24050_Vernon Packaging_Decision Memo_20220509

DECISION MEMORANDUM DATE: May 9, 2022
FROM: Peter Doorn TO: BF Assessment File
RE: Vernon Packaging 848 N. Trade Street Winston-Salem, Forsyth County Brownfields Project No. 24050-20-034
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 can be made suitable for such uses. Introduction:
The Brownfields Property comprises approximately 3.99 acres located at 848 N. Trade Street in Winston-Salem and identified by Forsyth County parcel identification number (PIN) 6823-19-5678. The current Brownfields Property is a recombination of 848, 850, and 860 N. Trade Street and O W. Eighth Street originally identified by PINs 6835-19-5549, 6835-19-5455, 6835-19-5759, and 6835-19-5350, respectively. The Brownfields
Property is in a primarily light industrial and commercial area north of downtown Winston-Salem. Redevelopment Plans:
The Prospective Developer (PD), CCC Trade Street, LLC applied to the Brownfields
Program in September 2020 and received their Letter of Eligibility for the project on December 23, 2020. The PD has committed to redevelopment for high-density residential. An Environmental Management Plan (EMP) was approved on June 30, 2021 and demolition activities began in July 2021. Construction of multi-family apartments is
scheduled to begin in early 2022. The PD has indicated that a small portion of the
Brownfields Property will be deeded back to Winston-Salem for the Ninth Street Extension upon completion of redevelopment. Site History:
The property historically consisted of residential properties from at least 1895 to
approximately 1940 when it was redeveloped with warehouses for light industrial use for the tobacco industry. Between approximately 1964 and 1980, the property gradually transitioned from tobacco warehouses to its current use as a commercial produce distribution center.

Prior to redevelopment, the Brownfields Property housed a 10,676 square foot (sq. ft.) warehouse at 848 N. Trade Street which was most recently occupied by Triad Produce. A 19,016 sq. ft. warehouse/office complex consisting of three connected buildings located
at 860 N. Trade Street was most recently occupied by Vernon Packaging. The northern gravel parking area of 850 N. Trade Street (Combs Produce) and a small area of paved parking at 0 W. Eighth Street (also Combs Produce) were purchased by the PD, but most
of the purchased property will be deeded to the City of Winston Salem for an access street (Ninth Street Extension) after redevelopment is completed. Gravel parking covered the northern and southern portions of the Brownfields Property and demolition began under the approved EMP in summer 2021 as discussed above.
Potential Receptors:
Potential receptors include residents, on-site workers, construction workers, and visitors. A Brownfields receptor survey was completed, and no water supply wells were identified within 1,500 ft of the Brownfields Property. Summary of Environmental Reports

Report By Date Summary of Contaminants
Soil Vapor Sampling Report - Vernon Packaging
Terracon June 23, 2021 Soil Vapor: Chloroform exceeds the Residential Soil Gas VISL. Constituents below the Residential Soil Gas VISLs in multiple samples
include acetone, dichlorofluoromethane, tetra-chloroethylene, and toluene. Using max values, HI = 0.072 and Carcinogenic Risk = 2.5x10-5
Brownfields Assessment Report - Vernon Packaging
Terracon May 13, 2021 Soil: Arsenic detections exceed Residential Preliminary Soil Remediation Goals (PSRGs). All detected volatile organic compounds (VOCs)
and semi volatile organic compounds (SVOCs)
are below established Residential PSRGs. Groundwater: Chromium exceeds the 2L Standard in two samples, but data indicates it is not hexavalent chromium. All detected VOCs and
SVOCs are below 2L Standards. Chloroform
exceeds the Residential Groundwater Vapor Intrusion Screening Level (VISL).
Phase 1 Environmental Site Assessment – N. Trade Street
Properties
Terracon May 15, 2020 ESA revealed no evidence of on-site Recognized Environmental Conditions (RECs) but noted historical uses of off-site properties as potential RECs to the east and southeast (upgradient)
included a former service station and former dry
cleaners. The ESA also noted that no releases at the adjacent upgradient properties have been documented.
Contaminated Media: 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 During the Brownfields assessment activities in March 2021, soil samples were collected from nine locations and analyzed for VOCs, SVOCs, and RCRA Metals and hexavalent
chromium. Samples from B-05 and B-06 located near the compressor and transformer were also analyzed for polychlorinated biphenyls (PCBs). The PCB results were below the laboratory reporting limits. Of the nine samples, two (B-04 and B-8) contained detections of select VOCs. While
estimated concentrations of chloro-dibromomethane, 1,2-dibromomethane, 1,4-dichlorobenzene, and xylene were detected, all VOC detections were well below Residential PSRGs. Of the nine samples collected, detections of SVOCs were found in one sample (B-8) and
were comprised of poly-nuclear aromatic hydrocarbons (PAHs). All PAHs detected were below the Residential PSRGs, except for benzo(g,h,i)perylene and phenanthrene which have no established Residential PSRG. Of the nine samples analyzed for metals, arsenic was detected above the Residential
PSRG of 0.68 mg/kg in two samples (B-8 at 1.12J mg/kg and B-10 at 0.975J mg/kg). The laboratory reporting limits for arsenic and hexavalent chromium exceed the Residential PSRGs. Arsenic concentrations are consistent and are commonly found naturally occurring in North Carolina soils. Hexavalent chromium is analyzed to facilitate risk evaluations and is not expected to be found at the property. For these reasons the
elevated reporting limits are acceptable for the intent analyzed.

Groundwater During the Brownfields assessment activities in March 2021, groundwater was collected from five newly installed monitoring wells on the property. Wells were located to evaluate impacts from potential on-site and off-site sources of contamination. The depth to groundwater ranged from approximately 37 to 46 feet below ground surface and is
generally flowing to the northwest. Groundwater samples were analyzed for VOCs, SVOCs, and RCRA metals. All detections in groundwater were below the 2L Groundwater Quality Standards except for chromium. Chromium exceeded the 2L Standard of 10 µg/L in MW-3 (14.3 µg/L) and in
MW-4 (104 µg/L) however the field notes from the sampling event observe that the MW-4 sample was collected with a bailer due to slow recharge rates and was turbid, which could contribute to the elevated chromium concentration. Further, while hexavalent chromium was analyzed outside of hold time, it was not detected in MW-4. As noted above, hexavalent chromium was detected but determined to not be a risk factor in site
soil. Other metals detected in groundwater include mercury (in one sample at an estimated concentration) and barium (in each sample, and at concentrations ranging from 132 to 369 µg/L). The VOCs chloroform, trans-1,2-dichloroethene, MTBE, and the SVOC
naphthalene were also detected at estimated concentrations that were well below the 2L Standards. The concentrations of chloroform detected in MW-2 (1.96 J µg/L), MW-4 (0.869 J µg/L), and MW-5 (1.28 J µg/l) were below the 2L Standard, but exceed the Residential Vapor Intrusion Screening Level (VISL) of 0.81 µg/L.
Surface Water and Sediment No surface water or sediment features are located on the Brownfields Property.
Soil Vapor During Brownfields assessment activities in June 2021, soil vapor was collected from eight soil vapor monitoring points (SVP-1 through SVP-8) located within the footprints of the proposed residential structures. Soil vapor borings were installed to depths of 8-10 ft bgs and samples were collected and analyzed for TO-15. Several VOCs were detected
at each sampling point, and all constituents detected were below their established Residential Soil Gas VISLs except for chloroform. In four of the soil vapor monitoring points, chloroform exceeded the Residential Soil Gas VISL of 4.1 µg/m3 (ranging from 4.12 to 97.3 µg/m3). Ethanol, 4-ethyl-toluene and trichlorofluoromethane were also detected but have no established Residential VISLs.
Other constituents detected in nearly all of the soil vapor samples include acetone, dichlorofluoromethane, tetrachloroethylene (PCE), and toluene. Notably, PCE was not detected in soil or groundwater but was detected in soil vapor ranging from 1.54 to 12.4 µg/m3 (below the Residential Soil Gas VISL of 280 µg/m3).

Methane The boring logs from the May 2020 Geotechnical Engineering Report documented fill material at up to 8 feet bgs, and noted the presence of concrete, asphalt, and/or wood fragments in four of the 21 geotechnical borings on the property. As a precaution, during
the soil vapor sampling in June 2021, each soil vapor sample was also analyzed for methane by EPA Method 8015M. No methane was detected at any of the sampling points.
Indoor Air
Indoor air at the Brownfields Property was not collected because all buildings will be demolished prior to construction of the apartment buildings. Risk Calculations
The DEQ Risk Calculator was developed to evaluate the risk of multiple contaminants
and multiple exposure routes associated with contaminated environmental media at a site. The risk evaluation procedures, equations, and default parameters used to create the calculator follow the current USEPA risk assessment guidance. The DEQ Risk Calculator dated June 2021 was used to calculate risk based on data available for media
including soil, groundwater, and soil vapor.
Risk Calculation Table 1 displays the risk calculated using the maximum sitewide concentrations for each media (soil, groundwater, and soil vapor).
Risk Calculation Table 1
Risk for Individual Pathways Output Form 1A
Version Date: June 2021
Basis: May 2021 EPA RSL Table
Site ID: 24050-20-034
Exposure Unit ID: Soil, Groundwater, and Soil Gas - max sitewide concentrations
Receptor Pathway Carcinogenic
Risk Hazard Index Risk exceeded?
Soil 5.0E-06 7.0E-02 NO
Groundwater Use*1.1E-05 2.0E-01 NO
Soil 5.5E-07 5.0E-03 NO
Groundwater Use*2.7E-06 3.8E-02 NO
Construction Worker Soil 3.3E-07 6.9E-02 NO
Soil 2.8E-06 3.9E-02 NO
Surface Water*NC NC NC
Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air 2.5E-06 9.4E-03 NO
Soil Gas to Indoor Air 2.5E-05 7.2E-02 NO
Indoor Air NC NC NC
Groundwater to Indoor Air 5.7E-07 2.2E-03 NO
Soil Gas to Indoor Air 1.9E-06 5.7E-03 NO
Indoor Air NC NC NC
Pathway Source
Source Soil NC
Source Groundwater NC
Source Soil NC
Source Groundwater NC
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
Surface Water Exceedence of 2B at Receptor?
Exceedence of 2B at Receptor?
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
CONTAMINANT MIGRATION CALCULATORS
Target Receptor Concentrations Exceeded?
Groundwater Exceedence of 2L at Receptor?
Exceedence of 2L at Receptor?
Based on the detections of metals and organic compounds (primarily PAHs) in soil, restrictions regarding soil will be imposed at the site. A groundwater use restriction will be included because of the detection of chromium in groundwater above the 2L Standard.
The indoor air risk for residents is calculated to be 2.5x10-5 for carcinogens and a hazard index (HI) of 0.072 for non-carcinogens using the maximum soil vapor concentrations from across the site. Based on the results of the assessment activities and the risk calculations, no vapor mitigation system is required. However, a minimum of two rounds of post-construction sub-slab vapor monitoring will be necessary to ensure that indoor air
risks do not increase following completion of construction activities on the property. The June 30, 2021 DEQ-approved EMP will need to be followed to safely direct the handling and disposal of potentially contaminated materials, building demolition, soil grading, or excavation activities begin. Prior to occupying the Brownfields Property, per
the terms of the EMP, final grade soil sampling will be required for areas not covered by a minimum of 2 feet of demonstratable clean fill, landscaping soil, or asphalt, concrete, or other impervious surface.
Required Land Use Restrictions: a. No use other than high-density residential and associated parking, drives, and walkways without DEQ approval
b. No high-density residential units may be sold individually c. Environmental Management Plan (EMP) required for redevelopment d. Annual redevelopment summary report required e. Demolition must comply with state & local requirements f. No use of groundwater or surface water
g. Final grade sampling required prior to occupancy h. No soil disturbance without DEQ approval or EMP i. No soil import/export without DEQ approval j. Standard VI language k. Post-construction soil vapor monitoring required
l. DEQ shall not be denied access m. Any required wells or vapor points must be maintained n. Deed or other instrument conveying an interest shall contain the Notice o. No use of contaminants known to be present on the BF Property p. Annual LURU to DEQ
Based on the site-specific data provided to the Brownfield program, the site is suitable for the approved uses only if the agreed upon land use restrictions in the BFA are abided by.