24025 Crayton Printing Decision Memorandum 20210730

DECISION MEMORANDUM DATE: July 30, 2021 FROM: Bill Schmithorst

TO: BF Assessment File RE: Crayton Printing 2301, 2321, 2327 Distribution Street and 2300, 2302, 2304, 2306
Dunavant Street
Charlotte, Mecklenburg County BF # 24025-20-060 Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than high density residential, office, parking,
retail, and with prior written DEQ approval commercial uses, can be made suitable for such uses. Introduction:
The Brownfields Property consists of four contiguous parcels of land that total
approximately 2.82 acres. The northern parcel (2301 Distribution Street) is developed with an approximate10,700-sq ft office/warehouse building that is currently unoccupied. The western parcel is developed with an approximate 12,000-sq ft office/warehouse building consisting of a vacant tenant space (2321A Distribution Street) and Crayton
Printing (2321B and 2321C Distribution Street). The southwestern parcel (2327
Distribution Street) is developed with an approximate 14,500-sq ft office/warehouse building currently occupied by Timely Filter Supply. The eastern parcel on Dunavant St. is developed with a multi-tenant commercial building consisting of four tenant spaces. Functional Fit currently occupies 2300 Dunavant Street, and the remaining tenant spaces
(2302, 2304, and 2306 Dunavant Street) are currently unoccupied.
Redevelopment Plans: The PD plans to develop the property for no uses other than high density residential, office, parking, retail, and with prior written DEQ approval commercial uses.
Redevelopment plans include constructing an urban residential (apartment) development,
potentially including mixed use elements, such as retail. Existing buildings will be demolished. Site History:
The Brownfields Property consisted of undeveloped land with a creek present onsite as
early as the 1930s. The land remained undeveloped until the mid-1950s when the property was cleared and the land and creek were graded level. By 1965, rail spurs were developed in the northern and central portions of the Brownfields Property. The current northern and western commercial buildings were constructed in the late 1960s, and the current eastern building was developed by the mid-1970s. The Brownfields Property was
utilized by various commercial occupants from the late 1960s until present. The western
parcel building (2321 Distribution Street) was utilized by a printing facility that manufactured printing plates in the late 1980s and a letter press and printing facility in the early 2000s. The buildings are currently unoccupied or are being vacated except for an electrician located in the northern property building and Timely Filter Supply in the
southwestern property building (2327 Distribution Street).
The Brownfields Property (2321 Distribution Street) was historically occupied by various printing and printing plate manufacturing companies, including Carolina Platemakers in the late 1980s and Crayton Printing from the early 2000s to the present. A small screen-
printing operation also occupied 2304 Dunavant St in the late 1970s to mid-1980s. Some
historic printing companies used solvent-based cleaners for printing equipment. Due to the lack of documentation for historic on-site printing processes and high potential for such processes to use hazardous substances, historical property use for printing operations was identified as a recognized environmental condition in the Phase I Report
dated April 3, 2020.
Sifco Selective Plating occupied the Brownfields Property (2302 Dunavant Street) in the early 1990s and generated hazardous waste. A September 13, 1994 letter from Sifco notified DEQ that the facility was closed, and remaining hazardous waste drums were
transported to a treatment, storage, and disposal (TSD) facility on September 1, 1994.
Based on the potential for undocumented release of plating chemicals and lack of specific information on the facility operations, the plating operation was identified as a potential environmental concern in the Phase I Report (April 2020).
The Dunavant Street Brownfields property (Brownfields Project Number 19038-15-060)
is located adjacent to the north and topographically upgradient of the subject Site. According to the Notice of Brownfields Property document dated February 11, 2016, the volatile organic compounds (VOCs) trichloroethylene (TCE), tetrachloroethylene (PCE), benzene, cis-1,2-dichloroethene (cis-1,2-DCE), methyl tert-butyl ether (MTBE), and
naphthalene were reported in groundwater samples collected on the Dunavant Street
Brownfields property at concentrations that exceed the NCAC 15A 2L Groundwater Quality Standards (NC 2L Standards) and DWM Vapor Intrusion Screening Levels (VISLs).
Environmental Assessments
In September 2020, brownfields assessment was conducted at the Brownfields Property in accordance with a DEQ-approved work plan to evaluate subsurface conditions for potential impacts associated with historical on-Site and nearby off-site operations. Assessment activities included collecting 10 soil samples, installing and sampling four
temporary groundwater monitoring wells, collecting seven sub-slab soil vapor samples,
and collecting five soil gas samples. In addition, receptor survey activities were completed to obtain information about land use, water supply, basements, underground utilities, drains, and surface water bodies in the vicinity of the Brownfields Property. Soil samples were collected at a depth of approximately 0-2 feet below ground surface and
were analyzed by a laboratory for VOCs, semi-volatile organic compounds (SVOCs),
Resource Conservation and Recovery Act (RCRA) metals, and hexavalent chromium.
Laboratory results indicated that arsenic and hexavalent chromium were detected above NC Inactive Hazardous Sites Branch Residential Preliminary Soil Remediation Goals (PSRGs); however, no VOCs or SVOCs were detected above PSRGs.
Groundwater samples collected in September 2020 were analyzed for VOCs, SVOCs and
RCRA metals. Laboratory results indicated VOCs were detected at concentrations above NC 2L Groundwater Quality Standards, including trichloroethylene (TCE) and tetrachloroethylene (PCE). In addition, VOCs were detected in sub-slab and soil gas samples at concentrations above NC Residential VISLs. Metals were not detected above
NC 2L Groundwater Quality Standards.
A review of the proposed redevelopment plans for the proposed apartment building and parking deck indicated that shallow groundwater may be encountered during redevelopment activities. Therefore, five additional groundwater monitoring wells were
installed in November 2020 in accordance with a DEQ-approved work plan, to evaluate
concentrations of contaminants in shallow groundwater. Groundwater samples were analyzed for VOCs, SVOCs and RCRA metals. Results indicated that several VOCs were detected above NC 2L Groundwater Quality Standards and Groundwater Residential VISLs.

Potential Receptors: A receptor survey was completed in September 2020. No water supply wells were identified within 1,500 ft. of the Brownfields Property. Potential receptors are construction workers, on-site workers, future residences, and visitors.

Contaminated Media: DEQ has evaluated data collected from the following media at the subject property: soil, groundwater, sub-slab soil vapor, 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 indicate that several SVOCs were detected in soil samples, collected in September 2020, above Residential PSRGs, including Acenapthalene (0.0029 J mg/kg), Benzo(a)pyrene (up to 0.327 mg/kg), benzo(g,h,i)perylene (up to 0.361 J
mg/kg), and phenanthrene (up to 0.835 mg/kg). Arsenic (up to 2.91 mg/kg) was detected
in each soil sample above the Residential PSRG of 0.68 mg/kg. Hexavalent chromium was detected in two soil samples at concentrations up to 0.621 J mg/kg which slightly exceeds the Residential PSRG of 0.31 mg/kg.
Groundwater
Laboratory analytical results from samples collected in September 2020 indicate that select VOCs were detected at concentrations above the laboratory method detection limits in the groundwater samples collected at the Brownfields Property. The VOC trichloroethylene (TCE) was detected in groundwater sample TMW-1 (25 μg/L) and
TMW-3 (6.8 μg/L) at concentrations above the NC 2L Standard and Residential
Groundwater VISLs of 3 μg/L and 1 μg/L, respectively. Vinyl chloride (1.7 μg/L) and
tetrachloroethylene (11.6 μg/L) were also detected at concentrations that exceed the 2L Standard and the Residential VISL in groundwater sample TMW-3. No other SVOCs or VOCs were detected in the groundwater samples above the 2L Standard. Chromium (up to 17.7 μg/L) was detected in upgradient groundwater sample TMW-2 at a concentration
that exceeds the 2L Standard of 10 μg/L.
Laboratory analysis of additional groundwater samples collected in November 2020 indicated that vinyl chloride exceeded the 2L Standard at MW-4 at a concentration of 3.1 μg/L. In addition, laboratory results indicated that several VOC compounds exceeded
Residential Groundwater VISLs. The VOC cis-1,2-dichloroethene was detected in
monitoring well MW-4 at a concentration of 14 μg/L. Tetrachloroethylene was detected at MW-3 and MW-5 at concentrations of 1.8 μg/L and 2.5 μg/L, respectively. Vinyl chloride was also detected at MW-4 at a concentration of 3.1 μg/L.
Surface Water
Surface water is not present at the site. Soil Vapor Laboratory results from samples collected in September 2020 indicated that petroleum-
related compounds benzene (up to 32 μg/m3) and ethylbenzene (up to 230 μg/m3) were
detected at concentrations exceeding the Residential VISLs of 12 μg/m3 and 37 μg/m3, respectively, in soil gas samples SG-1 through SG-4. Xylenes were detected in soil gas sample SG-3 (830 μg/m3) at a concentration that exceeds the Residential VISL of 700 μg/m3.

Sub-Slab Vapor A concentration of PCE (1,100 μg/m3) was detected in sub-slab vapor sample SS-2, collected in September 2020, at a concentration exceeding the Residential VISL of 280 μg/m3. Naphthalene was detected in sub-slab vapor sample SS-3 (15 μg/m3) at a
concentration above the Residential VISL of 2.8 μg/m3. Dichlorodifluoromethane was
detected at a concentration exceeding the Residential VISL of 700 μg/m3 in sub-slab vapor sample SS-7 (1200 μg/m3). Ethanol was detected in several samples at a concentration up to 510 μg/m3.
Indoor Air
No indoor air samples were collected. The existing buildings will be demolished and are not currently in use. Risk Calculations
Risk Calculations were performed using the NC DEQ Risk Calculator. The risk
calculations indicated the following based on available data, including the following media: groundwater (TMW-1), soil (SB-4), and sub-slab soil gas samples (site-wide worst case):
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Resident Soil 7.7E-06 9.2E-02 NO
Groundwater Use* 5.1E-05 9.0E+00 YES
Non-Residential
Worker
Soil 9.3E-07 7.4E-03 NO
Groundwater
Use* 8.5E-06 2.0E+00 YES
Construction Worker Soil 1.4E-07 1.1E-01 NO
Recreator/Trespasser Soil NC NC NC
VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Resident
Groundwater
to Indoor Air 2.1E-05 4.8E+00 YES
Soil Gas to
Indoor Air 1.9E-05 2.0E+00 YES
Red shading LICR> 1E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk HI = Hazard Index Based on the results from the risk evaluation indicating an elevated risk from VOCs in soil gas, DEQ-approved vapor mitigation measures will be required in future buildings
constructed on the Brownfields Property. The PD is planning to install active vapor mitigation consisting of sub-slab depressurization. Pre-occupancy indoor air sampling and sub-slab pressure monitoring will be required. Additional mitigation system monitoring requirements will be included in the Vapor Intrusion Mitigation System Plan. An Environmental Management Plan (EMP), approved by DEQ, will be required before
the start of soil grading or excavation activities to prevent exposure to site workers and future residents from unacceptable levels of contaminants, and to manage the safe handling and disposal of potentially contaminated materials during construction. In addition, final grade soil sampling will be required prior to occupying the Brownfields Property. Depth to groundwater is shallow across the property and may be encountered
during construction. Required Land Use Restrictions: A summary of the land use restrictions (LURs) is provided below.
1. No use other than high density residential, retail, 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 within the EMP.
4. Soil Import/Export must be approved by DEQ.
5. DEQ approved EMP
6. Access to Brownfields Property for environmental assessment. 7. Standard vapor intrusion LUR 8. NBP reference in deed. 9. No contaminants (included in Ex. 2 to the BFA) on property except for de minimis
amounts, fluid in vehicles, fuels for generators/equipment.
10. No childcare or schools permitted without DEQ approval. 11. Final grade soil sampling for RCRA metals, SVOCs, and VOCs will be conducted in exposed areas. 12. LURU submission January 1st.

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.
Property Management Unit
• Vapor mitigation is being installed.
• Pre-occupancy VI sampling is required.
• Final grade soil sampling required.