SF_F_NCN000420725_20230919_FRB_PASI(1)

September 19, 2023
Ms. Sandra Bramble, RPM
Restoration and Site Evaluation Section
Superfund and Emergency Management Division
US EPA Region IV
61 Forsyth Street SW, 11th Floor
Atlanta, GA 30303
Subject: Pre-CERCLA Screening Assessment (PCS)
Southern Resources Scrap Metal
NCN000420725
Charlotte, Mecklenburg County, NC
Dear Ms. Bramble:
Enclosed is the Pre-CERCLA Screening Assessment (PCS) for the above referenced site.
The NC Superfund Section conducted this PCS to address potential hazardous exposure via the
subsurface intrusion (SsI) component of the soil exposure and subsurface intrusion and air
migration pathways. Based on the PCS findings, this site is not recommended for addition to the
Superfund Emergency Management System (SEMS) under CERCLA. If you have any questions,
please contact me at [e-mail].
Sincerely,
, ,
Stuart F. Parker, Date Qu, Qi, Head Date
Hydrogeologist Site Evaluation &
NC Superfund Section Removal Branch
NC Superfund Section
cc: File
9/19/2023 9/19/2023
STATE OF NORTH CAROLINA
Department of Environmental Quality
Division of Waste Management
Superfund Section
PRE-CERCLA SCREENING ASSESSMENT (PCS)
SOUTHERN RESOURCES SCRAP METAL
NCN000420725
Charlotte, Mecklenburg County, NC
September 2023
Stuart F. Parker Qu Qi
Hydrogeologist Federal Remediation Branch
Head

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 INTRODUCTION ...............................................................................................................1

2.0 SITE LOCATION AND DESCRIPTION, OPERATIONAL AND REGULATORY
HISTORY ........................................................................................................................................1
2.1 Site Location and Description ..................................................................................1
2.2 Site Operational and Regulatory History .................................................................1
2.3 Previous Investigations ...........................................................................................3
2.3.1 Investigations at Neighboring Properties .....................................................3
2.3.2 IHSB Passive Soil Gas and Surface Water Investigation ............................4

3.0 SOURCES AND WASTE CHARACTERISTICS .............................................................5

4.0 GROUNDWATER MIGRATION PATHWAY .................................................................5
4.1 Hydrogeologic Setting .............................................................................................5
4.2 Groundwater Pathway Targets .................................................................................5
4.3 Groundwater Pathway Sampling and Results ..........................................................6
4.4 Groundwater Conclusions ........................................................................................6

5.0 SURFACE WATER MIGRATION PATHWAY ...............................................................6
5.1 Hydrologic Setting ...................................................................................................6
5.2 Surface Water Pathway Targets ...............................................................................6
5.3 Surface Water Pathway Sampling and Results ........................................................7
5.4 Surface Water Conclusions ......................................................................................7

6.0 SOIL EXPOSURE AND SUBSURFACE INTRUSION, AND AIR
MIGRATION PATHWAYS ...............................................................................................7
6.1 Land Use ..................................................................................................................7
6.2 Subsurface Intrusion Pathway Sampling and Results ..............................................7
6.3 Soil Exposure, Subsurface Intrusion, and Air Targets .............................................8
6.4 Soil Exposure and Subsurface Intrusion, and Air Conclusions ...............................9

7.0 SUMMARY AND CONCLUSIONS ..................................................................................9

LIST OF FIGURES

Figure 1: Site Location Plan

Figure 2: Site Plan

Figure 3: IHSB 2021 Passive Soil Gas Sample Results

Figure 4: EPA 2022 Indoor Air Sample Locations

EXECUTIVE SUMMARY

The Southern Resources Metals Recycling site is a former metals recycling facility that
operated from the 1970s until 2019. The site is currently a truck parking and storage lot. Site
operations in the 1980s and 1990s included vapor degreasing, metal parts washing and melting/
reclamation. Hazardous waste generated in the 1980s and early 1990s included petroleum-based
solvents and chlorinated volatile organic compounds (cVOCs), including trichloroethene (TCE)
and tetrachloroethene (PCE). The site had a history of regulatory compliance violations during
that period.

Phase I and Phase II environmental site assessments completed in 2019 and 2020 included
soil and groundwater sampling. The Phase II assessment documented soil and groundwater
contamination by cVOCs at the site, including PCE, TCE, dichloroethenes (DCE) and vinyl
chloride. Soil contamination was most evident beneath a former drum storage area in the east-
central portion of the property. Groundwater contaminant levels were highest at the northwestern-
most (predicted downgradient) monitoring well, located near the intersection of Raleigh Street and
East Craighead Road.

The site was entered into the NC DEQ Brownfields program in 2021. Contractors for the
prospective developer conducted a soil gas investigation along the northern and western margins
of the property, within footprints for proposed building construction. The majority of the (sixteen)
soil gas samples contained high concentrations of PCE and TCE, plus lower concentrations of
DCEs, vinyl chloride and petroleum hydrocarbons.

The site is surrounded by existing or former commercial/industrial facilities, three of which
also have planned or completed redevelopment for residential use under Brownfields agreements
with NC DEQ. One completed development to the southwest of the site incorporated a vapor
intrusion mitigation system (VIMS). A second property to the northwest of the site had localized
(but subsequently unconfirmed) TCE in soil gas and has been recommended for a VIMS during
future construction. A third property to the northwest of the site contained only localized low-
level PCE in soil gas, and cVOC groundwater contamination only in its extreme northwestern
portion, the latter being downgradient of proposed redevelopment and close to surface water.

In September 2021, contractors for the NC Superfund Section Inactive Hazardous Sites
Branch (IHSB) conducted a passive soil gas (PSG) investigation in proximity to the site. Passive
soil gas sampling was conducted on properties east, northeast and north of the site, and along the
right-of-ways of Greensboro Street, Raleigh Street and East Craighead Road to the east northeast,
north and northwest of the site property. TCE was detected in soil gas located downgradient from
a structure on a commercial/industrial property southeast of the site, directly east from the site’s
former drum storage area. TCE was also detected in soil gas samples directly downgradient
(northwest) from the site, near the intersection of Raleigh Street and East Craighead Road. The
latter results were consistent with previous groundwater data, and indicated a narrow off-site
plume migration, into an area where no inhabited structures currently exist.

The IHSB contractor conducted surface water sampling along Little Sugar Creek, the
nearest surface drainage further northwest of the site. Sampling revealed low concentrations of
cVOCs in a pattern that indicated discharge from a location upstream from the likely discharge
point for groundwater migration from the site.

In 2022, EPA Region 4 contractors conducted a removal site evaluation, sampling indoor
air at four commercial properties located north and northeast of the site. Indoor air at three of the
locations, northeast of the site, contained PCE, TCE and/or trans-1,2-DCE. The TCE results at one
commercial location exceeded Target Indoor Air Vapor Intrusion Screening Level, but not EPA
removal management levels. The EPA concluded that a removal action was not warranted.

1.0 INTRODUCTION

Under authority of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) and the Superfund Amendments and Reauthorization Act of
1986 (SARA), the North Carolina Superfund Section conducted a Pre-CERCLA Screening
Assessment (PCS) at the Southern Resources Scrap Metal site in Charlotte, Mecklenburg County,
NC. The purpose of this investigation was to collect information concerning conditions at and in
the vicinity of the site sufficient to assess the threat posed to human health and the environment at
off-site properties and to determine the need for additional CERCLA/SARA or other appropriate
action.

The scope of this investigation included reviews of private contractor site investigations
conducted at the site property and documents produced by and for the NC DEQ Brownfields
program. In addition, the PCS scope included review of an extensive 2021 passive soil gas
investigation completed for the NC Superfund Inactive Hazardous Sites Branch (IHSB) on
properties and right-of-ways in proximity to and downgradient of the site. Mecklenburg County
geographic information system (GIS) data were also reviewed to identify potential groundwater
receptors near the site.

2.0 SITE LOCATION AND DESCRIPTION, OPERATIONAL AND REGULATORY
HISTORY

2.1 Site Location and Description:

The site is located at 3826 Raleigh Street, Charlotte, NC 28206. Geographic coordinates
at the approximate property center are 35.25217o N Latitude and 80.79798o West Longitude (Refs.
3, 4, 5, 6; Figs. 1, 2).

The 3.2-acre site property is a former scrap metals recycling facility. Ground surface
elevation ranges from 714 to 726 feet, sloping generally west-northwest from the eastern property
line. The site is bounded by Raleigh Street to the north and far northeast, by Craighead Street to
the west, and by a limestone distribution company to the southeast. An east-west railway runs
south of the site property’s southern tip. The surrounding neighborhood has mostly
commercial/industrial use, with a condominium complex and retail south of the railroad, and a
recently constructed apartment complex to the southwest, across Craighead Street from the site
Surface drainage consists of Little Sugar Creek, which passes approximately 650 feet northwest
of the site property (Refs. 3, 4, 5, 6)(see Figs. 1, 2).

2.2 Site Operational and Regulatory History:

The site property, which originally measured approximately 4.8 acres, was commercially
developed in the late 1940s. On-site structures were constructed in the late 1940s, early-to-mid
1950s, and early 1960s. The site was occupied by construction-related companies from
approximately the late 1950s until the late 1970s (Refs. 3, 5, 6).

From the late 1970s to 2000 the site was operated as a scrap metal facility by Rainbow
Metals, and later by R&P metals. Rainbow Properties LC was formed in 2000 and the site

continued to operate as a scrap metal facility until Southern Resources closed the facility in 2019.
Since January 2021, site ownership has been listed as 3826 Raleigh Street LLC. The property is
presently used as a semi-truck parking lot/storage yard, with only one vacant brick structure and
one semi-enclosed metal structure remaining on the property (Refs. 3, 4, 5, 6, 30).

On site scrap metal operations reportedly included on site stockpiling and sorting at various
outdoor locations, as well as vapor degreasing, metal parts washing and melting/reclamation.
Compliance documents dated 1981 to 2009 indicated that hazardous waste generated in the 1980s
and early 1990s included petroleum-based solvents and chlorinated volatile organic compounds
(cVOCs), the latter including trichloroethene (TCE) and tetrachloroethene (PCE). During the
early-to-mid 1980s, Rainbow Metals reportedly generated two 55-gallon drums of waste TCE per
month from vapor degreasing operations. During the late 1980s and early 1990s, R&P Metals used
cVOCs and petroleum solvents in parts washing and metal melting/reclamation.
Several regulatory compliance violations reportedly occurred during these time periods (Refs. 5,
6).

On site environmental investigation commenced in 2019, when Southern Resources (then
the property owner) contracted Phase I and Phase II environmental site assessments (ESA)
preparatory to intended sale of the property and subsequent interest in redevelopment under the
NC Brownfields Program. The Phase II ESA consisted of soil and groundwater sampling using
push-core technology. Ten soil samples at eight locations were collected for VOC, semi-VOC
(SVOC) and metals analyses, based on field photo-ionization detector (PID) readings.
Groundwater samples were collected from three 20- to 25-foot deep temporary monitoring wells
installed on the property (Ref. 6).

Phase II ESA soil sample analysis detected elevated VOCs, SVOCs, arsenic and chromium.
VOCs and SVOCs (including TCE at 9.8 milligrams per kilogram [mg/kg]) were present mainly
in a single soil boring located in the east-central portion of the property, in an area between
structures that had formerly been used for chemical drum storage (Ref. 6).

Groundwater sample analysis detected cVOCs, including PCE, TCE, cis-1,2-
dichloroethene (DCE) and vinyl chloride. The highest TCE concentration (19,400 micrograms per
liter [µg/L]) was detected in the northwestermost (predicted downgradient) monitoring well, near
the intersection of Raleigh Street and East Craighead Road. In addition, cVOCs including TCE at
422 µg/L and cis-1,2-DCE at 1470 µg/L were detected in groundwater at a (predicted upgradient)
monitoring well near the southeast property line and other on-property structures. Using a NC risk-
assessment calculator, contractors determined that groundwater contamination posed excess risk
to non-residents/workers at the site via the groundwater to indoor air (subsurface intrusion)
exposure pathway (Ref. 6).

In early 2020, Sugar Creek Ventures LLC submitted a Brownfields Property Application
(BPA) for the site for entry into the NCDEQ Brownfields Program for high-density residential
redevelopment. After a Letter of Eligibility (LOE) was issued in March 2020, Sugar Creek
Ventures affiliate 3826 Raleigh Street LLC purchased the property in January 2021 and submitted
a revised BPA to reflect that they were the prospective developer. The revised LOE was issued
the following month (Ref. 7). The most recent activity was an on-site Brownfields Inspection
completed in March 2022 (Ref. 30).

In late March and early April of 2021, contractors for 3826 Raleigh Street LLC performed
a soil gas survey on the site. The contractor installed seventeen soil gas sampling points within
approximately 70 feet of the site’s north and west property lines, inside the planned residential
building footprints for site redevelopment. Sample probes were installed to approximately 5 feet
depth using push-core technology, during which soil samples were also collected and submitted
for laboratory analysis based on field PID screening. Additional groundwater depth/elevation data
were also gathered to assist in the probe placement. Laboratory samples were obtained from
sixteen of the probe locations using leak-tested laboratory Summa Canister technology (Ref. 7).

The majority of soil gas samples collected within the proposed building footprints
contained PCE and TCE, ranging in concentration up to 52,000 µg/m3 and 2,000,000 µg/m3,
respectively. Less frequent and lower-level detections also included cis-1,2-DCE, 1,1-DCE, vinyl
chloride, and other VOCs. Using the NC risk assessment calculator, and EPA Regional Screening
Level (RSL) default exposure factors and target risks, the contractor determined that the soil gas
levels posed excess risk to future residents in proposed site structures via the soil vapor to indoor
air (subsurface intrusion) exposure pathway. The risk, however, could be mitigated through design
and pre-construction installation of a vapor intrusion mitigation system (VIMS) (Ref. 7).

2.3 Previous Investigations:

2.3.1 Investigations at Neighboring Properties:
The site is surrounded by present-day or historical commercial/industrial properties, several of
which are being redeveloped under Brownfields agreements with the State of NC (Ref. 8):

1. Former Abernathy Lumber, 308 East Craighead Road (southwest of site): Brownfields
project redeveloped into two four-story apartment buildings in 2019. In 2007, TCE
concentrations in groundwater and soil gas ranged up to 2,200 µg/L and 392 µg/m3,
respectively. Construction incorporated a VIMS, with no sub slab detections, pre-
occupancy (Refs. 9, 10) (see Figure 2).

2. Former East Craighead Storage, 220 East Craighead Road (northwest of site): Brownfields
project with proposed apartment/townhome construction. TCE in soil gas ranged up to
7000 µg/m3 during initial sampling event in June 2016. High TCE levels (exceeding
residential screening levels) were limited to two southeastern (out of 11, total) sample
points, and not reproduced during resampling in January 2019. A VIMS has been
recommended for future residential construction (Refs. 11, 12) (see Figure 2).

3. Concrete Supply Company, 3823 Raleigh Street (north of site): Not a Brownfields site.
File review indicates petroleum incidents and an underground storage tank (UST) closure
in the late 1990s. Soils were analyzed for total petroleum hydrocarbons (EPA Method
5030/3550 TP), but no cVOC soil analyses were performed. During a January 2022
removal site evaluation (RSE), an EPA Region 4 contractor conducted indoor air sampling
at four locations, three within the concrete plant and one in a separate company classroom
northeast of the site (Refs. 13, 28, 29)(see Figures 2, 4).

4. Former Metromont Concrete, 4101 Greensboro Street (northeast of site): Brownfields
project with proposed residential townhomes (southwest portion) and mixed high-density
residential and commercial/retail (east portion) construction. File review indicates
petroleum UST closures in 2019. Monitoring well data indicate a northwestward
groundwater migration direction (Ref. 14) (see Figure 2). Petroleum constituents remain
present in groundwater underlying the Metromont site.

TCE, cis-1,2-DCE and vinyl chloride were detected only in groundwater beneath the
extreme northwest corner of property, downgradient from proposed development.
Localized PCE (2.6 µg/L) was detected in groundwater at a former UST located in the east-
central portion of the site. Soil gas sampling beneath the southwest corner of the property
(nearest to Southern Resources) resulted only in a single, low-level PCE detection at 2.2 J
µg/m3 that did not exceed its EPA commercial Target Sub-slab/Near-Source VISL of 584
µg/m3. The Brownfields contractor used the NC risk assessment calculator to determine
that (cVOC) soil gas and groundwater contamination did not pose excess risk to proposed
residential site structures via the indoor air (subsurface intrusion) exposure pathway (Ref.
14).

5. Patterson Heating and Air Conditioning, 3922 Greensboro Street (northeast of site) (Ref.
4). During a January 2022 removal site evaluation (RSE), an EPA Region 4 contractor
conducted indoor air sampling at three locations within the company structure (Refs. 28,
29)(see Figures 2, 4).

6. Consolidated Press, 3900 Greensboro Street (northeast of site) (Ref. 4). During a January
2022 removal site evaluation (RSE), a EPA Region 4 contractor conducted indoor air
sampling at three locations within the company structure (Refs. 28, 29)(see Figures 2, 4).

7. Former Tarmac Virginia, Inc./Hal Abernathy Contracting, 3934 Raleigh Street (east-
southeast of site). The property is a former limestone distribution facility. A diesel fuel
UST on this property was reportedly removed prior to a groundwater investigation
conducted in 1990. Monitoring well data (three wells) indicated a northwestward
groundwater migration direction. Groundwater beneath the property was contaminated
with petroleum hydrocarbons consistent with diesel fuel. A groundwater sample collected
from the northernmost (downgradient) monitoring well contained TCE at 32 µg/L. The
well was located in a wooded area near the northern property line about 100 feet east from
the drum storage area at the adjacent Southern Resources site (Ref. 15) (see Figure 2).

2.3.2 IHSB Passive Soil Gas and Surface Water Investigation

In September 2021, contractors for the NC Superfund Section IHSB conducted a passive
soil gas (PSG) and surface water investigation in the neighborhood adjacent to and downgradient
of the site. Thirty PSG samples were collected on properties north, northeast, east, and southeast
of the site; and along the right-of-ways of Greensboro Street, Raleigh Street, and East Craighead
Road to the northwest, north, northeast, and east of the site. In addition, surface water samples
were collected at three locations along Sugar Creek, the nearest surface water body located north

of the site (See Sections 5.3 and 6.2 of this report for additional information about surface water
and PSG sampling results) (Ref. 16)(see Figure 3).

3.0 SOURCES AND WASTE CHARACTERISTICS

Based on existing file information, possible sources evaluated for the site include drums of
waste TCE and other cVOCs and an unknown quantity of contaminated soil located in various
areas on the property including but not limited to the drum storage area, former equipment
maintenance pit, and forklift maintenance area, and other unidentified areas not previously
sampled (Refs. 5; 6; 7). Site operations included metal stockpiling and sorting, vapor degreasing,
and metal parts washing, melting, and reclamation (Refs. 5, 6). Petroleum solvents and cVOCs
were used at the site. Soil sampling during previous investigations contained cVOCs, petroleum-
related compounds, and metals (Refs. 5, 6, 7). No waste/source sampling was conducted as part of
this PCS.

4.0 GROUNDWATER MIGRATION PATHWAY

4.1 Hydrogeologic Setting:

Charlotte, NC lies within the Charlotte lithotectonic belt, which consists primarily of
igneous and metamorphosed igneous bedrock. Bedrock beneath the site is mapped as
metamorphosed quartz diorite and tonalite (Refs. 17, 18).

Except for the site’s far northwest corner, soil at the site is mapped as Urban Land, where
the natural soil profile has been disturbed by cutting/filling/grading. The remainder of the land
area is mapped as Cecil-Urban Land complex, consisting mainly of yellow-red sandy clay loam,
much of which has also been artificially disturbed. On-site subsurface explorations encountered
predominantly clay and some fill in the upper several feet, underlain by silt with varying amounts
of clay and sand (Ref. 19)

Site hydrogeology is reported to be typical of the piedmont.: The aquifer consists of the
saturated porous zone of the saprolite, hydraulically connected to water bearing fractures in the
underlying partially weathered and unweathered bedrock. Groundwater migration in bedrock is
controlled by spacing and orientation of fractures. In the overlying saprolite, groundwater
elevation and flow direction generally reflect surface topography and overland drainage (Ref. 18).

During the 2019 Phase II ESA, static groundwater depths in the three on-site temporary
monitoring wells ranged from approximately 14 to 18 feet below ground surface (Ref. 6).
Potentiometric maps from groundwater investigations at adjacent properties indicate that the local
potentiometric surface slopes toward the northwest, in the direction of Little Sugar Creek (Refs.
14, 15).

4.2 Groundwater Pathway Targets:

The City of Charlotte supplies drinking water to residences and businesses within the city
limits. The city’s drinking water source consists of surface water intakes along the Catawba River.

The nearest drinking water supply well is located at a church about 2.75 miles north from the site
(Ref. 20).

4.3 Groundwater Pathway Sampling and Results:

No groundwater sampling was conducted as part of the current PCS. Groundwater
samples collected during the 2019 Phase II ESA contained cis-1,2-DCE up to 1,470 µg/L; trans-
1,2-DCE up to 17,7 µg/L; PCE at 3.2J µg/L; TCE up 19,400 µg/L; and vinyl chloride at 4.5 µg/L.
TCE was detected in all groundwater samples above its EPA Maximum Contaminant Level (MCL)
of 5 µg/L; cis-1,2-DCE was detected above its MCL of 70 µg/L in two of the three groundwater
samples; and the single detection of vinyl chloride was above its MCL of 2 µg/L (Refs. 2, 6).

4.4 Groundwater Pathway Conclusions:

Municipal drinking water within the 4-mile radius is supplied City of Charlotte surface
water intakes. Groundwater contamination at the site is being addressed under a NC Brownfields
agreement. Subsurface intrusion via off-site migration of contaminated groundwater is being
addressed as nearby properties are redeveloped under property-specific NC Brownfields
agreements (Refs. 2, 6, 8, 11, 12, 14, 16)..

5.0 SURFACE WATER MIGRATION PATHWAY

5.1 Hydrologic Setting:

Ground surface elevation at the site ranges from 714 to 726 feet, sloping generally west-
northwest from the eastern property line. Surface water runoff drains towards Little Sugar Creek,
located about 650 feet northwest of the site. The probable point of entry (PPE) for surface water
runoff/storm drainage from the site is likely to be near where East Craighead Road crosses Little
Sugar Creek. From the PPE, Little Sugar Creek flows south-southwest for the entire 15-mile
surface water migration pathway target distance limit (TDL) (Refs. 5, 6, 21).
Mean annual stream flow in cubic feet/second (cfs) can be calculated by multiplying local
stream drainage area (in square miles [mi2]) by local mean annual runoff (14 inches) and dividing
by a conversion factor (13.58). Based on published drainage areas for locations downstream from
the site: Little Sugar Creek at Charlotte has a mean annual flow of approximately 60 to 72 cfs, and
is therefore classified as a small-to-moderate stream (Refs. 1, 22, 23).

5.2 Surface Water Pathway Targets:

No public surface water intakes are located within 15 miles downstream from the PPE. The
City of Charlotte drinking water intakes are located upstream of the PPE (Ref. 20). The nearest
identified fishery for human consumption is a 6-acre pond located parallel to Little Sugar Creek at
Freedom Regional Park, approximately 6.3 miles downstream from the site; the pond is elevated
above the creek, and the creek itself is not identified as a fishery (Refs. 24, 25). The nearest mapped
wetland is a 0.33-mile urban interval located approximately 0.05 mile downstream from the PPE.
A second 0.33-mile interval is located approximately 6.3 miles below the PPE. No additional

wetland frontage is mapped within the 15-mile TDL (Ref. 21). No threatened or endangered
species occurrences are identified specific to the proximal surface water pathway (Ref. 26).

5.3 Surface Water Pathway Sampling and Results:

No surface water sampling was conducted as part of the current PCS. In September 2021,
the IHSB collected surface samples at three locations along Little Sugar Creek. The farthest
downstream samples (SW-1 and duplicate sample SW-2) were collected from the overpass of East
Craighead Road. Mid-sampling (SW-3) was conducted approximately 600 feet upstream
(northwest) near the northern corner of Concrete Supply Company. The farthest upstream sample
(SW-4) was collected approximately 350 feet farther upstream, adjacent to the former Metromont
Concrete Company off Greensboro Street (Ref. 16).

The downstream and mid-stream surface water samples (SW-1, SW-2, SW-3) all contained
similar, low-level concentrations of PCE (up to 0.684 µg/L), TCE (up to 1.5 µg/L) and cis-1,2-
DCE (up to 1.2 µg/L). The upstream background sample (SW-04) was non-detect for cVOCs.
The location of farthest upstream cVOC detection (SW-3) indicated that the cVOC entry point was
located northeast of the site and Concrete Supply Company, alongside the former Metromont
Concrete property, which is consistent with the pattern of cVOC groundwater contamination at the
Metromont property (Ref.16)(see Figure 3)(also see Section 2.3.1 for additional information about
surface water sampling).

5.4 Surface Water Conclusions:

Based on a review of the previous investigations and findings, the site poses a minimal
exposure hazard via the surface water migration pathway.

6.0 SOIL EXPOSURE AND SUBSURFACE INTRUSION, AND AIR MIGRATION
PATHWAYS

6.1 Land Use:

The neighborhood surrounding the site has mostly commercial/industrial use, with a
condominium complex and retail south of the railroad, and a recently constructed apartment
complex southwest of the site, across East Craighead Road. No residents, schools or day care
facilities are located on or in immediate in proximity to the site (Refs. 4, 9, 10, 11, 12). Therefore,
the soil exposure and air migration are not of concern at this time.

6.2 Subsurface Intrusion Pathway Sampling and Results:

In September 2021, NC IHSB contractors conducted a passive soil gas (PSG) investigation
on properties and right-of-ways in proximity to the site property. PSG samplers were emplaced on
September 2 and 3, 2021 and retrieved on September 16 and 17, 2021 (Ref. 16). Results are
summarized as follows:

• Former Tarmac Virginia, Inc./Hal Abernathy Contracting (East, Southeast of site): PSG
samples (PSG-1, PSG-2, PSG-3, PSG-5) contained petroleum constituents. One sample
(PSG-3), located downgradient (north) from the on-site structure, contained TCE (21.3
µg/m3). Results were consistent with previously reported groundwater sampling results,
which indicated lateral migration of groundwater contaminants from the former drum
storage area at Southern Resources Scrap Metal. Another sample farther north (PSG-7)
contained trans-1,2-DCE (1.35 µg/m3) The TCE and DCE results did not exceed
commercial Target Sub-slab/Near Source Vapor Intrusion Screening Levels (29.2 µg/m3;
584 µg/m3) (Refs. 15, 16, 27)(see Figure 3).

• Patterson Heating and Air Conditioning, and Consolidated Press (Northeast of site): PSG
Samples (PSG-10, PSG-12, PSG-14 through PSG-18) contained petroleum compounds but
no cVOCs were detected (Ref. 16)(see Figure 3).

• Metromont/Concrete Supply Company property line (North-northeast of site): One PSG
sample (PSG-21) contained trans-1,2-DCE (1.48 µg/m3) (Ref. 16)(see Figure 3).

• Raleigh Street and East Craighead Road (Northwest of site): Four PSG samples (PSG-25
through PSG-28) contained TCE (ranging from 1.59 µg/m3 to 17,600 µg/m3). The highest
concentrations (PSG-26, PSG-27), exceeding Sub-Slab/Near-Source VISL, occurred near
the intersection, indicating northwestward migration of a narrow groundwater plume,
consistent with previously reported groundwater data from the Southern Resources Scrap
Metal site. Samples farther northwest along East Craighead Road, closer to the Concrete
Supply structures, were non-detect for cVOCs (Refs. 6, 16)(see Figure 3).

During the January 2022 RSE, the EPA contractor collected 11 indoor air samples at
commercial properties located north-northwest and northeast of the site including Concrete Supply
Company, Consolidated Press, and Patterson Heating and Air Conditioning. Chlorinated VOCs
were detected in indoor air at Consolidated Press, at Patterson Heating and Air Conditioning, and
in a classroom operated by Concrete Supply Company. The three structures are located in
proximity to one another, about 350 to 600 feet northeast of the site. The highest concentrations
of cVOCs detected included: PCE, 11.0 µg/m3 and TCE, 1.53 µg/m3 at Consolidated Press; and
trans-1,2-DCE, 0.543 µg/m3 at Patterson Heating and Air Conditioning. These concentrations did
not exceed the EPA Removal Management Levels. Therefore, the EPA concluded that a removal
action was not warranted, and a no further action decision was recommended. In February 2022,
the EPA notified NCDEQ of its recommendation (Refs. 2, 28, 29)(see Figure 4).

The indoor air TCE detections at Consolidated Press exceeded the commercial Target
Indoor Air VISL of 0.876 µg/m3 (Refs. 27, 28). However, no cVOCs had previously been detected
in soil gas outside the three structures during the 2021 PSG investigation (Ref. 16).

6.3 Soil Exposure, Subsurface Intrusion, and Air Targets:

The site is presently used as a semi-truck parking lot/storage yard. The facility’s main
structure is in disrepair and is posted as unsafe, and no other fully enclosed structures
remain on site; there are no on-site residents or workers. Approximately five commercial
facilities and one large apartment/condominium complex are in the immediate vicinity of

the site. The nearest residential units are located within 100 feet southwest of the site, in a
multi-story structure constructed with a VIMS. No schools or daycare centers are located in
the immediate vicinity of the site (Refs. 4, 9, 10, 30)(see Figure 2).

During the 2022 RSE, cVOCs were detected in indoor air at Consolidated Press, at
Patterson Heating, and in a classroom of Concrete Supply (Refs. 28, 29). Consolidated Press
reportedly employs 8 workers and Patterson Heat and Air Conditioning reportedly employs
25 workers (Ref. 31). The nearby Concrete Supply Company classroom is anticipated to be
inhabited only intermittently, by various employees.

No wetlands are identified in proximity to the site (Ref. 21). Due to the site’s heavily
urbanized setting, no terrestrial sensitive environments are anticipated to exist in the
immediate vicinity of the site.

6.4 Soil Exposure and Subsurface Intrusion and Air Conclusion:

Based on a review of the previous investigations, the soil exposure and air pathways are of
minimal concern at this site. The subsurface intrusion pathway is of some concern at this site.

7.0 SUMMARY AND CONCLUSIONS

Historical investigations reveal that groundwater and soil gas beneath the Southern
Resources Scrap Metal site contain high concentrations of cVOCs including TCE and PCE. The
site is a NC Brownfields site and planned site redevelopment will necessitate pre-construction
installation of VIMS under Brownfields LURs. Similar measures have been taken, or are
anticipated, at Brownfields redevelopments west and northwest of the site.

Groundwater and soil gas data indicate that site groundwater contaminants have migrated
off site to the northwest, near the intersection of Raleigh Street and East Craighead Road. However,
no inhabited off-site commercial or residential structures exist in proximity to this location, and
soil gas and indoor air sampling results at greater distance from the site indicate that contaminant
migration to the north and northwest of the site is limited in extent.

Indoor air sampling has detected cVOCs in commercial facilities northeast of the site. TCE
indoor air results inside one of the commercial facilities exceeded the commercial Target Indoor
Air VISL. However, previous PSG sampling results from those commercial properties were non-
detect for cVOCs, consistent with groundwater migration direction being northwest from the site.
Therefore, the indoor air cVOC contamination may be from an alternative source.

Surface water sampling in downgradient Little Sugar Creek detected low-level cVOCs,
however, the pattern of cVOC elevation in the creek indicates the presence of upstream source(s).

Current on- and off-site conditions and planned development, the potential for human
exposure to site contaminants is limited. Based on the PCS findings, this site is not
recommended for addition to the Superfund Emergency Management System (SEMS) under
CERCLA.

Southern Resources Scrap Metal
NCN000420725
Pre-CERCLA Screening Assessment References
September 2023

1) United States Environmental Protection Agency (EPA) 40 Code of Federal Regulations – Part
300, Hazard Ranking System, July 1, 2019, available on-line at:
https://semspub.epa.gov/work/HQ/100002489.pdf.

2) U.S. Environmental Protection Agency (EPA). Regional Removal Management Level
Summary Table, May 2023. Accessed on-line at:
https://semspub.epa.gov/work/HQ/404101.pdf.

3) Mecklenburg County, NC Geographic Information Service (GIS), Reviewed December 13,
2022 and March 22, 2023.
https://polaris3g.mecklenburgcountync.gov

4) Google Maps, Charlotte, NC: Latitude and Longitude Determination; Aerial Map and Imagery:
https://www.google.com/maps

5) Hart and Hickman, PC, Charlotte, NC: “Phase I ESA, 3826 Raleigh Street, Charlotte, NC”,
H&H Job No SNR-001. June 11, 2019.

6) Geosyntec Consultants of NC, PC, Charlotte, NC: “Phase II Environmental Assessment
Report, Subject Site: Southern Resources, 3826 Raleigh Street, Charlotte, NC”, Project No
GC7090. September 2020.

7) Geosyntec Consultants of NC, PC, Charlotte, NC: “Brownfields Soil and Soil Gas Site
Assessment Report, Site: Southern Resources Scrap Metal, 3826 Raleigh Street, Charlotte,
Mecklenburg County, NC, Parcel ID 09107201 and 09107201E”, NCBP Project #240124-2--
060 GC7090. May 2021.

8) NC DEQ, DWM, Brownfields Project Map Inventory Viewer:
https://www.deq.nc.gov/about/divisions/waste-management/science-data-and-reports/gis-
maps/brownfields-projects-map-inventory-and-document-download

9) Hart and Hickman, PC, Charlotte, NC: Letter to NC Brownfields Program Re: Filed Notice of
Brownfields Property, Craighead Road (Abernathy Lumber) Brownfields Property, Charlotte,
North Carolina, Brownfields Project No. 18015-14-060. June 3, 2015.

10) NC DEQ Brownfields Program Property Management Unit: Letter to Philemon NoDa Partners,
LLC, Re: Vapor Mitigation Compliance Review, 308 E Craighead Rd and 3712 Philemon Ave,
Charlotte, Mecklenburg County, Brownfields Project No. 18015-14-060. May 1, 2020.

11) Hart and Hickman, PC, Charlotte, NC: “Brownfields Assessment Report, East Craighead
Storage, East Craighead Road and Philemon Avenue, Charlotte, North Carolina”, H&H Job
No. AMK-009. May 4, 2019.

12) Hart and Hickman, PC, Charlotte, NC: “Environmental Management Plan Revision 1, East
Craighead Storage, Craighead Road and Philemon Avenue, Charlotte, North Carolina”, H&H
Job No. AMK-009. August 15, 2019.

13) INENCO, Inc., Mooresville, NC: UST Closure Report, GW/UST-12, Concrete Supply
Company, 3823 Raleigh Street, Charlotte, Mecklenburg County, NC. August 1997

14) Hart and Hickman, PC, Charlotte, NC: “Brownfields Assessment Report, Metromont Concrete
Facility, 4101 Greensboro Street, Charlotte, North Carolina”, Brownfields Project No. 22040-
18-060, H&H Job No. MTC-001. March 22, 2019.

15) ERC/EDGe, Charlotte, NC: “Report of Site Contamination Assessment, 3934 Raleigh Street,
Charlotte, North Carolina”. April 27, 1990.

16) ATC Associates, Raleigh, NC: “Passive Soil Gas and Surface Water Investigation, Southern
Resources Scrap Metal, 3826 Raleigh Street & East Craighead Road, Charlotte, NC, IHSB No.
NONCD0003152”, State Contract No. N091319. October 25, 2021.

17) Goldsmith, R., Milton, Horton, D., Wright, J. W. Jr.: Geologic Map of the Charlotte 1o x 2o
Quadrangle, North Carolina and South Carolina, 1988.

18) Heath, Ralph, Basic Elements of Groundwater Hydrology with Reference to Conditions in
North Carolina, Parts I-II, US Geological Survey Water Resources Investigations Open-File
Report 80-44, 1980.

19) Web Soil Survey: https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx

20) NC DEQ Superfund Section Inactive Hazardous Sites Branch: ARC GIS IHSB Map Viewer:
https://ncdenr.maps.arcgis.com/apps/webappviewer/index.html?id=1ff22e6cebe44424b64df2
fa4c5fc759

21) US Fish and Wildlife Service, National Wetland Inventory, Wetland Mapper
https://www.fws.gov/wetlands/data/mapper.html

22) Meikle, Robert L., US Department of the Interior Geological Survey: “Drainage Areas of
Selected Sites on Streams in North Carolina”. Open File Report 83-211. 1983.

23) US Geological Survey: “Map of Mean Annual Runoff for the Northeastern, Southeastern and
Mid-Atlantic United States, Water Years 1951-80”, Water Resources Investigations Report
88-1094. 1988.

24) Fishidy Interactive Map https://www.fishidy.com/fishing-maps

25) North Carolina Wildlife Resources Commission Fishing Areas GIS Mapping Tool:
https://www.ncpaws.org/wrcmapbook/FishingAreas.aspx

26) NC DEQ, Natural Heritage Program Data Explorer: Map | North Carolina Natural Heritage
Data Explorer (natureserve.org)

27) US EPA Vapor Intrusion Screening (VISL) Level Calculator Output. August 11, 2023.
https://epa-visl.ornl.gov/cgi-bin/visl_search.

28) Tetratech, Duluth, Georgia: “Removal Evaluation Report – FINAL, Southern Resources Scrap
Metal, Charlotte, Mecklenburg County, North Carolina, Contract Number: 68HE0519D0006,
TOLIN: 0097-023. March 10, 2022.

29) Webster, James W., USEPA Region 4 Emergency Response, Removal, Prevention and
Preparedness Branch: Letter to James Bateson, NCDEQ Division or Waste Management, Re:
Southern Resources Scrap Metal Site, Charlotte, Mecklenburg County, North Carolina, with
attached Pollution Investigation Report (POLREP). February 23, 2022.

30) Slaughter, Kevin, NCDEQ Division or Waste Management: DWM Brownfields Inspection
Report, Southern Resources Scrap Metal Site, Charlotte, Mecklenburg County, North
Carolina. March 11, 2022.

31) Buzzfile on-line business profiles: Patterson Heating and Air Conditioning Co. and
Consolidated Printing Co.
https://www.buzzfile.com/business/Patterson-Heating-and-AC-704-375-5591;
https://www.buzzfile.com/business/Consolidated-Press-Charlotte-704-372-6785

FIGURES

Southern Resources Scrap Metal
NONCD0003152
Charlotte, Mecklenburg County, NCMecklenburg County
SITE
Fig. 1:
Site Location Map
Stuart F Parker, NC DEQ
8/11/2023
Mecklenburg County
Fig. 2:
Site Plan
Stuart F Parker, NC DEQ
8/11/2023
Southern Resources Scrap Metal
NONCD0003152
Charlotte, Mecklenburg County, NC
Former
Abernathy
Lumber
Former
East Craighead
Storage
Concrete Supply
Company
Former Metromont Concrete
Former Tarmac
Virginia/
H Abernathy
Site
Structure
Former Drum
Storage Area
50SCALE: 1" = 200'2000100 150200NPSG-30PSG-29PSG-28PSG-27PSG-26PSG-24PSG-25PSG-23PSG-22PSG-21PSG-20PSG-19PSG-17PSG-18PSG-13PSG-12PSG-11PSG-16PSG-15PSG-8PSG-7PSG-6PSG-3PSG-4PSG-5PSG-1PSG-2PSG-9PSG-10PSG-14SW-1/SW-2SW-3SW-4LEGEND:NOTE: ALL LOCATIONS ARE APPROXIMATEMECKLENBURG COUNTYPARCEL LINESW-1PASSIVE SOIL GAS SAMPLE:NOT DETECTEDSample IdentificationSURFACE WATER SAMPLESample IdentificationPSG-11RALEIGH STREETGREENSBORO STREETEAST SUGAR CREEK ROADNORTH TRYON STREETPHILEMON AVNUEEAST CRAIGHEAD ROADLITTLE SUGAR CREEKRALEIGH STREETLITTLE SUGAR CREEKCONCRETESUPPLY CO.METROMONTPATTERSON HEATINGAND AIR CONDITIONINGCONCRETESUPPLY CO.CONSOLIDATED PRESSHAL CONTRACTINGPASSIVE SOIL GAS SAMPLE:ANALYTE DETECTEDSample IdentificationPSG-19SITE PROPERTY LINESOUTHERNRESOURCESSCRAP METALCONCRETESUPPLY CO.Figure:Drawing File:
Project Number:
Ckd. By:
Drn. By:
App'd By:
Ckd. Date:Scale:Date:H:\2021\OTHER OFFICES\NORTH CAROLINA\NCDEQ-IHSB\SOUTHERN RESOURCES\IHSB037P01-PSG.DWG, FIG2
PASSIVE SOIL-GAS ANALYTICAL RESULTS10/21/2021SEE LOWER LEFTSOUTHERN RESOURCES SCRAP METAL
3826 RALEIGH STREET & EAST CRAIGHEAD ROAD
CHARLOTTE, MECKLENBURG COUNTY, NORTH CAROLINA
IHSB037P01AS SHOWNDH
LG
NOTES:
1. Features shown are not an authoritative location, nor are they presented
to a stated accuracy.
2. ND = Not Detected
3. µg/m3 = micrograms per cubic meter
COORDINATE SYSTEM:
NAD 1983 NORTH CAROLINA STATE PLANE FIPS 3200, US SURVEY FEETFigure 3
File: C:\START_V\97-023_Southern_Resources_Scrap_Metal\mxd\sample_locations.mxd
Map Source:
ESRI Aerial Imagery 2018-2019.")j")j")j")j ")j ")j")j")j
")j
")a")jSRSM-CS-04
SRSM-CS-03
SRSM-CS-01
SRSM-CP-03
SRSM-CP-02
SRSM-CP-01
SRSM-HVAC-01
SRSM-HVAC-02
SRSM-HVAC-03
SRSM-AMBIENT-01
SRSM-CS-02 (-DUP)
Raleigh St
E
C
r
a
i
g
h
e
a
d

R
d
Greensboro St
Philemon Ave
Legend
")j Indoor Air Sample
")a Ambient Air Sample
Former Southern
Resources Scrap Metal(Site Location)
Adjacent Facilities
/
0 100 200
Feet
0097-023
Southern Resources
Scrap Metal
FIGURE 4
Sample Locations
TOLIN No.:
Site Name:
North CarolinaMecklenburgCharlotte
State:County:City:
United StatesEnvironmental Protection AgencyRegion 4
2/9/2022
Date:
dale.vonbusch
Analyst:
ConcreteSupply
ConsolidatedPress
Patterson Heating andAir Conditioning
ConcreteSupply
Former SouthernResourcesScrap Metal

ATTACHMENT 1:
Pre-CERCLA Screening Assessment
Checklist/Decision Form

OLEM 9355.1-119 February 2018
Pre-CERCLA Screening Checklist/DecisionForm
This form is used in conjunction with a site map and any additional information required by the EPA Region to
document completion of a Pre-CERCLA Screening (PCS). The form includes a decision on whether a site should
be added to the Superfund program’s active site inventory for further investigation. This checklist replaces
Attachment A in the December 2016 PCS Guidance document. A current version of the PCS checklist and
additional information is available at: https://www.epa.gov/superfund/pre-cercla-screening.
Region: State/Territory: Tribe:
EPA ID No. (If Available)
Site Name:
Other Site
Name(s):
Site Location:
(Street)
Congressional
District
(City) (State/Terr.) (County) (Zip+4) (No Zip
Available)
If no street address is available:
Checklist Preparer: (Township-Range) (Section)
(Name / Title) (Date)
(Organization) (Phone)
(Street) e-Mail -
(City) (State/Terr.) (County) (Zip+4)
Site Contact Info/Mailing Address:
CERCLA 105d Petition for Preliminary Assessment? If Yes, Petition Date (mm/dd/yyyy):
If Yes, RCRA Info Handler ID #: RCRA Subtitle C Site Status: Is site in RCRA Info?
Ownership Type: Additional RCRA Info ID #(s):
Site Type: State ID #(s):
Other ID #(s): Site Sub-Type:
Federal Facility? Federal Facility Owner:
Formerly Used Defense Site (FUDS)?
Federal Facility Docket? If Yes, FF Docket Listing Date (mm/dd/yyyy):
Federal Facility Docket Reporting Mechanism:
Native American Interest? If Yes, list Tribe:
Additional Tribe (s):
Additional Tribe (s):
PRE-CERCLA SCREENING CHECKLIST/DECISION FORM 1

Decimal Degree West (e.g., 77.036783)

<

OLEM 9355.1-119 February 2018
Site Description
Use this section to briefly describe site background and conditions if known or (easily) available, such as:
operational history; physical setting and land use; site surface description, soils, geology and hydrogeology;
source and waste characteristics; hazardous substances/contaminants of concern; historical releases,
previous investigations and cleanup activities; previous regulatory actions, including permitting and
enforcement actions; institutional controls; and community interest.
Geospatial Information
Latitude: Longitude:
Decimal Degree North (e.g., 38.859156)
Provide 4 significant digits at a minimum, more if your collection method generates them.
Except for certain territories in the Pacific Ocean, all sites in U.S. states and territories are located within the northern and
western hemispheres and will have a positive latitude sign and negative longitude sign. Coordinate signs displayed above are
based on the State/Territory entry on page A-1. Geospatial data tips from the PCS Guidance document are available here.
PointDescription:Select the option below that best represents the site
point for future reference and to distinguish it from any nearby sites.
See additional information here.
Geocoded (address-matched) Site Address
Site Entrance (approximate center of curb-cut)
Approximate Center of Site
Other Distinguishing Site Feature (briefly describe):
Point Collection Method: Check the method used to collect the coordinates
above and enter the date of collection. See additional information here.
Online Map Interpolation
GPS (handheld, smartphone, other device or technology with
accuracy range 25 meters)
GPS Other (accuracy range is ≥ 25 meters or unspecified)
Address Matching: Urban
Address Matching: Rural
Other Method (briefly describe below):
Collection Date (mm/dd/yyyy):
PRE-CERCLA SCREENING CHECKLIST/DECISION FORM
POINT-SELECTION CONSIDERATIONS
Often the best point is a feature
associated with the environmental
release or that identifies the site visually.
Use the curb cut of the entrance to the
site if there is a clear primary entrance
and it is a good identifier for the
overall location.
The approximate center of the site (a
guess at the centroid) is useful for
large-area sites or where there are no
appropriate distinguishing features.
Use the geocoded address if that is
the only or best option available, but if possible use something more
representative for sites larger than 50
acres.
2
•
•
•
•

OLEM 9355.1-119 February 2018
Complete this checklist to help determine if a site should be added to the Superfund
Active site inventory. See Section 3.6 of the PCS guidance for additional information. YES NO Unknown
1. An initial search for the site in EPA’s Superfund active, archive and non-site
inventories should be performed prior to starting a PCS. Is this a new site that does
not already exist in these site inventories?
2. Is there evidence of an actual release or a potential to release?
3. Are there possible targets that could be impacted by a release of contamination at
the site?
4. Is there documentation indicating that a target has been exposed to a hazardous
substance released from the site?
5. Is the release of a naturally occurring substance in its unaltered form, or is it
altered solely through naturally occurring processes or phenomena, from a location
where it is naturally found?
6. Is the release from products which are part of the structure of, and result in
exposure within, residential buildings or business or community structures?
7. If there has been a release into a public or private drinking water supply, is it due to
deterioration of the system through ordinary use?
8. Are the hazardous substances possibly released at the site, or is the release itself,
excluded from being addressed under CERCLA?
9. Is the site being addressed under RCRA corrective action or by the Nuclear
Regulatory Commission?
10. Is another federal, state, tribe or local government environmental cleanup program
other than site assessment actively involved with the site (e.g., state voluntary
cleanup program)?
11. Is there sufficient documentation or evidence that demonstrates there is no
likelihood of a significant release that could cause adverse environmental or
human health impacts?
12. Are there other site-specific situations or factors that warrant further CERCLA
remedial/integrated assessment or response?
PRE-CERCLA SCREENING CHECKLIST/DECISION FORM 3

OLEM 9355.1-119 February 2018
Preparer’s Recommendation: Add site to the Superfund Active site inventory.
Do not add site to the Superfund Active site inventory.
Please explain recommendation below:
PCS Summary and Decision Rationale
Use this section to summarize PCS findings and support the decision to add or not add the site to the Superfund active site inventory for further investigation. Information does not need to be specific but, where
known, can include key factors such as source and waste characteristics (e.g., drums, contaminated soil);
evidence of release or potential release; threatened targets (e.g., drinking water wells); key sampling results (if
available); CERCLA eligibility; involvement of other cleanup programs; and other supporting factors. Attach
additional pages as necessary.
Checklist Preparer Name Checklist Preparer Organization
EPA Regional Review and Pre-CERCLA Screening Decision
Add site to the Superfund active site inventory for completion of a:
Standard/full preliminary assessment (PA) Abbreviated preliminary assessment (APA)
Combined preliminary assessment/site inspection (PA/SI) Inegrated removal assessment and preliminary assessment Integrated removal assessment and combined PA/SI Other:
Do not add site to the Superfund active site inventory. Site is:
Not a valid site or incident
Being addressed by EPA’s removal program
Being addressed by a state cleanup program
Being addressed by a tribal cleanup program
Being addressed under the Resource Conservation and Recovery Act
Being addressed by the Nuclear Regulatory Commission
Other:
Date
Optional-PrintnameofEPASiteAssessormaking thisdecision:
EPA Regional Approval: (Enter Date and then click this box to Date
initiate digital signature stamp)
PRE-CERCLA SCREENING CHECKLIST/DECISION FORM 4

OLEM 9355.1-119 February 2018
Site Description
(All text as entered on page A-2)
PRE-CERCLA SCREENING CHECKLIST/DECISION FORM 5

OLEM 9355.1-119 February 2018
PCS Summary and Decision Rationale
(All text as entered on page A-4)
PRE-CERCLA SCREENING CHECKLIST/DECISION FORM 6