25054_Mt Gilead_Dec Memo 20220824

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Mt Gilead Cotton Co/25054-21-062 20220824
DECISION MEMORANDUM DATE: August 24, 2022
FROM: Carolyn Minnich TO: BF Assessment File
RE: Mt Gilead Cotton Oil Company 299 Industry Ave & South Wadesboro Blvd Mt Gilead, Montgomery County BF # 25054-21-062
Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than retail, parking, warehousing, and subject to DEQ’s prior written approval, other commercial uses, can be made suitable for such uses.
Introduction: The Brownfields Property is approximately 3.55-acres and is associated with Montgomery County Tax Parcel ID Numbers 6593-12-95-4641 and 6593-12-95-3728. The street address is 299 Industry Avenue and 0 South Wadesboro Boulevard. The Brownfields Property is on the west side of South Wadesboro Blvd, less than 0.1 miles
south of the intersection of South Wadesboro Blvd and NC Highway 73. The Brownfields Property is currently vacant and has undeveloped grassland. The surrounding area is occupied by industrial, commercial, and residential uses.
The Prospective Developer is Mt. Gilead DG, LLC, a North Carolina Limited Liability
Company, headquartered at 600 Green Valley Road, Suite 202, Greensboro, NC 27408. Its manager is Tom C. James. Redevelopment Plans:
Prospective Developer has committed itself to redevelopment for no uses other than
retail, parking, warehousing and with prior written DEQ approval, other commercial uses. Specifically, the redevelopment plan is for a Dollar General store with associated parking. The new building is designed with a vapor intrusion mitigation system as required in the land use restrictions.

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Mt Gilead Cotton Co/25054-21-062 20220824

Site History: North of the Brownfields Property is a former industrial complex. According to Environmental Reports, the Brownfields Property was used for parking and storage
related to activities at the adjacent Former Mt. Gilead Cotton Oil Company and the Russell-Harville Hosiery Mill since 1940. The property is undeveloped grassland with no structures. The Brownfields Property is serviced with the following utilities: Piedmont Natural Gas, Duke Energy, Montgomery County Public Utilities for water and sewer, and Charter/Centrylink.
In April 2021, a Phase 1 ESA dated April 2021 prepared by Emerald, Inc. identified two Recognized Environmental Conditions requiring additional investigation. First, the Brownfields Property was part of the Former Mt. Gilead Cotton Oil Company and the Russell-Harville Hosiery Mill industrial complex, with unknown chemicals and oils used
in the operations. Second, an AST that formerly or currently contains unknown substances is located on the adjacent parcel, approximately 50 feet from the property boundary. In May 2021, Emerald, Inc. conducted a Phase II Environmental Site Assessment to
determine if soil and groundwater had been impacted by an uncontrolled release of chemicals into the environment. The suspected source of impacts on the brownfields property is from the adjacent parcel upgradient former hosiery mill.
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Figure 1 Assessment Site Plan from April 2021

Figure 2Assessment Site Plan from March 2022
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Mt Gilead Cotton Co/25054-21-062 20220824
Potential Receptors: Potential receptors are construction workers, on-site workers, visitors, and trespassers.
Information on potential water supply well listed in Phase I Environmental Site Assessment Report prepared by Emerald, Inc dated April 22, 2021 Appendix C S Wadesboro Blvd EDR report dated March 26, 2021. The following question was posed: Water Supply Wells: The receptor survey states none in the area. The EDR Report lists
a PWS at Mt Olive Baptist Church (pg 122 in the PDF). Please provide more information about the potential well referenced in the EDR report. Email response from Chad McClary on Thursday 7/7/2022: We were not able to verify the existence of the water supply well, and I
believe that the EDR report may have misplaced the location. We could not find a
Mt Olive Baptist Church or a Mt Gilead Baptist Church in the town. I also looked
on the NC public water system registry for Montgomery County and the PWS
system ID could not be found. With no church matching the name, no matching
records in the database, not being able to verify the well during our site
reconnaissance, and no address we believe the well listed in the EDR report was a
mistake and I did not mention it in the report in an attempt to not confuse things. Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
groundwater, and exterior soil gas. DEQ relies on the following data to base its conclusions regarding the subject property and its suitability for its intended reuse. Please see the Brownfield Agreement’s Exhibit 2 for specific sample locations, dates, and contaminants of concern (COCs).

Soil

• In April 2021, eight soil borings were advanced on the Brownfields Property to a depth of 5 feet below ground surface (bgs). Soil samples were analyzed for
volatile organic compounds (VOCs). No detections were reported above laboratory reporting limits. The soil borings were properly abandoned after installation and samples collected.
• In March 2022, additional soil was completed and six soil borings were installed 3.5-5.5 ft bgs. Analysis includes VOCs, semi-volatile organic compounds (SVOCs), Resource Conservation and Recovery Act (RCRA) Metals, and hexavalent chromium (EPA Method 6010/7471/7199).
VOCs and SVOCs were not detected above laboratory detection limits at sampling locations. Detection of metals arsenic, barium, total chromium, lead, and mercury above laboratory limits was reported by the laboratory. None exceeded state standards.
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• Environmental Management Plan (EMP) states the Brownfields Property will balance for redevelopment or requirement small amount of import. Exporting soil
is not anticipated for the current redevelopment plan.
Groundwater In April 2021, the eight soil borings were scheduled to be converted to temporary wells.
Seven borings appeared to have water and 1-inch temporary wells were installed. Four of the wells were dry and three had sufficient water to purge and sample. Groundwater was collected and analyzed for VOCs at the following temporary wells GW-1, GW-2, and GW-4. Those contaminated that exceed NC 2L groundwater standards include tetrachloroethylene, trichloroethylene, and vinyl chloride. Groundwater
tetrachloroethylene contaminant was detected above its’ respective Residential Vapor Intrusion Screening Level (VISL) in temporary wells GW-2
• On February 11, 2022, several groundwater monitoring wells were planned to be
installed, however, only two borings and one groundwater monitoring well (MW-14) were advanced due to geologic issues. According to the environmental reports, shallow perch water was encountered above a dry weather rock through the Brownfields property, making drilling activities very challenging. The
shallow perched water zone was not readily apparent in many locations
throughout the property, with water only accumulating in the borehole after greater than two days in many locations. This perched watertable may be seasonal and dependent on area rainfall rates throughout the year.
Competent rock was encountered at between 4.5 and 17 feet BGS at drilling
locations. Monitoring well MW-14 was installed to a depth of 8 ft bgs. Each groundwater sample was analyzed for VOCs, SVOCs, and RCRA Metals. Laboratory reports listed no VOCs and SVOCs detected above detection limits Lead was detected in the primary sample at levels greater than the NC DEQ 2L
standard.

Surface Water
• Surface water is not located on nor borders the Brownfields Property.

Exterior Soil Gas In February 2022, ten soil gas sampling locations were installed to a depth of 5 ft bgs at the Brownfields Property. Nine soil gas samples were installed under the footprint of the proposed structure, and one was located between the structure and
previous groundwater sampling locations GW-2 and GW-4 (from the Phase II
Assessment). The soil gas sampling locations are presented on the figure above. During the development of SG-1 through SG-8, groundwater was found to have entered each sampling location. Samples were collected from two locations
Tetrachloroethylene (PCE) was detected and is the driving contamination in the risk
calculator.
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Mt Gilead Cotton Co/25054-21-062 20220824
The source of the PCE in the exterior soil gas is unknown, but could be related to groundwater detected in 2021 near sampling points GW-2 and GW-4 or an adjacent source at the former hosiery mill
The developer has agreed to install a vapor intrusion mitigation system in the proposed redevelopment due to construction timing and limited sampling. Sub-Slab Vapor
• Sub-slab vapor samples were not collected because no slabs are present. Indoor Air
• Indoor air samples were not collected because no buildings are present.

Risk Calculations Risk calculations were performed using the most recent DEQ Risk Calculator https://deq.nc.gov/permits-rules/risk-based-remediation/risk-evaluation-resources. The
DEQ Risk Calculator dated January 2022 was used to evaluate various scenarios for the
Entire Site. The risk calculations indicated the following based on available data, including the following media: groundwater, residual soil (based on confirmatory soil data), and
exterior soil gas.

Land Use Restrictions: The standard land use restrictions as to land use, no physical redevelopment without an EMP, reporting, prohibitions on groundwater use, restrictions on soil disturbance, vapor
intrusion provisions, known contaminant uses, notices, access, and land use restriction
update provisions will be included.
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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. PROPERTY MANAGEMENT ISSUES
• EMP approved and signed in April 2022.
• VIMS approved and signed in July 2022