19015_Asheville Foundry Inn Decision Memo 2018.10.22

DECISION MEMORANDUM

DATE: October 22, 2018

FROM: Cody Cannon

TO: Brownfields Assessment File

RE: Asheville Foundry Inn
35 Eagle Street & 51 South Market Street
Asheville, Buncombe County
BF # 19015-15-011

Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than a hotel, spa, open space and event
space, can be made suitable for such uses.

Introduction:
The Brownfields Property comprises two parcels totaling 1.019 acres. There are three
buildings, gravel parking areas and overgrown, wooded areas at the property.

The Brownfields Property is bordered to the north by Eagle Street and the Asheville
Police and Fire Departments; to the east by South Spruce Street, Mt Zion Missionary
Baptist Church, and a parking lot; to the south by South Spruce Street and Parking Lot
99; and to the west by THE BLOCK off Biltmore, South Market Street and other
commercial businesses.

Redevelopment Plans:
The prospective developer (PD) plans to redevelop the property into a hotel with
amenities such as: a spa, open space and event space. The PD plans to renovate the three
buildings located on the property, build two additional buildings, have lawn/grass-
covered areas, patio space, walkways, and paved areas.

Site History:
The site has historically been referenced by three addresses corresponding to the three
buildings currently present including: 35 Eagle Street, 51 South Market Street, and 42
South Spruce Street. These three buildings are remnants of the former Asheville Supply
and Foundry Company which operated as a foundry as early as 1895 based on
construction of former site buildings. The two buildings associated with 35 Eagle Street
and 42 South Spruce Street are now referenced collectively as 35 Eagle Street. The
existing buildings were constructed between 1913 and 1925. The site has undergone
many changes in its use but most recently operated as a radiator repair shop as early as
1995 according to Asheville city directory records. A summary of the historical site uses
according to Phase I and II Environmental Site Assessment Reports completed by Tetra
Tech, Inc. (2011) and Altamont Environmental, Inc. (2014) is provided below:

35 Eagle Street
 The western portion of the property contains the current 4-story building (11,500
square feet) which was constructed in 1920 and is currently vacant. It was used as
storage of machinery/machinery supplies from at least 1917 to 1925, vacant
warehouse space from 1950 to 1954, a tire warehouse in 1957, an automotive tire
company called Retreaders Supply Inc. from 1960 to at least 1972, and as
Boozers Radiator & Repair Service from approximately 1990 to at least 1995.
 The northeast portion of the property contained a building prior to being razed
sometime between 1925 and 1950. This portion of the site was used as a mattress
factory as early as 1901, a poultry dressing operation and vacant space in 1907,
and a portion of Asheville Supply and Foundry Co. from 1913 to at least 1925.
 The southern portion of the property was used as part of operations for Asheville
Supply and Foundry Co. from 1913 to at least 1925. A building was formerly
located on this portion of the site but was razed between 1925 and 1950.
 The eastern portion of the property is where the current 3-story building (10,800
square feet, formerly 42 South Spruce Street) is located. This area was used as
machine shop and wood working building from at least 1917 to 1925, an auto
repair shop in 1950 and a furniture warehouse from 1954 to at least 1972. There
was also an Acetylene welding building connected to the southern portion of the
building in 1925 but the building was razed shortly afterwards, between 1925 and
1950.

51 South Market Street
 This portion of the site is located at the corner of South Spruce Street and South
Market Street. The current building (3-stories; 14,800 square feet) was
constructed in 1923 and is currently vacant. Portions of this property have been
used as a machine shop prior to 1925, a recreation hall in 1950, a handbag
manufacturing company called Terry Co Inc. from 1945 to 1957, vacant space
from 1960 to 1963, Talman’s Office Supply from approximately 1964 to 1983,
and a furniture warehouse from 1972 to an indeterminate time.

The central portion of the Brownfields Property, on both 47 Eagle St and 51 South
Market Street, was utilized for parking from at least 1957-1972.

Tetra Tech completed a combined Phase I and II Site Assessment Report in 2011 which
included the collection of surficial and subsurface soil samples, lead based paint materials
sampling, and asbestos containing materials sampling. Elevated concentrations of
arsenic, lead, and several semi-volatile organic compounds (SVOCs) were observed in
both surficial and subsurface soil samples. Tetra Tech also discovered the presence of 2
underground storage tanks (USTs) due to exposed piping observed on the north side of
the 51 South Market Street building. On February 24, 2011, a 1,000-gallon UST (UST1)
and 550-gallon UST (UST2) were removed. Contaminated soil was discovered
underneath the 550-gallon UST and additional soil was excavated to six feet below the
bottom of the tank location. Seven confirmation samples were collected after the tank
removal. One sample collected from the bottom of the tank excavation and one sample
collected from the sidewalls of the tank excavation from UST1 contained concentrations
of total petroleum hydrocarbons (TPH) exceeding the North Carolina Department of
Environmental Quality (DEQ) UST screening level. Additionally, asbestos was
identified in the 51 South Market Street and 35 Eagle Street buildings while lead-based
paint was found in the 35 Eagle Street building.

Altamont Environmental completed a Phase II Environmental Assessment Report on
December 16, 2014 which included verification soil sampling of previous locations from
the Tetra Tech report (abundant lab qualifiers and elevated detection limits), horizontal
and vertical delineation soil sampling, sub-slab soil gas sampling beneath the 3 buildings,
and soil assessment of an area suspected to be the location of a former UST which was
removed without documentation. Concentrations of metals and SVOCs in surficial and
subsurface soils were lower than those previously reported by Tetra Tech. Arsenic
exceeded the industrial PSRG in only one sample while several samples had detections of
several SVOCs. The samples collected near the suspected former UST did not result in
any exceedances for TPH. None of the soil-gas samples contained concentrations
exceeding either the residential or industrial soil vapor screening levels.

Potential Receptors:
Potential receptors are: construction workers, on-site workers, hotel guests/customers,
vendors, and trespassers.

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.

Soil
Soil contaminants above industrial PSRGs include Arsenic and Lead. Elevated
concentrations of Benzo(a)pyrene, Benzo(a)anthracene, Benzo(b)fluoranthene,
Indeno(1,2,3-cd)pyrene, naphthalene, Aliphalitic Medium (C9-C19), Aliphalitic High
(C19-C36), Aromatic Medium (C9-C22) were also present in some 2011 samples.

Soil contaminants above UST Standards include TPH diesel range organics (DRO) and
gasoline range organics (GRO).

As outlined in the table below, the risk to future non-resident workers was calculated to
be below the DEQ Threshold for both the Lifetime Incremental Cancer Risk (LICR) but
above the Hazard Index (HI) for surficial and subsurface soil across the site.
Additionally, the risk to construction workers exceeds the HI when calculated using
solely surficial soil concentrations as well as surficial and subsurface soil combined.

Groundwater
One groundwater sample was collected April 28, 2015. The only detections were
chloroform and barium. These detections were well below the NCAC 2L Standard. As
outlined in the table below, the calculated risk does not exceed the LICR or HI for non-
residential groundwater exposure or groundwater to indoor air exposure.

Soil Vapor
A sub-slab soil gas sample was collected from each of the three buildings on November
21, 2011. There were no detections above IHSB Residential or Industrial Screening
Levels. As outlined in the table below, the non-residential risk for sub-slab soil gas does
not exceed the LICR or HI.

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, residual soil (based on
confirmatory soil data), and soil gas samples:

Medium Site Area
Non-Residential Worker
LICR HI
Groundwater
Exposure
Entire Site 5.3E-07 2.8E-3
Groundwater to
Indoor Air
Entire Site 1.4E-07 1.8E-04
Soil Exposure Entire Site 1.5E-05 1.3
Sub-Slab Soil Gas Entire Site 2.0E-08 1.5E-02

Medium Site Area
Construction Worker
LICR HI
Soil Exposure
(Shallow Only)
Entire Site 2.3E-06 1.1
Soil Exposure
(Shallow and Deep)
Entire Site 2.4E-06 9.5
Red shading LICR> 1E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index

Due to the results of the risk calculators, restrictions are in place regarding soil and
groundwater exposure and use at the Brownfields Property.

Required Land Use Restrictions:
Based on the site-specific data provided to the Brownfield program, the site reuse is
suitable for the site as long as the agreed upon land use restrictions in the BFA are abided
by.

1. No use other than for a hotel, spa, open space and event space. Definitions for Hotel
and Open Space.
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.
4. Final grade soil sampling.
5. Soil Import/Export.
6. No new buildings until DEQ says indoor air is safe/no VI issues/VI protection
installed.
7. No use of surface water.
8. EMP
9. Access to Brownfields Property for environmental assessment.
10. NBP reference in deed
11. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels
for generators/equipment
12. Abandon MWs
13. Repair any damaged MWs
14. LURU submission January 1st