HomeMy WebLinkAbout20003_CommScope Industrial_Decision Memo_2019.08.02DECISION MEMORANDUM
DATE: August 2, 2019
FROM: Cody Cannon
TO: Brownfields Assessment File
RE: CommScope Industrial
1545 St. James Church Road
Newton, North Carolina
BF # 20003-16-18
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than manufacturing, office space, and
parking.
Introduction:
The Brownfields Property comprises once parcel totaling 90.77 acres and is developed
with a manufacturing building that is approximately 307,626 square feet and a human
resources building that is approximately 19,496 square feet. The site also contains a
guard shack and fire suppression building.
The Brownfields Property is bordered to the north by undeveloped woodlands followed
by a scientific and medical equipment sales facility operated by The Sarstedt Group; to
the east by St James Church Road and agricultural land including a residence; to the
south by undeveloped woodlands and Smyre Creek; and to the west by an automotive and
industrial bearing manufacturing facility (WJB Bearings, Inc.) and a shopping cart
manufacturing facility (Technibilt).
Redevelopment Plans:
The prospective developer (PD) has utilized the property to relocate a tire retreading
operation managed by Snider Fleet Solutions. The PD has already completed many
interior renovations including the front office space, training facilities, and the main
warehouse space where tire retreading and wheel painting are conducted. Additional
renovations to the internal training program (“Snider University”) are ongoing. No
additional redevelopment plans are currently proposed for the site.
Site History:
Development of the property began in 1981 with building additions continuing into the
late 1980s resulting in the current building footprint as well as a guard shack and fire
suppression building. The facility was owned and operated by R.R. Donnelly Printing
Company and later Meredith/Burda, Inc. as a commercial printer producing publications,
catalogs, and advertising materials from 1981 until 1998. Toluene based inks were
utilized in production and the facility maintained two activated carbon solvent recovery
systems located immediately north of the building in order to recycle toluene vapors
captured during the drying process. The older of the two solvent recovery systems was
installed in 1981 and consisted of two above ground carbon adsorption tanks and three
20,000-gallon underground storage tanks (USTs). The newer solvent recovery system
was installed in 1986 and consisted of four above-ground carbon adsorption tanks
connected to a single 10,000-gallon UST. The facility also maintained a toluene ink tank
farm area to the northwest of the buildings (12 USTs), a wastewater treatment plant
(WWTP) complete with a single wastewater bypass UST located outside of the southeast
corner of the building, a railway spur for delivery of paper, a drum storage pad area, and
a basement level hazardous waste storage area. After purchasing the facility in 1998,
CommScope Industrial utilized the site for wire braiding and plastic coating until 2011.
History of Environmental Assessment
Environmental assessment began at the site in 1991 with a Site Inspection Report
completed by Halliburton Nus Environmental Corp. which detailed soil, sediment,
groundwater, and surface water samples collected from various locations across the site.
Elevated concentrations of metals were evident in soil and sediment samples but no
impacts were observed in groundwater or surface water (Smyre Creek) samples. A
Comprehensive Site Assessment Report was completed in August, 1994 by Trigon
Engineering Consultants, Inc. (Trigon) in response to a reported toluene leak from one of
the solvent recovery system tanks. An estimated 250 – 500 gallons of toluene were
spilled from a leaky tank valve over a 3-year period. Monitoring wells (12 shallow and 1
deep aquifer) monitoring wells were installed in the vicinity of the solvent recovery
system. Toluene was detected above the North Carolina Administrative Code Title 15A
Subchapter 02L (2L) groundwater standard and the Non-Residential Vapor Intrusion
Screening Level (VISL) at concentrations as high as 450,000 µg/L in the immediate
vicinity of the recovery system. Additionally, 20 shallow hand auger and 6 deeper
hollow stem soil samples were collected. None of the toluene concentrations observed
exceeded the industrial/commercial preliminary soil remediation goal (PSRG) with a
maximum concentration of 600 mg/kg. Trigon recommended the installation of a soil
vapor extraction (SVE) and groundwater pump and treat system. In 1995, an
SVE/Groundwater Recovery system began operation with several vapor extraction wells
throughout the solvent recovery area and 7 recovery wells located down gradient of the
source area within the warehouse building.
Printing operations ceased in December 1997, many of the remaining USTs were
removed in 1998. A UST Closure Report from June 1998 detailed the removal of 12
USTs in the ink tank farm, 4 USTs in the Solvent Recovery System area, and the bypass
UST associated with the WWTP. 25 shallow (0-3 ft BGS) and 13 deep (8–25 ft BGS)
soil samples were collected in the ink tank farm area. One sample location contained
concentrations of toluene exceeding the Residential PSRG (2018) for both shallow and
deep soil at 5,800 mg/kg and 10,420 mg/kg respectively. 22 direct push technology
(DPT) drilling points were advanced in the vicinity of the solvent recovery system
resulting in a total of 24 soil samples analyzed for toluene. Of the 24 samples, 2
contained concentrations of toluene exceeding the protection of groundwater PSRG at a
depth of 13-15 feet below ground surface (ft BGS). Samples were collected from 12
DPT locations in the vicinity of the WWTP UST resulting in toluene concentrations
above the protection of groundwater PSRG in 2 samples from 14-16 ft BGS.
Concentrations of tetrachloroethylene (PCE) exceeded the 2L groundwater standard in
monitoring well MW-12 (near boiler room) during a semi-annual monitoring event in
1997. This observation led to an investigation regarding the extent of PCE contamination
in groundwater in December 1998 which included the installation of monitoring wells
MW-15 (deep), MW-16 (deep), and MW-17 (shallow) in the vicinity of MW-12. Only
MW-17 (downgradient) contained detectable concentrations of PCE with a concentration
exceeding the 2L standard. Subsequent sampling events in the area resulted in
concentrations below detection limits.
Groundwater samples were collected using DPT sampling points near the former ink tank
farm and WWTP UST areas by SECOR in 1998 revealing elevated toluene
concentrations. Trigon was contracted in 1999 to verify the 1998 results. Shallow
monitoring wells MW-18 through MW-22 and deep well MW-29 were installed in the
former WWTP UST area. Concentrations of toluene exceeding the 2L standard were
observed in MW-18, MW-21, and MW-22. 3 soil samples were collected beneath the
UST closure sample DP-34 in the WWTP UST area and analyzed for toluene. No
detections were observed above the laboratory reporting limit. Monitoring wells MW-23
through MW-27 (shallow) and MW-29 (deep) were installed in the vicinity of the former
ink tank farm area. Samples from monitoring wells MW-24, MW-25, and MW-27
contained concentrations of toluene exceeding the 2L standard. Monitoring well MW-6R
was installed in the solvent recovery area to replace MW-6; concentrations of toluene
were below detection.
A combined Phase I and II Report was completed by Environmental Resources
Management (ERM) in November 1999 which focused on the investigation of several
identified potential environmental concerns including: the WWTP area, 2 closed-in-place
fuel USTs, a former drum storage area, a railroad spur, floor drain outfalls from the
bindery room, an electrical substation, a reported toluene spill (50-75 gallons) within the
northern portion of the manufacturing building in 1990, sanitary sewer lines, and a
methanol spill from a fluid chiller discovered by site personnel in November 1995 that
consisted of approximately 1,200 gallons of methanol released to the ground surface.
Soil and groundwater samples were submitted for analysis of volatile organic compounds
(VOCs) in each area of concern, polychlorinated biphenyls (PCBs) from the electrical
substation, and semi volatile organic compounds (SVOCs) from the rail spur area. No
detections were observed above applicable standards in any area with the exception of the
methanol spill. Groundwater impacts from DPT sampling points identified methanol
impacts as high as 447,000 µg/L. However, groundwater samples from nearby
monitoring wells MW-3 and MW-2R did not contain detections of methanol.
In October of 2002, the North Carolina Department of Environment and Natural
Resources (NC DENR) issued a Notice of Regulatory Requirement for the site which
mandated additional assessment for both the solvent recovery area and former ink tank
farm area. A Status of Site Investigation and Remedial Systems report was completed in
November 2002 detailing the results of toluene extraction from the SVE/Recovery
system in the former solvent recovery area. Most of the toluene recovered from the
system was reportedly being recovered at MW-34. Recovery wells RW-4, RW-5, and
RW-7 (downgradient of source area) contained concentrations of toluene exceeding the
2L standard at the time. However, decreasing toluene concentrations were observed
within the solvent recovery area, WWTP area, and the ink tank farm.
In February 2003, a Notice of Regulatory Requirement was issued by NCDENR requiring
additional soil sampling at previous UST closure soil sample locations where toluene
concentrations exceeded 7 mg/L and where the MDL was greater than the protection of
groundwater standard. In April 2003, a report detailing further sampling in the ink tank
farm area was submitted by Advance GeoServices, Corp. 30 soil samples were collected
in the former ink tank farm area (locations provided in hand drawn map). 20 samples
ranging in depth from 0 to 12 ft BGS were submitted for laboratory analysis of Toluene.
No detections above 1 µg/kg were reported. A Notice of No Further Action for the
former ink tank farm area was issued by NC DENR in April, 2003.
A Notice of Regulatory Requirement was issued by NCDENR in April 2003 requiring the
resampling of soil samples DP-33 and DP-34 in the WWTP UST area. Four samples
were collected (14-16 ft BGS and 24-26 ft BGS from each location) and submitted for
analysis of toluene. Low level detections of toluene (below protection of groundwater
PSRG) were observed. A Notice of No Further Action for the WWTP area was issued by
NC DENR in June, 2003.
Sampling of the groundwater recovery wells continued on a biannual basis through May,
2007 when a Semi-Annual Active Remediation Monitoring Report and Request for
Incident Closure Report was completed by Advanced GeoServices. The report revealed
that none of the recovery wells or associated monitoring wells contained toluene above
the 2L groundwater standard. All wells in the area except for RW-5 and MW-34
contained less than 1 µg/L toluene. In response to these observations, a Notice of No
Further Action for the solvent recovery area was issued by NC DENR in June, 2007.
In December 2013, AECOM, Inc. completed a Remedial Investigation and Remedial
Action Completion Report which included soil assessment of the former 100,000-gallon
basin located outside the southern corner of the warehouse building which reportedly
collected water from interior floor drains in the vicinity of the former printing and
chrome/copper etching operations. A total of 29 soil samples were collected in the
overflow basin and analyzed for VOCs, SVOCs, and Metals. Additionally, five
background soil samples (2-4 ft BGS) were collected from background locations across
the site. Concentrations exceeding the commercial/industrial PSRGs were observed for
arsenic, thallium, and chromium in both the basin and background soil samples.
Hexavalent chromium (Cr VI) was detected at concentrations above the industrial PSRG
in two of the fire sprinkler basin samples. A groundwater sample was collected from a
monitoring well (MW-1) installed in the center of the overflow basin and contained
concentrations of manganese exceeding the 2L standard.
A Notice of No Further Action for the site was issued by the NCDENR Inactive
Hazardous Sites Branch (IHSB) in October, 2014. In November, 2014 a Combined
Remedial Investigation and Remedial Action Completion Report was completed by
AECOM, Inc. and detailed some follow on groundwater sampling in connection with the
PCE concentrations observed in 1997. 4 new temporary monitoring wells were installed
in the vicinities of former monitoring wells MW-12, MW-15, MW-16, and MW-17. No
VOCs were detected in the four groundwater samples collected.
DEQ Brownfields conducted a site visit on December 19, 2018 and issued a Request for
Additional Assessment on December 31, 2018. Hart & Hickman, PC conducted the
additional assessment at the site from March 6 to March 8, 2019 which included the
installation and sampling of monitoring wells in the vicinity of the former WWTP UST
(TMW-1), the former solvent recovery area (TMW-2), and the former ink tank farm
(TMW-3). No VOCs were detected above laboratory reporting limits in any of the 3
monitoring wells. Additionally, 3 sub-slab soil gas samples were collected from the
lower level of the facility downgradient of the former solvent recovery area in the former
boiler room (SS-1), former WWTP area (SS-2), and former hazardous waste storage area
(SS-3). Several VOC constituents were detected in the sub-slab samples but none
exceeded applicable non-residential vapor intrusion screening levels (VISLs).
Potential Receptors:
Potential receptors are: construction workers, on-site workers, vendors, and trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
soil-gas, and groundwater. DEQ relies on the following data to base its conclusions
regarding the subject property and its suitability for its intended reuse.
Soil
Concentrations of arsenic and chromium (total) exceed the industrial PSRG at locations
across the site. However, background soil samples and samples collected from the former
overflow basin for Cr VI suggest that chromium is predominately trivalent across the site.
Thallium has been observed above the Industrial-PSRG in background soil samples and
samples from the former overflow basin.
Risk calculations were completed for soil utilizing the 2013 soil sampling data
(background soil and former overflow basin). A significant risk for soil exposure to non-
residential workers does not exist at the site. Calculations for construction worker
exposure were completed utilizing solely shallow soil (0-2 ft BGS) and again utilizing
both shallow and subsurface soil. The non-carcinogenic hazard index exceeds the
threshold of 1.0 for both scenarios.
Groundwater
Concentrations of toluene exceeded the 2L and Non-Residential VISL in several
groundwater wells near the former solvent recovery system. However, the operation of an
SVE and pump treat system remediated the groundwater to below 2L standards in all
affected recovery and monitoring wells. Groundwater from historical AOCs collected in
2019 revealed no exceedances of 2L standards for any constituent (VOCs, SVOCs,
RCRA Metals).
Risk calculations were made utilizing the March 2019 groundwater data. No risk exists
for groundwater exposure or groundwater to indoor air for non-residential workers.
Sub-Slab Soil Gas
Several VOCs were detected in sub-slab soil gas samples SS-1 through SS-3 but none
exceeded the industrial VISL. Toluene was detected at a concentration of 72,000 µg/m3
in sample SS-2 (DUP-1) which exceeds the Residential VISL. Risk calculations
performed utilizing the highest concentration of each detected constituent from each soil-
gas sample resulted in no significant risk to non-residential workers.
Risk Calculations
Medium Site Area
Non-Residential Worker
LICR HI
Sub-Slab Soil Gas Entire Site 8.2E-08 3.9E-02
Groundwater
Exposure
Entire Site 2.9E-05 7.4E-02
Groundwater to
Indoor Air
Entire Site 0.0 0.0
Soil Exposure Entire Site 1.2E-06 6.9E-01
Medium Site Area
Construction Worker
LICR HI
Soil Exposure
(Shallow Only)
Entire Site 1.3E-06 11
Soil Exposure
(Shallow and Deep)
Entire Site 1.4E-06 18
Red shading LICR> 1E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index
Due to the results of the risk calculators, restrictions are in place regarding soil and
groundwater exposure and use at the Brownfields Property.
Required 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 are abided
by.
1. No use other than industrial, warehousing, office space, parking, and with prior DEQ
approval, other commercial uses.
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.
4. Final grade soil sampling.
5. Soil Import/Export.
6. EMP
7. Access to Brownfields Property for environmental assessment.
8. NBP reference in deed
9. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels
for generators/equipment
10. LURU submission January 1st
SITE LOCATION MAP
CommScope Industrial
1545 St. James Church Road
Newton, North Carolina
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
3/22/2019 0
1SNL-002
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAP
7.5 MINUTE SERIES (TOPOGRAPHIC)
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203
704.586.0007(p) 704.586.0373(f)
NEWTON, NORTH CAROLINA 1993
SITE
ROLL
STORAGE
PRESSROOM
MAINTENANCE
BINDERY
SHIPPING
DP-5
DP-1DP-2
DP-7
MW-17 MW-16
MW-10
MW-15
MW-13
MW-26
GP-6
MW-2R
MW-3
MW-22
MW-19
MW-18
MW-28
MW-21
MW-20
MW-14
MW-5
MW-6R
MW-4
MW-11
MW-7
MW-23
MW-24
B-102
B-101
B-103
B-104
MWSEC-7
MWSEC-8
MWSEC-9
MWSEC-10
MWSEC-11
MWSEC-18 MWSEC-14
MWSEC-4
MWSEC-2MWSEC-3
MWSEC-1
SBSEC-220-2238-40NAPH0.0130.0101,2,3-TCB0.0160.0101,2,4-TCBND0.0071,2,4-TMBND0.008
B-102
B-101
B-103
B-104
B-101
B-102
B-101
B-103
MW-27
MWSEC-13
MWSEC-12
MWSEC-5
DP-8
MW-25R
DP-13
DP-3
MW-34
DP-16 MWSEC-17
MWSEC-16
MW-1
MW-12
TMW-2
TMW-3
TMW-1
SS-3
SS-2
SS-1
LEGEND
SANITARY SEWER LINE
WATER LINE
OVERHEAD POWER LINE
RAILROAD TRACKS
ABANDONED MONITORING WELL/ SOIL BORING
LOCATION
FORMER TEMPORARY MONITORING WELL/SOIL
BORING LOCATION
DIRECT PUSH SAMPLE LOCATION
2019 TEMPORARY MONITORING WELL LOCATION
SUB-SLAB SOIL GAS SAMPLE LOCATION
AREA OF CONCERN RECEIVING REGULATORY NFA
JOB NO. SNL-001
REVISION NO. 0DATE: 3-22-19
FIGURE NO. 2
COMMSCOPE INDUSTRIAL
1545 ST. JAMES CHURCH ROAD
NEWTON, NORTH CAROLINA
SITE MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 GeologyNOTES:
1. MAP PREPARED FROM HISTORICAL TRIGON ENGINEERING
CONSULTANTS, SECOR, ERM, AND AECOM ASSESSMENT
REPORTS.
PEC #4: FORMER DRUM
STORAGE YARD
PEC #2: TOLUENE AST (IN VAULT)
REMOVED 1998
EMPLOYEE
PARKING
HREC #2: FORMER INK UST
INCIDENT NO. 27045
NFA 2003
HREC #1: FORMER
METHANOL UST
CLOSED-IN-PLACE 1993
REMOVED 1998
HREC #1: TOLUENE SOLVENT RECOVERY UNITS
INCIDENT NO. 18811
NFA JUNE 2007
REC #3: FLUID CHILLERS
(1995 METHANOL SPILL)
PEC #3: TWO 50K FUEL OIL USTS
CLOSED-IN-PLACE 2000
TOLUENE USTs (3)
REMOVED 1998
PEC #3: FUEL OIL UST
CLOSED-IN-PLACE 1998 PEC #14: PAPER BURNER
OFFICES
FUEL OIL AST (250-GAL.)
BOILER
ROOM
HREC #3 FORMER WWTP UST
INCIDENT NO. 27432
NFA 2003
WATER TANK &
FIRE PUMP HOUSE
PEC #9: ELECTRICAL SUBSTATION
HREC #4: FORMER IMPOUNDMENT AREA
NCD 991279118
NFA 2014
PEC#3: FUEL OIL UST
CLOSED-IN-PLACE 1998
PEC #6: MAINTENANCE
AREA
REC #4: HYDRAULIC
ELEVATOR
PEC #1: FORMER WWTP
HREC #5: PCE GROUNDWATER IMPACTS
NCD 991279118
NFA 2015
PEC #8: DRAIN OUTFALLS
PEC #10: TOLUENE SPILL AT NEW
DECANTING ROOM
ROLL
STORAGE
PRESSROOM
MAINTENANCE
BINDERY
SHIPPING
DP-5
DP-1DP-2
DP-7
MW-17 MW-16
MW-10
MW-15
MW-13
MW-26
GP-6
MW-2R
MW-3
MW-22
MW-19
MW-18
MW-28
MW-21
MW-20
MW-14
MW-5
MW-6R
MW-4
MW-11
MW-7
MW-23
MW-24
B-102
B-101
B-103
B-104
MWSEC-7
MWSEC-8
MWSEC-9
MWSEC-10
MWSEC-11
MWSEC-18 MWSEC-14
MWSEC-4
MWSEC-2MWSEC-3
MWSEC-1
SBSEC-220-2238-40NAPH0.0130.0101,2,3-TCB0.0160.0101,2,4-TCBND0.0071,2,4-TMBND0.008
B-102
B-101
B-103
B-104
B-101
B-102
B-101
B-103
MW-27
MWSEC-13
MWSEC-12
MWSEC-5
DP-8
MW-25R
DP-13
DP-3
MW-34
DP-16 MWSEC-17
MWSEC-16
MW-1
MW-12
TMW-2
TMW-3
TMW-1
SS-3
SS-2
SS-1
(66.38)
(66.01)
(51.29)
6
6
66
6
2
62
5
8
58
5
4
54
LEGEND
SANITARY SEWER LINE
WATER LINE
OVERHEAD POWER LINE
RAILROAD TRACKS
ABANDONED MONITORING WELL/ SOIL BORING LOCATION
FORMER TEMPORARY MONITORING WELL/SOIL BORING
LOCATION
DIRECT PUSH SAMPLE LOCATION
2019 TEMPORARY MONITORING WELL LOCATION
SUB-SLAB SOIL GAS SAMPLE LOCATION
WATER TABLE ELEVATION MARCH 5, 2019 (FT)
ESTIMATED WATER TABLE ELEVATION CONTOUR LINE (FT)
INFERRED GROUNDWATER FLOW DIRECTION
JOB NO. SNL-001
REVISION NO. 0DATE: 3-22-19
FIGURE NO. 3
COMMSCOPE INDUSTRIAL
1545 ST. JAMES CHURCH ROAD
NEWTON, NORTH CAROLINA
POTENTIOMETRIC SURFACE MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 GeologyNOTES:
1. MAP PREPARED FROM HISTORICAL TRIGON
ENGINEERING CONSULTANTS, SECOR, ERM,
AND AECOM ASSESSMENT REPORTS.
EMPLOYEE
PARKING
OFFICES
BOILER
ROOM
WATER TANK &
FIRE PUMP HOUSE
(66.01)
66