Colonial Abrasive Decision Memo-OCR

DATE May 16, 2014
DECISION MEMORANDUM
FROM:
TO:
RE:
Sam Watson
BF Assessment File
Colonial Abrasives Project
312 South Pine Street
Aberdeen, Moore County
17044-13-063
Based on the following information, it has been determined that the above referenced site,
whose intended use is restricted light-industrial/commercial, can be made suitable for such uses.
Initial plans are to redevelop the property by constructing an industrial park to provide space for
office, retail, manufacturing and warehousing. The site is comprised of two lots totaling 11.11 acres
and is located within the Town of Aberdeen. The site has reportedly been developed since the
1930s. At some point in the past the site became a cannery operated by Luck's Corporation and
used to can beans and other food products. The site operated as a cannery until 1973. From 1973
until 2005 the site has been owned and operated by several adhesive manufacturing companies. The
soil and groundwater contamination at the site is attributed to manufacturing operations during this
time. Since 2005 the site has been owned by Meridian Real Estate, LLC and has been used as a
computer kiosk manufacturing and assembly facility by Meridian Zero Degrees. None of the
chemicals used during the previous adhesives manufacturing operations are used in current
operations.
Contaminated Media:
Groundwater:
Groundwater at the site has historically been impacted with chlorinated solvents (PCE, TCE, 111-
TCA and associated daughter products), VOCs and SVOCs. The solvents are attributed to leakage
and spills from an AST used to store PCE and leakage from a drain. pipe associated with the
chemical storage area. It is likely that some of the historical detections were also simply from
spillage during operations in the manufacturing building as well. The VOCs are attributed to a
former gasoline UST that was located onsite. The SVOCs are attributed to leakage from a hydraulic
press that was located in the main manufacturing facility.
In 2001, 3030 pounds ofHRC was injected via 56 injection points located along the northern and
eastern sides of the manufacturing building. Significant reduction in solvent concentrations have
been observed since that time.
During the most current sampling event (2013) only PCE was detected at levels exceeding the 2L
Standards in two wells. PCE was detected in MW-4, located in the former chemical storage area, at
a concentration of 1.9 ug/l. The 2L Standard is 0.7 ug/l. PCE was also detected in the sample from
MW-11, located inside the main manufacturing building adjacent to the former location of the
hydraulic press. The PCE at MW-11 was detected at a concentration of 3 5 ug/l.
It should be noted that PCE, nor any daughter products, nor any petroleum derived compounds were
detected in any downgradient wells at levels above 2L.
Though the impacts to groundwater are not significant at this time, they still pose a slight risk. As
such, I am placing a restriction on the use of groundwater at the site
Soil:
Soil at the site has historically been impacted by the same contaminants as were found in the
groundwater (chlorinated solvents, VOCs and SVOCs). The sources of the contamination have been
attributed to the same sources as the GW contamination. Early soil sampling at the site only tested
for TPH-DRO and Oil & Grease. No constituent specific analyses were performed. However,
results of this sampling indicated that only soils collected from the area where the former press was
located required further action.
In 2003, 160.53 tons of impacted soil was excavated from the hydraulic press area. Post excavation
sampling indicated that most of the SVOCs had been removed. Residual SVOCs remained in soils
situated below the west wall and a support beam located in the interior of the building.
Additional soil sampling was conducted in 2013 in the hydraulic press area. Constituent specific
analyses were run on the samples collected in 2013. Results of the analyses did not indicate the
presence of any compounds above industrial risk-based levels.
Though the 2013 samples suggested that the impacted soil had been removed and soil samples from
other areas of the property did not indicate soil impacts at level above industrial levels, I have placed
a restriction on the disturbance of soils beneath the existing slabs without DENR approval. This will
give us the opportunity to sample any soil beneath existing buildings if the existing buildings are
demolished and the slabs are taken up.
Vapor Intrusion:
Vapor intrusion is not considered to be a risk at the site. No compounds were identified in the
groundwater at levels exceeding the VI GW Screening Levels for industrial sites.
Potential Receptors:
The primary potential receptors to consider in the risk evaluation are workers
(office/ construction/ outdoor/indoor), site visitors and potential trespassers.
Work to Be Performed:
Active remediation is not being required by the PD for this site.
Required Land Use Restrictions:
In order to make the site suitable for its intended reuse, the brownfields agreement will contain the
following land use restrictions:
a. No use may be made of the Property other than for commercial/light industrial
purposes. For purposes ofthis restriction, the following definitions apply:
i. Commercial-an enterprise carried on for profit by the owner, lessee or
licensee; and
ii. Light Industrial -the indoor assembly, fabrication or processing of goods
and materials, using processes that do not create noise, smoke, fumes, odors, glare, or health
or safety hazards outdoors, and involving outdoor storage of related goods and material that
does not exceed 25 percent of the floor area of all buildings on the Property.
b. Groundwater at the Property may not be used for any purpose without the prior
written approval of DENR.
c. Soil on the Property that is situated beneath the slabs of pre-existing buildings
found at the sight at the time of this agreement may not be disturbed unless and until DENR states in
writing, in advance of the proposed disturbance, that the disturban¢e may proceed, if carried out
along with any measures DENR deems necessary in connection with the proposed disturbance to
avoid rendering the Property unsuitable for the uses specified in subparagraph 13 .a. above or public
health or the environment less than fully protected.
d. No basements may be constructed on the Property unless they are, as determined
in writing by DENR, vented in conformance with applicable building codes.
e. None of the contaminants known to be present in the environmental media at the
Property, including those appearing in Exhibit 2 to this Agreement, may be used or stored at the
Property without the prior written approval ofDENR, except in de minimis amounts for cleaning and
other routine housekeeping activities.
f. The Property may not be used as a park or for sports of any kind, including, but not
limited to, golf, football, soccer and baseball, without the prior written approval ofDENR.
g. The Property may not be used as a playground, or for child care centers, senior
care centers or schools.
h. The owner of any portion of the Property where any existing, or subsequently
installed, DENR-approved monitoring well is damaged shall be responsible for repair of any such
wells to DENR's written satisfaction and within a time period acceptable to DENR.
i. Neither DENR, nor any party conducting environmental assessment or remediation
at the Property at the direction of, or pursuant to a permit, order or agreement issued or entered into
by DENR, may be denied access to the Property for purposes of conducting such assessment or
remediation, which is to be conducted using reasonable efforts to minimize interference with
authorized uses of the Property.
j. During January of each year after the year in which the Notice referenced below in
paragraph 18 is recorded, the owner of any part of the Property as of January 1st of that year shall
submit a notarized Land Use Restrictions Update ("LURU") to DENR, and to the chief public health
and environmental officials of Moore County, certifying that, as of said January 1st, the Notice of
Brownfields Property containing these land use restrictions remains recorded at the Moore County
Register of Deeds office and that the land use restrictions are being complied with[, and stating:
i. the name, mailing address, telephone and facsimile numbers, and contact
person's e-mail address of the owner submitting the LURU if said owner acquired any part of the
Property during the previous calendar year; and
ii. the transferee's name, mailing address, telephone and facsimile numbers,
and contact person's e-mail address, if said owner transferred any part of the Property during the
previous calendar year.