, T394 Pine Avenue.Phone 364-1262 * .

What education'messages do families need to knowabout lead?• Good hygiene is the key. Wash your children's hands

• frequently.throughout the day and always before snacks

and meals. Keep fingernails short and clean..

• Keep your floors clean by vacuuming and damp

mopping. Leave your shoes at the door.

• Wash children's toys frequently, especially the ones

your child particularly likes to chew. . *

. • Encourage .your children to eat a well-balanced diet

high in calcium and iron. Garden produce should be •

washed before it is eaten. Feed young children snacks

and meals irr a high chair (after you have washed their

hands). - . ,

• Keep bare dirt areas in the yard -to a minimum.

_ Sandboxes.are great, especially if they are kept covered

• when not in use.' Wash your children's hands after

.. playing outside. .

• When- renovating older homes, take special

• precautions to avoid exposure to lead-bearing dust

and paint chips (especially for 'pregnant women and

young children). . .

4

TRAIL LEAD PROGRAMInformational Brochures

Lead and Your Family's Health

Lead Health and Environment Services - What's Available and Who to Contact

and your

Family's

Trail Lead Program

1051 Farwell St.

Trail, BC V1R 4S9

(250) 368-5323

cheryl [email protected]

TRAILtfAD PROGRAM

teckcomincoTeck Cominco Metals Ltd.PO Box 1000Trail, BC V1R 4L8(250) [email protected]

w%- •££"/•^"J^-' •:"£%!i^i$ri> •'.•1;.»;5T-

and your

Family'sLead and its compounds are very useful,but they can be harmful as well, especiallyto young children. Exposure to lead maycause behavioral problems, learningdisabilities or reduced intelligence. Becauselead can be found almost anywhere, youcan't avoid it entirely. However, Canadiansare exposed to much less lead now due toremoval of lead from gasoline additives,interior paint and solder in tin cans.

People who live in smelter communitiesare likely to be exposed to more lead thanpeople who live in most other areas. Trailis a great city in which to live and raise afamily, but we are a smelter community,and therefore we are exposed to somelead through house dust and soil. However,the environment now is better than it hasbeen in decades (a hundred years), and iscontinuing to improve every year. TeckCominco is committed to making furtherreductions in the amount of lead and othermetals released from its Trail Operations.

Community leaders, Teck Cominco,government experts, the Trail Health andEnvironment Committee and residentsare all working together to improve ourenvironment, and we are making significantprogress. We are continuing to seeconsiderable improvements in children'sblood lead levels, and we are confident thatthe efforts of this group will further reducelead exposure in the community.

How does lead get into ourbodies?In Trail, lead is present in the emissionsand dust from the smelter complex. Thelead particles fall to the ground andcontaminate yards and roads. This soiland dust gets tracked into our homes onshoes and clothes, and through windowsand doors. Paint and plumbing in olderhomes may also contain lead.

Most lead enters the body through themouth such as on food that has lead duston it. Because of their habit of putting toys,fingers and other objects into their mouths,young children are more likely to getelevated lead levels than other groups.

What is an acceptable levelof lead in children?As lead has no beneficial effects onhealth, the lower the amount in the body,the better. The Trail Lead Program usesguidelines similar to the U.S. Center forDisease Control to determine acceptableand elevated blood lead levels in acommunity. According to these guidelines,a lead level less than 10 ug/dL (microgramsper deciliter) is acceptable. The Trail Leadprogram is working to have all children inTrail with blood leads lower than 10 ug/dL.

Does lead affect all childrenequally?No. Studies show we should be mostconcerned about the lead levels of childrenunder the age of 3. Small children are mostlikely to put dirty objects into their mouths.They also absorb lead into the bloodstreammore readily than do older children andadults.

What are the effects ofelevated levels of lead inchildren?At very high levels, anemia, kidney damageand digestive problems may occur. Slightlyelevated lead levels may cause learning,behavioural, or psychological problems.Often the effects are so subtle that theycannot be noticed. Any symptoms that dooccur might be mistaken for illnesses suchas flu.

In Trail, any effects are so small that theyare not measurable in individual children.

What are the effects ofelevated levels of lead inadults?Adults are not as vulnerable to lead asyoung children. However, if levels aresufficiently elevated, adults may developfatigue, high blood pressure, digestiveand reproductive problems, and kidneydysfunction.

Adults working directly with lead or leadproducts, through work or as a hobby,should have their blood lead level checkedregularly. However, other adults living inTrail need not be concerned about leadexposure.

How often should mychildren have a blood leadtest?Children who live in the greater Trail areashould be tested each year until they arethree years old. The first test should bedone when your baby is crawling (between6 and 11 months). (Most lead exposurein very young children occurs from lead infloor dust.) It is important to find out if ababy's lead level is elevated, as it is mucheasier to correct at this young age. Testingis voluntary.

What should my child and Iexpect at the blood-testingclinic?A small amount (less than one teaspoon)of blood is taken from the child's arm.You are asked to hold your child on yourlap during the test. It is usually a quick andsimple procedure performed by a certifiedlaboratory technologist. Staff makes theclinics as child-friendly as possible.Balloons, stickers, soap and toys areavailable for children to take home, andthe waiting room has toys for children toplay with.

When will I get the results?The level of lead in the blood sample isanalyzed on site, the same day. You willbe phoned with the results. Results willalso be mailed to you and your doctor,if requested.

What happens if my childhas an elevated lead level?If your child has a lead level of 10 pg/dLor higher, the health coordinator of the TrailLead Program will request to visit yourhome.

You will be offered information and assis-tance to help reduce your child's lead level,such as advice about nutrition and hygiene;testing of your home and yard to determinewhy your child's blood lead is elevated; andservices such as removal of lead contami-nated material in the home environment.Your child's blood lead level will be moni-tored more frequently.

If your child's level is over 20, you are alsoreferred to your family doctor.

How can I keep mychildren's lead levels low?• Good hygiene is the key. Wash children'shands frequently and always before snacksand meals. Keep nails short and clean.Discourage children from putting non-fooditems in their mouths.

• Encourage your children to eat a well-balanced diet high in calcium and iron.Garden produce should be washed beforeit is eaten. Feed young children snacksand meals in a high chair.

• Keep your floors clean by vacuumingand damp-mopping. Leave your shoesat the door. Control dust by wet-wipingwindowsills, ledges, and flat surfaces.

• Keep bare dirt areas in the yard to aminimum. Sandboxes are great, especiallyif they are kept covered when not in use.Wash children's hands after playingoutside.

• When renovating older homes, takespecial precautions to avoid exposure tolead-bearing dust and paint chips. •

Minimizing OurExposure to Metals

Few Key Tips:

Practice good hygiene by washing children's handsafter playing, before eating and before bedtime

Keep fingernails clean and short

Leave outdoor shoes at the door

Keep floors clean by vacuuming and damp-mopping

Control dust by wet-wiping ledges, windowsills,and flat surfaces

Feed children a healthy diet, high in iron andcalcium

Keep bare dirt areas in the yard to a minimum

Carefully wash all fruits and vegetables

When renovating older homes, take specialprecautions to avoid exposure to lead-bearingdust and paint chips

Other Brochures Available:(call 368-LEAD)

® Lead and Your Family's Healthe Nutrition, Lead and Children© Work Project Assistance Programe Renovation: Lead in Your Home

©

contributing photographer: Larry Doell and RaefF Miles

IIIIIiiiii

HISTORY

Metal Levels in Trail Have DeclinedFor children, a blood lead level of 10 ug/dL is the"community concern level" and 15 ug/dL is the"individual concern level".

In 1991, only about 15% of Trail children had leadlevels below 10 and about 60% were below 15.

After the new lead smelter started up in 1997:

® Lead levels in air dropped about 70%

© Lead in dust (dustfall, street dust) droppedabout 40 - 50%.

® The average blood lead in Trail children alsodropped about 40 - 50%.

® Lead levels in soil have not changedappreciably in several decades.

As of 2000, about 75% of Trail children had leadlevels below 10 and about 93% were below 15.

Lead levels in adults living in Trail (and notworking in a lead-related job) are in the rangecurrently considered safe.

Arsenic and cadmium are two other metalsemitted by the smelter. They are generally foundwhere lead is present.

Arsenic and cadmium levels in air droppedby about 60 - 70% after 1997.

The health risks posed by arsenic and cadmium in theTrail environment are very low. Although there isa small calculated risk of adverse health effects, noevidence of increased disease rates related to metalsexposure has been found in the Trail population.

History of Children's Blood Lead Levels in Trail

Trail Lead New leadProgram Smelterstarted 1990 started 1997

1975.•••'.-••: 1980 .

CURRENT SERVICES/PROGRAMS

Public HealthCentree Blood lead testing, focusing on children who

are most at risk (those less than 3 years of age).

e Counseling and services for families with childrenwho have elevated or rising lead levels.

• Community and early childhood education aboutpreventing lead exposure.

• HE PA vacuum cleaner loans.

ContactCheryl Yates,Kootenay Boundary Health1051 Farwell St, Trail(250) 368-LEAD (368-5323)[email protected]

Cominco

City of Traile Flush and sweep the streets according to

recommended protocols.

e Dust control on alleys and other unpaved areas.

• Greening of bare public areas.

Contact:Public Works DepartmentCity of Trail(250) [email protected]

9 Pursue further reductions in plantsiteemissions, with increased reporting to publicon plans and progress.

® Plant more trees within and adjacent to

Cominco property to improve the dust barrierand continue other greening efforts around theproperty and community.

© Environmental monitoring of air and street dust.

e Address soil as needed on a case-by-case basis(coordinated with the counseling and servicesprogram operated by public health).

® Advise and assist people doing excavation,construction, demolition or renovation (WorkProject Assistance Program—full programavailable starting 2002).

Contact:Steve HiltsCominco Ltd.(250) [email protected]

Coordinationof Services

• The Trail Health and Environment committee,appointed by the City of Trail, oversees thework being carried out by Cominco, KootenayBoundary Health and the City.

9 This committee involves the community,government and industry working together toprotect community health.

Reaching for New GoalsTrail saw huge improvements in children's blood leadlevels and environmental conditions from 1975 to 2000.

As of 2000, the average blood lead level in Trailchildren was acceptable. However, there were stillabout 7% of Trail children who had elevated bloodlead levels (higher than 15 micrograms per decilitre).

Blood Lead Goals for 2005

® At least 90% of children should have blood leadlevels less than 10jUg/dL

e At least 99% of children should have bloodlead levels less than 15 /ug/dl_.

iiiiiiiiiii

ATTACHMENT A-2

Attachments referenced on page 17 of the "Independent Review Panel Responses to KeyIssues/Questions "

Example of a 'clean' letter from the US EPA provided to property owners at theSmuggler Mountain Superfund Site in Aspen, Colorado

DEC 06 2003 4:33PM DUNLOP ENVIRONMENTHL CONS 370-333-4820 P•2

DUNLOP ENVIRONMENTAL CONSULTING, INC.5" Environmental and Public Health Planning for the Future

Thomas S. Diinlop

President, 2001

U.S. Environmental Protection Agency'Region VIIIArmando Saenz99918th Street, Suite 500Denver, Colorado80202

Re: "Clean" Letter to Remediated Properties on the Smuggler Mountain Superfund Site

Dear Mr. Saenz:

As you will notice from the letterhead, this communication is coming from DunlopEnvironmental Consulting, Inc.(DEC,Inc.). The letter is being sent under authority of acontractual agreement that DEC, Inc. has. with Pitkin County. DEC, Inc. has been retained tomanage teclinical issues involving the Smuggler Mountain Superfund Site (Site).

Defined in Section VI (15) (g) of the Consent Decree between Pitkin County and theU.S, EPA, homeowners within the Smuggler Mountain Superfund Site who have remediatedtheir property are to receive a "clean" .letter from EPA. The letter will state the propertyrequires no farther remediation. The basis for the latter is determined by the fact thatproperty owners must comply with requirements found in the Consent Decree andInstitutional Controls. The landowners shall protect their property by placinguncontaruinated soil over lead containing soil, and revejjetate the yard after a construction orlandscaping project has taken place. A proper covering of lead containing soil has also beendetermined to be 12 inches of gravel, or paving with concrete or asphalt.

Find below a list of individuals names and addresses that have performed work on.their property resulting in remediation as defined above, or the contaminated soil wasremoved to a proper repository and replaced with clean £11. These individuals qualify for a"clean" letter from EPA because they have token approved measures to remove contaminatedsoil ftora direct human contact

• Pitkin County (Norm Marrah)530 E. Main St. Aspen, Colo. 81611(For creation of a parking lot along Park Circle at (he intersection of Smuggler MountainRoad)• Lora J. Lewis 935 Gibson Ave. Aspen, Colo. 8161 1• Susan Schlundt 326 Oak Lane Aspen, Colo. 81611• Rich Wager 517 Park Circle Aspen, Colo.8161 1• Stephanie Costello 328 Oak Lane Aspen, Colo.81611

Post Office Box 6289 • Snowmass Village, Colorado 8161$ USA • Office and Fax (970) 923-4820

O prlnt«4

DEC 06 2003 4:33PM DUNLOP ENVIRONMENTHL CONS 970-923-4020 P-3

. Steve KeUer 4545 Post Oak Place Houston, Texas 77027Lot 6 Mocklin Subdivision (Steve Keller is the responsible party for the Mocklin

Subdivision)

Attached picas, Had a sample later » previously written by EPA to other property

owners on the Site.

Thank you for your continued assistance in management of this requirement of theConsent Deere*. As always, contact me. should you have questions or comment, surrounding

this request. ,

Sincerely,

Thomas S. DunlopPresident

Cc: Norm Marrah, Pitkb County Env. Health Director[yce Cassin, Aspen Env. Health DirectorJohn Ely, Pitkin County AttorneyJohn Worcester, Aspen City Attorney

^ DEC 06 2003 4:33PM DUKLOP ENViRONMENTRL CONS 970-923-4820p.«

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION VIII

999 18th STREET - SUITE 500DENVER, COLORADO 80202-2466 ... _.

Ref: 8EPR-SB. ,jpr

2737-074-03-956 :'.: *'"* '' '"'J

Pitkiil County •: ;';.130 So. Galena ^:1 ;'.:••Aspen, CO B1611 .

Dear Pitkin County.

Almost one year ago the United States EnvironmentalProtection Agency CSEA) and Pitkin County came to agreement ofi acourse of action for the residential area of the SmugglerMountain Superfund Site (Operable Unit One). As part of thatagreement, BPA is sending you this letter to notify you ae to thestatus of your property. EPA has determined that yourproperty(a), as identified above, has met one of the followingtwo criteria:

1} The property does not require cleanup because leadconcentrations that may. be on your property are below EPA'saction level at this site,

o r , . . .

2) Excavation work performed at this property, by you orthe others, assures protection of human health and theenvironment.

Bepauae your property meets one of thaae two conditions, EPAdoes not believe that the lead that may be in the soil will posea risk to human health or the. environment.

You may rely on this letter as documentation that EPA doesnot plan to carry out additional 9uperfund activities at yourproperty. We thank you very much for your understanding and.cooperation at this site.

Should you have any questions in this matter, you naycontact Brian Pinkowski, Remedial Project Manager at1303) 312-6212. '

Sincerely,

Max H. DodsouAssistant Regional Administratorfor Ecosystems Protection andRemediation

—ftiDlad an Reevcltil Paper

IIIII

ATTACHMENT B

WORK GROUP REQUESTS FOR CLARIFICATION AND SUMMARY OF PANEL• RESPONSES

I

I

I

I

I

I

I

I

I

I

I

ATTACHMENT B

WORK GROUP REQUESTS FOR CLARIFICATIONAND SUMMARY OF PANEL RESPONSES


Based on the Panel's review of the 'Methods and Standards for Evaluating the Performance of the LakeCounty Community Health Program' document (the 'Performance Standards Document') and theevaluation of data from the years 2000, 2001, and 2002, presented in the 2002 Annual Report, pleaseaddress the following:

Original Question:II. 1. Please comment on the appropriateness and applicability of the statistical methods and standardspresented in the Performance Standards Document for evaluating the performance of the Program withrespect to the established Remedial Action Objectives.

n.l.a. Is the rationale for each performance standard adequately described, appropriate, and scientificallydefensible?

Original Panel Response fPart 1 of 3);n.l.a.i. The Panel believes that the rationale for the establishment of standards has been adequatelydescribed in the 'Performance Standards Document'. The Panel considers the standards, as describedin the document, to be reasonable but arbitrary, as they do not mirror National standards (e.g. soillead level of 3500 ppm and lead based paint at 6mg/cm2).

WorkGroup Comment/Request:The LCCHP Work Group recognizes that the site-specific "action levels" or "trigger levels" thatare used to decide when remedial action is warranted for various media such as soil, interior dust,and paint do not mirror values for soil, dust, or paint that are used at many other sites across thenation. These trigger levels were selected for use at Leadville based on the results of the baselinehuman health risk assessment, which included a multivariate structural equation analysis of all dataavailable on the relationship between the probability of elevated blood lead in children and thelevel of lead in contaminated media in Leadville. Given this background for the trigger levels, theWork Group does not feel the word "arbitrary" is an appropriate designation for these values, butrecognizes that the baseline human health risk assessment was not submitted to the Panel forreview, and that the Panel would not have the data needed for judging the appropriateness of thesesite-specific trigger levels. In any event, it is precisely because these trigger levels are not"standard" that the outcome-based (i.e., blood lead-based) performance standards were developed.That is, the LCCHP draws a distinction between "performance standards" (as described in the

performance evaluation methods document) and media "trigger levels", and one of the mainpurposes of the performance standards is to determine if the trigger levels selected are actuallyadequate to achieve the target reduction in blood lead levels in the community.

Panel Clarification; The panel reiterated that the rationale for the establishment of theperformance standards has been adequately described in the Performance StandardsDocument and clarified that the second sentence of their response, characterizing thestandards as arbitrary, was directed at the program's trigger criteria rather than the

methods for evaluating performance. Based on the Work Group Comment/Requestprovided above, the panel stated that they now have a better understanding that the triggerlevels in Leadville were based on the best site-specific data available at the time, andtherefore the trigger levels should not be thought of as arbitrary. However, the Panelreiterated their concern, based on the weight of evidence from more recent studies at othersites, that the trigger levels for soil and paint are high, relative to standards, or action levels,applied at other sites. The panel indicated that their concerns on the likely efficacy of theLCCHP program, specifically given the relatively high trigger criteria for paint, were notintended as criticisms of the Performance Evaluation method.

Original Panel Response (Part 2 of 3):n.l.a.ii. The Panel believes that the performance standards for meeting the Remedial ActionObjectives are appropriate. The Panel does not feel that the term "scientifically defensible " isappropriate -within this context and, therefore, offers no response to this query.

Work Group Comment/Request:The Work Group is pleased that the Panel considers the basic performance standards to beappropriate, but would like to request clarification as to why the Panel does not feel that the term"scientifically defensible" is applicable in this context. More specifically, the Work Group washoping the Panel would comment on whether the basic design and strategy of the performanceevaluation approach is expected to be able to provide a reliable or valid (i.e., scientificallydefensible) technical basis for recognizing if and when the health-based Remedial ActionObjectives have been achieved at the site.

Panel Clarification; The panel clarified that the basic data collection strategies andstatistical evaluation methods developed to evaluate the performance of the LCCHP wereappropriate and valid. The response regarding the term "scientifically defensible" wasprovided due to uncertainty as to whether the terminology is appropriate. The panel agreesthat the methodology of the established performance standards evaluation is defensible.

Original Panel Response (Tart 3 of 3):Il.l.a.iii. The Panel also notes the absence of a critical path or timeline for completion as part of thePerformance Standards. Inclusion of a timeline would be considered normal practice in such adocument.

Work Group Comment/Request;The Work Group would like to request clarification from the Panel as to why absence of a timelineis considered to be important with regard to the performance criteria. As discussed in Section 6.1of the Methods document, the Work Group recognized the need to track results over time and toguard against spurious decisions due to short-term variability. As the analysis presented inAttachment 3 indicates, a minimum of three years of data is judged to be required in order tocapture temporal variability, and after three years of data have been collected, the need to continuethe program is determined by an assessment of whether or not the performance criteria aresatisfied. This includes an assessment both of the P10 and P15 values, and of the uncertaintyaround those estimates. Thus, even when the PI 0 and PI 5 goals have been met, if uncertainty istoo large, additional years of data may be required to increase the number of observations anddecrease uncertainty to acceptable levels. Thus, the duration of the program is dependent on thevalues and quality of the data, rather than attaining a prescribed number of years of data. Does thePanel suggest that a more formal schedule with defined critical events be established as part of theperformance evaluation method?

Panel Clarification; The panel clarified that a time line, identifying milestones forachieving program goals, was suggested to ensure that a strategy was in place in case theLCCHP did not achieve its target objectives within a reasonable time period. Morespecifically, the Panel expressed concern that the program objectives may not be achievedin SU1, without some adjustments to the current program. The panel recommends that theWorkgroup develop a time line for deciding if and when a change in the LCCHP may berequired.

Original Question;Il.l.b. Does the method adequately demonstrate the long-term effectiveness of the remedy andcompliance with RAOs?

Original Panel Response:The Panel feels that this is a critical question that cannot be answered at this time, and cites the

following reasons:• There is not enough long term data available at this point• P-10 and P-15 values have not changed significantly in either SU-1 or SU-2• The majority of properties will not necessarily have been remediated if or when the

Performance Standard has been met.

Work Group Response/Request;The Work Group would like to clarify the intent of this question. It was not our goal to ask thePanel whether they felt that the data available at this time are adequate to establish that theprogram will be effective in the long-term. Rather, it was the intent of this question to determine ifthe panel felt that the basic design and strategy of the performance evaluation program would beadequate to assess long-term effectiveness as data are collected in the future. That is, the intendedfocus of the question is on the method, not on the results. Thus, the question could better havebeen written as: "Will the performance criteria adequately test or assess the long-term effectivenessof the remedy and compliance with RAOs?" The Work Group hopes the Panel will offer theiropinions on this issue.

Panel Clarification; As noted above, the panel clarified that they believe the methodsdeveloped for evaluation of the LCCHP program performance are appropriate.

Original Question:n.2. Please comment on the data evaluation techniques and statistical methods presented in thePerformance Standards Document and make any suggestions or recommendations for modification orimprovement.

H.2.a. Have Type I and Type II error rates been assessed adequately and in a scientifically defensiblemanner?

Original Panel Response;The Panel was in agreement that the methods and performance standards formulated by the workgroup very carefully and quantitatively addressed Type 1 and Type 2 errors. The Panel does notbelieve that the term "scientifically defensible " is appropriate within this context.

Work Group Response/Request;As above, the Work Group would like to seek clarification from the Panel as to why they feel theterm "scientifically defensible" is not applicable in this content. More specifically, the WorkGroup would like clarification as to whether the Panel perceives any statistical limitations or flawsin the strategy or method for estimating the probability of decision errors from data that have beenor will be collected during the project.

Panel Clarification: The panel reiterated that they believe the statistical methods developedto address Type I and Type II error rates are appropriate and valid. Their only concern wasover the appropriateness of the use of the term "scientifically defensible" (See previousclarification to n.l.a.iifor discussion of this terminology).

Original Question:n.2.b. Has the uncertainty in the P10 and PI5 values been assessed adequately and in a scientificallydefensible manner?

Original Panel Response;The Panel feels that the Working Group was highly innovative in using the Monte Carlo Analysis toaddress uncertainty in P-10 and P-15 values. The approach is considered to be highly appropriateand astute. Again, the term "scientifically defensible " is considered inappropriate within the contextof the question.

Work Group Response/Request;As above, the Work Group would like to seek clarification from the Panel as to why they feel theterm "scientifically defensible" is not applicable in this context. More specifically, the WorkGroup would like clarification as to whether the Panel perceives any statistical limitations or flawsin the strategy or method for estimating the uncertainty around estimates of P10 and P15 based onsite-specific blood lead data sets that may be available now or may become available in the future.

Panel Clarification; As noted above, the panel clarified that they believe the statisticalmethods developed for evaluation of the LCCHP program performance are appropriate.

Original Question:II.2.e. Do the methods and standards for evaluating performance provide reasonable assurance that theProgram's goal regarding residual risk - to ensure that whatever residual risks that remain will besufficiently low as to not exceed the RAOs (described in section 7.0 of the Performance StandardsDocument) - will be achieved?

Panel Response;The Institutional Controls referenced in the Work Plan, which are intended to provide ongoing controlmeasures to assure the protection of completed remediation and protection of human health once theLCCHP performance standards have been met, have not yet been approved or implemented. ThePanel feels that in the absence of details on how the Institutional Controls will be implemented andenforced, there is insufficient data to respond to this question at this time. Please see the Panelsconcerns regarding the importance of Institutional Controls in Section IV, Other.

Work Group Response/Request;

The Work Group would like to clarify the intent of this question. It was not our goal to ask thePanel to evaluate the expected efficacy of various Institutional Controls that are described in thework plan for the site. Rather, it was the intent of this question to determine if the panel felt that,if and when the performance criteria are achieved at the site, it will be appropriate to conclude thatresidual risks in the community are likely to be below the health-based goals established in theRemedial Action Objectives. The Work Group hopes the Panel will offer their opinions on thisissue.

Panel Clarification; The Panel agreed that the basic outcome-based stopping rulesestablished in the LCCHPperformance evaluation plan (a running three-yearaverage P10 < 5% and PIS <1%) are reasonable, and in fact are more rigorousthan at many other locations where programs are underway to reduce leadexposure. However, the Panel reiterated that the LCCHP will not remove allsources of lead exposure and that residual risks would remain in the community,especially from lead paint hazards. As such, the panel expressed the opinion that itmay be difficult to determine whether compliance with the RAOs will bemaintained "now and in the future" (as the RAOs are stated) without effectiveInstitutional Controls to prevent disturbance of the remedy over time or ongoingblood-lead monitoring at a minimum. Because of this, the Panel reiterated theirview that is desirable to provide on-going support to the community even after theLCCHP remedy is considered complete.

ATTACHMENT C

WORK GROUP RECOMMENDATIONS

ATTACHMENT C

WORK GROUP RECOMMENDATIONS

This attachment presents the recommendations of the LCCHP Work Group with respect to thecomments and recommendations provided by the Independent Review Panel in their Responses toKey Issues/Questions document. Work Group comments regarding specific responses providedby the IRP are provided and, where appropriate, recommendations to EPA regarding theimplementation of changes to the LCCHP are also discussed.

While a response or recommendation is not being provided by the Work Group for every findingor recommendation of the IRP, the Work Group desires to provide comments and/orrecommendations to selected IRP responses. These comments and/or recommendations areprovided below, referenced to and numbered according to the structure of the IRP report.

I. LCCHP Implementation

Original Question;1.2 Please provide any suggestions or recommendations you may have for improving thestructure (i.e., organization, responsibilities and internal communications) of LCCHPmanagement and administration

Panel Response;In response to this question, the IRP provided (in part) the following recommendations(summarized):

The extension of the team approach to more actively involve members of the local publicand increase community "ownership" of both the problem and its solutions, through theuse of "Champion Moms", and bi-annual or quarterly public meetings to engage andinvolve community leaders.

Work Group Comment/Recommendation;The Work Group recognizes that 'word of mouth' referrals, or the "neighbor to neighbor"approach identified by the IRP in their discussion of "Champion Moms", is an effectiverecruiting method. Given that the Leadville community is relatively small, manyreferrals are received for both the blood lead program and the environmental programfrom friends and relatives of participants. In addition, it is common when a property issampled or remediated on a block, multiple inquiries are received from neighbors. TheProgram also encourages participation by using yard signs during exterior remediationactivities. The Program will continue to encourage participants to talk with theirneighbors and friends to enhance recruitment.

The Work Group also acknowledges that engaging and involving community leadersthrough periodic public meetings may be an effective way of developing a sense of pridein the achievements of the program and improve the visibility of the program within thecommunity. The Program has made presentations to community groups including,schools, the Lions Club, the Lake Interagency Council (LIAR), and the Leadville CityCouncil. In addition the Leadville Mayor and County Commissioners are routinelyinvolved in monthly to quarterly meetings regarding the program.

Original Question:1.3.b (Paraphrased) Provide specific feedback with respect to the community awareness,education, and recruitment activities component of the program.

Panel Response:In response to this question, the IRP provided (in part) the following recommendations toimprove community awareness and recruitment (summarized):

The use of "Champions", or neighborhood volunteers (see response to 1.2 above);

The use of trained, temporary paid staff, to go door to door in SU1 in a concertedrecruitment effort. Recommended consulting with an epidemiologist to help design adoor-to-door survey;

Send a yearly reminder of the program to everyone in SU1, with a follow-up one-on-onevisit;

Develop an evaluation of public needs, with consultation with people knowledgeableabout community assessments;

The use of "key informants" who can represent the common needs, concerns, and desiresof identified segments of the population.

Work Group Comment/Recommendation;At the present time, the program is enjoying excellent participation in the blood leadtesting program and the environmental program is at capacity. The Work Group feelsthat the program is effectively recruiting from multiple segments of the community, asrepresented in the annual report through the presentation of participation rates by area,language, and other socio-economic demographics. The IRP has provided some helpful,specific strategies for community outreach and the Work Group recommends that thesestrategies be considered further should program participation decline in the future.

The Work Group would also like to point out that the blood lead program does in factsend out reminder cards on an annual basis, followed up by a telephone call to the familyto encourage testing.

Original Question:I.3.d (Paraphrased) Provide specific feedback with respect to the environmental testingprogram and procedures component of the program.

Panel Response:In response to this question, the IRP provided (in part) the following specificrecommendations regarding soil and dust sampling procedures:

The Panel recommends that drip line testing be emphasized in the soil sampling regime tohelp determine the presence and influence of soil lead from deteriorating external leadbased paint sources.

Panel members expressed concern that the three sample method currently in use fortesting house dust is not sufficient to identify hazards or provide house-wide clearanceand recommends that the Program follow protocols described in EPA 402 Regulations,and that entryways always be tested.

Work Group Comment/Recommendation;The dust sampling methodology and soil sampling procedures were thoroughly discussedin the development of the LCCHP. With respect to dust sampling, the EPA regulationscited by the IRP are based on wipe-sampling methodology, which provides lead loading,rather than lead concentration results, that are not comparable to the established triggercriteria for lead in dust. As stated in the Work Plan, the main entry is identified as one ofthe three sampling locations for dust.

With respect to drip line soil sampling, the Work Group believes the current procedure inthe Work Plan is sufficiently flexible to address lead in soil in the drip line (e.g., adjacentto the structure), where exterior lead based paint may be a source. The currentprocedures require the collection of samples from all bare areas, or when soil orvegetative cover conditions are different. This procedure ensures that drip line soils aresampled when the area is bare or different from the surrounding yard (i.e., flower orvegetable garden). Drip line soils may not be sampled separately if the area is similar tothe adjacent yard, or when covered with gravel or rock, however, these conditions alsolimit a child's exposure to the soil. In addition, if the remediation of exterior lead basedpaint is required, additional soil sampling is performed per the Work Plan.

Original Question:I.3.e (Paraphrased) Provide specific feedback with respect to the blood lead testing programand procedures component of the program.

Panel Response:In response to this question, the IRP provided (in part) the following specificrecommendations regarding blood lead sampling procedures:

Panel members did not feel that waiting until a child is 12 months of age to beginrecruitment into the LCCHP was ideal, and would encourage blood lead testing starting atage 9 months. The Panel also recommended the use of a professional Phlebotomist tocollect samples in children under the age of 12 months.

Work Group Comment/Recommendation;The program is following current CDC guidelines, which recommend testing beginningat the age of 12 months. This is also consistent with Medicaid requirements. Childrenyounger that 12 months are routinely tested if a sibling has an elevated blood lead, or ifthe parents request testing. In addition, the program does have access to a professionalphlebotomist through the hospital.

Original Question:I.3.f (Paraphrased) Provide specific feedback with respect to the data management, evaluation,and reporting practices of the program.

IIIIIIIIIIIIIIIIIII

Panel Response:In response to this question, the IRP provided a number of specific suggestions, asfollows:

i. Use of a multi-variate regression method to better understand the determinants ofelevated blood lead in Leadville;

ii. Consider providing previous years results in the Annual Report to demonstratetrends of blood lead levels over time, as a function of multiple variables;

iii. Consider the use of a GIS system to allow for spatial tracking of children withelevated blood lead levels, to identify potential "hot spots" of exposure, andidentify targets for recruitment;

v. Split the collected sample base at the mean rather than at the P-10 or.P-15 levelsto increase the statistical power of the analysis;

vi. Consider testing for representativeness of lead-based paint hazards as well as soillead; and

vii. Use the suggested analytical strategy to evaluate and improve the program andmore effectively target the basic problem areas.

Work Group Comment/Recommendation:

i. The Program has and will continue to evaluate methods of evaluating programdata, such as multi-variate regression analyses, to develop an understanding ofthe factors, or sources contributing to elevated blood leads. See response to item1.4. below for additional discussion.

ii. The Work Group agrees that the presentation of trends for certain data would behelpful and, based on the IRP's recommendation, is planning to present trends inparticipation, mean blood lead levels, and P10 and PI5 levels in the next annualreport.

iii. The Work Group understands the potential of GIS technology, however detailedmapping (i.e., to the property level) is not currently available for Leadville. Asubstantial commitment of time and money (that is not currently budgeted)would be required to generate the information necessary to develop a fullyintegrated GIS system for the site. Notwithstanding, spatial analysis tools,including GIS, may be considered by the Work Group in the future. In addition,in considering spatial analysis techniques care must be taken to prevent anypotential breach of confidentiality, given the small population of Leadville.

v. See discussion below related to item 1.4.

vi. The representativeness test, using soil concentrations, included in the Methodsand Standards for Evaluating Performance (Standard 4) was not intended topresume that exposure to lead in soil is the predominant lead exposure pathway.Rather it was developed as a way to ensure that the program participants

represent the population as a whole. In addition, due to the number of variablesinvolved in paint sampling, the Work Group believes it would be very difficult todevelop a metric to uniformly quantify lead paint hazards. However, the WorkGroup does feel that understanding the significance or contribution of lead-basedpaint to blood lead levels is important and continues to be considered. See Item1.4 below for additional discussion.

vii. As stated in the preceding responses, the Work Group will consider alternate dataevaluation techniques to improve the program and focus on identified 'problemareas'. See Item 1.4 below for additional discussion.

Original Question;1.4 Statistical Unit 1 has not met the performance standards criteria; please provide anyadditional implementation recommendations that could be considered by the Work Group to meetthese standards.

Panel Response:In response to this question, the IRP made the observation that while the mean blood leadconcentration is declining, the percentage of participants with blood lead levels greaterthan 10 and 15 ug/dl (P10 and P15), respectively, has not significantly changed overtime; implying that there is a "tail" at the high end of the blood lead distribution that hasnot responded to the current interventions. To develop a better understanding of thedeterminants (or predictors) of blood lead, the panel recommendended dividing theoverall sample of children into two groups, i.e., those with blood lead levels above andbelow the mean, and evaluate each group using a multi-variate regression to increase thestatistical power of these evaluations in an attempt to reveal the dominant exposurepathways.

Work Group Comment/Recommendation;The Work Group is in agreement that the IRP's observations on this issue are among themost significant findings of the Independent Review Panel's report. Previous dataevaluation efforts (included in recent Annual Reports) have utilized all paired data toprepare bi-variate plots to represent the relationship between blood lead andenvironmental media data. The Work Group has discussed the possibility of performingmore robust analyses (i.e., to include data from multiple, or more recent, years or toperform multi-variate regression analyses) and has tasked the Performance StandardsWorking Group with developing a cost-effective, step-wise approach to investigate thedeterminants of elevated blood lead levels in the persitent upper tail of the distribution.

The Work Group concurs with the IRP's recommendation to develop a specific plan orstrategy following a structured process to investigate additional data evaluationtechniques or efforts to help in determining the factors that contribute to elevated bloodlead levels in Leadville children.


I

I

I

I

i

I

See Attachment B - Work Group Requests for Clarification and Summary of PanelResponses for additional discussion on the questions posed and responses provided in thisSection.

IIII_ III. Annual Report

Original Question;m.l Please comment on whether the LCCHP Annual Reports (2001 and 2002) meet the

I requirements and expectations of the Work Plan.

Panel Response:The Panel felt that the Annual Reports met the requirements and expectations of theWork Plan but offered the following recommendations for improvement:

• i. Include a target date to achieve program objectives; and

ii. Provide an executive summary that highlights outcomes in layman's terms.

• Work Group Comment/Recommendation;

— i. Please refer to the Work Group Request for Clarification and Summary of Panel• Responses (Attachment B). The Work Group recommends that a timeline

regarding decisions related to program's performance be included in thestructured data evaluation plan referenced in Item 1.4 above.

• ii. The Work Group will include an executive summary in future Annual Reports.

Original Question;III.3.a (Paraphrased) With respect to improving future Annual Reports, do you recommendadditional data analysis to support compliance with the RAOs:

Panel Response;

I The Panel recommends that the annual report should include a frequency distribution ofhemoglobin concentrations.

I Work Group Comment/Recommendation:The Blood Lead Program collects hemoglobin data, but has not formally reported thisinformation in the past. The Work Group has recommended that the Blood LeadProgram provide this information along with blood lead concentration for evaluation by

• the Work Group. This information will be incorporated in the next Annual Report.

IV. Other

Original Question:FV.1 Please provide any other feedback or thoughts you feel may be helpful to the Work Groupin managing the ongoing implementation of the Program.

Panel Response;The Panel provided (in part) the following recommendations that the Work Group wouldlike to comment on:

i. In their feedback to this question, the Panel expressed a concern regarding thelong-term effectiveness of the remedy and specifically cited their opinion of theimportance of Institutional Controls.

ii. While not asked to comment on the trigger levels for environmental responseactions, the Panel did recommend a more aggressive response for deterioratedlead based paint hazards (>1 and <6 mg/cm2) and suggested the use of dust leadloading (evaluated by wipe sampling) rather than dust concentration (evaluatedby vacuum sampling) for the evaluation of risks related to lead in dust.

Work Group Comment/Recommendation:

i. The Institutional Controls (ICs) program, as required by the ROD to support theLCCHP, is currently under development with ongoing discussions occurringbetween the County, the EPA and the CDPHE. As such, details of the proposedICs program were not provided to the Independent Review Panel for theirconsideration in their review of the Program. Please refer to the additionaldiscussion provided in Attachment B.

ii. Please refer to the discussion provided in Attachment B (item II. 1 .a.i) foradditional discussion regarding the development of the trigger criteria for theLCCHP. It should be noted that the Baseline Human Health Risk Assessmentwas not provided to the Independent Review Panel because it was notconsidered to be within the scope of the program review, consistent with therequirements for the Independent Review in the Work Plan.

With respect to the comments related to the dust sampling methodology utilizedby the LCCHP, the vacuum sampling method employed by the LCCHP is a HUDapproved method and the only available method to provide results of leadconcentration in dust, which are required for comparison to the leadconcentration trigger criteria enumerated in the ROD.

In addition, the Work Group would like to clarify that while the trigger criteriacite a preference for education of participants at properties where paint with leadconcentrations between 1 and 6 mg/cm2 are present, more aggressive actions (i.e.,response actions) are considered, on a case-by-case basis, at properties whereyoung children reside.

SUMMARY OF PANEL RECOMMENDATIONS

IIiiiiiiiiiiiiiiiii

In addition to the Panel responses enumerated above, a number of other comments andrecommendations (not specifically identified in the body of the Panel's report) wereincluded in the Summary of Panel Recommendations at the end of their report. WorkGroup comments and recommendations on these items are listed below:

Panel Recommendation:Modify the access agreement to allow for long-term monitoring and surveillance of dustlead levels, maintenance of soil remediation, etc. following initial remediation.

Work Group Comment/Recommendation;In accordance with the Work Plan, follow-up inspections are routinely conductedapproximately one year following remediation to inspect the condition of completedactions. Clearance sampling is performed following dust and paint actions andresidents/owners are provided with instructions on maintaining their property to minimizelead exposures. While long-term monitoring of dust lead levels within a home is notconducted under the program, some follow-up sampling has been conducted in the past,and resampling of a property may be performed at the owner/residents request or inresponse to an elevated blood lead level. Based on the IRP's comments, the Work Grouprecommends that all currently available information related to post remediation orfollow-up dust sampling be reviewed. Based on that review, the Work Group will makea recommendation to EPA regarding the importance and utility of resampling dust at aselect number of properties as part of the five-year review process for the Superfund Site.

Panel Recommendation;Initiate follow-up monitoring of the effectiveness of educational efforts in lowering bloodlead levels by observing the condition of lead-based paint and testing dust lead levels,and interviewing "educated" families.

Work Group Comment/Recommendation;As stated in the preceding comment, the program does not currently perform long-termmonitoring of paint and dust. The performance of such an effort would require additionalresources and funding. The Work Group recommends that the program continue itspractice of performing additional investigations and interviews to follow-up on EBLchildren residing at properties that have been sampled and remediated if blood lead levelsare not observed to decline. The educational subcommittee of the Work Group hasdiscussed the development of a survey or other method to evaluate the effectiveness ofthe educational efforts.

Panel Recommendation;Reduce reliance on HEPA vacuums as an active form of remediation. The filters mayactually reduce suction and decrease efficiency.

Work Group Comment/Recommendation;The use of HEPA vacuums through the vacuum loan program administered by theLCCHP is not considered active remediation. These vacuums are made available toparticipants where active remediation is pending, or to residents that may be remodelingtheir homes. When a dust removal response action is performed by the program as activeremediation, the use of HEPA vacuums is recommended by the HUD Guidelines andrequired under Colorado's Regulation 19. Active dust removal, as described in the Work

Plan, also involves the cleaning of hard surfaces in addition to vacuuming, in accordancewith HUD guidelines and State Regulations.

Panel Recommendation:Remove references to the use of TSP as an active form of remediation. It has a tendencyto damage paint and has not demonstrated significant effectiveness in lowering EBLs.

Work Group Comment/Recommendation;The use of TSP as a cleaning agent as part of a dust removal response action was astandard method referenced in both the HUD guidelines and State regulations, at the timethe Work Plan was developed. The Work Group recommends modifying the Work Planto reflect the current HUD Guidelines and State regulations, which have removed thespecific reference to TSP, and replaced it with "a cleaning agent".

Panel Recommendation;Distribute free iron supplements and vitamins at the Health Department, as appropriate,to simplify availability and enhance recruitment.

Work Group Comment/Recommendation;The Lake County Health Department has investigated this issue and has reported to theWork Group that the vitamins recommended by local doctors contain fluoride and are notavailable 'over the counter'. The cost of these vitamins is approximately $16 per 100tablets. The Work Group is recommending that a voucher for vitamins be provided to allchildren with elevated blood leads and low hemoglobin levels. Following furtherevaluation of the association between hemoglobin and blood lead data (to be included inthe 2003 Annual Report as recommended in Item Hl.S.a), the Work Group will revisit theissue of whether to consider broader distribution.

Panel Recommendation;Educate and encourage realtors to practice HUD and EPA mandated regulationsregarding representations of condition that are accurate and unbiased.

Work Group Comment/Recommendation:All property owners participating in the program are made aware of these requirementsand realtors are identified as a target group for education and outreach efforts. Theeducational subcommittee of the Work Group will redistribute materials to local realtorsregarding these disclosure requirements.

Panel Recommendation;Provide property owners with a "clean letter" from the EPA once successful remediationof their property has been accomplished.

Work Group Comment/Recommendation;The Work Group believes that the procedures currently in place for the LCCHP providethe necessary information to property owners regarding the completion of remediation attheir property. The LCCHP provides Property Documentation Reports to all owners whohave entered the program that provide all information on environmental sampling and

remedial actions, if performed, and reference to EPA's approval of the Work Group'srecommendations.

Panel Recommendation:Encourage construction and remodeling that incorporates bare floors that are easier toclean and trap less dust than carpet, especially in entryways.

Work Group Comment/Recommendation;The educational subcommittee of the Work Group discussed the IRP's suggestion ofencouraging bare floors when remodeling. Since there is some controversy around thistopic nationally the group recommends that information be presented in the "Tips forreducing lead in your home" brochure and that residents be encouraged to contact theprogram for information regarding lead hazards prior to remodeling.

Panel Recommendation;Welcome the press and media to become involved in excercises such as this IndependentReview Panel.

Work Group Comment/Recommendation;The press and media are not invited to Work Group meetings due to the confidentialnature of the information discussed. However, the press and media can attend publicmeetings periodically scheduled with local community leaders to discuss the progress andachievements of the program(See Item 1.2). In addition the local press is used toadvertise the program and employees of the local newspapers have participated in theenvironmental program.

10

ATTACHMENT D

IIIIIii

SCOPE OF WORK

I AndKEY ISSUES/QUESTIONS

I

I

I

I

I

I

I

iiii


SCOPE OF WORK

The Lake County Community Health Program (LCCHP) is the remedial action selected by theU.S. EPA to address human health risks from exposure to sources of lead within Operable Unit 9(Residential Populated Areas) of the California Gulch Superfund Site (the Site). The Site lieswithin Lake County, Colorado, which is a relatively small (380 square miles), predominantlyrural county with a 2000 population of approximately 7,800 (U.S. Bureau of the Census, 2000).According to records from the Lake County Assessor's Office, there were approximately 3,500residential units, including multiple-dwelling units, located within OU9 in 1999.

The LCCHP is an innovative remedy that has been designed to reduce overall lead-related risk tochildren in Leadville by including responses that address numerous sources of lead exposure,even sources that would not be addressed under EPA's Comprehensive Environmental Response,Compensation and Liability Act (CERCLA) authorities. The potential sources of lead exposurethat are addressed by the LCCHP's investigation and remediation programs include soil, housedust, drinking water and interior and exterior paint. This comprehensive approach was originallyproposed and eventually adopted in response to strong community interest in managing exposuresto lead in lieu of a more conventional, residential-soil removal program. The program wasdesigned to operate in a manner that minimizes impacts to the community and optimizes the useof available resources to reduce resident children's lead exposure and ultimately reducecommunity-wide blood lead levels to meet EPA's risk-reduction goals for this Site.

The LCCHP has been implemented since May 2000 and currently provides a range of services toassist residents in reducing their exposure to lead in and around their homes. These servicesinclude routine blood lead testing for resident children and pregnant or nursing women,environmental lead investigations at residential properties within OU9, remediation of potentialsources of lead exposure identified through those investigations and community education andawareness programs. Residents' participation in any aspect of the program is voluntary.

The quantitative remedial action objectives (RAOs) of the selected remedy for OU9 were statedin the EPA's Record of Decision (ROD) (EPA, 2000), as follows:

RAO-1: No more than 5 percent of all children (ages 0 to 72 months) who live at this site,either now or in the future, will have blood lead values higher than 10 ug/dL.

RAO-2: Health will be adequately protected if the highest risk level at any sub-location isa probability that no higher than one percent that a population of children (ages 0 to 72months) residing at that sub-locatjon will exceed a blood lead value of 15 ug/dL.

An additional qualitative RAO was added during the development of the Feasibility Study forOU9 and also considered during remedy selection:

Reduce the direct exposure of lead incurred by children, which will result in optimal riskreduction through effective use of resources.

Since selection of the remedy, more detailed performance standards were developed to define themeasures used to evaluate performance of the LCCHP relative to these RAOs.

Because the LCCHP is distinct in its approach from typical Superfund remedies selected toaddress sources of lead in residential areas, the EPA has required that design and implementationof the program be reviewed and evaluated by a panel of experts who have experienceimplementing or evaluating lead risk reduction programs but who are not directly involved in theLCCHP or its original development.

The independent panel will be tasked with completing a thorough review and evaluation ofLCCHP design and implementation. The goal of this review will be to provide recommendationsfor improving the overall effectiveness and efficiency of the program in meeting its statedobjectives and established performance standards. The review will include the following tasks:

• review and comment on the LCCHP Work Plan (MFC, 2000), the 'design' documentand implementation plan for the program;

• review and evaluate the administration and implementation of the program withrespect to the requirements of the Work Plan;

• evaluate and comment on the remedy's performance standards as measures of theoverall effectiveness of the LCCHP;

• evaluate community outreach and education programs and make recommendationsfor improving their effectiveness; and

• evaluate resident participation in blood lead monitoring and environmental testingprograms and make recommendations for improving participation, if warranted.

The focus of the independent review panel shall be to evaluate the structure and operation of theprogram and the appropriateness of performance standards. The panel will have the opportunityto make recommendations for improving the design and implementation of the LCCHP, as theysee necessary. This scope of review includes a broad range of program components, including:program administration and work group operations; recruitment activities; community awarenessand education programs; interactions with program participants; environmental testing programand procedures; blood lead testing program and procedures; data evaluation practices;implementation of response actions; and data management and reporting practices. Theindependent review is not intended to address certain fundamental elements of the programdescribed in the Record of Decision (ROD), including: remedial action objectives, the voluntarynature of the program, program eligibility, the media addressed, and trigger criteria for thevarious media used as the basis for recommending response actions.

Members of the independent panel will convene in Leadville, Colorado to observe the functioningelements of the program and to meet with LCCHP staff, the advisory work group (includes stateand local health department representatives) and a group of program participants. Members ofthe review panel will be provided with the following information, prior to visiting the Site, toassist them in initiating the review process:

• Record of Decision for Operable Unit 9, Residential Populated Areas, CaliforniaGulch Superfund Site, Leadville, Colorado. U.S. EPA, September 1999.

• Work Plan for the Lake County Community Health Program, Operable Unit 9,Residential Populated Areas, California Gulch Superfund Site. December 2000.

• Methods and Standards for Evaluating the Performance of the Lake CountyCommunity Health Program. July 2002.

• Leadville Kids First Program Report, 1994-1999 Progress and Results. February2001.

• Lake County Community Health Program, 2001 Annual Report. July 2002.

• Lake County Community Health Program, 2002 Annual Report. June 2003.

• Package of information containing brochures and educational materials distributed aspart of the outreach efforts of the program.

Additional background documents and information regarding the program will be made availableto the review panel, upon request, following the completion of their initial review.

It is anticipated that the review panel will complete its review during a two-day working sessionin Denver and Leadville. An agenda for the two-day program review session is attached. Panelmembers will be expected to review the above referenced information prior to arriving for theworking session. A list of key issues and/or questions to be answered by the review panel will beprovided to the panel in advance of the working session. The purpose of this list is to provide afocus for the review and to provide a format for the work product to be developed by the reviewpanel. A facilitator will be assigned to the review panel to assist them in coordinating theirreview and in compiling their work product. The working session will consist of a series ofinteractive presentations conducted by program staff and Work Group members, focused oncertain aspects of the program, a site tour, and an opportunity to interact with local communityleaders and possibly program participants. The final session of the program review will bereserved for a private session with the review panel and the facilitator at which time they willhave the opportunity to draft their findings and responses to the list of questions provided, andcompile a list of recommendations. The work product resulting from this independent reviewwill be a written report detailing the findings and recommendations of the review panel. Thefinal report of the independent review panel shall be submitted within 30 days of the completionof the working session. The facilitator will circulate a draft of the report to panel membersfollowing the working session and will coordinate the finalization and submittal of the report.The report will be submitted directly to the LCCHP's advisory work group, Lake County HealthDepartment, CDPHE and EPA. After receiving the independent panel's findings andrecommendations, the Work Group will review and discuss this report and make a finalrecommendation to the EPA regarding the implementation of any changes to the operation of theprogram.

J:\BLDO 1 \5626\Task 10\PeerReview\IndRevSOW Final.doc


KEY ISSUES/QUESTIONS

The Independent Review Panel is being tasked with preparing a written report detailingtheir findings and recommendations developed through the review of the program. TheLCCHP Work Group has prepared this list of questions and issues to solicit input fromthe review panel on specific aspects of the program. The Work Group is requesting thatthe panel's final report be divided into sections corresponding with the headings providedin this document, followed by responses to the specific questions posed below and anyother feedback the review panel would like to provide. The Work Group does notanticipate that the final report will contain lengthy background discussion, rather acompilation of comments and recommendations that the LCCHP Work Group and theEPA can consider to further improve the implementation and effectiveness of theprogram.

I. LCCHP ImplementationBased on the Panel's review of the LCCHP Work Plan and the Program'soperations to date, please address the following:

1. Is the Program being implemented in a manner consistent with the designpresented in the Work Plan?

2. Please provide any suggestions or recommendations you may have forimproving the structure (i.e., organization, responsibilities and internalcommunications) of LCCHP management and administration.

3. In providing your feedback with respect to the implementation of theProgram, please consider these specific components of the Programdesign:- Program administration and Work Group operations;- Community awareness, education, and recruitment activities;- Interactions with Program participants and coordination between

environmental testing and blood lead programs;- Environmental testing program and procedures;- Blood lead testing program and procedures;- Data management, evaluation, and reporting practices;- Implementation of response actions; and- Documentation and reporting practices.

4. Statistical Unit 1 has not met the performance standards criteria; pleaseprovide any additional implementation recommendations that could beconsidered by the Work Group to meet these standards.

IIIIIIIIIIIIIIIIIII

II. Evaluation of PerformanceBased on the Panel's review of the ''Methods and Standards for Evaluating thePerformance of the Lake County Community Health Program' document (the'Performance Standards Document') and the evaluation of data from the years2000, 2001, and 2002, presented in the 2002 Annual Report, please address thefollowing:

1. Please comment on the appropriateness and applicability of the statisticalmethods and standards presented in the Performance Standards Documentfor evaluating the performance of the Program with respect to theestablished Remedial Action Objectives.a. Is the rationale for each performance standard adequately described,

appropriate, and scientifically defensible?b. Does the method adequately demonstrate the long-term effectiveness

of the remedy and compliance with RAOs?

2. Please comment on the data evaluation techniques and statistical methodspresented in the Performance Standards Document and make anysuggestions or recommendations for modification or improvement.a. Have Type I and Type II error rates been assessed adequately and in a

scientifically defensible manner?b. Has the uncertainty in the P10 and PI5 values been assessed

adequately and in a scientifically defensible manner?c. Do the required criteria adequately assess the overall

representativeness of the available blood lead data, used to derive thetheoretical blood lead distribution for the community at large?

d. Does the test of proportions used in Performance Standard 4 providereasonable assurance that blood lead program participants are not fromresidences that underestimate the high end of the soil lead distributionfor the statistical unit as a whole?

e. Do the methods and standards for evaluating performance providereasonable assurance that the Program's goal regarding residual risk -to ensure that whatever residual risks that remain will be sufficientlylow as to not exceed the RAOs (described in section 7.0 of thePerformance Standards Document) - will be achieved?

III. Annual ReportBased on the Panel's review of the 2001 and 2002 Annual Reports and the 1994-1999 Progress and Results Report, please address the following:

1. Please comment on whether the LCCHP Annual Reports (2001 and 2002)meet the requirements and expectations of the Work Plan.

2. Please comment on whether data presented in the 2002 annual report areadequate to support evaluation of the program performance standards(Refer to Appendix D of the 2002 Annual Report)?

3. Please make any suggestions or recommendations for improving the valueand usefulness of future ajinual reports. However, in making yoursuggestions and recommendations, please be mindful that these areproduced as public documents and the confidentiality of programparticipants must be maintained.a. Do you recommend additional data analysis to support compliance

with the RAOs?b. Are there components of the data analysis presented in the annual

report that you feel are not necessary?c. Can you identify ways to streamline the annual report?

IV. Other

1. Please provide any other feedback or thoughts you feel may be helpful tothe Work Group in managing the ongoing implementation of the Programand ensuring long-term protection of public health.

2. Was the Independent Review Panel provided with the tools andinformation needed to complete the Program review in accordance withthe Scope of Work?

J:\BLDO 1 \5626\Task 10\PeerReview\LCCHPjanel questions_Final.doc

lake county community health program independent review panel · haven connecticut, focusing on...

Documents