HomeMy WebLinkAbout23045_Acme Spinning Mill Decision Memo 202108031
DECISION MEMORANDUM
DATE: August 3, 2021
FROM: Bill Schmithorst
TO: BF Assessment File
RE: Acme Spinning Mill
182 Woodlawn Street and 667 Cason
Belmont, Gaston County
BF # 23045-19-036
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than office, industrial, warehousing, parking,
and with prior written DEQ approval, other commercial uses, can be made suitable for
such uses.
Introduction:
The Brownfields Property consists of four parcels (Parcel Nos. 203018, 226572, 203503,
and 3596005284) on approximately 58 acres of land located in a mixed commercial,
industrial, and residential area of Belmont, North Carolina.
Redevelopment Plans:
Belmont Industrial, LLC intends to redevelop the Brownfields Property for no uses other
than office, industrial, warehousing, parking, and with prior written DEQ approval, other
commercial uses.
Site History:
The Brownfields Property is in the process of being redeveloped with two new
warehouse buildings. Historically, the western and central portions of the property (west
of railroad tracks) were occupied by single family residences and the Acme Spinning
Mill prior to 1938 to 1986. Parkdale Mills operated a textile yarn spinning operation in
the former Acme Spinning Mill buildings from 1986 until 2002 (Parcel Nos. 203018 and
226572). All structures were removed from the western and central portions of the
property in 2006. The eastern portion of the property (east of railroad tracks) has
historically not been developed with structures (Parcel No. 226572). Portions of the
eastern portion of the property were covered in gravel in 2015 for parking for a holiday
train. The northern parcel (Parcel No. 3596005284) was primarily comprised of
undeveloped land with scattered barns and storage sheds from at least the late 1930s until
the late 1990s.
An additional parcel (Parcel No. 203503) located along Cason Street was added to the
Brownfields Property in June 2020 under a revised Brownfields Property application. The
area near the southern property boundary was historically developed with seven
residences located along Cason Street. The residences were razed in the early 2000s.
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Areas of dumping were identified in the southern, western, and northern portions of the
Brownfields Property where the land surface had been previously disturbed by
excavation and trenching. The debris consisted mostly of household refuse; however,
some paint cans, bricks, and antifreeze containers were observed. Fites Creek transects
the parcel and with flow towards the adjacent Jadco-Hughes Superfund Site property.
The Jadco-Hughes Superfund Site (USEPA Docket No. 91-31-C) property is located
adjacent to the north property boundary and topographically downgradient from the
Brownfields Property (Parcel No. 3596005284). The Jadco-Hughes site maintains a
groundwater pump and treat system downgradient of the Brownfields Property for the
recovery of VOCs in groundwater. This source of groundwater contamination was
located on the Jadco-Hughes property. In 1989, extensive exploratory test pit excavations
and assessment were completed as part of a Remedial Investigation to assess the contents
and extents of buried material on the property. Results of the exploratory assessment
indicated the presence of impacted soils, drums, reclamation waste materials, and other
miscellaneous debris (i.e. bricks, concrete, drum carcasses and lids, hoses, scrap metal,
bottles, etc.). Organic debris consisting of sparse lumber and a piece of a wooden pallet
were observed in test pits located over 300 feet north of the Acme Spinning Mill
Brownfields property. However, observations of test pits and exploratory borings within
the area of the landfill south of the former Jadco-Hughes building nearest the northern
Site boundary did not identify buried organic debris. As part of the Superfund
investigation, the responsible party installed two groundwater monitoring wells on the
northern brownfields parcel to serve as upgradient monitoring wells to the Jadco-Hughes
property; however, only one monitoring well, MW-20, remains. The most recent Jadco-
Hughes annual groundwater reports indicate that VOCs were not detected in groundwater
in upgradient located wells near the Brownfields Property. Based on the information
provided, there is no indication that the Brownfields Property is impacted by
contaminants from the Jadco-Hughes Superfund Site.
Environmental Assessments
A 10,000-gallon heating oil underground storage tank (UST) was removed from the
former Parkdale Mills site in January 1992 (NCDEQ UST Incident No. 16345). During
the removal of the UST, approximately 40 cubic yards of contaminated soils was
excavated from the UST basin. Five soil samples were collected and analyzed for total
petroleum hydrocarbons (TPH) gasoline and diesel range organics. Laboratory results
indicated that elevated levels of total petroleum hydrocarbons. In October 2007, a
Limited Site Assessment Report was conducted to further assess the former UST basin. A
monitoring well was installed in the former UST basin and soil samples and a
groundwater sample were collected during the installation of the monitoring well.
Samples were analyzed for volatile organic compounds (VOCs), semi-volatile organic
compounds (SVOCs), and MADEP volatile petroleum hydrocarbons (VPH) &
extractable petroleum hydrocarbons (EPH). Based on laboratory results, targeted
compounds were not detected in the soil and groundwater samples collected from the
former UST basin. The NCDEQ UST Program issued a No Further Action (NFA)
determination for the incident on October 30, 2007.
3
A limited soil and groundwater environmental assessment was conducted at the
Brownfields Property in October 2014 for property due diligence purposes. Four soil
samples were collected and three temporary shallow groundwater monitoring wells were
installed at the Brownfields Property. Both soil and groundwater samples were submitted
to a laboratory for the analysis of VOCs and SVOCs. Laboratory results indicated that
tetrachloroethylene and trichloroethylene were detected above North Carolina
Groundwater Quality Standards in one monitoring well (B4-GW). In addition, laboratory
results indicated that benzo(a)pyrene was detected in two soil samples (B-1 and B-2) at
concentrations above Commercial/Industrial USEPA Preliminary Soil Remediation Goals
(PSRGs).
Based on the exceedance of 2L Groundwater Standards detected in October 2014, a
Notification of an Inactive Hazardous Substance or Waste Disposal Site letter was
submitted to NCDEQ on January 15, 2015 by the property owner, Alliance Real Estate
III, Inc. The NCDEQ Inactive Hazardous Sites Branch (IHSB) assigned the reported
incident EPAID: NONCD0002983. No additional actions have been requested by IHSB.
The source area(s) for the compounds detected in groundwater were not identified and
may be from an offsite source or also potentially from historical operations.
Environmental samples, including nine soil and four soil vapor samples, were collected at
the Brownfields Property in December 2014 to provide additional data following the
October 2014 assessment. Laboratory results indicated that chlorinated VOCs, including
tetrachloroethylene, were detected in the soil gas samples at concentrations below North
Carolina Non-Residential Vapor Intrusion Screening Levels (VISLs). Laboratory results
also indicated that several SVOCs were detected above Commercial/Industrial PSRGs in
shallow soils in three of nine soil samples collected at the subject site. There were no
laboratory detections above Commercial/Industrial PSRGs in the deeper soil samples.
Additional soil and soil vapor samples were collected at the Brownfields Property in
January and February 2020 for the purpose of filling in data gaps identified from previous
assessment activities, in accordance with a DEQ-approved brownfields assessment work
plan. Additional assessment activities included collecting five soil gas samples for the
analysis of VOCs. In addition, four subsurface samples and five composite surface soil
samples were collected for the analysis of Resource Conservation and Recovery Act
(RCRA) metals. Subsurface soil samples were collected to further evaluate for potential
impacts in the areas of previously collected soil samples HHSB-2, HHSB-3, HHSB-4,
and HHSB-7. In addition, 25 shallow soil borings were advanced in the vicinity of former
residences in the northern and western portions of the Brownfields Property for collection
of five composite soil samples (COMP-1 through COMP-5) to evaluate potential impacts
from possible historical use of lead-based paints on residential structures. Laboratory
results from the analysis of soil samples indicated that Commercial/ Industrial PSRGs
were not exceeded.
Soil vapor samples activities conducted in the western portion of the Brownfields
Property in February 2020 included sampling permanent vapor monitoring point VMP-
4
and sampling temporary vapor monitoring points TVMP-1, VMP-2A, VMP-3A, and
VMP-4A. The sampling points were located around the approximate footprint of the
proposed warehouse building. Two additional soil vapor monitoring points were installed
and sampled (TVMP-1 and TVMP-2) within the footprint of the eastern proposed
warehouse building. Laboratory results for the soil vapor samples indicated that screening
levels were not exceeded.
An additional parcel (Parcel No. 203503) adjacent to the northeast of the original
Brownfields Property was added in June 2020. Prior to the parcel being added, a Phase II
Environmental Site Assessment (ESA) was conducted for property due diligence
purposes in February 2016. Assessment activities included soil, sediment, and
groundwater sampling to evaluate the potential for impacts in areas of environmental
concern identified in a December 2015 transaction screen report. Phase II ESA sampling
activities included collecting five soil samples (SB-1 through SB-5), three sediment
samples (SED-1 through SED-3) from an onsite drainage area, and one groundwater
sample from a temporary groundwater monitoring well (TMW-1). Laboratory analytical
results for soil sample SB-4 collected near the northern parcel boundary, where surface
dumping had been observed, indicated the presence of polychlorinated biphenyls (PCBs)
and metals in soil at concentrations above the laboratory method detection limits in an
area where unauthorized surface dumping was observed. The concentrations of Aroclor
1248 (13 milligrams per kilogram [mg/kg]) and Aroclor 1254 (8.9 mg/kg) were above the
Commercial/Industrial PSRGs of 0.94 mg/kg and 0.97 mg/kg, respectively. Arsenic was
detected in soil sample SB-2 (central portion of the parcel) at a concentration of 22 mg/kg
which exceeds the Industrial/Commercial PSRG of 3.0 mg/kg. No other organic or
inorganic compounds were detected in the soil samples at concentrations above the
Commercial/Industrial PSRGs. Laboratory analytical results for sediment samples
collected near the observed culvert outfalls did not indicate the presence of organic
compounds at concentrations above the Industrial/Commercial PSRGs. Groundwater
sample laboratory analytical results did not identify organic compounds at concentrations
above the laboratory method detection limits, which were below NC 2L Groundwater
Standards.
Additional environmental assessment activities were conducted in October 2020 on the
northeast parcel to fill in data gaps identified from the previous site assessment, in
accordance with a DEQ-approved work plan. Soil samples were collected in areas of
previously identified soil impacts in the northern portion of the Brownfields Property and
in the western and northern portions of the Brownfields Property. Groundwater
assessment activities were also conducted along the western (upgradient) and northern
(downgradient) property boundaries. Four delineation shallow soil samples (SB-4A
through SB-4D) were collected around previous soil sample SB-4, where PCBs were
previously detected. Three soil samples (SB-6 through SB-8) were collected on the
western portion of the parcel near the adjacent offsite carpentry and stone shop and four
soil borings (SB-9 through SB-12) were collected on the northern portion of the parcel
along the boundary of the Jadco-Hughes Superfund Site. Soil samples SB-4A through
SB-4D were analyzed for PCBs and soil samples SB-6 through SB-12 were analyzed for
VOCs, SVOCs and RCRA metals. In addition, three temporary shallow groundwater
5
monitoring wells (TMW-2 through TMW-4) were installed and sampled, and existing
monitoring well MW-20 was also sampled. TMW-2 was installed as an upgradient well;
TMW-3 was located adjacent to the offsite carpentry and stone shop, TMW-4 was
installed along the western property boundary and cross-gradient to the offsite RV service
facility located across Cason Street. Groundwater samples were submitted to a laboratory
for the analysis of VOCs, SVOCs, and RCRA metals.
In addition, two surface water and sediment samples were collected from Fites Creek at
the parcel in October 2020 and submitted to a laboratory for the analysis of VOCs,
SVOCs, and RCRA metals. The samples were collected at the upgradient and
downgradient northern parcel boundaries.
Laboratory results from the October 2020 sampling activities indicated that no PCBs
were detected in soil PCB delineation samples. In addition, no VOCs or SVOCs were
detected in soil above Industrial/Commercial PSRGs. Arsenic was the only metal
detected above PSRGs. Results from groundwater sample analyses indicated no
exceedances of 2L Groundwater Standards. Surface water sample laboratory results
indicate that 1,1-dichloroethene was detected at a low concentration in the downgradient
sample, and no other compounds were detected above North Carolina 2B Surface Water
Standards. There is no North Carolina surface water standard for1,1-dichloroethene. No
organic compounds or metals were detected in sediment above Commercial/Industrial
PSRGs. Phenanthrene was detected at a low concentration in one sediment sample;
however, there is no established standard for the compound.
Potential Receptors:
Potential receptors are: construction workers and on-site workers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property:
groundwater, soil, surface water and soil gas. DEQ relies on the following data to base its
conclusions regarding the subject property and its suitability for its intended reuse.
Soil
Laboratory analytical results from 2014 indicate the presence of SVOCs in shallow soils
at the subject site. Benzo(a)pyrene was detected above its Commercial/Industrial PSRG
of 0.29 mg/kg in shallow soil samples HHSB-2 (3.82 J mg/kg; 0-2 ft.), HHSB-3 (1.24 J
mg/kg; 0-2 ft.), and HHSB-7 (4.22 mg/kg; 2-4 ft.). Additionally, benzo(a)anthracene and
benzo(b)fluoranthene were detected at concentrations exceeding their
Commercial/Industrial PSRGs of 2.9 mg/kg in soil samples HHSB-2 (0-2 ft.) and HHSB-
7 (2-4 ft.).
Laboratory results from 2016 indicated that Aroclor 1248 was detected at a concentration
of 13 mg/kg (0-2 ft.) and Aroclor 1254 was detected at a concentration of 8.9 mg/kg (0-2
ft.) in soil sample SB-4. Results from sediment samples indicated arsenic was detected in
sample SED-1 at a concentration of 5.2 mg/kg and SED-2 at a concentration of 12 mg/kg.
6
Laboratory results from February 2020 indicated exceedances of arsenic PSRGs at
concentrations up to 6.02 mg/kg. Results indicated that no exceedances of PSRGs for
VOCs or SVOCs.
Laboratory results from the October 2020 sampling event of the northern brownfields
parcel indicated that arsenic was detected above PSRGs at concentrations up to 3.33
mg/kg. In addition, phenanthrene was detected in one sediment sampling at a
concentration of 0.232 J. There is no established screening level for the compound.
Groundwater
Tetrachloroethylene was detected in temporary groundwater monitoring well B4-GW, in
October 2014, above the NCDEQ 2L Groundwater Quality Standards at a concentration
of 250 ug/l and trichloroethylene was detected at a concentration of 5.4 ug/L. In addition,
laboratory results indicated that tetrachloroethylene and trichloroethylene exceeded Non-
Residential Groundwater to Indoor Air VISLs. The compound cis-1,2-dichloroethylene
was also detected at a concentration of 28 ug/L. There is no established standard for the
compound for Non-Residential Groundwater to Indoor Air VISLS.
Surface Water
Laboratory analytical results from October 2020 identified low levels of 1,1-
dichloroethene (up to 1.8 μg/L) and trichlorofluoromethane (up to 0.93 J μg/L) at
concentrations above laboratory method detection limits in downstream surface water
sample BF-SW-2 and its duplicate sample. Surface water standards have not been
established for 1,1-dichloroethene. The concentration of trichlorofluoromethane is below
the North Carolina In-Stream Target Value for Class C waters of 67,000 μg/L. No other
organic compounds were detected at concentrations above laboratory method detection
limits in the surface water samples collected at the Site.
Soil Vapor
Soil gas samples were collected at the Brownfields Property in December 2014 and
February 2020 and analyzed for VOCs. Laboratory results indicated that no VOCs were
detected above North Carolina Non-Residential Vapor Intrusion Screening Levels
(VISLs). However, several VOC compounds were detected that have no established
screening level, including (with highest corresponding detection level listed: 1,3-
Dichlorobenzene (46 g/m3), Cis-1,2-Dichloroethylene (2.1 g/m3) 4-Ethyltoluene (14.3
g/m3), trichlorofluoromethane (46.8 g/m3), 1,1,2-Trichlortrifluoroethane (1.8 J g/m3).
Soil vapor samples indicated that concentrations of VOCs did not increase from
December 2014 to February 2020.
Risk Calculations
Risk Calculations were performed using the NCDEQ risk calculator. The highest
concentrations detected in environmental media were used for risk screening, including
HHSB-7 (soil), worst case site wide soil gas, B-4 (groundwater), and worst case surface
water. The risk calculations indicated the following based on available data:
DIRECT CONTACT SOIL AND WATER CALCULATORS
7
Receptor Pathway Carcinogenic
Risk
Hazard
Index
Risk
exceeded?
Non-Residential Worker Soil 2.6E-06 2.0E-02 NO
Groundwater Use 9.5E-06 2.1E+00 YES
Construction Worker Soil 3.2E-07 5.3E-01 NO
Recreator/Trespasser Soil 2.6E-05 1.4E-01 NO
Surface Water 0.0E+00 6.3E-04 NO
VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic
Risk
Hazard
Index
Risk
exceeded?
Non-Residential Worker Groundwater to
Indoor Air
5.0E-06 1.3E+00 YES
Soil Gas to Indoor
Air 3.3E-06 7.4E-02 NO
Red shading LICR> 1E-04 or HI> 1.
HI = Hazard Index
Risk calculations for the Brownfields Property indicate that risk hazard indices were
exceeded for groundwater use and groundwater to indoor air. However, soil gas sample
risk calculations indicated a low risk for soil gas. Vapor mitigation is not being required.
As a precaution, the Prospective Developer is installing vapor barriers beneath the
warehouse buildings. 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. Groundwater use
at the site will be prohibited.
Additional soil vapor samples will be collected along the property boundary shared with
the northern parcel (Parcel No. 203503) and the Jadco-Hughes Superfund site to verify
there are no soil vapor impacts from the adjacent property. As of the Brownfields
Agreement signing, the prospective developer did not have plans for redevelopment for
the northern parcel.
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, office, warehousing, parking and with prior written DEQ
approval, other commercial uses
2. Complete assessment of northern Parcel No. 203503
3. No groundwater or surface water 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 protocol is followed.
6. Standard VI LUR
8
7. EMP
8. Access to Brownfields Property for environmental assessment.
9. NBP reference in deed.
10. No childcare center or school without NCDEQ approval.
11. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels
for generators/equipment.
12. Ongoing maintenance of vapor intrusion mitigation systems (VIMS), if VIMS is
required.
13. Final grade soil sampling for RCRA metals, SVOCs, and VOCs will be conducted in
exposed areas.
14. LURU submission January 1st