23081_Kroehler Manufacturing Decision Memorandum 20210214

DECISION MEMORANDUM DATE: February 14, 2021 FROM: Bill Schmithorst

TO: BF Assessment File RE: Kroehler Manufacturing 3412 Monroe Road
Charlotte, Mecklenburg County
BF # 23081-19-060 Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than high density residential, retail, office,
parking, warehousing and with prior written DEQ approval, other commercial uses, can
be made suitable for such uses. Introduction: The Brownfields Property is comprised of one parcel totaling approximately 6.55 acres
that is developed with an approximately 121,238 square foot industrial warehouse. The
building is currently occupied by Party Reflections for storing, cleaning, and transporting party rental supplies and equipment. The Brownfields Property is located in a mixed commercial, industrial and residential area bordered to the north by Technocom Business Systems, Monroe Road, followed by single-family residences and commercial buildings;
to the east by Penske Truck Rental, to the west by Atlantic Sweetener and a Norfolk
Southern Railway line; to the south by Norfolk Southern Railway followed by Henderson Properties corporate office. Redevelopment Plans:
The Prospective Developer intends to redevelop the property for potential high density
residential, retail, office, parking, warehousing and commercial uses. Site History: Prior to 1950, the Brownfields Property consisted of agricultural land. In 1950, the
original building was constructed and occupied by Kroehler Manufacturing, a furniture
manufacturing company. In the mid-late 1950s, the building was expanded on the southern portion of the building and a partial basement was developed. Kroehler Manufacturing occupied the Site until 1985. Greenline Corporation then purchased the Brownfields Property and assembled and manufactured conveyor parts within the site
building. For a period of time, Greenline Corporation continued operations and rented
portions of the site building to additional tenants who used the building as storage space. Since approximately 2004, Party Reflections has occupied the Brownfields Property for its party rental supplies and equipment.
Based on historical records summarized in the October 7, 2019 Phase I and II report, four
underground storage tanks (USTs) were removed from the Brownfields Property in November 1992. One 12,500-gallon #2 fuel oil UST, one 6,000-gallon gasoline UST, and one 3,000-gallon gasoline UST were removed from an area near the southern side of the building and adjacent to a loading dock and one 10,000-gallon UST was removed from
an area northwest of the building. Following removal, petroleum-impacted soil was
identified below the former 6,000 gallon UST and approximately 101 tons of soil were removed. Closure samples indicated no detectable concentrations of total petroleum hydrocarbons. The NCDEQ UST Section issued a No Further Action Letter for the UST incident on June 9, 1995. A NCDEQ UST incident number was not provided in copies of
the available communications.

Environmental Assessments A Phase II site assessment was conducted at the Brownfields Property on September 12
and 13, 2019 for property due diligence purposes. Assessment activities included
collecting soil samples from four (4) soil borings in the basement of the Brownfields Property building adjacent to three floor drains (SB-4 through SB-6) and the hydraulic freight elevator (SB-3), and two soil borings outside of the building; one downgradient of the building to the northwest (SB-1) and one at the former drum storage building/sump
(SB-2). The soil samples adjacent to the floor drains (SB-4 through SB-6) were collected
at a depth of 2 to 4 ft bgs, and the soil sample located adjacent to the freight elevator (SB-3) was collected at a depth of 10-12 ft bgs. The exterior soil samples (SB-1 and SB-2) were collected at a depth of 0-2 ft bgs. Soil samples were submitted to a laboratory for the analysis of volatile organic compounds (VOCs) and semi-volatile organic compounds
(SVOCs). One soil sample (SB -3) collected adjacent to the freight elevator was analyzed
for PCBs. In addition, two soil samples (SB-1 and SB-2) collected from the temporary monitoring well borings were also analyzed for Resource Conservation and Recovery Act (RCRA) Metals. Two shallow temporary groundwater monitoring wells (TMW-1 and TMW-2) were installed; however, TMW-1 was dry upon sampling and only TMW-2 was
sampled. The groundwater sample was submitted for the analysis of VOCs and SVOCs.
Laboratory results from the September 2019 assessment indicated that arsenic was the only constituent detected above Residential Preliminary Soil Remediation Goals (PSRGs). Both VOCs and SVOCs were detected in groundwater above NC 2L
Groundwater Standards.
A sub-slab soil vapor assessment was conducted in December 2019. As reported in Vapor Intrusion Assessment Report (February 17, 2020), four sub-slab soil vapor samples were collected beneath the existing building and submitted to a laboratory for the analysis of
VOCs by Method TO-15. As part of the assessment, both sub-slab soil vapor and radon,
along with indoor air radon samples were collected. Analysis of the radon results indicated an attenuation factor between sub-slab and indoor air radon samples ranging from 0.00109 to 0.00024.
In June 2020, additional soil and groundwater samples were collected at the Brownfields
Property, in accordance with a DEQ approved work plan, to fill in data gaps remaining from previous assessment activities. Environmental assessment activities included soil sampling to evaluate the potential for impacts near on-site rail spurs, and groundwater sampling to evaluate subsurface conditions in areas upgradient and downgradient of the
Brownfields Property building. Laboratory analytical results did not indicate the presence
of VOCs or SVOCs at concentrations above the DEQ IHSB Residential or Industrial/Commercial PSRGs in soil samples collected in the area of on-site rail spur corridors. Arsenic was detected at a concentration above the DEQ IHSB Residential and Industrial/Commercial PSRG in the composite soil sample collected near the active rail
spur along the western and southwestern boundaries. Laboratory analytical results did not
indicate the presence of VOCs or SVOCs at concentrations above the DEQ 2L Groundwater Quality Standards in Brownfields assessment groundwater samples collected at the Site. However, TCE was detected in groundwater sample TMW-4 collected downgradient and west of the site building at a concentration slightly exceeding
the DEQ DWM Residential Vapor Intrusion GWSL, but below the Non-Residential
GWSL. No other compounds were detected at concentrations above the DEQ DWM Vapor Intrusion GWSLs in Brownfields assessment groundwater samples collected at the Brownfields Property.
Potential Receptors:
Potential receptors are: construction workers, on-site workers, future residences, visitors, and trespassers. A receptor survey was completed in June 2020. No sensitive receptors were identified. The area is served by municipal water and sewer. Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: groundwater, soil and sub-slab soil vapor. DEQ relies on the following data to base its conclusions regarding the subject property and its suitability for its intended reuse. Soil
Laboratory results from September 2019 indicate that benzo(a)pyrene was detected above NC Residential PSRGs in a soil sample collected beneath the basement (SB-5). In addition, arsenic was detected in soil samples SB-1 (2.55 mg/kg) and SB-2 (1.10 mg/kg) at concentrations consistent with observed regional naturally occurring arsenic levels. No releases of materials containing arsenic have been reported at the Brownfields Property.

Groundwater Laboratory results from September 2019 for samples collected from temporary monitoring well TMW-2 indicated that 1,1-dichloroethane (40.4 μg/L), benzene (1.9 μg/L), and naphthalene (26.7 μg/L) were detected above NC 2L Groundwater Standards.
However, the VOCs did not exceed DEQ DWM Residential Vapor Intrusion GWSL. Laboratory results from June 2020 indicate that TCE (1.7 μg/L) was detected in groundwater sample TMW-4 located downgradient and west of the Brownfields Property
building at a concentration slightly exceeding the DEQ DWM Residential Vapor
Intrusion GWSL of 1.0 μg/L, but below the Non-Residential GWSL of 4.4 μg/L.
Surface Water Surface water is not present.

Soil Vapor Soil vapor was not sampled. Sub-Slab Vapor
Laboratory results from three sub-slab soil vapor samples collected in December 2019
indicated that several VOC compounds were detected above laboratory method detection limits; however, no VOC compounds were detected at a concentration exceeding NC Residential Vapor Intrusion Screening Levels.
Indoor Air
No indoor air samples were collected for the analysis of VOCs.
Risk Calculations Risk calculations were performed using the NC DEQ Risk Calculator. Sample results
from the samples with the highest concentrations of contaminants detected in
groundwater and soil were used for evaluating risk at the Brownfields Property, including SB-2 for soil and TMW-4 for groundwater. In addition, the highest concentrations of each detected compound from all three sub-slab soil vapor samples (SSV-1, SSV-2 and SSV-3) were used for evaluating soil vapor risk. The risk calculations indicated the
following based on available data, including the following media: groundwater, residual
soil, and sub-slab soil vapor samples:
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Resident Soil 1.7E-05 1.7E-01 NO
Groundwater Use 2.6E-05 6.7E-01 NO
Non-Residential Worker
Soil 1.4E-06 1.9E-02 NO
Groundwater Use 5.7E-06 1.5E-01 NO
Construction Worker Soil 2.1E-07 1.0E-01 NO
Recreator/Trespasser Soil 9.0E-06 7.4E-02 NO

VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Resident
Groundwater to Indoor Air 7.5E-06 3.4E-01 NO
Soil Gas to Indoor Air 1.1E-05 2.7E-01 NO
Non-Residential
Worker
Groundwater to
Indoor Air 1.6E-06 8.2E-02 NO
Soil Gas to Indoor Air 8.5E-07 2.1E-02 NO
Red shading LICR> 1E-04 or HI> 1. LICR = Lifetime Incremental Cancer Risk HI = Hazard Index Risk Calculator results indicate that the LICR and HI for environmental media sampled was not exceeded for Residential or Commercial/Industrial uses.

An Environmental Management Plan (EMP), approved by DEQ, will be required before the start of soil grading or excavation activities to prevent exposure to site workers and future residents from potential unacceptable levels of contaminants, and to manage the safe handling and disposal of potentially contaminated materials during construction.
Additional soil gas assessment may be required if the property is developed for
residential use. Required Land Use Restrictions:
A summary of the land use restrictions (LURs) is provided below.
1. No use other than high density residential, retail, office, recreational, parking, open space, and with prior written DEQ approval, other commercial 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 must be approved by DEQ. 5. DEQ approved EMP 6. Access to Brownfields Property for environmental assessment.
7. Standard vapor intrusion LUR
8. No child care or adult care centers. 9. NBP reference in deed. 10. No contaminants (as included in Ex. 2 to the BFA) on property except for de minimis amounts, fluid in vehicles, fuels for generators/equipment.
11. Final grade soil sampling for RCRA metals, SVOCs, and VOCs will be conducted in
exposed areas. 12. LURU submission January 1st
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.