FAQs: What EPA's Updated Screening Levels for Lead in Residential Soil Mean for EPA's Brownfields Program
These FAQs provide background information on EPA's updated screening levels for lead in residential soil guidance for Superfund and Resource Conservation and Recovery Act (RCRA) sites, and how EPA's Brownfields and Land Revitalization Program will align with this guidance. FAQs listed below are for informational purposes, and are applicable only to EPA's Brownfields Program.
Background
1. What change did EPA make to screening levels for lead in residential soil at CERCLA and RCRA Corrective Action sites?
On January 17, 2024, the U.S. Environmental Protection Agency issued updated guidance lowering the recommended screening levels for lead in residential soil at CERCLA sites and RCRA Corrective Action Facilities.
- EPA lowered the recommended screening level from 400 parts per million (ppm) to 200ppm.
- At residential properties with multiple sources of lead exposure (e.g., lead water service lines, lead-based paint or non-attainment areas where the air lead concentrations exceed National Ambient Air Quality Standards [NAAQS]), EPA lowered the recommended screening level to 100ppm.
2. Why did EPA update this guidance?
Protecting children from lead exposure is one of EPA's top priorities. The science on lead has evolved to demonstrate that lead exposure is harmful to children's health at lower levels than we previously understood.
The updated guidance strengthens protection against lead exposure in residential areas where children live and play.
The updated guidance also recognizes the cumulative impacts to human health from aggregate sources of lead in a community. Overburdened and underserved communities may be especially at risk from aggregate sources of lead.
3. Where can I find more information about these changes?
- Find the Resource Page on the Updated Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities here.
- Find the EPA's Final Strategy to Reduce Lead Exposures and Disparities in U.S. Communities here.
Aligning the Updated Guidance with EPA's Brownfields Program
General Information
4. How is EPA's Brownfields Program aligning the updated guidance into Brownfields Program activities?
EPA's Brownfields Program is:
- Aligning Targeted Brownfields Assessment (TBA) activities to the updated guidance at sites considered for residential reuse and,
- Encouraging EPA Brownfields Project Officers to discuss the updated guidance with brownfields grantees at sites considered for residential site reuse.
5. What is a "site considered for residential reuse" under the Brownfields Program?
A site considered for residential reuse under EPA's Brownfields Program is one where the planned reuse may be residential. Residential reuses may be any areas where children have unrestricted access to lead-contaminated soil, including properties containing single and multi-family dwellings, apartment complexes, vacant lots in residential areas, schools, day-care centers, community centers, playgrounds, parks and other recreational areas in green ways.
6. Does EPA's Brownfields Program's alignment with the updated screening level guidance change whether states and Tribal Nations have regulatory authority over brownfield sites?
No. States and Tribal Nations remain the regulatory entities that oversee brownfield site assessment and cleanup.
7. Are states and Tribal Nations required to use EPA's updated screening level guidance at brownfield sites?
No. States and Tribal Nations are the regulatory entities that oversee brownfield site assessment and cleanup, and as such they are not required to use the updated screening levels. EPA will refer to State or Tribal Response Programs for application of screening for lead in soil at brownfield sites where the planned site reuse may be residential.
8. Does EPA's Brownfields Program's alignment with the updated screening level guidance require states and Tribal Nations to change the lead screening levels they established for brownfield site assessment and cleanups?
No. EPA's Brownfields Program's decision to align with the updated screening level guidance does not affect state or Tribal Nation site screening levels for lead in residential soil at brownfield sites.
9. What is the difference between screening levels and cleanup levels for brownfield sites?
Screening levels are not cleanup levels. Definitions which distinguish the two are below.
Soil Screening levels at Brownfield Sites:
- Are used in the early stages of investigation to identify areas of potential risk due to contamination. A screening level does not identify whether there is direct exposure to a contaminant.
- May depend on the type of contaminant found at a site (e.g., lead) and type of property (e.g., residential, non-residential, etc.) amongst other factors.
Soil Cleanup levels at Brownfield Sites:
- Are used to identify the specific concentration of contaminants in soil that must be achieved to ensure the site is safe for its intended use. The soil must be remediated to meet or fall below the established cleanup level.
- They are developed after assessing the specific risks and other relevant site-specific information. The levels may depend on:
- The type of contaminant found at a site (e.g., lead).
- How the site will be reused (e.g., residential, industrial, etc.).
- Potential pathways and extent of exposure.
- If there is exposure to vulnerable populations such as children or women of child-bearing age.
- Cost and feasibility.
- May vary from site-to-site based on conditions specific to the area.
EPA's TBA Program
10. How is EPA's Brownfields Program incorporating the updated screening level for lead in residential soil via the TBA Program?
When an EPA contractor conducts a TBA at a brownfield site where lead is a contaminant and the reuse of the site may be residential, contractors employed by EPA will note the EPA's updated screening level for lead in residential soil alongside the appropriate state or Tribal Nation screening level, as available. Reports will reflect the updated EPA screening levels in both the summary of sampling results and the discussion sections of the TBA final report.
- Example report language: "Note: As of January 2024. EPA's screening levels for lead in residential soil are 200ppm, or 100ppm at residential properties with multiple sources of lead exposure."
Note: As per question #6 above, States and Tribal Nations remain the regulatory entities that oversee brownfield site assessment and cleanup.
11. What information should EPA contractors use to determine the appropriate residential lead screening level (200ppm or 100ppm) for TBA sites?
EPA TBA contractors should follow the lead soil screening level of 200ppm unless an additional source of lead is identified at a site.
In making a site-specific decision on whether to use a screening level of 200ppm v. 100ppm, EPA TBA contractors may use national data sets in the Residential Lead Screening Level Checklist, which is used by EPA's Superfund Program. EPA TBA contractors should work with EPA regional staff to access the GIS tool mentioned in the checklist. EPA TBA contractors can alternatively use the National data sets identified in the "References" column in Table 1 of the checklist; these resources are open to the public.
Site-specific sources of information (e.g., data from the local health department or local public water system), alone or in combination with national data sets, may also be used to select an appropriate screening level of either 100ppm or 200ppm. EPA TBA contractors need to document the site-specific rationale for the selected screening level in TBA reports.
EPA Brownfield Grant Recipients
12. How does EPA's updated screening level for lead in residential soil affect sites receiving grant assistance from EPA's Brownfields Program?
Sites receiving grant assistance from EPA's Brownfields Program must continue to follow the soil screening and cleanup levels established by states and Tribal Nations.
13. When are specific opportunities for brownfields grant recipients to discuss the updated guidance with EPA regional staff?
EPA regional staff are always available to discuss EPA's updated guidance for screening levels for lead in residential soil.
At sites where lead is a contaminant and the planned reuse may be residential, EPA regional staff will work with the grant recipient to inform them about EPA's soil screening level guidance of 200ppm, or 100ppm at properties with multiple sources of lead exposure.
Specific opportunities where EPA staff and grant recipients can discuss this updated lead guidance include:
1) In the initial meeting with your project officer.
2) When meeting with the state and the QEP for the grant kickoff call.
3) During Quality Assurance plan development.
States and Tribal Nations are the regulatory entities that oversee brownfield site assessments and cleanups. Brownfields grant recipients follow the soil screening and cleanup levels set by their state or Tribal Nation.