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HomeMy WebLinkAbout20080_True Textiles_Decision Memo_202009221 True Textiles/20080-16-086/20200416 DECISION MEMORANDUM DATE: September 22, 2020 FROM: Jordan Thompson TO: BF Assessment File RE: True Textiles 304 East Main Street Elkin, Surry County BF # 20080-16-086 Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than industrial, office, retail, open space, recreation, and with prior written DEQ approval, other commercial uses, can be made suitable for such uses. A final planned layout for the Brownfields Property has not been outlined at this time. Introduction: JW Industrial Group, LLC is a North Carolina limited liability company whose business address is 2130 N Tryon Street, Charlotte, North Carolina 28206. The business representative is James Dellinger, Jr. This agreement pertains to 52.1 acres of land located at 304 E Main Street in Elkin, Surry County consisting of a portion of a larger parcel located north of East Main Street (Surry County Parcel No. 495115641270) and three parcels located south of East Main Street (Surry County Parcel Nos. 495115525807, 495115521832, and 495115534150. The Brownfields Property is bisected east to west by East Main Street and railroad tracks. Current uses of the Brownfields Property consist of warehousing and office operations. On-site contamination of soil, groundwater, soil gas, and indoor air are present. Soil is impacted with metals, semi-volatile organic compounds (SVOCs), and petroleum compounds above Industrial/Commercial Preliminary Soil Remediation Goals (PSRGs); groundwater is impacted with volatile organic compounds (VOCs), SVOCs, and metals above NC DEQ 15A NCAC 2L Groundwater Standards (2L Standards) and Non- Residential Vapor Intrusion Screening Levels (VISL); soil vapor is impacted with one VOC (trichloroethylene) above non-residential Vapor Intrusion Screening Levels (VISLs); and indoor air is impacted with VOCs above non-residential Indoor Air Screening Levels (IASLs). Redevelopment Plans: The PD intends to reuse the existing site buildings for commercial businesses, a brewery or winery, a performing art center/museum, and warehousing operations. Site History: 2 True Textiles/20080-16-086/20200416 a. In the early 1890s the Brownfields Property, in addition to nearby parcels, was developed with a textile mill. Textile operations expanded on the Brownfields Property and nearby properties from the mid-1910s through the 1980s, including the construction of additional site buildings. On-site operations included yarn production, weaving, nylon yarn extrusion, textile dyeing, and fabric coating. Occupants of the Brownfields Property have included CMI Industries; Chatham; Interface Fabrics Group; Westpoint Home; and True Textiles. In the mid-2000s textile operations were reduced to consist of fabric coating, washing/drying of fabrics, and nylon yarn extrusion. Operations were further reduced through 2019 and the most recent operator, True Textiles, is in the process of vacating the site. The following is a brief description of the former uses of the Site buildings, which are outlined on the plat component of the Notice of Brownfields Property: b. Buildings 1 through 16 were historically utilized for washing/drying operations, chemical storage, maintenance areas, and shipping/receiving. Material dyeing and bulk chemical mixing operations were located in the basement areas of certain buildings. c. Buildings 17 and 18 were historically utilized as offices, a recreation facility, a bank, and a printing operation from at least the early 1940s through the late 1990s. The former printing operations utilized acids, heavy metals, and solvents. These buildings are currently occupied by The Foothills Art Council for arts and crafts classes. d. Buildings 19 and 23 through 26 were historically utilized for: training (Building 24), warping (Buildings 19 and 23), a machine and maintenance shop (ground floor of Building 23), warehousing, and general office activities. These processes utilized cutting oils, lubrication oils, and a solvent based parts washer. e. Building 20 was historically utilized as a training center and retreat, the area surrounding this building was vacant land and process water storage. f. Building 22 was historically utilized for general office and blending activities for site tenants. g. Buildings 27 through 30 were previously utilized as boiler houses. Ancillary to the boiler houses were an alum water treatment area, settling pond, and associated storage areas. Building 27, which was used for alum water treatment, is located on the Brownfields Property, and Buildings 28-30 are located on the parent parcel but not on the Brownfields Property, which is only a portion of the original mill. Historically, water was treated with alum and soda ash to operate a natural gas boiler that provided steam and heat to site buildings. Coal and fuel oil fired boilers were utilized until 2009, when the boilers were transitioned to natural gas. Bulk quantities of coal were historically stored on the parent parcel but not the Brownfields Property based on delineation activities. h. Buildings 21 and 31 through 38 were historically utilized for nylon yarn extrusion operations, a dye house within Buildings 21 and 31, shipping/receiving, storage, and garneting operations. Garneting consists of reducing or shredding textiles to a fibrous material for reuse. Building 38 is currently leased to a candle distributor for storage of glass jars. i. Surrounding parcels associated with former site operations consisted of coal ash ponds and storage areas to the south and east of the Brownfields Property. The southern parent parcel also contains the flood plain and fly ash basins previously associated with the Brownfields Property. The fly ash basins were utilized to collect ash from the on- 3 True Textiles/20080-16-086/20200416 site coal fired boilers. The flood plain area was utilized to dispose of mill waste such as bulk textiles, construction/metal debris, etc. The north adjacent property was previously utilized for textile operations associated with the Brownfields Property. The north adjacent property is an NCDEQ Inactive Hazardous Sites Branch (IHSB) Superfund Site under the oversight of the Registered Environmental Consultant (REC) program (DEQ IHSB #NONCD0002987). j. Elkin Partner Holdings LLC, an affiliate entity of the Prospective Developer, currently owns the Brownfields Property. Site operations since the Prospective Developer and affiliate entities have owned the property included continued lease to True Textiles for limited textile operations (2017-2019), demolition of certain site buildings, and additional assessment as requested by DEQ. On-site operations currently consist of storage of glass candle jars, arts and crafts classes offer through the Foothills Arts Council, and decommissioning of former True Textiles operations in select buildings, as noted above. In the early 1890s the Brownfields Property, in addition to nearby parcels, was developed with a textile mill. Textile operations expanded on the Brownfields Property and nearby properties from the mid-1910s through the 1980s, including the construction of additional site buildings. On-site operations included yarn production, weaving, nylon yarn extrusion, textile dyeing, and fabric coating. Occupants of the Brownfields Property have included Chatham (late 1890s-1988 and 1988-1992 operating as Chatham Manufacturing Company owned by Northern Feather); CMI Industries (1992-2000); Interface Fabrics Group (2000-2013); Westpoint Home, a subsidiary of CMI Industries (2008); and True Textiles (2008- 2016/17). In the mid-2000s textile operations were reduced to consist of fabric coating, washing/drying of fabrics, and nylon yarn extrusion. Operations were further reduced through 2019 and the most recent operator, True Textiles, is in the process of vacating the site. Environmental Overview a. As discussed above, operations on the Brownfields Property formerly included textile manufacturing and dyeing. Excess process water from the dyeing operations was discharged via a piping network to the south adjacent property. The floor drains consist of a variety of building materials including concrete, PVC, terra cotta, and carbon steel. The non-sanitary piping network is currently out of use but remains connected to the south adjacent property. Sanitary drains within the buildings are connected to the municipal sewer system. From the mid-1960s to the late 2010s, the piping network discharged to an off-site wastewater treatment plant (WWTP) located at 175 Fabric Lane to the southeast of the Brownfields Property. Prior to that time, wastewater was discharged to the south adjacent property for eventual discharge to the Yadkin River. The dye pits and drainage piping network has previously been identified as a source of potential contamination for the Brownfields Property that has been investigated prior to and during Brownfields Assessment activities. b. Additional environmental concerns previously noted on the Brownfields Property included a former printing operation within the basement of an office building, former machine and maintenance shops, a former chemical mixing room, underground storage tank (USTs) systems, aboveground storage tank (AST) systems, and hydraulic elevators within certain site buildings. These environmental concerns have been investigated on-site since the early 1990s. Generally, environmental assessment activities 4 True Textiles/20080-16-086/20200416 have identified the presence of soil, groundwater, soil vapor, and indoor air impacts of VOCs, SVOCs, and metals above NCDEQ Industrial/Commercial Action Levels. c. A former AST area was located in the western portion of the Site building and contained three ASTs. The contents of the ASTs were varsol, acetic acid, and alum slurry. This area also contained a buried steel railroad tank car that acted as a varsol UST, latex storage ASTs within immediately adjacent site buildings, and a lined latex drying bed. The ASTs were removed in 2001, and the UST was removed in approximately 1990. In 2001, approximately 400 cubic yards of impacted soils were excavated from the area of the former UST. Confirmation soil sampling following impacted soil removal indicated that petroleum impacts were removed to below 40mg/kg in the excavated area. Historic groundwater sampling events in the area of the former AST and UST were found to contain VOCs and SVOCs above 2L Standards. Free-phase varsol product was removed from two wells in the AST area briefly in the late 1990s that has since ceased. d. The most recent soil evaluation for the Brownfields Property was completed in June 2017 as part of Brownfields Assessment activities on the property as well as in the remainder of the former textile operation footprint. Soil borings were installed in areas of environmental concern as previously identified from former site operations. Following sample collection, impacts of SVOCs and metals were identified above Industrial/Commercial PSRGs. e. The most recent groundwater evaluation for the Brownfields Property was completed in June 2017 as part of Brownfields Assessment activities on the property as well as in the remainder of the former textile operation footprint. Monitoring wells sampled on the Brownfields Property were analyzed for VOCs, SVOCs, and Metals. Impacts of VOCs, SVOCs, and metals were identified in groundwater above 2L Standards. Compared to former environmental sampling reports, groundwater concentrations of impacts have decreased over time. Groundwater flow has been documented to generally be to the southeast toward the Yadkin River. f. The most recent vapor intrusion evaluation for the Brownfields Property was completed in June 2016 as part of Brownfields Assessment activities on the property as well as in the remainder of the former textile operation footprint. The vapor intrusion evaluation consisted of sampling indoor air as well as sub-slab soil gas samples via summa canisters as well as high volume sampling (HVS). Sample locations were identified based on former use of the Site buildings and previously identified areas of concern. Generally, the vapor intrusion evaluation samples were collected in the former warehouse areas (Buildings 1 and 3); the former dye houses (Buildings 7, 8, 9, 32, and 34); and in the former office building downgradient of former industrial operations (Buildings 17 and 18). Sub- slab sample results identified impacts of VOCs above non-residential Soil Gas Screening Levels (SGSLs) in buildings 5 and 8. Indoor air sample results also identified impacts of VOCs above non-residential SGSLs in buildings 8 and 17. g. The textile operations also previously utilized coal fired boilers and disposed of coal ash into two holding basins and within the flood plain of the south adjacent property. These areas are noted but are not a part of this Brownfields Agreement. h. The Brownfields Property has numerous historic Underground Storage Tanks (USTs) listed for the facility number 00-0-000000876. Previous environmental reports indicated that up to 44 USTs were historically present on the Brownfields Property and adjacent properties. Most USTs were removed prior to December 1989 with closure 5 True Textiles/20080-16-086/20200416 documentation unavailable. A former Varsol UST was located between Buildings 7 and 8 and was assessed and remediated from the early 1990s through the early 2000s. Per reports in 2001, at that time, all known USTs throughout the Brownfields Property have been removed. However, based on the lengthy industrial use of the property, there is the potential for unknown, or “orphan” USTs to remain. The potential remaining USTs would likely contain oils, soaps, and petroleum fuels. i. Multiple ASTs for use in on-site operations including: clean process water, fuel oil, used oil, process water treatment ASTs, alum, liquid nitrogen, process chemicals, universal waste, and lubricant oils. As site operations cease and the site buildings are removed, ASTs and any identified USTs shall be removed or abandoned in place per the land use restrictions set forth in this agreement. j. The Brownfields Property previously maintained a Title V Air Quality permit identified as permit # 01315R28 that was most recently issued in 2013 and expired in 2018. A current permit is not available for the Brownfields Property. The most recent inspection of the facility was completed in 2009, and no violations were noted at that time. k. The former operating entity of the Brownfields Property previously maintained a NPDES permit for discharge to the Yadkin River associated with the former textile operations. The most recent permit became effective on January 1, 2014 and expired on December 31, 2018. Activities covered under the NPDES permit were located off-site to the southeast of the Brownfields Property and operations included treatment of process water associated with operations on the Brownfields Property. l. IHSB file correspondence was reviewed for the Brownfields Property between 1992 and 2019. Of note, a ranking system summary sheet dated December 20, 2004 indicated that in April 2004 PCBs were detected in material collected after a transformer overheated and spilled. Soil sampling conducted by the site occupant (WestPoint Sevens) detected elevated concentrations of PCBs in soils in the spill area. No evidence of soil removal was identified in a review of available documents. Review of files from IHSB indicate that the release may have occurred on the north adjacent property. However, detailed site drawings are not available. m. A receptor survey was completed in March 2018 for the Brownfields Property that identified residences, daycares, and basements within 1,000 feet of the Brownfields Property. No public or private water supply wells were identified and the nearest surface water body was identified as a reservoir and on-site tributary followed by the Yadkin River to the south of the Brownfields Property. Potential Receptors: Potential receptors are: construction workers, on-site workers, visitors, and trespassers. Contaminated Media: DEQ has evaluated data collected from the following media at the subject property: soil, groundwater, 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 Soil has been sampled on the property as part of additional assessment events since the early 1990s related to on-site releases. Soil impacts consist of VOCs, SVOCs, metals, and 6 True Textiles/20080-16-086/20200416 petroleum related impacts, which are generally shallow (approx. 6ft below ground surface), with the exception of petroleum related impacts, which are located from one to 16ft below ground surface. The most recent soil evaluation was completed in June 2017 at the request of the Brownfields Program. The risk calculator results outlined below are based on the highest concentrations detected in 2017 north of E Main Street and south of E Main Street. Note that the risk calculator does not calculate TPH-GRO/DRO and thus the impacts of such from older sampling events are not included in the risk calculations. Groundwater Groundwater data is available for the Brownfields Property from the early 1990s. Due to the historical use of the property for textile manufacturing and dyeing and former releases, a permanent groundwater well network is in place. A Notice of Violation was issued for the property in April 1992 following receipt of an environmental site investigation report that documented on-site impacts. Since that time, groundwater monitoring has been conducted on-site and the property is listed under the DEQ IHSB program. The groundwater network was sampled by the property owners through 2015 and submitted to DEQ’s IHSB Section. Groundwater impacts consist of VOCs, SVOCs, and metals above 2L Standards and certain VOC impacts above Non-Residential Vapor Intrusion Screening Levels (VISLs). The most recent groundwater sampling event was completed at the request of the Brownfields Program in 2016. In general, based on the historical groundwater data available, concentrations of groundwater impacts appear to be declining. Groundwater flow is to the south toward the Yadkin River, which is located approximately 500 ft south of the southern-most parcel boundary. Based on conversations with Collin Day, Supervisor with the NC DEQ IHSB, it is not anticipated that the monitoring wells will be needed by their program. Surface Water Surface water is not located on the Brownfields Property. The nearest adjacent surface water bodies consist of a man made retention pond located south of the southern warehouse building, a stream originating to the south of the Brownfields Property, and the Yadkin River, located approximately 500ft south of the Brownfields Property. Soil Gas Based on the current plan to reuse existing site buildings soil gas samples were not collected on the Brownfields Property. Sub-Slab Vapor Sub-slab and high volume samples were collected beneath certain site buildings in 2016 at the request of the Brownfields Program. Sample results identified the presence of Trichloroethylene above non-residential VISLs within the northwestern site buildings 5 and 8 where dyeing operations formerly occurred. 7 True Textiles/20080-16-086/20200416 Risk calculations were performed per building for soil gas samples. No exceedances to non-residential hazard indices or lifetime incremental cancer risks were identified. Indoor Air Indoor air samples were collected in certain site buildings in 2016 at the request of the Brownfields Program. Sample locations were based on targeted occupied buildings. One round of 24 hour summa canister samples, and one round of quantitative passive samples for 11-17 days were collected. Sample results identified impacts of chloroform and naphthalene within site buildings 8 and 17 (naphthalene only) above non-residential Indoor Air Screening Levels (IASLs). Risk calculations were performed per building for indoor air samples. No exceedances to non-residential hazard indices or lifetime incremental cancer risks were identified. Risk Calculations Risk calculations were performed using the most recent DEQ Risk Calculator https://deq.nc.gov/permits-rules/risk-based-remediation/risk-evaluation-resources. For the purposes of site evaluation, groundwater was evaluated for the highest concentration detected on-site in the most recent sampling event; soil was evaluated at the highest concentrations detected during the most recent sampling event north of East Main Street and south of East Main Street; and sub-slab soil gas and indoor air were evaluated per building. 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 Residential Industrial / Commercial LICR HI LICR HI Groundwater Exposure Entire Site 2016 (Data available for North of E Main Street only) 2.8 E-04 7.7 3.5 E-05 1.2 Groundwater to Indoor Air 3.4 E-05 0.23 4.5 E-06 0.055 Soil Vapor Building 5 3.7 E-5 5.8 2.4 E06 0.46 Building 8 2.4 E-05 3.6 1.5 E-06 0.29 Building 17 8.9 E-06 0.21 6.8 E-07 0.016 Building 18 7.1 E-06 0.18 5.4 E-07 0.014 Indoor Air Building 1 2.3 E-06 0.044 5.3 E-07 0.01 Building 3 3.1 E-06 0.067 7.0 E-07 0.016 Building 7 5.9 E-06 0.061 1.3 E-06 0.015 Building 8 1.6 E-04 2.7 3.8 E-05 0.63 Building 9 2.9 E-06 0.41 6.7 E-07 0.097 Building 17 3.2 E-05 0.57 7.3 E-06 0.14 8 True Textiles/20080-16-086/20200416 Building 18 3.8 E-06 0.082 8.6 E-07 0.02 Building 32 3.8 E-05 0.38 8.6 E-06 0.091 Building 34 6.6 E-06 0.099 1.5 E-06 0.024 Soil Exposure North of E Main Street 2.6 E-04 5.4 1.7 E-05 0.38 Soil Exposure – Construction Worker 3.3 E-06 8.8 3.3 E-06 8.8 Soil Exposure South of E Main Street 1.2 E-05 3.9 2.6 E-06 0.26 Soil Exposure – Construction Worker 1.4 E-06 5.8 1.4 E-06 5.8 Red shading LICR> 1E-04 or HI> 1. LICR = Lifetime Incremental Cancer Risk HI = Hazard Index Based on the planned reuse of the Brownfields Property for industrial, office, retail and with prior written DEQ approval, commercial uses and the above risk calculations, it appears that the site can be made suitable for the intended reuse with the following land use restrictions. 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. - No childcare/adult care without prior DEQ approval - No groundwater use - Soil disturbance must have prior written DEQ approval - Final grade sampling required for future redevelopment - No ground contact sports without prior DEQ approval - Soil import/export must be approved - Existing and future building vapor intrusion evaluation requirement - No slab disturbance without DEQ approval or prior notice - On-going indoor air samples for continued occupancy - Surface water may only be used for storm water collection and reuse - Building demolition shall be in compliance with legal requirements - Known USTs/ASTs shall be removed - EMP requirement for redevelopment - Redevelopment summary report required annually during redevelopment - DEQ and its representatives shall be allowed access - Deed conveyance of the Notice of Brownfields Property - Known contaminants may not be used on-site - Monitoring wells shall be abandoned - Annual LURU submittal PROPERTY MANAGEMENT ISSUES 9 True Textiles/20080-16-086/20200416 - Note need for final grade sampling post any future redevelopment. - There is the potential for many orphaned USTs to be present on-site, EMPs will need to be robust in covering that subject. - Indoor air sampling required prior to occupancy of site buildings not already assessed. On-going sample collection for at least two additional cycles required for previously assessed buildings.