22016_Quality Products Decision Memorandum 20200127

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DECISION MEMORANDUM
DATE: January 27, 2020 FROM: Bill Schmithorst TO: BF Assessment File
RE: Quality Products Company 1513, 1515, 1521, 1525, 1529, and 1537 South Mint Street, and 404 Westwood Avenue Charlotte, Mecklenburg County
BF # 22016-18-060 Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than retail, office, restaurant, brewery or food production facility, entertainment, open space, amenity space, parking, industrial,
warehousing, and with prior written DEQ approval, other commercial uses, can be made suitable for such uses. Introduction: The Brownfields Property comprises six parcels totaling approximately 1.39 acres of land
located in a mixed commercial, industrial, and residential area of the South End district in Charlotte (Tax PINs 11908315, 11908316, 11908317, 11908301, 11908302, and 11908411). The northeastern portion of the Brownfields Property is developed with a single-story multi-tenant commercial building. Southwestern portions of the Brownfields Property are developed with three industrial warehouse buildings utilized for auto-repair
related operations. Remaining portions of the Brownfields Property consist of undeveloped land. The northern Brownfields Property building (1513 and 1515 South Mint Street) is an
approximately 14,000 square foot single story commercial building with three tenant
spaces. The western-most tenant space has most recently been occupied by a hydraulic hose fabrication and sales facility (Pirtek), the central tenant space is unoccupied, and the eastern tenant space has most recently been used as an administrative office for a demolition and abatement contractor business (RCI Demolition). The 1521 South Mint
Street portion of the Brownfields Property is undeveloped and used as a gravel parking
area. The western (1525 South Mint Street) and northwestern parcels (1529 and 1537 South Mint Street) are developed with three industrial warehouse buildings that have most recently been occupied for automotive repair-related purposes (Dee Gainey’s). The southeastern parcel (404 Westwood Avenue) consists primarily of undeveloped vegetated
land with a gravel driveway and waste receptacle enclosure located near Westwood
Avenue. Redevelopment Plans:
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The PD intends to remodel the existing buildings for uses including retail, office, parking, restaurant, open space, entertainment, amenity space, brewery or food production facility,
industrial, warehousing, and with prior written DEQ approval, commercial uses. Site History: The Brownfields Property was initially developed with a small office building, two small commercial buildings, and several residential buildings as early as the 1920s. The
industrial warehouse building located at 1525 South Mint Street was constructed in the 1930s and additions to the original 1920s office and commercial buildings, resulting in the existing multi-tenant commercial building, were completed through the 1940s until the 1960s. Residences in the southwestern portion of the Brownfields Property were removed over time and the two industrial warehouses located at 1529 and 1537 South
Mint Street were constructed by the 1960s. The 404 Westwood Avenue parcel located in the southeastern portion of the Brownfields Property was developed with a residence in the 1920s which was razed in the 1980s. The 404 Westwood Avenue parcel has remained undeveloped land since the 1980s.
The western parcels located along Westwood Avenue and near the Westwood Avenue and South Mint Street intersection were developed with four residences and associated garage structures as early as 1929. By 1933, the industrial warehouse located at 1525 S. Mint Street was constructed and has been utilized for automotive repair and automotive painting purposes since that time. The remainder of the western parcels were residential
until the 1960s, when the residences located south of Westwood Avenue were razed for construction of the two industrial warehouse buildings located at 1529 and 1537 South Mint Street. The 1525, 1529, and 1537 South Mint Street buildings have been utilized for automotive repair, body shop, and painting purposes by the Stockton Motor Co., S&R Auto & Truck Service, Inc., Pete’s Paint & Body Works, Bush Limousine Service, Dale’s
Auto Service, and Dee Gainey’s Body Shop, Inc. since construction. The 1920s residence located at 404 Westwood Avenue was razed in the late 1980s and has been undeveloped vacant land since that time.
As early as 1929, the eastern portion of the Brownfields Property was developed with a
small office building and two small commercial buildings, and the central portion of the Brownfields Property was developed with a duplex residential building. The buildings in the eastern portion of the Brownfields Property were occupied by the Jewel Tea Company, Rudisill Gold Mine Inc., and Cabarrus Mining & Milling Company as early as
the 1930s. By the early to mid-1940s, the eastern and south-central portion of the
Brownfields Property was developed with the Charlotte Metal Stamping, Inc. facility. Charlotte Metal Stamping operations included a die stamping room, two machine shop areas, a paint booth, and a tin shop.
Quality Products Company, Inc. purchased the Charlotte Metal Stamping, Inc. facility in
the early 1950s and continued metal stamping operations. Additions were constructed on the western side of the 1940s facility in the 1960s and the metal stamping facility encompassed the eastern and central portions of the Brownfields Property resulting in the current Brownfields Property buildings. By the late 1960s, an additional machine shop
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was constructed south of the Quality Products Company facility in the central portion of the Brownfields Property. Quality Products Company metal stamping operations
continued at the Brownfields Property until the mid-1980s. The machine shop in the central portion of the Brownfields Property was demolished in the mid-1980s and the parcel was used for parking when Quality Products Company operations ceased. Since the 1980s, several businesses have occupied portions of the northern building including a civil engineering firm, a coffee bean roasting company, a telemarketing business, and
laser engraving businesses. Environmental Assessments: A Phase II ESA soil and sub-slab soil vapor assessment was conducted in January 2018 at 1513, 1515, and 1521 South Mint Street to evaluate the potential for impacts in areas
of potential environmental concern identified during the Phase I ESA. H&H collected one soil sample for laboratory analysis of volatile organic compounds (VOCs) and semi-VOCs (SVOCs) within the footprint of surficial oil staining observed south of the 1515 South Mint Street (Pirtek) building. Four sub-slab soil vapor samples were collected for analysis of VOCs within the 1513 and 1515 South Mint Street buildings. Soil sample
laboratory analytical results indicate that no VOCs or SVOCs exceeded DEQ Inactive Hazardous Site Branch (IHSB) Industrial/Commercial Preliminary Soil Remediation Goals (PSRGs) Sub-slab soil vapor laboratory analytical results indicated the presence of several VOCs
above laboratory method detection limits in each sub-slab soil vapor sample. Trichloroethylene (TCE) was detected at concentrations exceeding the DEQ Division of Waste Management (DWM) Non-Residential Vapor Intrusion Sub-Slab and Exterior Soil Gas Screening Levels (SGSLs) in two sub-slab soil vapor samples collected in the northern portions of the 1513 and 1515 South Mint Street buildings. No other
compounds were detected at concentrations above the DEQ DWM Non-Residential Vapor Intrusion SGSLs. In December 2018, additional soil, groundwater, and indoor air assessment activities
were completed at the Brownfields Property in accordance with a DEQ-approved
Brownfields Assessment Work Plan dated November 28, 2018. Groundwater assessment activities included collection of three groundwater samples for laboratory analysis of VOCs, SVOCs, and Resource Conservation and Recovery Act (RCRA) metals. Groundwater sample analytical results indicated that TCE was detected at a concentration
above both the DEQ 2L Groundwater Quality Standard (2L Standard) and the DEQ
DWM Non-Residential Vapor Intrusion Groundwater Screening Level (GWSL) in a sample collected in the southeastern and hydraulically upgradient portion of the Brownfields Property. No other compounds were detected at concentrations above the 2L Standard or DEQ DWM Non-Residential Vapor Intrusion GWSLs.

As part of the December 2018 Brownfields assessment activities, four indoor air samples were collected for VOC analysis to evaluate the potential for a completed structural vapor intrusion pathway from sub-slab soil vapor to indoor air within the 1513 and 1515 South Mint Street buildings. The indoor air sample analytical results indicated that TCE was
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detected at concentrations above the DEQ DWM Non-Residential Vapor Intrusion Indoor Air Screening Level (IASL) in three of the four indoor air samples. In addition, heptane
was detected at a concentration above the DEQ DWM Non-Residential Vapor Intrusion IASLs in an indoor air sample collected within a hydraulic hose fabrication workshop area in the western-most tenant space. The consultant for the PD confirmed that there were no TCE-sensitive populations working within the affected building. In addition, it was also reported that only one individual was working in the building and averaged less
8 hours per work day. Tenants are relocating as the buildings are being remodeled for change in use. No other compounds were detected at concentrations exceeding the DEQ DWM Non-Residential Vapor Intrusion IASLs in the December 2018 indoor air samples collected within the 1513 and 1515 South Mint Street building.
Additional soil assessment activities were also conducted as part of the December 2018 Brownfields assessment activities and included collection of six soil samples for laboratory analysis of VOCs, SVOCs, and RCRA metals plus hexavalent chromium. Laboratory analytical results indicated that arsenic was detected at concentrations exceeding the DEQ IHSB Industrial/Commercial PSRG in soil samples collected south of
the 1513 and 1515 South Mint Street building. No other compounds were detected at concentrations above the IHSB Industrial/Commercial PSRGs in the December 2018 soil samples. In August 2019, Phase I and Phase II ESAs were conducted in connection with the 1525,
1529 and 1537 South Mint Street and 404 Westwood Avenue parcels. Phase II ESA activities included collection of soil, groundwater, and sub-slab soil vapor samples for laboratory analysis to evaluate the potential for impacts in areas of concern identified during the Phase I ESA. Soil assessment activities included collection of 10 soil samples for laboratory analysis of VOCs, SVOCs, and RCRA metals plus hexavalent chromium,
and one soil sample for the analysis of PCBs. Groundwater assessment activities included collection of four groundwater samples for laboratory analysis of VOCs, SVOCs, and RCRA metals. Sub-slab soil vapor assessment activities included collection of six soil vapor samples for laboratory analysis of VOCs from within the 1525, 1529,
and 1537 South Mint Street buildings (two sub-slab soil vapor samples were collected in
each building). Soil sample laboratory analytical results from the August 2019 assessment indicated that 1,4-dichlorobenzene, naphthalene, and mercury were detected at concentrations above the
DEQ IHSB Industrial/Commercial PSRGs in a soil sample collected beneath the 1525
South Mint Street building slab adjacent to a floor drain. In addition, arsenic was detected at a concentration above the DEQ IHSB Industrial/Commercial PSRG in a soil sample collected beneath the 1525 South Mint Street building slab in the area of a paint booth. Mercury was also detected above the DEQ IHSB Industrial/Commercial PSRG in
a soil sample collected adjacent to an underground storage tank located in the northern
portion of the 1525 South Mint Street building. No other compounds were detected above the DEQ IHSB Industrial/Commercial PSRGs.
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Groundwater sample laboratory analytical results from the August 2019 assessment indicated that 1,2-dichloroethane was detected at a concentration above the 2L Standard
in a sample collected northwest and hydraulically downgradient of the 1537 South Mint Street building. No other compounds were detected above the 2L Standards and no compounds were detected above the DEQ DWM Non-Residential Vapor Intrusion GWSLs in groundwater.
Sub-slab soil vapor laboratory analytical results indicated that naphthalene was detected at a concentration above the DEQ DWM Non-Residential Vapor Intrusion SGSL in one sub-slab soil vapor sample collected in the 1525 South Mint Street building. No other compounds were detected at concentrations above the DEQ DWM Non-Residential Vapor Intrusion SGSL in the August 2019 sub-slab soil vapor samples.
In November 2019, supplemental Brownfields soil and groundwater assessment activities were completed to further evaluate the potential for impact on the 1537 South Mint Street and 404 Westwood Avenue parcels. Soil assessment activities included collection of two soil samples for laboratory analysis of VOCs, SVOCs, and RCRA metals plus hexavalent
chromium. Groundwater assessment activities included collection of two groundwater samples for laboratory analysis of VOCs, SVOCs, and RCRA metals. Soil sample laboratory analytical results indicated that no compounds were detected at concentrations above the DEQ IHSB Industrial/Commercial PSRGs. Groundwater sample laboratory analytical results indicated that no compounds were detected at concentrations above the
2L Standards or DEQ DWM Non-Residential Vapor Intrusion GWSLs. Potential Receptors: Potential receptors are: construction workers and on-site workers. A Brownfields
Program receptor survey was completed and indicated that no active water supply wells were identified within 1,500 ft. of the Brownfields Property. No surface water bodies were identified on the Brownfields Property or on adjacent properties.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: groundwater, soil, sub-slab 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 Laboratory results indicated that soil sample SB-1 collected at a depth of 8-10 feet exceeded the Non-Residential PSRGs for Total Petroleum Hydrocarbons (TPH) GRO (799 mg/kg), TPH DRO (106 mg/kg) and Total C9-C18 Aliphatics 212.5 mg/kg. In
addition, laboratory results indicated that soil sample SB-1 exceeded Non-Residential
PSRGs for mercury at a concentration of 10.5 mg/kg.
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Laboratory results indicated that soil sample SB-2, collected at a depth of 3-4 feet exceeded Non-Residential PSRGs for 1,4-dichlorobenzene (23.6 mg/kg), naphthalene (42
mg/kg), and mercury (30.2 mg/kg). In addition, laboratory results indicated that soil samples SB-4, SB-6, SB-7, and BG-2 exceeded the Non-Residential PSRGs for arsenic.
Groundwater Trichloroethylene was detected above the NC 2L Standard in a groundwater sample collected from temporary monitoring well TMW-3 on December 20, 2018 at a concentration of 6.6 µg/L. The sample also exceeded the Non-Residential Vapor Intrusion Screening Level for groundwater. 1,2-Dichloroethane was detected in a
groundwater sample collected from temporary monitoring well TMW-4 on July 27, 2019 above the NC 2L Standard at an estimated concentration of 0.55 µg/L.
Surface Water Surface water is not located on the Brownfields Property.

Sub-Slab Vapor Sub-slab soil vapor laboratory analytical results from January 2018 indicated that samples collected from SSV-1 and SSV-2 exceeded the NC Non-Residential Vapor Intrusion Screening Levels (VISLs) at concentrations of 7,700 µg/m3 and 12,000 µg/m3,
respectively. In addition, laboratory results from July 2019 indicated that SSV-1 exceeded VISLs for naphthalene at a concentration of 390 µg/m3. Indoor Air Indoor air samples were collected on December 19, 2018 and laboratory analytical results
indicated that concentrations exceeded NC DWM Non-Residential Indoor Air Screening Levels for trichloroethylene at indoor air sample locations IAS-1 (4.4 µg/m3), IAS-2 (16 µg/m3), and IAS-3 (5.0 µg/m3). In addition, laboratory analytical results indicated that heptane exceeded NC DWM Non-Residential Indoor Air Screening Levels at indoor air
sample location IAS-4 at a concentration of 500 4.4 µg/m3.

Risk Calculations Risk Calculations were performed using Excel worksheets provided the NCDEQ Brownfields Toxicologist. The environmental media samples with the highest
concentrations of contaminants were used for risk screening purposes, including TMW-3
for groundwater, SB-1 for soil, SSV-2 for sub-slab soil gas, and IAS-2 for indoor air. The risk calculations indicated the following based on available data, including the following media: groundwater, residual soil (based on confirmatory soil data), sub-slab soil vapor, and indoor air:

DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Non-Residential Soil 0.0E+00 2.2E+00 YES
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Worker Groundwater Use* 2.2E-06 5.1E-01 NO
Construction Worker Soil 0.0E+00 6.5E+00 YES
Recreator/Trespasser Soil 0.0E+00 2.0E+00 YES
VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Non-Residential Worker
Groundwater to Indoor
Air 8.9E-07 3.0E-01 NO
Soil Gas to Indoor Air 4.1E-05 1.4E+01 YES
Indoor Air 1.0E-05 1.9E+00 YES

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 exceeded for soil, groundwater to indoor air, soil gas to indoor air, and indoor air. The Prospective Developer is planning to install vapor mitigation systems in existing buildings at 1513-1515 (Tax Parcel ID Nos. 119-083-16 and 119-083-15) and 1525 (Tax
Parcel ID No. 119-083-01) S. Mint St. In addition, areas of soil contamination will be
capped with an impervious surface or clean fill material. 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 retail, office, restaurant, brewery or food production facility, entertainment, open
space, amenity space, parking, and with prior written DEQ 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
3. No disturbing soil without DEQ approval or for landscape/mowing/pruning/repair of
underground infrastructure (written notice to DEQ)/work for EMP. 4. Soil Import/Export protocol is followed. 5. Standard VI LUR 6. EMP
7. Access to Brownfields Property for environmental assessment.
8. NBP reference in deed. 9. No childcare center or school without NCDEQ approval. 10. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels for generators/equipment.
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11. Ongoing maintenance of vapor intrusion mitigation systems (VIMS), if VIMS is required.
12. Final grade soil sampling for RCRA metals, SVOCs, and VOCs will be conducted in exposed areas. 13. LURU submission January 1st