Pollution/Situation Report Profile

Oak Haven Lead
Salisbury, NC - EPA Region IV
POLREP #1
Removal Site Evaluation POLREP

Printer Friendly | PDF

U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Oak Haven Lead - Removal Polrep
Initial Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV

Subject:

POLREP #1
Removal Site Evaluation POLREP
Oak Haven Lead
B433
Salisbury, NC
Latitude: 35.6369299 Longitude: -80.5296993

To:

From:

Jeffery Crowley, On-Scene Coordinator

Date:

10/15/2009

Reporting Period:

1. Introduction

1.1 Background

Site Number:	B433	Contract Number:
D.O. Number:		Action Memo Date:
Response Authority:	CERCLA	Response Type:	Time-Critical
Response Lead:	EPA	Incident Category:	Removal Assessment
NPL Status:	Non NPL	Operable Unit:
Mobilization Date:		Start Date:
Demob Date:		Completion Date:
CERCLIS ID:	NCN000410468	RCRIS ID:
ERNS No.:		State Notification:	9/10/09
FPN#:		Reimbursable Account #:

1.1.1 Incident Category

CERCLA incident category: Other; improper disposal of batteries

1.1.2 Site Description

1.1.2.1 Location

The Oak Haven Lead Site (the "Site) is located in Salisbury, Rowan County, North Carolina (35.6369299 latitude, -80.5296993 longitude). The Site is currently the location of the Oak Haven Mobile Home park. The mobile home park is approximately on 31 acres with the projected impacted area to be 3 acres. There are 63 mobile homes in the community.

The Site is bordered by Airport Road to the north, woods to the east and south, and industrial buildings to the west. The site drains into a storm sewer that cuts through the middle of the community that empties into an unnamed tributary of Grants Creek.

During the installation of a sanitary sewer along the western portion of the property, the work crew dug into battery chips and referred the Site to North Carolina Department of Environment and Natural Resources (DENR). DENR conducted an investigation of the property and determined that the storm sewer that runs through the Site was built up on battery casings and battery chips were used as fill material. DENR conducted sampling activities and found elevated levels of lead contamination in the soils surrounding the storm sewer. It is believed that the chips were deposited in this location sometime in the early 1970s while grading the land for the mobile home park.

1.1.2.2 Description of Threat

In September of 2009 DENR asked Region 4 Emergency Response and Removal Branch (ERRB) to visit the Site. During that time DENR was excavating one portion of the contaminated soil but due to budgetary restrictions would not be able to complete the full removal. During the excavation, DENR dug down as far as 10 feet below ground surface (bgs) and were digging into large quantities of battery chips. DENR then referred the Site to ERRB for a Removal Site Evaluation (RSE) based on the elevated levels of lead present from the battery chips in surface soils.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

During the week of September 14, 2009 EPA and its Superfund Technical Assessment and Response Team (START) contractor mobilized to the Site to determine if the Site needed an immediate response from the removal completed by DENR. Over 300 surface (0-1") samples were collected and screened using X-Ray Florescence (XRF) technology. Only one sample came back above the EPA residential screening level of 400 ppm for lead.

The following week of September 21, 2009, EPA and START again sampled the site; this time using a hand auger and XRF to collect samples at 0-6", 6"-1', and 1'-2'. At several of the sample locations battery chips were found in the sampled soil. Results of this sampling concluded that there was lead levels above EPA residential screening levels present in the surface soils. In most locations in the contaminated area, the lead concentration increased as the depth of the sample increased; this is in concurrence with DENR sampling conducted earlier.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative

The Site has had one prior sampling event and removal by DENR prior to EPA getting involved. Results of the DENR sampling revealed levels exceeding EPA Removal Action Levels (RALs) in several locations; with lead levels as high as 14,000 milligrams per kilogram (mg/kg). As a result of their sampling, they identified 4 areas for excavation. During the week of August 31, 2009 DENR began excavation on the largest of the areas they identified. This area would be located along the northern edge of the storm drain. During this action they excavated an estimated 1200 tons of soil.

On September 10, 2009 EPA OSCs conducted a site visit during the excavation and noted a large number of battery chips in the bottom of the 10' deep excavation pit. Even describing that whole battery casings were stacked along the storm sewer. The hole was filled in with clean soil leaving the battery casings at the bottom.

During the following weeks of September 14 and September 21, 2009 EPA OSC Crowley mobilized with START members to conduct a removal site evaluation. The maximum detected concentration of lead was 23,200 mg/kg. Sampling was also conducted near the outfall of the storm sewer and no levels were detected above RALs.

After a review of the data generated from the site evaluation and the known presence of source materials buried in the soils and a review of all site information, ERRB has concluded that the site meets the criteria as set forth in 40 CFR 300.415 (b)(2) for a time critical removal action.

2.1.2 Response Actions to Date

There have been no response actions to date by ERRB as this Site.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

Several PRPs have been identified and letters notifying them of potential liability under Section 107(a) of CERCLA are being prepared.

2.2 Planning Section

Lead is a hazardous substance, as listed in 40 CFR 302.4, and referred to in Section 101 (14) of CERCLA, as amended. Lead contaminated soil at the Site pose a significant threat to public health. The threat comes primarily from potential human exposure to this hazardous substance. Direct contact and ingestion of this hazardous substance is the primary pathway of exposure. Continued release of this hazardous substance may cause potential chronic health effects to persons living and working nearby.

Lead present in on-site surface and subsurface soils pose the following threats to public health or welfare as listed in Section 300.415 (b)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP):

Section 300.415 (b)(2)(i) Actual or potential exposure to nearby human populations, or the food chain from hazardous substances pollutants or contaminants;

DENR's initial investigation revealed that there is significant lead contamination present in soils very close to several mobile homes. Further sampling conducted by EPA confirmed elevated lead levels. EPA Region 4 Technical Services Section (TSS) recommends an RAL of 400 mg/kg lead for residential exposure scenarios. Concentrations exceeding these levels at the Site were confirmed though on-site XRF analysis and laboratory analysis. The maximum lead concentration detected in surface soils was 23,200 mg/kg.

The battery chips and casings are positioned as fill material for the storm sewer that cuts through the middle of the Site. There are several mobile homes that line the valley where the storm sewer runs. It was also noted that the neighborhood is home to many children. These children play in and around the contaminated area as it is located in one of the few open areas of the community. Children as well as adults could come in contact with the contaminants via windborne dust, inadvertent ingestion of contaminated soil, and direct contact with the contaminated surface soils.

Section 300.415 (b)(2)(iv) High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface that may migrate;

Analytical results reveal that elevated lead levels are present at or near the surface creating a potential for migration to off-site locations. Lead concentrations exceeding the lead RAL of 400 mg/kg was confirmed through on-site XRF and laboratory analysis.

Section 300.415 (b)(2)(v) Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released;

As stated earlier, the site drains to the east toward Grants Creek. If the contamination is not addressed with a removal action then lead contamination could possibly migrate offsite.

Section 300.415 (b)(2)(vii) The availability of other appropriate federal or state response mechanisms to respond to the release;

DENR has asked for EPA assistance with this Site.

Due to the threat and/or future threat to human health from the hazardous substance, the Site achieves removal eligibility based on the removal criteria listed above.

2.3 Logistics Section