19025_AMI_DM_20230125

DECISION MEMORANDUM
DATE: January 25, 2023
FROM: Sharon Eckard
TO: BF Assessment File
RE: American Media International (AMI)
2609 Tucker Street & Hahn Road
Burlington, Alamance County
Brownfields Project No. 19025-15-001
Based on the following information, it has been determined that the above -referenced
site, whose intended use is for no uses other than for warehousing of yarn and finished
hosiery goods, office, truck driving school operations, associated parking, and subject to
DEQ prior written approval, other commercial uses, can be made suitable for such uses.
Introduction:
The Brownfields Property is comprised of two parcels totaling 17.63-acres. One parcel is
assigned Parcel ID No. 12077 and is addressed as 2609 Tucker St.; it is about 7 acres and
has one manufacturing building that was constructed in three stages constructed on it. A
small one-story wooden building in the rear parking area was formerly used as a chemical
storage building. The second parcel is assigned Parcel ID No. 121701 and has an address
of Hahn Road; it is largely a 10.78 acre vacant and partially vegetated field, with a
drainage ditch along its southern extent. A building with tanks is located on the vacant lot
and is believed to contain remediation equipment from one of the remedial activities
previously attempted at the Brownfields Property.
Several residential properties lie to the northwest of the Brownfields Property along Hahn
Road. Water supply well sampling and soil vapor assessment has been conducted on a
number of these properties by IHSB.
The Prospective Developer (PD) and current property owner is Carolina Hosiery Mill,
Inc., and its principal office is located at 2316 Tucker Street, Burlington, NC 27215 and
its mailing address is PO Box 850, Burlington, NC 27216. The President of the PD entity
is Ernest A. Koury, Jr. and its Secretary is Miltom E. Petty, both at the same mailing
address.
The Brownfields Property was purchased by the PD from Burlington Property, LLC on
July 1, 2015 (Book 3446, Page 0844). The Brownfields Property was developed
originally in 1984. It currently has 143,944 square foot industrial manufacturing building
located on it. This building contains two electric freight elevators toward the rear of the
building.
AMI/I 9025-15-001 /25Jan2023

Redevelopment Plans:
The PD plans to utilize the existing buildings, which were vacant at the time the PD
purchased the Brownfields Property, for the storage of yarn and finished hosiery goods,
and potentially for the manufacture of hosiery products.
Site History:
The industrial portion of the AMI site was first developed for manufacturing purposes by
1977. It appears to have been farmland prior to that time. It was originally purchased by
Heritage Casket Co. in 1970 and was used for casket manufacturing until April 1980
when it was purchased by Bill & Peggy Britt. The Britt's leased the property to
Marseilles Casket Co., the parent company of Heritage Casket. In 1986, the Britt's placed
the property under the ownership of the Bill & Peggy Britt Ltd. Partnership and began
leasing the property to American Media International (AMI) in June 1992. AMI
manufactured various types of media materials, i.e., cassette tapes, digital video discs,
and compact discs, and included printing operations. By 1993, additional building
construction had been undertaken as the building had been expanded to the southwest.
The vacant parcel was purchased by Bill and Peggy Britt Ltd in 1993. In 1995, the Britts
sold the property to AMI and in turn AMI sold the property to Burlington Property, LLC
in 2000.
As part of a Phase I environmental site assessment conducted in 1992, stained soils were
observed in and around an empty drum storage area, the chemical storage building,
former compressor area, and near heating and air conditioning equipment along the
western side of the building. Subsequent soil sampling in these areas indicated that soil
was impacted with chlorinated volatile organic compounds (cVOCs) at the chemical
storage building on the northwest side (rear) of the main building.
Additional investigation led to a number of site assessments, including the installation of
multiple shallow and deep bedrock wells, geophysical logging of wells, bedrock fracture
analysis, offsite groundwater and soil vapor evaluations, and at least three on -site
remedial actions including soil removal and treatment, air sparging/soil vapor extraction,
and groundwater remedial actions involving injection of emulsified oil to enhance the
degradation of the cVOCs in groundwater (Injection Permit No. WI0400066).
The discovery of very elevated cVOCs, primarily tetrachloroethylene (PCE) and
trichloroethylene (TCE), and their degradation products in site soil and groundwater led
to the NC DEQ DWM Inactive Hazardous Sites Branch (IHSB)'s predecessor at that
time, the DWQ Aquifer Protection Section, to issue Incident No. 11596. The site was
later transferred to the jurisdiction of the IHSB and was assigned Incident Number
NONCD0001259. Hazardous waste codes associated with this site include D001
(ignitable wastes), D002 (pH <2 or >12.5), D039 (PCE), D040 (TCE), D043 (vinyl
chloride). In addition, work at the site included compliance inspections and litigation
among the various parties regarding liability for the costs of the assessment and cleanup.
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DENR issued a Notice of Violation (NOV) to AMI on February 7, 2000 for a violation of
the State's Groundwater Quality Standards (NC2L). The NOV required the submittal of a
Corrective Action Plan to address soil and groundwater contamination, sample drinking
water wells within 500 feet of the site and take a soil sample at the storm drain outfall.
Sample results indicated that VOCs were not detected in the soil samples at the storm
drain outfall. AMI disposed of a total of 37 55-gallon drums containing impacted soil
and drill cuttings in June 2000, as a result of the investigations.
Nearby residences with impacted drinking water had been connected to city water in
sometime between the early 1990s and 2001. Reportedly, Environmental Investigations
(EI) abandoned 11 water supply wells that were located within 1,500 feet of the
Brownfields Property in June 2001.
In 2002, an air sparge and soil vapor extraction system was installed at the Brownfields
Property; however, it had been designed during a drought period and became inundated
and non-functional when groundwater levels returned to pre -drought conditions. In 2005,
an amended Corrective Action Plan (CAP) was submitted to DENR by Solutions-IES that
proposed a pilot test injection to facilitate reductive dechlorination of the groundwater;
however DENR requested additional bedrock assessment first and there is no indication
that the injection pilot test was conducted.
In 2014, IHSB had S&ME sample soil vapor at properties adjacent to the AMI site along
Hahn Road, and to sample a water supply well at a commercial property located about
700 feet to the northeast from the AMI property. These included 2523 Tucker Street
Extension (commercial property occupied by Oakley Paint & Paper Co., Inc.), and
several residences (930, 939, 952, 960, 963, 1003, 1006, and 1010 Hahn Rd). The results
of this investigation were relayed to property owners in a series of letters in May 2014
along with a statement as to whether the results exceeded soil vapor intrusion screening
levels (VISLs) at that time, and if they did, recommended additional sampling to evaluate
the vapor intrusion pathway. Concentrations of PCE and TCE in soil vapor exceeded
VISLs only at one residential property, 1006 Hahn Road. PCE and TCE were also
detected in the onsite WSW-1 at 2523 Tucker Street on April 9, 2014 at 32 micrograms
per liter (µg/1) and 30 µg/l, respectively.
IHSB sent a second letter to this 1006 Hahn Road address in June 2014 requesting
authorization to sample the property; however, there is no documentation in the
Laserfiche file as to whether any additional testing was conducted at this property. The
industrial water supply well at 2523 Tucker Street was evaluated previously in 2012 and
was found to contain PCE and TCE in exceedance of the MCL at that time; these
concentrations were very similar to those detected in 2014. The owner was instructed not
to drink the groundwater by IHSB; it is used only for industrial supply and not for potable
purposes.
A private well survey near the former AMI site was conducted by the IHSB in July 2020.
A total of 10 well survey forms were sent out to individual property owners along Hahn
Road near the AMI site, and six forms were returned. The following addresses either
AMI/I 9025-15-001 /25Jan2023

indicated they do not have a potable well on the property or the well had been closed and
sealed when the property was connected to city water by AMI years prior: 930, 952, 960,
966, 1003, and 1010 Hahn Rd. One mailer sent to 903 Hahn Road was returned to sender,
unable to forward, and the others were not returned.
Mineral Springs Environmental also conducted a private well survey in January 2022 as
part of conducting an updated Brownfields Receptor Survey on the Brownfields Property.
Their findings indicated that private water supply wells were abandoned at the following
addresses on Hahn Road: 930, 939, 952, 960, 963, 966, 1003, 1006, and 1003, and at
2612 Tucker Street. There is a well at 936 Hahn Road that is used only for irrigation
purposes, but the residence is connected to municipal water. A well that is listed as
present, but caved in and therefore not useable is noted at Hahn Rd (no address provided;
parcel No. 8864520314.) An additional private well is located at 1931 Hatchery Rd
approximately 1200 feet to the northwest of the AMI site, but its status could not be
determined.
Potential Receptors:
Potential receptors are: construction workers, on -site workers, visitors, trespassers, and
offsite residents along Hahn Road. Note that all those residents that wished to have their
water supply well abandoned and connected to municipal water for their domestic supply
did so previously at AMI's expense.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
groundwater, and indoor air. DEQ relies on the following data to base its conclusions
regarding the subject property and its suitability for its intended reuse.
Soil
Soil data were collected at the Brownfields Property in 1992 and in 1999 based on
staining that was identified during a Phase I environmental site assessment within
proximity to the former chemical storage building at the rear parking area. Impacted soil
that was disturbed to install an air sparge/soil vapor extraction system was excavated,
thermally treated on site by Soil Solutions, stockpiled onsite, and subsequently removed;
reportedly about 224 tons of soil were treated and removed; however, available
documentation does not identify the specific areas nor depths of the soil removal. Hence
concentrations that exceed nonresidential PSRGS are provided in Exhibit 2, although it is
possible that especially the shallow soil was removed during these remedial activities.
Prior soil analyses were limited to cVOC analyses; semi -volatile and metals analyses
were not performed. Concentrations of PCE and TCE were highest at a depth of 12-13
feet below ground surface (bgs) in GP-10, a Geoprobe boring advanced in 1999
downgradient of the chemical storage building at concentrations of 460 milligrams per
kilogram (mg/kg) and 39 mg/kg, respectively. Vinyl chloride was also above its
nonresidential PSRG at 3.7 mg/kg in Geoprobe GP-3 from a depth of 0-3 ft bgs in 1999.
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AMI/I 9025-15-001 /25Jan2023

No additional documentation of later soil sample results is available in DWM's
Laserfiche file.
Groundwater
Shallow groundwater was initially sampled at the Brownfields Property in 1999, and for a
time was periodically monitored, along with deeper bedrock groundwater, through about
2008. Subsequent to that the PD sampled a small subset of the groundwater wells in
2016. Past analyses were limited to VOCs, particularly cVOCs. Primarily, PCE, TCE,
cis-1,2-DCE, and vinyl chloride were detected broadly and at elevated concentrations.
Often sample results indicate large dilution factors were used by the analytical laboratory,
up to 500x in one dataset.
Concentrations of PCE & TCE have decreased over time in certain wells, but remain
substantially elevated over their respective NC 2L standards from a maximum of 56,000
µg/L of PCE in well MW-11 in 2000 to 2,480 µg/L in 2016, and a maximum of 41,000
µg/L in 2004 to 21,000 µg/L in well MW-13 in 2016, and a maximum concentration of
TCE in well DMW-1 at 34,000 µg/L in 2007 to 20,500 µg/L in 2008.
Concentrations of other cVOCs detected above their respective 2L standards in the last
sampling round in either 2008 or 2016 are 1, 1 -dichloroethene (1,1-DCE) up to 13.7 µg/L;
cis-1,2-DCE up to 1,150 µg/L; 1, 1, 1,2-tetrachloroethane (1,1,1,2-TCA) up to 15.5 µg/L;
1,1,2-trichloroethane (1,1,2-TCA) up to 26.3 µg/L; and vinyl chloride up to 463 µg/L.
Many of the most recent groundwater data collected at the Brownfields Property does
exceed their respective Non -Residential Groundwater Vapor Intrusion Screening Levels
(VISLs) for PCE, TCE, 1,1,2-TCE, and vinyl chloride; cis-1,2-DCE is detected in
groundwater but does not have an established VISL.
It's important to note that no building exists at this time over the area with the highest
groundwater concentrations and existing indoor air data collected in 2016 and in 2021
does not indicate that the groundwater conditions are contributing to an indoor air issue
inside the existing building.
Surface Water
Surface water has not been sampled at the Brownfields Property. A storm water
conveyance discharges to an area along the southwestern corner of the larger vacant lot.
Soil samples collected from 1-3 ft bgs at the outfall did not indicate the presence of
VOCs.
Soil Gas
Soil gas sampling was not conducted on the Brownfields Property. IHSB did require soil
vapor testing at nearby residences and noted that one off -site residence with a basement
(1006 Hahn Road) did have soil gas concentrations of PCE and TCE in excess of
residential VISLs in 2014.
Sub -Slab Vapor
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AMI/19025-15-001 /25Jan2023

No sub -slab data is currently available. The PD in 2016 opted to collect only indoor air
samples from within the onsite building and that indoor air sampling was repeated in
October 2021 (see below).
Indoor Air
Ten indoor air samples (IA-1 through IA-10 and one background sample (IA-11) were
collected by the PD's consultant in 2016. The sampling effort was repeated in the same
locations in October 2021. Several compounds were detected in the 2021 indoor air
samples (2-butanone, tetrahydrofuran, 4-methyl-2-pentanone, 1,4-dioxane, chloroform,
carbon tetrachloride, tetrachloroethene, and toluene, but no compounds were detected
above their respective DWM Non -Residential VISLs; there were certain compounds that
were detected for which there is not an established VISL, including
trichlorofluoromethane, ethanol, acetone, and 2-propanol.
Risk Calculations
Risk calculations were performed using the June 2021 DEQ Risk Calculator
https:Hdeq.nc. goy/permits-rules/risk-based-remediation/risk-evaluation-resources.
Changes to the risk calculator did not warrant updating to the January 2022 risk
calculator. For the purposes of looking at the site spatially, the site was viewed in its
entirety. The risk calculations indicated the following based on available data, including
the following media: soil, groundwater, and indoor air.
Risk for Individual Pathways
Version Date: June 2021
Basis: May 2021 EPA RSL Table
Site ID: 19025-15-001
Exposure Unit ID: Site -Wide Max conc gw, soil, indoor air
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carciinnogenic
sk
Hazard Index
Risk exceeded?
Resident
Soil
9.2E-05
1.2E+01
YES
Groundwater Use*
6.8E-02
7.8E+03
YES
Non -Residential Worker
Soil
9.3E-06
2.4E+00
YES
Groundwater Use*
8.6E-03
1.7E+03
YES
Construction Worker
Soil
2.3E-06
1.4E+01
YES
Recreator/Trespasser
Soil
4.8E-05
1.6E+00
YES
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
2.2E-02
4.3E+03
YES
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
2.8E-05
4.0E-01
NO
Non -Residential Worker
Groundwater to Indoor Air
3.3E-03
1.0E+03
YES
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
6.4E-06
9.4E-02
NO
Based on available data, the calculated risk from direct groundwater exposure pathways
exceeds an acceptable carcinogenic risk range and the noncancer hazard index of 1 for
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AMI/19025-15-001 /25Jan2023

both residential and nonresidential exposure scenarios. However, the property is hooked
up to municipal well water and the groundwater is not used for any purpose; it will be
further prohibited by the land use restrictions in the Brownfields Agreement.
The calculated risk values for direct exposure to soil exceeds the noncancer hazard index
of 1 for residential, nonresidential, construction worker, and recreator/trespasser
scenarios. Land use restrictions regarding the contact with site soil will be included in
the Brownfields Agreement.
Although the calculated risks for the groundwater to indoor air exposure pathway exceeds
an acceptable environmental risk range carcinogenic risk and exceeds the noncancer
hazard index threshold value of 1, the actual indoor air sampling conducted in the
existing building both in 2016 and in 2021 indicates that the calculated risk based on the
indoor air data does not exceed the acceptable environmental carcinogenic risk nor does
it exceed a noncancer hazard index of 1.
No exterior soil gas nor sub -slab data were collected at this site. It should be noted that
the contaminated groundwater plume does not appear to be located below the existing
building and with the exception of small concentrations of PCE in indoor air in two
indoor air samples that are below non-residential VISLs, the known contaminated area at
the site does not appear to create an indoor air exposure to site compounds of concern.
However, if new construction occurred over the plume area, or if the existing building is
modified, additional vapor intrusion assessment should be conducted and, if warranted,
appropriate mitigation measures should be employed for these areas.
The Brownfields Agreement will include the standard brownfields land use restrictions as
to allowable land uses, groundwater use prohibition, soil disturbance, soil export/import,
EMP, abandonment of wells, redevelopment reporting, notice, agreement not to use
products onsite containing known site contaminants, and the annual obligation of the land
use restriction update submittal. In addition, residential use and childcare centers, adult
care centers, and schools are not approved uses unless DEQ provides written approval.
Based on the site -specific data provided to the Brownfield program, the site can be made
suitable for the intended reuses as long as the agreed upon land use restrictions in the
BFA are abided by.
Brownfields Property Management Unit:
VI does not appear to be occurring in the existing building in excess of acceptable
environmental risk ranges; however, the release that caused the groundwater
contamination with chlorinated solvents was located west of the building. Should new
construction be contemplated at the site or the existing building foundation be modified,
additional VI assessment, and if warranted, VI mitigation measures should be employed
accordingly.
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AMI/19025-15-001 /25Jan2023