HomeMy WebLinkAbout21040 Chemstreams Decision Memorandum 20180608DECISION MEMORANDUM
DATE: June 8, 2018
FROM: Bill Schmithorst
TO: Brownfields Agreement File
RE: Chemstreams, Inc.
3501 Gribble Road
Stallings, Union County
BF # 21040-17-090
Based on the following information, it has been determined that the above referenced
Brownfields Property, whose intended use is for no uses other than commercial,
industrial, office, warehouse, and parking, can be made suitable for such uses.
Introduction:
The Brownfields Property is approximately 2.9 acres and contains one 10,000 sq. ft.
warehouse building and two small concrete block storage buildings. All buildings are
constructed on concrete slabs. The Brownfields Property is bordered by commercial and
industrial properties including: to the north by CSX Railroad and Metromont Materials
Corp.; to the east by Sun Charlotte Industrial, LLC (unoccupied commercial property); to
the south by Pike Electric/Duke Energy; and to the west by Sweep a Lot (Curtis F. Foster
and Tonya Foster, property owners).
Redevelopment Plans:
Redevelopment plans for the Brownfields Property include commercial, industrial, office,
warehouse, and parking uses.
Site History:
The Brownfields Property was used primarily for agricultural purposes until
approximately 1983. Historical data refers to a possible asphalt plant at the Brownfields
Property, based on NCDOT 1975 aerial photographs. Industrial activities were conducted
at the Brownfields Property from 1983 until 1998 including ethylene glycol recycling,
brake fluid and windshield fluid manufacturing.
According to the NCDEHNR’s Superfund Section’s May 1995 Preliminary Site
Assessment/Site Inspection, Chemstreams, Inc. was one of five companies that operated
glycol recycling at the Brownfields Property between 1991 and 1995. Companies
operating on the property included Novachem, Distech, Inc., Chemstreams, Summit
Resource Management and National Petroleum Packers. National Petroleum Packers
operated at the Brownfields Property from 1993 until 1998. In May 2000, the facility
was purchased at auction by Boulos Family Properties, LLC; however, operations at the
facility did not resume. Regulated materials remained on the Brownfields Property until
later removal actions.
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The property is currently owned by Boulous Family Holdings, LLC. Recent property
owners have included: Boulous Family Holdings, LLC (2011-2018); Boulous Family
Properties, LLC (2000-2011); and Robert G. Shory, III (1986-2000). The property is
currently leased by the prospective developer, WOD Ventures, LLC, and used to store
parked vehicles.
In 1993, a CERCLA Citizens suit was filed by the property owners against Summit
Resources Management, Inc. Summit Resources Management, Inc. was operating on the
Brownfields Property and the adjacent property at 3481 Gribble Road. The EPA Region
IV Emergency Response and Removal Branch removed hazardous material from the
3481 Gribble Road property including 5,000 drums and 800 5-gallon buckets. In October
1994, the NCDENR Superfund Section conducted soil and groundwater sampling on the
Brownfields Property and analyzed the samples for VOCs, SVOCs and metals. No
exceedances of current non-residential property screening levels were found.
Environmental Conditions Summary
A USEPA enforcement and removal action (NCD986232213) was conducted on the
property adjacent to the Brownfields Property located at 3481 Gribble Road and the
Brownfields Property from September 1993 to May 1994. Summit Resources
Management, Inc. operated a glycol, brake fluid and windshield fluid recycling operation
on the Brownfields Property located at 3501 and 3481 Gribble Road. As part of the
removal action, environmental samples were collected on the Brownfields Property.
Results from soil and groundwater samples collected at the Brownfields Property by the
EPA did not show exceedances of current non-residential screening levels.
In March 2007, the Brownfields Property was referred to the EPA for a removal
evaluation (NCD986205060). Multimedia screening and sampling events were
conducted between June and August 2007. Exceedances of non-residential screening
levels were detected for arsenic, although only one of the arsenic concentrations was
above expected regional background arsenic concentrations.
EPA-directed field removal activities were conducted at the Brownfields Property
between October 2010 and February 2011, and the plant was dismantled. Materials
removed from the Brownfields Property for offsite disposal included: 302 overpacked
drums from the warehouse, 28 lab packed drums from the chemistry lab and closet,
201,582 gallons of waste, 1,775 tons of solidified/stabilized material (including tank
bottoms), 14,400 pounds of scrap aluminum, 7,530 pounds of scrap staining steel and
106.3 tons of scrap steel from the 26 above ground storage tanks (ASTs), tanker trucks
and glycol recycling processor.
EPA-directed soil sampling activities were conducted at the Brownfields Property in
January 2011 and 25 subsurface soil samples were collected. One soil sample exhibited a
concentration of tetrachloroethylene (PCE) above the EPA Region 4 regional screening
level (RSL). The soil was removed to the clay layer and transported off-site.
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Concentrations of arsenic in soil also exceeded industrial screening levels. The
Brownfields Property was referred to the Superfund Remedial and Site Evaluation
Branch (SRSEB) for ground water contamination assessment. The Brownfields Property
was assigned low priority status by the NCDENR Inactive Hazardous Sites Branch
(IHSB Inventory No. NCD986232213).
Soil
Site assessment activities conducted in 2007 and 2011 showed exceedances of screening
levels in soil for arsenic. An additional soil and groundwater assessment was conducted
by Resolve Environmental Services, PLLC (Resolve) in August 2017 for WOD Ventures
LLC. Results from the sub surface soil assessment did not show exceedances of non-
residential screening levels for VOCs, SVOCs or metals.
Soil Vapor
A soil gas assessment was conducted by Resolve at the Brownfields Property in
December 2017. Results from the assessment showed that VOCs, including chloroform,
ethylbenzene, heptane, trichloroethylene, vinyl chloride and xylene exceeded non-
residential soil gas risk screening levels.
Groundwater
Groundwater assessment activities were conducted at the Brownfields Property in August
2017. Groundwater assessment results showed exceedances of North Carolina
Groundwater 2L Standards for benzene, vinyl chloride, chromium, and lead. A receptor
survey completed by Resolve indicated that no sensitive receptors were located near the
Brownfields Property.
Potential Receptors
Potential receptors are: on-site workers and trespassers. No groundwater supply wells
were identified within 1,500 feet of the Brownfields Property.
Contaminated Media
DEQ has evaluated data collected from the following media at the subject property: soil,
soil-gas, and groundwater. DEQ relies on the following data to base its conclusions
regarding the subject property and its suitability for its intended reuse. Contaminants
exceeding screening levels are shown on Exhibit 2.
Soil
Soil contaminants above non-residential screening levels include arsenic.
Groundwater
Groundwater contaminants above the NCAC 2L Standard include: benzene, vinyl
chloride, chromium, and lead.
Soil Vapor
Soil vapor contaminants detected above IHSB Non-Residential Screening Levels include:
chloroform, ethylbenzene, heptane, trichloroethylene, vinyl chloride and xylene.
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Risk Calculations
Risk Calculations were performed using Excel worksheets provided by Sandy Mort,
NCDEQ Brownfields Toxicologist. The risk calculations indicated the following based
on available data, including the following media: groundwater, surface and subsurface
residual soil, and soil gas:
PRIMARY CALCULATORS
Receptor Pathway Carcinogenic
Risk
Hazard
Index
Risk
exceeded?
Non-
Residential
Worker
Soil Combined
Pathways 8.1E-05 1.5E+00 NO
Groundwater
Combined Pathways* 1.2E-04 2.1E-01 YES
Construction
Worker
Soil Combined
Pathways 2.2E-06 8.6E-01 NO
VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic
Risk
Hazard
Index
Risk
exceeded?
Non-
Residential
Worker
Groundwater to Indoor
Air 2.1E-05 1.3E-01 NO
Soil Gas to Indoor Air 3.3E-04 3.7E+01 YES
The mediums affected include groundwater, soil vapor, and soil. The risk driver for
surface and subsurface soil is arsenic. The PD is proposing to add appropriate vapor
mitigation systems to buildings constructed onsite in areas with elevated VOC soil vapor
concentrations to address potential vapor intrusion issues. In addition, the PD will add
appropriate dust control measures to address potential exposure to arsenic and SVOCs
during construction.
Required Land Use Restrictions
Based on the site-specific data provided to the Brownfield program, the site reuse is
suitable for commercial, industrial, office, warehouse and parking, as long as the agreed
upon land use restrictions in the BFA are followed.
1. No use other than for. Definitions for warehousing, office, and Parking.
2. No groundwater use
3. No disturbing soil without DEQ approval or for landscape/mowing/pruning/repair of
underground infrastructure (written notice to DEQ)/work for EMP.
5. Soil Import/Export.
6. No new buildings until DEQ says indoor air is safe/no VI issues/VI protection
installed.
8. EMP
9. Access to Brownfields Property for environmental assessment.
10. NBP reference in deed.
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11. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels
for generators/equipment.
12. LURU submission January 1st
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