20082_Peden Steel_ DM_20180925

DECISION MEMORANDUM
DATE: September 25, 2018
FROM: Sharon Poissant Eckard, PG
TO: BF Assessment File
RE: Peden Steel
2200 Atlantic Avenue, 1200 Wicker Drive, I I I I & 1121 E. Whitaker Mill
Rd, and 1859 Capital Boulevard
Raleigh, Wake County
BF # 20082-16-092
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no use other than for office, retail, restaurant, hotel, open
space, associated parking, and with prior written DEQ approval, multi -unit residential
and other commercial uses, can be made suitable for such uses. Single family homes are
prohibited; townhomes, duplexes, or other units with yards are prohibited unless
approved in writing by DEQ in advance.
For the purposes of this Agreement, any residential use of any area of the Brownfields
Property requires prior written DEQ approval. Any portions of the Brownfields Property
not specifically approved by DEQ for residential use may not be used for child care, adult
care centers or schools without the prior written approval of DEQ.
Introduction
The Brownfields Property is comprised of an assemblage of five parcels totaling about
18.6 acres in a primarily commercial and industrial area of Raleigh north of downtown.
The Prospective Developer (PD) is Plan of Steel, LLC, which is 100% owned by Grubb
Ventures, LLC of Raleigh. R. Gordon Grubb and Sam Crutchfield are the PD contacts.
Existing structures at the Brownfields Property include two warehouse buildings, two
commercial buildings, and a vehicle maintenance area. Certain documents reference
parcel identifiers. A description of those follows:
Parcel A is occupied by the original Peden Steel manufacturing building and an open area
north of this building; it includes a warehouse building in the southwestern area of the
site where most recently Waste Management conducted recycling operations. Former
operations included a former maintenance/tool shop along the southwestern side of the
building, and a former paint shop north of the existing building that was demolished in
the late 1980s or early 1990s. The former paint shop area is associated with lead -
contaminated soil to an approximate depth of one foot that was discovered in 1988 and
removed circa 1990 under the oversight of the Hazardous Waste Section of the NC
Department of Environment, Health and Natural Resources, DEQ's predecessor at that
time. The northern area of Parcel A, which is immediately adjacent to Parcel E, was

found to contain elevated lead in concentrations that exceeded its Toxic Characteristic
Leaching Potential (TCLP) in soil samples from areas that are anticipated to be excavated
for redevelopment.
Parcel B is occupied by a commercial warehouse building that was added to the Peden
operations in the central area of the site at a later date, and has most recently been
operated by Waste Management. Sources of contamination in this building include a
tool/chemical storage room, waste oil above ground storage tank (AST), and a machine
shop with flammable materials cabinet storage.
The northern area of Parcel B was most recently used as an open area for trailer parking.
Parcel C is primarily occupied by a commercial building toward the southeastern area of
the Brownfields Property that most recently housed conveyor, sorting and baling
machines for recycling materials for Waste Management operations. Sources of
contamination include the use of hydraulic oil inside the building, a 250-gallon diesel
AST, and a maintenance shop on the east side. Former use areas include a former
maintenance shop on the south side of the building and the area immediately north of this
building, which is the location of the UST release (DEQ UST Section Incident No.
21567). Multiple remedial events have been conducted to remediate this release after the
USTs were removed on March 22, 2000. These included aggressive fluid vapor recovery
(AFVR) events from 2001-2006, a mobile multi -phase extraction (MMPE) event in 2007,
and in -situ surfactant injection events with subsequent extractions beginning in 2012.
There is an irregular extension of Parcel C to the south immediately adjacent to other
commercial properties; it is currently unused space.
The DWM UST Section, Raleigh Regional Office, issued a Notice of Regulatory
Requirements to Peden Family, LLC on September 29, 2017 requesting that a Notice of
Residual Petroleum (NORP) be filed with the Wake County Register of Deeds due to the
residual contamination in the former UST area. Further email communication between
Sharon Eckard of Brownfields and Mark Powers of the Raleigh Regional Office indicated
that a recorded Brownfields Agreement would be an acceptable alternative in lieu of
recording a NORP on the property and that the UST Section was amenable to the closure
of all monitoring wells at the Brownfields Property.
Parcel D is subdivided into three areas along the northeastern and north central areas of
the Brownfields Property: 1) a commercial office building that housed the business
operations of Peden Steel, its subsequent business affiliates, and that of tenants in the
northeast corner of the property; 2) Pratt Industries' vehicle maintenance area for the
maintenance of Waste Management trucks along the north -central area of the property;
and 3) the southeastern extension immediately adjacent to Parcel C and to the offsite
location of a former chemical release from the adjacent property to the east (former
printer).
N

The Pratt Industries area was used historically and until October 2016 for vehicle
maintenance. Potential sources of contamination in the vehicle maintenance area include
parts washer stations, ASTs, 55-gallon drums, and new and waste oil buckets that were
observed in and adjacent to the maintenance building.
Parcel E is located at the northwestern area of the Brownfields Property; it was primarily
used for tractor trailer parking and is not affiliated with known industrial use other than
parking.
Redevelopment Plans:
For the initial redevelopment phase, the PD plans to keep the warehouse structures and
renovate them for office, retail and restaurant purposes, and to construct a new 300-
apartment unit residential structure with a swimming pool and parking (generally Parcels
A, B, portions of D, & E). The project will also include developing an access road from
Wicker Drive, named Iron Works Drive. The details of subsequent phase(s) of
redevelopment are unknown at this time, but will address the other areas of the
Brownfields Property, including Parcel C & the remainder of Parcel D.
The only structures that are planned to be demolished currently include those affiliated
with the former Pratt Industries' maintenance building in the north -central area of Parcel
D. However, the buildings on Parcel C may also be demolished.
Site History:
Historical information indicates that prior to the late 1950s, the Brownfields Property was
originally agricultural and wooded property. Peden Steel first developed the Brownfields
Property for steel fabrication purposes in about 1957 and continued operations until 1982
when operations ceased. Since that time, the property has been owned by one or other
Peden Family entities, and the Brownfields Property was leased to other commercial
operators. The PD purchased the Brownfields Property on January 19, 2017.
Other commercial operations have included Peden Commercial Realty, welding &
fabrication, NC DOT, sheet rock, and other commercial tenants. The most recent tenants
have been Waste Management or affiliated company(ies) for recycling of paper, plastics,
and glass, and Pratt Industries, which conducted truck maintenance activities at the
Brownfields Property since the 1950s, first on Peden Steel trucks and then on Waste
Management trucks.
The recycling operations ceased in 2017 and the vehicle maintenance operations ceased
in 2016. Known sources of contamination are: 1) historic paint shop that was demolished
in the late 1980s/early 1990s, 2) use of chemicals by Peden Steel, and 3) known releases
from three (1-1,000 gallon gasoline, 1-7,500 gallon gasoline and 1- 10,000 gallon diesel)
fuel underground storage tanks (USTs) that were removed in 2000 (UST Section Incident
No. 21567).

Potential Receptors:
Potential receptors are: construction workers, on -site workers, future residents, visitors,
animals (pets), and trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
groundwater, soil vapor, 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
Soil samples have been collected at the Brownfields Property for the following: 1) former
paint shop assessment in the late 1980s/1990; 2) the UST investigations conducted since
2000; and 3) through an assessment conducted in 2018 to evaluate the quality of soil for
disposal purposes and brownfields purposes. Historically, soil identified as heavily
contaminated from lead and paint (color) was removed from the property in 1990. Soil in
the vicinity of the USTs has been subject to remedial activities for about 18 years;
therefore, historic soil data was not relied upon in these assessments as it is likely there
has been remediation of unsaturated soil in the vicinity of the USTs.
Soil assessment data from 2018 indicates that there are identified areas of soil that will be
cut during site grading that contain elevated concentrations of lead (up to 11,400
milligrams/kilogram (mg/kg)) and cadmium (19.8 mg/kg). This soil exceeds the Toxic
Characteristic Leaching Potential (TCLP) for lead of 5 mg/L. Special handling of these
soils will be required and is discussed below.
In addition, there are exceedances of arsenic above its residential screening level of 0.68
mg/kg and bis(2-ethylhexyl) phthalate above its residential screening level of 39 mg/kg.
There were low detections of polynuclear aromatic hydrocarbons (PAH) compounds for
which the State does not have established regulatory screening levels, such as
(benzo(g,h,i)perylene, p-isopropyltoluene, 4-nitrophenol, and phenanthrene.
Soil samples collected from near the exterior of the building foundation at the vehicle
maintenance area in the northern area of the site (Parcel D) did not indicate signs of soil
contamination at the exterior of the building foundation, but no sampling was conducted
below the slab and due to observed conditions inside the building, the soil could be
contaminated in certain localized areas below the slab. Groundwater and soil vapor data
collected nearby to the immediate west (see below) indicates that a source of PCE is
within the subsurface in this area.
Groundwater
Most groundwater wells were installed at the Brownfields Property as part of the UST
investigation and therefore are clustered in the vicinity of the UST excavation on Parcel
C. Downgradient wells were also placed on Parcel D as part of the UST work. As part of
the Brownfields assessment, temporary groundwater wells were installed and sampled on
the downgradient side of the vehicle maintenance area on Parcel D and on Parcel E below
the footprint of the proposed residential building.
2

No groundwater contaminants exceeding NC 2L groundwater standards or NC vapor
intrusion screening levels (VISLs) were detected from well TMW-2 installed from within
the residential building footprint. A low concentration of tetrachloroethylene (PCE) was
detected in well TMW-1 and a duplicate sample downgradient of the vehicle maintenance
area.
Groundwater in the vicinity of the UST investigation and remedial activities indicates
that originally groundwater was grossly contaminated with a number of petroleum
hydrocarbon constituents with certain samples exceeding the NC DWM UST Section
Gross Contaminant Levels (GCLs) for benzene, n-butylbenzene, sec-butylbenzene, 1,2-
dibromoethane (EDB), ethylbenzene, naphthalene, n-propylbenzene, toluene, total
xylenes, 1,2,4-trimethylbenzene, and 1,3,5-trimethylbenzene. Additional contaminants
historically in excess of NC 2L standards include acetone, 1,2-dichloroethane, 1,2-
dichloropropane, isopropylbenzene, lead, methyl-tert-butyl ether (MTBE), PCE,
trichloroethylene (TCE), and 1,2,3-trichloropropane. Although still elevated in certain
wells, groundwater concentrations related to the UST release have significantly decreased
over the years including order of magnitude decreases such that there are no longer any
exceedances of GCLs in recent groundwater samples.
Surface Water
Surface water is not located on the site.
Soil Vapor
Soil vapor samples were collected near the exterior building foundations of the
commercial building on Parcel C and near the vehicle maintenance building on Parcel D.
Soil vapor samples collected near the building on Parcel C indicate exceedances of
residential VISLs for benzene, 1,3-butadiene, ethylbenzene, PCE,
trichlorofluoromethane, and total xylenes.
The one soil vapor sample collected near the maintenance building on Parcel D indicated
that the detected concentration of PCE exceeds its residential VISL in this area, but does
not exceed its non-residential VISL.
Sub -Slab Vapor
Sub -slab vapor samples were collected below the two warehouse buildings on Parcel A
(PA-1-PA-7) and Parcel B (PB-1 — PB-4), and below the office building in the
northeastern corner of the property (013-1 — OB-2). Sub -slab vapor sample results
indicate that sub -slab vapor below the warehouse buildings on Parcels A and B exceed
residential VISLs for isopropanol, PCE and TCE. Non-residential VISLs were not
exceeded by the sample results.
Indoor Air
Indoor air samples were not collected at the Brownfields Property as available soil vapor
or sub -slab vapor contaminant concentrations did not exceed non-residential vapor
intrusion screening levels in existing commercial structures.
5

Risk Calculations
Risk Calculations were performed using the DWM risk calculator (February 2018
version). For the purposes of looking at the site spatially, the site was divided into seven
areas based on parcel configuration, operations, and known contaminants from those
historic operations: 1) Parcel A (PA), 2) Parcel B (PB), 3) Parcel C (PC), 4) Parcel D,
Office Building (PDOB), 5) Parcel D, Vehicle Maintenance Area (PDVMA), 6) Cut Area
B/C, 7) Cut Area on the north side of Parcel A/south side Parcel E (PAE), and 8) Cut
Area D on the south side of the property. The risk calculations indicated the following
based on available data, including the following media: groundwater, sub -slab vapor, and
soil gas. A discussion of each area followed by the summary output of the risk calculator
is provided below.
Parcel A: Data from Parcel A is based on sub -slab vapor samples PA-1 through PA-7
collected on August 26, 2016 only. These data note that although there were
tetrachloroethylene (PCE) concentrations in sub -slab soil vapor that exceeded residential
vapor intrusion screening levels (VISLs), the non-residential VISL for PCE was not
exceeded. The risk calculator results bear this out with respect to soil gas with a
noncancer hazard index of 2 for residential scenarios and a noncancer hazard index of
0.16 for non-residential scenarios.
Soil that was discovered to be contaminated with high levels of lead under the former
paint shop in the late 1980s on this parcel was removed from the property by 1990,
although soil contaminated with elevated concentrations of lead was determined to
remain at the property north of the former paint shop by sampling conducted in 2018.
Note that the presence of elevated lead is not reflected in the risk calculator output
below. Decisions about lead -contaminated soil at the site are based on total lead levels
and Toxic Characteristic Leaching Potential (TCLP) analyses and are discussed below. It
is possible that soil or groundwater below the foundation of the warehouse on Parcel A
could be impacted with other contaminants, but based on 2016 sub -slab vapor sampling,
if present, those potential contaminants do not appear to pose a risk of vapor intrusion.
Co

Summary of Risk Assessment Output
Version Date: February 2018
Basis: November 2017 EPA RSL Table
Site ID: 20082-16-092
Exposure Unit ID: Parcel A -warehouse
PRIMARY CALCULATORS
Receptor
Pathway
Carciinnogenic
sk
Hazard Index
Risk exceeded?
Resident
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Groundwater Combined Pathways*
0.0E+00
0.0E+00
NO
Non -Residential Worker
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Groundwater Combined Pathways*
0.0E+00
0.0E+00
NO
Construction Worker
Soil Combined Pathways
0.0E+00
0.0E+00
NO
User Defined
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Surface Water Combined Pathways*
0.0E+00
0.0E+00
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carci�nskenic
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
1.0E-05
2.0E+00
YES
Indoor Air
0.0E+00
0.0E+00
NO
Non -Residential Worker
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
8.0E-07
1.6E-01
NO
Indoor Air
0.0E+00
0.0E+00
NO

Parcel B: Data from Parcel B is based on sub -slab vapor samples P13-1 through P13-4
collected on August 26, 2016 only. Groundwater monitoring well MW-2 is also located
on Parcel B; however, groundwater data from this well was collected only early on in the
UST investigation on Parcel C for petroleum hydrocarbons only, and monitoring appears
to have been discontinued when petroleum hydrocarbon compounds were not detected in
this shallow groundwater well. These data, like those detected below the building at
Parcel A, note that although there were PCE concentrations in sub -slab soil vapor that
exceeded residential VISLs, the non-residential VISL for PCE was not exceeded. The
risk calculator results bear this out with respect to soil gas with a noncancer hazard index
of 3.3 for residential scenarios and a noncancer hazard index of 0.26 for non-residential
scenarios.
Summary of Risk Assessment Output
Version Date: February 2018
Basis: November 2017 EPA RSL Table
Site ID: 20082-16-092
Exposure Unit ID: Parcel B - warehouse
PRIMARY CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded?
Resident
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Groundwater Combined Pathways*
0.0E+00
0.0E+00
NO
Non -Residential Worker
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Groundwater Combined Pathways*
0.0E+00
0.0E+00
NO
Construction Worker
Soil Combined Pathways
0.0E+00
0.0E+00
NO
User Defined
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Surface Water Combined Pathways*
0.0E+00
0.0E+00
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carciinnogenic
sk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
1.3E-05
3.3E+00
YES
Indoor Air
0.0E+00
0.0E+00
NO
Non -Residential Worker
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
9.8E-07
2.6E-01
NO
Indoor Air
0.0E+00
0.0E+00
NO

Parcel C: Data from Parcel C is the most inclusive because of the UST incident
occurring on this parcel; it includes groundwater from multiple wells (MW-1, MW-1R,
MW-1D, MW-2D, MW-4, MW-6, MW-9, and MW-10) drilled within and around the
UST excavation and exterior soil gas data (SG-1 through SG-4) obtained from near the
foundation of the commercial building on Parcel C. Soil data from the year 2000 (S-1
through S-9) was excluded from this analysis as these data pre -dated remedial events
performed in the area of the UST excavation and are not considered to reflect current
conditions at Parcel C. Similarly, only the most recent groundwater data were used in the
risk calculator as significant reductions in concentrations (orders of magnitude in some
cases) have been observed since the initial discovery of the release due to time and
remedial activities.
Please note that sub -slab vapor samples were not collected from below the foundation of
the building on Parcel C. In addition, reporting limits for EDB and 1,1,2-trichloroethane
were higher than their respective residential VISLs. Groundwater pathways pose an
unacceptable risk for residential and non-residential scenarios as does the risk of vapor
intrusion for residential scenarios.
Summary of Risk Assessment Output
Version Date: February 2018
Basis: November 2017 EPA RSL Table
Site ID: 20082-16-092
Exposure Unit ID: Parcel C- Maintenance/UST
PRIMARY CALCULATORS
Receptor
Pathway
Carciinnogenic
sk
Hazard Index
Risk exceeded?
Resident
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Groundwater Combined Pathways*
3.5E-01
7.0E+02
YES
Non -Residential Worker
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Groundwater Combined Pathways*
2.8E-02
1.7E+02
YES
Construction Worker
Soil Combined Pathways
0.0E+00
0.0E+00
NO
User Defined
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Surface Water Combined Pathways*
0.0E+00
0.0E+00
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carci�nskenic
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
1.0E-03
7.1E+01
YES
Soil Gas to Indoor Air
1.6E-04
7.0E+00
YES
Indoor Air
0.0E+00
0.0E+00
NO
Non -Residential Worker
Groundwater to Indoor Air
2.3E-04
1.7E+01
YES
Soil Gas to Indoor Air
1.2E-05
5.6E-01
NO
Indoor Air
0.0E+00
0.0E+00
NO
X

Parcel D — Office Building: Data from Parcel D is collected from within the vicinity of
the office building in the northeastern area of the property. It includes groundwater data
(MW-3, MW-5, & MW-7), and sub -slab vapor data from 013-1 and 013-2. Groundwater
concentrations from MW-3 account for all the detections noted in this area of the site due
to its proximity to the UST release. Risk calculations indicate that although groundwater
to indoor risk exceeds a noncancer hazard index of 1 for residential scenarios, the soil gas
to indoor air risk values do not exceed either an acceptable risk for cancer nor the
threshold hazard index of 1 for either residential nor non-residential scenarios.
Summary of Risk Assessment Output i
Version Date: February 2018
Basis: November 2017 EPA RSL Table
Site ID: 20082-16-092
Exposure Unit ID: Parcel D- Office Building
PRIMARY CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded?
Resident
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Groundwater Combined Pathways*
8.7E-04
2.4E+01
YES
Non -Residential Worker
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Groundwater Combined Pathways*
2.0E-04
5.6E+00
YES
Construction Worker
Soil Combined Pathways
0.0E+00
0.0E+00
NO
User Defined
Soil Combined Pathways
0.0E+00
0.0E+00
NO
Surface Water Combined Pathways*
0.0E+00
0.0E+00
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Ha7ardIndex
Risk exceeded?
Resident
Groundwater to Indoor Air
3.7E-05
1.0E+00
YES
Soil Gas to Indoor Air
4.3E-06
2.5E-02
NO
Indoor Air
0.0E+00
0.0E+00
NO
Non -Residential Worker
Groundwater to Indoor Air
8.4E-06
2.4E-01
NO
Soil Gas to Indoor Air
3.3E-07
2.0E-03
NO
Indoor Air
0.0E+00
0.0E+00
NO
10

Parcel D -Vehicle Maintenance Area: Data from Parcel D — Vehicle Maintenance Area
was collected from within the vicinity of the former Pratt Industries truck maintenance
area in the north -central area of the Brownfields Property. It includes groundwater data
from wells MW-8 and TMW-1, sub -slab vapor data from SG-5, and soil data from SB-1
through S13-8. Risk calculations indicate that groundwater exceeds the acceptable
carcinogenic risk of 1E-04, primarily due to the presence of 1,2-dibromoethane (EDB)
for residential scenarios. No other scenarios exceed the acceptable cancer risk range or
the threshold noncancer hazard index.
Note that sub -slab vapor samples were not collected from below the foundation of the
building on Parcel D where vehicle maintenance activities have been conducted. It is
possible that soil or groundwater below the foundation of the building on Parcel D in the
vicinity of the vehicle maintenance activities could be impacted with other contaminants.
Summary of Risk Assessment Output LVA I i 4 i I I 1 171100,I
Version Date: February 2018
Basis: November 2017 EPA RSL Table
Site ID: 20082-16-092
Exposure Unit ID: Parcel D -Vehicle Maintenance Area
PRIMARY CALCULATORS
Receptor
Pathway
Carciinnogenic
sk
Hazard Index
Risk exceeded?
Resident
Soil Combined Pathways
4.1E-06
9.4E-02
NO
Groundwater Combined Pathways*
1.3E-04
8.0E-02
YES
Non -Residential Worker
Soil Combined Pathways
8.4E-07
7.2E-03
NO
Groundwater Combined Pathways*
3.0E-05
1.9E-02
NO
Construction Worker
Soil Combined Pathways
1.4E-07
7.8E-02
NO
User Defined
Soil Combined Pathways
2.3E-06
5.1E-02
NO
Surface Water Combined Pathways*
0.0E+00
0.0E+00
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carci�nskenic
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
5.7E-06
1.8E-02
NO
Soil Gas to Indoor Air
1.3E-05
6.0E-01
NO
Indoor Air
0.0E+00
0.0E+00
NO
Non -Residential Worker
Groundwater to Indoor Air
1.3E-06
4.2E-03
NO
Soil Gas to Indoor Air
1.0E-06
4.8E-02
NO
Indoor Air
0.0E+00
I 0.0E+00
NO
11

Northern Area Parcel A/E: The area comprised of the northern extent of Parcel A and
the southern extent of Parcel E will be cut during redevelopment grading activities. Data
for the risk calculations included groundwater data from TMW-2 and the following soil
samples collected in 2018: Pool-1, Cut A-1, Cut A-2, Cut B-1, Cut B-2, Cut C-1, and Cut
C-2. No soil vapor data was collected in this area. Metals data indicated that soil in
certain cut areas were contaminated with total lead concentrations (up to 11,400 mg/kg)
that would likely exceed the lead TCLP leaching threshold of 5 milligrams/liter (mg/L).
Followup TCLP testing bore this out. This indicates that the soil would be considered a
hazardous waste if excavated from this location under most circumstances. Based on
EPA policy from the 1990s that is still in effect and has been recognized by the NC
DWM Hazardous Waste Section, under certain circumstances the EPA allows for the
removal of such soil and placement elsewhere at the site without invoking criteria for the
removal of hazardous waste. This will be performed as per an approved Remedial Action
Plan that will be required within the Brownfields Agreement and with consultation with
and review by the Hazardous Waste Section.
The soil identified in the cut area that exhibits hazardous concentrations of lead will be
cut from the cut areas and immediately placed in a designated fill area onsite. The top of
the material will be covered with an orange geotextile or screening material for a visual
indication of the top of this placed material, and covered with at least one to two feet of
demonstrably clean fill material, and capped to prevent exposure. The location of this
material will be identified on the brownfields survey plat.
Note that due to the reference values pertaining to lead, the DWM risk calculator does not
include lead concentrations in its calculations. Rather, a straight comparison of lead
values detected in site soil is made to the applicable soil remedial goal. In this case that
would be to the residential soil remedial goal of 400 mg/kg.
Therefore, the risk values calculated below are for any other contaminants that were
detected in soil or groundwater in this area of the site other than lead.
12

Summary of Risk Assessment Output
Version Date: February 2018
Basis: November 2017 EPA RSL Table
Site ID: 20082-16-092
Exposure Unit ID: Parcel A/E - Cut Soil & TMW-2
PRIMARY CALCULATORS
Receptor
Pathway
Carcinnskemc
Hazard Index
Riskexceeded?
Resident
Soil Combined Pathways
8.7E-06
4.9E-01
NO
Groundwater Combined Pathways*
0.0E+00
1.4E-04
NO
Non -Residential Worker
Soil Combined Pathways
1.8E-06
3.7E-02
NO
Groundwater Combined Pathways*
0.0E+00
2.3E-05
NO
Construction Worker
Soil Combined Pathways
4.4E-07
7.2E-01
NO
User Defined
Soil Combined Pathways
4.9E-06
2.7E-01
NO
Surface Water Combined Pathways*
0.0E+00
0.0E+00
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carci�nskenic
Hazard Index
Riskexceeded?
Resident
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
1.3E-05
6.0E-01
NO
Indoor Air
0.0E+00
0.0E+00
NO
Non -Residential Worker
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
1.0E-06
4.8E-02
NO
Indoor Air
0.0E+00
0.0E+00
NO
13

Cut D-1 and Cut D-1B: The area where samples Cut D-1 and Cut D-1B were obtained is
at the far southern extent of the Brownfields Property. These soils were not found to
contain contaminants in excess of residential soil remedial goals except for arsenic. Only
low concentrations of volatile organic compounds were detected in these soil samples
above method reporting limits. These cut soils do not exceed acceptable residential
cancer risk ranges nor the noncancer hazard index threshold value of 1.
Summary of Risk Assessment Output
Version Date: February 2018
Basis: November 2017 EPA RSL Table
Site ID: 20082-16-092
Exposure Unit ID: Cut D-1/D-1B
PRIMARY CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded?
Resident
Soil Combined Pathways
5.8E-06
1.2E-01
NO
Groundwater Combined Pathways*
0.0E+00
1.4E-04
NO
Non -Residential Worker
Soil Combined Pathways
1.3E-06
8.9E-03
NO
Groundwater Combined Pathways*
0.0E+00
2.3E-05
NO
Construction Worker
Soil Combined Pathways
4.4E-07
7.2E-01
NO
User Defined
Soil Combined Pathways
3.3E-06
6.6E-02
NO
Surface Water Combined Pathways*
0.0E+00
0.0E+00
NO
VAPOR INTRUSION CALCULATORS
MM
Receptor
Pathway
CarcinogenicRisk
Ha7ardIndex
Risk exceeded?
Resident
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
1.3E-05
6.0E-01
NO
Indoor Air
0.0E+00
0.0E+00
NO
Non -Residential Worker
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
1.0E-06
4.8E-02
NO
Indoor Air
0.0E+00
0.0E+00
NO
Any utility or other work that involves disturbing soil below the foundation of the
existing buildings on Parcels A, B, C, D (Vehicle Maintenance Area), or elsewhere at the
Brownfields Property must be done under an approved Environmental Management Plan
(EMP).
Because vapor intrusion risk in this area is not indicated, multi -family residential use is
permitted on the northern area of Parcel A and Parcel E (Phase 1 redevelopment) as long
as the lead -contaminated soil is addressed as described in the brownfields agreement so
that exposure to residents and other users of the site to this contaminated soil is
prevented.
Multi -family residential use of the office building on the eastern portion of Parcel D is
allowable based on the lack of vapor intrusion risk determined at the site.
Reuse of existing buildings or new construction on Parcels A (southern area), B, C, and D
(Vehicle Maintenance Area) are limited to non-residential purposes only where children
or sensitive use populations do not frequent the site. Residential use of these parcels will
14

be expressly prohibited unless further assessment, remediation, or the design, installation
and operation of vapor mitigation systems to DEQ's written satisfaction indicates
otherwise.
Required Land Use Restrictions:
The required land use restrictions will include specific reuse prohibitions for residential
use in certain areas, an EMP, prohibition against groundwater use, soil import/export
restriction, specific soil disturbance LURs, including addressing hazardous
concentrations of lead in excavated soil onsite, and the typical notice, access,
groundwater well abandonment, land use restriction update, and other standard language.
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 and as long as PD conducts the removal of lead -contaminated soil from identified cut
area in accordance with EPA/HW Section accepted policy.
15