23020 Beltex Mill Decision Memorandum 20200924

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DECISION MEMORANDUM
DATE: September 24, 2020 FROM: Bill Schmithorst TO: Beltex Mill Brownfields File
RE: Beltex Mill 130 Performance Drive Belmont, Gaston County BF # 23030-19-036
Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than industrial, office, parking and with prior written DEQ approval, other commercial uses, can be made suitable for such uses.
Introduction: The Brownfields Property is comprised of one parcel totaling approximately 20.64 acres of land containing a vacant 54,537 square ft. office/warehouse building. The BF Property is located in an industrial and commercial area of Belmont, Gaston County (Tax PIN:198162).
Redevelopment Plans: The Prospective Developer plans to use the property for warehouse/light industrial uses. Dry Pro Basement Systems, a company specializing in building foundation waterproofing services, will operate on the Brownfields Property.
Site History: The Brownfields Property primarily consisted of agricultural and wooded land prior to the late-1930s. In the mid-1950s, residential structures were present in the southern
portion of the Brownfields Property. In 1979, the original footprint of the current
industrial building was developed as a textile spinning mill. This mill was operating under the name Beltex when it closed in 2001. In the mid-1990s and mid-2000s, the original building footprint was expanded to increase the warehouse space and office space, respectively. The building was occupied by Wachs Services, a welding services
company, from 2007 to 2018.
An environmental site assessment was conducted at the Brownfields Property in October 2018 for property due diligence purposes. Four subsurface soil samples were collected at areas identified during previous Phase I site assessment activities. The areas sampled
included a manhole oil pit and discharge pipe, and the former septic system leach field.
Samples were submitted to a laboratory for the analysis of semi volatile organic compounds (SVOCs) and volatile organic compounds (VOCs). In addition, one temporary shallow groundwater monitoring well was installed adjacent to the manhole oil pit, and a groundwater sample was submitted to a laboratory for the analysis of VOCs
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and SVOCs. No constituents were detected in soil above applicable industrial/commercial risk screening levels. Tetrachloroethylene was detected in
groundwater above 15 NCAC 02L Groundwater Standards. A vapor intrusion assessment was conducted at the Brownfields Property on March 25 and 26, 2019, in accordance with a DEQ approved work plan. Assessment activities included collecting seven indoor air samples and seven sub-slab samples from within the
warehouse/manufacturing building. The samples were submitted to a laboratory for the analysis of VOCs by EPA Method TO-15. No VOCs were detected above applicable DWM Non-residential Vapor Intrusion Screening Standards. Two additional temporary shallow groundwater monitoring wells were installed and
sampled in April 2019. Both groundwater monitoring wells were located between the existing building on the Brownfields Property and the residences located south of the Brownfields Property. The groundwater samples were analyzed by a laboratory for VOCs, SVOCs and Resource Conservation and Recovery Act (RCRA) metals. Laboratory results indicate that no constituents were detected above NC 2L Standards.
In September 2019, a limited environmental site assessment was conducted, in accordance with a DEQ-approved Work Plan, for the purpose of supplementing previous sampling activities. The scope of work included collecting three subsurface soil samples and one groundwater sample. The soil samples were analyzed by a laboratory for RCRA
metals and the groundwater sample was analyzed for VOCs, SVOCs and RCRA metals. Laboratory results indicated that no soil samples exceeded the Industrial/Commercial PSRGs for RCRA metals. Groundwater laboratory analytical results indicated that tetrachloroethylene was detected above the 15A NCAC 02L Groundwater Standard (NC 2L Standard).
The Phase II assessment results indicating an exceedance NC 2L Standards for tetrachloroethylene were submitted to the NCDEQ Inactive Hazardous Sites Branch (IHSB) on April 4, 2019 by Robinson, Bradshaw & Hinson, P.A., on behalf of the owner,
130 Performance Drive, LLC. According to the NCDEQ IHSB (Memo to File, NCDEQ,
May 24, 2019), the contaminants detected in groundwater at the Brownfields Property are likely related to the Beltex Corporation Site located south of the property or related to Beltex operations on both properties. Therefore, the NCDEQ IHSB assigned the Brownfields Property to the Beltex Corporation Site under IHSB site identification
number NONCD0001336.
Potential Receptors: A site receptor survey was completed and potential receptors identified include water supply wells at four residences located south of the property, across Performance Drive.
The Brownfields Property is served by municipal water. The depth to groundwater is
below the depth of planned constructions activities, thus precluding construction workers and site workers as potential receptors. Contaminated Media:
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DEQ has evaluated data collected from the following media at the subject property: soil, groundwater and soil vapor. DEQ relies on the following data to base its conclusions
regarding the subject property and its suitability for its intended reuse.
Soil No constituents were detected above risk screening levels.
Groundwater Laboratory results indicate that tetrachloroethylene was detected above 2L Groundwater Standards in monitoring well TMW-1 at a concentration of 77.7 µg/L. In addition, TMW-1 exceeded the DWM Non-Residential Groundwater Vapor Intrusion Screening Level for tetrachloroethylene. Groundwater laboratory results indicated that tetrachloroethylene
was detected above 2L Groundwater Standards in monitoring well TMW-4 at a concentration of 1.4 µg/L.
Surface Water Surface water is not located on the site.

Sub-Slab Vapor No constituents were detected above risk screening levels. Indoor Air
In May 2020, one indoor air sample was collected in the basement of the Building and submitted to a laboratory for the analysis of VOCs. Laboratory results indicated that three petroleum hydrocarbon VOCs exceeded Non-Residential VISLs. Prior subslab vapor sampling did not indicate a vapor intrusion risk from these three compounds, and the source of these compounds was not identified.

Risk Calculations Risk Calculations were performed using the NCDEQ Risk Calculator (May 2019). The environmental samples indicating the highest concentration of contaminants detected
were used in the risk model. The risk calculations indicated the following based on
available data, including the following media: groundwater and sub-slab soil vapor:
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Non-Residential
Worker
Soil 0.0E+00 0.0E+00 NO
Groundwater Use 2.2E-06 5.3E-01 NO
VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Non-Residential Worker
Groundwater to
Indoor Air 1.3E-06 3.6E-01 NO
Soil Gas to Indoor Air 2.3E-07 6.2E-02 NO
Indoor Air 1.3E-05 5.3E-01 NO
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Red shading LICR> 1E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk HI = Hazard Index Risk calculations for the Brownfields Property indicate that risk hazard indices were not exceeded in soil or groundwater. However, VOCs were detected in one indoor air sample
collected in the basement at levels above NC Vapor Intrusion Screening Levels. If the basement is occupied, adequate ventilation will be required per DEQ approval, as addressed in the BFA land use restrictions. The source of tetrachloroethylene was not identified; therefore, an Environmental Management Plan will be required as a precaution to protect workers from potential exposures to subsurface soil and to control any future
export or import of fill materials at the Brownfields Property. Required Land Use Restrictions: Based on the site-specific data provided to the Brownfield program, site reuse is suitable
for industrial, office, parking, and, subject to DEQ’s prior written approval, other commercial uses, as long as the agreed upon land use restrictions in the BFA are abided by. 1. No use other than industrial, office, parking and with prior written DEQ approval,
other commercial uses 2. No groundwater use 2. No disturbing soil without DEQ approval or for landscape/mowing/pruning/repair of underground infrastructure (written notice to DEQ)/work for EMP. 3. Soil Import/Export protocol is followed. 4. Standard VI LUR
5. EMP 6. Access to Brownfields Property for environmental assessment. 7. NBP reference in deed. 8. No childcare center or school without NCDEQ approval.
9. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels
for generators/equipment. 10. Ongoing maintenance of vapor intrusion mitigation systems (VIMS), if VIMS is required. 11. Final grade soil sampling for RCRA metals, SVOCs, and VOCs will be conducted in
exposed areas.
12. LURU submission January 1st