22019 Cone Mill Greensboro Decision Memorandum 20190521

DECISION MEMORANDUM
DATE: March 19, 2019 FROM: Bill Schmithorst TO: Cone Mill- Greensboro Project File
RE: Cone Mill - Greensboro 1700, 1701, 1702 and 1707 Fairview Street Greensboro, Guilford County BF # 22019-18-041
Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than retail, office, restaurant, parking, high density residential, recreation, open space, brewery or food production facility, and commercial, can be made suitable for such uses.
Introduction: The Brownfields Property comprises three parcels totaling 21.21 acres and is developed on the eastern parcels with a two story, approximate 800,000 square foot manufacturing building with a basement (Parcels 7875167370 and 7875261625). The western parcel
(7875163235) consists of asphalt, overgrown vegetation, and a railroad spur along the northern property boundary. The property is served by municipal water and sewer. The Brownfields Property is located in a mixed industrial and residential area bordered to the south by 9th Street with wooded land and single-family residences farther south; to the east by Cone Mills wastewater treatment plant with single-family residences farther east;
to the west by North Buffalo Creek and Fairview Street and Revolution Ballfield (City of Greensboro and Cone Mills White Oak Plant; and to the north by Cone Mills White Oak Plant. The building and property was used by Cone Mills as a warehouse from 1977 until 1996. The building has been vacant since 1996.

Redevelopment Plans: The PD plans to develop the Brownfields Property into a mixed use development including retail, office, restaurant, brewery or food production facility, parking, high density residential, recreation, open space, and commercial, and can be made suitable for
such uses. Proposed redevelopment will include reuse of existing buildings and new
construction. North Buffalo Creek is currently located within the property boundary, but will not be included within the Brownfields Property boundary. The creek has been subdivided as a separate parcel and ownership will be transferred to the City of Greensboro for use as open space.

Site History: The Brownfields Property was developed in 1895 for use as a rug manufacturing business. Cone Mills purchased the manufacturing facility in 1911 and operated it as a contract print works plant until 1977. Historical manufacturing activities included textile
printing and finishing. The Brownfields Property contains a two story, approximate 800,000 square foot manufacturing building with a basement. Municipal water and sewer
are provided to the Brownfields Property by the City of Greensboro. The building was used by Cone Mills as a fabric storage warehouse from 1977 until 1996. The building has been vacant since 1996. Historical aerial photographs from the 1930s depict residential structures on the
southeastern portions of the Brownfields property. The residential structures are no longer present in a 1948 aerial photo. Historical records indicate that multiple above ground storage tanks and a gasoline underground storage tank were located on the northern and western portions of the property.
A detached power house is located on the western side of the plant. The power house formerly received steam heat through overhead high pressure steam pipes that was generated from an off-site Cone Mills facility. In September 2017, an environmental assessment was conducted by ECS at the
Brownfields Property. During the assessment, soil samples were collected from 16 soil borings advanced in potential areas of concern identified during previous Phase I environmental assessment activities. The soil samples were analyzed for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs) base neutrals & acid extractables (BNA), and total Resource Conservation and Recovery Act (RCRA) metals.
In addition, three permanent monitoring wells were installed at the Brownfields Property. The groundwater samples were analyzed for VOCs, SVOCs, and total RCRA metals. ECS also collected ten soil-gas samples (SG-1 through SG-10) at the subject site to be analyzed for VOCs using EPA Method TO-15.
Laboratory analysis detected several SVOCs at concentrations above Residential Health-Based Preliminary Soil Remediation Goals (PSRGs) in the soil samples collected on the north side the existing building. The soil samples were collected between 3 and 4 ft below ground surface (bgs). Concentrations of VOCs exceeding the applicable NC 2L
Groundwater Quality Standards (NC 2L) were detected in the groundwater sample
collected from monitoring well MW-2, located near the north side of the building. Analysis of soil gas samples detected VOCs in one sample located in the center of the building above the NCDEQ residential soil gas screening levels (SGSLs).
An additional environmental assessment was conducted by ECS in October 2018 to
further assess environmental conditions at the site. A component of the assessment included an electromagnetic (EM) and ground penetrating radar (GPR) survey to determine if unknown underground storage tanks (USTs) were present at the Brownfields Property. The GPR survey was conducted in the vicinity of the former residential
structures, outside of the boiler room, and in the vicinity of the former UST/AST located
on the eastern parcel to the north/northeast of the building. It was reported that no anomalies indicative of USTs were detected.
During the October 2018 environmental assessment, eight soil samples were collected, five permanent groundwater monitoring wells were installed, and three sub-slab soil gas
samples were collected. Groundwater samples were collected from each new monitoring well and the three existing monitoring wells. The groundwater samples were analyzed by a North Carolina certified laboratory for VOCs, SVOCs, total RCRA metals, hexavalent chromium, pesticides, and perfluorinated compounds (PFCs) (EPA Method 537). Soil samples were analyzed for VOCs, SVOCs, total RCRA metals, hexavalent chromium,
and pesticides. Soil gas samples were analyzed for VOCs by EPA Method TO-15. Results from the October 2018 showed an exceedance of SVOCs in one soil sample near the north side of the existing building. One groundwater sample exceeded NC 2L Standards for benzene and naphthalene. In addition, two sub-slab soil gas samples
exceeded SGSLs for tetrachloroethylene. All relevant data is tabulated in Exhibit 2 to the Brownfields Agreement. Potential Receptors: Potential receptors are future residents, visitors, on-site workers, construction workers,
and trespassers. In addition, N. Buffalo Creek, located adjacent to the northwestern Brownfields Property boundary, is a potential surface water receptor. No private water supply wells are reported to be located within 1,500 feet of the property. Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil, soil gas, sub-slab vapor, and groundwater. DEQ relies on the following data to base its conclusions regarding the subject property and its suitability for its intended reuse. Additional details regarding the results from the site assessment activities conducted at the site can be found in Environmental Services Report, Former Print Works Plant, ECS
Southeast , LLP, January 18, 2019 and Environmental Services Report, Former Print
Works Plant, Former Print Works Plant, ECS Southeast, LLP, April 18, 2017. A summary of sample results exceeding applicable screening values is provided in Exhibit 2 of the Brownfields Agreement.

Soil September 2017 Results Results from the environmental assessment indicated SVOC detections above Residential PSRGs in soil samples SB-2, SB-3, SB-4, SB-7, SB-9, and SB-10. The highest detections
of SVOCs in soil were found in soil sample SB-3 located along the north side of the
existing building at a depth of 2-4 feet. Laboratory analyses from sample SB-3 indicated that benzo(a)anthracene (3.60 mg/kg), benzo(b)fluoranthene (3.99 mg/kg) and benzo(a)pyrene (3.07) were detected at concentrations above Residential PSRGs. Laboratory metals analyses indicated that arsenic and cadmium were detected in soil
sample SB-9 at concentrations of 9.84 mg/kg and 19.2 mg/kg, respectively.
October 2018 Results Soil analytical results indicated that benzo(a)pyrene was detected above the Residential Preliminary Soil Remediation Goal (PSRGs) at a depth of 2-4 feet in soil sample SB-4,
located at the north side of the existing building, at a concentration of 0.709 mg/kg. In addition, laboratory results indicated that arsenic was detected above its Residential
PSRG in soil samples SB-3, SB-4, SB-6, and SB-7 at concentrations up to 2.1 mg/kg. The arsenic concentrations are comparable to background arsenic concentrations found at other sites in the North Carolina Piedmont. Laboratory results did not detect hexavalent chromium above the PSRG; however, the reporting limits were above the Residential PSRG for some of the samples. Results also indicate that no pesticides were detected.

Groundwater Laboratory analysis detected benzene and naphthalene at concentrations above North Carolina 2L Groundwater Quality Standards (NC 2L) in the groundwater sample collected from MW-2 in October 2018. No SVOCs were detected above screening levels.
Laboratory analysis detected several metals at concentrations above NC 2L Standards in groundwater samples collected during the October 2018 assessment, including barium, cadmium, chromium, and lead. Mercury was also detected in the groundwater sample collected from monitoring well MW-5 above its NC2LGWQS. Hexavalent chromium
was not detected in groundwater samples. The groundwater samples were collected using a bailer and it was reported that sediment was present in the samples. Sub-Slab Soil Vapor Laboratory analysis indicated that tetrachloroethylene was detected at concentrations
above North Carolina Department of Environmental Quality (NCDEQ) Division of Waste Management’s (DMW’s) Residential and Non-Residential Soil Gas Screening Levels (SGSLs), in sub-slab soil gas samples collected in October 2018 from SG-1 (5,600 ug/m3) and SG-2 (340 ug/m3). Sample SG-1 (2018) was collected at the former machine shop and SG-2 (2018) was collected within the central portion of the building.
Additional VOCs were detected during the September 2017 site assessment in soil gas sample SG-7 (2017), located in the central area of the existing building, including ethylbenzene, 1,3,5-trimethylbenzene, and total xylenes. According to the NCDEQ Risk Calculator, laboratory results from samples SG-1 (2017) and SG-7 (2017) were above the
calculated non-carcinogenic hazard quotient (HI) of 1.0.

Risk Calculations Risk calculations were performed using Excel worksheets provided by Sandy Mort, NCDEQ Brownfields Toxicologist. For the purposes of looking at the site spatially, risk
calculations were run for individual samples with the highest concentrations of
constituents analyzed, including soil gas (SG-1 (2018) and SG-2 (2018)), soil (SB-4), and groundwater (MW-2). Risk calculations are summarized below.
VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
SG-1
Resident Soil Gas to Indoor Air 1.9E-05 4.1E-00 YES
Non-Residential Soil Gas to Indoor Air 1.4E-06 3.3E-01 NO
Worker
SG-7
Resident Soil Gas to Indoor Air 5.6E-05 2.7E+00 YES
Non-Residential Worker Soil Gas to Indoor Air 4.3E-06 2.1E-01 NO
MW-2
Resident Groundwater to Indoor Air 7.4E-06 1.2E-01 NO
Non-Residential
Worker Groundwater to Indoor Air 1.7E-06 2.8E-02 NO

PRIMARY CALCULATORS – GROUNDWATER (MW-2) AND SOIL (SB-4)
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Resident
Soil Combined
Pathways 3.1E-05 1.6E-01 NO
Groundwater
Combined
Pathways*
1.1E-04 2.9E+00 YES
Non-
Residential
Worker
Soil Combined
Pathways 2.0E-06 1.4E-02 NO
Groundwater
Combined
Pathways*
2.6E-05 7.0E-01 NO
Construction
Worker
Soil Combined
Pathways 1.8E-06 2.1E-01 NO
Red Lettering LICR> 1E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index Results from risk calculations indicate that indoor air soil vapor and groundwater have hazard risk indices above 1.0. In order to mitigate risks from groundwater contaminants,
a land use restriction will be placed on the Brownfields Property prohibiting groundwater
use. Risks from soil vapor may require vapor mitigation using both NCDEQ-approved engineering and land use controls, as warranted by the planned use in areas of elevated VOC soil vapor concentrations. Any activities on the property requiring subsurface excavation or earth moving will be conducted under a NCDEQ-approved Environmental
Management Plan. In addition, final grade soil sampling will be conducted before the
Brownfields Property can be occupied for its proposed use. Required Land Use Restrictions: Based on the site-specific data provided to the Brownfields 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 high-density residential, retail, office, recreational, open space,
parking, restaurant, brewery or food production facility, and commercial, can be made suitable for such uses. 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. Soil Import/Export protocol is followed. 5. Standard VI LUR 6. EMP 7. Access to Brownfields Property for environmental assessment. 8. NBP reference in deed.
9. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels for generators/equipment. 10. Ongoing maintenance of vapor mitigation systems. 11. Final grade soil sampling for RCRA metals, SVOCs, and VOCs will be conducted in exposed areas.
12. LURU submission January 1st