22067_RJR Tobacco Area 2A_DM_20191217

DECISION MEMORANDUM
DATE: December 17, 2019
FROM: Sharon Eckard, PG
TO: BF Assessment File
RE: RJ Reynolds Company
WPDA Area 2-A
Formerly 0, 875, & 1001 Reynolds Blvd, and 4010 Assembly Drive
Winston-Salem, Forsyth County
Brownfields Project #22067-18-034
Based on the following information, it has been determined that the above
referenced site, whose intended use is for no uses other than as office, retail, high -density
residential, hotel, and associated recreational space and parking, and subject to DEQ's
prior written approval, other commercial uses, can be made suitable for such uses. Note
that restrictions apply to residential use in the BFA.
Introduction:
The Brownfields Property comprises four parcels totaling approximately 19.88 acres:
Forsyth County PINS: 6837-10-9441 (0 Reynolds Boulevard), 6837-10-3471 (1001
Reynolds Boulevard), 6837-00-4711 (875 Reynolds Boulevard), and 6837-00-7458 (4010
Assembly Drive).The Brownfields Property is located north of downtown Winston-Salem
in an industrial park developed by R.J. Reynolds Tobacco Company, which was formerly
known as the "Whitaker Park Manufacturing Complex" (Whitaker Park). The
Brownfields Property was subdivided from the RJ Reynolds Tobacco Company's Area 2
of Whitaker Park, and is referred to as Area 2-A.
Although at one time, additional structures were present on Area 2-A, currently only
Buildings No. 2-1 and No. 2-2, and a boiler house along Reynolds Boulevard are
standing; all other structures on Area 2-A were demolished by the former owner prior to
the donation of the Brownfields Property to the Prospective Developer.
The Prospective Developer is WPDA, Inc., a North Carolina non-profit corporation
chartered on April 19, 2011 and amended on April 28, 2014 for the purpose of managing
the Brownfields Property. Originally known as Whitaker Park Development Authority,
Inc., WPDA, Inc. was created by Winston-Salem Business Inc., the Winston-Salem
Alliance, and Wake Forest University. Its address is 1080 West Fourth Street, Winston-
Salem, NC 27101, and its President is Robert E. Leak, Jr. WPDA, Inc. acquired the
Brownfields Property by donation from R.J. Reynolds Co. in 2017.
RJReynolds Area 2-A/22067-18-034/17Dec2019

Redevelopment Plans:
The Prospective Developer will be redeveloping the Brownfields Property in phases with
the first phase related to the renovation of Buildings 2-1 and 2-2 into residential space.
There will be ground floor residential space. Buildings 2-1 and 2-2 are on the National
Register of Historic Places.
Additional phases of redevelopment may include the construction of new buildings or
areas for hotel, restaurant, recreational spaces, and open space. Additional assessment of
soil and groundwater, and perhaps soil gas, should be performed prior to the construction
and occupancy of any new buildings on the site as soil and groundwater assessment of
Area 2-A was limited in areal extent and for some samples, limited in selected analytes.
Site History:
The Brownfields Property was first developed for tobacco warehousing, stemming and
re -drying operations, and cigarette production purposes since R.J. Reynolds Tobacco
Company began operations in the 1920s. By 1928, a coal-fired boiler house was present
in the southeastern corner of the Brownfields Property, as were one 500,000-gallon water
reservoir, several tobacco warehouses in the northeastern area of the Brownfields
Property, and a rail line along the northeastern Brownfields Property boundary.
By 1950, a separate boiler house, a rail spur, a second 500,000-gallon water reservoir,
and what was originally called the "Leaf Warehouse No. 2" for the storage of leaf
tobacco, had been constructed along Reynolds Boulevard. Reportedly, the coal -boiler
was last used in 1958. The Leaf Warehouse No. 2 came to be known, and is now referred
to, as Building No. 2-1. Operations in Building No. 2-1 later included tobacco stemming
and most recently tobacco recovery operations. However, Building No. 2-1 is listed as a
hazardous waste storage location in an early assessment report. The actual location of
this reference is unknown.
By 1958, Building No. 2-2 was constructed immediately north of Building No. 2-1 as
was an area for the parking and possibly maintenance of trucks to the northwest of
Building No. 2-2. Building No. 2-2 was noted as a storage location of used oil
contaminated with refrigerant in an early assessment report, but the actual location of this
storage is not known.
By 1963, other buildings, including Buildings No. 2-3, No. 2-4, and No. 2-5 (garage
warehouse), were constructed on the Brownfields Property. A fueling station near
Building No. 2-5 stored diesel in a 7,500-gallon underground storage tank (UST) and
gasoline in a 1,000-gallon UST. Buildings No. 2-1 and No. 2-2 were most recently used
for tobacco recovery operations. Later, Building No. 2-7 was added to the north of
Building No. 2-2.
By 2017, the tobacco warehouses in the northeastern portion of the Brownfields
Property, the garage, the 500,000-gallon reservoirs, and Building 2-5 were demolished
prior to donating the Brownfields Property to the Prospective Developer.
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RJReynolds Area 2-A/22067-18-034/17Dec2019

Summary of Environmental Conditions:
Pertinent environmental information regarding the Brownfields Property and surrounding
area includes the following:
1) two USTs were removed from the fueling station near Building No. 2-5 in Area 2-A in
1989 (NC DWM UST Section Incident No. 4018). Contaminated soil as a result of
releases from the fuel pump island and associated UST piping were removed from the
area in 1989. A groundwater well, MW-2-5-1, was installed in the vicinity of the tank
excavation in February 1989, sampled, and subsequently abandoned. However, at that
time, the well was sampled by EPA Methods 601 and 602 only with rather elevated
reporting limits; it was not sampled for the full analytical suite we would do today;
2) Reportedly, the abandoned concrete saddle supports were used to hold a 10,000-gallon
used oil above ground storage tank (AST);
3) Other than fuel sources and used oil handling and storage, chemical use at the
Brownfields Property is believed to be limited to fumigation of stored tobacco leaf that
was conducted by a contractor. Reportedly, chemicals used for the fumigation, which are
believed to have included phosphine compounds, were not stored onsite; and
4) Coal was stockpiled near the boiler house to the east of Building No. 2-2 and it is
believed that coal ash is likely to have been deposited in the area near the boiler house.
Environmental site assessment activities conducted in Area 2-A have focused primarily
on sub -slab vapor and indoor air assessment of existing Buildings 2-1 and 2-2 to evaluate
potential risks related to redevelopment of these buildings for residential use. Other
assessment is limited to groundwater results from the 1989 monitoring well installed near
the UST excavation, and one recent temporary groundwater well sample (GW-1)
collected in the same area for the entire 20 acres, and localized soil assessment that is
limited in areal extent and in analytical suite. Care should be taken to limit the risk
calculator output to only those areas specifically represented by the data used at the time.
Additional environmental assessment addressing remaining data gaps are required by
subparagraph 15.h. of this Agreement prior to redevelopment of the Brownfields Property
outside of Buildings 2-1 and 2-2.
Potential Receptors:
Potential receptors are construction workers, workers, residents, visitors, and trespassers.
Contaminated Media Summary:
DEQ has evaluated data collected from the following media in localized areas at the
subject property: groundwater, soil, sub -slab vapor, and indoor air. DEQ relies on the
following data to base its conclusions regarding the specific areas of the subject property
represented by these data, and its suitability for its intended reuse.
RJReynolds Area 2-A/22067-18-034/17Dec2019

Soil
Soil samples were limited to seven (7) areas of the 20-acre Brownfields Property and
were collected primarily from a depth of 1.5 feet below ground surface and in areas
associated with the northeastern tobacco warehouses, and the coal storage area. Not all
samples were evaluated by EPA Method 8260, 8270 and RCRA metals, nor were
organochlorine or organophosphate pesticides, herbicides analyzed for in all soil samples.
Soil contaminants detected in excess of their respective residential screening levels at the
Brownfields Property include aldrin up to 0.212 milligrams per kilogram (mg/kg), arsenic
up to 5.72 mg/kg, and dieldrin up to 0.4 mg/kg. Soil constituents that were detected but
do not have an established screening level are cis -Chlordane, trans -Chlordane, and endrin
ketone up to 0.13 mg/kg, 0.059 mg/kg, and 0.0045 mg/kg, respectively.
Note that the pesticide detections are all from the GP-3 area either from samples collected
in June 2017 or from a resampling and laboratory split event in September 2017. No soil
samples have been collected in other warehouse areas on the Brownfields Property such
as the warehouse along the western boundary of Area 2-A, nor in the eastern and
southeastern extents of Area 2-A.
Sample GP-10 was collected from near the former coal storage area, but its analysis did
not include EPA Method 8270 for semi -volatile organic compounds (SVOCs). The area
of coal storage and possible coal ash may be larger than what could be evaluated by this
one sample.
Groundwater
Available groundwater is very limited. An old report notes that groundwater
concentrations in a well installed in 1989 (MW-2-5-1) was sampled for EPA Methods
601 and 602 and did not have constituents; however, there was no laboratory data nor
tabulated data that accompanied that report. A temporary groundwater sample (GW-1)
was collected from a Geoprobe location (GP-1) in June 2017 in the same general area and
analyzed by EPA Methods 8260 and 8270, but not metals; however, it is not clear
whether this well was properly constructed nor purged prior to the collection of this
sample. This is the only location across the entire 20 acre Brownfields Property that has
any groundwater data associated with it.
Based on this one limited sample data, the only contaminant that is detected in this one
groundwater sample is carbon tetrachloride at 8 micrograms per liter (µg/L) above its NC
2L standard of 0.3 µg/L, and above its residential vapor intrusion screening level in
groundwater of 4.1 µg/L.
The direction of groundwater flow has not been identified specifically at the Brownfields
Property.
Surface Water
There is no surface water at the Brownfields Property.
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RJReynolds Area 2-A/22067-18-034/17Dec2019

Soil Gas
No soil gas sampling was conducted at the Brownfields Property.
Sub -Slab Vapor
Sub -slab vapor sampling was conducted in multiple locations below existing Buildings 2-
1 and 2-2 in 2019 to evaluate the potential exposure under residential use scenarios as
both of these buildings will have ground floor residential use under the existing
redevelopment plan.
No VOCs were detected in sub -slab vapor samples in exceedance of residential VISLs
for soil vapor, including carbon tetrachloride, that was detected in groundwater to the
northwest of these buildings above its residential VISL. Certain compounds were
detected in sub -slab vapor; however, none of these compounds have established VISLs.
These are: ethanol, 4-ethyltoluene, cis-1,2-dichloroethylene (cis-1,2-DCE), trans-1,2-
DCE, and trichlorofluoromethane.
Indoor Air
Indoor air samples were collected contemporaneously with the sub -slab vapor samples in
2019 within existing Buildings 2-1 and 2-2, some of which were collected in proximity to
elevator shafts at the buildings. Indoor air contaminants that exceeded their respective
residential VISL were chloroform (0.13J microgram per cubic meter (µg/m3)), dieldrin
(0.007 µg/m3), and naphthalene (up to 0.28 µg/m3). Compounds that were detected but
that do not have established VISLs included 1,2-dichloro- 1, 1,2,2-tetrafluoroethane,
ethanol, and trichlorofluoromethane.
Risk Calculations
The available site data was entered into the DWM Risk Calculator (May 2019 version).
For the purposes of conducting the risk evaluation, the available data was used to create
three (3) risk calculators: 1) Soil and groundwater (limited in extent and analytes), 2) sub -
slab vapor and indoor air collected in Building 2-1, and 3) sub -slab vapor and indoor air
from samples collected in Building 2-2. The results of the risk calculations are provided
below:
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RJReynolds Area 2-A/22067-18-034/17Dec2019

1) Soil and Groundwater (limited in extent and anal. es)
This calculator (below) is based on data collected from seven shallow soil areas across
the 20-acre property and does not include many areas that may be developed in the
future, and from one groundwater sample near the former UST excavation area.
Although this calculator indicates that there are no unacceptable environmental risks
(carcinogenic risk less than 10E-4 and a hazard index less than 1) with respect to soil and
groundwater at the Brownfields Property, this should be confirmed with additional
assessment data as required in the BFA before construction or grading occurs outside of
the renovations of existing Buildings 2-1 and 2-2.
Risk for Individual Pathways
Version Date: May 2019
Basis: May 2019 EPA RSL Table
Site ID: 22067-18-034
Exposure Unit ID: Limited site soil & gw (in areal extent & analytes)
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carciinnogenic
sk
Hazard Index
Risk exceeded?
Resident
Soil
5.1E-05
6.7E-01
NO
Groundwater Use*
2.1E-05
1.9E-01
NO
Non -Residential Worker
Soil
1.2E-05
5.0E-02
NO
Groundwater Use*
5.2E-06
4.1E-02
NO
Construction Worker
Soil
1.6E-06
2.0E-01
NO
Recreator/Trespasser
Soil
2.8E-05
3.7E-01
NO
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
2.0E-05
1.2E-01
NO
Soil Gas to Indoor Air
0.0E+00
0.0E+00
NO
Indoor Air
0.0E+00
0.0E+00
NO
Non -Residential Worker
Groundwater to Indoor Air
4.6E-06
2.9E-02
NO
Soil Gas to Indoor Air
0.0E+00
0.0E+00
NO
Indoor Air
0.0E+00
0.0E+00
NO
6
RJReynolds Area 2-A/22067-18-034/1713ec2019

2) Sub -slab vapor and indoor air collected in Building2-1
This risk calculator (below) is based on data collected from multiple sub -slab vapor and
indoor air sample locations in Building 2-1 in 2019 only; there are no soil nor
groundwater data in this calculator. The results indicate that there are no unacceptable
environmental risks (carcinogenic risk less than 10E-4 and a hazard index less than 1)
with respect to sub -slab vapor and indoor air samples collected from within Building 2-2.
No vapor mitigation measures are contemplated for this future residential space based on
these data.
Risk for Individual Pathways it
Version Date: May 2019
Basis: May 2019 EPA RSL Table
Site ID: 22067-18-034
Exposure Unit ID: Building 2-1; sub -slab vapor and indoor air data ONLY (8/21/19)
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carciinnogenic
sk
Hazard Index
Ri sk exceeded?
Resident
Soil
0.0E+00
0.0E+00
NO
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
0.0E+00
0.0E+00
NO
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
1.2E-05
2.9E-01
NO
Indoor Air
7.1E-06
3.2E-01
NO
Non -Residential Worker
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
8.9E-07
2.3E-02
NO
Indoor Air
1.6E-06
7.7E-02
NO
7
RJReynolds Area 2-A/22067-18-034/1713ec2019

3) Sub -slab vapor and indoor air from samples collected in Building2-2
This risk calculator (below) is based on data collected from multiple sub -slab vapor and
indoor air sample locations in Building 2-2 in 2019 only and does not contain soil nor
groundwater data. The results indicate that there are no unacceptable environmental risks
(carcinogenic risk less than 10E-4 and a hazard index less than 1) with respect to sub -slab
vapor and indoor air samples collected from within Building 2-2. No vapor mitigation
measures are contemplated for this future residential space based on these data.
Risk for Individual Pathways 1
Version Date: May 2019
Basis: May 2019 EPA RSL Table
Site ID: 22067-18-034
Exposure Unit ID: Building 2-2; sub -slab & indoor air data from 8/21/19 only
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded.
Resident
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carciinnogenic
sk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
1.7E-06
1.8E-01
NO
Indoor Air
6.2E-06
1.9E-01
NO
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
1.3E-07
1.4E-02
NO
Indoor Air
1.4E-06
4.6E-02
NO
Required Land Use Restrictions —
Land use restrictions will include the standard land use, Environmental Management
Plan, reporting, groundwater, soil disturbance, known contaminants, notice, and LURU
LURs. In addition, the residential use has been cleared for existing Buildings 2-1 and 2-2
based on sub -slab and indoor air data; however, additional assessment is required to be
conducted prior to redevelopment of the other areas of the Brownfields Property.
Based on the site -specific data provided to the Brownfield program, the site reuse
(limited to Buildings 2-1 and 2-2 for high density residential) is suitable for the site as
long as the agreed upon land use restrictions in the BFA are abided by. Occupancy of the
buildings should first require final grade sampling of exposed areas as some areas around
the buildings are sites of old rail lines or other types of equipment
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RJReynolds Area 2-A/22067-18-034/1713ec2019