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U N I T E D S T A T E S E N V I R O N M E N T A L P R O T E C T I O N A G E N C YR E G I O N V I M

9 9 9 18th S T R E E T - S U I T E 5 0 0D E N V E R , COLORADO 80202-2466

534738

Ref: EPR-SRF I N A L P O L L U T I O N REPORT

C A L I F O R N I A G U L C H , OPERABLE U N I T I XR E M O V A L A C T I O N S P E R F O R M E D U N D E R T H E K I D S F I R S T P R O G R A M

I . H E A D I N G

Date: December 15,1998S u b j e c t : C a l i f o r n i a G u l c h S u p e r f u n d S i t e , Operable Uni t I X ,Residential S o i l s

Twenty (20) Time-Cri t i ca l Removals Performed Under the K i d s Fir s tProgram During the T i m e Period S t a r t i n g October 31,1997 thruN o v e m b e r s , 1998.From: Rebecca Thomas , Remedial Project Manager

To: Max H. DodsonAssi s tant Regional Admini s t ra t orO f f i c e of Ecosystems Protection and RemediationPOLREP No.: POLREP 1 a n d F I N A L

I I . B A C K G R O U N DN P L Status: F I N A LS i t e No. COD980717938Action Memorandum S t a t u s : A p p r o v a l dates f or Action Memorandums, S t a r tDates and C o m p l e t i o n Dates are indicated belowfor each p r o p e r t y in de s cr ip t i on s of eachresponse action.

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I l l S I T E I N F O R M A T I O NThe C a l i f o r n i a G u l c h Site (Site) was l i s t ed on the N a t i o n a l Prior i t i e s List onSeptember 8, 1983. The site is in a historic mining area covering 16 % squaremile s of a watershed that drains a long C a l i f o r n i a G u l c h to the Arkansas River.S t a r t i n g in 1859, the area was mined extensively for g o l d , l e ad , si lver, copper, zinc,and manganese. Six impounded t a i l i n g s dumps surround the city of L e a d v i l l e ,Colorado. Many smelters, which were located around the C i t y , processed si lver,lead and zinc at various times. Heavy metal residues are present in much of theSite . A p p r o x i m a t e l y 7,400 p e o p l e l ive in L e a d v i l l e and Lake County.As a result of the August 1994 Consent Decree between the United Sta t e s andvarious p o t e n t i a l l y r e spons ib l e part ie s , Asarco, Inc. has assumed the r e s p o n s i b i l i t yto addres s the Residential S o i l s Operable Uni t IX (OU IX). The Consent Decreec a l l s f o r t h e f ormat i on o f t h e Kids Fir s t Program (KFP).The Kids First Program is designed to reduce young children's exposure to lead.The Program also provides in format ion to the community about lead f ound withinthe home and environment.The Kids First Program was deve loped by the S t a t e of Colorado , EPA and Asarcowith input from the Ci ty of Leadv i l l e and Lake County. The Ci ty of L e a d v i l l e andLake County, S t a t e of Co lorado , EPA and Asarco work together on Kids First as theKids First Work Group. T h i s program is being i m p l e m e n t e d as ou t l ined in theConsent Decree with guidance from the Kids First Work Group.This program is an interim program unti l a Record of Decision is e s tabl i shed for theres idential area.The Kids F i r s t Program is a voluntary program consisting of:* P r o v i d i n g an educational program to the L e a d v i l l e community about s tayingsa f e around lead,* e s t a b l i s h i n g a loan program of HEPA (High E f f i c i e n c y Part i cu la t e A e r o s o l )vacuums to reduce lead dust ins ide homes,* conducting environmental assessments of soils, dust, paint and water todetermine those e l i g i b l e for a response action,

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* recommending appropr ia t e response actions to ERA for approval andi m p l e m e n t a t i o n by Asarco, and* continuing the on-going blood lead monitoring through Lake County N u r s i n gServices.

I V . R E S P O N S E I N F O R M A T I O NThe Time Critical Removal Actions listed below were performed under the Kids Firstprogram. E x h i b i t s / F i g u r e s are provided in each Action Memorandum to dep i c t theareas to be remediated.Operable Uni t 9, KFP Removal 21An Action Memorandum for a T i m e Crit i cal Removal at the Trujillo residencelocated at 712 East 6th Stree t , Leadv i l l e , Colorado, was signed on December 1,1997. S o i l s in the front yard of the Trujillo proper ty exceeded the KFP T r i g g e r levelof 3,500 ppm lead.The action consisted of removal of soil to f a c i l i t a t e grad ing and drainagerequirements and i n s t a l l a t i o n of a 6 inch cover over the entire property. Covermaterial s consisted of t o p s o i l , sod, gravel, concrete, road base. In a d d i t i o n anasphalt drainage swale was graded along the south property line (along East 6thS t r e e t ) to minimize surface water run-on from up-gradient of the property.The structure located at the Trujillo residence, has been determined to be non-contributing to the L e a d v i l l e H i s t o r i c M i n i n g District by the State H i s t o r i cPreservation O f f i c e (SHPO). However, archaeological po t en t ia l has beeni d e n t i f i e d at this property. A cultural resource pro f e s s i ona l monitored excavationof soils at this property.The Removal Action at the Trujillo residence was completed byOctober 23,1998.

A C T I O N M E M O R A N D U M S I G N E D : D E C E M B E R 1,1997REMOVAL START: DECEMBER 1,1997REMOVAL C O M P L E T E : OCTOBER 23,1998

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Operable Unit 9, KFP Removal 22An Action Memorandum for a T i m e Cri t i cal Removal at the Vierczhalck residencelocated at 322 West 3rd Street, Leadv i l l e , Colorado, was signed on December 1,1997. S o i l s in the beds adjacent to the house exceeded the KFP t r igger level of3,500 ppm lead.The action consisted of removal of material to a d e p t h of 6 inches in the f o u r s lagcovered f l ower beds f o l l o w e d by in s ta l la t i on of 6 inches of river-washed gravel intwo of the beds adjacent to the west side of the house. Six inches of top soil wasi n s t a l l e d in the third bed adjacent to the house and in the bed adjacent to the southside of the shed.The structure located at the Vierczhalck residence has been determined to be non-contribut ing to the L e a d v i l l e H i s t o r i c M i n i n g District by the Sta t e H i s t o r i cPreservation O f f i c e ( S H P O ) .The Removal Act ion at the Vierczhalck residence was comple t ed byJ u n e 11,1998.

A C T I O N M E M O R A N D U M S I G N E D : D E C E M B E R 1,1997R E M O V A L S T A R T : J U N E 8,1998REMOVAL C O M P L E T E : J U N E 11,1998

Operable Uni t 9, K i d s F i r s t Program (KFP) Removal 23An Action Memorandum for a Time Critical Removal at the Gonzales residence(815 East 6 t h S t r e e t ) was signed on J u n e 8,1998. S a m p l e s co l l ec t ed under theKids First Program determined that lead levels in samples collected from soil s inseveral areas of the Gonzales property, located at 815 East 6 th Stree t , L e a d v i l l e ,Colorado , exceeded the Kids First t r igger value of 3,500 ppm.The action consisted of i n s t a l l a t i o n of cover materials i n c l u d i n g top s o i l , sod, cleanb a c k f i l l , cobbles, roadbase and concrete. A concrete pad and road base wasin s ta l l ed from the existing concrete pad in front of the garage to East 6 th Street . Aminimum of six inches of material was removed from the area where the road basewas in s ta l l ed . Top soil was removed to a d ep th of six inches from the area locatedalong the east side of the proper ty and was replaced with road base. Top soil wasi n s t a l l e d in the front yard from the house to the north f ence line. Clean fill material

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and large cobbles were i n s t a l l e d from the f ence l ine to East 6 t h Street . Six inchesof material was removed from the two f l ower beds (one on the east side of thehouse and one on the north side). The area was b a c k f i l l e d with top soil.The State His tor i c Preservation O f f i c e (SHPO) has determined that the structureon the Gonzales proper ty is non-contributing to the L e a d v i l l e H i s t o r i c M i n i n gDistrict. Since archaeological potential was i d e n t i f i e d at the proper ty, a culturalresource p r o f e s s i o n monitored excavation of so i l s at th i s property.The Removal Action at the Gonzales residence (815 East 6 th S t r e e t ) wascomple t ed by July 7,1998.

A C T I O N M E M O R A N D U M S I G N E D : J U N E 8,1998R E M O V A L S T A R T : J U N E 8,1998R E M O V A L C O M P L E T E : J U L Y 7,1998

Operable Uni t 9, KFP Removal 24An Action Memorandum for a Time Critical Removal at the Foy residence, locatedat 172 S o u t h T o l e d o Stre e t , L e a d v i l l e , Colorado , was signed on July 7, 1998.S a m p l e s collected under the Kids First Program determined that lead levelsin sample s col lec ted from the gravel and s l a g driveway, from the land s capedarea adjacent to the driveway, and from the small f l ower bed in the front yardnear the driveway at the Foy proper ty exceeded the Kids First t r igger value of3,500 ppm. In addi t ion, the areas are either bare or accessible to the children.Remediation activit ies inc luded removal of soil as appropr ia t e to f a c i l i t a t eg r a d i n g and drainage requirements; i n s t a l l a t i o n of a concrete pad centered onthe s idewalk; removal of six inches of material and i n s t a l l a t i o n of a minimumof six inches of compacted road base on the remainder of the driveway;i n s t a l l a t i o n of a minimum of six inches of top soil in the land s caped area; andremoval of a minimum of six inches of material and replacement with t o p s o i lin the f l ower bed.The structure on this p r o p e r t y has been determined to be non-contributing tothe L e a d v i l l e His tor i c M i n i n g District by the State His tor i c PreservationO f f i c e (SHPO). In a d d i t i o n , because the areas to be remediated have beendis turbed, archaeological potential is not considered s igni f i cant . There f or e theresponse action was not monitored by a cultural resource p r o f e s s i o n a l .

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The Removal Action at the Foy residence was comple t ed by July 11,1998A C T I O N M E M O R A N D U M S I G N E D : J U L Y 7,1998R E M O V A L S T A R T : J U L Y 7,1998R E M O V A L C O M P L E T E : J U L Y 11,1998

Operable U n i t 9, KFP Removal 25An Action Memorandum for a T i m e Cri t i ca l Removal at the Kolakowski residencelocated at 813 Spruce S t r e e t , L e a d v i l l e , Colorado , was signed on July 7, 1998.S a m p l e s col lec ted under the Kids First Program determined that lead level sin s a m p l e s col lec ted from the so i l s in the f l o w e r bed a long the back of thehouse and the small back yard at the Kolakowski proper ty exceeded the KidsFirst t r igger value of 3,500 ppm. The grass in the back yard is dense and ingood condit ion. T h e r e f o r e , no remediation activities were per formed in thatarea.Remediation activities in the f l o w e r bed along the west side of the houseinc luded removal of material to a minimum d e p t h of six inches andreplacement with six inches of top soil.The structure on this proper ty has been determined to be p o t e n t i a l l ycontributing to the L e a d v i l l e H i s t o r i c M i n i n g District by the Sta t e H i s t o r i cPreservation O f f i c e (SHPO). SHPO assigned th e site number 5LK40.105to thi s property. However, because the areas to be remediated have beend i s turb ed , archaeological po t en t ia l was not considered to be s i g n i f i c a n t .T h e r e f o r e , the response action was not monitored by a cultural resourcepro f e s s i ona l . .The Removal Action at the Kolakowski residence was comple t ed byJ u l y 14,1998.

A C T I O N M E M O R A N D U M S I G N E D : J U L Y 7,1998R E M O V A L S T A R T : J U L Y 7,1998REMOVAL C O M P L E T E : J U L Y 14,1998

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Operable Uni t 9, KFP Removal 26An Action Memorandum for a T i m e Cri t i cal Removal at the Patti residence ,located at 130 West 7th Str e e t , L e a d v i l l e , Colorado was signed onJuly 7,1998. S a m p l e s col lec ted under the Kids Firs t Program determined thatlead level s in s ampl e s co l l e c t ed from the so i l s in the f l o w e r bed a long thewest side of the house and the front yard at the Patti proper ty exceeded theKids First t r igger value of 3,500 ppm. The grass in the front yard is dense andin good condition. No remediation activities were performed in that area.Remediation activit ie s in the f l o w e r bed a long the west s ide of the houseincluded removal of material to a minimum d e p t h of six inches andreplacement with six inches of top soil.The structure on this property has been determined to be p o t e n t i a l l ycontributing to the L e a d v i l l e H i s t o r i c M i n i n g District by the Sta t e H i s t o r i cPreservation O f f i c e (SHPO). SHPO assigned the site number 5LK40.107to thi s property. However, because the areas to be remediated have beendi s turbed , archaeological po t en t ia l is not considered to be s i g n i f i c a n t .T h e r e f o r e , the response action was not monitored by a cultural resourcep r o f e s s i o n a l .The Removal Action at the Patti residence was comple t ed byJ u l y 14,1998.

A C T I O N M E M O R A N D U M S I G N E D : J U L Y 7,1998REMOVAL S T A R T : J U L Y 7,1998R E M O V A L C O M P L E T E : J U L Y 14,1998

Operable Uni t 9, KFP Removal 27An Action Memorandum for a T i m e Cri t i ca l Removal at the Ramos residence ,located at Lake F o r k T r a i l e r Park #26, L e a d v i l l e , Co lorado , was signed on July 7,1998. S a m p l e s collected under the Kids First Program determined that leadlevels in sample s co l l ec t ed from so i l s in the bare areas at the front and back

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of the tra i l er and yard surrounding the t ra i l er at the Ramos proper ty exceededthe Kids First t r i g g e r value of 3,500 ppm. In a d d i t i o n , the grass in yard iss po t ty and in poor condition.Remediation activities inc luded removal of material to a minimum d e p t h of sixinches in the two bare areas and the yard. Top soil and sod were ins ta l l ed inthe area. A f iv e inch s tr ip of t o p s o i l (to a l l ow p l a n t i n g of b e d d i n g p l a n t s ) wasi n s t a l l e d a long the edges.The structure on thi s proper ty has been determined to be non-contributing tothe L e a d v i l l e His t or i c M i n i n g District by the Stat e H i s t o r i c PreservationO f f i c e (SHPO). In a d d i t i o n , because the areas to be remediated have beend i s t urb ed , archaeological potent ial is not considered s ign i f i can t . T h e r e f o r eresponse actions were not monitored by a cultural resource p r o f e s s i o n a l .The Removal Action at the Ramos residence was completed byJ u l y 17,1998,

A C T I O N M E M O R A N D U M S I G N E D : J U L Y 7,1998REMOVAL S T A R T : J U L Y 7,1998R E M O V A L C O M P L E T E : J U L Y 17,1998

Operable Unit 9, KFP Removal 28An Action Memorandum for a Time Critical Removal at the A l i e n residence, locatedat 203 West 9 t h St, L e a d v i l l e , Colorado was signed on August 17,1998. S a m p l e scol l ec t ed under the Kids First Program determined that lead level s in thes a m p l e col lec ted f rom so i l s in the bare area of the back yard at the Alienproper ty exceeded the Kids First t r igger value of 3,500 p p m .Remediation act ivit ie s included removal of material to a minimum d e p t h of sixinches and replacement with C l a s s six road base which was i n s t a l l e d andcompacted in this area. A border of railroad ties was i n s t a l l e d between theroad base and exist ing grass.The structure on thi s proper ty has been determined to be p o t e n t i a l l ycontributing to the L e a d v i l l e His t or i c Landmark District by the State H i s t o r i cPreservation O f f i c e (SHPO). SHPO assigned th e site number 5LK40.106

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to this property. In addi t i on, archaeological potential has been i d e n t i f i e d atthis property. T h e r e f o r e a cultural resource pro f e s s i ona l monitored excavationof so i l s at this proper tyThe Removal Action at the A l i e n residence was completed byS e p t e m b e r ? , 1998.

A C T I O N M E M O R A N D U M S I G N E D : A U G U S T 17,1998R E M O V A L S T A R T : A U G U S T 17,1998R E M O V A L C O M P L E T E : S E P T E M B E R 7,1998

Operable Unit 9, KFP Removal 29An Action Memorandum for a T i m e Critical Removal at the Cruz-Sanchezresidence was signed on August 17,1998. S a m p l e s co l l ec t ed under the KidsFirst Program determined that lead level s in the sampl e s col lec ted from so i l sin the driveway and the yard in front of the trai l er at the Cruz-Sanchez proper tyexceeded the Kids First tr igger value of 3,500 ppm and the area is bare.Remediation act ivit ie s are described below:The condition of the f ront yard was evaluated in the field and the area wasprepared for sod and top so i l and sod was i n s t a l l e d . Remediation activities forthe driveway, shown on F i g u r e 3, inc lude removal of a minimum of six inchesof material. A six inch reinforced concrete pad wi l l be i n s t a l l e d in the drivewayto match surrounding grade and wi l l be graded to drain toward the street.The structure on this prop er ty does not contribute to the L e a d v l l l e H i s t o r i cLandmark District because it is a mobile home. Excavation of so i l s at th i sproper ty was not monitored by a cultural resource pro f e s s i ona l because thearea had been disturbed.The Removal Action at the Cruz-Sanchez residence was completed byS e p t e m b e r 2,1998.

A C T I O N M E M O R A N D U M S I G N E D : A U G U S T 17,1998R E M O V A L S T A R T : A U G U S T 17,1998REMOVAL C O M P L E T E : S e p t e m b e r 2,1998

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Operable Unit 9, KFP Removal 30An Action Memorandum for a T i m e Critical Removal at the Daigle residence,located at 323 West 4th Str e e t , was signed on Augus t 17, 1998. S a m p l e sco l l e c t ed under the Kids First Program determined that lead level s in thes ampl e s col lec ted from so i l s in the bare area in the southeast comer of theproper ty and soil s in the f l o w e r bed in the backyard at the D a i g l e proper tyexceeded the Kids First tr igger value of 3,500 p p m . The area in the southeastcomer is in poor condition and soi l s in the f l o w e r bed are accessible tochildren.Remediat ion activities for the bare area inc luded removal of material to aminimum d e p t h of six inches and replacement with clean topsoi l and sod. Anapprox imate one foo t wide s tr ip of river washed gravel was i n s t a l l e d along thegarage. Metal e d g i n g was i n s t a l l e d between the gravel and the sod.Remediation for the f l ower bed included removal of a minimum six inches ofsoil and replacement with clean t o p s o i l to match the exi s t ing grade.The structure on this property has been determined to be p o t e n t i a l l ycontributing to the L e a d v i l l e H i s t o r i c Landmark District by the Sta t e H i s t o r i cPreservation O f f i c e (SHPO). SHPO assigned th e site number 5LK40.110to thi s property. Archaeological po t ent ia l was not i d e n t i f i e d at th i s property.Excavation of soi l s was not monitored by a cultural resource pro f e s s i ona l .The Removal Action at the D a i g l e residence was comple ted onS e p t e m b e r 2,1998.

A C T I O N M E M O R A N D U M S I G N E D : A U G U S T 17,1998R E M O V A L S T A R T : A U G U S T 17,1998R E M O V A L C O M P L E T E : S E P T E M B E R 2,1998

Operable Unit 9, KFP Removal 31An Action Memorandum for a T i m e Critical Removal at the Rhoades residence,located at 211 East 4th Stree t , L e a d v i l l e , Colorado , was signed on Sept ember 17,1998. S a m p l e s col lec ted under the Kids First Program determined that leadlevels in the samples collected from soil s in the bare area at the at the south

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end of the driveway and within the area of the concrete f o u n d a t i o n of theRhoades p r o p e r t y exceeded the Kids First t r i g g e r value of 3,500 ppm. Thelead concentrations in samples collected from f l ower beds along the north andwest s ides of the house also exceeded the Kids First t r i g g e r value. The leadconcentration in the s ampl e s col lec ted from the gravel driveway and theadjacent east side yard did not exceed the Kids First tr igger value.The Kids Firs t Work Group (KFWG) recommended remediation o f the areaswith lead concentrations that exceeded the Kids First t r igger value of 3,500ppm (the f l o w e r beds along the north and west s ides of the house and thebare area at the south end of the driveway and within the area of the concretef o u n d a t i o n ) . However, the proper ty owners opted for no action in the f l o w e rbeds (which have thick, well established f lower s and grasses) along the northand west sides of the house.Lead concentrations in the samples collected from the driveway and theadjacent east s ide yard did not exceed the Kids f i r s t t r i gg er value of 3,500ppm. However, a ch i ld who had an elevated blood lead level (greater than 40ug/dl) and underwent medical treatment to reduce her blood lead level spendsa s i g n i f i c a n t amount of time at this property. T h e r e f o r e , due to this specialcircumstance, the decision was made to remediate the driveway and east s ideyard.Remediation activities inc luded removal of material , as a p p r o p r i a t e , tof a c i l i t a t e g r a d i n g and drainage requirements and to a l l ow i n s t a l l a t i o n of aminimum six inch cover in the areas to be addres sed. Cover materialsconsisted of concrete, compacted road base, t o p s o i l , t op so i l and sod, andgravel.The Stat e H i s t o r i c Preservation O f f i c e (SHPO) has determined that thi sproper ty p o t e n t i a l l y contributes to the L e a d v i l l e H i s t o r i c Landmark District.Archaeological potential was id en t i f i ed at this property. There f or e , a culturalresource pro f e s s i ona l monitored excavation of so i l s at this property.The Removal Action at the Rhoades residence was completed onS e p t e m b e r 4,1998.

A C T I O N M E M O R A N D U M S I G N E D : S E P T E M B E R 17,1998R E M O V A L S T A R T : A U G U S T 26,1998R E M O V A L C O M P L E T E : S E P T E M B E R 4,1998

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Operable Unit 9, KFP Removal 32An Action Memorandum for a T i m e Cri t i ca l Removal at the Sorcic residence,located at 430 East 8th Stre e t , L e a d v i l l e , Colorado, was signed on Sep t ember 17,1998. S a m p l e s collected under the Kids First Program determined that leadl eve l s in the sampl e s collected from so i l s in the bare area in the back yardand f rom the gravel covered area in the front yard of the Sorcic proper tyexceeded the Kids First t r igg er value of 3,500 ppm.Remediation activities for the bare area in the backyard included removal ofmaterial to a minimum d e p t h of six inches. Clean t o p s o i l and sod wasi n s t a l l e d over the area with the exception of a s tr ip one foot wide s t r ip a longthe house where river washed gravel was i n s t a l l e d . Metal e d g i n g wasi n s t a l l e d between the gravel and the sod. Remediation for the gravel walk inthe front yard included removal of a minimum six inches of soil andreplacement with a concrete s i d ewa lk graded to match the surroundinggrades. The driveway and drainage swale were excavated, as a p p r o p r i a t e ,to allow drainage. An arch corrugated metal p i p e (CMP) was in s ta l l ed in thedrainage swale. A six inch reinforced concrete slab was constructed over theCMP for the driveway to match the surrounding grades.The structure on thi s proper ty has been determined to be p o t e n t i a l l ycontributing to the L e a d v i l l e H i s t o r i c Landmark District by the Sta t e H i s t o r i cPreservation O f f i c e (SHPO). SHPO assigned the site number 5LK1263 tothis property. Archaeo logi ca l potent ial was i d e n t i f i e d in the backyard at thi sproperty. T h e r e f o r e , a cultural resource pro f e s s i ona l monitored excavation ofsoil s in the backyard.The Removal Action at the Sorcic residence was comple t ed onS e p t e m b e r 14,1998.

A C T I O N M E M O R A N D U M S I G N E D : S E P T E M B E R 17,1998R E M O V A L S T A R T : S E P T E M B E R 3,1998R E M O V A L C O M P L E T E : S E P T E M B E R 14,1998

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Operable Uni t 9, KFP Removal 33An Action Memorandum for a T i m e Crit ical Removal at the W o h l m u t h residence,located at 214 West 7 th Str e e t , L e a d v i l l e , Colorado was signed onSeptember 17, 1998. S a m p l e s col lec ted under the Kids First Programdetermined that lead level s in the s ampl e s co l l e c t ed from so i l s in the grassarea in the front yard; the f l o w e r beds on the east and west s ides of the frontporch, the quarter circle f l ower beds in the front yard next to the s idewalk , andthe area in the backyard with thin grass cover of the W o h l m u t h proper tyexceeded the Kids First t r igger value of 3,500 ppm.Remediation act ivi t ie s inc luded removal of so i l s to a minimum d e p t h of sixinches from the grass area and quarter circle f l o w e r beds in the front yard.Clean t op s o i l was placed in the excavated area and graded to match thesurrounding grade. Sod was then i n s t a l l e d . The f l o w e r bed on the west sideof the porch was removed and reshaped s imi lar to the f l o w e r bed on the eastside of the porch. A minimum of six inches of material was excavated fromthe f l o w e r beds around the front porch and along the front of the house. Cleant o p s o i l was then i n s t a l l e d in the two f l o w e r beds to match the surroundinggrade. A minimum of six inches of material was removed from the areas withthin grass in the backyard. Clean t op s o i l was placed in the excavated areasand graded to match the surrounding grades. Sod was then i n s t a l l e d .The structure on thi s proper ty has been determined to be p o t e n t i a l l ycontributing to the L e a d v i l l e H i s t o r i c Landmark District by the S t a t e H i s t o r i cPreservation O f f i c e (SHPO). SHPO assigned the site number 5 L K 1 2 6 2 tothis property. Archaeo logi ca l potent ial was not i d e n t i f i e d at thi s property.T h e r e f o r e , a cultural resource pro f e s s i ona l did not monitor excavation of so i l sat thi s proper ty.The Removal Action at the Wohlmuth residence was comple ted onS e p t e m b e r 29,1998.

A C T I O N M E M O R A N D U M S I G N E D : S E P T E M B E R 17,1998R E M O V A L S T A R T : S E P T E M B E R 17,1998R E M O V A L C O M P L E T E : S E P T E M B E R 29,1998

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Operable Uni t 9, KFP Removal 34An Action Memorandum for a Time Critical Removal at the Grant residence,located at 225 East 9th Stre e t , in L e a d v i l l e , Colorado was signed onS e p t e m b e r 24, 1998. S a m p l e s col lec ted under the Kids First Programdetermined that lead levels in the sample s co l l e c t ed from s o i l s in the barearea in the back yard; from the soils in the front and east yards and from theso i l s in the former f l ower bed along the east side of the house, on the Grantproper ty , exceeded the Kids First t r igg er value of 3,500 p p m .Remediation activities in c lud ed removal of soil to a minimum d e p t h of sixinches from the front and east side yards. Clean t o p s o i l was placed in theexcavated area and graded to match the surrounding grade and to f a c i l i t a t edra inage away from the house. Sod was then i n s t a l l e d . The soi l s in theformer f l o w e r beds were removed to a minimum d e p t h of six inches. A onefoot wide s trip of river washed gravel was in s ta l l ed along the house. Metale d g i n g was be i n s t a l l e d between the gravel and the sod. A minimum of sixinches of material was removed from the bare area in the back yard. Roadbase was in s t a l l ed and compacted in the excavated area to match thesurrounding grade and to f a c i l i t a t e drainage away from the house and shed.The structure on thi s proper ty has been determined to be p o t e n t i a l l ycontribut ing to the L e a d v i l l e H i s t o r i c Landmark District by the Sta t e H i s t o r i cPreservation O f f i c e (SHPO). SHPO assigned the site number 5 L K 1 2 6 9 toth i s property. Archaeological potential was i d e n t i f i e d in the backyard at thi sproperty. T h e r e f o r e , a cultural resource pro f e s s i ona l monitored excavation ofso i l s in the backyard.The Removal Action at the Grant residence was completed onS e p t e m b e r 29,1998.

A C T I O N M E M O R A N D U M S I G N E D : S E P T E M B E R 24,1998R E M O V A L S T A R T : S E P T E M B E R 24,1998REMOVAL C O M P L E T E : S E P T E M B E R 29,1998

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Operable Unit 9, KFP Removal 35An Action Memorandum for a T i m e Critical Removal at the Lind residence, locatedat 229 East 9th Stree t , in L e a d v i l l e , Colorado was signed on S e p t e m b e r 24,1998.S a m p l e s co l l e c t ed under the Kids First Program determined that lead l eve l sin the s ampl e co l l ec t ed from soi l s in the area covered with spo t ty grass in theback yard and the east side yard of the Lind prop er ty , exceeded the Kids Firstt r igger value of 3,500 ppm.Remediation activities inc luded removal of soil to a minimum d e p t h of sixinches from the back yard. Clean t op s o i l was p laced in the excavated areaand graded to match the surrounding grade and to f a c i l i t a t e drainage awayf rom the house. Sod was then i n s t a l l e d . A one foo t wide s tr ip of riverwashed gravel was i n s t a l l e d a long the house. Metal e d g i n g was i n s t a l l e dbetween the gravel and the sod. A minimum of six inches of material wasremoved from the area between the east side of the house and the adjacenthouse and replaced with pea gravel.The structure on thi s prop er ty has been determined to be p o t e n t i a l l ycontributing to the L e a d v i l l e H i s t o r i c Landmark District by the S t a t e H i s t o r i cPreservation O f f i c e (SHPO). SHPO assigned the site number 5 L K 1 2 6 1 tothis property. Archaeological potential was i d e n t i f i e d in the backyard at thisproperty. T h e r e f o r e , a cultural resource p r o f e s s i o n a l monitored excavation ofso i l s in the backyard.

The Removal Action at the Lind residence was comple t ed onS e p t e m b e r 28,1998.A C T I O N M E M O R A N D U M S I G N E D : S E P T E M B E R 24,1998R E M O V A L S T A R T : S E P T E M B E R 24,1998R E M O V A L C O M P L E T E : S E P T E M B E R 28,1998

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Operable Unit 9, KFP Removal 36An Action Memorandum for a T i m e Crit i cal Removal at the Lykins residencelocated at 512 !4 East 7th Street , L e a d v t l l e , Colorado, was signed on September 24,1998. S a m p l e s c o l l e c t ed under the Kids First Program determined that leadl eve l s in the s ampl e co l l e c t ed from so i l s in the area between the s idewalk andthe house; the area along East 7th S t r e e t ; the so i l s in the east side yard; andthe northeast comer of the backyard of the Lykins property, exceeded the KidsFirst t r igg er value of 3,500 p p m .The remediation activit ies inc luded removal of soil to a minimum d e p t h of sixinches from the areas to be remediated. Clean t op s o i l was placed in theexcavated area in the east s ide yard, and graded to match the pre-exi s t inggrade and to f a c i l i t a t e drainage away from the house. Sod was thenin s ta l l ed . A strip of gravel was in s ta l l ed along the house. Metal edg ing wasi n s t a l l e d between the gravel and the sod. Clean t op so i l was placed in the "L"shaped area in the southwest comer of the east side yard. Clean t op s o i l wasplaced in the excavation between the house and the s idewalk to match thegrade of the s idewalk. Road base was i n s t a l l e d in the area between thea spha l t driveway and the house and compacted to match the grade of thedriveway and to f a c i l i t a t e drainage away from the house. Reinforcedconcrete was ins ta l l ed in the excavation on the s lope and the drainage swalealong East 7th Street and matching the grade of the a spha l t . Cl ean sand wasplaced in the northeast comer of the backyard. A six by six foo t sandbox wasconstructed within thi s area.The Stat e H i s t o r i c Preservation O f f i c e (SHPO) determined that the structurelocated on this proper ty does not contribute to the L e a d v i l l e H i s t o r i c LandmarkDistrict. Archaeological potential was i d e n t i f i e d in the backyard at thisproper ty; therefore, a cultural resource pro f e s s i onal monitored excavation ofsoi l s in the backyard. Archaeological potent ial was not i d e n t i f i e d in the otherareas to be remediated; there fore , monitoring by a cultural resourcepro f e s s i onal was not required in the other areas involved in this responseaction.

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The Removal Action at the Lykins residence was comple t ed onOctober 19,1998.A C T I O N M E M O R A N D U M S I G N E D : S E P T E M B E R 24,1998REMOVAL S T A R T : S E P T E M B E R 24,1998REMOVAL C O M P L E T E : OCTOBER 19,1998

Operable Unit 9, KFP Removal 37An Action Memorandum for a Time Cri t i ca l Removal at the Quintana residencelocated at Lake F o r k T r a i l e r Park #115, L e a d v i l l e , Colorado, was signed onS e p t e m b e r 24, 1998. S a m p l e s co l l ec t ed under the Kids First Programdetermined that lead level s in the s ampl e col lec ted from so i l s from the f l o w e rbed in the front yard; from the soils in the north side yard and from the so i l sat the east end of the lot and along the south side of the mobile home of theQuintana prop er ty , exceeded the Kids First t r igger value of 3,500 p p m .The remediation activit ies inc luded removal of soil to a minimum d e p t h of sixinches from the areas to be remediated. Clean topsoi l was placed in theexcavated area in the f l o w e r bed at the front of the mobile home and gradedto f a c i l i t a t e drainage away from the mobile home. Sod was then i n s t a l l e d .Road base was placed and compacted in the excavation along the north sideof the porch. Clean t op so i l and sod was i n s t a l l e d in the excavation along thenorth s ide of the mobile home to the east end of the lot and graded to f a c i l i t a t edrainage away from the mobile home. Road base was placed and compactedin the excavation at the east end of the shed and a long the south s ide of themobile home and graded to f a c i l i t a t e drainage away from the shed and mobilehome.The structure located on thi s proper ty if a mobi le home; there fore , it does notcontribute to the L e a d v i l l e H i s t o r i c Landmark District Archaeologicalpotent ial was not i d e n t i f i e d ; therefore monitoring by a cultural resourcepro f e s s i ona l was not required.

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The Removal Action at the Quintana residence was completed onOctobers, 1998.A C T I O N M E M O R A N D U M S I G N E D : S E P T E M B E R 24,1998R E M O V A L S T A R T : S E P T E M B E R 24,1998R E M O V A L C O M P L E T E : OCTOBER 8,1998

Operable Unit 9, KFP Removal 38An Action Memorandum for a T i m e Cri t i ca l Removal at the J a u e r n i g g residencelocated at 125 East 13th Stree t , L e a d v i l l e , Colorado , was signed onOctobers, 1998. S a m p l e s co l l ec t ed under the Kids First Program determinedthat lead level s in the s a m p l e co l l ec t ed from so i l s in the driveway and the areaadjacent to the east side of the house on the J a u e r n i g g property, exceededthe Kids First tr igger value of 3,500 ppm.The remediation activities i n c l u d e d removal of soil to a minimum d e p t h of sixinches from the areas to be remediated. A reinforced concrete pad wasi n s t a l l e d in the excavation in the driveway and matched the grade of East 13thStreet. A s tr ip of gravel was i n s t a l l e d along the east s ide of the concrete.Gravel was placed in the excavation to the east side of the house.The State H i s t o r i c Preservation O f f i c e (SHPO) determined that the structurelocated on thi s proper ty does not contribute to the L e a d v i l l e H i s t o r i c LandmarkDistrict. Archaeological potent ial was not i d e n t i f i e d at thi s proper ty; there fore ,a cultural resource pro f e s s i ona l was not required to monitor excavation ofsoilsThe Removal Action at the J a u e r n i g g residence was comple t ed onOctober 19,1998.

A C T I O N M E M O R A N D U M S I G N E D : OCTOBER 5,1998R E M O V A L S T A R T : O C T O B E R S , 1998R E M O V A L C O M P L E T E : OCTOBER 19,1998

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Operable Unit 9, KFP Removal 39An Action Memorandum for a T i m e Crit i cal Removal at the Griego residencelocated at 618 East 7th Stre e t , L e a d v i l l e , Colorado , was signed onOctober 22,1998. S a m p l e s co l l ec t ed under the Kids First Program determinedthat lead level s in the s a m p l e col lec ted from so i l s in the west side yard of theGriego proper ty , exceeded the Kids First t r igger value of 3,500 ppm.The remediation activities included removal of soil to a minimum d e p t h of sixinches f r om the area to be remediated. C l e a n t o p s o i l was placed in theexcavated area in the west side yard and graded to f a c i l i t a t e drainage awayfrom the house. N a t i v e seed mix was then p la c ed .The structure on this proper ty is a modular home and, therefore, does notcontribute to the L e a d v i l l e H i s t o r i c Landmark District. Archaeologicalpo t ent ia l was i d e n t i f i e d at this p r o p e r t y ; there fore , a cultural resourcepro f e s s i ona l monitored excavation of soi l s at thi s property.The Removal Action at the Griego residence was comple t ed onNovember 6,1998.

A C T I O N M E M O R A N D U M S I G N E D : OCTOBER 22,1998REMOVAL S T A R T : OCTOBER 22,1998R E M O V A L C O M P L E T E : N O V E M B E R 6,1998

Operable Unit 9, KFP Removal 40An Action Memorandum for a T i m e Cri t i ca l Removal at the Lee-Sobal residencelocated at 311 East 4th Stree t , L e a d v i l l e , Colorado , was signed on October 22,1998. S a m p l e s col lec ted under the Kids First Program determined that leadl evel s in the sample co l l e c t ed from soi l s in the parking area; in the front andwest side yards; in the p i l e in the northwest comer; in the bare area in thewest side of the back yard; in the east side of the back yard; and in thef lowerbed in the east side yard of the Lee-Sobal proper ty , exceeded the KidsFirst t r i g g e r value of 3,500 p p m .

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The remediation activities included removal of soil from the areas to beremediated to an adequate d e p t h to a l low for replacement of six inches ofclean material and to f a c i l i t a t e drainage away from the house. A six-inchreinforced concrete pad was constructed in front of the house. A concretesidewalk was constructed from the south end of the concrete driveway to theporch on the east side of the house. A f l o w e r bed was constructed east of thehouse and filled with clean t o p s o i l . Six inches of river washed gravel wasp lac ed in the excavated area east of the new driveway. Six inches ofcompacted road base was placed in the excavation north of the gravel andnew concrete p a d , e x t end ing west to the f ence along Starr Ditch and north tothe edge of the a spha l t on East 4th Street. Six inches of clean t op s o i l wasplaced in the excavation in the west side of the front yard and all of the backyard. T o p s o i l only was placed in the center of the west front yard and alongthe west and south edges of the back yard. The remainder of the front yardand west h a l f of the back yard was seeded with C l i m a x native seed mix. Sodwas i n s t a l l e d in the east side of the back yard. Six inches of gravel wasplaced in the area between the house and the new s idewalk and along theperimeter of the house.The S t a t e H i s t o r i c Preservation O f f i c e (SHPO) determined that the structurelocated on this property does not contribute to the L e a d v i l l e His tor i c LandmarkDistrict. Archaeo logi ca l po t ent ia l was i d e n t i f i e d at thi s proper ty; there fore , acultural resource pro f e s s i ona l monitored the excavation of soils.The Removal Action at the Lee-Sobal residence was completed onOctober 27,1998.

A C T I O N M E M O R A N D U M S I G N E D : OCTOBER 22,1998R E M O V A L START: OCTOBER 22, 1998R E M O V A L C O M P L E T E : OCTOBER 27,1998.

V . COST I N F O R M A T I O NAsarco, Inc. is the party that was r e spons ib l e for p e r f o r m i n g these removal actions.

V I . D I S P O S I T I O N O F W A S T E SAll wastes removed during the course of these removal actions were disposed onsite as approved by EPA.

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