16037_Liberty Fabrics_DM_20180522

DECISION MEMORANDUM
DATE: May 22, 2018
FROM: Sharon Poissant Eckard, PG
TO: BF Assessment File
RE: Liberty Fabrics
28333 US Highway 64
Jamesville, Martin County
BF # 16037-12-059
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than industrial, including the manufacture of
fixtures and display items for the retail industry, warehousing of these goods, office,
associated parking, and with DEQ approval, other commercial uses, can be made suitable
for such uses.
Introduction:
The Brownfields Property comprises one tax parcel (0101844) totaling about 39.5 acres
and is developed with a single -story metal -framed building totaling about 107,000 square
feet in area, an inactive, partially decommissioned wastewater treatment system, and
other ancillary buildings. The Brownfields Property is bordered to the north by the
Roanoke River; to the east by a partially wooded undeveloped or agricultural lot with
what appears to be an agricultural pond; to the south by US Highway 64 with wooded or
agricultural land beyond; and to the west by partially wooded vacant lots along Robin
Lane and a Citgo Mini -Mart and Grill on US Highway 64. A stream transects the
western area of the Brownfields Property and flows north toward the Roanoke River.
Redevelopment Plans:
The Prospective Developer, Carolina Store Fixtures, LLC, purchased the Brownfields
Property in November 2012, and has been operating there since that time, assembling
wooden display fixtures. The PD has renovated certain buildings for its use, but does not
have plans to demolish buildings and construct new structures at this time. There are two
water supply wells remaining at the Brownfields Property and the PD operates one of
them once a year to fill the onsite 300,000-gallon AST for fire suppression purposes.
Site History:
The Brownfields Property was used for agricultural purposes until 1972 when it was
developed by Coats & Clark Inc. for textile -related operations, primarily the manufacture
of zipper tape and zippers. The Brownfields Property was sold to Penn Elastic Company
on September 2, 1981, which added a dye house and operated the site until a corporate
merger with Liberty Fabrics took place in 1989. Penn Elastic Company granted the
Brownfields Property to Liberty Fabrics, Inc. on March 31, 1989. Liberty Fabrics

continued operations there until sometime in 2001. Elastic products, zippers and zipper
tape were produced at the Brownfields Property over this time period.
On December 27, 2001, Liberty Fabrics sold the Brownfields Property to McMurray Real
Estate Holdings, and from 2001 to about 2005-2006, McMurray Knit Fabrics operated
the facility for warp knitting operations. The Martin County Economic Development
Corporation acquired the Brownfields Property July 17, 2006 through a Deed of Gift
from McMurray Real Estate Holdings. The site laid idle from 2005 until November 19,
2012, when the Prospective Developer, Carolina Store Fixtures, LLC, purchased the
Brownfields Property for the assembly of display fixtures for the retail industry.
Past owner/operators stored No. 2 fuel oil and waste oil in several above ground storage
tanks (ASTs). There are no known underground storage tanks (USTs) at the facility.
A wastewater treatment system was constructed in 1978 and included two large concrete -
lined impoundments (a digester and an aeration basin), reportedly 12 feet deep, and a
clarifier, reportedly 17 feet deep. The wastewater treatment system accepted waste from
the interior floor drains routed from the manufacturing areas. Treated process wastewater
effluent was discharged to the Roanoke River via a PVC discharge line under a NPDES
permit (No. NC0023710). Empty drums were washed out and stored in a secondary
containment area immediately southeast of the impoundments. The clarifier has been
removed and the ponds are inactive, but are collecting rainwater; there appears to be
debris of some kind in the western pond. The DEQ Division of Water Resources (DWR)
was contacted regarding the wastewater treatment pond system's regulatory status and
DWR indicated that they have no further requirements for pond closure for the property
owner at this time.
Two production water supply wells (PW-01 & PW-02) are located onsite and are
screened in the Castle Hayne aquifer to depths of 160 and 151 feet below ground surface,
respectively. Approximately 250,000 to 275,000 gallons of water were used daily in the
production process. A 300,000 gallon above ground storage tank (AST) stored the water:
the PD continues to pump at least one of the water supply wells periodically to maintain a
store of fire suppression water in this AST. The production wells were sampled in 2013
for VOCs and SVOCs; none were detected in these water samples above laboratory
reporting limits. Potable water is supplied separately by the Town of Jamesville.
A receptor survey conducted in 2002 indicated that there may be private water supply
wells located to the west and to the south of the Liberty Fabrics plant site; a follow-up
Brownfields receptor survey indicated that there are indications of two private water
supply wells located west of the site and two located south of the site across the highway.
The wells to the west could not be field -verified due to no trepassing signs along a private
road. It is unlikely that these wells are impacted from site groundwater as the onsite
water supply wells is not itself impacted.
A private grave site is located just north of the northeast area of the plant site; however,
there are reportedly no headstones present to determine the age of the plots.
N

An unnamed stream that flows northward toward the Roanoke River is located on the
western portion of the Brownfields Property; reportedly, this stream received septic waste
discharge from the plant in the 1970s prior to the connection to the sanitary sewer system,
but since then only receives surface water drainage from the plant site.
There are three separate oil releases from the heat exchange system are regulated by the
DWM Washington Regional Office UST Section. The first (Incident No. 88335)
occurred on October 24, 1984 under the operations of Penn Elastics, when a fire at the
plant's boiler room resulted in an oil release that migrated up to 200 yards away from the
boiler room through a drainage ditch. Actions to remediate this spill are not well
documented. The second release (Incident No. 87402) occurred in 1997 from the same
boiler system when the facility was operated by Liberty Fabrics. The third release
(Incident No. 87758) occurred in 2005 while the site was operated by McMurray Fabrics
and was cleaned up and closed out. About 25 tons of soil from the site was excavated
from the site in February 2002, although the location is not clear. Impacted soil was
disposed of at the G&S Land Company Landfarm in Williamston, NC (NCDENR Permit
No. SR0700121).
The discovery of a release of tetrachloroethene (PCE) in groundwater at the site in
December 2001 (Incident No. 86132) triggered a Notice of Violation (NOV) that was
issued by the Groundwater Section of the North Carolina Department of Environment
and Natural Resources (predecessor agency to DEQ) on March 11, 2002. The NOV
prompted the performance of a Comprehensive Site Assessment (CSA) in April 2002,
followed by quarterly groundwater monitoring from 2002 through 2005 and semi-annual
monitoring thereafter through 2010.
A NOV was issued by the Division of Water Quality, Aquifer Protection Section
(Incident No. 87758) on May 12, 2006 related to an incident where heat transfer oil
sprayed from an AST north of the boiler room onto the ground and surrounding structures
on June 26, 2005. This release occurred in an area where a known release of about 100
gallons of oil from the boiler room occurred on July 13, 1997. This resulted in the
excavation and offsite disposal of approximately 24 tons of contaminated soil from
within the area between the boiler room and the wastewater impoundments on September
20-21, 2005, and the placement of clean backfill material in the excavation. In
correspondence to Sara Lee Brands, the DEQ UST Section, Washington Regional Office
issued a No Further Action (NFA) letter for Incident No. 87758 on March 16, 2018.
A Notice of Regulatory Requirements for Contaminant Assessment and Cleanup (NORR)
was issued by the DENR (DEQ predecessor agency), Division of Waste Management
(Groundwater Incident No. 86132) to a number of potential responsible parties on
November 29, 2010 for initial abatement actions, assessment and remediation of the
Brownfields Property.
A Request to Prepare a Site Assessment Report (SAR) was issued by DENR, DWM on
April 26, 2010 assess the Liberty Fabrics site due to its priority ranking from the PCE and
1, 1 -dichloroethene (1,1-DCE) concentrations in groundwater. A NORR was issued by

DENR DWM on November 29, 2010 for Incident No. 86132 indicating that the site could
be cleaned up through the Registered Environmental Consultant (REC) Program.
Sub -slab vapor contaminant concentrations, particularly tetrachloroethylene (PCE), led to
the pilot testing, installation and start-up of a vapor intrusion mitigation system (VIMS)
at the facility in 2016. Reportedly, the VIMS has been operational nearly continuously
since November 2016. On -site personnel have conducted the monthly and semi-annual
inspections of the system. Mid -Atlantic Associates personnel performed an inspection,
which included the collection of vacuum measurements at 12 monitoring points on
January 3, 2018.
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,
groundwater, and sub -slab vapor. DEQ relies on the following data to base its
conclusions regarding the subject property and its suitability for its intended reuse.
Soil
Petroleum hydrocarbon releases to the ground near the boiler room were addressed
through excavation; confirmatory soil sampling indicates that residual soil impact is less
than DWM screening levels or UST Section action levels.
One area toward the rear of the Brownfields Property was found to have detections of
arsenic and polynuclear aromatic hydrocarbons (PAHs) above their respective non-
residential screening levels.
Groundwater
Groundwater is contaminated primarily with the chlorinated solvents tetrachloroethene,
(PCE), and trichloroethene (TCE), with historically lower concentrations of cis-1,2-
dichloroethene, methylene chloride, naphthalene, and bis(2-ethylhexyl) phthalate.
Contaminants appear to be localized within the proximity of wells MW-0I and TMW-1,
and have shown evidence of a trend of decreasing concentrations since first discovered in
2001/2002; certain contaminants have reduced to non -detectable concentrations or
concentrations that are below NC 2L or VISL concentrations. PCE concentrations range
up to 31 µg/L in well MW-0I in 2006 and to 23 µg/L in TMW-1 in 2013. Certain wells
show a reduction in contaminants since the site was originally assessed in 2001, e.g.,
MW-0I samples indicate that PCE concentrations were reduced to 7.4 µg/L from a
maximum of 31 µg/L. Similarly, TCE concentrations in MW-01 reduced from a
maximum value of 10 µg/L in 2006 to 1.9 µg/L in 2013.
Surface Water
Surface water is located along the western edge of the site in a creek, which flows
northward toward the Roanoke River. It has not been sampled as groundwater wells
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between the creek and the plant site were not found to be contaminated with chlorinated
solvents nor petroleum hydrocarbons.
A drainage ditch immediate north of the plant site was sampled and was not found to
contain chemicals of concern above laboratory reporting limits.
Soil Vapor
Soil vapor samples have not been collected at the site. Instead sub -slab vapor samples
were originally collected in 2013, the results of which initiated the design and installation
of a sub -slab vapor mitigation system at the Brownfields Property to mitigate the
concentrations of PCE and TCE below the slab.
Sub -Slab Vapor
Sub -slab vapor samples were collected on September 10, 2013. Concentrations of PCE
(up to 15,000 µg/m3) and TCE (up to 480 µg/m3) exceed their respective DWM non-
residential screening levels of 3,500 µg/m3 and 180 µg/m3, respectively. The sub -slab
vapor impacts are limited to the area around sub -slab vapor sample VI-1. These results
prompted the initiation of the design and installation of a sub -slab vapor mitigation
system at the Brownfields Property. The recent risk calculations confirm that this was an
appropriate action.
Post-VIMS installation sub -slab vapor samples were collected in April 2018 from vapor
points MP-2, -4, -10 and -11, which are more distant from the area of contaminated
soil/groundwater and are believed to be outside the zone of influence for the current
VIMS configuration. TCE was not detected in these sub -slab vapor samples. PCE was
detected at concentrations ranging from 1.8 µg/m3 to 43 µg/m3, which are orders of
magnitude below the non-residential vapor intrusion screening level (VISL) for PCE of
3,500 µg/m3. Hence, it was determined that additional modifications to the VIMS were
not needed as contaminants in sub -slab vapor did not exceed non-residential VISLs.
Indoor Air
Indoor air samples were collected at the Brownfields Property using Radiello samplers
from March 27 through April 3, 2018. Vapor mitigation performance data have
demonstrated that the key parameters of PCE and TCE were not detected above reporting
limits in these samples.
Vapor Intrusion Mitigation S
ystem Performance
A subslab vapor intrusion system was installed at the Brownfields Property in 2016.
Performance data collected in 2018, including vacuum measurements, sub -slab vapor and
indoor air sampling, indicated that the VIMS is meeting performance objectives within
the zone of influence of the system, i.e., within the area impacted by the contaminant
release.
Risk Calculations
Risk Calculations were performed using Excel worksheets (October 2017 version)
provided by Sandy Mort, NCDEQ Brownfields Toxicologist. For the purposes of looking
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at the site spatially, site -wide data collected in 2013 was used although elevated
concentrations of chlorinated solvents in groundwater and sub -slab vapor are localized
around MW-01. The risk calculations indicated the following based on available data,
including the following media: groundwater, residual soil (based on confirmatory soil
data), and sub -slab vapor data:
Summary of Risk Assessment Output n
Version Date: October 2017
Basis: June 2017 EPA RSL Table
Site ID: 16037-12-059
Exposure Unit ID: PCE Release
PRIMARY CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Soil Combined Pathways
1.7E-04
9.1E-01
YES
Groundwater Combined Pathways*
4.0E-05
4.7E+00
YES
Non -Residential Worker
Soil Combined Pathways
1.0E-05
7.4E-02
NO
Groundwater Combined Pathways*
8.6E-06
9.3E-01
NO
Construction Worker
Soil Combined Pathways
5.8E-07
1.7E-01
NO
User Defined
------- Soil Combined Pathways
Surface Water Combined Pathways*
- 9.3E-05
0.0E+00
5.0E-01
0.0E+00
YYY NO
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
6.8E-06
1.6E+00
YES
Soil Gas to Indoor Air
9.8E-05
1.9E+01
YES
Indoor Air
0.0E+00
0.0E+00
NO e
Non -Residential Worker
Groundwater to Indoor Air
1.3E-06
3.8E-01
NO
Soil Gas to Indoor Air
6.8E-06
1.5E+00
YES
Indoor Air
0.0E+00
I 0.0E+00
NO
Red shading LICR> 1 E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index
From these risk calculations, which were run on data collected in 2013 before the on -site
VIMS was installed, soil, groundwater, groundwater to indoor air, and soil gas to indoor
air exposure pathways for residential scenarios exceed either the non -cancer hazard index
of 1, or both an acceptable carcinogenic risk range and the hazard index of 1. Residential
use of the Brownflelds Property will be prohibited.
The soil gas to indoor air exposure pathway for non-residential workers also exceeds the
hazard index of 1. Vapor mitigation was deemed appropriate to mitigate this risk and was
installed at the Brownfields Property in 2016. A VIMS has been operating there since
November 2016. Performance data collected in early 2018 indicated that the VIMS is
functioning according to plan in those areas where a zone of influence can be obtained.
Eastern monitoring points (MP-2, -4, -10, and -11) indicate that these points are outside
the zone of influence of the VIMS, but sub -slab data collected from these points indicates
that PCE and TCE are either far below its non-residential VISL, or are not detected above
a reporting limit that is far below the non-residential VISL, respectively.
no

Required Land Use Restrictions:
The land use restrictions that will be included in this Brownfields Agreement will include
a prohibition against residential and sensitive population use, an EMP, soil
disturbance/management restrictions, need for continued VI mitigation and performance
evaluation, restrictions on onsite chemical use, limited well abandonment, limited water
supply usage, wastewater treatment system decommissioning, and tenant/deed
notifications.
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. The VI mitigation system must be operated and maintained in good working order
and monitored in accordance with an approved revised VI mitigation plan.
Continued Monitoring
Based on historic groundwater, soil vapor, and indoor air data, and the performance of
the VIMS, Brownfields has agreed in concept to allow quarterly monitoring of the VIMS
to consist of pressure monitoring only of certain monitoring points in accordance with
their request in the VIMS Performance Assessment Report (Mid Atlantic Associates, May
4, 2018).
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