22018_Westinghouse_Decision Memo

DECISION MEMORANDUM
DATE: July 31, 2020
FROM: Brad Atkinson
TO: BF Assessment File
RE: Westinghouse Electric Meter and Light
2728 Capital Blvd.
Raleigh, Wake County
BF Project No. 22018-18-092
Based on the following information, it has been determined that the above -referenced
site, whose intended use is for no uses other than office, restaurant, warehouse, retail,
high -density residential, industrial, hotel, food and beverage processing, grocery, parking,
and, subject to DEQ's prior written approval, other commercial uses including drop -in
child care, can be made suitable for such uses.
Introduction:
The Prospective Developer is SVC 2728 Capital Partners, LLC which is located at 700
Spring Forest Road, Suite 105, Raleigh, NC 27609. The Managing Director of the PD is
Lee H. Roberts.
The Brownfields Property comprises one parcel totaling 32.35 acres (Wake County Tax
Parcel 1715-81-7820) and is located at 2728 Capital Boulevard, Raleigh, Wake County.
Structural improvements include primarily one large building, approximately 547,000
square feet in area (divided into an approximately 100,000-square foot two-story office
space connected to approximately 447,000 square feet of warehouse, industrial,
commercial, and retail space).
The Brownfields Property is regulated under the DWM Inactive Hazardous Sites Branch
(IHSB) under identification number NCD 003195963. In addition to the name
Westinghouse, some regulatory agency file documentation for this Brownfields Property
may be referenced under the site or building name of Parker Lincoln.
Redevelopment Plans:
The Prospective Developer plans to redevelop the Brownfields Property by renovating
the current partially occupied building and then leasing the entire building to high value
tenants. At some time in the future, the Brownfields Property is planned to be
redeveloped for other non-residential purposes, which could involve demolition of the
existing building, and could include residential uses, the location of which may be
restricted, on the Brownfields Property.
Site History:
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The Brownfields Property has been developed since at least 1938 when it was used
mainly for agricultural purposes. The Brownfields Property was part of a larger
(approximately 100-acre) property which was sold by a group of individuals to
Westinghouse Electric Corporation (Westinghouse) in June 1952. The current building
was constructed in 1953 as an electronic meter manufacturing plant by Westinghouse.
Operations by Westinghouse entailed the assemblage of electric meters, including
degreasing and electroplating operations, and waste handling.
Westinghouse sold its operations to ABB Power T&D Co., Inc. (ABB) in 1989 and then
transferred the Brownfields Property to ABB on or about March 26, 1990. ABB sold the
Brownfields Property to Parker Raleigh Development XX Ltd Partners (Parker Raleigh)
in December of 1993. ABB continued similar manufacturing processes and operations at
the Brownfields Property as a tenant until 1996 when all manufacturing and plating at the
Brownfields Property were discontinued. ABB decommissioned its operations before
selling the Brownfields Property, which was then repurposed from industrial to
warehouse, office, logistics, and commercial uses.
Sometime during or soon after 1994, part of the building was converted to a
manufacturing space for Delta Consolidated Industries (Delta), which conducted plastic
injection molding operations at least until 2005. By 1996, Parker Raleigh also leased a
significant portion of the building to various North Carolina regulatory agencies,
including the North Carolina Department of Environment and Natural Resources
(predecessor to NCDEQ).
Raleigh Portfolio NW LLC acquired the Brownfields Property on January 18, 2006.
Known tenants since that time have included Delta, various North Carolina regulatory
agencies, NC State University, R&M Electronic Co., Savvis Inc., Great Escape
Millworks, Web -Don, Inc., Icore Reico, and Centurylink Technical Solutions.
The Brownfields Property is currently owned by the Prospective Developer, which
purchased the Brownfields Property on April 18, 2018 from Raleigh Portfolio NW LLC.
It is currently used for office, retail, light manufacturing and assembly, and warehouse
purposes and is occupied by six tenants: the North Carolina Education Lottery, Inventory
Management Incorporated, Reico Kitchen and Bath, Web -Don, Habitat for Humanity of
Wake County (Habitat) and Great Escape Millwork. The Prospective Developer also has
a ground lease with GTE Mobil Net for a cellular communications tower located on the
western portion of the Brownfields Property.
The Brownfields Property is regulated by the DEQ Inactive Hazardous Sites Branch
(IHSB) listing under identification number NCD 003195963. Environmental site
assessments date back to the 1980s, the documentation of which are included in more
recent Phase I environmental site assessments conducted at the Brownfields Property.
Recent environmental assessments, which included the collection of soil, groundwater,
sub -slab vapor, and indoor air samples, were conducted at the Westinghouse Site,
including the Brownfields Property, from 2009 to 2019.
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According to information in the Environmental Reports, in -ground concrete basins, a
drum storage area, at least one underground storage tank (UST), and an aboveground
storage tank (AST), which stored fuel for the former on -site boilers, were historically
present at the Brownfields Property. One 30,000-gallon UST which contained #6 fuel oil
and the AST were removed in the 1990s. Reportedly, samples collected beneath the UST
did not exhibit evidence of contamination, although no analytical data associated with
this reported sampling was readily available.
The electric meter manufacturing operation generated sludges from electroplating
wastewater treatment, degreasing still bottoms, waste solvents, paints and inks, and
precipitates from plating tanks. Wastes were stored in onsite drum storage areas and two
in -ground concrete basins located at the Brownfields Property directly south of the main
warehouse building. In addition, a waste treatment and sludge impoundment area was
located offsite to the southwest of the Brownfields Property on an abutting three -acre
parcel now owned by the City of Raleigh (PIN 1715812016). These wastes included
metals such as zinc, tin, nickel, and chromium, F-listed and D-listed compounds, and
cyanide. Westinghouse's waste treatment operations were cleaned up and
decommissioned, and on October 15, 1985, North Carolina officials approved the closure
of the drum storage area and the storage basins located at the Brownfields Property, as
well as the offsite waste treatment and sludge impoundment area.
Several releases were documented during this period, including the release of an
unknown quantity of tetrachloroethylene (PCE) in 1987 from at least one known tank
overfilling event, and low concentrations of metals and tetrachloroethylene (PCE) in the
former electroplating room, which were detected in soil after the electroplating room was
decommissioned. When the release was discovered, excavation work showed the spill
was contained to a small area and approximately 5.5 to 8.3 cubic yards of saturated soil
were excavated and reportedly disposed of offsite. The excavation was inspected by the
Department of Environment, Health, and Natural Resources (predecessor to DEQ) prior
to it being backfllled, although neither pre -excavation soil samples nor post -excavation
confirmatory soil samples appear to have been collected.
In 2005, a consultant conducting a Phase I environmental site assessment in the area of
the building operated by Delta noted leaking oil on the floor and a breached containment
berm. In April and May 2017, chlorinated solvents were detected in groundwater
monitoring wells installed at the Brownfields Property at the direction of the DEQ IHSB.
In October and December 2017, two rounds of vapor intrusion testing were conducted
inside the building at the Brownfields Property. PCE and trichloroethylene (TCE) were
detected in concentrations above DEQ non-residential vapor intrusion screening levels
(VISLs) in soil gas samples below the building floor slab. In the October 2017 sampling
event, indoor air samples collected from one location in the Web -Don office area located
at the back corner near Westinghouse Boulevard exhibited PCE and TCE concentrations
above DEQ non-residential VISLs. To address this indoor air quality issue, adjustments
were made to the building HVAC system to increase the fresh air makeup, and openings
in the concrete floor slab were sealed. Subsequent results of indoor air quality sampling
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conducted in this area have not exhibited indoor concentrations of PCE and TCE above
the non-residential VISLs.
To continue to monitor for PCE, TCE, and their degradation products in indoor air
resulting from vapor intrusion at the Brownfields Property, the Prospective Developer has
implemented an Indoor Air Quality Monitoring Program as outlined in the DEQ
Brownfields-approved Revised Indoor Air Quality Monitoring Work Plan, Parker
Lincoln Property (Mid Atlantic, October 4 2018). Indoor air quality testing was
conducted in November 2018, February 2019, and June 2019 in accordance with this
work plan.
One indoor air sample collected in the Great Escapes Millwork space in February 2019
and one sample collected in the Habitat space collected in June 2019 exhibited TCE at or
slightly above its nonresidential short-term action level for TCE of 8.8 µg/m3 according
to DEQ's Supplemental Vapor Intrusion Guidance — TCE Indoor Air Inhalation
Immediate Action Levels and Response (July 2019). On both occasions, supplemental
ventilation was provided and public health information was shared with the affected
tenants with follow-up with affected individuals as needed.
Follow up sampling conducted in March, July, and December 2019, and February 2020
indicated that TCE concentrations were reduced to below the nonresidential short-term
action level in those four sampling events. Additional monitoring for these chlorinated
solvent compounds is planned for August 2020 using the near -real-time analysis
approach detailed in the Mid -Atlantic Associates' July 2019 work plan and to be
performed by Hartman Environmental Geosciences to further evaluate the source of TCE
and other chlorinated solvents in indoor air.
Potential Receptors:
Potential receptors are: construction workers, on -site workers, future residents, visitors,
and trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property:
groundwater, sub -slab soil vapor, and indoor air. DEQ relies on the following data to
base its conclusions regarding the subject property and its suitability for its intended
reuse.
Soil
As mentioned above, in the latter part of 1987, a spill of PCE occurred on the
Brownfields Property. When the release was discovered, the spill was contained and
approximately 5.5 to 8.3 cubic yards of saturated soil were excavated and reportedly
disposed of offsite. The excavation was inspected by the Department of Environment,
Health, and Natural Resources (predecessor to DEQ) prior to it being backfilled, although
samples do not appear to have been collected.
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The Brownfields Property is currently either covered by asphalt pavement, the large
commercial building, or landscaped areas. Soil was not sampled for evaluation of this
Brownfields Agreement; potentially contaminated soil discovered during future
redevelopment activities will be addressed through a DEQ-approved Environmental
Management Plan (EMP) required by the Brownfields Agreement.
Groundwater
Groundwater sampling events that occurred at the Brownfields Property were either
during a one-time event in 2009, or have occurred during the time period 2015 — 2018.
No trend in contaminant concentrations can be discerned based on the distribution of data
among these time periods.
Groundwater impacts were discovered exterior to the building in two main areas. There
are no groundwater samples collected from below the building itself.
The first area identified is located at the southern back corner of the Brownfields Property
during investigations conducted in 2009-2010 when the City of Raleigh purchased the
southern portion of the Westinghouse Site. Wellpoints for the collection of groundwater
samples were advanced by a direct push rig. From those wellpoints, PCE was detected in
GP-45 and GP-47 at concentrations of up to 22 and 11 micrograms per liter (µg/L),
respectively, in excess of the NC 2L standard of 0.7 µg/L. TCE was detected in GP-45 at
1.3 µg/L, below the 2L standard of 3 µg/L.
The second area was identified in April and May 2017, when chlorinated solvents were
detected in groundwater monitoring wells installed near the northern back corner at the
Brownfields Property at the direction of the DEQ IHSB. PCE was detected in wells
MW-3S, MW-31), MW4S, and MW-41) with concentrations up to 17 and 186 µg/L in the
latter two wells, respectively. TCE was detected in MW-4S and MW-4D at
concentrations up to 3.6 µg/L and 160 µg/L.
Vinyl chloride was also detected in well MW-2D at an estimated value of 0.24J µg/L,
above its NC 2L standard of 0.03 µg/L. 1,2-Dichloroethane was detected in well MW-41)
in 2017 at a concentration of 1.16 µg/L, above its NC 2L standard of 0.4. µg/L.
Concentrations of TCE and PCE in wells GP-45S, GP-45I, MW-41), and MW-4S exceed
the residential vapor intrusion screening levels of 1.0 µg/L and 12 µg/L, respectively.
Surface Water
Surface water is not located on the Brownfields Property.
Soil Gas
Soil gas samples were not collected on the Brownfields Property as the focus was to
obtain sub -slab vapor samples below the existing building.
Sub -Slab Vapor
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A total of 25 sub -slab vapor sampling locations (SS-1 through SS-25) were installed and
sampled throughout the facility, four in the former office portion in the front of the
building and 21 in the former manufacturing portion of the building.
Concentrations of chloroform were detected in six sub -slab vapor samples ranging from
89.6 micrograms per cubic meter (µg/m3) to 653 µg/m3, which may be attributable to
leaks from water pipes, which routinely contain chloroform from the municipal
disinfection process. Significant concentrations of PCE and TCE were detected above
their respective residential vapor intrusion screening levels, and in some cases above their
respective industrial vapor intrusion screening levels. Exceedances of PCE were
observed in 20 sub -slab vapor samples, ranging in concentration from 425 µg/m3 to
49,500 µg/m3, with the highest concentration at sample location SS-3. Exceedances of
TCE were observed in eight sub -slab vapor samples, ranging in concentration from 22.8
µg/m3 to 1,520 µg/m3, with the highest concentration also at location SS-3.
Indoor Air
Indoor air sampling has occurred on multiple occasions from 2017 through 2020.
Twenty-four generally equivalent locations were sampled, either with Summa canisters
or with Radiello passive samplers, or both. Of the 14 indoor air locations sampled
throughout the building on November 16, 2017, 13 locations failed the residential indoor
air vapor intrusion screening level for TCE and six of those also failed the non-residential
indoor air vapor intrusion screening level for TCE.
The building use during the assessment process has been non-residential. When
exceedances of non-residential indoor air screening levels were exceeded, the Prospective
Developer took measures to mitigate the impact and then conduct follow-up sampling to
confirm the mitigation performed as desired. However, because the prospective
developer has stated a possible redevelopment of the Brownfields Property might include
residential use, residential screening levels were used for comparison purposes.
The highest level of contamination has generally occurred in the northern back portion of
the building, an area where a plating line and plating lab were believed to have been
operated. The primary indoor air contaminants of concern are PCE and TCE, although
other constituents such as benzene, carbon tetrachloride, cyclohexane, ethylbenzene,
heptane, hexane, toluene, and xylenes have also exceeded their respective residential
indoor air vapor intrusion screening levels at least once in the 2017 through 2020 indoor
air sampling events.
The concentrations of PCE in eight indoor air samples exceeded the residential vapor
intrusion screening level for PCE in indoor air of 8.3 µg/m3, and ranged from 8.5 µg/m3
to the maximum measured concentration of 309 µg/m3 in indoor air sample IA-103
collected in November 2017; however, the concentration measured in a sample collected
from the IA-103 location in February 2020 had declined to 32 µg/m3, still in excess of the
residential vapor intrusion screening level.
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The concentrations of TCE in 17 indoor air samples exceeded the residential vapor
intrusion screening level for TCE in indoor air of 0.42 µg/m3, and ranged from 0.77
µg/m3 to the maximum measured concentration of 14 µg/m3 in indoor air sample IA-107
collected in February 2019; however, the concentration measured in a sample collected
from the IA-107 location in February 2020 had declined to below a detection limit of
0.29 µg/m3.
The concentrations of all indoor air contaminants in all 12 indoor air samples collected
during the most recent round of indoor air sampling occurring in June 2020 using
Radiello passive samplers were below their respective residential and non-residential
indoor air screening levels. PCE was the only contaminant detected and it was present in
five of the 12 indoor air sampling locations with concentrations ranging from 2.9 — 6.1
µg/m3, all of which were below the residential indoor air vapor intrusion screening level
of 8.3 µg/m3 .
Risk Calculations
Risk calculations were performed using the December 2019 DEQ Risk Calculator
https:Hdeq.nc. gov/pennits-rules/risk-based-remediation/risk-evaluation-resources.
For the purposes of looking at the site spatially, the site was evaluated as a whole.
The risk calculations indicated the following based on available data, including the
following media: groundwater, sub -slab soil vapor, and indoor air. Data used in the risk
calculations were maximum levels for groundwater and sub -slab soil vapor, and the
February 2020 data for indoor air. Subsequent indoor air data received in July 2020 show
only PCE is present in indoor air.
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Risk for Individual Pathways
Version Date: December 2019
Basis: November 2019 EPA RSL Table
Site ID: 22018-18-092
Exposure Unit ID: Entire site
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazardlndex
Risk exceeded?
Resident
Soil
NC
NC
NC
Groundwater Use*
3.5E-04
6.1E+01
YES
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
6.0E-05
1.4E+01
YES
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil _ �7 ________
Surface Water*
NC
NC
NC
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
1.5E-04
3.4E+01
YES
Soil Gas to Indoor Air
3.0E-04
5.8E+01
YES
Indoor Air
5.0E-06
1.2E+00
YES
Non -Residential Worker
Groundwater to Indoor Air
2.5E-05
8.1E+00
YES
Soil Gas to Indoor Air
2.0E-05
4.6E+00
YES
Indoor Air
1.0E-06
3.0E-01
NO
The risk calculations for this Brownfields Property indicate that while the carcinogenic
risk for both residential indoor air and nonresidential worker exposure pathways are
within an acceptable range, the calculated noncancer hazard index for indoor air for the
residential exposure pathway is sufficiently high (HI=1.2) to be considered an
unacceptable risk for residential use of the existing building as well as sufficiently high as
to require vapor mitigation practices on potential future new residential buildings within
or near the footprint of the existing building.
The calculated carcinogenic risk level for soil gas to indoor air exposure pathway in
residential scenarios and the calculated noncancer hazard index exceed an acceptable
carcinogenic risk range and exceed the hazard index threshold value of 1. For
nonresidential worker scenarios, only the noncancer hazard index of 4.6 exceeds the
threshold value of 1 while the carcinogenic risk is within an acceptable risk range.
Therefore, the existing building is considered a potential vapor intrusion risk for
nonresidential uses and warrants continued indoor air sampling to evaluate risk from
potential indoor air contaminants.
The calculated carcinogenic and noncancer risk values for groundwater contamination for
residential scenarios exceeds an acceptable carcinogenic risk range and exceeds the
noncancer hazard index threshold value of 1. For nonresidential groundwater water use,
only the noncancer hazard index threshold value of 1 is exceeded.
No soil sample data was available, so risk associated with contact of soil could not be
calculated. To accommodate this unknown, but likely risk of exposure to soil
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contaminants with redevelopment at the Brownfields Property, soil disturbance is
prohibited unless under a DEQ-approved EMP that will be required as part of the
Brownfields Agreement.
Required Land Use Restrictions:
The land use restrictions (LURs) will include those standard provisions related to the
following: anticipated land uses and their definitions which only allow for townhome
development with DEQ approval should townhomes be proposed in the future, daycares,
requirement for an Environmental Management Plan and redevelopment report,
groundwater use, soil disturbance, final grade sampling, access for environmental work,
vapor mitigation, prohibition on use of products with known contaminants, repair of
damaged monitoring wells, and LUR update obligation.
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.
PROPERTY MANAGEMENT ISSUES
PMU issues could evolve after Hartman Environmental indoor air monitoring is
completed. This includes the possibility of continued indoor air monitoring.
Per the EMP, any slab breech must be preapproved by DEQ. (Remove this parenthetical
after EMP is revised — on 7.31.2020 BIN and WBA spoke with MKS regarding potential
breeches of the slab. The decision was made to revise the EMP to require any slab
breeches to be preapproved by NCBP.)
Provisions to ventilate and monitor the indoor air must be undertaken if the slab is ever
breeched.
Valuable graphics:
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11
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Above: Soil gas and sub -slab vapor exceedances for non-residential (red) and residential
(orange) based on multiple sampling events. From AECOM Conceptual Site Model
9.5.2019
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Above: Black dashed outline of a believed former plating line and plating lab in the
northern back portion of the building based on old blueprints of building. Hand drawing
is by Mid -Atlantic Associates and is not included in any report.
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