21050_South Saunders Street_DM_20230428

DECISION MEMORANDUM
DATE: April 28, 2023
FROM: Kelly Johnson/Sharon Eckard
TO: BF Assessment File
RE: South Saunders Street Assemblage
0 South Dawson Street; 0 Green Street; 1019 Mount Hope Drive; and
0, 927, 951,1001, 1015, 1017, 1019, 1021, 1021 B, 1023, 1025, 1027,
1029, 1031, 1033, 1035, 1041 South Saunders Street
Raleigh, Wake County
BF Project No. 21050-17-092
Based on the following information, it has been determined that the above -referenced
site, whose intended use is for no uses other than office, parking, retail, high -density
residential, greenway, open space, and subject to DEQ's prior written approval, other
commercial uses, can be made suitable for such uses.
Introduction:
The Prospective Developer (PD) is CS Smith, LLC, a member -managed limited liability
company, headquartered at 2321 Blue Ridge Road, Suite 202, Raleigh, North Carolina
27607. The Manager of the PD entity is Christopher L. Woody II, located at the same
address.
The Brownfields Property is a multi -parcel property totaling 9.15 acres that as originally
applied for was comprised of 20 contiguous parcels; however due to recombination
activity, three of the original parcels were combined into one parcel as noted below.
Rocky Branch Creek forms the northeastern boundary of the Brownfields Property.
The Brownfields Property is located in Raleigh, Wake County at the following addresses:
• 0 Green Street, PIN 1703-44-3170;
• 1019 Mount Hope Drive, PIN 1703-44-4408;
• 0 South Saunders Street, PIN 1703-44-2220;
• 927 South Saunders Street, assigned new PIN 1703-44-4767 (which was
recombined in December 2021 with the parcels formerly addressed as 0 South
Dawson Street, and 951 and 1001 South Saunders Street and portions of parcels
with addresses 1019 Mouth Hope Drive and 1015, 1017, and 1027 South
Saunders Street);
• 1015 South Saunders Street, PIN 1703-44-2683;
• 1017 South Saunders Street, PIN 1703-44-2592;
• 1019 South Saunders Street, PIN 1703-44-3412;
• 1021 South Saunders Street, PIN 1703-44-2374;
• 1021B South Saunders Street, PIN 1703-44-2339;
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• 1023 South Saunders Street, PIN 1703-44-3208;
• 1025 South Saunders Street, PIN 1703-44-4351;
• 1027 South Saunders Street, PIN 1703-44-4451;
• 1029 South Saunders Street, PIN 1703-44-3344;
• 1031 South Saunders Street, PIN 1703-44-4149;
• 1033 South Saunders Street, PIN 1703-44-3285;
• 1035 South Saunders Street, PIN 1703-44-2220; and
• 1041 South Saunders Street, PIN 1703-44-2069
Currently, the northern portion of the Brownfields Property is currently undergoing
construction and all former residences on the southern portion of the Brownfields
Property have been demolished and this portion of the Brownfields Property is vacant.
Redevelopment Plans:
The PD plans to redevelop the Brownfields Property in phases and is currently
constructing four connected seven to eleven story multi -use buildings on the northern
portion of the Brownfields Property with office, retail, high -density residential, and
parking uses, including a large central parking deck. Pre -construction activities for the
construction in the north began in December 2021. Based on the data collected at the
Brownfields Property, vapor intrusion mitigation was indicated for residential use of the
northern portion of the Brownfields Property. A Vapor Intrusion Mitigation plan dated
April 14, 2022 for the northern portion of the Brownfields Property was determined to be
compliant with anticipated land use restrictions on May 19, 2022.
Based on the commercial nature of former businesses along S. Saunders Street, although
the southern area of the Brownfields Property has been vacant, a vapor intrusion
assessment should be conducted prior to any construction of buildings on that part of the
property to evaluate the need for a vapor intrusion mitigation system.
Site History:
In general, the Brownfields Property has had numerous commercial uses on the central to
northern portions of the site and primarily residential uses on the southern portion of the
site. Commercial activities have included a metal fabrication shop; carpet cleaner
company; gas station; towing business; automotive service and repair.
There does not appear to be Sanborn Fire Insurance map coverage for this area. The
earliest available aerial photograph available for the site is from 1938. Based on this
1938 aerial, the Brownfields Property was developed with several structures that appear
to be residences on the southern portion, an agricultural field near the center, and a large
structure, possibly commercial, at the middle western portion of the Brownfields Property
possibly coinciding with the 1015 South Saunders Street address.
At the time of the Brownfields Property Application, 1015 S. Saunders Street was used as
an automotive repair shop and towing business; 1017 South Saunders Street was an
automotive sales center and repair shop; 1001 South Saunders was a metal fabrication
shop; 927 South Saunders Street was a non-profit automotive sales and repair center;
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1021 and 1021 B South Saunders Street was occupied by residences; and the following
addresses were vacant and undeveloped: 0, 951, 1019, 1023, 1025, 1027, 1029, 1031,
1033, 1035, 1041 South Saunders Street, 1019 Mount Hope Drive, 0 South Dawson
Street, and 0 Green Street.
Regulatory actions at the Brownfields Property includes the following:
• 927 South Saunders Street, former R.B. Stokes Concrete Co., LUST Database #
11802 and NC DEQ UST Database # RA-1923:
o UST status listed as temporarily closed. A release was reported in May
1993 when petroleum contamination exceeding NC 2L groundwater
standards was discovered in a monitoring well associated with a 2,000-
gallon gasoline UST that was reportedly operated from approximately
1957 until 1987.
o According to City Directories, a foundry operated at the site from at least
1941-1947, which corroborates interview information contained in a May
31, 1994 Comprehensive Site Assessment retrieved from the DEQ public
file repository, Laserfiche.
o The now demolished structure for the R.B. Stokes Concrete Co was
originally constructed in 1953. Wheels 4 Hope which was a charity
automotive repair and sales facility operated at 927 South Saunders at the
time of the Brownfields Property Application, but ceased operations
before the property was acquired by the PD.
• 1001 South Saunders Street (now recombined with the parcel with address 927
South Saunders Street):
o former location of N.A. Dunn Oil Company, LUST Database # 33036 and
UST Database # RA-5496.
o According to the NC DEQ UST Section, files have been misplaced for this
site and unavailable; however, a release was reported in February 2006
and the site formerly operated one 10,000-gallon diesel UST, one 7,500-
gallon gasoline UST, two 4,000-gallon gasoline USTs, and one 4,000-
gallon kerosene UST.
o A Limited Site Assessment was reportedly conducted and a
Comprehensive Site Assessment was requested by the UST Section but it
does not appear to have been completed.
Regulatory actions or pertinent environmental information regarding adjacent properties
includes:
• Adjacent to the north of the Brownfields Property, across Rocky Branch Creek, at
901 South Saunders Street is the site of a historical release noted in the NC DEQ
UST Database as Ervin Radiator Works assigned Incident No. 11803. This
incident resulted in the removal of four USTs and while the most recent
environmental report available on Laserfiche dated June 29, 1995 recommended
further action by the consultant, there is no information that this site is closed out
or issued a no further action letter. This property is now developed with the
Gateway Park apartment complex.
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• Adjacent to the west of the Brownfields Property, across South Saunders Street, at
1014 & 1010 South Saunders Street is a documented release with a No Further
Action Letter issued on October 15, 1991. East Carolina Metal Treat, Inc.
operated at this address that heat treated metals using water and oil quench baths
containing sodium cyanide salts, sodium carbonate, and calcium carbonate with
operations reportedly beginning in 1975. Used bath wastes were reportedly
poured onto a dirt parking lot on a regular basis until 1981 and sampling of soils
in the area indicated the presence of total cyanides, barium, cadmium, chromium,
lead, and silver; however, note that the regulatory files containing the actual
concentrations of these metals in soils have not been located. However, according
to the 1991 No Further Action letter, the concentrations of metals within soil were
compared against worker exposure and residential adult and child exposure
scenarios and below health -based cleanup levels. This site has been operated by
Axis Holdings Company since November 2012, which produces essential oils via
extraction from botanical sources according to a DEQ Hazardous Waste Section
report associated with a site visit on August 17, 2015. This site visit was in
response to a fire at this facility on August 15, 2015 that consumed four 55-gallon
drums of methanol.
• A drycleaners, Kwiklean Cleaners, is located to the west, across South Saunders
Street, at 1004 South Saunders Street. There are no known releases from these
operations; however, there is no known environmental sampling data available for
this cleaners. According to the most recent Dry Cleaning Solvent Act (DSCA)
Compliance Program document dated September 15, 2017, the site has operated
as a dry cleaner since 1978 and while it still has one dry cleaning machine
installed in 1997 that uses perchloroethylene (PCE), it is no longer used for dry
cleaning operation as the facility operates as a pick-up store only. Note that the
machine is still present and regularly maintained in case the owner needs to
operate the machine if his primary machine at a different site goes down.
Potential Receptors:
Potential receptors are construction workers, on -site workers, future residents, visitors,
and trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property:
Groundwater, soil, sub -slab soil vapor, surface water, and stream sediment. 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).
Risk Calculations:
Risk calculations were performed using the January 2023 DEQ Risk Calculator
https:Hdeq.nc. goy/permits-rules/risk-based-remediation/risk-evaluation-resources.
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For the purposes of looking at the site spatially, the site was evaluated as a whole with
maximum concentrations of each contaminant. There is a separate calculator for the
surface water and stream sediment to not interfere with soil sample risk calculations.
The risk calculations indicated the following based on available data, including the
following media: groundwater, soil, and sub -slab vapor. Note a separate calculation was
made for surface water and stream sediment.
Site -Wide Soil, GW & Sub -Slab Vapor:
Risk for Individual Pathways MR. RRIM11,
Version Date: January 2023
Basis: November 2022 EPA RSL Table
Site ID: 21050-17-092
Exposure Unit ID: All Site Media 2018-2019 excl SW and Sediment
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carc�skenic
Hazard Index
Risk exceeded?
Resident
Soil
1.8E_04
1.7E+00
YES
Groundwater Use*
1.2E-02
2.8E+02
YES
Non -Residential Worker
Soil
1.2E-05
1.4E-01
NO
Groundwater Use*
3.3E-03
6.6E+01
YES
Construction Worker
Soil
2.9E-06
2.1E+00
YES
Reereator/Trespasser
Soil
-- ------------------------
-------- -------
Surface Water*
1.0E-04
NC
9.4E-01
YES
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
7.7E-04
3.4E+01
YES
Soil Gas to Indoor Air
2.2E-04
2.3E+01
YES
Indoor Air
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
1.8E-04
8.2E+00
YES
Sort Gas to Indoor Air
1.6E-05
1.9E+00
YES
Indoor Air
NC
NC
NC
soil
• The maximum contaminant concentration values in soil samples, which were
primarily collected along South Saunders Street around the former auto repair
buildings from depths 1 to 2 feet below ground surface (bgs), with some samples
to 6 feet bgs, exceed both residential and non-residential PSRGs. Applying these
maximum contaminant values across the site yields a calculated carcinogenic risk
(CR) that exceeds the acceptable regulatory CR of lE-4 and the noncancer
threshold hazard index (HI) of 1 for direct exposure in residential settings. Soil
HI values exceed 1.0 for construction worker and are just under 1.0 for
recreator/trespasser exposures. The calculated CR and HI for non-residential
worker exposure to site soil does not exceed either of these risk thresholds.
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• Note that soil represented by soil boring locations, SB-4, SB-7, SB-9, and SB-11,
was relocated on -site to the area noted on the plat beneath the northeast corner of
the parking garage in the central portion of the Brownfields Property.
• Asbestos containing soils (ACS) and asbestos containing materials (ACM) were
discovered during grading activities on March 29, 2022. The ACS and ACMs are
likely associated with historical use of the Brownfields Property as residential and
mixed commercial uses, and the majority of the ACS and ACM were
cementitious building siding material (commonly referred to as "transite"). Other
forms of observed suspect ACMs generally included building materials such as
roofing materials, floor materials, mastic, and some insulation materials. DEQ
Brownfields was kept in the loop and conducted a site visit; however, Hart &
Hickman, Mr. Jeff Dellinger, an Industrial Hygiene Consultant Supervisor with
the DHHS, and Enpuricon handled work plans, on -site management, and export
of these asbestos containing materials. From April through August 2022,
approximately 16,086.89 tons of ACS and ACMs were transported off -site for
disposal at GEL's Red Rock Disposal landfill, 7130 New Landfill Drive, Holly
Springs, NC.
• To reach final grades, approximately 28,420 cubic yards (cy) of soil were
imported to the Brownfields Property from Martin Marietta's quarry located at
1111 E. Garner Road in Garner, NC. According to conversations between Martin
Marietta and Hart & Hickman, the soil obtained from the quarry was virgin
overburden. Soil samples for VOCs, SVOCs, RCRA Metals, and hexavalent
chromium did not exhibit any VOCs or SVOCs above the laboratory reporting
limit and metals with similar concentrations had been already observed on -site,
and possibly attributable to natural background conditions. This soil import was
approved by Brownfields via email on March 24, 2022.
• An abandoned approximately 4,000-gallon UST was encountered during
excavation activities in the central portion of the northern half of the Brownfields
Property. The UST was removed and soil surrounding the tank was excavated,
placed on plastic, and stockpiled before being exported to Triangle Area Earth
Corporation, a permitted bioremediation soil farm located at 336 Denton Lane in
Zebulon. A soil sample from the bottom of the excavation and one sample from
the stockpiled soils were collected; the sample from the base of the excavation pit
exhibited 1,4-dichlorobenzene, arsenic, and hexavalent chromium above their
respective residential PSRGs.
• Approximately 125.51 tons of soil were exported during June 2022 to Triangle
Area Earth Corporation, a permitted bioremediation soil farm located at 336
Denton Lane in Zebulon, NC. DEQ Brownfields approved this export via email
on March 31, 2022.
• Approximately 800 cy of stockpiled soils on the Brownfields Property were
exported from the site to GFL's Red Rock C&D Landfill in Holly Springs, NC.
Based on requirements of the landfill, soil samples were collected for analysis for
the seven Toxic Characteristic Leaching Potential (TCLP) metals, TCLP VOCs,
TCLP SVOCs, total PCBs, total petroleum hydrocarbons (TPH) Gasoline Range
Organics (GRO), TPH Diesel Range Organics (DRO), and oil & grease with silica
gel wash. Based on the analytical results, the landfill accepted transfer of these
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soils. DEQ Brownfields requested confirmation that soils exported to this landfill
would be the final location of these soils in perpetuity which Hart & Hickman
stated was true in an email dated January 26, 2023. DEQ Brownfields stated that
they have no objections to export of these soils to the above referenced landfill in
an email dated January 26, 2023.
• One temporary above ground storage tank (AST) used for equipment refueling
was located at the location of TEMP-AST-081022 as reported in the
Redevelopment Summary Report dated December 29, 2022. Once this temporary
AST was removed, a soil sample was collected from below the tank, which did
not exhibit VOCs but did exhibit SVOCs benzo(a)anthracene, benzo(a)pyrene,
and benzo(b)fluoranthene above their respective residential PSRGs.
• In accordance with the approved EMP, final grade sampling will be conducted
with results submitted to DEQ Brownfields which will better define site
conditions following development activities and risk to the public.
Groundwater
• Depth to groundwater is approximately 7 to 20 bgs at the Brownfields Property
and was observed to flow to the northeast toward Rocky Branch Creek.
Groundwater contaminants are believed to be from onsite sources. Additionally,
there are at least one or two nearby releases that are either upgradient or cross
gradient located west of the Brownfields Property, across South Saunders Street.
• Based on the risk calculator output, the acceptable regulatory CR of lE-4 and the
threshold noncancer HI of 1.0 are exceeded for direct exposure to groundwater in
both residential and non-residential scenarios, and are exceeded for the
groundwater to indoor air calculation for both residential and non-residential
exposure scenarios.
• For direct exposure to groundwater, the primary contaminants driving
carcinogenic risk appear to be ethylbenzene and naphthalene and the primary
contaminants contributing to the HI include benzene, cis,1,2-dichloroethylene,
ethylbenzene, 1-methylnaphthalene, 2-methylnaphthalene, naphthalene, toluene,
trichloroethylene, and xylenes.
• For the groundwater to indoor air pathway, the primary CR and HI risk drivers
include benzene, ethylbenzene, naphthalene, and xylenes.
• There appears to be no evidence that groundwater impacts are causing off -site
issues, though a low concentration of TCE was detected in the surface water of
the neighboring stream, but at a concentration that did not trigger a risk
exceedance for exposures to surface water.
• According to the Redevelopment Summary Report dated December 29, 2022,
existing monitoring wells MW-3 and MW-7 were abandoned on February 2, 2022
in accordance with anticipated land use restrictions and because development
activities would have damaged these wells. Well abandonment records indicate
that MW-3 and MW-7 were approximately 25 feet deep and 20 feet deep,
respectively.
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Exterior Soil Gas
• Sub -slab soil gas sampling was conducted at on -site buildings prior to their
demolition; these structures were suspected to be closer to potential impacts so no
exterior soil gas was collected.
Sub -Slab Vapor
• Sub -slab vapor samples were collected from the structures before demolition
activities to understand vapor intrusion risk at the site.
• Based on the risk calculator output, the acceptable regulatory CR of lE-4 and the
threshold HI of 1.0 are exceeded for soil gas to indoor air risk in residential
scenarios and the HI of 1.0 is exceeded for non-residential exposure scenarios.
• For soil gas to indoor air risk calculations, the primary contaminants driving the
risk include benzene, 1, 1 -dichloroethylene, tetrachloroethylene, 1,1,1-
trichloroethane, trichloroethylene, 1,2,4-trimethylbenzene, 1,3,5-
trimethylbenzene, and xylenes. It is important to note that 1, 1 -dichloroethylene,
tetrachloroethylene, and trichloroethylene were the largest contributors to the HI.
• Based on results of the sub -slab soil vapor sampling, vapor intrusion mitigation is
required for the Brownfields Property.
Indoor Air
• Because the previous structures were planned to be vacated upon purchase by the
PD and subsequently demolished, indoor air was not collected at the site.
Surface Water & Sediment — NE boundary
Risk for Individual Pathways
Version Date: January 2023
Basis: November 2022 EPA RSL Table
Site ID: 21050-17-092
Ex sure Unit ID: Surface Water & Sediment
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardlndex
Risk exceeded?
Resident
Soil
7.3E-06
8.7E-02
NO
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
7.2E-07
6.9E-03
NO
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
3.6E-07
7.0E-02
NO
Recreator/Trespasser
Soil
4.0E-06
4.7E-02
NO
Surface Water*
1.1E-06
4.0E-02
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carci nogenic
Risk
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
NC
NC
NC
Stream Sediment
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• While the calculated risk values do not indicate an exceedance of an acceptable
CR or HI, note that trichloroethylene was reported at a laboratory estimated value
(above the laboratory method detection limit but below the laboratory reporting
limit) in the downstream surface water sample SW-3; however, the estimated
concentration of TCE in sample SW-3 is below the 2B standard.
Land Use Restrictions:
LURs will include the standard land use restrictions including approved uses, land use
definitions, prohibition on adult or childcare facilities, requirement for an EMP,
groundwater, soil disturbance, known contaminants, access, notification, monitoring well,
vapor intrusion, surface water, and land use restriction update LURs.
Based on the site -specific data provided to the Brownfield Redevelopment Section, 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
The site is currently undergoing construction on the northern portion of the Brownfields
Property. The northern portion has an EMP approved on December 8, 2021 and the
structures are being built under a vapor intrusion mitigation plan that was determined to
be compliant with anticipated land use restrictions on May 19, 2021. The vapor intrusion
mitigation plan has requirements for pre- and post -occupancy sampling.
Future development will include the southern portion, which will require a separate EMP
and further assessment to evaluate the need for vapor intrusion mitigation in this area for
future buildings. PD had attempted to add laboratory use to the approved land uses, but
could provide no details about the type of lab, chemical compounds that would be in use,
nor its proposed location. Also there was no assessment in the southern area of the site so
one could not use the exceptions for chemical use for a lab as it is not known that Exhibit
2 is complete. Therefore, laboratory use was excluded at this time, but the PD was
notified that with further details, it was possible that the laboratory use could be
considered under the additional commercial use clause.
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