159 Dinah Road, Asheboro, North Carolina 27203

Lead and arsenic are present from battery cracking activities formerly performed at the Site.  The facility was reportedly in operation from 1965 to 1981.  Operations included hundreds of batteries being broken to remove the lead plates and melted in drums to be salvaged.  Battery acid was reportedly allowed to spill onto the ground.  EPA and Superfund Technical Assessment Response Team (START) site assessment on 04/01/2010 revealed XRF detections up to 59,700 ppm for lead and up to 3,735 for arsenic.  The Site is a wooded area behind 159 Dinah road and bordered by a gravel road.  Battery chips and casings were observed to be confined to a bermed area.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

EPA & START conducted a site assessment on 04/01/2010 to delineate the extent of contamination.  XRF readings were taken and two samples for analyticals were submitted as 5-point composite and grab samples.  Readings were taken from grid-like locations along the existing berm behind 159 Dinah road.  XRF readings for lead and arsenic exceeded EPA's RAL for residential lead (400 ppm) and residential arsenic (40 ppm).  Lead was present along the berm up to 59,700 ppm and arsenic up to 3,735 ppm.

Analytical results indicate that lead is present in surface soils above the residential EPA RAL of 400 ppm for lead.  No laboratory data exceeded EPA's RAL for arsenic.  Lead concentrations were detected in surface soils in one composite sample at 5,460 ppm and in one grab sample at 34,900 ppm.

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

Lead and arsenic 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 20,000 ppm.  Further sampling conducted by EPA confirmed elevated lead levels.  EPA Region 4 Technical Services Section (TSS) recommends an RAL of 400 ppm for residential lead exposure scenarios and an RAL of 40 ppm for residential arsenic exposure.  Concentrations exceeding these levels at the Site were confirmed though on-site XRF analysis.  The maximum lead concentration detected in surface soils was 59,700 ppm and 3,735 ppm for arsenic.

The battery chips were reportedly crushed and dispersed throughout the Site.  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.