HomeMy WebLinkAbout20086_Chadbourn_Mill_Decision-Memo_20170712DECISION MEMORANDUM
DATE: July 12, 2017
FROM: Bill Schmithorst
TO: Brownfields Agreement File
RE: Former Chadbourn Mill
451 Jordan Place & 2625 North Davidson Street
Charlotte, Mecklenburg County
BF # 20086-16-060
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than high density multi-family residential,
retail uses, office, hotel, warehousing, recreational, open space, and parking, can be made
suitable for such uses.
Introduction:
The Brownfields Property is approximately 5.75 acres and it contains a building formerly
occupied by a hosiery mill facility with a free-standing building that was occupied by a
boiler (Exhibit 1). The property is surrounded by land in commercial, industrial, and
residential use; bordered to the north by Charles Avenue and residential uses, to the south
by land used for commercial, industrial and residential uses, to the east by N. Davidson
Street and a Neese Sausage facility, and to the west by a Duke Power sub-station on N.
Brevard Street.
Redevelopment Plans:
Redevelopment plans for the Brownfields Property include high density multi-family
residential, retail, office, hotel, warehousing, recreation, brewery, open space, and
parking uses following site demolition and regrading activities.
Site History:
North-central portions of the Brownfields Property were developed with residences as
early as 1929. By 1938, a portion of the existing mill building was present along N.
Brevard Street. Several additions to the mill building including a dye house, machine
shop, free-standing boiler building, and smokestack were constructed in the 1940s. A
warehouse addition on the northeastern portion of the mill building was completed in the
1960s.
The current building on the Brownfields Property was initially occupied by Rufus D.
Wilson, Inc. and operated as a hosiery mill from the mid to late 1930s until the mid-
1940s. In the mid-1940s, the Rufus D. Wilson company acquired Larkwood Silk Hosiery
Mills, Inc. and changed the name of the mill to Chadbourn Hosiery Mill, Inc. In the mid-
1950s, Chadbourn Mill acquired Gotham Hosiery mill and changed its name to
Chadbourn-Gotham Mill, Inc. Chadbourn-Gotham Mill continued hosiery manufacturing
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operations at the Site until the mid to late 1970s. Since that time, the mill building was
used for warehouse space and storage. Opera Carolina utilized portions of the building
for a short time in the 2010s. The mill building is currently unoccupied.
North-central and northeastern portions of the Brownfields Property were developed with
residences and mill administrative offices from the 1930s until the mid to late 1970s. By
the 1980s, structures in north-central and northeastern portions of the Brownfields
Property had been removed. The eastern and southeastern portions of the Brownfields
Property were developed with residences from the late 1930s to the early 1980s when the
residences were removed. The parcel in the northeastern portion of the Brownfields
Property was most recently utilized by a construction contractor for storage of equipment
and materials. The eastern half of the Brownfields Property is currently vacant
undeveloped land.
The Prospective Developer purchased the Brownfields Property in December 2015. The
451 Jordan Place parcel containing the mill building was purchased from Wellmon
Family, LP, and the smaller vacant 2625 N. Davidson Street parcel was purchased from
2625 N. Davidson, LLC.
Potential Receptors:
Potential receptors are: construction workers, on-site workers, residents, customers,
vendors, and trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
soil-gas, and groundwater. A summary of highest detections exceeding screening levels is
provided in Exhibit 2. DEQ relies on the following data to base its conclusions regarding
the subject property and its suitability for its intended reuse. Refer to the following
reports for site specific data used for evaluation of site risks.
Title Prepared by Date of Report
Supplemental Soil Assessment Activities,
Chadbourn Mill, 451 Jordan Place & 2625 N.
Davidson Street
Hart & Hickman May 9, 2017
Brownfields Assessment Report, Chadbourn Mill,
451 Jordan Place & 2625 N. Davidson Street
Hart & Hickman February 17, 2017
Phase I and II Environmental Site Assessment
Report, Former Chadbourn Mill, 451 Jordan Place
Hart & Hickman November 9, 2016
Limited Site Investigation Report, Chadbourn Mill,
451 Jordan Place
Terracon Consultants,
Inc.
September 7, 2016
Phase I Environmental Site Assessment, Wellmon
– 751 Jordan Place, Charlotte, NC
Summit Engineering and
Construction Services,
Inc.
September 1, 2015
Phase I Environmental Site Assessment, UCI, LLC
Property – 2625 N. Davidson Street, Charlotte, NC
Danner Enterprises, LLC
t/a Salem Environmental
March 31, 2015
Limited Soil Sampling and Analysis – 2625 N.
Davidson Street, Charlotte, NC
Boyle Consulting
Engineers
December 30, 2014
Chadbourn Mill Decision Memo
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Soil
Six soil samples and two background soil samples were collected on September 30, 2016.
Each sample was analyzed for VOCs (EPA Method 8260B), SVOCs (EPA Method
8270D) and Metals (EPA Methods 6010D/7471B/7196A). Soil samples were screened in
the field for VOCs from ground surface to the final boring depth using a PID, and soil
samples were submitted for laboratory analysis from the boring interval showing the
highest PID reading or visual evidence of potential contamination. Soil contaminants
above residential screening levels include: arsenic, lead, manganese, and thallium. As
shown in the table below, the highest concentrations detected were above the calculated
Hazard Index of 1.
Groundwater
Groundwater samples were collected from three temporary wells TMW-1 and TMW-3 on
September 30, 2016 and TMW-2 on October 3, 2016. Additional groundwater samples
were collected from temporary monitoring well TMW-4 on January 27, 2017. Each of the
samples was submitted to a laboratory for analysis of VOCs (EPA Method 8260B),
SVOCs (EPA Method 8270D) and Metals (EPA Methods 6020A-B/7470A).
Groundwater contaminants above the NCAC 2L Standard include:
bromodichloromethane, manganese, and trichloroethene. As shown in the table below,
the highest concentrations were above the calculated Hazard Index of 1.
Sub-Slab Soil Vapor
Two sub-slab samples (SV-02 and SV-03) were collected from the mill building and one
sub-slab sample (SV-01) was collected from the boiler building on September 28, 2016.
Each sample was submitted for laboratory analysis of VOCs by USEPA Method TO-15.
Sub-slab soil vapor contaminants detected above IHSB Residential Screening Levels
include: Trichloroethylene, 1,4-Dichlorobenzene, and Naphthalene. As shown in the table
below, the highest concentrations were above the calculated Hazard Index of 1.
Soil Vapor
Soil vapor samples were collected on September 29, 2016 from six vapor monitoring
points located within the footprint of the proposed mixed-use buildings and were
submitted for laboratory analysis of VOCs by USEPA Method TO-15. Soil vapor
contaminants detected above IHSB Residential Screening Levels include: Benzene,
Chloroform, Ethylbenzene, Hexane, Naphthalene, Tetrachloroethene, Trichloroethylene,
1,2,4-Trimethylbenzene, Xylenes. As shown in the table below, the highest
concentrations were below the calculated Hazard Index of 1.
Indoor Soil Vapor
Two indoor air samples were collected from the mill building (IAS-2 and IAS-3) on
January 27, 2017 and one indoor air sample (IAS-1) was collected from the boiler
building. Indoor air soil vapor contaminants detected above IHSB Residential Screening
Levels include Naphthalene which was detected in the mill building. As shown in the
table below, the highest concentrations were below the calculated Hazard Index of 1.
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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, subsurface residual soil,
soil gas, and indoor air:
PRIMARY CALCULATORS
Receptor Pathway Carcinogenic
Risk
Hazard
Index
Risk
exceeded?
Resident Soil Combined
Pathways
5.3E-06 2.5E+00 YES
Groundwater
Combined Pathways
1.5E-04 9.8E+00 YES
Non-Residential
Worker
Soil Combined
Pathways
1.0E-06 1.7E-01 NO
Groundwater
Combined Pathways
1.3E-05 1.9E+00 YES
Construction
Worker
Soil Combined
Pathways
3.0E-07 1.4E+01 YES
VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic
Risk
Hazard
Index
Risk
exceeded?
Resident Groundwater to
Indoor Air
2.7E-05 2.1E+00 YES
Soil Gas to Indoor
Air
1.8E-05 2.4E-01 NO
Indoor Air 3.3E-06 1.8E-01 NO
The mediums affected include groundwater, groundwater to indoor air, soil vapor, and
subsurface soil. The groundwater, groundwater to indoor air and soil vapor risk drivers
are primarily related to TCE detected in groundwater. No TCE was detected in soil or
indoor air. The risk driver for subsurface soil is Manganese due to the risks related to
construction workers from soil dust generation. Manganese was also detected at elevated
concentrations in site specific background subsurface soil samples collected near the
property boundary. The PD is proposing to add appropriate vapor mitigation systems to
buildings constructed onsite to proactively address potential vapor intrusion issues. In
addition, the PD will add appropriate dust control measures to address potential exposure
to manganese during construction.
Required Land Use Restrictions:
Based on the site-specific data provided to the Brownfield program, the site reuse is
suitable for high density multi-family residential, retail, office, hotel, brewery,
warehousing, recreation, open space, and parking, as-long-as the agreed upon land use
restrictions in the BFA are abided by.
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1. No use other than for definitions for Hotel, Open Space, High Density Residential,
Retail, Warehousing, Recreation, Commercial and Parking.
2. No groundwater use
3. No disturbing soil without DEQ approval or for landscape/mowing/pruning/repair of
underground infrastructure (written notice to DEQ)/work for EMP.
5. Soil Import/Export.
6. No new buildings until DEQ says indoor air is safe/no VI issues/VI protection
installed.
8. EMP
9. Access to Brownfields Property for environmental assessment.
10. NBP reference in deed
11. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels
for generators/equipment
14. LURU submission January 1st
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Exhibit 2
The most recent environmental sampling at the Brownfields Property reported in
the Environmental Reports occurred in January 2017. The following tables set forth, for
contaminants present at the Brownfields Property above unrestricted use standards or
screening levels, the concentration found at each sample location, and the applicable
standard or screening level. Screening levels and applicable standards are shown for
reference only and are not set forth as cleanup levels for purposes of this Agreement.
GROUNDWATER
Groundwater contaminants in micrograms per liter (the equivalent of parts per
billion), the standards for which are contained in Title 15A of the North Carolina
Administrative Code, Subchapter 2L (2L), Rule .0202, (April 1, 2013 version):
Groundwater
Contaminant
Sample
Location Date of
Sampling
Concentration
Exceeding
Standard
(g/L)
Standard
(g/L)
Bromodichloromethane TMW-1 9/30/2016 0.80 0.6
Bromodichloromethane TMW-3 9/30/2016 0.96 0.6
Manganese TMW-2 10/3/2016 2,500 50
Manganese TMW-3 9/30/2016 94 50
Trichloroethene TMW-2 10/3/2016 11 3
SOIL
Soil contaminants in milligrams per kilogram (the equivalent of parts per million),
the screening levels for which are derived from the Preliminary Residential Health-Based
Soil Remediation Goals of the Inactive Hazardous Sites Branch of DEQ’s Superfund
Section (October 2016 version):
Soil
Contaminant
Sample
Location
Depth
(ft)
Date of
Sampling
Concentration
Exceeding
Screening
Level1
(mg/kg)
Residential
Screening
Level2 (mg/kg)
Arsenic SB-2 8-10 9/30/2016 0.69 0.68
Arsenic SB-3 2-4 9/29/2016 2.9 0.68
Arsenic SB-4 7-9 9/30/2016 0.97 0.68
Arsenic BKG-1 3-3.5 9/29/2016 2.0 0.68
Arsenic BKG-2 3-3.5 9/29/2016 1.2 0.68
Manganese SB-1 5-7 9/29/2016 1,600 360
Manganese SB-2 8-10 9/30/2016 2,800 360
Manganese SB-4 7-9 9/30/2016 1,300 360
Manganese SB-5 1-3 9/30/2016 1,400 360
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Soil
Contaminant
Sample
Location
Depth
(ft)
Date of
Sampling
Concentration
Exceeding
Screening
Level1
(mg/kg)
Residential
Screening
Level2 (mg/kg)
Manganese SB-6 2-4 1/27/2017 1,000 360
Manganese BKG-1 3-3.5 9/29/2016 590 360
Manganese BKG-2 3-3.5 9/29/2016 370 360
Thallium SB-2 8-10 9/30/2016 0.63 0.156
Thallium BKG-1 3-3.5 9/29/2016 0.16 0.156
Thallium BKG-2 3-3.5 9/29/2016 0.23 0.156
Total Petroleum
Hydrocarbons (Diesel)
SS-5 1-2 12/17/2014 480 1003
1 Concentrations of arsenic, manganese, and thallium detected in soil samples collected at the Brownfields
Property may be naturally occurring.
2 Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening levels
displayed for carcinogens are for a 1.0E-6 lifetime incremental cancer risk.
3. 100 mg/kg is the DEQ UST Section action level for TPH DRO. An additional soil sample (SS-2A) was
collected from the general location of SS-5 on April 6, 2017 and analyzed by EPA Method 8270D. There
were no detections of SVOCs above screening levels.
SUB-SLAB SOIL VAPOR
Sub-slab vapor contaminants in micrograms per cubic meter, the screening levels
for which are derived from the Residential Vapor Intrusion Screening Levels of the
Division of Waste Management (October 2016 version):
Sub-slab Soil Vapor
Contaminant
Sample
Location
Date of
Sampling
Concentration
Exceeding
Screening Level
(µg/m3)
Residential
Screening Level1
(µg/m3)
Trichloroethylene SV-01 8/10/2016 9,100 13.9
Trichloroethylene SV-01 9/28/2016 2,500 13.9
1,4-Dichlorobenzene SV-03 9/28/2016 170 85.1
Naphthalene SV-02 9/28/2016 34 20.9
Naphthalene SV-03 9/28/2016 6,000 20.9
1Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening levels
displayed for potential carcinogens are for a 1.0E-5 lifetime incremental cancer risk.
SOIL VAPOR
Soil vapor contaminants in micrograms per cubic meter, the screening levels for
Chadbourn Mill Decision Memo
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which are derived from the Residential Vapor Intrusion Screening Levels of the Division
of Waste Management (October 2016 version):
Soil Vapor
Contaminant
Sample
Location
Date of
Sampling
Concentration
Exceeding
Screening Level
(µg/m3)
Residential
Screening Level1
(µg/m3)
Benzene VMP-1 9/30/2016 1,900 120
Chloroform VMP-1 9/30/2016 270 40.7
Ethylbenzene VMP-1 9/30/2016 390 374
Hexane VMP-1 9/30/2016 12,000 4,870
Naphthalene VMP-1 9/30/2016 200 20.9
Tetrachloroethene VMP-1 9/30/2016 400 278
Trichloroethylene VMP-1 9/30/2016 230 13.9
1,2,4-Trimethylbenzene VMP-1 9/30/2016 230 48.7
Xylene, m- & p- VMP-1 9/30/2016 1,200 695
1Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening levels
displayed for potential carcinogens are for a 1.0E-5 lifetime incremental cancer risk.
INDOOR AIR
Indoor air contaminant screening levels in micrograms per cubic meter, the
screening levels for which are derived from the Residential Vapor Intrusion Screening
Levels of the Division of Waste Management (October 2016 version):
Indoor Air
Contaminant
Sample
Location
Date of
Sampling
Concentration
Exceeding
Screening Level
(µg/m3)
Residential
Screening Level1
(µg/m3)
Naphthalene IAS-3 1/27/2017 3.0 0.626
1Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening levels
displayed for potential carcinogens are for a 1.0E-5 lifetime incremental cancer risk.