1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

NC DENR conducted sampling along Psalm Street and found lead present at concentrations up to 43,600 ppm.  NC DENR requested EPA conduct further investigation.  EPA conducted a site visit on 1/3/2010 and visually observed the presence of battery chips in various locations along Psalm Street and private driveways and determined further action was necessary. 

EPA and Superfund Technical Assessment Response Team (START) revisited the site on 03/31/2010 to conduct a more thorough assessment to delineate the extent of contamination through composite and grab samples within residential yards and along the gravel road on Psalm Street.  All sampling was screened with an X-Ray Fluorescene (XRF) technology to document and correlate with laboratory data.  The Site is comprised of 20 parcels that include residential homes, one private business, and vacant lots.  Five point composite samples, at 0 - 6 inches in depth, were taken from each parcel, including 2 duplicates, for a total of 22 samples.  XRF readings within the parcels were below EPA's residental RAL of 400 ppm for lead that ranged from 32 ppm - 274 ppm.  One XRF reading spiked at 4,745 ppm as the highest detection within a vacant parcel for lead.  Seventeen grab samples, including one duplicate, were also taken at 0 - 6 inches in depth along the gravel road on Psalm Street at 50 foot intervals.  XRF readings for the grab samples ranged from 35 ppm -  4,794 ppm.  Five drinking water samples, including one duplicate, and natural attenuation parameters were taken from 5 residential homes.  Numerous battery connectors and adapters were found beneath the brush in one vacant parcel. 

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; 

NC DENR's initial investigation revealed that there is significant lead contamination present in surface soils, up to 43,600 ppm.  Further sampling conducted by EPA confirmed elevated lead levels.  EPA Region 4 Technical Services Section (TSS) recommends an RAL of 400 ppm lead for residential exposure scenarios.  Concentrations exceeding these levels at the Site were confirmed though on-site XRF analysis.  The maximum lead concentration detected in surface soils was 4,794 ppm.

The battery chips were reportedly crushed, by a local battery shop, and dispersed throughout the Site and mixed with gravel to create a road.  It was observed that the neighborhood is home to several children.  These children play in and around the contaminated area.  Children, as well as adults, are at risk to 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;

XRF levels 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 ppm was confirmed through on-site XRF readings.

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

If the contamination is not addressed with a removal action, there is a potential for lead contamination to migrate offsite.

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

At the request of NC DENR, EPA has collected sufficient data to proceed with a removal action.

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.