18010_Hamilton Beach II_DM_20170615

DECISION MEMORANDUM

DATE: June 15, 2016

FROM: Samuel P. Watson

TO: BF Assessment File

RE: Hamilton Beach II
234 Springs Road
Washington, Beaufort County
18010-14-007

Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than industrial purposes, can be made
suitable for such uses.

Introduction:
The Brownfields Property comprises one parcel totaling 28.557 acres located within the
city limits of Washington, Beaufort County, but is not contiguous with the primary
boundaries of the city. The site is surrounded by undeveloped woodlands, agricultural
land, commercial/industrial properties and a few rural residential properties. The site is
the former location of the Hamilton Beach facility which manufactured small household
appliances. The property contains one large industrial, slab on grade building consisting
of 391,646 square feet, one small metal storage shed, a small shelter structure and a guard
shack. Various underground and above ground storage tanks, containing diesel fuel,
gasoline, waste oil and chlorinated solvents were historically located along the southern
part of the building near the southeast corner. All of these tanks have been abandoned or
removed. The facility is currently utilized by idX Impressions, LLC which assembles
display cases, shelving units, counter units and other fixtures used in retail stores. The
property was purchased by 234 Springs Rd., LLC, the Prospective Developer, in April
2014, after submitting a Brownfields Property Application, dated March 13, 2014, to the
Program. The Prospective Developer currently owns the property.

Redevelopment Plans:
The Prospective Developer intends to expand its fixture assembly operations by investing
approximately $1,800,000 in equipment and building improvements.

Site History:
The site was developed in 1966 by Hamilton Beach but ownership of the property was
retained by the City of Washington. Hamilton Beach operated the manufacturing facility
until 1998. No manufacturing of parts or components has occurred at the site since
Hamilton Beach ceased activities in 1998 although Hamilton Beach continued to occupy
a portion of the facility for administrative purposes and to operate a call center. until
2008. The facility was occupied by Impressions Marketing Group, Inc. starting in 2001
and was utilized for the assembly of display cases, shelving units, counter units and other
fixtures used in retail stores. idX Impressions, LLC purchased Impressions Marketing
Group and continued operations in 2013. The facility is currently only utilized to
assemble parts and components that are shipped to the facility.

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:
groundwater, surface water, soil, sub-slab 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
Soil at the site was sampled for VOCs, SVOCs and metals using EPA Methods 8260B,
8270C, 6010B and 7471A. Samples were collected at levels from 0-2 feet and either 3-5
feet or 2-4 feet below ground surface (bgs) from each location. Results from sample
location F18B, collected at 3-5 feet bgs contained 1,2-Dichloroethane at 8.75 mg/Kg and
Trichloroethene at 6.58 mg/Kg. The Industrial PSRG for 1,2-Dichloroethane and
Trichloroethene are 2 mg/Kg and 3.8 mg/Kg, respectively. Arsenic was detected in
sample F17A, from 0-2 feet, at a concentration of 30.6 mg/Kg. The industrial PSRG for
arsenic is 3 mg/Kg. Both F17A and F18B are located along the southern portion of the
southeast corner of the building in the area of known release and where the USTs and
ASTs historically used by the site were located.

Groundwater
Groundwater at the site has been sampled for VOCs, SVOCs and metals using EPA
Methods 8260B, 8270C, 6010B and 7470A since 1998. Concentrations of chlorinated
volatile organic compounds are elevated. The latest round of groundwater sampling
(2015) indicated the presence of 1,1,1-Trichloroethane (1,1,1-TCA), 1,1-Dichloroethane
(1,1-DCA), 1,1-Dichloroethene (11-DCE), 1,2-Dichloroethane (1,2-DCA), Benzene, cis-
1,2-Dichloroethene (cis-1,2-DCE), Tetrachloroethene (PCE), Trichloroethene (TCE) and
Vinyl Chloride (VC) at the site exceeding their respective NC 2L Standards. 1,1,1-TCA
was detected at two locations above standards ranging from 1,660 micrograms per liter
(ug/L) to 325 ug/L. 1,1-DCA was detected in nine samples above 2L standards ranging
from 7.4 ug/L to 3470 ug/L. 1,1-DCE was detected in one sample (NW-K-6) at a
concentration of 2,220 ug/L. 1,2-DCA was detected in six wells at concentrations
ranging from 2 ug/L to 66.2 ug/L. Benzene was detected in two wells, NW-G-12 and
MW-227, at concentrations of 14.7 ug/L and 2.4 ug/L, respectively. Cis-1,2-DCE was
detected in four wells at concentrations ranging from 82.2 ug/L to 14,000 ug/L. TCE was
detected in one well, MW-ERH2, at a concentration of 348 ug/L. TCE was detected in
four wells at concentrations ranging from 17.8 ug/L to 251 ug/L and VC was detected in
nine wells at concentrations ranging from 1.1 ug/L to 5,020 ug/L. It is worthy to note
that the pervasiveness of the PCE daughter products, particularly VC, demonstrates that
natural attenuation, the approved corrective action for the site, is actively occurring at the
site.

Surface Water
Surface water at the site consists of a drainage ditch that runs along the eastern and
southern boundary of the site. Surface water samples were analyzed for VOCs, SVOCs,
and metals using EPA Methods 8260B, 8270B, 6010B and 7471A. Samples collected
from this surface water contained TCE at 3 ug/L, exceeding the 2B Standard of 2.5 ug/L.
1,1-DCA, Chloroethane and cis-1,2-DCE were also detected in samples of the surface
water above method detection limits. There are no established surface water standards
for these compounds.

Soil Vapor
Soil Vapor samples were not collected at the site due to the preference to collect sub-slab
vapor samples.

Sub-Slab Vapor
Sub-Slab Vapor samples were collected at four locations beneath the building in
September 2008. Two of the samples were collected near the southeast corner of the
building where the underlying shallow groundwater is known to be impacted. A third
location was collected near the central portion of the building that overlies the deeper
groundwater contamination. A fourth sample was collected from the central portion of
the building where no known contaminants underlie the building. The samples were
analyzed for VOCs using EPA Method TO-15. Only samples Sample 01 and Sample 02,
collected from the southeast corner area of the building, contained compounds exceeding
the IHSB Non-Residential Screening Limits. Both Sample 01 and Sample 02 contained
1,1-DCA, 1,1-DCE, TCE and VC at concentrations above screening limits. The
maximum concentrations detected in either of the samples were 43,000 micrograms per
cubic meter (g/m3) of 1,1-DCA in Sample 02, 51,000 g/m3 of 1,1-DCE in Sample 01,
1,700 g/m3 of TCE in Sample 01, and 34,000 g/m3 of VC in Sample 01.

Indoor Air
Indoor air samples were collected from the interior of the rooms at the same general areas
as the sub-slab samples in September 2008, with the exception of the location of indoor
air sample Sample 02, which was located closer to the central portion of the building than
the sub-slab Sample 02 location, but still within the area overlying the shallow
groundwater contamination. These samples were analyzed for VOCs using EPA Method
TO-15. A single sample, HBB Washington-Grab, was collected in May 2008 and located
in the central portion of the building. This sample was analyzed for VOCs using EPA
Method TO-15. Results from Sample 02 indicate the presence of 1,2-DCA at a
concentration of 0.51 g/m3, exceeding the Non-Residential Screening Limit of 0.472
g/m3. Results for Sample 03 indicated the presence of TCE at a concentration of 4
g/m3, exceeding the Screening Limit of 1.75 g/m3. TCE in this sample does not
however exceed the NC DHHS Action Level for TCE of 8.8 g/m3. Sample HBB
Washington-Grab contained concentrations of Toluene, Ethylbenzene, m,p-Xylene, and
o-Xylene at concentrations exceeding the Screening Levels. Toluene was detected at
9,600 g/m3 above the screening level for toluene of 4,380 g/m3. Ethylbenzene was
detected at 410 g/m3, exceeding the screening level of 4.91 g/m3. m,p-Xylene and o-
Xylene were detected at 1,000 g/m3 and 130 g/m3, respectively, exceeding the
screening level for both of these compounds, which is 87.6 g/m3.

Risk Calculations
Risk calculations were performed using Excel worksheets provided by Sandy Mort,
NCDEQ Brownfields Toxicologist. For the purposes of looking at the site spatially, the
VI risk from Groundwater was evaluated by considering all samples together, and by
dividing the data into shallow groundwater samples and deep groundwater samples. The
soil, sub-slab VI risk, and indoor air VI risk were all evaluated considering all sample
locations together. The risk calculations indicated the following based on available data,
including the following media: groundwater, residual soil (based on confirmatory soil
data), soil gas, indoor air, and fill soil samples:

Medium Site Area
Non-Residential
LICR HI
Soil Entire Site 1.61E-05 6.90E-01
Sub-Slab Vapor Entire Site 1.80E-04 3.35E+00
Indoor Air Entire Site 3.50E-06 4.90E-01
VISL-GW Entire Site 2.20E-03 2.89E-01
VISL-GW Shallow 2.20E-03 2.89E+01
VISL-GW Deep 1.90E-05 2.82E-01
Red shading LICR> 1E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index

These calculations indicate the following:
• The LICR for soil, indoor air and VISL-GW for the deep aquifer are within an
acceptable risk range of 1E-06 to 1E-04 for non-residential settings.
• Hazard indices for soil, indoor air and VISL-GW for the deep aquifer are below
the hazard index of 1 for non-residential settings.
• The LICR for sub-slab soil gas and VISL-GW for the shallow aquifer exceed the
acceptable risk range of 1E-06 to 1E-04 for non-residential settings.
• Hazard indices for sub-slab soil gas and VISL-GW for the shallow aquifer exceed
the hazard index of 1 for non-residential settings.

With regards to groundwater risk, the site and surrounding area are connected to the
municipal water supply. Therefore, risk of ingestion of groundwater is not considered an
issue for this site. However, a restriction on exposure to and use of groundwater have
been placed on the site as a precautionary measure.

With regards to surface water, the use of surface water at the site is prohibited.

With regard to soil risk, only 1,2-DCA, TCE and arsenic were detected in the soil at
concentrations exceeding their respective Industrial Screening Levels. However, the risk
evaluation indicates that these concentrations do not exceed the acceptable LICR range or
the HI. Therefore, the risk from soil is not considered an issue for the site and no
restrictions have been placed on the disturbance of soil at the site.

With respect to vapor intrusion risks, the risk evaluation indicates that the risks from sub
slab soil gas and the shallow aquifer GW contamination exceed the acceptable risk range
for LICR and exceed the HI of 1. However, the indoor air sampling and risk evaluation
of the indoor air results indicate that there is no risk associated with the vapor intrusion
within the existing building. As such, no requirements to retrofit the building with any
vapor mitigation systems is being required. However, a restriction is being placed on any
new construction that will ensure that the new building is either not located near the
contaminated plume, provides data showing no VI issues exist, or requires a VI
mitigation system be installed.

Required Land Use Restrictions:
Land use restrictions will include the standard use, groundwater, surface water, known
contaminants, DEQ access, and LURU reporting. The standard restriction on
construction and occupation of new buildings on the site without proof that the building
is not at risk of vapor intrusion has also been placed on the property to ensure that any
future construction placed within the bounds of the shallow groundwater plume will not
be at risk. The property is being restricted to commercial/industrial use. No residential
use is permitted.

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.