18060_Decision Memorandum - Cooper Bussmann - Final

DECISION MEMORANDUM

DATE: August 10, 2018

FROM: Brad Atkinson

TO: BF Project Files

RE: Cooper Bussmann
210 Dixie Trail
Goldsboro, Wayne Co.
BF # 18060

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, institutional, parking and
with prior written approval from DEQ, other commercial uses, can be made suitable for such uses.

Introduction:
The Brownfields Property comprises one parcel (Wayne County Tax Parcel Identification Number 2598668317) totaling 7.73 acres with approximately 78,715 sq. ft. of manufacturing and related
office space in a steel building. Business operation ceased in December 2014 and the property has remained vacant since.

Redevelopment Plans:
The Prospective Developer is the Wayne County Development Alliance, Inc., (WCDA) a non-profit corporation formed to lead economic development initiatives for Wayne County, purchased
the Brownfields Property on January 25, 2015. WCDA has the building listed for sale and is seeking an industrial or commercial entity to occupy the space.

Site History:
The Brownfields Property was used as agricultural land before it was developed in 1973 when a metal building was constructed on the northeast portion of the site for McGraw Edison.
The building structure was expanded twice prior to 1993, by which it took on its current configuration. The only known use of the Brownfields Property has been for the manufacture
of electronic equipment and electronic components (fuse holders and breakers), which included the use of injection molding.

Historical information indicates that a company known as Sycor, Inc. maintained the address of the Brownfields Property by 1977, but that Bussman Division, Cooper Industries (later Cooper
Bussman, Inc. and Cooper Industries) took over operations from McGraw-Edison via merger by 1986. Operations at the Brownfields Property ceased in December of 2014.

Cooper Bussman LLC (US EPA ID NCD982137101) was a conditionally exempt small quantity generator from October 28, 1998 until October 31, 2012. Cooper Bussmann produced the following
wastes associated with their manufacturing operations at the Brownfields Property: D001 (Ignitable Hazardous Waste); D002 (Corrosive Hazardous Waste, pH<2); D006 (Cadmium); D008 (Lead);
D011 (Silver); F003 & F005 (Spent No-Halogenated Solvents).

Cooper Bussmann also maintained an Air Permit (Permit #05040R07) issued 11/28/2012 by the North Carolina Division of Environmental and Natural Resources (NCDENR) Division of Air Quality
and a Stormwater No Exposure Exclusion Certification (Permit # NCGNE0033) issued 8/14/2012 by NCDER Division of Water Quality.

An approximate 900-gallon concrete pit, used as temporary holding structure for waste oil, is located on the west exterior side of the main building. The pit received waste propylene
glycol-hydraulic oil mix via concrete trenches from within the building. Use of the pit ended by the end of June 2014. After June 2014 and prior to June 9, 2017, the pit was filled
with concrete and rendered unuseable.

Trichloroethylene (TCE) was used and stored at the site in small quantities. Virgin TCE was stored in five-gallon buckets in a flammable storage cabinet. TCE was not stored in tanks
or used for degreasing operations (no tanks or parts washers were used onsite). TCE was used to clean 0.5-inch diameter by 0.5-inch tall metal caps used to cover connections for electrical
fuses. The soldering process included the use of a resin-based flux, which needed to be cleaned before the caps could be placed on the fuses. The process included pouring approximately
one pint of TCE and grounded corn cob or walnut shells (tumbling media) into a small cement mixer. The TCE/tumbling action would remove the resin. TCE evaporated during the mixing process
and the caps were cleaned in batches. TCLP testing on the used tumbling media was below EPA hazardous levels which was then transported to and disposed of in accordance with local,
state and federal regulations. TCE was also reportedly used sporadically to remove bottle fuse labels. TCE was used from approximately 1990 to the mid-1990s. The facility converted
to a citrus-based cleaner when the fuse line moved to Juarez, Mexico in 2009. No TCE was detected in the soil or groundwater samples collected at the Brownfields Property.

Cooper Bussmann (NONCD0002598) entered into the Inactive Hazardous Sites Branch (IHSB) Registered Environmental Consultant (REC) Program on August 12, 2014. As requested by the REC
Program, a round of soil and groundwater assessment was conducted in two separate events on July 14-15, 2014 and November 25, 2014 at the Brownfields Property. There were no detections
above Industrial/Commercial PSRGs in soil or above the NCAC 2L Standards in groundwater. Phenanthrene was detected in soil, but the contaminant does not have an established screening
level.

On March 6, 2015, the IHSB issued a No Further Action (NFA) letter to Cooper Bussmann and the site was transferred onto IHSB’s NFA category of sites.

Potential Receptors:

Potential receptors are construction workers, on-site workers, visitors, and trespassers.

Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil and groundwater. DEQ relies on the following data to base its conclusions regarding the subject
property and its suitability for its intended reuse.

Soil
Soil contamination in excess of the DWM Industrial/Commercial PSRGs exists on the Brownfields Property in the concentrations detailed in the table below, but this is limited to detections
of polynuclear aromatic hydrocarbons (PAHs) in shallow soil in one boring, B-8.

Groundwater
Groundwater data from the most recent sampling event that was conducted on November 25, 2014 did not exceed NC 2L Standards for VOCs, SVOCs, and RCRA metals. Three compounds (ethylene
glycol, bis(2-ethyl hexyl) phthalate, and di-butyl phthalate) were detected in the November 25, 2014 groundwater sampling event below their respective NC 2L standard. However, these
compounds are not volatile and therefore do not pose a risk of vapor intrusion.

Surface Water
Surface water is not located on the site.

Soil Vapor
No soil vapor samples were collected because VOCs were not detected in soil and groundwater samples.

Sub-Slab Vapor
No sub-slab soil vapor samples were collected because VOCs were not detected in soil and groundwater samples collected from near the building slab.

Indoor Air
No indoor air samples were collected because VOCs were not detected in soil and groundwater samples collected from near the building slab.

Risk Calculations
Risk Calculations were performed using the DWM Risk Calculator (February 2018 version). The site was not divided into separate special units for evaluation due to the relatively small
size of the site. The risk calculations were made using the maximum values for each contaminant from the most recent sampling event for each location. The risk calculations indicated
the following based on available soil and groundwater data:

/
Red shading LICR> 1E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index

Required Land Use Restrictions:
Land use restrictions will include the standard Environmental Management Plan, groundwater, soil disturbance, monitoring well abandonment / replacement, and known contaminants LURs.

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.