23052 Southern Steel Dec Memo 20210128

DECISION MEMORANDUM DATE: January 28, 2021 FROM: Carolyn Minnich

TO: BF Assessment File RE: Southern Steel 3015 Wilkins Blvd, Charlotte, Mecklenburg County
Brownfields Project No. 23052-19-060
Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than industrial, office, warehousing, brewery or food production facility, retail, restaurant, high density residential, parking and subject to DEQ’s prior written
approval, other commercial uses, can be made suitable for such uses.
Introduction: The Brownfields Property comprises one parcel ~5.1848 acres (Mecklenburg Tax Parcel ID No. 11701118). The immediate area has commercial/industrial development: to the north QuikTrip gas station with a convenience store and liquor store; to the east Eastway Wrecker Service and
Sam Auto Salvage Yard; to the south vacant land and Norfolk Southern railroad right of way and tracks; and to the west by school bus maintenance facility and parking lot for Charlotte Mecklenburg Schools. The Brownfields Property is one of several parcels that were included in the former Southern
Steel Facility (“Southern Steel”). More information is presented on site history below. Redevelopment Plans: Future development will include the construction of three light industrial buildings to be used
predominantly for warehousing/distribution purposes. In September 2020, the land use was
expanded to include high density residential. The City of Charlotte Comprehensive Redevelopment Plan for Wilkinson Blvd include mixed use with commercial, residential, and industrial uses. Redevelopment in this area will create jobs, increase tax base, revitalize a blighted area (it is currently littered with trash and debris), and preserve green space.

A portion of the Brownfields Property in the figure below is highlighted yellow to define a “Area of Known Soil Contamination”. Soils in this area are impacted with elevated levels of lead, proper management requires an impervious cap of clean fill, asphalt, or concrete as outlined in one of the LURs. The redevelopment plan shows a building and parking lot over this area.

Site History:
The Brownfields Property was developed in 1911 for industrial use along with the adjacent parcels as Southern Steel. The facility comprised six buildings, approximately167,000 sq. ft. Southern Steel operated from 1911 through 2002 as a steel fabrication facility. From 2002-2009, the facility was used as a steel warehouse. In 2010, the buildings were demolished, and
foundations were removed. The Brownfields Property is currently undeveloped, vacant land.
In the mid-2000s, the 10.9 acres parcel that was the former Southern Steel Facility was split and divided into 4 parcels. In 2014, one parcel was sold to Quik Trip Corporation and developed as a service station and convenience store. In 2015, another parcel was sold to The Mecklenburg
County Alcoholic Beverage Control Board (”ABC Store”) for a retail center. In 2019, the
Brownfields Property was sold to the Prospective Developer. The remaining parcel is less than one acre and serves as a storm water retention pond and open land. Other DEQ involvement on the Brownfields Property includes the following:
1. Southern Steel Company, LLC. was listed as a Conditionally Exempt Small Quantity
Generator of hazardous waste in 2005 Facility ID No. NCD003152501. Inventory included arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, methyl ethyl ketone, and other volatile organic compounds. No violations or citations have been recorded.
2. Two Aboveground Storage Tank (“AST”) incidents are reported on the Brownfields
Property Incident No. 91069 from April 2008 and Incident No. 91127 from March 2010. These incidents are assigned low risk in the DEQ Underground Storage Tank (“UST”) Section. Both of these incidents related to transformer oil leaks due to vandalism on the vacant Brownfields Property.
3. Adjacent to the north of the Brownfields Property is Quik Trip 1004 Service Station,
Site ID Facility No. 00-0-0000039351. The following UST incidents are associated with the Quik Trip Property, but were under ownership of Southern Steel, UST Incident Nos.: 91122, 27138, 36945, all are low risk and from 1996.

Potential Receptors:
Potential receptors are for commercial/industrial uses are construction workers, on-site workers, visitors, and trespassers. Potential receptors for residential use are residents, children, and pets. Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil and
minor impacts in the groundwater. DEQ relies on the following data to base its conclusions regarding the subject property and its suitability for its intended reuse. Soil
Environmental investigations of soil and groundwater began at Southern Steel as early as 1994.
Metals concentrations were detected in soil samples, specifically lead and chromium that exceeded state standards. Approximately 2,056 tons of soil were excavated from numerous areas on the former Southern Steel facility and transported off site as hazardous and non-hazardous waste in December 1994 through November 1995.

In 2019, Phase II activities were conducted to assess soil impacts on the Brownfields Property. Nine soil borings were advanced in areas of concern and analyzed for RCRA metals and volatile organic compounds (“VOCs”). The Brownfields Property is covered by approximately 1-2 ft of fill dirt following the demolition of Southern Steel buildings and during the redevelopment of the
northern parcel, Quik Trip and ABC Store. No evidence of staining is currently visible. Metals
are the contaminants of concern (COCs) specifically lead impacts. Concentrations of lead ranged from 23 mg/kg to 1240 mg/kg, five of the samples are above the residential standard (400 mg/kg). Sample depths were 1-3 feet below ground surface (“bgs”). Soil characterization samples were collected at a depth of 1-4 ft bgs and sampled via Toxicity Characteristic Leaching
Procedure (“TCLP”) method. The results for lead concentrations ranged from 0.13 mg/L to 26.0
mg/L. Five of the fifteen composite samples exceeded 5 mg/L, the EPA Maximum Concentrations for Toxicity Characteristic. An “Area of Known Soil Contamination” has been defined on the brownfields plat map and soils must be capped. Soils that are disturbed must be disposed of off-site in accordance with applicable regulations.

Hexavalent Chromium, cobalt, arsenic, and manganese concentrations were detected above residential PSRGs during the 2019 soil sampling. As a result of the 2019 data, in Feb 2020, seven shallow soil samples were collected and
analyzed for TCLT RCRA Metals and hexavalent chromium:
• Hexavalent Chromium concentrations ranged from below laboratory detections limits (<0.318 mg/kg) to 4.01 mg/kg.
• Cobalt concentrations above the residential PSRG (4.7 mg/kg) were detected in soil
borings SB-5, SB-6, SB-8, ad SB-9 (7.33, 9.33, 5.38, 13.1 mg/kg, respectively.)
• Arsenic concentrations ranged from 1.22 mg/kg to 3.51 mg/kg across the Brownfields Property. These detections exceed the residential PSRG standard of 0.68 mg/kg.
• Manganese concentrations were detected across the Brownfields Property ranging from
60.7 mg/kg to 429 mg/kg. The PSRG non-diet standard is 380 mg/kg and soil boring SB-5 exceeds this standard.

Groundwater In 2019, four temporary wells were installed, samples collected and analyzed for VOCs by EPA Method 8260B, RCRA Metals (plus beryllium, cobalt, manganese, and nickel) by EPA Method
6020/7470, and hexavalent chromium by EPA Method 7199. No VOCs were detected above the
laboratory detection limits in groundwater samples. Metal concentrations for cobalt, manganese, and chromium were detected above 2 L standards. Arsenic, barium, lead, nickel, selenium, and silver concentrations were detected above laboratory detection limits but below the 2L standards.
In 2010, two temporary groundwater wells were installed and sampled. The results were
included in the Subsurface Investigation Activities Report dated February 2011 prepared by CRA Geological Services, Inc. The analytical data are presented in the report, but the laboratory analytical reports were not provided, and data could not be validated. Therefore, it is not included in the Brownfields Agreement Exhibit 2. However, for comparison purposes, the
analytical data is consistent with results from 2019.
During the receptor survey, two industrial process wells were identified adjacent to the Brownfields Property. These wells are located 725-850 ft cross gradient and southwest of the Brownfields Property at 2200 Donald Ross Road. Reportedly, the wells are used for fire
suppression and industrial process water at Southern Metals Company. Shallow soil
contamination at the Brownfields Property is not likely to impact the groundwater usage by the industrial water supply wells at 2200 Donald Ross Road. No additional groundwater assessment was necessary.
Surface Water
Surface water may or may not be present on the Brownfields Property. An unnamed tributary of Irwin Creek is shown on some maps within the county and not on others. The Environmental Reports indicate a body of water on the southwest corner of the Brownfields Property. This area is within the Mecklenburg County Wetland buffer and no redevelopment is permitted. No
surface water samples were collected during the Brownfields assessment activities.

Soil Vapor No vapor assessment activities were conducted. Volatile Organic Compounds (VOCs) were not
detected above laboratory method detection limits(MDL) in soil or groundwater samples.

Sub-Slab Vapor No structures are on the Brownfields Property at the time of assessment. And VOCs were not detected above the MDL for soil or groundwater. Therefore, no sub-slab samples were collected.

Indoor Air No structures are on the Brownfields Property at the time of assessment. And VOCs were not detected above the MDL for soil or groundwater. Therefore, no indoor air samples were collected.

Risk Calculations The DEQ Risk Calculator was developed to evaluate the risk of multiple contaminants and multiple exposure routes associated with contaminated environmental media at a site. The risk evaluation procedures, equations, and default parameters used to create the calculator follow the
current USEP risk assessment guidance. The DEQ Risk Calculator dated July 2020 was used to
evaluate the following.

The Brownfields Property was evaluated as a whole. The risk calculations indicated the following based on available data, including the following media: groundwater and soil samples:

Based on the risk calculator, groundwater use needs to be restricted. This will be a land use
restriction. The second risk area is soil. The following are screens indicating what compounds are the greatest risk. For the construction worker, the highest concentrations are from manganese and benzo(a)pyrene. Using the proper PPE and education can be provided to reduce exposure a construction worker may have on the Brownfields Property.

The residential soil risk summary page indicates cobalt and manganese (non-diet) concentrations
present the highest risk. The redevelopment plans include capping the soils with concrete caps, asphalt parking lots, and importing clean fill. Final grade sampling will be required.
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.
• No groundwater usage
• Install, maintain, inspect soil cap in Area of Known Soil Contamination
• No soil disturbance without DEQ approval
• Soil may not be removed from or soil imported without DEQ approval
• Final grade sampling reqt
• Standard VI LUR with preceding paragraph to LURs indicating the existing structure meets the VI reqt, but new structures require evaluation.
• EMP required prior to redevelopment
• Annual development summary report required
• No use of known contaminates on the BF Property
• DEQ shall not be denied access
• Deed conveyance of Notice
• Maintenance of future monitoring wells as needed to remain on site
• LURU submittal