WentworthFurniture_Decision Memo_09.18.2020

DECISION MEMORANDUM
DATE: March 13, 2020
FROM: Cody Cannon
TO: Brownfields Assessment File
RE: Wentworth Furniture
1808 Emmanuel Church Road
Conover, North Carolina
BF # 21006-17-18
Based on the following information, it has been determined that the above referenced
property, whose intended use is for no uses other than industrial, warehousing, retail,
parking, institutional, and with prior written DEQ approval other commercial uses, is or
can be made suitable for these uses.
Introduction:
The Brownfields Property comprises once parcel totaling 4.38 acres and is developed
with a warehouse building totaling approximately 54,519 square feet which includes
newly renovated office space along the northern edge of the building. An approximate
1,600 square foot storage building with unconditioned indoor air space is also present on
the property.
The Brownfields Property is bordered to the north by Emmanuel Church Road followed
by a warehousing facility for Southern Furniture Co. to the northeast and a warehousing
facility for Colonial Distribution to the northwest; to the east by rail road tracks and a
warehousing facility for Ideal Italia Furniture; to the south by a metal fabrication facility
called Conover Metal Products, Inc.; and to the west by a motorcycle dealership called
Michael's Cycles and More.
Redevelopment Plans:
The prospective developer (PD) has begun redevelopment of the Brownfields Property by
renovating the office space in the front of the building and establishing a furniture pallet
manufacturing operation in a portion of the warehouse. Another section of the warehouse
is currently being leased to a custom cabinet manufacturing operation. Additional
redevelopment plans include interior and exterior building renovations.
Site History:
According to a review of historical aerial photographs and city directories, the
Brownfields Property was comprised of vacant farm land until at least 1964, when the
land was cleared for development. By 1976, the current warehouse building was present
on the property and the current shed was present by 1984. The Brownfields Property has
historically been used for furniture manufacturing by various entities. City directories
state the property was in use by D6cor Originals, Inc. from at least 1989 to 2005,

Wentworth Furniture, Inc. from at least 2010 to 2015, and Abbey Lane Cabinetry in
2015. Decor Originals, Inc. was listed as a Resource Conservation and Recovery Act
(RCRA) small quantity generator of hazardous waste. Wentworth Furniture, Inc. was
listed as a RCRA conditionally exempt small quantity generator of hazardous waste.
Both companies reportedly produced waste including chlorinated solvents. The PD
purchased the property on November 3, 2016 from Bank of the Ozarks, which acquired
the property though a court ordered sale to satisfy the default of a Deed of Trust on the
property. The PD has since used the property for pallet manufacturing and, by a tenant,
for custom cabinetry operations.
Environmental Assessment History
A Phase II Environmental Site Assessment report was completed by EnviroAssessments
on June 13, 2016. Soil, groundwater, and geophysical assessments were conducted to
investigate Recognized Environmental Conditions (RECs) identified in an EDR Radius
Map Report dated April 25, 2016. Identified RECs included two former underground
storage tanks installed on June 17, 1975. One of the USTs reportedly contained 5,000-
gallons of kerosene while the second UST contained up to 2,000-gallons of an unknown
liquid. No evidence of USTs was observed from ground penetrating radar (GPR) and
electromagnetic (EM) surveys in the areas of the former UST canopies located near the
northeastern corner of the warehouse building and on the south side of the shed building.
Four soil samples were collected at a depth of 10 feet below land surface (ft BLS) from
each former UST basin. Additionally, two temporary monitoring wells were installed on
either side of each former UST basin. Total Petroleum Hydrocarbons (TPH) were
detected in two of the eight soil samples but below the DEQ UST Section Action Levels.
Concentrations of volatile organic compounds (VOCs) including Methylene Chloride,
Tetrachloroethylene (PCE), and Trichloroethylene (TCE) were detected above the North
Carolina Administrative Code Title 15A Subchapter 2L groundwater standards (2L) in
the two monitoring wells (WS-3 and WS-4) in the vicinity of the former UST on the
south side of the storage shed building. TCE concentrations in monitoring wells WS-3
and WS-4 exceeded the DEQ Non -Residential Vapor Intrusion Screening Level (VISL)
at 341 µg/L and 434 µg/L respectively. TCE was also detected above the 2L
groundwater standard and Non -Residential VISL in monitoring well WS-1 located near
the northeastern corner of the warehouse building at a concentration of 6.2 µg/L.
In response to a Request for Additional Assessment Letter issued by the DEQ
Brownfields Program on December 27, 2018, Blue Ridge Engineering, PLLC (Blue
Ridge) completed a Summary of Analytical Results from Groundwater, Soil, and Vapor
Sampling report on July 31, 2019 (Revised on December 31, 2019). Groundwater and
soil samples were collected from three locations including the locations of former
monitoring wells WS-2 and WS-4 and the open area along the southern portion of the
warehouse building. Additionally, seven sub -slab soil gas samples were collected from
locations throughout the warehousing and office areas of the building. TCE was detected
above the 2L groundwater standard and Non -Residential VISL in monitoring wells W-6
(former WS-4) and W-7. Concentrations of selenium, lead, chromium, and barium
exceeded 2L groundwater standards in monitoring well W-6 (former WS-4). No

concentrations of VOCs, Semi -volatile organic compounds (SVOCs), or RCRA Metals
exceeded DEQ Industrial/Commercial Preliminary Soil Remediation Goals (PSRGs) in
the soil samples collected. Several VOCs were detected in the seven sub -slab soil gas
samples collected. However, sub -slab sample V-4, located in the central portion of the
warehouse building, contained a concentration of TCE (337 µg/ru) in exceedance of the
Non -Residential VISL.
Due to the risk associated with the sub -slab soil gas sample results, DEQ Brownfields
requested that an indoor air investigation be conducted at the property. Blue Ridge
completed an Indoor Air Assessment Report on January 20, 2020. Indoor air samples
were collected from five sample locations across the warehousing and office portions of
the building. Several VOCs were detected in each of the samples but only Ethylbenzene
was detected at a concentration exceeding the DEQ Non -Residential Indoor Air
Screening Level (IASL) in sample A-4 located in the southeastern portion of the
warehouse in the cabinet manufacturing area. TCE was detected in indoor air samples A-
2A and A-4 but below the Non -Residential IASL at 1.1 µg/m3 and 0.97 µg/m3
respectively.
Potential Receptors:
Potential receptors are: on -site workers, construction workers, and trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property:
groundwater, soil, soil -gas, 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
Data from soil samples collected as part of the 2019 Brownfields assessment was utilized
for risk assessment for non-residential soil exposure. No detections of VOCs, SVOCs, or
RCRA Metals exceeded DEQ Industrial/Commercial PSRGs. The associated
carcinogenic and non -carcinogenic risk values calculated using the DEQ Risk Calculator
(December 2019) do not exceed thresholds for non-residential workers or construction
workers.
Groundwater
Data from the three groundwater monitoring wells collected as part of the 2019
Brownfields assessment was utilized to assess direct groundwater exposure risk and
groundwater to indoor air risk for future non-residential workers at the property.
Concentrations of barium, chromium, lead, selenium, and TCE exceeded the 2L
groundwater standards. Concentrations of TCE exceeded the Non -Residential VISL. The
DEQ Risk Calculator (December 2019) was used to calculate the direct exposure risk and
groundwater to indoor air risk on a site wide worst case scenario basis. The non -
carcinogenic risk threshold for direct groundwater exposure for non-residential workers

was exceeded at 18. The non -carcinogenic risk threshold for groundwater to indoor air
for non-residential workers was exceeded at 11.
Sub -Slab Soil Gas
Data from the seven sub -slab soil gas samples collected as part of the 2019 Brownfields
assessment was used to assess the vapor intrusion risk from sub -slab soil gas to non-
residential workers. Trichloroethylene exceeded the Non -Residential VISL at a
concentration of 337 µg/m3 in sample V-4. The DEQ Risk Calculator (December 2019) was
used to calculate the sub -slab soil gas to indoor air risk for non-residential workers on a site wide
worst case scenario basis. Neither the carcinogenic nor the non -carcinogenic hazard index
exceeds the DEQ risk threshold.
Indoor Air
Data from the five indoor air samples collected as part of the 2019 indoor air assessment was
used to assess the indoor air risk for non-residential workers at the Brownfields property. Several
VOCs were detected in all samples but only ethylbenzene was detected at a concentration of
exceeding the non-residential IASL in sample A-4. Neither the carcinogenic nor the non -
carcinogenic hazard index exceeds the DEQ risk threshold.
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, soil, sub -slab soil gas, and
indoor air.
Medium
Site Area
Non -Residential
Worker
LICR
HI
Groundwater
Exposure
Entire Site
8.6E-05
18
Groundwater to
Indoor Air
Entire Site
3.1E-05
11
Soil Exposure
Entire Site
5.4E-07
4.3E-02
Sub -Slab Soil Gas
Entire Site
3.9E-06
4.2E-01
Indoor Air
Entire Site
2.6E-06
2.8E-01
Medium
Site Area
Construction Worker
LICR
HI
Soil Exposure
Entire Site
8.8E-08
1.8E-01
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index
Bold and Red shading LICR> 1E-04 or HI> 1.
Due to the results of the risk calculators, restrictions are in place regarding groundwater,
soil gas, and indoor exposure 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 for industrial, warehousing, retail, parking, institutional, and with
prior DEQ approval other commercial uses.
2. No use as a childcare of adult care facility.
3. No groundwater use
4. 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 requires prior DEQ approval.
6. Standard Vapor Intrusion Language: No occupancy of new buildings until DEQ says
indoor air is safe/no VI issues/VI protection installed.
7. Quarterly indoor air monitoring of existing building until a minimum of 6
sampling events demonstrate that VOC concentrations are either stable or
decreasing and the calculated risk does not exceed the DEQ threshold for non-
residential workers; the PD can submit a request to DEQ to reduce the frequency or
cease sampling events.
8. Environmental Management Plan
9. DEQ access to Brownfields Property.
10. Notice of Brownfields Property reference in deed.
11. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels
for generators/equipment
12. Abandon any existing monitoring wells.
13. Land Use Restriction Update submission by January 31 st each year.

Fl ure 1—Site Location Ma Source: USGS 7.5 Minute Topographic Map Newton, North Carolina
g p Quadrangle 1993
9111 Monroe Road, Suite 175 Site Name: EMJA Properties LLC
Charlotte, North Carolina 28270
T 704.846.8853 F 704.846.3271 1% 1808 Emmanuel Church Road
enviroassessments.com i Conover, North Carolina
EA Project Number: 16-10477.2
enviroassessments BB&T Project Number: OMS-211401 — Report #1

SUSPECT FORMER
UST BASIN #1 \
0
/ CANOPY
� ftftI
SITE BUILDING
IS-6-10 (ND)
s-1,2-DCE: 4.6
ethyl Chlor: 5.6
CE: 7.2
'E: 434
LEGEND
0 Soil sample location
0 Soil and groundwater sample location
Soil results are reported in milligrams per kilogram (mg/kg)
Groundwater results are reported in micrograms per liter (ug/L)
ND = Non -Detect (below laboratory reporting limits)
IS-4-10
TPH-DRO: ND
TPH-GRO: 6.9
MEK: 5.2
Methvl Chlor: 3.0
S-3-10 (ND)
/ F—E:6.2
D)
STORAGE
BUILDING S-8-10 (ND)
S-5-10 (ND)
• WS-3
• Methyl Chlor: 5.7
•••~ PCE: 5.1
7-10 ITCE: 341
H-DRO: 11.4
H-GRO: ND r SUSPECT FORMER UST BASIN #2
TPH: Total Petroleum Hydrocarbons
DRO: Diesel Range Organics
GRO: Gasoline Range Organics
PCE: Tetrachloroethene
TCE: Trichloroethene
Cis-1,2-DCE: Cis-1,2-Dichloroethene
MEK: 2-Butanone
Methyl Chlor: Methylene Chloride
BOLD results exceed the NC Action Level of 10 mg/kgmg/kg for TPH or NCAC 2L Groundwater Quality Standards
Figure 3 — Sample Detail Map Scale: 1 inch = 30 Feet N r
9111 Monroe Road, Suite 175 Site Name: EMJA Properties LLC
Charlotte, North Carolina 28270
T704.846.8853 F704.846.3271 1808 Emmanuel Church Road
enviroassessments.com Conover, North Carolina
EA Project Number: 16-10477.2
enviroassessments BB&T Project Number: OMS-211401 — Report #1

94P7 `q+s
ca.vaMe
Subject Property
6.26 Acres
5/8" Imn Fro!
Fouts
Conover Metal Products, AC
3K 982 PG 695
Exhibit
SAMPLE LOCATION MAP
Summary of Analytical Results from
Groundwater, Soil, and Vapor Sampling Activities
BF 21006-17-18
Page 10 of 12
Wonial Investors, LLC /
6K 3145 PG 1997 /
f
N64'98'W"W J
]R'ReLar //
Southern Furniture Company of
Co hover, INC
9K 1300 PG 650
wFeer un.
��Oty
4FY
Serxr ManM1ola -� `
/
PaMTMC �-�
IIgMPde./ ftallro lTrads Vndxkallmad
+�
'_
eF'r
FFYC-I.
RYP•)
.
eld
Alp
4 ,10
F�
r+
.vN'.
i
ad

Exhibit
GROUNDWATER FLOW POTENTIOMETRIC MAP
e Plus of Conover, LLC
iK 3271 PG 1424
PS 48 PG M
Tract 1
Summary of Analytical Results from
Groundwater, Soil, and Vapor Sampling Activities
BF 21006-17-18
Page 12 of 12
T Gas Line
(End LWanan unknown)
Southe
Pavement
4�
R-
Tree Lire —
(typ.l
Rat CPeGl� Fr
S
v�

Exhibit
VAPOR SAMPLE LOCATION FLOOR PLAN
Summary of Analytical Results from
Groundwater, Soil, and Vapor Sampling Activities
BF 21006-17-18
Page 11 of 12