17039_LinPac_DM_20160921

DECISION MEMORANDUM
DATE: September 21, 2016
FROM: James Rudder
TO: Lin Pac Brownfields Assessment File
RE: Lin Pac
7205 Cessna Drive
Greensboro, Guilford County
BF # 17039-13-041
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than warehousing and industrial use, can be
made suitable for such uses.
Introduction:
The Property comprises one parcel (parcel ID 7815906477) totaling 6.69 acres. The
Property is located in an industrial park south of the Piedmont Triad International Airport
in Guilford County. The Property is surrounded by industrial and commercial properties
and is adjacent to a railroad. The Prospective Developer is Bright Plastics, which has
owned and operated out of the onsite building since late October 2013.
Redevelopment Plans:
Bright Plastics is currently using the Property for warehousing and may begin
manufacturing at some time in the future. Bright Plastics plans to perform injection
molding design, processes, and assembly operations.
Site History:
The Property was initially developed in 1981 and additional construction occurred in
2004. Prior to development, the Property was undeveloped pastureland. The original
owner, Boeing Investments sold the Property to Lin Pac Corrugated, Inc. in 1982. Lin
Pac Corrugated, Inc. owned the Property and operated a corrugated cardboard
manufacturing plant until 2008. The Property was vacant from 2008-2009 until purchased
by the Prospective Developer on October 28, 2013. A 20,000 gallon diesel UST was
removed from the site in 1994, contamination was reported, and a Comprehensive Site
Assessment was completed in May 1995.
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,
soil gas, and groundwater. DEQ relies on the following data on which to base its
conclusions regarding the subject property and its suitability for its intended reuse.

Soil
Soil samples were collected in association with closure of one 20,000 gallon diesel UST
in June, September, and December 1994. Several soil samples collected from depths of 3
to 10 feet below grade exceeded the standard for Total Petroleum Hydrocarbons — Diesel
Range Organics (TPH-DRO). Reported concentrations ranged from 262 mg/kg to a
maximum of 4,840 mg/kg TPH-DRO. No evidence of soil removal has been provided,
but in July 2002 NCDENR's UST Section determined that the soil contaminant
concentrations associated with the former UST "...does not exceed the
industrial/commercial maximum soil concentrations and groundwater contamination
meets the cleanup requirements for a low risk site."
Groundwater
A Comprehensive Site Assessment completed in 1995 for the former UST reported
groundwater was encountered in the UST excavation in 1994, and in 1995 the depths to
groundwater in six on -site groundwater monitoring wells ranged from 9.57 feet to 11.16
feet below flush -mounted tops of casing. Based on this data groundwater appears to be
flowing from east to west north and south of the building, with an off -site source for
chlorinated solvents located to the east. Multiple groundwater samples were collected
from temporary and permanent groundwater monitoring wells from February 1996
through August 2008. Three petroleum hydrocarbon compounds and lead were reported
to slightly above NC 2L standards.
Compound
Date
Location
Concentration
Exceeding
Standard ug/L
15NCAC 2L
Groundwater
Standard ug/L
Lead
3/8/1995
MW-1
26
15
3/8/1995
MW-2
21
15
3/8/1995
MW-4
61
15
Naphthalene
12/14/1994
MW-2
47.6
6
7/l/1995
MW-2
45.1
6
Tetrachloroethene (maximum of 128 ug/L) and trichloroethene (maximum of 87.6 ug/L)
were reported above their respective water quality standards of 0.7 ugL tetrachloroethene
and 3 ug/L trichloroethene. The chlorinated solvents are believed to originate from an
off -site, upgradient location, as the highest concentrations were reported in the northeast
corner of the Property, a location believed to be upgradient from the on -site building.
Surface Water
Surface water is not located on the Brownfields Property.
Soil Vapor
Three soil gas samples were collected at the Brownfields Property on April 18, 2013.
One sample was collected on the upgradient side of the Property between the on -site
building and the potential off -site source for chlorinated solvents. The soil vapor samples

were collected from a depth interval of five to six feet below grade. SG-2 was located
immediately adjacent to the northeast corner of the building, close to the highest reported
groundwater concentrations. SG-3 was located immediately adjacent to the building's
mid -eastern side, and SG-1 was collected immediately adjacent to the buildings
southwestern side, between the former UST location and the building. Regulated
compounds were not reported above DWM Non -Residential Vapor Intrusion Screening
Levels (March 2016 version). Trichloroethene was reported at a concentration of 14
ug/m3 in sample SG-2, with the DWM Non -Residential soil vapor screening level for
TCE being 175 ug/m3.
Sub -slab Vapor
Sub -slab vapor samples were not obtained due to the soil vapor results.
Indoor Air
Indoor air samples were not obtained due to the soil vapor sample results which did not
indicate the need for this testing.
Risk Calculations
Risk calculations were performed using Excel worksheets provided by Sandy Mort,
NCDEQ Brownfields Toxicologist. The risk calculations indicated the following based
on available data, including the following media: groundwater, residual soil (based on
confirmatory soil data), soil gas, indoor air, and fill soil samples:
Medium
Site Area
Non -Residential
LICR
HI
Groundwater
MW-12
1.2 E-05
4.03 E+00
Groundwater
MW-10
1.9 E-06
6.32 E-01
Groundwater
MW-7
7.5 E-07
2.94 E-01
Soil Vapor
SG-1
2.6 E-07
1.81 E-01
Soil Vapor
SG-2
3.5 E-06
1.01 E+00
Soil Vapor
SG-3
1.3 E-06
3.41 E-01
Red shading LICR> 1 E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index
The results of vapor intrusion screening calculations for groundwater samples reported
one groundwater sample exceeding the screening levels (MW-12). This exceedance was
caused primarily because of the detection of 87.6 ug/L TCE in the groundwater sample.
Groundwater monitoring well MW-12 was located in the northeast corner of the Property
and adjacent to Cessna Drive. Groundwater flow from well MW-12 is not expected to
flow beneath the on -site building. Soil gas sample SG-2 was located adjacent to well
MW-12, but closer to, and adjacent to, the northeast corner of the on -site building. Well
MW-12 and soil gas sample SG-2 were located to detect whether contaminants from the
suspected off -site, upgradient source of the chlorinated solvents were migrating onto the
Brownfields Property.

Site visits documented by photographs demonstrate the on -site building has a high (about
26 to 28 feet) inside ceiling; many different bays with roll -up doors; and at least four
large louvered vents which open periodically to vent outside air into the building. The
concrete floor beneath the on -site building is approximately one foot thick to withstand
its original uses. The site building conditions, and the very slight exceedance of 0.01 for
the Hazard Index calculated using the soil gas samples indicates soil vapor would not be
expected to exceed current DWM Non -Residential Vapor Intrusion Screening Levels at
the Lin Pac Brownfields Property.
Required Land Use Restrictions:
The land use restrictions limit the Brownfields Property uses to industrial, warehousing
and parking. Groundwater or surface water cannot be used at the Property without DEQ
permission, and allowable soil disturbances are minimal and clearly defined. Physical
redevelopment of the Property must occur in accordance with an approved
Environmental Management Plan. Access to the site to DEQ or DEQ contractors for
completing additional assessment or remediation is permitted.
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.