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Home My WebLink About19039_Oneida_Mill_Decision_Memo_20161014Oneida Mills_Decision Memo October 14, 2016 DECISION MEMORANDUM FROM: Lebeed Kady TO: BF Assessment File RE: Oneida Mills 219 W Harden Street Graham, Alamance County BF # 19039-15-01 Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than multi-family residential and associated parking, can be made suitable for such uses. Introduction: The property is comprised of one parcel (parcel ID 145558) totaling approximately 6.84 acres. The Property is currently owned by the Prospective Developer, who purchased the property from Jay Burke Rentals, Inc. on October 28, 2015, to whom Kayser-Roth sold the Property in 2008. Jay Burke Rentals, Inc. had originally applied to the Brownfields Program in June 2, 2008, but on August 6, 2011 the application was put on No Further Interest (NFI) status. This agreement is based on a second application from a different developer. Redevelopment Plans: The Prospective Developer (PD) intends to invest $15,700,000 for the redevelopment of the property that will provide public benefits in the form of multi-family housing to the surrounding area. The proposed development transforms a vacant, blighted property into much needed affordable housing for workforce and families. The new housing stock will attract wage earners to the local community which leads to economic growth for the area. All buildings on site: building 1, building 1 annex, building 2, building 3, building 4 are all existing historic structures being renovated into apartments. There are no new buildings on site. The mill is being redeveloped under the Park Service’s historic tax credit program and as such, some additions from 1960 are being removed leaving the pre- 1960’s mill for loft apartments. Site History: The Property was initially developed in the 1800s as a textile mill and was owned by Oneida Mills, a cotton mill and yarn throwing operation. Oneida Mills owned and operated the facility from around 1898 to the 1930s. In the late 1930s to 1940s, the Property was purchased by Burlington Mills, which continued the cotton mill operations at the site. During their occupation of the Property until the 1950s, Burlington Mills shifted their operations to rayon manufacturing. Kayser-Roth Hosiery Co. began Oneida Mills_Decision Memo operating at the Property in the 1950s, continuing the rayon manufacturing process until at least 1994. In addition to the Property’s use as a textile mill, associated warehousing and trucking activities have occurred on the Property. In the 1970s Kayser-Roth began using the facility primarily as a truck transportation terminal. Since the mid to late 1990’s, the Property has been vacant and no operations other than environmental sampling have occurred. The Property is listed under the Resource Conservation and Recovery Act (RCRA) as a non-generator, meaning that no hazardous waste is currently being generated at the Property. The Property is also listed as a State Hazardous Waste Site (SHWS). The Property is listed with the Inactive Hazardous Site’s (IHSB) branch of DEQ (Incident # 21742) due to the presence of chlorinated solvents in the groundwater and soil at the Property. The source of the chlorinated solvents is likely the present and historic dry cleaner located directly across W Harden Street to the south of the Property. In May 1989 a 11,000-gallon underground storage tank (UST) was removed from the Property by GSX Tank Management, Inc. In September 1993, 1007.32 tons of petroleum-impacted soil associated with a former 12,000-gallon above ground storage tank (AST) containing #5 fuel oil was removed by Four Seasons Environmental, Inc. These ASTs were removed in November 1993 by Four Seasons Environmental, Inc. Uncontaminated concrete support pillars (used for support of the former AST) abandoned fuel lines and natural gas lines that were encountered during soil remediation activities were also removed in November 1993. In addition to the 1007.32 tons of contaminated soil removed, uncontaminated debris removed totaled 80 tons and contaminated debris removed from the property totaled 3.05 tons. Impacted soils and other removed materials were transported to licensed facilities based on the materials hazardous classification. A No Further Action (NFA) letter regarding the USTs was issued to Kayser Roth by DEQ’s predecessor, NCDEHNR, in July 1994. Three contaminants were detected in Sub-slab soil gas sampling in September 11, 2013. None of the contaminants were above residential screening levels. The Prospective Developer (PD) proposed installing a Vapor Intrusion Mitigation System (VIMS) beneath buildings slabs and within crawl space areas of three buildings at the site as shown in plat for buildings 2, 3, and 4. This is also demonstrated in the Sub Slab Vapor Mitigation System Report of January 8, 2016. As for building 1 and building 1 Annex the, PD investigated them further by conducting indoor air sampling reported in the “Indoor Air Sampling Report” dated July 13, 2016. None of the six indoor air samples exceeded IHSB Residential Screening values for the contaminants of concern. Consequently, chemical vapor intrusion is not occurring through the concrete floor in the buildings on the property. Potential Receptors: Potential receptors are construction workers, onsite workers, future residents, visitors, and trespassers. Oneida Mills_Decision Memo Contaminated Media: DEQ has evaluated data collected from the following media at the subject property: soil, groundwater, Soil Vapor 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 was found to be contaminated above Preliminary Residential Health-based Soil Remediation Goals (PSRG) of the Inactive Hazardous Sites Branch of DEQ’s Superfund Section (April 2016 version) in areas designated as parking lots or with the VIMS area and with s depth of 2-3 feet. The contaminants metals arsenic and cadmium are in locations B-7 and B-8 areas where former “Drug House”, “Waste House, and “Oil Room” were once located; volatile organic compounds (VOCs) tetrachloroethylene (PCE) and trichloroethylene (TCE); petroleum hydrocarbons (TPH-DRO); and polyaromatic hydrocarbons (PAHs) benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluroanthene, and indeno(1,2,3-cd)pyrene in the location of B-1, B-2 and B-3 former area of electrical transformers and location B-7 and B-8 former Drug House. Groundwater Groundwater samples obtained from the area of the old warehouse and Drug House were found to contain VOCs benzene, PCE and TCE contaminated above their respective standards from Title 15A of the North Carolina Administrative Code, Subpart 2L (2L), Rule .0202 (April 1, 2013 version); or the 2L Groundwater Interim Maximum Allowable Concentration (IMACs), (April 1, 2013 version). Soil Vapor Soil Vapor samples were collected from sub-slab at building 1, building 2 and the former warehouse locations. Concentrations showed exceedances to the Sub-slab or Exterior Soil Gas Concentration to Indoor Air concentrations screening limits for residential vapor intrusion screening levels (VISL) of the Division of Waste Management (November 2015 version). Sub-slab concentrations were higher for Benzene, 1,2,4-Trimethylbenzene, and M&p-Xylene. The Property will have a parking lot in the area of former warehouse. Building 2 will have a VIMS installed. While building 1 was sampled again in June 23, 2016 for the contaminants of concern. Six indoor air quality samples were collected and it does not appear that chemical vapor intrusion is occurring in building 1. Risk Calculations Risk Calculations were performed using Excel worksheets provided by Sandy Mort, NCDEQ Toxicologist. The risk calculations indicated the following based on available data, including the following media: groundwater, residual soil (based on confirmatory soil data), and indoor air samples: Oneida Mills_Decision Memo LICR HI LICR HI Groundwater MW‐1‐10 7.40E‐04 1.61E+02 1.70E‐05 3.84E+01 Soil Combine 7.90E‐04 2.70E+02 9.36E‐05 5.76+01 Sub‐Slab Vapor Bldg 15.10E‐07 5.64E‐02 3.90E‐08 4.48E‐03 Medium Location Summary Table: Oneida Mills Residential Non‐Residential Red shading LICR> 1E-04 or HI> 1. LICR = Lifetime Incremental Cancer Risk HI = Hazard Index The Brownfields site will have land use restrictions on using groundwater for any purpose. Areas with soil contamination will have no residential buildings, only parking lots established on contaminated areas. Areas with Sub-slab Vapor concentrations exceedances are covered either via a Vapor Intrusion Mitigation System (Buildings 2, 3 and 4), or are tested to be below risk for residential use (Building 1 and Building 1 Annex). Work to Be Performed: Although risk calculations were determined to be low for residential limits, the PD performed additional sampling for indoor air. Analysis performed confirmed that areas of Building 1 and Annex Building 1 are safe for residential use. Required Land Use Restrictions: Land use restrictions will include standard LURs and as set below: 1. No use may be made of the Property other than for multi-family residential and associated parking in specified areas in the plat; 2. Physical redevelopment of the Property may not occur other than in accord, as determined by DEQ, with an Environmental Management Plan (“EMP”) approved in writing by DEQ in advance; 3. Groundwater may not be used without prior written approval from DEQ 4. No building maybe constructed or occupied without addressing vapor intrusion issues to DEQ satisfaction; and 5. Property owner must submit an annual Land Use Restrictions Update to DEQ, to the chief public health and environmental officials of Wake County certifying compliance with the land use restrictions. 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.